AGRO-INPUTS PROJECT Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP) 2013

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1 AGRO-INPUTS PROJECT Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP) 2013 November 28, 2013 Prepared for review by the United States Agency for International Development under USAID Cooperative Agreement No. AID- 388-A , Bangladesh Agro-Inputs Project, implemented by CNFA USAID/Bangladesh AIP PERSUAP i This report is made possible through the generous support of the American people through the United States Agency for International Development (USAID). The contents are the responsibility of CNFA and do not necessarily reflect the views of USAID or the United States Government.

2 2013 USAID/Bangladesh AIP PERSUAP ii

3 Amendment to Initial Environmental Examination (IEE) for the Agro-Inputs Project (AIP) in Bangladesh PERSUAP Incorporating Communications and Training Materials A. IEE (#1) PROGRAM/ACTIVITY DATA: COUNTRY CODE 388 Program Objective Program Areas: Project Country Economic Growth (EG) 4.5 Agriculture 4.6 Private Sector Capacity Agro-Inputs Project in Bangladesh (AIP) Bangladesh/ANE AIP Funding Begin: FY 2011 AIP Funding End: FY 2015 LOP Amount: $262,395,209 AIP Sub-Activity Amount: $14,328,062 Original IEE Prepared By: IEE Amendment Prepared By: Nathan Martinez and Alamgir Hossain Alan Schroeder, PhD, MBA, Environmental Assessment Professional Date of Original IEE: January 11, 2012 Current Date of IEE Amendment: November 28, 2013 Other PERSUAPs Referenced and Covered Under IEE: 2013 Bangladesh PROSHAR (Program for Strengthening Households' Access to Resources) PERSUAP IEE Amendment (Y/N): Y ENVIRONMENTAL ACTIONS RECOMMENDED IN ORIGINAL IEE: (Place X where applicable) Categorical Exclusion: X Negative Determination w/ Conditions: X Positive Determination: X Deferral: 2013 USAID/Bangladesh AIP PERSUAP iii

4 B. BACKGROUND The purpose of this IEE Amendment is to present and approve the 2013 USAID/Bangladesh Agricultural Inputs Project (AIP) Pesticide Evaluation Report (PER) and Safer Use and Action Plan (SUAP) that was recommended to be done in the IEE listed above. The Implementing Partner (IP) CNFA s AIP has presented for analysis the Bangladesh Department of Agricultural Extension Plant Protection Wing(DAE-PPW) a list of pesticides that are registered and available in the parts of Bangladesh where AIP works. To understand the agriculture pesticide sales and use sector in Bangladesh, and risks inherent in the special cropping systems AIP will serve, the PERSUAP team visited and interviewed upazilla-level Extension Officers, as well as randomly chosen Agro-Dealer Shops and Typical Farmers. Ultimately, the information contained in this PERSUAP report will inform AIP and USAID/Bangladesh on pesticides (by the common denominator of pesticide Active Ingredient - AI) that can and cannot be procured and/or used with USAID and project resources. But, more than that, it will also focus on state-of-the-art best practices for pesticide Agro-Dealer Shops and Farmer s Fields, as well as IPM/pesticide knowledge, organized into each crop-pest combination found in project areas, and that the Agro-Dealers and Extension Service agents should be able to teach to farmer clients. The next step for AIP, then, is to put this information to use in the SUAP and project-produced training materials. And, beyond that, the IPM information in this PERSUAP report should be turned into state-of-the-art Crop and Pest Management Plans (CMPs, PMPs). These guide everyone involved in pest prevention and control with a solid field management tool. This 2013 USAID/Bangladesh AIP PERSUAP addresses needs raised in the original IEE (Annex 18) as well as those further clarified in the recommended follow-on Environmental Due Diligence Report (EDDR) and PERSUAP Scope of Work (SOW). Due to the inherent risk concerns presented by pesticides, USAID s environmental regulations require that all programs that include assistance for the promotion (sales of pesticides by retailers), procurement (directly or through financial instruments used by retailers) or use (such as on demonstration or demo plots) of pesticides must assess risks associated with this assistance following the Pesticide Procedures described in 22 CFR (Regulation) Regulation 216, or Reg. 216, parts (b)(1)(i) (a through l) assert and require that at least 12 factors must be addressed. These 12 factors are, since 2000, normally examined in a technical analysis document called a Pesticide Evaluation Report (PER), through which risk mitigation or safe use recommendations are made. Then these PER risk mitigation recommendations are put to action using a business-plan styled Safer Use Action Plan (SUAP). The SUAP will contain the pesticide risk mitigation recommendations from the PER, along with sector-recognized best practices, with the name of a responsible project staff to implement each, the date each will start and be completed by, and importantly with a sign-off with someone with power, like the AIP Chief of Party (COP) for staff buy-in and to ensure that recommendations, along with resources to implement them, are seriously tackled and completed. These very same recommendations/sector best practices can then be put into a USAID-required Environmental Mitigation and Monitoring Plan (EMMP), which beyond the SUAP includes columns for AIP and USAID to be able to track monitoring of risk mitigation and see who is responsible for monitoring it. The EMMP also identifies potential environmental concerns associated with specific activities, but outlines specific measures to be used to mitigate the potential concern (risk). Also, the EMMP should establish a working schedule for the mitigation 2013 USAID/Bangladesh AIP PERSUAP iv

5 measures, establish procedures on how it will be monitored, detailing any sampling and analysis procedures needed to adequately monitor the mitigation measure (best management practice). The PERSUAP is a stand-alone document but is also an integral component of the EMMP. The Agro-Inputs Project in Bangladesh The objective of the AIP is to improve the supply of quality agricultural inputs through input retailers. Its central effort is the creation of a sustainable Agro Input Retailers Network (AIRN) through Intervention 1. Interventions 2-4 are designed to work in concert and holistically with Intervention 1. AIP s four interventions are: 1) Establishment of an Agro-Input Retailers Network; 2) Development of Market Information Systems; 3) Setting Quality Control Standards for inputs and lessening Regulatory Constraints; and 4) Strengthening Local Organizations towards direct implementation. The creation of AIRN will leverage 3,000 Government of Bangladesh (GOB)-registered agroinputs retailers in 20 Feed-the-Future (FTF) districts, to supply quality, unadulterated agricultural inputs to over 1 million farmers. Amongst the 3,000 retailers, 300 will be womenowned, and who will be established by matching grants and other technical assistance. All retailers will be supported to make informed business decisions for efficient, ethical, and sciencebased operations. Retailers will first join AIRN, and then gain the Astha (Bengali: trust ) Seal of Quality after going through basic training and agreeing to a business code of ethics. Market information systems will create and distribute an Ag-Inputs Monthly Price outlook bulletin primarily on seeds, fertilizers and plant protection products. The bulletin will be underpinned by a Geographic Information System (GIS). This will depict visual representation of input distribution networks, transportation infrastructure, client concentrations, cropping patterns, product and price trends, and other important information. Improving quality control standards and regulatory constraints will involve working with industry associations and the GOB to develop industry standards for each of the major crops, and building capacities of associations to assert their voice to the GOB. AIRN will conduct Business Ethics Audits of certified retailers for transparency and consistency. AIP will build the capacity of local organizations so that they become up to USAID s standards, as future implementers of AIP. This will be made possible through capacity building and providing financial assistance to the organizations like business associations, NGOs, microfinance institutions, research institutes and government. The project approach to rejected pesticides in this PERSUAP or its updates is that the AIP will categorically not procure or purchase any inventory, including pesticides, for AIRN-Astha members, nor for female grantees (who will also be AIRN-Astha members) to maintain or set up agro-inputs businesses. Moreover, the AIP will not collaborate with any entity to demonstrate (through Demonstration Plots and their accompanying Field Days), nor promote any pesticides that will be in the rejected category of this PERSUAP or its annual updates of accepted/rejected pesticides. The scope of the project includes 500 demonstration plots, and, up to 2,894 GoB-registered agricultural natural and chemical pesticide products containing 145 chemical AIs as of March, USAID/Bangladesh AIP PERSUAP v

6 C. COUNTRY AGRICULTURE, CROPS, PESTS, IPM AND ENVIRONMENTAL BASELINE INFORMATION A rich multitude of crops and mixed aquatic culture (fish and prawns alternating with rice) are grown and produced throughout the winter (mid-october to mid-march, or dry Robi) season and summer (mid-april to mid-october, or wet Kharif) season in Bangladesh. These include not just valuable exportable cash crops like jute fiber, betel palm nut and deciduous betel tree leaves, but also a wide variety of vegetables, herbs, spices and fruits. Pests (insects, mites, nematodes, mollusks plant-eating snails and slugs, and rodents) diseases (fungi, viruses, and bacteria) and weeds negatively affect, and reduce yield potential of most crops produced in Bangladesh. Farmers cannot achieve their food security and cash crop potentials unless they have access to quality soil, water/irrigation technologies, quality hybrid seeds/seedlings, mechanization, greenhouse/plastic tunnel technologies, physical, mechanical and chemical weed control, fertilizers, as well as modern state-of-the-art Good Agriculture Practices (GAPs)/Integrated Pest Management (IPM) information and some natural or synthetic pesticides. Hybrid seed supplies are relatively sufficient and some farmers have access to and use natural manures; few (less than 5%) that were observed use purchased mineral fertilizers. Most (85%) small-scale farmers observed during this study in Bangladesh have at most 2-3 small (250ml to 500ml) bottles of pesticides for use on their pond-bund structures, fields and fruit tree stands. Field visits show that Bangladeshi farmers do not produce and augment their soil with compost, and do not have full access to mechanization or irrigation sources or services; instead they rely almost completely on rainfall and flooding from lowlands. All of these practices need to be improved before production potentials can be realized. As of March 2013, Bangladesh s DAE-PPW had registered 3,307 pesticide products containing 248 chemical AIs. 2,894 pesticide products are agricultural and 145 AIs are agricultural; the remaining are registered for public health. Most of these pesticides are registered for agricultural uses, including fumigants for warehouses and soil, as well as a few that can serve for public health and animal health. Small to medium scale Agro-Dealer Shops exist across Bangladesh, with the larger ones relatively much better organized and with BMPs (Best Management Practices), while many of the smaller ones in smaller towns are not. The Bangladesh pesticide sector is sufficiently developed and diverse due to smallholder demand and use. Large-scale commercial and estate farms, which are far and few between in Bangladesh, have their own input sources and suppliers. Eighteen commercial pesticide re-packagers and/or formulators (precisely mix various active and inactive ingredients to make pesticides) exist in Bangladesh, with ACI, Bayer, and Syngenta being prominent, among others. Farmers in Bangladesh do not treat their own seed (saved or otherwise) with protectant pesticides; they buy them treated. Most vegetable seed comes ready with colored seed treatment pesticides on them; some maize and wheat seed is treated, but rice seed is not. D. EVALUATION OF ACTIVITY WITH RESPECT TO POTENTIAL ENVIRONMENTAL IMPACTS AND IDENTIFICATION OF MITIGATION MEASURES All activities approved in the original IEE remain valid (see Annex 18 for original IEE). This proposed amendment to the IEE will assist with the following additional activities towards current objectives: Produce the 2013 USAID/Bangladesh AIP PERSUAP to cover any and all activities related 2013 USAID/Bangladesh AIP PERSUAP vi

7 to pesticide training, procurement, and/or use on AIPactivities that could or will use pesticides. Prepare AIP s environmental compliance staff to be able to do training to retailers which will include best practices for sourcing and using inputs including IPM preventive tools and curative pesticides for treating seed, crops and grain storage. E. RECOMMENDED ENVIRONMENTAL ACTION 1. Recommended Environmental Threshold Determinations: A Negative Determination with Conditions was recommended for activities that are related to pesticide training, procurement,, distribution and use, directly or through other financial instruments (credit, sub grants, vouchers) under this amendment pursuant to 22 CFR 216.3(a)(2)(iii). 2. Conditions Implementation of the following risk mitigation recommendations and Good Agriculture Practices (GAPs) from the PERSUAP are conditions for any assistance to retailers and farmers that might include training on, discussing or promotion of the use of pesticide inputs. Pesticide Use Defined Pesticide use by the Bangladesh AIP was defined and agreed upon at the outset of this PERSUAP study as including: Promotion during project training, Use on project demonstration plots, Procurement directly by project for beneficiaries or spray services, Collaborative efforts with agro-dealers, or Subsidization or financing by the project through sub-grantees or credit agreements. Pesticides rejected by this PERSUAP analysis cannot be procured and/or 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 beneficiary retailers with their own resources and use by beneficiary farmer-clients of pesticides on their own farms (unless they are project demonstration plots), although the AIP can and should make recommendations for the purchase and use of safer alternatives. IPM Defined A good definition of IPM from the Organization for Economic Co-operation and Development (OECD) 1 follows: Integrated pest management (IPM) is an approach to the management and control of agricultural pests which relies on site- and condition-specific information to manage pest populations below a level that causes economic injury and that minimizes risks to humans and the natural environment. Although any among a wide range of pest control agents may be used (including chemical sprays), IPM generally stresses the use of alternatives, such as crop rotations, USAID/Bangladesh AIP PERSUAP vii

8 mechanical cultivation, and biological agents, where such methods are deemed to be effective. Conditions 1: Allowed and 2: Rejected Pesticides Condition 1: Upon approval of this PERSUAP, the pesticide active ingredients (AIs) listed as allowed in the table that follow and ONLY those AIs may be procured and/or used by the USAID/Bangladesh AIP 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. Condition 2: Upon approval of this PERSUAP, the pesticide active ingredients (AIs) listed as rejected in Annex 17may NOT be supported by the USAID/Bangladesh AIP covered by this PERSUAP. Allowed pesticides are those that passed the 12-factor analyses, particularly Factor A: Bangladesh Department of Agricultural Extension, Plant Protection Wing (DAE-PPW) and EPA Registration and RUP (Restricted Use Pesticide) Status & Factor E (Acute/Chronic Toxicological Hazards) for similar unrestricted use, as analyzed and summarized in Annex 7. Synthesizing across the PER analysis, ONLY the below-listed pesticides containing the active ingredients are permitted for procurement and/or usein USAID/Bangladesh AIP. For reference, AIs considered, but REJECTED are also listed in Annex 17. Allowed Fumigant AIs registered by Strict Conditions Bangladesh DAE-PPW and registered with USEPA for similar unrestricted use aluminum phosphide for stored grains for use only by trained and certified Allowed Miticide AIs registered by Bangladesh DAE-PPW and registered with USEPA for similar unrestricted use applicators, not farmers; see Fumigation PEA Strict Conditions abamectin/avermectin use only formulations below 1.9% hexythiazox -- sulfur -- Allowed Insecticide AIs registered by Bangladesh DAE-PPW and registered with USEPA for similar unrestricted use Strict Conditions abamectin/avermectin use only formulations below 1.9% acephate -- acetamiprid but only when plants are in vegetative state, not when flowering due to risk to pollinators and honeybee colony collapse disorder amitraz -- beta-cypermethrin -- bifenthrin -- buprofezin -- carbaryl USAID/Bangladesh AIP PERSUAP viii

9 chlorantraniliprole -- chlorfenapyr -- chlorpyrifos-ethyl for uses except spraying for household pests, favor the use of granular formulations for soil pests cypermethrin registered USA for medical, veterinary and household use diazinon but, choose and use non-rup formulations deltamethrin do not get into open water dimethoate but, choose and use non-rup formulations emamectin benzoate but, choose and use non-rup formulations Esfenvalerate but, choose and use non-rup formulations fenitrothion -- fipronil registered USA for use against termites, ticks, mites, fleas, ants, roaches and mole crickets flubendiamide -- gamma-cyhalothrin but, choose and use non-rup formulations imidacloprid but only when plants are in vegetative state, not when flowering due to risk to pollinators and honeybee colony collapse disorder indoxacarb (S-isomer) -- lambda cyhalothrin use only formulations 10% and below lufenuron -- malathion -- methomyl use only acute toxicity Class II and III products; not Class I phosphorous acid -- pymetrozine -- spinosad -- spirotetramat -- thiacloprid but only when plants are in vegetative state, not when flowering due to risk to pollinators and honeybee colony collapse disorder thiamethoxam but only when plants are in vegetative state, not when flowering due to risk to pollinators and honeybee colony collapse disorder zeta-cypermethrin but, choose and use non-rup formulations Allowed Fungicide AIs registered by Strict Conditions Bangladesh DAE-PPW and registered with USEPA for similar unrestricted use azoxystrobin -- carbendazim -- carboxim -- chlorothalonil -- copper USAID/Bangladesh AIP PERSUAP ix

10 copper hydroxide -- copper oxychloride -- copper sulfate -- cymoxanil -- cyproconazole -- dicloran/dcna -- difenoconazole -- dimethomorph -- fenamidone -- fosetyl aluminum -- mancozeb -- mandipropamid -- metalaxyl -- metiram -- propamocarb HCl -- propiconazole -- pyraclostrobin -- streptomycin sulfate -- tebuconazole -- tetraconazole -- tetracycline hydrochloride -- thiophanate methyl -- thiram -- trifloxystrobin -- Allowed Herbicide AIs registered by Strict Conditions Bangladesh DAE-PPW and registered with USEPA for similar unrestricted use 2 4 D -- bensulfuron-methyl -- carfentrazpone-ethyl -- cyhalofop-butyl -- fenoxaprop-p-ethyl but, choose and use only Class II and III products, not Class I glyphosate -- MCPA -- Mefenacet -- metribuzin -- nicosulfuron -- orthosulfamuron -- orzalin -- oxadiazon -- pendimethalin -- penoxysulam USAID/Bangladesh AIP PERSUAP x

11 pretilachlor -- propanil -- quinclorac -- quizalfop-p-ethyl but, choose and use only Class II and III products, not Class I triasulfuron -- Allowed Rodenticide AIs Strict Conditions bromadiolone -- zinc phosphide only in concentrations of 2% and lower, which are EPA acute toxicity Class III Condition 3: The Safer Use Action Plan (SUAP, Section 4) provides a succinct, stand-alone statement of compliance requirements, synthesized from the 12-factor analysis. It also provides a template for assigning responsibilities and timelines for implementation of these requirements. The AIP must complete this SUAP template (Annex 16) and submit to its AOR/COR for approval and provide an annual update thereafter. With respect to pesticides, the Safer Use Action Plan satisfies part of the requirement for an environmental mitigation and monitoring plan (EMMP). The project EMMP should incorporate the SUAP by reference, and include other issues like soil erosion and fertilizer use, among others. Condition 4: The AIP, during the pesticide safer use training and IPM training required by this PERSUAP, will (1) promote and teach proper sprayer maintenance and repair; and (2) train participants on post-spray hygiene. See Annex 14 (page 123) for PERSUAP consultant s analysis of training materials, with recommendations for improving them. Condition 5: The AIP will assure and require well-maintained sprayers and proper post-spray hygiene and facilities for pesticide use under their direct control. Condition 6: Where pesticide use is not under project direct control, but the project is nonetheless supplying or supporting the purchase of PERSUAP-allowed pesticides or application equipment, the project will assure that appropriate PPE, post-spray facilities for washing clothing and equipment, and proper disposal of wastes are in place and undertake all feasible measures to promote their use. Condition 7: If agricultural production is done within 10km up-wind or up-stream from a protected area, the AIP should investigate and strongly recommend the use of an IPM plan with preventive measures, as well as botanical and biological controls, as practical, or produce Organic crops near these valuable natural resources. Condition 8: If a regional (for South and Southeast Asia) or Bangladesh-specific pesticide container recycling facility is brought on-line during the life of the project, USAID should encourage its use, once it is ascertained that the facility is designed, built, and operated in accordance with national laws of Bangladesh and applicable international conventions, and is operated under all applicable valid licenses and permits. Currently there is no plan to open such a facility in Bangladesh or any other country in South or Southeast Asia USAID/Bangladesh AIP PERSUAP xi

12 Condition 9: The AIP conduct training programs on monitoring and data record keeping techniques for pest control and pesticide needs and/or effectiveness. Condition 10: The AIP AOR, at least two or more times annually, make visits along with the MEO/or DMEO to several randomly selected retailers receiving assistance through the USAID AIP and check for compliance with the recommendations on pesticides and IPM practices recommended in this PERSUAP (see Annex 1). Condition 11: This 2013 PERSUAP document recommends that updates to the IPM and pesticide information and analyses contained in it be done at least once a year. The reasons for this are: EPA pesticide registrations and restrictions change every couple of months, DAE-PPW registrations will change, and new eco-toxicological information will be generated continuously for most pesticide AIs. Thus AIP will need access to the best, most up-to-date information available. F. LIMITATIONS OF THE IEE This IEE Amendment does not cover major activities involving: 1. Activities affecting endangered species or introducing exotic species or in ecologically critical areas as specified in country regulations. 2. Support to extractive industries (e.g. mining and quarrying). 3. Support for activities that promote timber harvesting. 4. Construction, reconstruction, rehabilitation, or renovation work. 5. Activities involving support to agro-processing, industrial enterprises, and regulatory permitting. 6. Activities involving support to industrial enterprises, and regulatory permitting. 7. Potential activity components dealing with privatization of industrial facilities or infrastructure with heavily polluted property. 8. Project preparation, project feasibility studies, and infrastructure investments for projects that may have a potentially significant impact on the environment. 9. Procurement or use of genetically modified organisms (GMOs). 10. DCA or GDA programs. Any of the above actions would require another amendment to the IEE approved by the BEO. G. REVISIONS Pursuant to 22 CFR 216.3(a) (9), if new information becomes available (and it will, at least annually) that indicates that activities covered by the IEE might be considered major and their effect significant, or if additional activities are proposed that might be considered major and their effect significant, this Initial Environmental Examination will be reviewed and, revised by the MEO with concurrence by the BEO. It is the responsibility of the USAID A/COR to keep the MEO, REA and BEO informed of any new information or changes in the activity that might require revision of the IEE USAID/Bangladesh AIP PERSUAP xii

13 CLEARANCE: USAID APPROVAL OF ENVIRONMENTAL ACTION(S) RECOMMENDED AOR Date: Beth A. Hain Mission Environmental Officer Date: Tamar Barabadze Regional Environmental Adviser: Date: (Central and South Asia & OAPA) Andrei Barannik Deputy Mission Director (A): Date: Ramona El Hamzaoui Mission Director (A): Date: Paul Sabatine Approval: Bureau Environmental Officer Date: John Wilson Approved: Distribution: Disapproved: 1. OAA 2. Project files 3. CORs/AORs and Activity Managers 4. Office Chiefs 5. AIP /Implementing Partners 2013 USAID/Bangladesh AIP PERSUAP xiii

14 2013 Bangladesh Agro-Inputs Project (AIP) Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP) By CNFA For USAID Bangladesh Covering Agriculture Sub-Sectors of Pesticide Procurement and Use in: Agriculture (Seed, Nursery, Field, Mixed Bund-Pond Cropping) July-November 2013 Author Alan Schroeder, PhD, MBA 2013 USAID/Bangladesh AIP PERSUAP xiv

15 TABLE OF CONTENTS AMENDMENT TO INITIAL ENVIRONMENTAL EXAMINATION (IEE) FOR THE AGRO-INPUTS PROJECT (AIP) IN BANGLADESH PERSUAP INCORPORATING COMMUNICATIONS AND TRAINING MATERIALS... III ACRONYMS... 1 ACKNOWLEDGEMENTS... 3 EXECUTIVE SUMMARY... 4 SECTION 1: INTRODUCTION PURPOSE, SCOPE & ORIENTATION USAID ENVIRONMENTAL REGULATIONS DEVELOPMENT TITLE 22, CODE OF FEDERAL REGULATIONS, PART 216 (22 CFR 216) THE PESTICIDE EVALUATION REPORT AND SAFER USE ACTION PLAN (PERSUAP) INTEGRATED PEST MANAGEMENT USAID POLICY BANGLADESH PERSUAP METHODOLOGY AND SCOPES OF WORK (SOW) SECTION 2: BACKGROUND COUNTRY BACKGROUND USAID BANGLADESH AIP BACKGROUND OTHER BANGLADESH DONOR AGRICULTURE PROJECTS BACKGROUNDS BANGLADESH PESTICIDES AND STANDARDS ISSUES BANGLADESH INTERNATIONAL OBLIGATIONS AND PESTICIDE SECTOR RISKS SECTION 3: PESTICIDE EVALUATION REPORT FACTOR A: USEPA REGISTRATION STATUS OF THE PROPOSED PESTICIDE FACTOR B: BASIS FOR SELECTION OF PESTICIDES FACTOR C: EXTENT TO WHICH THE PROPOSED PESTICIDE USE IS, OR COULD BE, PART OF AN IPM PROGRAM FACTOR D: PROPOSED METHOD OR METHODS OF APPLICATION, INCLUDING THE AVAILABILITY OF APPLICATION AND SAFETY EQUIPMENT FACTOR E: ANY ACUTE AND LONG-TERM TOXICOLOGICAL HAZARDS, EITHER HUMAN OR ENVIRONMENTAL, ASSOCIATED WITH THE PROPOSED USE, AND MEASURES AVAILABLE TO MINIMIZE SUCH HAZARDS FACTOR F: EFFECTIVENESS OF THE REQUESTED PESTICIDE FOR THE PROPOSED USE FACTOR G: COMPATIBILITY OF THE PROPOSED PESTICIDE USE WITH TARGET AND NON- TARGET ECOSYSTEMS FACTOR H: CONDITIONS UNDER WHICH THE PESTICIDE IS TO BE USED, INCLUDING CLIMATE, GEOGRAPHY, HYDROLOGY, AND SOILS FACTOR I: AVAILABILITY OF OTHER PESTICIDES OR NON-CHEMICAL CONTROL METHODS FACTOR J: HOST COUNTRY S ABILITY TO REGULATE OR CONTROL THE DISTRIBUTION, STORAGE, USE, AND DISPOSAL OF THE REQUESTED PESTICIDE FACTOR K: PROVISION FOR TRAINING OF USERS AND APPLICATORS FACTOR L: PROVISION MADE FOR MONITORING THE USE AND EFFECTIVENESS OF EACH PESTICIDE USAID/Bangladesh AIP PERSUAP xv

16 SECTION 4: PESTICIDE SAFER USE ACTION PLAN (SUAP) INTRODUCTION ALLOWED PESTICIDES USAID FIELD MONITORING REQUIREMENT SUMMARY OF COMPLIANCE REQUIREMENTS (SAFER USE MEASURES) ANNEX 1: MATRIX OF BANGLADESH CROPS WITH PRIMARY PRODUCTION CONSTRAINTS, PERSUAP-RECOMMENDED PEST PREVENTION GAP/IPM TACTICS & PERSUAP-RECOMMENDED CURATIVE TOOLS AND TACTICS ANNEX 2. GUIDELINES FOR PEST MANAGEMENT PLANS (PMPS) FOR BANGLADESH CROPS AND BENEFICIARIES ANNEX 3. ELEMENTS OF INTEGRATED PEST MANAGEMENT (IPM) PROGRAM STEP 1: LEARN AND VALUE FARMERS INDIGENOUS IPM TACTICS STEP 2: IDENTIFY KEY PESTS FOR EACH TARGET CROP STEP 4: CHOOSE IPM METHODS, IDENTIFY NEEDS AND ESTABLISH PRIORITIES STEP 5: DO EFFECTIVE ACTIVITIES AND TRAINING TO PROMOTE IPM STEP 6: PARTNER SUCCESSFULLY WITH OTHER IPM IMPLEMENTERS STEP 7: MONITOR THE FIELDS REGULARLY STEP 8: SELECT AN APPROPRIATE BLEND OF IPM TOOLS STEP 9: DEVELOP EDUCATION, TRAINING, AND DEMONSTRATION PROGRAMS FOR EXTENSION WORKERS STEP 10: MONITORING, RECORD-KEEPING AND EVALUATION (M&E) ANNEX 4. BOTANICAL ACTIVE INGREDIENTS IN PESTICIDES, REPELLENTS, AND BAITS REGULATED BY USEPA ANNEX 5. NATURAL PESTICIDES THAT HAVE BEEN COMMERCIALIZED ANNEX 6. ACUTE TOXICITY OF PESTICIDES: EPA AND WHO CLASSIFICATIONS ANNEX 7: PERSUAP ANALYSES OF ACTIVE INGREDIENTS IN PESTICIDES REGISTERED IN BANGLADESH ANNEX 8. TRAINING TOPICS AND SAFER PESTICIDE USE WEB RESOURCES, AND BANGLADESH PPE SOURCING ANNEX 9. FIELD MONITORING FORM FOR FARMER BEST PRACTICES INCLUDING GAP AND IPM OPTIONS (IN ENGLISH; BANGLA TRANSLATION FOLLOWS) ANNEX 10: FARM AND PROJECT RECORD KEEPING ASSOCIATED WITH PESTICIDE USE (ENGLISH VERSION; BANGLA VERSION IMMEDIATELY FOLLOWS) ANNEX 11: 2013 BANGLADESH AIP PERSUAP COUNTRY VISIT SCHEDULE, CONTACTS AND MAP OF VISIT SITES ANNEX 12: PERSUAP REFERENCES ANNEX 13: SCOPE OF WORK USAID/Bangladesh AIP PERSUAP xvi

17 ANNEX 14: PERSUAP CONSULTANT ANALYSES OF CLA S TRAINING MATERIALS WITH RECOMMENDATIONS ANNEX 15: COMMUNICATIONS MEDIA PLAN FOR USE BY AIP S COMMUNICATION SPECIALIST FOR MARKETING IPM AND PESTICIDE SAFE USE INFORMATION ANNEX 16: MITIGATION AND MONITORING PLAN FOR IPM AND PESTICIDE SAFETY ANNEX 17: PESTICIDE ACTIVE INGREDIENTS (AIS) REJECTED BY THIS PERSUAP ANNEX 18: INITIAL ENVIRONMENTAL EXAMINATION OR REQUEST FOR CATEGORICAL EXCLUSION USAID/Bangladesh AIP PERSUAP xvii

18 ACRONYMS AI AIRN AOR BEO BMP BT CBD CCD CFR CLA CLI COP COP6 COR CRSP DAE-PPW DCA DMEO DANIDA DOE EA EC EC50 ECA EDDR EG EPA ETOA EU EurepGAP FAO FDA FIFRA FRAC GAP GDA GlobalGAP GIS GMO GOB GUP Ha HRAC HT ID IEE Active Ingredient (reference to chemical/s in pesticides) Agro-Input Retailers Network Agreement Officer s Representative (USAID) Bureau Environmental Officer (USAID) Best Management Practice Bacillus thuringiensis (a bacteria that produces a toxin used as a pesticide) Convention on Biological Diversity Colony Collapse Disorder Code of Federal Regulations (USA) Crop Life Asia (Asian branch of CLI) Crop Life International (private sector pesticide companies trade association) Chief of Party (USAID) Sixth Conference of the Parties (COP6) of the CBD (above) Contracting Officer s Representative (USAID) Collaborative Research Support Program Department of Agricultural Extension, Plant Protection Wing Development Credit Authority Deputy Mission Environmental Officer (USAID) Danish Development Agency Department of Environment Environmental Assessment Emulsifiable Concentrate (pesticide formulation) Effective Concentration 50 (acute toxicity measure) Ecologically Critical Area Environmental Due Diligence Report (USAID) Economic Growth US Environmental Protection Agency (also known as USEPA) Environmental Threats and Opportunities Analysis (aka 118/119 study) European Union European Good Agriculture Practices Food and Agriculture Organization (United Nations) Food and Drug Administration (USA) Federal Insecticide, Fungicide and Rodenticide Act (USA) Fungicide Resistance Action Committee Good Agriculture Practice Global Development Alliance Global Good Agriculture Practices, a certification system Geographic Information System Genetically Modified Organism Government of Bangladesh General Use Pesticide Hectares Herbicide Resistance Action Committee Highly Toxic Identification Initial Environmental Examination (USAID) 2013 USAID/Bangladesh AIP PERSUAP 1

19 IGR IPM IRAC IRIN LC50 LD50 M&E MD MEO MRL MSDS MSL MT MT NAT NCAT NEPA NGO OECD NIFA PAN PEA PER PERSUAP ph PHI PIC POPs PMP PNT PPE R&D toxin REA Reg 216 REI RUP S&C SOW ST SUAP UC UN USAID USDA USEPA VHT WHO WP Insect Growth Regulator Integrated Pest Management Insecticide Resistance Action Committee Integrated Regional Information Networks (of the UN) Lethal Concentration 50 (acute toxicity measure) Lethal Dose 50 (acute toxicity measure) Monitoring and Evaluation Micro Dispersion (pesticide formulation) Mission Environmental Officer (USAID) Maximum/Minimum Residue Level/Limit Material Safety Data Sheet Meters above Sea Level Metric Tons Moderately Toxic Not Acutely Toxic National Center for Appropriate Technology (USA) National Environmental Policy Act (USA) Non-Governmental Organization Organization for Economic Co-operation and Development National Institute of Food and Agriculture (USA) Pesticide Action Network (pesticide NGO) Programmatic Environmental Assessment (USAID) Pesticide Evaluation Report Pesticide Evaluation Report and Safe Use Action Plan log of Hydrogen concentration, measure of acidity Pre-Harvest Interval Prior Informed Consent (a treaty, relates to toxic pesticides) Persistent Organic Pollutants (a treaty, relates to toxic persistent pesticides) Pest Management Plan Practically Non-Toxic Personal Protection Equipment Reproductive and Developmental toxin Regional Environmental Advisor Regulation 216 (USAID Environmental Procedures) Re-Entry Interval (safety period after pesticide spraying) Restricted Use Pesticide Standards and Certification Scope of Work Slightly Toxic Safer Use Action Plan University of California United Nations United States Agency for International Development United States Department of Agriculture US Environmental Protection Agency (also known as EPA) Very Highly Toxic World Health Organization (United Nations) Wettable Powder (pesticide formulation, usually for fungicides) 2013 USAID/Bangladesh AIP PERSUAP 2

20 ACKNOWLEDGEMENTS This PERUAP team of Shakil Ahmed, Environmental Specialist, Sardar Md. Salahuddin, Agro Input Quality Control and Standards Specialist, and International Consultant Alan Schroeder would like to warmly acknowledge the assistance of USAID Bangladesh staff members Tamuna Barabadze, Senior GCC Advisor and MEO, Anar Khalilov and Beth Hain, the AOR(s), and Md. Ashiqur Rahman, Deputy MEO for guidance, advice and presence with the team in the field. The team is also indebted to Mark Treacy, Senior Capacity Building Advisor and Interim Chief of Party, for logistics and wise advice. USAID Asia Bureau Regional Environmental Advisor and Bureau Environmental Officer, who will also review the draft document and provide valuable comments, are also acknowledged. Other individuals and institutions too numerous to list availed themselves for interviews and contributed to the accuracy and completeness of this study. They are listed in Annex 13 to this document USAID/Bangladesh AIP PERSUAP 3

21 EXECUTIVE SUMMARY Introduction 22 CFR 216, or USAID s Regulation 216, in section (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 PERSUAP (Pesticide Evaluation Report and Safer Use Action Plan). The main purpose of a Pesticide Evaluation Report (PER) and Safer Use Action Plan (SUAP) is to bring USAID-funded projects into compliance with USAID s environmental regulations (Title 22 of the Code of Federal Regulations (CFR), part 216, or Regulation 216) on pesticide use. In addition to compliance, this document offers best practices for the AIP to follow, to ensure that its USAID-funded activities reduce the chances of environmental and health impacts due to pesticide training, procurement, and/or use. If the AIP desires to procure and/or use pesticides rejected by this PERSUAP analysis, it will need to perform an Environmental Assessment (EA) on those chemicals and their use. Background To achieve its objectives, the AIP in Bangladesh may need to procure and/or use pesticides, as part of Best Management Practices (BMPs) and Integrated Pest Management (IPM) approaches. An IEE (Annex 18) has been produced that recommends the production of this PERSUAP study in order to analyze such pesticide use, within the Bangladesh pesticide system. This is the first AIP PERSUAP version produced for USAID Bangladesh. Purpose In compliance with USAID s Pesticide Procedures (22 CFR 216.3(b)), this 2012 Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP) for the USAID/Bangladesh AIP Portfolio: Establishes the subset of pesticides (of those registered by the Government of Bangladesh DAE-PPW) for which procurement and/or use is authorized on USAID/Bangladesh AIP activities. Establishes requirements attendant to procurement and/or for these pesticides to assure that pesticide procurement/use (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 the PERSUAP. Scope Specifically, the AIP and its activities are covered by this PERSUAP, which includes support for developing state-of-the art input suppliers, using industry and sector-recognized BMPs USAID/Bangladesh AIP PERSUAP 4

22 Pesticide Definition by EPA For the purposes of this PERSUAP, the word pesticide is used, following EPA s guidelines 2, 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. Pesticide Use Defined Pesticide use by the Bangladesh AIP was defined and agreed upon at the outset of this PERSUAP study as including: Promotion during project training, Use on project demonstration plots, Procurement directly by project for beneficiaries or spray services, Collaborative efforts with agro-dealers, or Subsidization or financing by the project through sub-grantees or credit agreements. Pesticides rejected by this PERSUAP analysis (Annex 17) cannot be procured and/or 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 beneficiary retailers with their own resources and use by beneficiary farmer-clients of pesticides on their own farms (unless they are project demonstration plots), although the AIP can and should make recommendations for the purchase and use of safer alternatives. Modern Agriculture, Quality Control Standards and Market Access Any AIP activity that aims to help beneficiaries capture pieces of quality foreign markets by use of volunteer Standards and Certification (S&C) systems, like GlobalGAP, Organic, Fair Trade, or Scientific Certification Society (SCS) that audits and certifies coffee in Bangladesh 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 the AIP without other S&C systems. Pesticides Requested or Desired or Available for use by USAID Bangladesh AIP activities This 2013 PERSUAP first evaluates the pesticides registered and found available in Bangladesh so that decisions can be made when choosing, or avoiding, alternatives. Finally, it evaluates pesticides that potential project beneficiary retailers and farmers currently desire and use so that recommendations can be made for safer alternatives as higher risk products are phased out. Findings: Allowed and Rejected Pesticides (from IEE Amendment) Upon approval of this AIP PERSUAP, the pesticide active ingredients (AIs) listed as allowed in the table that follows and ONLY those AIs may be supported by the USAID/Bangladesh USAID/Bangladesh AIP PERSUAP 5

23 AIP activities 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 table in Annex 17 also sets out all AIs considered but rejected, along with the reasons for the rejection. Allowed pesticides are those that passed the 12-factor analyses, particularly Factor A (EPA & Bangladesh Registration and EPA RUP Status) & Factor E (Acute/Chronic Toxicological Hazards) for similar unrestricted useas analyzed and summarized in Annex 7. Conditions 1: Allowed and 2: Rejected Pesticides (from IEE Amendment) Condition 1: Upon approval of this PERSUAP, the pesticide active ingredients (AIs) listed as allowed in the table that follow and ONLY those AIs may be procured and/or used by the USAID/Bangladesh AIP 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. Condition 2: Upon approval of this PERSUAP, the pesticide active ingredients (AIs) listed as rejected in Annex 17may NOT be supported by the USAID/Bangladesh AIP covered by this PERSUAP. Allowed pesticides are those that passed the 12-factor analyses, particularly Factor A: Bangladesh Department of Agricultural Extension, Plant Protection Wing (DAE-PPW) and EPA Registration and RUP (Restricted Use Pesticide) Status & Factor E (Acute/Chronic Toxicological Hazards) for similar unrestricted use, as analyzed and summarized in Annex 7. Synthesizing across the PER analysis, ONLY the below-listed pesticides containing the active ingredients are permitted for procurement and/or use in USAID/Bangladesh AIP. For reference, AIs considered, but REJECTED are also listed in Annex 17. Allowed Fumigant AIs registered by Strict Conditions Bangladesh DAE-PPW and registered with USEPA for similar unrestricted use aluminum phosphide for stored grains for use only by trained and certified Allowed Miticide AIs registered by Bangladesh DAE-PPW and registered with USEPA for similar unrestricted use applicators, not farmers; see Fumigation PEA Strict Conditions abamectin/avermectin use only formulations below 1.9% hexythiazox -- sulfur -- Allowed Insecticide AIs registered by Bangladesh DAE-PPW and registered with USEPA for similar unrestricted use Strict Conditions abamectin/avermectin use only formulations below 1.9% acephate USAID/Bangladesh AIP PERSUAP 6

24 but only when plants are in vegetative state, acetamiprid not when flowering due to risk to pollinators and honeybee colony collapse disorder amitraz -- beta-cypermethrin -- bifenthrin -- buprofezin -- carbaryl -- chlorantraniliprole -- chlorfenapyr -- chlorpyrifos-ethyl for uses except spraying for household pests, favor the use of granular formulations for soil pests cypermethrin registered USA for medical, veterinary and household use diazinon but, choose and use non-rup formulations deltamethrin do not get into open water dimethoate but, choose and use non-rup formulations emamectin benzoate but, choose and use non-rup formulations Esfenvalerate but, choose and use non-rup formulations fenitrothion -- fipronil registered USA for use against termites, ticks, mites, fleas, ants, roaches and mole crickets flubendiamide -- gamma-cyhalothrin but, choose and use non-rup formulations imidacloprid but only when plants are in vegetative state, not when flowering due to risk to pollinators and honeybee colony collapse disorder indoxacarb (S-isomer) -- lambda cyhalothrin use only formulations 10% and below lufenuron -- malathion -- methomyl use only acute toxicity Class II and III products; not Class I phosphorous acid -- pymetrozine -- spinosad -- spirotetramat -- thiacloprid but only when plants are in vegetative state, not when flowering due to risk to pollinators and honeybee colony collapse disorder thiamethoxam but only when plants are in vegetative state, not when flowering due to risk to pollinators and honeybee colony collapse disorder zeta-cypermethrin but, choose and use non-rup formulations 2013 USAID/Bangladesh AIP PERSUAP 7

25 Allowed Fungicide AIs registered by Strict Conditions Bangladesh DAE-PPW and registered with USEPA for similar unrestricted use azoxystrobin -- carbendazim -- carboxim -- chlorothalonil -- copper -- copper hydroxide -- copper oxychloride -- copper sulfate -- cymoxanil -- cyproconazole -- dicloran/dcna -- difenoconazole -- dimethomorph -- fenamidone -- fosetyl aluminum -- mancozeb -- mandipropamid -- metalaxyl -- metiram -- propamocarb HCl -- propiconazole -- pyraclostrobin -- streptomycin sulfate -- tebuconazole -- tetraconazole -- tetracycline hydrochloride -- thiophanate methyl -- thiram -- trifloxystrobin -- Allowed Herbicide AIs registered by Strict Conditions Bangladesh DAE-PPW and registered with USEPA for similar unrestricted use 2 4 D -- bensulfuron-methyl -- carfentrazpone-ethyl -- cyhalofop-butyl -- fenoxaprop-p-ethyl but, choose and use only Class II and III products, not Class I glyphosate -- MCPA USAID/Bangladesh AIP PERSUAP 8

26 Mefenacet -- metribuzin -- nicosulfuron -- orthosulfamuron -- orzalin -- oxadiazon -- pendimethalin -- penoxysulam -- pretilachlor -- propanil -- quinclorac -- quizalfop-p-ethyl but, choose and use only Class II and III products, not Class I triasulfuron -- Allowed Rodenticide AIs Strict Conditions bromadiolone -- zinc phosphide only in concentrations of 2% and lower, which are EPA acute toxicity Class III Condition 3: The Safer Use Action Plan (SUAP, Section 4) provides a succinct, stand-alone statement of compliance requirements, synthesized from the 12-factor analysis. It also provides a template for assigning responsibilities and timelines for implementation of these requirements. The AIP must complete this SUAP template and submit to its AOR/COR for approval and provide an annual update thereafter. With respect to pesticides, the Safer Use Action Plan satisfies part of the requirement for an environmental mitigation and monitoring plan (EMMP). The project EMMP should incorporate the SUAP by reference, and include other issues like soil erosion and fertilizer use, among others. Condition 4: The AIP, during the pesticide safer use training and IPM training required by this PERSUAP, will (1) promote and teach proper sprayer maintenance and repair; and (2) train participants on post-spray hygiene. See Annex 14 (page 123) for PERSUAP consultant s analysis of training materials, with recommendations for improving them. Condition 5: The AIP will assure and require well-maintained sprayers and proper post-spray hygiene and facilities for pesticide use under their direct control. Condition 6: Where pesticide use is not under project direct control, but the project is nonetheless supplying or supporting the purchase of PERSUAP-allowed pesticides or application equipment, the project will assure that appropriate PPE, post-spray facilities for washing clothing and equipment, and proper disposal of wastes are in place and undertake all feasible measures to promote their use. Condition 7: If agricultural production is done within 10km up-wind or up-stream from a protected area, the AIP should investigate and strongly recommend the use of an IPM plan with preventive measures, as well as botanical and biological controls, as practical, or produce Organic crops near these valuable natural resources USAID/Bangladesh AIP PERSUAP 9

27 Condition 8: If a regional (for South and Southeast Asia) or Bangladesh-specific pesticide container recycling facility is brought on-line during the life of the project, USAID should encourage its use, once it is ascertained that the facility is designed, built, and operated in accordance with national laws of Bangladesh and applicable international conventions, and is operated under all applicable valid licenses and permits. Currently there is no plan to open such a facility in Bangladesh or any other country in South or Southeast Asia. Condition 9: The AIP conducts training programs on monitoring and data record keeping techniques for pest control and pesticide needs and/or effectiveness. Condition 10: The AIP AOR, at least two or more times annually, make visits along with the MEO/or DMEO to several randomly selected retailers receiving assistance through the USAID AIP and check for compliance with the recommendations on pesticides and IPM practices recommended in this PERSUAP (see Annex 1). Condition 11: This 2013 PERSUAP document recommends that updates to the IPM and pesticide information and analyses contained in it be done at least once a year. The reasons for this are: EPA pesticide registrations and restrictions change every couple of months, DAE-PPW registrations will change, and new eco-toxicological information will be generated continuously for most pesticide AIs. Thus AIP will need access to the best, most up-to-date information available. Results of Pesticide Evaluation Report (PER) 12-Factor Analyses Factor A (EPA & Bangladesh Registration and RUP Status) & Factor E (Acute/Chronic Toxicological Hazards) The primary outcomes of Factor A & E analyses are the allowed AIs listed above in the left column. Pesticides that are rejected by these analyses (Annex 17) cannot be procured and/or used in any way by AIP (USAID) funds that go to retailers or plot demonstrations. Pesticides containing paraquat are still found in many small agrodealer shops, and small-scale farmers should be encouraged by the AIP to not use them. Endosulfan may still be found, especially in areas where cotton is and was grown, and in 2011 it was added to the POPs list for phase out in countries that use it. Endosulfan (an organochlorine insecticide which is highly toxic and persists in the environment) is a USEPA restricted use pesticide which USAID/LAC no longer approves for any use. USEPA will completely phase out its use by Several safer alternatives to these older types of chemicals now exist. Factor B (Pesticide Selection Basis): Farmers Select Pesticides by Agrodealer Advice and Cost Most (85%) small-scale farmers observed during this study in Bangladesh have at most 2-3 small (250ml to 500ml) bottles of pesticides for use on their pond-bund structures, fields and fruit tree stands. Those that do use pesticides often do so based upon the advice of agrodealers or neighbors. And, they will often select the lowest cost pesticides, which is not ideal, as they should also focus on attributes such as quality, safety, reliability, and trusted brands. Some domestic products may currently or eventually be considered to be of quality, safe, reliable and trusted USAID/Bangladesh AIP PERSUAP 10

28 Just the fact that a few farmers will already value or buy and use pesticides, even the cheapest pesticides, provides a market entry point for name-brand products once their benefit for cost per value is realized. This PERSUAP makes pesticide selections based upon registration, safety and resistance management. And, it encourages the AIP to promote quality, safe, reliable and trusted pesticides where applicable. Factor C (IPM): Little use of IPM & Factor I (Chemical and Non-Chemical Alternatives Available): Little use of Chemical and Non-Chemical Alternatives Most small-scale farmers use very few preventive non-chemical IPM tools and tactics on row crops, root crops, vegetables and fruits. Exceptions may include small-scale production of highvalue crops cotton, groundnuts, sugarcane, soybeans, some export fruit crops, and betel nut and leaf. Commercial or estate farms growing high-value crops will have incentives to produce clean produce for export. In general, they have higher access to high levels of resources, education, information and training, and they actively use preventive IPM tools and tactics to the maximum in order to reduce costs and pesticide residues. Within in the project area inside the FTF zone, there were few commercial or estate farms observed. These included some jute plantations as well as a large (11 ha) farms that grew off-season watermelons, jute and fruit trees. This PERSUAP provides the beginnings of Pest Management Plans (PMPs) in Annex 1. This annex contains numerous non-chemical preventive measures and curative chemical pesticide choices for primary crop-pest pairs likely to be encountered in Bangladesh on crops supported by current or future AIP activities. AIP training on these elements will further socialize and raise awareness of the importance and benefits of using an IPM approach to agricultural production, including pesticide rotation and cost savings by using some preventive tools. Factor D (Pesticide Application & Safety Equipment): Knapsack Sprayers Leak onto Users. Hand-pump backpack sprayers, used by smalland medium-scale farmers, among others, can and do eventually develop leaks at every junction where sprayer parts meet (filler cap, pump handle entry, exit hose attachment, lance attachment to the hose and at the lance handle) and these leaks soak into exposed skin. Moreover, clothing serves as a wick that holds these pesticides in constant contact with the skin. Unless the clothes are washed immediately after use, other family members may also come in contact with pesticide residues. AIP is recommended to look into the possibility of the development and use of professional spraying and record-keeping services. Such services would be aware of and help promote the abeyance of sprayed field REI (Re-Entry Interval) and PHI (Pre-Harvest Interval) to farmers. These services can be designed to be accessible by farmers at congregation places (farm stores/retailers, cooperatives, associations, produce consolidation/cold storage/processing sites). Such services will be encouraged to properly maintain spray equipment and use recommended PPE. In the absence of such spray services, AIP activities, retailers, and its field demo partners are recommended to promote and teach proper sprayer maintenance and repair, and post-spraying hygiene during training. Farmers and some Fumigators do not use Personal Protection Equipment. Very few small-scale producers have access to, or can afford, or will use Personal Protection Equipment (PPE) when applying pesticides. Larger-scale certified estate farms have, and make their farm laborers use, PPE. Other than a paper or cloth filter mask that 2013 USAID/Bangladesh AIP PERSUAP 11

29 accompanies some backpack sprayer purchases often found inside the sprayer tank, most village and city agrodealers/retailers visited do not stock any appropriate PPE. Provision of low-cost or subsidized very basic PPE, such as gloves and mask, and repeated training on pesticide risks and the use of appropriate (for the pesticide) PPE are recommended for reducing risks to users. In order to ensure this, the use of PPE in demonstration plots needs to be monitored by the AIP throughout the LOP. At a bare minimum, gloves should be used by those who first open and pour out concentrated pesticide product from the bottle. This recommendation should be added to the implementation plan, and is in the EMMP section covering pesticide use. Concentrated product is the most risky; once it becomes mixed with water, and diluted, risks of poisoning begin to decrease. A list of suppliers of PPE in Bangladesh is included in Annex 8. Although in Bangladesh the team found no to very little pesticide sub-dividing from the manufacturer s bottle to unmarked water or other bottles, AIP is recommended to encourage farmers to purchase pesticides only from reliable retailers and companies and in the original bottles with safety labels. Females, Immune-Compromised Pesticide Applicators, and Children. Most (85%) small-scale farmers observed during this study in Bangladesh have at most 2-3 small (250ml to 500ml) bottles of pesticides for use on their pond-bund structures, fields and fruit tree stands. Pesticide risks to females include reproductive and developmental risks to developing fetuses, as well as endocrine disruption, which can affect hormone production. Mother s milk can contain fat-soluble pesticides. Immune-compromised retailers and farmers that are HIV positive or have tropical diseases such as TB (tuberculosis) or malaria are at additional risk because health risks are generally cumulative. Some female farmers and immune compromised individuals will use pesticides on their crops. Pesticides add additional stresses to the health of individuals who are pregnant, lactating or immune compromised. Furthermore, farmers often store pesticides in the original containers in the home. This increases the risks that children will get access and accidentally ingest them. And it increases the risks that other household members, like maids, could possibly confuse these with cooking or cleaning supplies. AIP is recommended to discourage pregnant and lactating female retailers and farmers, as well as immune compromised (HIV, TB, malaria, and so on) individuals, from using pesticides. All pesticide applicators, including women, need to use recommended PPE. Project staff should train retailers and farmers on the risks to households, in particular to children, and the need to secure pesticides from them. No Proper Disposal of Empty Pesticide Bottles. Empty pesticide bottles are thrown in the field, burned, buried or sometimes reused. In many places Crop Life International is working to develop a system for collecting empty bottles for disposal or recycling. Ideally, empty bottles would be collected, cleaned properly and recycled into plastic objects like fence posts. In the absence of such a collection and recycling system, the next best approach is to wash, puncture and burry empty bottles. Burning them creates toxic and carcinogenic fumes. AIP should recommend that all farmers triple-rinse (to remove pesticide residues) empty containers into their backpack sprayers or in the field 30 meters away from open water and wells, puncture the empty container (so it cannot be reused) and buried USAID/Bangladesh AIP PERSUAP 12

30 Factor E (Acute/Chronic Toxicological Hazards) All Pesticide AIs Present Risks & Factor G (Target and Non-Target Hazards) Pesticides Kill More Than Target Pests In addition to acute and chronic human health hazards and water pollution risks of the proposed chemicals almost all pesticide AIs, as well as many household chemicals, present some degree of additional chronic risks to people including potential carcinogenic, endocrine, developmental and reproductive risks. And, almost all pesticide AIs present risks to some other organisms, including fish, honeybees, birds, amphibians, earthworms, mollusks, crustaceans, aquatic insects and plankton. Moreover, natural pesticide AIs extracted from plants and microbes carry these risks as well. For pesticides that possess chronic health risks for humans, pesticide users need to be encouraged even more to use appropriate PPE. For pesticides highly or very highly toxic to honeybees, all spraying should be done late in the day when the winds have calmed and bees are at the hive. For pesticides highly or very highly toxic to aquatic organisms, application should not be done within 30 meters of open water. AIP is recommended to provide training on these best practices, and to help monitor to ensure retailers and farmers are following these recommended best practices. Factor F (Pesticide Effectiveness): Variable Product Quality, Development of Pesticide Resistance This PERSUAP does not, and cannot, make pesticide brand or content quality determinations or distinctions; the body that can and should do this is Bangladesh DAE-PPW, when it tests, accepts, registers, samples and controls pesticide products entering Bangladesh. Therefore pesticides that are registered by DAE-PPW should be trusted to be of reliable quality, safety, and consistency. Pesticide resistance can become a problem when the same chemicals are used over and over to control a particular pest. After a period of time, the pest may develop resistance to a chemical so that the chemical no longer effectively controls the pest at the same rate. Higher and higher rates or dosages and more frequent applications become necessary until eventually the chemical ceases to provide adequate control. AIP can encourage beneficiaries to use reliable quality DAE-PPW-registered products accepted by this PERSUAP, and rotate pesticides from one class or type of chemical to another to reduce the development of pesticide resistance. Factor H (Climate, Flora, Fauna, Geography, Hydrology, and Soils Pesticide Use Conditions): The Lack of Use of GAPs Can Lead to Damage of Natural Resources The 2010 USAID Foreign Assistance Act (parts 118/119) update on the Conservation of Tropical Forests and Biodiversity in Bangladesh provides ample information on the natural resources at risk from multiple threats. Principal among them is agriculture. See: The overwhelming majority of deforestation, soil erosion and loss of fertility, as well as loss of biodiversity, is due to agricultural land use by small-scale producers. Alternatively, in general in most countries, the vast majority of pesticide pollution comes from large-scale commercial and estate farms. The AIP is recommended to promote GAPs and IPM to retailers and farmers in order to improve agricultural production among small- to medium-scale farmers, so that natural resources are put at lower risk USAID/Bangladesh AIP PERSUAP 13

31 Factor J (Host Country Pesticide Management Abilities): A Lack of Resources Can Lead to Increased Risks Most emerging market countries, Bangladesh included, do not have sufficient resources to do all that is needed to better manage pesticides and use. As noted above, a few toxic pesticides are still found in Bangladesh, and the extension service cannot reach most farmers. The lack of resources leads to increased risks. Fortunately, projects from developed market countries help fill this resource gap, often serving as de facto extension services. What this means is that donor projects also have a responsibility to know about, understand, and promote the best practices and recommendations available. For the AIP, this PERSUAP, and the information in it, is meant to assist with this challenge. See, e.g., papers that address risks and opportunities in the broader sphere of food security and the environment: Factor K (Training): Limited IPM and Pesticide Safety Training of Implementers and Beneficiaries Bangladesh retailers and farmers have had limited national and donor assistance with farmer IPM and pesticide safety training. As a follow-up to this PERSUAP, this PERSUAP recommends that such training should be performed by the AIP for select leader beneficiaries (the retailers, previously trained supply chain staff and trainers, and other AIP field demonstration plot collaborators), on AIP project activities. The AIP project is expected to use the GAP/IPM information in Annex 1 as well as hot-linked pesticide safety websites referred to in this PERSUAP to train beneficiaries. Factor L (Monitoring): Small Scale Farmers do not Monitor or Keep Farm Records Bangladesh small-scale farmers do not keep records of information on crops grown, production, pest attack, pesticides used, if the pesticides worked well or not, and post-harvest intervals to reduce pesticide residues. Certified large-scale commercial and estate farms, on the other hand, generally keep detailed records. As small and medium scale farmers move further toward producing certified (Organic, FairTrade, GlobalGAP, British Retail Consortium BRC) export crops, they will need to be taught how to do proper record keeping. This PERSUAP recommends that the AIP teach this during training of retailers, supply partners, and reinforce at demonstration plots. How to Use this PERSUAP Efficiently The best way to use this document is to focus on the parts that apply to the crops produced, the pests of each and the preventive and curative tools and tactics, including pesticides. To do this efficiently, search this document for the crops or pests (common or scientific name) using the Word computer program s Find feature, which allows one to enter the word or phrase desired, and then takes one to the exact parts of the report where the word or phrase is used. Specific pesticide active ingredients in Annexes 1 and 7 can be found using the same method USAID/Bangladesh AIP PERSUAP 14

32 Pictures and common and scientific names of common agricultural pests in Bangladesh can be found at: Update the Report Annually (next in September 2014) and Amend the Report in Two Years New pesticides and EPA registrations change weekly. In addition, new human health and environmental data is produced continuously. For these reasons and others, this PERSUAP should be updated at least annually, and amended, if significant (more than 10) pesticide registration changes are found by AIP staff in charge of environmental compliance, and after two years in order to remain current and accurate USAID/Bangladesh AIP PERSUAP 15

33 SECTION 1: INTRODUCTION 1.1 Purpose, Scope & Orientation Purpose: In compliance with USAID s Pesticide Procedures (22 CFR 216.3(b)), this 2013 Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP) for the USAID/Bangladesh Agro-Inputs Project portfolio of activities: Establishes the set of pesticides for which support is authorized on USAID/Bangladesh AIP activities. Support includes purchase, direct use, recommending for use, financing, and other actions that directly facilitate the procurement and/or use of pesticides. 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 the PERSUAP. Scope: Specifically, this PERSUAP covers the AIP. Orientation: The set of authorized pesticides and requirements for safer use are established through Section 3 of the document, the Pesticide Evaluation Report (PER), which assesses the 12 pesticide risk evaluation factors (A through l) required by 22 CFR 216.3(b). The Safer Use Action Plan (SUAP, Section 4) provides a succinct, stand-alone statement of compliance requirements, synthesized from the 12-factor analysis. It also provides a template for assigning responsibilities and timelines for implementation of these requirements. 1.2 USAID Environmental Regulations Development From 1974 to 1976, over 2,800 Pakistan malaria spray personnel were poisoned (5 to death) by insecticide mishaps on a USAID/WHO anti-malaria program 3. In response to this and other incidents arising from USAID programs, a lawsuit was brought by a coalition of environmental groups for USAID s lack of environmental procedures for overseas projects. USAID, in response to the lawsuit, drafted 22 CFR 216 (Reg. 216). This regulation, which was updated in 1979 to include extraterritorial affairs in response to changes in the scope of the application of the National Environmental Policy Act (NEPA), now guides most USAID activities that could have potentially negative environmental impacts. 1.3 Title 22, Code of Federal Regulations, Part 216 (22 CFR 216) According to Title 22, Code of Federal Regulations, Part 216 (22 CFR 216), all USAID activities are subject to analysis and evaluation via at minimum an Initial Environmental Examination (IEE), and at maximum an Environmental Assessment (EA). Only one IEE (Asia 12-29) on economic growth, agriculture and food security was written in 2012 that covers the AIP, among others. It recommended (on page 17) that a PERSUAP be produced to deal with reducing risks from the use of pesticides on AIP. This 2013 AIP PERSUAP responds to those IEE recommendations USAID/Bangladesh AIP PERSUAP 16

34 A large part of Title 22, Code of Federal Regulations, Part 216 (22 CFR 216) is devoted to pesticide use and safety. Sub-Part requires that if USAID is to provide support for the use of pesticides in a project, 12 pesticide factors must be analyzed and recommendations be written to mitigate risks to human health and environmental resources. This plan must be followed up with appropriate training, monitoring and reporting for continuous improvement on risk reduction and adoption of international best practices for crop production, protection and pesticide use safety, and is strongly encouraged. 1.4 The Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP) In the USA, the EPA can rely on the following safety-enhancing factors and features, not present to the same degree in most emerging market countries including Bangladesh: An educated literate population of retailers and farmers and farm laborers Quality IPM information and Pest Management Plans (PMPs) A well-functioning research and extension system to extend IPM information to farmers Certification systems for farmer training on restricted and other pesticides Quality affordable PPE to reduce pesticide exposure Quality pesticide labels and Material Safety Data Sheets (MSDS) to guide farmer safety Accurate information and training on pesticide use, transport, storage and disposal Because of the differences in infrastructure and resource availability, USAID and US regulations require location-specific analysis of pesticide use in emerging market countries, and development of procedures to promote safer use. In the late 1990s, USAID s Bureau for Asia staff developed the Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP) a tool to analyze the pesticide system or sector in any given country or territory. The PERSUAP tool which was not envisioned and is not contained per se in the language of Title 22, Code of Federal Regulations, Part 216 (22 CFR 216) focuses on the particular circumstances, crops, pests and IPM/pesticide choices of a project or program. This systems approach analyzes the pesticide sector or system from registration to import through use to disposal, and develops a location-specific pesticide risk profile based on the analysis. A PERSUAP is generally recommended by and submitted as an amendment to the program or project IEE or an EA (although most PERSUAPs are very similar to an EA in terms of breadth and detail). Although not actually an explicit goal of the PERSUAP, the application of PERSUAP recommendations has additional benefits. It helps to prepare project participants to be able to more rapidly adopt Best Management Practices (BMPs) and meet the needs of Standards and Certification (S&C) Systems like GlobalGAP, Organic, Fair Trade, Rainforest Alliance, British Retail Consortium and other S&C systems, as desired, for future market access. 1.5 Integrated Pest Management USAID Policy In the early 1990s, USAID adopted the philosophy and practice of Integrated Pest Management (IPM) as official policy. IPM is also strongly promoted and required as part of Regulation Since the early 2000s, IPM which includes judicious use of safer pesticides has been an integral part of GAPs and is increasingly considered to constitute best management practices in agriculture USAID/Bangladesh AIP PERSUAP 17

35 A good definition of IPM from OECD 4 follows: Integrated pest management (IPM) is an approach to the management and control of agricultural pests which relies on site- and condition-specific information to manage pest populations below a level that causes economic injury and that minimizes risks to humans and the natural environment. Although any among a wide range of pest control agents may be used (including chemical sprays), IPM generally stresses the use of alternatives, such as crop rotations, mechanical cultivation, and biological agents, where such methods are deemed to be effective. The strongest selling points for IPM beyond the health and environmental benefits are, that IPM: Is, in the long run, more effective than using synthetic pesticides Is, once-established, self-perpetuating to a degree Is less damaging to essential soil health and nutrient cycling Leaves fewer pesticide residues that confound international trade Generally requires less capital (but more labor) investment Can be used preventively to eliminate or minimize the need for responsive controls (e.g. applying pesticides after a pest outbreak occurs to an already-damaged area) IPM can include possible pest management techniques and tools including: Soil and water tests, raised-bed production, tunnels, drip-irrigation 5 Pest scouting, monitoring, and identification for accurate decision-making Cultural methods that promote pest avoidance and a healthy plant that can better tolerate or resist pests. These methods include, but are not limited to, use of resistant varieties, early/late plantings/harvestings, crop rotation, pruning diseased parts, destruction of pest refuge plants near fields and in crop residues, and GAP practices Natural pest control by encouraging and protecting (or purchase and release of) parasitoids, predators, and pest diseases Mechanical weed or insect pest control using manual, hoe and machine practices Chemical practices such as use of judicious, knowledgeable, and safe application of natural (derived from nature; extracted from plants, microbes, and other organisms) or synthetic pesticides Good soil characteristics are essential to plant health. For most crops, soils need to provide adequate nutrients and moisture and be well drained. A healthy soil will have a greater capacity to moderate the uptake of fertilizers and will allow a more balanced uptake of nutrients, creating a healthy plant that is less attractive to some pests and more resistant to pest damage. 1.6 Bangladesh PERSUAP Methodology and Scopes of Work (SOW) USAID Bangladesh mission requested that this AIP PERSUAP be produced to respond to needs found in the Bangladesh IEE covering agriculture and AIP s activities. CNFA financed and implemented this work, and the Bangladesh USAID mission supported the study with the IEE, information, and good advice Note that drip irrigation does not re-charge underground aquifers, so water must be used carefully USAID/Bangladesh AIP PERSUAP 18

36 The complexity of the tasks needed for this study required that the consultant provide wideranging and cutting-edge IPM, agronomic, business, entomological, phytopathological, rodentological, weed and chemical advice, in addition to environmental compliance interpretation. In order to make this PERSUAP study unbiased and as objective as possible, pesticide Active Ingredients (AIs) were chosen as the common denominator for analysis, and product brand names were avoided. The strategy used for writing this PERSUAP is for it to contain as many links to websites with best practices as possible, both to make it easier to use (reduce the report s length and thickness) and more up-to-date or accurate (as websites are updated, but static information is not). So, instead of having numerous Annexes containing pesticide safety equipment recommendations or safe pesticide use practices, hot-linked websites now take their place. However, if project participants do not have access to the Internet, the AIP should reproduce and distribute key information. The scopes of work (SOWs) for this work are attached as Annex 13. SECTION 2: BACKGROUND 2.1 Country Background Bangladesh is situated at the downstream of the watershed of a sprawling, inter-linked basin of three great river systems the Ganges, Meghna and Brahmaputra. Its extensive alluvial soils, abundant water resources and biological diversity all contribute to a rich and varied natural economy. Yet, Bangladesh has one of the world s poorest populations. The situation presents a paradox of poverty in the midst of plenty. The total area of Bangladesh is 147,570 km2, an area roughly the size of the state of Wisconsin, with a Deltaic geomorphology similar to the state of Louisiana. Bangladesh has the highest population density (more than1000 persons per km2) of any non-city state in the world. The estimated population in 2009 is more than 150 million (up from 90 million in 1981) and may not stabilize before reaching 250 million. Almost half of the population lives below the poverty line. Although the current population growth rate is declining towards 1 percent, a drop from three percent only 25 years ago, this is still a major concern because of the density and size of the existing population, and increasing pressures on natural resources and the environment. Bangladesh Agriculture and Natural Resource Base to Support It The contribution of agriculture and natural resources needed to do agricultural production to livelihoods and to Bangladesh s economy is immense, straddling the fisheries and forestry sectors. The people of Bangladesh depend on biodiversity for their day-today sustenance as well as overall livelihood security. More than 80% of the rural population is directly or indirectly dependent on open access natural resources. Over 60 million people are directly dependent on aquatic resources on a daily basis. An estimated 1.3 million people are full-time fishermen and another 11 million fish on a part-time basis. Fifty to sixty-five per cent of the country s protein requirement is met by the consumption of fish. The fisheries sector contributes about 5% of the GDP of Bangladesh, earning 11% or more of total export revenue, and employing about 20% of the country s total work force. Agriculture and forestry activities together provide approximately two-thirds of the country s employment, contributing about 20% of GDP USAID/Bangladesh AIP PERSUAP 19

37 The Sundarbans alone provide livelihoods and employment to an estimated 112,000 people. About 335,000 people are now involved in social forestry activities in rural areas. These people plant trees in the Government land and guard them until maturity. Once the trees are harvested the people and the Government share the profit. Bangladesh agro-ecological zones Figure 1: Bangladesh Agro-Ecological Zones Above and beyond the statistics on agriculture and the natural resource sector s contribution to the national economy lies another striking fact that is related to the existing national focus on land use. Wetlands have been historically considered as wastelands, and conversion of those lands for agricultural and other uses has been a common practice. This is directly related to the need to increase agricultural production to feed the growing populace. Many coastal mangroves have been converted for shrimp farming. Side by side, infrastructure and other development activities have contributed to the destruction of productive ecosystems, without giving any consideration to the economic and ecological value of these resources. Vast areas of pristine evergreen forests had submerged and destroyed, and the ethnic communities of 2013 USAID/Bangladesh AIP PERSUAP 20

38 the area had to be shifted, due to the dam and hydro-electricity plant in Kaptai, Rangamati. The cost of inaction regarding ecosystem degradation is extremely high; conversely, the benefits of action may be extremely rewarding. The information below on Bangladesh geography/topography, natural resources including plant and animal resources, bio-ecological zones, soils, climate and rainfall, hydrology, and protected areas all give a flavor of the country, and its tremendous resource base upon which agriculture both depends and must protect. The geography of Bangladesh is captured well by Wikipedia 6. Bangladesh is a low-lying, riverine country located in South Asia with a largely marshy jungle coastline of 710 km (441 mi) on the northern littoral zone of the Bay of Bengal. In fact, surface water and hydrology are its main feature much of the country is submerged in one way or the other. Figure 2: Bangladesh Geography and Topography The physical geography of Bangladesh is varied and has an area characterized by two distinctive features: a broad deltaic plain subject to frequent flooding, and a small hilly region crossed by swiftly flowing rivers. The country has an area of 147,570 square kilometers and extends 820 kilometers north to south and 600 kilometers east to west. Bangladesh is bordered on the west, north, and east by a 4,095- kilometer land frontier with India and, in the southeast, by a short land and water frontier USAID/Bangladesh AIP PERSUAP 21

39 (193 km) with Burma (Myanmar). On the south is a highly irregular deltaic coastline of about 580 kilometers, fissured by many rivers and streams flowing into the Bay of Bengal. The territorial waters of Bangladesh extend 12 nautical miles (22 km), and the exclusive economic zone of the country is 200 nautical miles (370 km). Roughly 80% of the landmass is made up of fertile alluvial lowland called the Bangladesh Plain. The plain is part of the larger Plain of Bengal, which is sometimes called the Lower Gangetic Plain. Although altitudes up to 105 meters above sea level occur in the northern part of the plain, most elevations are less than 10 meters above sea level; elevations decrease in the coastal south, where the terrain is generally at sea level. With such low elevations and numerous rivers, water and concomitant flooding is a predominant physical feature. About 10,000 square kilometers of the total area of Bangladesh is covered with water, and larger areas are routinely flooded during the monsoon season. The only exceptions to Bangladesh's low elevations are the Chittagong Hills in the southeast, the Low Hills of Sylhet in the northeast, and highlands in the north and northwest. The Chittagong Hills constitute the only significant hill system in the country and, in effect, are the western fringe of the north-south mountain ranges of Burma and eastern India. The Chittagong Hills rise steeply to narrow ridgelines, generally no wider than 36 meters, with altitudes from 600 to 900 meters above sea level. At 1,052 meters altitude, the highest elevation in Bangladesh is found at Mowdok Mual, in the southeastern part of the hills. Fertile valleys lie between the hill lines, which generally run north-south. West of the Chittagong Hills is a broad plain, cut by rivers draining into the Bay of Bengal, that rises to a final chain of low coastal hills, mostly below 200 meters, that attain a maximum elevation of 350 meters. West of these hills is a narrow, wet coastal plain located between the cities of Chittagong in the north and Cox's Bazar in the south. About 67% of Bangladesh's nonurban land is arable. Permanent crops cover only 2%, meadows and pastures cover 4%, and forests and woodland cover about 16%. The country produces large quantities of quality timber, bamboo, and sugarcane. Bamboo grows in almost all areas, but highquality timber grows mostly in the highland valleys. Rubber planting in the hilly regions of the country was undertaken in the 1980s, and rubber extraction had started by the end of the decade. A variety of wild animals are found in the forest areas, such as in the Sundarbans on the southwest coast, which is the home of the Royal Bengal Tiger. The alluvial soils in the Bangladesh Plain are generally fertile and are enriched with heavy silt deposits carried downstream during the rainy season. Bangladesh Wild Plant Diversity The number of species of plants in Bangladesh is still not completely known (Table 2). It is thought that many species are disappearing before they can be scientifically described and classified. Khan et al. (2001) listed 106 species of plants under the categories of threatened (Critically Endangered, Endangered, and Vulnerable), Lower Risk, Data Deficient, and Not Evaluated, including two or three species of ferns, four species of gymnosperms and approximately 100 species of angiosperms (Appendix I). Of these, the palm Corypha taliera is considered as Critically Endangered, the last surviving individuals of the species in the world being limited to Bangladesh USAID/Bangladesh AIP PERSUAP 22

40 Number of Wild Plant Species in Bangladesh Categories Recorded Estimated Algae 3,600 6,000 Bryophytes Pteridophytes Gymnosperms 5 5 Angiosperms 3,000 5,000 Bangladesh Wild Animal Diversity Information on animal diversity in Bangladesh remains incomplete, the vertebrates probably being the best-known group. The high diversity of fishes and birds relative to the size of the country is notable. Tentative numbers of species are as follows: Monera (eubacteria etc.) 166 Protista (protozoa, viruses, etc.) 341 Animalia: invertebrates Poriferans 7 Cnidarians 68 Platyhelminths 23 Nematodes 105 Annelids 62 Arthropods 1547 Molluscs 347 Echinoderms 6 Animalia: vertebrates Fishes 653 Amphibians 34 Reptiles 154 Birds 650 Mammals 120 Bangladesh Invasive Alien Species Decision VI/23 of the Sixth Conference of the Parties (COP6) of the Convention on Biological Diversity (CBD) defines invasive alien species as non-native species whose introduction and/or spread threaten biological diversity. Invasive alien species compete and suppress the survival of native species, rendering habitats vulnerable to fire and deterioration. Plants: Of the invasive alien plant species known from Bangladesh, the most important of these include the following: Eichhornia crassipes (Kachuri pana) Eupatorium odoratum (Ayapan) Mikania cordata (Assam lota) Croton bonplandianum (Bon khira) Lantana camara (Nak phul) Leucaena leucocephala (Teli kadam) Acanthospermun hispidum (Katahara) Cassia occidentalis (Kasundi) Ageratum conyzoides (Goat weed, ghag) Alternanthera flocoidea (Hechi) Atylosia scarabaeoides, Commelina obliqua (Jotakansira) 2013 USAID/Bangladesh AIP PERSUAP 23

41 Convolvulus arvensis, Evolvulus nummularius (Bhuiokra) Hyptis suaveolens (Bon topma) Ipomoea fistulosa (Dolkalmi) Ludwigia adscendens (Keshordham) Mimosa pudica (Lajjaboti) Eichhornia crassipes (Kachuri pana) is a widespread weed of freshwater ecosystems. Eupatorium odoratum (Ayapan) and Mikania cordata (Assam lota) are invaders of terrestrial ecosystems that overtop the canopy of shrubs and young tree saplings. Croton bonplandianum (Bon khira) and Lantana camara (Nak phul) grow along the edges of forest and wastelands and invade local vegetation communities. Animals: Little information is available on invasive alien animal species in Bangladesh (Rashid 2004). The introduction of alien animal species, particularly fish, began in the early 1950s, primarily to increase food production. To date, at least 32 fish species have been introduced, but their impact on indigenous species has not been thoroughly assessed. Tilapia, consisting of two species, Oreochromis mosambicus and O. niloticus, are of greatest concern because they have invaded all available habitats, including estuaries. Bangladesh Genetic Diversity The natural ecosystems and diverse agro-ecosystems of Bangladesh are rich in plant and animal genetic resources. Local communities have selected and conserved genetic variations of plants and animals in the various agro-ecological zones for centuries. Recently, there have been organized efforts aimed at preserving genetic diversity by both governmental and non-governmental agencies, which have built up large germplasm collections. The Bangladesh Agricultural Research Institute and Bangladesh Jute Research Institute are preserving germplasm of crop, rice and jute varieties. The Bangladesh Agricultural University is conserving germplasm of traditional and non-traditional fruits, while the Bangladesh Forest Research Institute is maintaining germplasm of rattans, bamboos, timber trees and medicinal herbs. Plant Diversity: Domesticated plants in Bangladesh range from rice and millets to tubers such as Dioscorea (yam), Colocasia (taro), Ipomoea batatus (sweet potato), legumes, oil seeds, vegetables, fruits, spices and fiber (cotton and jute). Six thousand varieties of rice (Oryza sativa) are known to have existed in the country. Animal Diversity: Domesticated animal biodiversity in Bangladesh is largely limited to livestock (primarily cattle, goats, sheep and buffalo) and poultry (primarily chickens and ducks), to species raised in aquaculture operations (primarily fish), and to a very limited extent to domestic pets (dogs, cats, ornamental fish) USAID/Bangladesh AIP PERSUAP 24

42 Figure 3: Bangladesh Bio-Ecological Zones Bangladesh Soil Resources The intricate river system systems of Bangladesh drain a basin of some 1.76 million square km and carry not only snowmelt water from the Himalayas but also runoff water from some of the highest rainfall areas of the world. Over tens of thousands of years, the sediments carried by the huge discharges of these rivers have built a broad delta, forming most of the large area of Bangladesh and the submerged delta-plain in the Bay of Bengal. These huge sediments are the major sources of formation of 80% soils of the country. The remaining 20% of soils have been formed in Tertiary and Quaternary sediments of hills (12 %) and in uplifted Pleistocene terrace (8%). Two distinct conditions occur in Bangladesh regarding soil formation: alternating seasonal wet or inundated and dry conditions, as prevalent on most of the floodplain areas, and intermittently wet or moist or dry conditions on the upland areas of terraces and hills. The soil formation process differs significantly between floodplain, hill and uplifted terrace. In the floodplains, there are active, young and old floodplain landscapes. Active floodplains occupy land within and adjacent to the main rivers where shifting channels deposit and erode new sediments during the annual floods. Newly deposited alluvial soil within this floodplain is 2013 USAID/Bangladesh AIP PERSUAP 25

43 stratified in different layers. Usually, silt and clay deposits are finely stratified, and sand deposits, as well as mixed sand and silt deposits are coarsely stratified. Figure 4: Bangladesh Soil Types The young and old floodplains are virtually stable land that the main river channel has moved away, but they are crossed by tributary or distributary channels that vary from active to moribund delta. The Madhupur clay floodplain terrace was uplifted and formed a terrace above sea level before the Late Pleistocene. Since then it has been subject to the action of soil forming processes. Soils have been developed in the two kinds of Madhupur clay: the deeply weathered pervious clay and little altered impervious clay. They vary considerably in drainage, depth of solum and degree of profile development, depending on the extent of weathering of the parent material parent and the topography. Hill soil forming processes, which formed the far Eastern edge of the country bordering Burma, are active for a significant and continuous period. Erosion on steep slopes of high hills, the weathered material on the hills is constantly removed and thus keeps the soils young on the high hills. The soils on the lower hills are older as erosion is less severe and allows soil material to accumulate. The sedimentary rocks underlying steep to very steep high hill ranges are usually hard and relatively rich in weatherable minerals and lower hills are unconsolidated and poor in weatherable minerals. Soils have been developed from these minerals through prolonged 2013 USAID/Bangladesh AIP PERSUAP 26

44 weathering under well to excessively drained conditions, leaching, acidification and removal of surface material by erosion. There is an increase of clay content from surface to subsoil indicating clay illuviation in most of the soils formed in the low hills. Bangladesh Climate: Rainfall & Temperatures Climate Bangladesh has a tropical monsoon climate characterized by wide seasonal variations in rainfall, high temperatures, and high humidity. Regional climatic differences in this flat country are minor. Three seasons are generally recognized: a hot, muggy summer from March to June; a hot, humid and rainy monsoon season from June to November; and a warm-hot, dry winter from December to February. In general, maximum summer temperatures range between 38 and 41 C (100.4 and F). April is the hottest month in most parts of the country. January is the coolest month, when the average temperature for most of the country is C (61 68 F) during the day and around 10 C (50 F) at night.. Figure 5: Rainfall in Bangladesh, Winds are mostly from the north and northwest in the winter, blowing gently at 1 to 3 kilometers per hour (0.6 to 1.9 mph) in northern and central areas and 3 to 6 kilometers per hour (1.9 to 3.7 mph) near the coast. From March to May, violent thunderstorms, called northwesters by local English speakers, produce winds of up to 60 kilometers per hour (37.3 mph). During the intense storms of the early summer and late monsoon season, southerly winds of more than 160 kilometers per hour (99.4 mph) cause waves to crest as high as 6 meters (19.7 ft) in the Bay of Bengal, which brings disastrous flooding to coastal areas. Rainfall Heavy rainfall is characteristic of Bangladesh causing it to flood every year. With the exception of the relatively dry western region of Rajshahi, where the annual rainfall is about 1,600 mm (63.0 in), most parts of the country receive at least 2,300 mm (90.6 in) of rainfall per year. Because of its location just south of the foothills of the Himalayas, where monsoon winds turn west and northwest, the region of Sylhet in northeastern Bangladesh receives the greatest average 2013 USAID/Bangladesh AIP PERSUAP 27

45 precipitation. From 1977 to 1986, annual rainfall in that region ranged between 3,280 and 4,780 mm (129.1 and in) per year. Average daily humidity ranged from March lows of between 55 and 81% to July highs of between 94 and 100%, based on readings taken at selected stations nationwide in About 80% of Bangladesh's rain falls during the monsoon season. The monsoons result from the contrasts between low and high air pressure areas that result from differential heating of land and water. During the hot months of April and May hot air rises over the Indian subcontinent, creating low-pressure areas into which rush cooler, moisture bearing winds from the Indian Ocean. This is the southwest monsoon, commencing in June and usually lasting through September. Dividing against the Indian landmass, the monsoon flows in two branches, one of which strikes western India. The other travels up the Bay of Bengal and over eastern India and Bangladesh, crossing the plain to the north and northeast before being turned to the west and northwest by the foothills of the Himalayas. Natural calamities, such as floods, tropical cyclones, tornadoes, and tidal bores destructive waves or floods caused by flood tides rushing up estuaries ravage the country, particularly the coastal belt, almost every year. Between 1947 and 1988, 13 severe cyclones hit Bangladesh, causing enormous loss of life and property. In May 1985, for example, a severe cyclonic storm packing 154-kilometre-per-hour (95.7 mph) winds and waves 4 meters (13.1 ft) high swept into southeastern and southern Bangladesh, killing more than 11,000 persons, damaging more than 94,000 houses, killing some 135,000 head of livestock, and damaging nearly 400 kilometers (248.5 mi) of critically needed embankments. Annual monsoon flooding results in the loss of human life, damage to property and communication systems, and a shortage of drinking water, which leads to the spread of disease. For example, in 1988 two-thirds of Bangladesh's 64 districts experienced extensive flood damage in the wake of unusually heavy rains that flooded the river systems. Millions were left homeless and without potable water. Half of Dhaka, including the runway at the Shahjalal International Airport an important transit point for disaster relief supplies was flooded. About 2,000,000 tons (2,204,623 short tons; 1,968,413 long tons) of crops were reported destroyed, and relief work was rendered even more challenging than usual because the flood made transportation of any kind exceedingly difficult. A tornado in April 1989 killed more than 600 people, possibly many more. There are no precautions against cyclones and tidal bores except giving advance warning and providing safe public buildings where people may take shelter. Adequate infrastructure and air transport facilities that would ease the sufferings of the affected people had not been established by the late 1980s. Efforts by the government under the Third Five-Year Plan ( ) were directed toward accurate and timely forecast capability through agrometeorology, marine meteorology, oceanography, hydrometeorology, and seismology. Necessary expert services, equipment, and training facilities were expected to be developed under the United Nations Development Programme USAID/Bangladesh AIP PERSUAP 28

46 Figure 6: Bangladesh temperatures, Bangladesh Hydrology The rivers of Bangladesh mark both the physiography of the nation and the life of the people. About 700 in number, these rivers generally flow south. The larger rivers serve as the main source of water for cultivation and as the principal arteries of commercial transportation. Rivers also provide fish, an important source of protein. Flooding of the rivers during the monsoon season causes enormous hardship and hinders development, but fresh deposits of rich silt replenish the fertile but overworked soil. The rivers also drain excess monsoon rainfall into the Bay of Bengal. Thus, the great river system is at the same time the country's principal resource and its greatest hazard. The profusion of rivers can be divided into five major networks. The Jamuna-Brahmaputra is 292 kilometers long and extends from northern Bangladesh to its confluence with the Padma. Originating as the Yarlung Tsangpo River in China's Xizang Autonomous Region (Tibet) and flowing through India's state of Arunachal Pradesh, where it becomes known as the Brahmaputra ("Son of Brahma"), it receives waters from five major tributaries that total some 740 kilometers in length. At the point where the Brahmaputra meets the Tista River in Bangladesh, it becomes known as the Jamuna. The Jamuna is notorious for its shifting subchannels and for the formation of fertile silt islands (chars). No permanent settlements can exist along its banks. The second system is the Padma-Ganges, which is divided into two sections: a 258-kilometer segment, the Ganges, which extends from the western border with India to its confluence with the Jamuna some 72 kilometers west of Dhaka, and a 126-kilometer segment, the Padma, which runs from the Ganges-Jamuna confluence to where it joins the Meghna River at Chandpur. The Padma-Ganges is the central part of a deltaic river system with hundreds of rivers and streams some 2,100 kilometers in length flowing generally east or west into the Padma. The third network is the Surma-Meghna River System, which courses from the northeastern border with India to Chandpur, where it joins the Padma. The Surma-Meghna, at 669 kilometers 2013 USAID/Bangladesh AIP PERSUAP 29

47 by itself the longest river in Bangladesh, is formed by the union of six lesser rivers. Below the city of Kalipur it is known as the Meghna. When the Padma and Meghna join together, they form the fourth river system the Padma-Meghna that flows 145 kilometers to the Bay of Bengal. This mighty network of four river systems flowing through the Bangladesh Plain drains an area of some 1.5 million square kilometers. The numerous channels of the Padma-Meghna, its distributaries, and smaller parallel rivers that flow into the Bay of Bengal are referred to as the Mouths of the Ganges. Like the Jamuna, the Padma-Meghna and other estuaries on the Bay of Bengal are also known for their many chars. A fifth river system, unconnected to the other four, is the Karnaphuli. Flowing through the region of Chittagong and the Chittagong Hills, it cuts across the hills and runs rapidly downhill to the west and southwest and then to the sea. The Feni, Karnaphuli, Sangu, and Matamuhari an aggregate of some 420 kilometers are the main rivers in the region. The port of Chittagong is situated on the banks of the Karnaphuli. The Karnaphuli Reservoir and Karnaphuli Dam are located in this area. The dam impounds the Karnaphuli River's waters in the reservoir for the generation of hydroelectric power. During the annual monsoon period, the rivers of Bangladesh flow at about 140,000 cubic meters per second, but during the dry period they diminish to 7,000 cubic meters per second. Because water is so vital to agriculture, more than 60% of the net arable land, some 91,000 km², is cultivated in the rainy season despite the possibility of severe flooding, and nearly 40% of the land is cultivated during the dry winter months. Water resources development has responded to this "dual water regime" by providing flood protection, drainage to prevent overflooding and waterlogging, and irrigation facilities for the expansion of winter cultivation. Major water control projects have been developed by the national government to provide irrigation, flood control, drainage facilities, aids to river navigation and road construction, and hydroelectric power. In addition, thousands of tube wells and electric pumps are used for local irrigation. Despite severe resource constraints, the government of Bangladesh has made it a policy to try to bring additional areas under irrigation without salinity intrusion. Water resources management; including gravity flow irrigation, flood control, and drainage, were largely the responsibility of the Bangladesh Water Development Board. Other public sector institutions, such as the Bangladesh Krishi Bank, the Bangladesh Rural Development Board, the Bangladesh Bank, and the Bangladesh Agricultural Development Corporation were also responsible for promotion and development of minor irrigation works in the private sector through government credit mechanisms. Bangladesh Protected Parks, Natural Resources and Species The major protected areas of Bangladesh are listed on Wikipedia, with links to descriptions of each one. See Three Ramsar sites in Bangladesh 7 are Sundarbans, the largest collection of tidal halophytic mangrove forest in the world, and Haors (wetland ecosystems) Hakaluki Haor, and Tanguar Haor. Unwise use or overuse of pesticides can impact any of these aquatic ecosystems adversely, at the local level, especially from commercial farms. Fortunately there are very few large-scale commercial farms in Bangladesh, so the risks are lower. Once pesticides are diluted further downstream, the risks of impact decrease exponentially USAID/Bangladesh AIP PERSUAP 30

48 The Government of Bangladesh (GOB) maintains a website with important protected areas, at National parks number at 17, for a total area of 45,745 hectares. Wildlife sanctuaries also number at 17, for a total of 224,833 hectares. 2.2 USAID Bangladesh AIP Background The Agro-Inputs Project (AIP) is one project that will most certainly work with pesticides. The word inputs guarantees it. The Bangladesh Agricultural Inputs Project (AIP) aims to increase smallholder production and productivity in order to reduce poverty and improve food security in Bangladesh s southern delta. CNFA will achieve this goal through the following objectives: Establishment of Agro-Input Retailers Network: Creation of AIRN, with 3,000 certified retailers in 20 districts, supplying improved agricultural inputs to over 1 million farmers; Market Information Systems: Distribution of 200,000 Monthly Price Outlooks, developed through an innovative GIS-platform Input Market Information System; Quality Control and Standards and Regulatory Constraints: 50 input supply companies and 3,000 retailers adhering to 8 new input quality standards developed by industry associations through advocacy activities with public and private stakeholders; and Local Organizations Qualified to Receive Direct USAID Funding: At least 3 organizations qualified for direct USAID funding, no later than end of PY3. This scope of the project includes 500 demonstration plots and, as of March of 2013, up to 248 chemical active ingredients contained in 3,307 registered chemical pesticide products in an array of agro-ecological zones in AIP s target areas, and with an array of cropping patterns within them. These include retailers and farmers in the lower delta (at or below sea level, where there is a lot of tidal brackish as well as standing fresh water) that produce alternating rice and shrimp/fish cultures in ponds contained by high soil bunds. These soil bunds (that can be one to two meters above the water level) are used in these areas for the production of fruits and vegetables. Further inland and upland (a few centimeters above sea level, where it is relatively dryer, with less flooded, tidal and standing water), farmers produce rice, as well as an array of vegetables, fruits and areca (betel) palm nut and the deciduous betel tree leaf that, along with lime/calcium hydroxide, is chewed with betel 8 for stimulating the senses. Even further upland in one subregion, farmers produce maize and wheat staples, along with vegetables and fruits. AIP areas The following figure shows the working area and locations of intended AIP assistance. They occur mostly throughout the southwest of the country to the center USAID/Bangladesh AIP PERSUAP 31

49 Figure 7: AIP Working Areas by Districts AIP sites for PERSUAP study The AIP works mostly in the zones 11, 12, 13 and 14, above. Below is a map detailing areas where AIP will be active and places to be studied for the PERSUAP USAID/Bangladesh AIP PERSUAP 32

50 Figure 8: AIP visit sites for PERSUAP study 2.3 Other Bangladesh Donor Agriculture Projects Backgrounds Recent Historical and Current Donors in the Agriculture Sector of Bangladesh The top five donors in the agriculture sector are IFDC, DANIDA, IFAD, CIMMYT and CGIAR, as follows, with some major efforts. Their primary activities to contribute to agricultural production over the past five years are listed below USAID/Bangladesh AIP PERSUAP 33

51 IFDC 9 Over the past five years, IFDC has implemented the following fertilizer assistance projects: Urea Deep Placement (UDP) and Fertilizer Deep Placement (FDP) technologies and training; Improved Livelihoods for Sidr-Affected Rice Farmers (ILSAFARM); Market Development in the Fertilizer Sector (Katalyst I); and Fertilizer Compost Licensing Project (Katalyst II) DANIDA 10 Agriculture Sector Programme Support (ASPS Phase II ended in 2012) ASPS II addressed key strategic issues such as: a) capacity development of farmers by involving poor women and men in Farmer Field Schools and promoting the spread of knowledge through training of Farmer Trainers b) promotion of farmers organisations c) development of the negotiating capacity of farmers organisation to formulate and demand adequate agricultural extension services from the public and private sector d) agricultural diversification in particular in livestock and fishery/aquaculture with increased awareness about production, food use and nutrition linkages e) promoting decentralisation in agriculture through capacity development of Union Parishads f) integration of minor road activities into the ASPS with support to rural roads and market access g) capacity development of relevant government department/agencies and h) providing support to the Planning Commission and the line ministries for institutional and policy development. Agricultural Growth and Employment Programme (AGEP) From 2013 to 2017, the Agricultural Growth and Employment Programme will be in line with the priorities of the Government of Bangladesh as set out in the Country Investment Plan (CIP) and the Sixth Five Year Plan. In line with CIP and the Sixth Five Year Plan, Agricultural Growth and Employment Programme will focus, among others, on: Integration of crops, fishery and livestock extension Diversification of agricultural production with special focus on high value crops Formation of producer/marketing groups at village level Agro Business Development IFAD IFAD has been working in Bangladesh for more than 30 years and has developed in-depth knowledge of the country's needs in the areas of infrastructure, inland fisheries, agriculture, markets, microfinance and gender. Based on this experience, and in full alignment with the government's sixth five-year plan, IFAD is committed to supporting more commercial and remunerative livelihoods for farmers and fishers. The IFAD 2012 Country Strategic Opportunities Programme (COSOP) for Bangladesh has three main objectives: Enable poor people in vulnerable areas to better adapt their livelihoods to climate change USAID/Bangladesh AIP PERSUAP 34

52 Help small producers and entrepreneurs benefit from improved value chains and greater market access Economically and socially empower marginalized groups, including poor rural women. The COSOP continues IFAD's successful targeting approach in Bangladesh. The country programme's target group includes people living in extreme and moderate poverty. Its targeting strategy starts by identifying geographic areas of poverty and then assessing household assets and needs including food supply in those areas. CIMMYT Over the past five years, CIMMYT has tested and contributed several new varieties of maize and wheat. These have increased production and have reduced the need for numerous pesticide applications. Most new varieties contain sufficient resistance to pests that pesticides are not needed. CGIAR Bangladesh became a member of the CGIAR in Its official support to the CGIAR and its Centers is provided by the Ministry of Agriculture through the Bangladesh Agricultural Research Council (BARC). BARC's collaborative work with the CGIAR's International Maize and Wheat Improvement Center (CIMMYT) and International Rice Research Institute (IRRI) comprises part of Bangladesh's National Agricultural Research Management project. According to a World Bank study, the collaboration between the international agricultural research centers and the national agricultural research system of Bangladesh has been very important to the growth of agricultural research and agricultural productivity in Bangladesh. The collaboration started in 1966 with the beginning of the International Rice Research Institute's (IRRI) relationship with the Agricultural Research Institute and has involved a number of activities. These activities have involved researching crops and posting center researchers in Bangladesh to work with local researchers on local problems, regular visits by center staff, training programs at the centers or run by the centers, joint programs of germplasm testing and publications. The outcome of this collaboration has been more food production and probably improved income distribution. Modern varieties of rice and wheat have increased the demand for labor, which benefits the landless laborers who are the poorest group in Bangladesh. Increased food production has reduced the real price of food grains, which primarily benefits poorer consumers both in the cities and the countryside. 2.4 Bangladesh Pesticides and Standards Issues Neonicotinoid Pesticides, Risks to Pollinators and Colony Collapse Disorder A group of new (since the late 1990s) neonicotinoid pesticides has, for the past 5 years, been implicated as one among several factors in the unusual die-off of honeybee colonies in the USA and throughout Europe. Other factors include parasitic honeybee mites, viruses transmitted by these mites, climate change, loss of habitat, other pesticides and changes in nutrition. This honeybee die-off phenomenon is named Colony Collapse Disorder (CCD). Neonicotinoid 2013 USAID/Bangladesh AIP PERSUAP 35

53 pesticides registered by Bangladesh DAE-PPW 11 include acetamiprid, imidacloprid, thiacloprid and thiamethoxam. The one neonicotinoid that remains most implicated as a chemical factor in CCD is clothianidin, and it is not registered in Bangladesh. On April 30, 2013, the EU (European Union) imposed a two-year ban on the use of clothianidin, imidacloprid and thiamethoxam on flowering crops pollinated by honeybees, to take effect in December 1, 2013, unless compelling scientific evidence to the contrary becomes available 12. Then, on May 2, 2013, the EPA and USDA published a study 13 of their own on CCD. One of the principal authors, Dr. May Berenbaum, herself a professional beekeeper and renowned entomologist, disagreed with this approach. In an interview with the New York Times 14, Dr. Berenbaum noted that it is not a simple matter of just removing pesticides. There are too many factors involved. And, the authors prefer to let science drive the outcome of decision making instead of jumping to conclusions based upon the results of a few studies. And, in Australia and Canada, where neonicotinoid pesticides are also extensively used, CCD is not a serious issue. This implies that other factors, or combinations of factors, are at work. USAID regulations follow EPA regulations and advice. The recommendation for AIP is that they train agro dealers and farmers on the risks from neonicotinoids, and to avoid spraying these during crop flowering when honeybees are likely to visit. This is also reflected above for neonicotinoid pesticides accepted for promotion and use by AIP and its beneficiaries. Use of GlobalGAP as a Quality Farm Standard Started in 1997 as EurepGAP (European Good Agriculture Practices), the new GlobalGAP (Good Agriculture Practices) is a private sector body that sets voluntary standards for the certification of agricultural products around the globe. The GlobalGAP standard is primarily designed to reassure consumers about how food is produced on the farm by minimizing detrimental environmental impacts of farming operations, reducing the use of chemical inputs and ensuring a responsible approach to worker health and safety as well as animal welfare. GlobalGAP serves as a practical manual for Good Agricultural Practice anywhere in the world. The basis is an equal partnership of agricultural producers and retailers who wish to establish efficient certification standards and procedures. The GlobalGAP website, is a comprehensive knowledge base for all interested parties: producers, suppliers, retailers, journalists and consumers. With its clear and easy navigation, the website incorporates exhaustive information on the GlobalGAP standard and its modules and applications. The recommendation for AIP is that, as practicable, they learn and promote the use of GlobalGAP crop production standards, especially for any crops that may in the future reach export markets that demand GlobalGAP standard quality. 11 Unauthored List of Registered Agricultural, Bio, and Public Health Pesticides in Bangladesh. DAE-PPW USAID/Bangladesh AIP PERSUAP 36

54 2.5 Bangladesh International Obligations and Pesticide Sector Risks Bangladesh International Obligations (see sources below) Pesticides Stockholm Convention on Persistent Organic Pollutant (POPs) (signed 23 May,2001, ratified 12 March, 2007) 15 Bangladesh is not yet a party to the Rotterdam Convention on Prior Informed Consent (PIC) Procedure for Certain Hazardous Chemicals and Pesticides 16 Basel Convention on the Control of Transboundry Movement of Hazardous Wastes and their Disposal (accession on 1 April, 1993) 17 Montreal Protocol on Substances Depleting Ozone Layer (ratified on 2 August, 1990) 18 Stockholm Persistent Organic Pollutants (POPs) are chemicals that are toxic, persistent in the environment, and liable to bioaccumulate. These chemicals are among the most dangerous and highly toxic pollutants released into the environment every year by human activity. Their effects on humans can include cancer, allergies and hypersensitivity, damage to the central and peripheral nervous systems, reproductive disorders, and disruption of the immune system. Some POPs are also considered to be endocrine disrupters, which, by altering the hormonal system, can damage the reproductive and immune systems of exposed individuals as well as their offspring; they can also have developmental and carcinogenic effects. The Stockholm Convention on Persistent Organic Pollutants was established to eliminate or restrict the production and use of POPs. Through the World Bank s Global Environment Fund (GEF), countries are creating sustainable capacity and ownership so as to meet their obligations under the Stockholm Convention including preparation of POPs National Implementation Plans. A National Implementation Plan describes how each country will meet its obligations under the Convention to phase-out POPs sources and remediate POPs contaminated sites. Rotterdam The Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade, more commonly known simply as the Rotterdam Convention, is a multilateral treaty to promote shared responsibilities in relation to importation of hazardous chemicals. The convention promotes open exchange of information and calls on exporters of hazardous chemicals to use proper labeling, include directions on safe handling, and inform purchasers of any known restrictions or bans. Signatory nations can decide whether to allow or ban the importation of chemicals listed in the treaty, and exporting countries are obliged make sure that producers within their jurisdiction comply. Basel &chapter=27&lang=en USAID/Bangladesh AIP PERSUAP 37

55 The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal, usually known as the Basel Convention, is an international treaty that was designed to reduce the movements of hazardous waste between nations, and specifically to prevent transfer of hazardous waste from developed to less developed countries. It does not, however, address the movement of radioactive waste. The Convention is also intended to minimize the amount and toxicity of wastes generated, to ensure their environmentally sound management as closely as possible to the source of generation, and to assist LDCs in environmentally sound management of the hazardous and other wastes they generate. Montreal The Montreal Protocol on Substances that Deplete the Ozone Layer (a protocol to the Vienna Convention for the Protection of the Ozone Layer) is an international treaty designed to protect the ozone layer by phasing out the production of numerous substances believed to be responsible for ozone depletion. The treaty was opened for signature on September 16, 1987, and entered into force on January 1, 1989, followed by a first meeting in Helsinki in May Since then, it has undergone seven revisions. It is believed that if the international agreement is adhered to, the ozone layer is expected to recover by Methyl bromide used for agricultural fumigation is one of the protocol chemicals being phased out worldwide. Bangladesh Pesticides Profile: Pesticide System Risks The following table consolidates and prioritizes pesticide system risk in Bangladesh Problems, constraints or risks in the Recommendations for donors and the Priority Bangladesh pesticide cycle of use AIP Limited funds for analyzing and Donors and produce exporters and Med monitoring pesticides and residues authorities combine resources Limited resources for pesticide Taxes need to be levied from agriculture Low regulations enforcement sector Limited resources for extension Do demonstration plots and field days High Lack of pesticide toxicity awareness by farmers Limited farmer knowledge of IPM tools Do repeated training on pesticide toxicity, choice, dose for each crop and pest, REI, PHI and risks Increase knowledge, do repeated training on IPM Do repeated training on calibration & application Do repeated training on pesticide cautions Med High Over- and under-applications of Med pesticides Illiterate farmers cannot read pesticide High labels Wrong pesticide applied for pest Do repeated training on pesticide choice High Pesticide shops with limited safety equipment (PPE) on hand Pesticides stored in the home, where children are present Encourage shops to source less expensive PPE through low-cost suppliers like China; and, where appropriate, subsidize PPE to reduce farmer costs Do repeated training on proper pesticide storage Med High 2013 USAID/Bangladesh AIP PERSUAP 38

56 Pesticide mixing with bare hands and little use of PPE by pesticide appliers Pesticides applied at wrong time of day and with winds too high, and rain Back-pack sprayers leak onto spray personnel Toxic aluminum phosphide present in input stores Proper unused pesticides & empty container disposal lacking Do training on proper mixing and PPE to use; provide PPE Do repeated training on application times risks Do repeated training on sprayer maintenance Do repeated training on pesticide choice & quality Do repeated training on proper disposal High Med High High High Bangladesh Pesticides Profile: Factors that reduce risks from pesticides Reduced risk inherent in the cropping and input systems in Bangladesh: The introduction and use of biological pest control techniques in Bangladesh, such as pheromone traps to monitor fields and reduce the number of pests by trapping them. Many less toxic products are being registered and used by farmers in Bangladesh, than compared with just 10 years ago when some highly toxic chemicals were still being registered and promoted. Lower costs for biologically derived, highly effective and approved for Organic insecticide products like spinosad, an extract from a soil bacterium are now a reality. Many newer nicotinoid insecticides are also now available, as long as they are not used when crops are in flower. The increasing world-wide availability and use of small, single-use sachets and smaller bottles of pesticides (as opposed to one and five liter bottles) with labels containing important and potentially life-saving information (in local languages) that are marketed by the formal pesticide importer/distributor sector. These small quantities and labels help resolve on-farm pesticide quantity storage, illegal subdividing and use issues. The likely small scale of most USAID-supported beneficiary plots, combined with lack of financial resources, will limit the quantities of synthetic pesticides used, and will promote the use of other cultural techniques to solve pest issues. Conclusion: There still remain some issues with pesticides that can increase the risk for errors to occur, and thus the risks that retailers and farmers, laborers, farm family members, and even international consumers may be acutely or slowly poisoned and/or their environment may become polluted and damaged. Thus the pesticide risk profile for Bangladesh is higher than might be encountered in some more developed as well as other developing countries, though it is rapidly changing for the better as S&C-GAP systems are being implemented and EU rules for import tolerances are adopted. Extra care will be needed with emphasizing and implementing mitigation measures that work USAID/Bangladesh AIP PERSUAP 39

57 SECTION 3: PESTICIDE EVALUATION REPORT This part of the PERSUAP, the PER (Pesticide Evaluation Report), addresses pesticide choices based upon environmental and human health issues, uses, alternate options, IPM, biodiversity, conservation, training, PPE options, monitoring and mitigation recommendations according to the twelve Regulation 216.3(b)(1) Pesticide Procedures Factors, outlined and analyzed below. Reg (b)(1)(i) stipulates: 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 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. Factors to be considered in such an evaluation shall include, but not be limited to the following: (see box, right) The PERSUAP can recommend or propose specific pesticides to replace those highly used or desired pesticides that are rejected, but the job of recommending pesticides for specific uses against specific pests is usually the mainstay of a Department of agriculture s extension service, if they have such a capability. In Annex 1, this PERSUAP proposes IPM choices available, including proposed possible pesticides used for the same pests in the USA and other developed countries that might be used after all other options are exhausted. Usually, a PERSUAP should not replace an extension service and the expert advice that they can provide. It would be ideal to find pesticides for every need that are Class IV acute toxicity, have no chronic human health issues, no water pollution issues and no aquatic ecotoxicity issues. Such pesticides do not exist. Most pesticides, including natural pesticides, have toxicity to at least one aquatic organism, or bees, or birds. THE 12 PESTICIDE FACTORS Factor A. USEPA Registration Status of the Proposed Pesticides Factor B. Basis for Selection of Pesticides Factor C. Extent to which the proposed pesticide use is, or could be, part of an IPM program Factor D. Proposed method or methods of application, including the availability of application and safety equipment Factor E. Any acute and long-term toxicological hazards, either human or environmental, associated with the proposed use, and measures available to minimize such hazards Factor F. Effectiveness of the requested pesticide for the proposed use Factor G. Compatibility of the proposed pesticide use with target and non-target ecosystems Factor H. Conditions under which the pesticide is to be used, including climate, geography, hydrology, and soils Factor I. Availability of other pesticides or non-chemical control methods Factor J. Host country s ability to regulate or control the distribution, storage, use, and disposal of the requested pesticide Factor K. Provision for training of users and applicators. Factor L. Provision made for monitoring the use and effectiveness of each pesticide 3.1 Factor A: USEPA Registration Status of the Proposed Pesticide USAID project activities are effectively limited to promoting during training, recommending, buying, subsidizing, financing or permitting on demonstration plots, pesticides containing active 2013 USAID/Bangladesh AIP PERSUAP 40

58 ingredients (AIs) in products registered in Bangladesh by Bangladesh DAE-PPW (or those that become registered by Bangladesh DAE-PPW in the near future) and in the US by the EPA for the same or similar uses, without restriction. Emphasis is placed on similar use because often the crops and their pest species found overseas are not present in the US, and therefore pesticides may not be registered for the exact same use, but often are registered for similar crops, pests, methods of application, and pest situations. The USEPA classifies pesticides according to actual toxicity of the formulated products, taking formulation types and concentrations into account, thus generally making the formulated product less toxic than the active ingredients alone would be. This method of classifying acute toxicity is accurate and representative of actual risks encountered in the field. By contrast, the WHO acute toxicity classification system is based on the active ingredient only. For a comparison of USEPA and WHO acute toxicity classification systems, see Annex 6. In the USA, only, some specific commercial pesticide products are labeled as Restricted Use Pesticides (RUPs) due to inordinate risks, usually under specific circumstances of use, such as formulation or crop. However, for each AI, which may be present in a number of RUP products, there are generally additional or other products, formulations and uses with the exact same AI that do not possess the same risks and are thus labeled or determined to be General Use Pesticides that is not RUP. Ergo, for each AI, there may be RUP and non-rup products depending upon risks they do or do not pose. Analysis: Annex 7 provides EPA registration status analysis for each AI found in selected pesticides currently registered (and proposed for imminent registration) for import, imported and used in the Bangladesh. Annex 7, column number three, labeled EPA Registered has a yes if the AI is registered by EPA in pesticides for same or similar uses. If column three has a no it is not registered by EPA and is thus one reason for shading the AI line with red signifying that it is not approved by the PERSUAP Annex 7 analysis. Pesticide AIs that pass this registration factor, and all following pertinent factor analyses, are shaded with green. Issue: Pesticide products analyzed and found containing active ingredients not EPAregistered or in same or similar RUP pesticide products The below table is the result of the Factor A analysis, showing pesticide AIs in Bangladesh DAE- PPW-registered products, imported, sold by retailers and used by farmers, that are NOT in EPA registered products or in RUP products. BELOW FOR INFORMATION ONLY. NO USE. Rejected Fumigant (AIs registered by Reasons for Rejection Bangladesh DAE-PPW and considered but Rejected for Use by the AIP) methyl bromide RUP, Montreal Protocol ozone depleting chemical being phased out internationally bristifluron not EPA registered Rejected Miticide (AIs registered by Reasons for Rejection Bangladesh DAE-PPW and considered but Rejected for Use by the AIP) bromopropylate not EPA registered 2013 USAID/Bangladesh AIP PERSUAP 41

59 cyhexatin mislabeled by DAE-PPW as insecticide; not EPA registered ethion not EPA registered propargite RUP Rejected Insecticide AIs registered by Reasons for Rejection Bangladesh DAE-PPW and considered but Rejected for Use by the AIP alpha-cypermethrin not EPA registered cadusafos not EPA registered carbofuran RUP, Class I carbosulfan not EPA registered cartap hydrochloride not EPA registered endosulfan RUP, being phased out as banned under POPs Treaty 19 ethion not EPA registered fenazaquin not EPA registered fenbutatin oxide RUP fenthion not EPA registered fenalerate not EPA registered isoprocarb not EPA registered monomehypo not EPA registered phenthoate not EPA registered phoxim not EPA registered profenofos RUP quinalphos not EPA registered thiodicarb RUP triazophos not EPA registered validamycin not EPA registered Rejected Fungicide AIs registered by Reasons for Rejection Bangladesh DAE-PPW and considered but Rejected for Use by the AIP diniconazole not EPA registered edifenaphos not EPA registered flusilazole not EPA registered hexaconazole not EPA registered iprovalicarb not EPA registered isoprothiolane not EPA registered kasugamycin not EPA registered 19 Endosulfan (an organochlorine insecticide which is highly toxic and persists in the environment) is a USEPA restricted use pesticide which USAID/LAC no longer approves for any use. USEPA will completely phase out its use by USAID/Bangladesh AIP PERSUAP 42

60 propamocarb not EPA registered propineb not EPA registered quaternary ammonium not EPA registered tricylclazole not EPA registered tridemorph not EPA registered zineb not EPA registered Rejected Herbicide AIs registered by Reasons for Rejection Bangladesh DAE-PPW and considered but Rejected for Use by the AIP acetochlor RUP butachlor not EPA registered ethoxysulfuron not EPA registered isoproturon not EPA registered metamifop not EPA registered oxadiargyl not EPA registered paraquat RUP pretilaclor not EPA registered pyrazosulfuron-ethyl not EPA registered Rejected Rodenticide AIs registered by Bangladesh DAE-PPW and considered but Rejected for Use by the AIP None identified Compliance Requirements AIP will only promote, finance and use on demonstration plots, pesticides registered by EPA for same or similar use and not classified by EPA as RUP products. If USAID wishes to authorize the procurement and/or use of any non-epa registered or RUP product in a USAID project, including use on any demonstration plot, then a full Environmental Assessment (EA) must be done and approved by the Bureau for Asia BEO. 3.2 Factor B: Basis for Selection of Pesticides This procedure generally refers to the practical, economic and/or environmental rationales for choosing a particular pesticide. In general, best practices and USAID which promote IPM as policy dictate that the least toxic pesticide that is effective is selected. Fortunately, as a general but important trend, the more toxic pesticides (Class I) are decreasing in number worldwide and the number of least toxic pesticides (Class IV) is increasing. Thus, farmers may be able to choose products of lower toxicity (Class III and IV/U pesticides), especially if PPE is not available or used. Environment/Agriculture 2013 USAID/Bangladesh AIP PERSUAP 43

61 Farmers most often choose pesticides based upon price, availability, proven efficacy (known to control the pests) and recommendations from neighbors or agrodealers (so it is good that AIP is working with this group). This PERSUAP, however, uses additional criteria for selection of pesticides based upon safety and acute toxicity ratings, chronic toxicity issues, groundwater safety and relative ecotoxicological safety. It is important to recall that almost every pesticide known, including almost every natural pesticide has toxicity to at least one aquatic organism, or bees, or birds. Most also have some human chronic health issues. Mitigation measures allow us to use these pesticides with reduced risks to human health and the environment. Safer Use Actions/Risk Mitigation AIP supports the procurement and use of pesticides with the lowest human and environmental risk profiles (see decision matrix in Annex 7, MSDSs, and pesticide labels), as practical. This criterion shall be fully reflected in the pest management plans (PMPs) required by this PERSUAP. Recommendation: Encourage Bangladesh DAE-PPW to become increasingly aware of EPA-approved biological and naturally derived pesticides, as practical, such as some of those listed in Annexes 4 and 5, and consider registering some additional natural and Class IV pesticides. 3.3 Factor C: Extent to Which the Proposed Pesticide Use Is, Or Could Be, Part of an IPM Program USAID promotes training in and the development and use of integrated approaches to pest management tools and tactics whenever possible. This section emphasizes how any of the approved pesticides can be incorporated into an overall IPM strategy, as the ultimate pest control tools, following exhaustion of all preventive tools and tactics. Environment/Agriculture Certainly, some of the approved pesticides are more useful and gentler on the environment than others; Annex 7 shows relative toxicities of each pesticide AI. In general, most of the natural products and extracts are less disruptive to the ecosystem. However, agricultural production cannot rely solely on the use of natural pesticides, unless they are certified as Organic. Good crop management practices can strongly affect the success of IPM, and good agronomic or cultural practices are the most basic and often the most important prerequisites for an effective IPM program. A healthy and vigorous crop optimizes both capacity to prevent or tolerate pest damage while maintaining or increasing yield potential. In the USA, the USDA supports several programs aimed at investigating and developing IPM tools and tactics. These include NIFA 20 (the National Institute of Food and Agriculture) and the National Sustainable Agriculture Information Service of the National Center for Appropriate Technology 21 (NCAT). Bangladesh has a cadre of experts who recognize the importance of these tools and techniques, and are ready to implement them in crop-specific PMPs USAID/Bangladesh AIP PERSUAP 44

62 According to USAID experts in the crop protection sector, the requested pesticides are fitted into overall GAPs and IPM programs, and their use is reduced when in combination with other preventive tools, as follow (with tactics used in Bangladesh highlighted in yellow): o Soil quality and nutrition testing o Resistant varieties o Certified seed o Seed treatment o Soil solarization (heating under plastic with direct sun heat) o Raised-bed production o Use of plastic and organic mulches o Proper seeding/thinning rate o Soil moisture testing o Organic fertilizers/compost o Synthetic fertilizers o Crop rotation o Green manures o Manipulate plant/harvest time o Trap crops o Pruning o Farmscaping 22 o Correct pest/disease ID o Weekly monitoring o Baited traps o Sticky traps o Pheromone traps o Pheromone inundation o Crop residue destruction o Artisanal (home made) pesticides o Conservation practices o Mechanical weeding o Spot pesticide treatments o Production of natural microbial pesticides To further put IPM tools and tactics into practice, Annex 1 contains a detailed Crop-Pest-IPM- Pesticide matrix for each crop to be grown by USAID-assisted farmers, noting most major pests of each crop, a list of preventive tools and tactics recommended for the same pests in countries with significant commercial production and a list of natural and synthetic chemical alternatives recommended by leading state extension services in the USA. IPM philosophy includes the use of synthetic pesticides as part and parcel of an overall harmonized and coordinated approach to pest management. The principles of IPM were initially developed by entomologists for farmers and users of insecticides, miticides, nematicides and molluscicides because all of these chemicals impact animal biochemical pathways and are thus capable of harming other animals and beneficial animals if used unwisely or over-used. Thus, the most intense focus of traditional IPM is on these types of organisms and chemicals. Safer Use Actions/Mitigation USAID/Bangladesh AIP PERSUAP 45

63 Pesticide Safer Use training required under this PERSUAP will include IPM principles as well as crop- or pest-specific IPM practices relevant to the audience. (See Annex 1). Starting from the information in PERSUAP Annex 1 & Annex 2, the AIP project and those beneficiaries supporting crop production will adopt/develop crop- and pest-specific IPM-based Pest Management Plans (PMPs) 23. Chemical controls specified in these plans will weight low-toxicity options. PMPs can be translated into posters/handouts for on-farm use in prediction and management of the major pests of each crop. The AIP can train appropriate project staff, partners and beneficiaries in these PMPs. These project activities will require and enforce PMP implementation in situations where the project has direct control over pesticide use, and require and enforce that field extension under direct project control be PMP-based. Where project control over extension or agricultural practice on the ground is less than complete, these project activities will promote and support PMPs to the greatest practicable extent. 3.4 Factor D: Proposed Method or Methods of Application, Including the Availability of Application and Safety Equipment This section examines how the pesticides are to be applied, to understand specific risks with different application equipment available and application methodologies, and the measures to be taken to ensure safe use for each application type. Pesticides can and do enter the body on the hands, skin or eyes when mixing and from splashes, on back, arms and hands from leaky backpack sprayers when spraying, through the nose and mouth as vapors while spraying and from spray drift, and by mouth from ingestion on food or cigarettes. Environment/Agriculture Findings from a survey show that all of the following types of equipment or methods are used to apply pesticides to field crops or orchards in Bangladesh: hand-pump backpack motorized backpack granular Issue: Leaky backpack sprayers. Hand-pump backpack sprayers, used by small- and mediumscale farmers, among others, can and do eventually develop leaks at almost every parts junction (filler cap, pump handle entry, exit hose attachment, lance attachment to the hose and at the lance handle) and these leaks soak into exposed skin. Moreover, clothing serves as a wick that holds these pesticides in constant contact with the skin. Unless the clothes are washed immediately after use, other family members may also come in contact with pesticide residuals. Safer Use Actions/ Mitigation 23 see Year-Round IPM Programs on upper left side of website 2013 USAID/Bangladesh AIP PERSUAP 46

64 Work with the Government of Bangladesh, pesticide private sector, CLA and others to encourage agro dealer shops to source less expensive PPE through low-cost suppliers like China; and, where appropriate, subsidize PPE to reduce farmer costs The AIP, during the pesticide safer use training required by this PERSUAP, will (1) promote and teach proper sprayer maintenance and repair; and (2) train participants on post-spray hygiene. The AIP will assure and require well-maintained sprayers and proper post-spray hygiene and facilities for pesticide use under their direct control. Where pesticide use is not under project direct control, but the project is nonetheless supplying or supporting the purchase of pesticides or application equipment, the project will assure that appropriate post-spray facilities for washing clothing and equipment, and proper disposal of wastes are in place. Issue: Pesticide granules and powders applied by hand. Many farmers that use pesticides formulated as granules or powders apply these by hand, without benefit of gloves. Gloves must be used for these applications. Issue: Farmers do not use PPE. Most Bangladesh farmers do not use PPE. However, pesticide labels provide guidance on appropriate PPE to use, and EPA has such guidance on a dedicated website 24. Safer Use Actions/ Mitigation The pesticide safer use training required by this PERSUAP will include descriptions of health risks to retailers and spray operators in demonstration plots (see risks for each pesticide AI in Annex 7), use of appropriate PPE and its maintenance, and advice on minimizing discomfort from wearing PPE, such as spraying in the afternoon when it is cooler and the honeybees do not forage, and when there is little wind or sun and no rain. Where pesticide use is under their control, the AIP shall assure that appropriate PPE is provided, is well maintained, and properly utilized. This includes the use of gloves for granular applications. Where pesticide use is not under project control, but the project is nonetheless supplying or supporting the purchase of pesticides or application equipment, the project will assure that appropriate PPE is available and undertake all feasible measures to promote its use. Recommendation: As appropriate, the AIP will promote the development and use of professional spraying and record-keeping services, accessible by farmers at congregation places (retail farms stores, cooperatives/associations, produce consolidation/cold storage/processing sites). Spray service companies that may be specifically promoted by the AIP will demonstrate that they maintain spray equipment and use recommended PPE. 3.5 Factor E: Any Acute and Long-Term Toxicological Hazards, either Human or Environmental, Associated With the Proposed Use, And Measures Available To Minimize Such Hazards USAID/Bangladesh AIP PERSUAP 47

65 This section of the PERSUAP examines the acute and chronic toxicological risks associated with the proposed pesticides. Information on specific risks to environmental resources and how to mitigate or minimize such risks are detailed below under Factor G. Pesticides are poisons, and nearly all of them including natural ones present acute and/or long-term toxicological hazards, especially if they are used incorrectly. The pesticide AI analysis matrix in Annex 7 contains information on acute and chronic human and environmental toxicological risks for each AI in products registered for use in Bangladesh. Pesticides that are rejected by this Factor E analysis are as follows: Rejected Insecticide AIs carbofuran (Class I) endosulfan (an organochlorine insecticide which is highly toxic and persists in the environment), and is a USEPA restricted use pesticide which USAID/LAC no longer approves for any use. USEPA will completely phase out its use by 2016.) Rejected Herbicide AI paraquat (Class I) Although farmers interviewed in the FTF zone indicated that they knew of no recent farmer deaths linked to pesticides (other than for suicide), a review of the Internet does produce some evidence for such poisonings. A 2012 article in the Daily Star indicates that pesticides used on litchis could have poisoned Bangladeshi children. 25 Furthermore, the Book titled Understanding livelihoods dependent on inland fisheries in Bangladesh and Southeast Asia 26 indicates that agrochemicals used in the dry season negatively impact fisheries. The Stockholm Convention on Persistent Organic Pollutants (POPs) and Rotterdam Convention s Prior Informed Consent (PIC) procedure which list banned and highly regulated toxic chemicals, respectively, were not known when Regulation 216 was written, so there is no language directly governing their use on the AIP. Nevertheless, they present high risks to users and the environment, due to persistence and toxicity. It is thus prudent that they be discussed. The following websites contain current lists of all POPs and PIC chemicals: None of the chemicals contained on the new 2013 POPs or PIC lists (see lists of these chemicals for 2013 at the websites referenced above) were found to be present in Bangladesh and they will be increasingly unlikely to be found in the future as world-wide production of most of these chemicals has ceased or is ceasing. Further, there are numerous less-toxic replacements for all of these chemicals. These newer chemicals are rapidly replacing the older, more dangerous chemicals. Pesticides on the 2011 POPs or PIC lists should not be used on the AIP USAID/Bangladesh AIP PERSUAP 48

66 Safer Use Actions/ Mitigation Even if most Bangladesh retailers and farmers supported through AIP are encouraged to use, get access to and use affordable PPE, pesticides with high acute toxicity (Class I) will not be procured and/or used on USAID activities. AIP must not support the farmers that will use PERSUAP-allowed (or even purchased, if that should occur) pesticides without PPE. PPE use must be ensured for those chemicals that are potential carcinogens (PC) or likely carcinogens (LC) in Annex 7. No known carcinogens are on the allowed pesticides list. (See Section 4: Safer Use Action Plan). All of these have been shaded in red in Annex 7 and do not appear in Annex 1. The pesticide safer use training required by this PERSUAP will include basic first aid for pesticide overexposure, availability and use of antidotes, and following recommendations found on pesticide Labels and MSDSs for commonly used pesticides. 3.6 Factor F: Effectiveness of the Requested Pesticide for the Proposed Use This section of the PERSUAP requires information similar to that provided previously, but more specific to the actual conditions of application and product quality. This section considers the use of low-quality generic products (such as some of those imported from China and India, from where most generic pesticides originate) as well as the development of pest resistance to proposed pesticides, both of which will decrease effectiveness (efficacy). Environment/Agriculture Pesticides are important pest management tools. Many pesticides gradually lose their effectiveness especially if overused and not rotated with other classes of pesticides due to the development of resistance by pests. Pest resistance is a heritable and significant decrease in the sensitivity of a pest population to a pesticide that is shown to reduce the field performance of those specific pesticides. The management of the development of pesticide resistance is an important part of sustainable pest management and this, in conjunction with alternative pest management strategies and Integrated Pest Management (IPM) programs, can make significant contributions to reducing risks to humans and the environment. Annex 7 serves as one tool for managing resistance by providing the class of each pesticide AI, so that project field managers and farmers can rotate pesticides among classes. Pests known to have developed significant pesticide resistance (especially to older-generation organophosphate, carbamate and synthetic pyrethroid insecticides, strobin fungicides and azine herbicides) globally: Whiteflies Aphids Spider mites Thrips Mealybugs Scales Psyllids Colorado Potato Beetle Corn Earworm 2013 USAID/Bangladesh AIP PERSUAP 49

67 Powdery mildew Downy mildew Pesticides with known global resistance by certain pests or diseases (use with care do careful calculations of dose and rotate with other classes or families of pesticides) Most of the older and more toxic pesticides no longer registered by EPA, already rejected Many of the synthetic pyrethroids already rejected due to RUPs Permethrin Strobin fungicides Glyphosate herbicide Azine herbicides Issue: Lack of knowledge and information on reduced pesticide effectiveness and resistance. At some point, project field staff and retailers and farmers may begin to note that some products no longer work well to control pests in their field, and will likely begin to blame pesticide manufacturers for a weaker product. This could be due to the use of cheap generic products, improper dosing, or the development of resistance. Retailers should be trained to understand the development of resistance, and project implementers should be on the lookout for it during their field visits. A resistance management strategy should also consider cross-resistance between pesticides with different modes/target sites of action. Pests may develop cross-resistance to pesticides based on mode/target site of action. Annex 1 shows IPM tools that are currently effective against specific pests of USAID crops. It also contains, where relevant, comments about rotating pesticides or any resistance issues of importance that are known for that pest and type of pesticide. The website can be used to search for specific known resistance issues in countries with certain pest or disease resistance to specific pesticide AIs with the resources to buy and use large quantities of pesticides. Fungicide resistance and rotation recommendations are found on the Fungicide Resistance Action Committee (FRAC) website If pesticide use is warranted and a risk of pesticide resistance development is identified, a Resistance Risk Management approach should be followed. The following section details points of concern for both application equipment and pesticide applications. Ways to address and manage or mitigate pest resistance: Use IPM to minimize pesticide use: Minimizing pesticide use is fundamental to pesticide resistance management. IPM programs incorporating pest monitoring in USA states of California, New York, Maryland and Canada have demonstrated 25 to 50% reduction in pesticide use with an increase in crop quality. IPM programs will help determine the best application timing for pesticides (when they will do the most good), thus helping to reduce the number of applications. The use of nonchemical strategies, such as pest exclusion (e.g., screening, microtunnels, greenhouses), host-free periods, crop rotation, biological control, and weed control may reduce the need to use chemicals and consequently slow the development of pesticide resistance USAID/Bangladesh AIP PERSUAP 50

68 Avoid Knapsack Mixes: Never combine two pesticides with the same mode of action in a tank mix (e.g., two organophophate insecticides or two azine herbicides). Such a 'super dose' often increases the chances of selection for resistant individuals. In some cases, mixing pesticides from two different classes provides superior control. However, long-term use of these two-class pesticide mixes can also give rise to pesticide resistance, if resistance mechanisms to both pesticides arise together in some individuals. Continued use of the mixture will select for these multiple-pesticide-resistant pests. Avoid Persistent Chemicals: Insects with resistant genes will be selected over susceptible ones whenever insecticide concentrations kill only the susceptible pests. An ideal pesticide quickly disappears from the environment so that persistence of a 'selecting dose' does not occur. When persistent chemicals must be used, consider where they can be used in a rotation scheme to provide the control needed and with a minimum length of exposure. Use Long-term Rotations: Resistance management strategies for insects, weeds, and fungal pathogens all include rotating classes of pesticides. Pesticides with the same modes of action have been assigned the same group number by their respective pesticide resistance action committees, Insecticide Resistance Action Committee (IRAC), Fungicide Resistance Action Committee (FRAC), and Herbicide Resistance Action Committee (HRAC). These group numbers have been included in the treatment tables of this guideline to help clarify when rotating pesticides, which ones can be rotated. However, the strategies used in rotations differ. For example, with fungicides, it is suggested that classes be rotated every application. With insecticides, a single chemical class should be used for a single generation of the target pest followed by a rotation to a new class of insecticide that will affect the next generation and any survivors from the first generation. Longer use of a single chemical class will enhance the chance of resistance since the survivors of the first generation and the next will most likely be tolerant to that class. Rotating through many chemical classes in successive generations will help maintain efficacy. Safer Use Actions/ Mitigation For any pesticides directly procured or used, or applied, the AIP will use quality name-brand products. The pesticide safer use training required by this PERSUAP and extension activities will include the fundamentals of safer pesticide purchase, including to encourage farmers to use quality name-brand products and discourage farmers from using cheap generic products. The pesticide safer use training required by this PERSUAP and extension activities will teach and emphasize proper sprayer calibration and spray nozzle choice. PMPs and extension will include and emphasize pesticides rotation among the classes of pesticides to reduce the development of resistance and the above recommendations for reducing resistance. 3.7 Factor G: Compatibility of the Proposed Pesticide Use with Target and Non-Target Ecosystems This section examines the potential effect of the pesticides on organisms other than the target pest. Non-target ecosystems include protected areas, species and water resources. Non-target 2013 USAID/Bangladesh AIP PERSUAP 51

69 species of concern include fish, honeybees, birds, earthworms, aquatic organisms and beneficial insects. Issue: Pesticides can impact biodiversity and protected areas Annex 7 compiles the known risks to the different types of terrestrial and aquatic organisms referred to above for each pesticide active ingredient found in pesticide products registered for use in Bangladesh and covered by this PERSUAP, so that informed product choices can be made if a pesticide is to be used in or near sensitive areas or resources. A USAID Biodiversity and Tropical Forestry analysis update was performed in 2010 for Bangladesh and it identified critical protected areas and biodiversity protection issues. Among them, under Economic Growth, is support to agriculture initiatives including use of fertilizers, pesticides and potential future use of Genetically Modified Organisms (GMOs). Major National Parks in Bangladesh are discussed, above under the background section; refer to this section and the references in it 27. Safer Use Actions/ Mitigation of Risks to Sensitive Areas Before the development of PMPs, identify and map all sensitive areas near the project sites. Maintain a 2.5 to 5 km buffer no-spray zone around national parks or other protected areas. Use GAPs and avoid using highly toxic or persistent pesticides where endangered species are known to exist. Recommendation: If agricultural production is done within 10km up-wind or up-stream from a protected area, the AIP should investigate and strongly recommend the use of botanical and biological controls, as practical, or produce Organic crops near these valuable natural resources. Issue: Pesticides can persist in the environment after application The effect of each pesticide on non-target ecosystems will depend on how long it stays in the environment, that is, its rate of breakdown, or half-life. Half-life is defined as the time (in days, weeks or years) required for half of the pesticide present after an application to break down into degradation products. The rate of pesticide breakdown depends on a variety of factors including temperature, soil ph, soil microbe content and whether or not the pesticide is exposed to light, water, and oxygen. Many pesticide breakdown products are themselves toxic, and each may also have a significant half-life. Since pesticides break down with exposure to soil microbes and natural chemicals, sunlight and water, there are half-lives for exposure to each of these factors. Fortunately, most of the very persistent pesticides AIs, like chlorinated hydrocarbons, are no longer available or used in modern agriculture. 27 Two Ecologically Critical Areas (ECA) fall within the AIP project area. The Sundarbans Reserve Forest (and within it, three Wildlife Sanctuaries), and the non-gazetted Marzat Haor USAID/Bangladesh AIP PERSUAP 52

70 Pesticides with a long residual period (that are labeled persistent and may last for years) include atrazine herbicide and organochlorine pesticides. Many if not most of the newer carbamate, organophosphate, neonicotinoid, synthetic pyrethroid, natural botanical and microbial extracts, mineral and vegetable oils, soap fatty acids and growth regulator insecticides and most fungicides recommended in Annex 1 break down much more quickly in the environment, generally within weeks. Safer Use Actions/ Mitigation Wherever possible, the AIP use those pesticide AIs suggested in Annex 1 (none of which are judged to be unreasonably persistent or known water pollutants see below). Issue: Pesticides can adsorb (stick to) to soil, leach and contaminate groundwater resources Each pesticide has physical and chemical characteristics, such as solubility in water, ability to bind to soil particles and be held there (adsorbed) and their natural breakdown rate in nature. If they are strongly held by soil they do not enter the soil water layers and the ground water table as easily. A listing of these properties for at least some of the pesticides in use in Bangladesh can be found by checking at this website: In general, pesticides with water solubility greater than 3 mg/liter have the potential to contaminate groundwater; and pesticides with a soil adsorption coefficient of less than 1,900 have the potential to contaminate groundwater. In addition, pesticides with an aerobic soil half-life greater than 690 days or an anaerobic soil half-life greater than 9 days have the potential to contaminate groundwater. Moreover, pesticides with a hydrolysis half-life greater than 14 days have potential to contaminate groundwater. The potential for pesticides to enter groundwater resources depends, as indicated above, on the electrical charge contained on a pesticide molecule and its ability and propensity to adhere to soil particles, but this also depends on the nature and charge of the soil particles dominant in the agriculture production area. Sand, clay and organic matter, and different combinations of all of these, have different charges and adhesion potential for organic and inorganic molecules. Sandy soil often has less charge capacity than clay or organic matter, and will thus not interact significantly with and hold charged pesticide molecules. So, in areas with sandy soil, the leaching potential for pesticides is increased, as is the velocity with which water and the pesticide migrate. A pesticide s ability to enter groundwater resources also depends on how quickly and by what means it is broken down and the distance (and thus time) it has to travel to the groundwater. If the groundwater table is high, the risk that the pesticide will reach it before being broken down is increased. Thus, a sandy soil with a high water table is the most risky situation for groundwater contamination by pesticides. Groundwater contamination potential for each pesticide active ingredient available in Bangladesh is provided in Annex 7. Safer Use Measures/Mitigation Do not use or recommend for use herbicides or other pesticides with high leaching and groundwater pollution potential (see Annex 7) near drinking water sources, on highly sandy soils or soils with water tables close (2-3 meters) to the surface. Issue: Pesticides can damage environmental resources/non-target organisms 2013 USAID/Bangladesh AIP PERSUAP 53

71 Improperly used pesticides can and do damage the following natural resource/non-target organisms: honeybees needed for pollinating two-thirds of all crops fish needed for aquifer health and human food birds needed to control insect pests predators and parasitoids needed to control insect pests earthworms needed for soil health mollusks and crustaceans needed for aquifer health and human food clean water needed for drinking, irrigating and washing biodiversity and rare species needed for ecosystem functioning Safer Use Actions/Mitigation Where a project activity has direct control over pesticide use, assure the following. Where aproject activity is supporting or recommending pesticide use but has less than complete control, take all practicable measures to assure the following: Do not apply granular pesticides in fields frequented by migratory waterfowl. Completely cover granules with soil, especially spilled granules at the ends of rows Do not spray or rinse equipment in or within 30 meters of ponds, drainage ditches, and surface waters Minimize chemical spray drift by using low-pressure sprays and nozzles that produce large droplets, properly calibrating and maintaining spray equipment, and use of a driftcontrol agent Do not spray pesticides with high toxicities to aquatic organisms before an impending rainstorm, as they can be washed into waterways before breaking down. Ensure that pesticides labeled for certain types of use environments, or areas, are in fact used according to label recommendations. Since transport of soil particles with pesticides adsorbed to them is a likely transportation route to waterways, employ techniques to reduce farm soil erosion whenever erosion is likely (such as terracing, employing ground covers between rows, planting rows perpendicular to the slope, using drip irrigation, and so on). Warn beekeepers of upcoming spray events so that they may move or protect their hives; Spray at night (best), very early morning or late afternoon when winds are below 13 kph, there is no rain and bees do not forage Read and follow pesticide label instructions including environmental warnings, and especially if not literate, be trained on how to interpret pictograms (safety graphics) contained on each pesticide container. Choose the pesticide least toxic to fish and wildlife (see Annex 7, MSDS and pesticide label) Using forward linkage support, train agro dealers and farmers from the outset on how to properly dispose of empty pesticide containers (and continue to provide repeated training on what this means locally) Annex 15 contains recommendations for a communications campaign to raise community and farmer awareness on the risks and benefits of pesticide use, IPM and pesticide safety USAID/Bangladesh AIP PERSUAP 54

72 3.8 Factor H: Conditions under Which the Pesticide Is To Be Used, Including Climate, Geography, Hydrology, and Soils In general, in addition to covering biodiversity and protected areas under Factor G above, this requirement attempts to protect natural resources from the dangers of pesticide misuse and contamination, especially of groundwater resources. Bangladesh Climate and Geography Bangladesh s climate and geography are described in the background section to this report, with maps on rainfall, temperatures and country relief; refer to them for background on this factor. Bangladesh Hydrology Bangladesh s hydrology is described in the background section to this report; refer to it for background on this factor. Recommendation: Avoid applying pesticides within 30 meters of watersheds and bodies of water. Bangladesh Soils Bangladesh s soils are described in the background section to this report, with a soils map; refer to it for background on this factor. Safer Use Actions/Mitigation Where a project has direct control over pesticide use, assure the following. Where a project is supporting or recommending pesticide use but has less than complete control, take all practicable measures to assure the following: Hydrology. Do not spray or rinse pesticide equipment in or within 30 meters of ponds, irrigation and drainage ditches, and other surface waters. Do not spray pesticides with high toxicities to aquatic organisms before an impending rainstorm, as they can be washed into waterways before breaking down. Soils: Do not use or recommend for use herbicides or other pesticides with high leaching and groundwater pollution potential (see Annex 7) near drinking water sources, on highly sandy soils or soils with water tables close (2-3 meters) to the surface. Soils: Since transport of soil particles with pesticides adsorbed to them is a likely transportation route to waterways, employ techniques to reduce farm soil erosion whenever erosion is likely. Such techniques include vegetated buffer strips, green manure, mulching, terracing, employing wind breaks, employing ground covers between rows, planting rows perpendicular to the slope, using drip irrigation, and so on). 3.9 Factor I: Availability of Other Pesticides or Non-Chemical Control Methods 2013 USAID/Bangladesh AIP PERSUAP 55

73 This section identifies less toxic synthetic, as well as non-synthetic or natural (extracts of naturally-occurring plants, spices, oils, fatty acids, induced resistance elicitors, minerals, microbes or microbial extracts) pesticide options for control of pests, and their relative advantages and disadvantages. Many of these natural pesticides can be toxic to humans, and several are even classified as RUPs due to environmental risks; thus safe pesticide use practices extend to these natural as well as synthetic (produced in laboratories or factories) pesticides. Environment/Agriculture Annex 1 the heart of this PERSUAP contains numerous non-chemical control methods for every major pest of every USAID-supported crop in Bangladesh. It is the intent of this PERSUAP that the AIP dealing with agriculture use this valuable resource, which compiles all known IPM tools and tactics for each pest of each crop. It can be considered as a pullout, standalone section that can be reproduced as necessary, and should be considered for translation into local languages, lamination, and distribution to farm input supply companies to help advise farmers at point-of-purchase. Issue: Natural pest controls availability Natural chemicals: Many non-synthetic chemical IPM tools and technologies are listed in Annexes 4 and 5. The list of natural pesticides likely entering Bangladesh is not very extensive compared with other emerging market countries. In general, most synthetic soil pesticides/fumigants are very highly toxic. However, there are some companies producing next-generation natural chemicals in the USA: Bio Huma Netics, for natural nematicides and Agra Quest, for bioactive essential oils. For commercial operations, especially greenhouses, biological controls and beneficial organisms are available commercially from two large international companies, Koppert of Holland and Biobest of Belgium. Koppert provides many biological controls against spider mites, beetles, leaf miners, mealy bugs, thrips, aphids, whiteflies, and moth and butterfly larvae. Koppert also provides the Koppert Side Effects List, a list of the side effects of pesticides on biological organisms, at Biobest of Belgium provides many of the same or similar biological controls as Koppert, and includes a control against leafhoppers. Their website is: These are especially useful for greenhouse and seedling production systems. Both companies also sell live bumblebees for greenhouse pollination assistance. Safer use Measures/Mitigation As appropriate, the AIP will promote low-risk preventive and natural chemical pest controls that are found in Annexes 1, 4 and 5 of this PERSUAP, including incorporating these controls in the pest management plans (PMPs) developed under this PERSUAP Factor J: Host Country s Ability to Regulate or Control the Distribution, Storage, Use, and Disposal of the Requested Pesticide This section examines the host country s existing infrastructure and human resources for managing the use of the proposed pesticides. If the host country s ability to regulate pesticides is 2013 USAID/Bangladesh AIP PERSUAP 56

74 inadequate, the proposed action use of pesticides could result in greater risk to human health and the environment. The Department of Agricultural Extensionin Bangladesh has produced pesticide regulations and has a long list of permitted pesticides for agricultural pest control. Some unregistered pesticides, likely entering the country informally through India or Myanmar may, in the future, be found in Bangladesh pesticide stores. For a country where PPE is, for all intents and purposes, not much used on small-scale farms, there are still some very toxic products being sold in quantity, all of which leads to increased risk. Inventory and disposal of obsolete pesticides According to the FAO, as of 2013, there is no good information tallied on the amount of obsolete pesticides there are in Bangladesh. See where Bangladesh is glaringly missing from the FAO s inventory lists for Asia and South Asia. Disposal of pesticide containers Discussions with Bangladesh pesticide system actors indicate that the issue of the final disposition of empty pesticide containers is well understood. The present solution is to triple-rinse the containers, puncture them to discourage re-use, and bury or burn them. Burning plastic bottles and single-use sachets can lead to the formation of toxic furans and dioxins, and is not recommended. Using a good forward linkage campaign, AIP should encourage Crop Life International to develop a program to collect, clean, puncture and recycle empty containers in Bangladesh. GlobalGAP and other S&C systems require that empty pesticide containers are triple rinsed over a pesticide mixing pit, and then properly stored in plastic drums in the field or storage shed, to await disposal. Website provides pesticide and container best practices disposal options. Safer Use/Mitigation Actions Absolutely no POPs or PIC chemicals will be procured and/or used on the AIP. This includes but is not limited to, the following chemicals that might be encountered in Bangladesh: endosulfan (added in 2011 as a POPs chemical). No such AI is included in the allowed pesticides list. (See Section 4: Safer Use Action Plan.) Where alternatives (Classes III and IV/U) exist, do not recommend or use EPA and WHO Acute Toxicity Class II pesticide products on the AIP, unless the USAID project can verify that producers and laborers (pesticide applicators) properly and consistently utilize PPE as recommended by the pesticide label and MSDS. PMPs and field extension will give preference to the use of Class III and IV/U pesticide alternatives, which exist in large numbers in farm stores visited. For all project demonstration plots supported by USAID, encourage and support the use of GlobalGAP best practices with pesticide storage, use and disposal, whether or not certification is sought. If the Bangladesh pesticide container recycling facility is brought on-line during the life of the project, USAID should encourage its use, once it is ascertained that the facility is designed, built, and operated in accordance with national laws of Bangladesh and 2013 USAID/Bangladesh AIP PERSUAP 57

75 applicable international conventions, and is operated under all applicable valid licenses and permits Factor K: Provision for Training of Users and Applicators USAID recognizes that, in addition to the use of PPE, safety training is an essential component in programs involving the use of pesticides. The need for thorough training is particularly acute in emerging market countries, where the level of education of applicators may typically be lower than in developed countries. Issue: Retailers and farmers need intensive and repeated training Training in Safe Pesticide Use and GAP/IPM are of paramount importance for USAID project beneficiary farmers and farm laborers using pesticides. According to the UN s Integrated Regional Information Networks (IRIN) 28, In 2011, some 900,000 farmers received [IPM and pesticide safety] training, out of 12 million farming families in Bangladesh. Additional and refresher trainings are superb means for effecting beneficiary farmer behavioral change, now especially, as they expand their agricultural opportunities, and before risky behaviors become set. Safer Use/Mitigation Actions The AIP will implement IPM and Pesticide Safer Use training for all relevant project staff and beneficiaries, training all target individuals within 6 months and providing short annual refresher training thereafter. Wherever relevant, the AIP will provide training to project staff, and beneficiary farmers and extension agents on the crop-specific, IPM-based pest management plans required by this PERSUAP. Simple crop/pest cycle handouts for farmers should be introduced in these trainings and used in field extension. Recommendation: The AIP develop and deliver a course to train trainers in GlobalGAP compliance procedures and to work with the DAE-PPW on chemical registration, storage, and disposal issues. The AIP can work with agro-dealers to conduct farmer-training programs on monitoring and data record keeping techniques for pest control and pesticide needs and/or effectiveness Factor L: Provision Made For Monitoring the Use and Effectiveness of Each Pesticide Evaluating the risks, impacts and benefits of pesticide use should be an ongoing, dynamic process. Pest resistance is one of the risks for which this element is intended, as well as human health and safety and environmental effects. Record keeping should track quantities and types of pesticides used, where they were used and what they were used for with notes on efficacy. Records of training received are also important to keep, if GlobalGAP standardization or certification will be sought. Notes on effectiveness of individual pesticides and pest numbers will help develop a more sustainable pesticide use plan for USAID beneficiary producer. Records of farmers will need to make note of any reductions in pesticide efficacy experienced, which is the first indication that resistance may be developing, USAID/Bangladesh AIP PERSUAP 58

76 and then a strategy needs to be in place to determine a shift to a different pesticide class, and rotation among classes, to overcome resistance development. Issue: USAID beneficiaries and farm record keeping On USAID project demonstration plots, pesticide use documentation is available sporadically and not retained from year to year. Developing a more systemized approach to record keeping will allow seasonal and annual comparison of pesticide effectiveness, pest numbers, crop production, maintenance of safety equipment, and so on. The following aspects should be included in the record keeping system, for a USAID-funded program (the AIP local environmental specialist, along with other delegated staff can compile, disseminate and update): Local regulatory compliance: A list of country laws related to the use of agrochemicals for plant protection, short notes on the relevance of the law, dates the laws come into or exit force and MRLs for each crop-pesticide combination. A pesticide checklist: This list allows agronomists to ensure that the pesticides they are using are registered. It should also provide notes on special safety requirements. GAPs/IPM measures tried/used (see Annex 1): USAID agronomists should try to incorporate a minimum of at least ten new IPM measures per annum and document their success or failure. PPE: Lists of the types of equipment made available to applicators, number of pieces, prices and contact details of suppliers, dates when equipment needs to be washed, maintained or replaced. PPE should be numbered or personally assigned to applicators to ensure that it is not taken into the home where (as a contaminated material) it could pose a risk to family members. See Annex 8 for in-country addresses for PPE sourcing. Monitoring/recording pests: Agronomists should incorporate into their records regular field pest monitoring and identification. This could be done by the agronomists themselves, or if properly trained, by farmers. Environmental conditions: Field conditions should be incorporated into the record keeping system (for example; precipitation, soil analyses and moisture, soil ph, temperatures and so on). Information should be transmitted at least annually and USAID should report to USAID on this progress in pesticide safety and GAP/IPM use in quarterly/annual reports. Issue: Monitoring by USAID contractor/grantee field staff and beneficiary farmers should be trained to detect, and report to AIP field staff who would report to the AIP environmental staff tasked with pesticide safety: Resistance: Pesticide resistance development among pests has likely occurred and could eventually occur more, and will be noted by farmers complaining that the spray no longer works as it once did. Human poisonings and any incidences of chronic health issues. Farm animal and livestock deaths. Any incidences of water pollution. Fish, bird, wildlife or honeybee kills. Any of the above items should be reported immediately to USAID. Other information should be transmitted at least annually to USAID, and USAID should report on this progress in pesticide environmental and human health safety in annual reports USAID/Bangladesh AIP PERSUAP 59

77 Issue: USAID Planning and Reporting Several issues could receive even more attention in USAID annual work plans and annual reports. These include a section on Environmental Impact Mitigation and Best Practices, with subsections (and issues) on: Country and EPA regulation compliance (documents and enforcement status, risk, pollution, mitigation) GAPs/IPM measures tried/used and on what percent of project plots Biodiversity and conservation (soil, water, energy, protected habitats, biodiversity and protected species) measures used on what percent of plots Inputs and PPE use and issues (types, amounts and issues with products, sprayers, MRLs, REIs, PHIs, MSDSs) Training/capacity building in IPM and Safe Use (hands-on, demos, sessions, meetings, extension, flyers, brochures, pamphlets, posters, crop technical GAP information sheets, and radio and TV outreach/safety message enforcement) Using Annex 10, USAID project staff should put brief plans for monitoring the environmental and human health impact of production activities, incorporating recommendations found in this PERSUAP into the Annual Action Plans. USAID staff keeps records on the implementation of the recommendations found in this PERSUAP, and report on them in Quarterly and Annual Reports, under a heading titled Environmental Impact Mitigation and Best Practices. The AIP AOR, MEO and REA, at least two times annually, make auditory visits to several randomly selected plots receiving assistance through the USAID project and check for non-compliance with the recommendations on pesticides and IPM found in this PERSUAP. The data collection form attached as Annex 9 could be adapted and used for this purpose USAID/Bangladesh AIP PERSUAP 60

78 SECTION 4: PESTICIDE SAFER USE ACTION PLAN (SUAP) 4.1 Introduction This Safer Use Action Plan is the definitive statement of AIP pesticide compliance requirements and is synthesized from the PER analysis: Section 4.2, immediately below, lists allowed pesticides. Annex 17 lists pesticides that are rejected by this PERSUAP. Section 4.3 establishes USAID s and AIP s field monitoring requirements for compliance with safer use conditions Section 4.4 summarizes the safer use conditions attendant to use/support of these pesticides. These conditions are then detailed in the attached mandatory template (Annex 16) for assigning responsibilities and timelines for implementation of these requirements, and for tracking compliance. The AIP must submit a completed SUAP template to its AOR/COR (completed template by AIP is presented in Annex 16) and provide an annual update thereafter. With respect to pesticides, the Safer Use Action Plan satisfies the requirement for an environmental mitigation and monitoring plan (EMMP). The project EMMP should simply incorporate the SUAP by reference. 4.2 Allowed Pesticides Synthesizing across the PER analysis, ONLY the below-listed pesticides (active ingredients) are permitted for procurement and/or use in USAID/Bangladesh AIP. For reference, AIs considered, but REJECTED are also listed in Annex 17. Allowed Fumigant AIs registered by Strict Conditions Bangladesh DAE-PPW and registered with USEPA for similar unrestricted use aluminum phosphide for stored grains for use only by trained and certified Allowed Miticide AIs registered by Bangladesh DAE-PPW and registered with USEPA for similar unrestricted use applicators, not farmers; see Fumigation PEA Strict Conditions abamectin/avermectin use only formulations below 1.9% hexythiazox -- sulfur -- Allowed Insecticide AIs registered by Bangladesh DAE-PPW and registered with USEPA for similar unrestricted use Strict Conditions abamectin/avermectin use only formulations below 1.9% acephate USAID/Bangladesh AIP PERSUAP 61

79 but only when plants are in vegetative state, acetamiprid not when flowering due to risk to pollinators and honeybee colony collapse disorder amitraz -- beta-cypermethrin -- bifenthrin -- buprofezin -- carbaryl -- chlorantraniliprole -- chlorfenapyr -- chlorpyrifos-ethyl for uses except spraying for household pests, favor the use of granular formulations for soil pests cypermethrin registered USA for medical, veterinary and household use diazinon but, choose and use non-rup formulations deltamethrin do not get into open water dimethoate but, choose and use non-rup formulations emamectin benzoate but, choose and use non-rup formulations Esfenvalerate but, choose and use non-rup formulations fenitrothion -- fipronil registered USA for use against termites, ticks, mites, fleas, ants, roaches and mole crickets flubendiamide -- gamma-cyhalothrin but, choose and use non-rup formulations imidacloprid but only when plants are in vegetative state, not when flowering due to risk to pollinators and honeybee colony collapse disorder indoxacarb (S-isomer) -- lambda cyhalothrin use only formulations 10% and below lufenuron -- malathion -- methomyl use only acute toxicity Class II and III products; not Class I phosphorous acid -- pymetrozine -- spinosad -- spirotetramat -- thiacloprid but only when plants are in vegetative state, not when flowering due to risk to pollinators and honeybee colony collapse disorder thiamethoxam but only when plants are in vegetative state, not when flowering due to risk to pollinators and honeybee colony collapse disorder zeta-cypermethrin but, choose and use non-rup formulations 2013 USAID/Bangladesh AIP PERSUAP 62

80 Allowed Fungicide AIs registered by Strict Conditions Bangladesh DAE-PPW and registered with USEPA for similar unrestricted use azoxystrobin -- carbendazim -- carboxim -- chlorothalonil -- copper -- copper hydroxide -- copper oxychloride -- copper sulfate -- cymoxanil -- cyproconazole -- dicloran/dcna -- difenoconazole -- dimethomorph -- fenamidone -- fosetyl aluminum -- mancozeb -- mandipropamid -- metalaxyl -- metiram -- propamocarb HCl -- propiconazole -- pyraclostrobin -- streptomycin sulfate -- tebuconazole -- tetraconazole -- tetracycline hydrochloride -- thiophanate methyl -- thiram -- trifloxystrobin -- Allowed Herbicide AIs registered by Strict Conditions Bangladesh DAE-PPW and registered with USEPA for similar unrestricted use 2 4 D -- bensulfuron-methyl -- carfentrazpone-ethyl -- cyhalofop-butyl -- fenoxaprop-p-ethyl but, choose and use only Class II and III products, not Class I glyphosate -- MCPA USAID/Bangladesh AIP PERSUAP 63

81 Mefenacet -- metribuzin -- nicosulfuron -- orthosulfamuron -- orzalin -- oxadiazon -- pendimethalin -- penoxysulam -- pretilachlor -- propanil -- quinclorac -- quizalfop-p-ethyl but, choose and use only Class II and III products, not Class I triasulfuron -- Allowed Rodenticide AIs Strict Conditions bromadiolone -- zinc phosphide only in concentrations of 2% and lower, which are EPA acute toxicity Class III 4.3 USAID Field Monitoring Requirement In addition to continuous monitoring by the AIP environmental compliance staff and others delegated, USAID s AOR, MEO and/or REA must at least two times annually, make inspection visits to several randomly selected plots receiving project assistance to check for compliance with the IPM and safer use measures summarized in section 4.4 below, and detailed data collection form found in Annex 9 and in the compliance tracking and reporting template that follows in Annex Summary of Compliance Requirements (Safer Use Measures) The above-listed allowed AIs can ONLY be used in compliance with the safer use measures and restrictions specified in the PER. These can be summarized as follows: A. Only pesticides approved by this PERSUAP may be procured and/or with USAID funds in USAID/Bangladesh AIP activities. These pesticides are enumerated in section 4.2, above. Pesticide procurement and/or use = use of USAID funds to: purchase pesticides; directly fund the application of pesticides; recommend pesticides for use; or purposely facilitate or enable the application or purchase of pesticides via provision of application equipment, credit support, or other means. B. AIP project support to field crop production e.g. field demo plots, pesticide support must be governed by a set of locally adapted, crop- and pest-specific IPM-based pest management plans. (Annex 1 below provides key information for IPs to develop these plans.) C. Appropriate project staff & beneficiaries must be trained in safer pesticide use & pesticide first aid; 2013 USAID/Bangladesh AIP PERSUAP 64

82 D. To the greatest degree practicable, the AIP and its activities must require use & assure maintenance of appropriate PPE and application equipment as well as safe pesticide purchase, handling, storage and disposal practices; E. The AIP project must be systematic in their pesticide-related record keeping and monitoring. The PER and the annexes provide substantial resources to support compliance with these requirements, as detailed in the table below. IPM/Safer Use Requirement Pesticide recommendations and use must be governed by a set of crop- and pest-specific IPMbased pest management plans. (AIP, demo farmers, partners and retailers are responsible for developing these plans.) Appropriate AIP staff & beneficiaries must be trained in safer pesticide use & pesticide first aid Farm Compliance Monitoring forms Key Resources Provided Annex 1: sets out in table format crop-by-crop, pest-by-pest chemical and nonchemical management methods recommended by this PERSUAP. This is intended to serve as the basis for a crop-specific pest management plan. Annex 7 provides toxicology information for each approved active ingredient, including human acute toxicities and chronic health issues, water pollution potential, as well as potential ecotoxicities to important non-target organisms like fish, honeybee pollinators, birds and several aquatic organisms. Annex 8 Training Topics provides significant discussion of safer use training elements. Annex 9 provides ideas for farm monitoring information to collect, and a format to collect it AIP must be systematic in their pesticide-related record-keeping and monitoring AIP communication specialist must reach public audiences with IPM and pesticide safety information AIP must track the impact of risk mitigation measures Annexes 10 & 11 provide record-keeping templates/aids Annex 15 provides ideas for ways to implement communications and topics to focus on. Annex 16 provides a template for monitoring risk mitigation actions 2013 USAID/Bangladesh AIP PERSUAP 65

83 2013 USAID/Bangladesh AIP PERSUAP 66

84 Annex 1: Matrix of Bangladesh Crops with Primary Production Constraints, PERSUAP-Recommended Pest Prevention GAP/IPM Tactics & PERSUAP-Recommended Curative Tools and Tactics Major Pests & Diseases Rice shoot & stem borer Preventive IPM Tactics Rice Use resistant and early-maturing varieties. Improved semidwarf varieties are generally more resistant to stem borers than the tall traditional ones. Transplant & grow healthy rice seedlings and plants. Harvest at the very base of the plants, or plow stubble under and flood. Early/synchronized planting & water management Curative IPM Tools: Pesticides Use natural extracts of neem and chili peppers. Wheat Leaf rust Use certified disease-free resistant hybrid seed. Resistant cultivars of wheat are available. Brinjal/Eggplant Stem and fruit borer Avoid growing eggplant 2 years in succession. Fruit sanitation. Remove infected fruit and destroy by composting. If new races of the fungus render current sources of resistance obsolete, fungicides such as propiconazole can be applied at 4 oz per acre to control disease outbreaks. To protect the flag leaf, applications should be made between tillering and heading. Spray with Neem extract. No additional methods. Leaf-eating caterpillars/moth larvae (several species) Sesame Eliminate nearby weeds. Use natural insecticide sprays containing BT, spinosad or neem oil. Groundnut, Soya Peanut leaf spots Crop rotations out of legumes for three or four years are Rotate fungicides containing copper, 2013 USAID/Bangladesh AIP PERSUAP 67

85 recommended. Select varieties with partial resistance and/or reduced susceptibility to disease (Perry for early leaf spot and web blotch). Beans: Long Bean, Lima Bean Aphids Common predators of aphids in beans include lady beetles, syrphid flies, and green lacewings. These and parasitoids generally keep aphid populations under control. Monitor the crop regularly. Bean leaf beetles Do not plant beans near Cucurbits. Practice post harvest tillage to expose the grubs in the soil to the sun heat and to predators. Rotate beans with non-host plants such as maize or sunflower to break the development cycle of the pest. Delay sowing, where practicable, to allow the crop to escape from high populations. chlorothalonil and propiconazole. Aphid controls in beans are seldom necessary, but if it is desired use spot treatments of natural insecticides containing neem oil or synthetic insecticides containing malathion or dimethoate. Can spray with natural insecticide containing neem oil/azadirachtin. Can use synthetic insecticides containing malathion. Tobacco white fly (Bemisia tabaci) Cucurbits: Cucumber, Squashes, Melons, Gourds Controlled in nature by hymenopteran parasitoids Soil drench with imidacloprid or (Encarsia and Eretmocerus species), lady beetles and thiamethoxam. minute pirate bugs. Spray natural solutions of insecticidal Monitoring crops and establishment of a pesticide program soap, horticultural oil, abamectin, neem after finding 1 white fly per 10 plants, spraying may be oil/azadirachtin or Beauveria bassiana if used. the infestation is heavy. Yellow sticky traps may reduce populations but cannot Spray with synthetic insecticides prevent the spread. containing acetamiprid or buprofezin. Downy Mildew (Pseudonospora cubensis) Resistant varieties are available for control. Use only clean, disease-free planting material. Make sure that soil is well drained. Avoid overhead irrigation. Apply a fungicide when disease symptoms first occur and repeat if symptoms worsen. Prune off heavily diseased old parts. Use synthetic pesticide containing mancozeb + metalaxyl, chlorothalonil, propamocarb, mancozeb, mefenoxam, azoxystrobin, famoxadone, cymoxanil + mancozeb USAID/Bangladesh AIP PERSUAP 68

86 Crucifers (cabbage, broccoli) Diamondback moth, Parasitoid, Diadegma semiclausum Plutella xylostella, For monitoring, use light traps over soap dish to control adult stages and monitoring insect population s dynamics. Sticky bright yellow or blue traps will help to trap and control adult stages. Crop rotation with non-susceptible hosts. Use of trap crops such as inter-planted or edge-planted mustards (but monitor and destroy plants before adults are produced). Mating disruption with sex pheromones has been shown to be effective in reducing diamondback moth populations in Florida. Sprinkle irrigation may reduce the number of caterpillars in the field; if it is applied at dusk, it may limit the activity of adults. Club root, Use lime to increase the ph if soil ph is lower than 7.2. Plasmodiophora Use resistant varieties if available. brassicae Use crop rotation to non-cole crops for several years. Control brassicaceous weeds near field. Manage drainage so soil does not waterlog. Use fresh soil for seedbed. Elevated seedbed. Weeds Hoe or hand weeding. Plastic mulch. Solanaceous Crops Tomato, Potato Late blight, Use tolerant varieties. Phytophthora infestans Drain the growing area adequately before planting. Follow proper planting date; do not plant late. Farmers use sticks and lines to raise tomato plants and fruit into the air to aerate the plant and raise the leaves and fruit away from the soil. Pruning lower leaves Bamboo stacking Plastic mulch Trichoderma Use of natural biological control with Trichogramma species, Metharizium anisopliae, Beauveria bassiana, Bacillus thuringiensis and neem applications. Use the Insect Growth Regulator (IGR). Rotate synthetic insecticides containing abamectin, imidacloprid, emamectin benzoate. Use Trichoderma sp. Herbicides are not recommended. Use synthetic fungicides containing azoxystrobin, copper sulfate, mancozeb, chlorothalonil, dimethomorph, pyraclostrobin USAID/Bangladesh AIP PERSUAP 69

87 Tomato leaf curl virus transmitted by whiteflies Bacillus subtilis Psedomonas flourescens Practice crop rotation Destroy infected plants especially before flowering and fruit set. Re solanaceous weeds Control root-knot nematodes Remove possible source of primary inoculums (infected seeds, weeds, tobacco products) Screening of seed beds Plastic mulch Trichoderma Bacillus subtilis Pseudomonas flourescens. Weeds Hoe or hand weeding Plastic mulch Leafminers, Liriomyza spp Purple blotch Alternaria porri Downy mildew Peronospora Alliums: Onions, Garlic Weed and crop residues removal after harvest. Crop rotation with corn, onions or other species not related with snow peas. Use of plastic mulch with a reflectent color, silver grey will be one of the more effectives. Use of yellow or blue sticky traps. Parasitoids/predators Botanical insecticides Use certified disease-free seedlings. Sanitation, clean up crop residues, burn. Plastic mulch covering to avoid plant contact with soil and minimize weeds that enhance microclimate conditions favorable to disease dispersion. Heat treatment of bulbs at 35 to 40 C for 4 to 8h reduces the disease significantly. Eliminate crop residues, plant during dry season, and avoid irrigation during heat of the day. Use crop rotation. Use certified seed and good drainage. Plastic mulch covering to avoid plant contact with soil and minimize weeds that enhance microclimate conditions Spray natural solutions of insecticidal soap, horticultural oil, neem oil or Beauveria bassiana if the infestation is heavy. Treat soil with synthetic systemic insecticides containing imidacloprid or thiamethoxam. Spray with synthetic insecticides containing acetamiprid. Herbicides are not recommended. Use of synthetic insecticides containing abamectine or cyromazine. Use of natural fungicides containing Trichoderma, Pseudomonas fluorenscens, or Bacillus subtilus USAID/Bangladesh AIP PERSUAP 70

88 destructor favorable to disease dispersion. Heat treatment of bulbs at 35 to 40 C for 4 to 8h reduces the disease significantly. Eliminate crop residues, plant during dry season, and avoid irrigation during heat of the day. Use crop rotation. Use certified seed and good drainage. Sanitation, clean up crop residues, burn. Weeds Hoe or hand weeding Plastic mulch Anthracnose, Colletrotichum sp. Chilies/peppers Use certified disease-free seed and transplants of resistant varieties 29. Seed can be disinfested with a 30-minute soak at 52 C. Sanitize seedling flats if reusing them. Rotate out of infested fields to other crops for 3 years. Avoid potato, soybean, tomato, eggplant, and cucurbits as rotation crops 30. If using overhead sprinkler irrigation, apply in early morning so plants can dry before night-fall. Use mulch to reduce water splash onto leaves and fruit, and weed regularly without damaging fruit. Harvest fruit as soon as it is ripe. Sanitation: Remove and dispose of diseased plants throughout season and after harvest. Herbicides are not recommended. At flowering, can use synthetic fungicides containing mancozeb or metiram. Mites Polyphagotarsonemus latus Spider mites have many natural enemies that often limit populations; predacious mites and some insect feeds on spider mites, eg (Phytoseiulus persimilis and Amblyseius andersoni); the major predator mites commercially available for purchase and release are the western predatory mite and Phytoseiulus. Do weed control in and around field. Adequate irrigation is important because water-stressed Broad-spectrum insecticide treatments for other pests frequently cause mite outbreaks, so avoid these when possible. Natural insecticidal soaps or agricultural oils and neem extracts can be used for management (apply especially on the undersides of leaves). Use of synthetic insecticides containing USAID/Bangladesh AIP PERSUAP 71

89 Thrips Thrips parvispinus trees are most likely to be damaged. Use resistant varieties. Practice crop rotation out of solanaceous and other host crops. Use blue sticky traps for monitoring. Use plastic mulch. malathion or abamectin. Use insecticides containing thiamenthoxam, acetamiprid, imidacloprid, spinosad abamectin. Weeds Hoe or hand weeding. Plastic mulch. Herbicides are not recommended USAID/Bangladesh AIP PERSUAP 72

90 Annex 2. Guidelines for Pest Management Plans (PMPs) for Bangladesh Crops and Beneficiaries Recommended Timeline: By November 2014, make Pest Management Plans for at least ten key crops and the key pests, diseases, and weeds that impact their production. What is a PMP 31 Pest Management Plans or Guides provide field crop, livestock production or project decision-makers farmers and farm managers with best production practices recommendations, usually adapted by region, crop phenology and seasons. The aims of PMPs are to reduce the risks to production from pests by using a combination of best practices, including IPM, Integrated Vector Management (IVM) and Integrated Weed Management (IWM), that maximize crop or livestock health, and thus resilience to or tolerance of pests, and without an over-reliance on pesticides needed when best practices are not followed. Thus, prevention of pests plays a strongly pivotal role in the PMP, followed closely by management of pests when prevention alone is not adequate for the level of control needed or desired. Who are the PMP s intended audiences and users? Farm land preparation and crop production decision-makers Farmers Farm managers Why is a PMP being done? PMP Objectives: Prevent or reduce pest damage risk to agricultural production or health Protect the health of farmers, farm family members, laborers and community members from pesticide risks Maintain economically sound practices Reduce environmental pollution and degradation risks Enhance the overall quality and quantity of biodiversity on the sustainable farm work environment Respond to foreign market demand for the use of agriculture sector best management practice standards, also called Good Agriculture Practices (GAPs) which include IPM measures, to achieve farm and produce certification Comply with local, regional, donor and international laws, conventions, and regulations Organization of the PMP The following pieces of crop- or livestock-specific background information are used to build a PMP base General information on the crop/livestock/sector Crop/livestock common/species names: Crop/livestock developmental stages: Production regions and how they differ by soil type, ph, fertility, etc Overall concerns and priorities for crop/livestock production 31 PMPs or Year-Round (seasonal) IPM Programs are state of the art in many developed countries, and they help institutionalize IPM in planning and practice. PMPs provide agriculture managers and farmers with a tool to predict and prevent many crop pests of each crop throughout a season. See examples of PMPs at upper left corner under Year-Round IPM Programs USAID/Bangladesh AIP PERSUAP 73

91 Crop/livestock cultural best practices Crop/livestock Good Agriculture Practices (GAPs) including some IPM (see PERSUAP section on GAPS and IPM) recommendations Individual Pest Prevention and Management Sections for each of the following pest types: Invertebrate (Insects, Mites, Slugs/Snails, Nematodes) Diseases (Fungi, Bacteria, Viruses, Other) Weeds (annual grasses, broadleaves, perennial grasses, broadleaves, sedges, others) Vertebrates (birds, rodents, other) For each pest type, first, identify overall priorities for pest prevention and management in the target crop or livestock. Next, identify individual pest species noting the type of damage incurred; part of plant damaged: roots/rhizomes/tubers, stems/stalks, leaves, florescence, or seeds (field or stored); or if livestock, part of animal affected. To best understand how to manage a pest, one needs to understand how, where, when and on what parts of the plant or animal the pest feeds. For field pests and stored grain/food pests, many PMPs are designed and outlined as follows, for each major species of pest (insects, mites, slugs/snails, nematodes): Photographs of each pest, life stages Photographs of plant or livestock damage Description of the pest, life cycle and survival strategies 32 : Description of damage symptoms Best Prevention Practices o Use any and all of the above GAPs including IPM o Country or region-specific information Best Management Practices o Focus on prevention (above) o Country or region-specific information Information on PMP-recommended pesticides: Information needed for each pesticide referenced in the above PMP, by pest (so the farmer/farm manager has the information at their fingertips and do not need to refer to other documents and tables to find it): Pesticide essential information needed Active Ingredient (AI) name Product Trade names (with EPA and WHO Acute Toxicity Classifications in parenthesis) Amounts to use per hectare Price Pre-Harvest Interval (PHI) Special comments on best application methods and frequency Any resistance management strategies needed Pesticide application record sheet Guidelines for reducing spray drift Re-entry interval (REI): field safe re-entry period after spraying 32 Survival strategies: All pests have survival strategies that allow them to live and breed in each crop s farming systems. Knowing the survival strategies, including overwintering habit and alternate host plants, that are employed by the pest can help with decision making at the farming systems-level (e.g. choice of rotation crops) and also can help to anticipate pest outbreaks USAID/Bangladesh AIP PERSUAP 74

92 Maximum residue levels (MRL) permitted by markets Pesticide precautions with use including Reading the label Legal responsibilities and permitted registration uses Permit requirements for possession and use Recommended and obligated use of PPE and best practices First aid and antidotes Transportation best practices Storage best practices Safe use best practices Container disposal best practices Leftover pesticide disposal best practices Protection of non-pest animals, plants, endangered species and water body quality Protect natural enemies & honeybees: Posting signage in treated fields Some chemicals not permitted on processed crops Potential for phytotoxicity (crop injury) on some crops Documentation and record-keeping on plots Information needed on Natural Enemies of Pests: Common Names of Predators and Parasitoids effective against above pests: For a list of common natural enemies of crop pests, see Genera will likely be the same around the world, with different species in different continents, filling similar niches. IPM s broad implementation beyond the retailer level, i.e. to farmers, will require far more resources than those within the present project design and Objective. Amongst other cost items, whose costing are beyond the scope of this PERSUAP, the AIP can place an IPM Coordinator, and enhance its present number of professional training staff. IPM is presently the DAE s policy on pest management, and its policy cites advisory structures at the national, regional, District, and upazilla levels. AIP can cost and implement a feasibility study, business model and plan, and training of field application services of pesticides. PMP approval would ideally be performed at the District or upazilla DAE levels USAID/Bangladesh AIP PERSUAP 75

93 Annex 3. Elements of Integrated Pest Management (IPM) Program IPM 33 Although farmers are likely using numerous IPM tactics, without really calling them that, IPM philosophy or planning is not generally an active part of crop production in Bangladesh plots; thus, a basic understanding of the steps or elements needed in an IPM program are addressed below. Step 1: Learn and value farmers indigenous IPM tactics. Most farmers are already using their own forms of GAPs and IPM, many of which are novel, self-created, adapted for local conditions, and many of which work well. These local tools and tactics need to be well understood and taken into account when making PMPs. Accurate assessments of these farmer s GAP and IPM technologies, as well as an understanding of actual losses due to different constraints in farmers fields are required before designing a crop production and pest management program. Standards and Certification (S&C) farmers will have records of historical pesticide use and trends, as well as information on current use of artisanal or local IPM tactics. Step 2: Identify key pests for each target crop. Although perhaps up to ten species of pests may impact a crop and yields at different plant growth stages, generally only two or three are considered serious enough to spend money controlling. Farmers should be encouraged to monitor their population size, their life cycle, the kind of damage they cause and actual losses. Note that crop loss figures based on farmers perceptions of damage and loss are often overestimated. Step 3: Evaluate all management options. Use of best management practices, preventive measures, and organic options to control pest impacts may eliminate the need for synthetic pesticides. Step 4: Choose IPM methods, identify Needs and Establish Priorities. Continue dialog with project field staff, Department extension staff and farmers when choosing methods to be used. Consider the feasibility of attractive methods, including the availability of resources needed, farmers perceptions of pest problems, their abilities to identify pests, their predators, diseases and parasitoids, and to act upon their observations. Step 5: Do effective activities and training to promote IPM. Next, identify strategies and mechanisms for fostering the transfer of the needed IPM technology under various project and institutional arrangements, mechanisms, and funding levels. Define what is available for immediate transfer and what may require more adaptation and validation research. Set up an initial planning workshop (with a COP-supported and signed Action Plan) to help define and orient implementation activities, and begin to assign individual responsibilities. Learning-by-doing/discovery training programs The adoption of new techniques by small-, medium- and large-holder farmers occurs most readily when program participants acquire knowledge and skills through personal experience, observation, analysis, experimentation, decisionmaking and practice. At first, frequent (usually weekly) sessions are conducted for farmers during the cropping season in farmers fields by trained instructors or extension agents. Smallholder support and discussion groups Weekly meetings of smallholders, held during the cropping season, to discuss pest and related problems can be useful for sharing the success of various control methods. However, maintaining attendance is difficult except when there is a clear financial incentive (e.g., credit, advance knowledge of nearby infestations for early action leading to yield improvement). Educational material USAID/Bangladesh AIP PERSUAP 76

94 In many countries, basic written and photographic guides to pest identification and crop-specific management techniques are unavailable or out of date. Videos featuring graphic pictures of the effects of acute and chronic pesticide exposure, and interviews with poisoning victims can be particularly effective. Youth education Promoting and improving the quality of programs on IPM and the risks of synthetic pesticides has been effective at technical schools for rural youth. In addition to becoming future farmers, these students can bring informed views back to their communities. Food market incentives (especially important in the last decade) Promoting Organic, GlobalGAP, BRC, Fair Trade or other certification for access to the lucrative and rapidly growing S&C systems-driven international and regional food markets can be, and is, a strong incentive to adopt IPM. Step 6: Partner successfully with other IPM implementers. The following design steps are considered essential. Articulate the partnership s vision of IPM Organizations may forge partnerships based on a common commitment to IPM only to discover too late that that their visions of IPM differ considerably. It is therefore highly important that partners articulate a common, detailed vision of IPM, centered on the crops and conditions the project will encounter. Confirm partner institutions commitment The extent of commitment to IPM integration into project, design, and thus implementation depends strongly upon the following key variables: IPM program integration into larger project. The IPM program is likely to be part of a larger sustainable agriculture project. The IPM program must fit into a partner s overall goals. The extent of this integration should be clearly expressed in the proposed annual work plan. Cost sharing. The extent of funds (or in-kind resources) is a good measure of a genuine partner commitment. Participation of key IPM personnel. Organizations should have staff with expertise in IPM. In strong partnerships, these staff members are actively involved in the partnership. Step 7: Monitor the fields regularly. At minimum twice a week, farmers should monitor their fields for pests, as some pest populations increase rapidly and unexpectedly; this increase is usually related closely to the stage of crop growth and weather conditions, but it is difficult to predict the severity of pest problems in advance. Step 8: Select an appropriate blend of IPM tools. A good IPM program draws from and integrates a variety of pest management techniques, like those presented in the above list. Flexibility to fit local needs is a key variable. Pesticides should be used only if no practical, effective, and economic non-chemical control methods are available. Once the pesticide has been carefully chosen for the pest, crop, and environment, it should be applied only to keep the pest population low, not necessarily eliminate it. Step 9: Develop education, training, and demonstration programs for extension workers. Implementation of IPM depends heavily on education, training, and demonstration to help farmers and extension workers develop and evaluate the IPM methods. Hands-on training conducted in farmers fields (as opposed to a classroom) is a must. Special training for extension workers and educational programs for government officials and the public are also important. Step 10: Monitoring, Record-Keeping and Evaluation (M&E) USAID/Bangladesh AIP PERSUAP 77

95 Develop data collection forms and checklists, collect baseline GAP/IPM data at the beginning of the project, and set targets. For the use and maintenance of Good Agriculture Practices (that include safe pesticide storage, use and disposal), maintain farm or project files of: farmer and farm employee training records certification; farm soil, water, biodiversity, cropping and pesticide use maps; pesticide purchase and stock records; price increases or decreases, chemical application instructions including target pest, type of chemical applied, dosage, time of spray, rates at which pesticides were applied, harvest interval days, application machinery, PPE required and used, and any special instructions on mixing, exposure to children or dangers. Further, for project staff, beneficiaries, produce processing facilities, food warehouses, seed multipliers, or farmers that store seed or food and deal with stored seed and food pests, there are warehouse BMPs and monitoring reports that incorporate some IPM tactics. These monitoring forms track, by location or warehouse, use of pallets, stacking, general hygiene and sanitation, damaged packages, actual infestations or signs of rodents, molds, insects, drainage, locks and security measures, use of IPM tactics including least toxic chemicals and strict BMPs, including restricted access, for use of common but hazardous fumigants like aluminum phosphide USAID/Bangladesh AIP PERSUAP 78

96 Annex 4. Botanical Active Ingredients in Pesticides, Repellents, and Baits Regulated by USEPA Name Other Names Use Toxicity EPA Tracking Number Allium sativum Garlic Repels insects Low Allyl isothiocyanate Oil of Mustard Kills & repels insects Questionable Anise Oil Repels vertebrates Low allyl anisole Estragole Kills beetles Low Azadirachtin Azadirachta indica Neem tree Kills & repels insects Low, IV extract Bergamot Repels vertebrates Canola Oil Brassica Napus B. Campestris Kills many insects Low Capsaicin Capsicum frutescans Repels vertebrates Low, III Castor Oil Repels vertebrates Low Cedarwood Oil Repels moth larvae Low Cinnamaldehyde Ceylon and Chinese cinnamon oils Kills insects, fungi & repels vertebrates* Low Citronella Oil Repels insects & vertebrates Low Cloves, Crushed Low Dihydroazadirachtin Neem tree extract Azadirachta Kills & repels insects III-IV indica Eucalyptus Oil Repels insects, mites fleas & mosquitoes Low Eugenol Oil of cloves Kills insects** Low Geraniol Oil of rose isomeric w/ linalool Repels vertebrates** Low Geranium Oil Low Indole from all plants Trap bait: corn rootworm beetles Low Jasmine Oil Low Jojoba Oil Kills & repels whitefly kills powdery mildew Low Lavandin Oil Repels clothes moth Low Lemongrass Repels vertebrates Low Linalool Oil of Ceylon isomeric w/geraniol Repels insects, ticks, mites & spiders Low Maple lactone Roach trap bait Low Methyl salicylate Oil of wintergreen Repels moths, beetle & vertebrates May be Toxic in large quantity Mint Herb Kills aphids Low Mint Oil Kills aphids Low Mustard Oil Repels insects, spiders & vertebrates Low Neem Oil Kills whitefly, aphids Low USAID/Bangladesh AIP PERSUAP 79

97 Name Other Names Use Toxicity EPA Tracking Number 1-Octen-3-ol From clover, alfalfa Trap bait: mosquitoes Low Orange Repels vertebrates Low p-methane-3,8 diol Eucalyptus sp. Repels biting flies, mosquitoes Low 2-Phenylethylpropionate From peanuts Kills insects, ticks, mites & spiders Low Pyrethrum Chrysanthemum sp. Stored products use III Red pepper Chilli Repels insects Low Rosemary Herb Low Rotenone Derris sp., Tephrosia Controls ticks III Ryania Ryania speciosa Kills thrips, codling moth, corn borers Sabadilla Schoenocaulon sp. III Sesame Oil Sesamum indicum Pyrethroid synergist Low Soybean Oil Soja Kills insects, mites Low Thyme Herb Controls aphids Low ,2,4 Trimethoxybenzene From squash Trap bait: corn rootworm, cucumber beetles Low Verbenone From pine trees Repels bark beetles Low * attracts corn rootworm beetles, ** attracts Japanese beetles. Not all plant extracts are listed. More detailed information available for most oils: Natural Source: Only one or a few sources are listed. Most of these chemicals are found in many different plants. Since the time in the late 1990s when EPA did register biological ingredients listed above, it has since developed a list of botanical extracts (mostly essential oils) under Minimum Risk Pesticides Exempted under FIFRA Section 25(b) 34. Some of the very same ingredients are in both lists. However, most US states and USAID consider botanical extracts and essential oils used to kill, destroy, mitigate, or repel pests to be analyzed and treated as pesticides USAID/Bangladesh AIP PERSUAP 80

98 Annex 5. Natural Pesticides That Have Been Commercialized Insecticides azadirachtin component in neem oil Bacillus thuringiensis-bt Beauveria basiana cartap hydrochloride chili pepper extract emamectin benzoate garlic extract/allicin harpin protein kaolin clay d-limonene Metarhizium anisopliae narrow range dormant oil neem oil nuclear polyhedrosis virus (NPV) Paecilomyces lilacinus Paecilomyces fumosoroseus pyrethrin pyriproxyfen ryania soap (insecticidal) spinosad buprofezin Fungicides Bacillus subtilis Bordeaux mix copper copper hydroxide copper oxychloride copper sulfate harpin protein sulfur Trichoderma species Nematocides Myrothecium verrucaria tomatillo oil + thyme oil extracts (Promax 35 ) Molluscicide iron phosphate botanical extract microbial microbial marine worm (Lumbriconereis heterodopa) extract botanical (spice) botanical extract botanical extract (spice) plant induced resistance elicitor inorganic mineral citrus extract (spice) microbial paraffin oil botanical extract microbial microbial microbial botanical extract IGR (Juvenile Hormone mimic) botanical extract fatty acids microbial extract IGR (Chitin Synthesis inhibitor) microbial inorganic (Bordeaux ingredients EPA registered) inorganic inorganic inorganic inorganic plant induced resistance elicitor inorganic microbial microbial botanical + spice extracts soil biopesticide inorganic USAID/Bangladesh AIP PERSUAP 81

99 Annex 6. Acute Toxicity of Pesticides: EPA and WHO Classifications General Toxicity Pesticides, by necessity, are poisons, but the toxicity and hazards of different compounds vary greatly. Toxicity refers to the inherent intoxicating ability of a compound whereas hazard refers to the risk or danger of poisoning when the pesticide is used or applied. Pesticide hazard depends not only on toxicity but also on the chance of exposure to toxic amounts of the pesticide. Pesticides can enter the body through oral ingestion, through the skin or through inhalation. Once inside the body, they may produce poisoning symptoms, which are either acute (from a single exposure) or chronic (from repeated exposures or absorption of smaller amounts of toxicant). US Environmental Protection Agency (USEPA) and World Health Organization (WHO) Toxicity Classifications Basically, there are two systems of pesticide toxicity classification. These are the USEPA and the WHO systems of classification. It is important to note that the WHO classification is based on the active ingredient only, whereas USEPA uses product formulations to determine the toxicity class of pesticides. So, WHO classification shows relative toxicities of all pesticide active (or technical) ingredients, whereas EPA classification shows actual toxicity of the formulated products, which can be more or less toxic than the active ingredient alone and are more representative of actual dangers encountered in the field. The tables below show classification of pesticides according to the two systems. a) USEPA classification (based on formulated product = active ingredient plus inert and other ingredients) Class Descriptive term Mammalian LD 50 Mammalian Irritation Oral Dermal Inhalation Eye 1 Skin Aquatic invert/fish (LC 50 or EC 50 ) 2 Honey bee acute oral (LD 50 ) LC 50 I Extremely toxic Corrosive Corrosive < 0.1 II Highly toxic Severe Severe < 2 µg/bee III Moderately toxic No corneal opacity Moderate µg/bee IV Slightly toxic None Moderate or slight Relatively non-toxic Practically non-toxic ,000 > 11 µg/bee Non-toxic > 10,000 1 Corneal opacity not reversible within 7 days for Class I pesticides; corneal opacity reversible within 7 days but irritation persists during that period for Class II pesticides; no corneal opacity and irritation is reversible within 7 days for Class III pesticides; and Class IV pesticides cause no irritation 2013 USAID/Bangladesh AIP PERSUAP 82

100 2 Expressed in ppm or mg/l of water b) WHO classification (based only on active or technical ingredient) Class Descriptive term Oral LD 50 for the rat (mg/kg body wt) Dermal LD 50 for the rat (mg/kg body wt) Solids Liquids Solids Liquids Ia Extremely hazardous Ib Highly hazardous II Moderately hazardous III Slightly hazardous U Unlikely to present acute hazard in normal use USAID/Bangladesh AIP PERSUAP 83

101 Annex 7: PERSUAP Analyses of Active Ingredients in Pesticides Registered in Bangladesh Introduction to Annex 7 Annex 7 below compiles all of the AIs in pesticides (natural and synthetic) registered for use in Bangladesh, and proposed for imminent registration. Project decision-makers especially those who interface at the field level with beneficiary retailers and farmers are encouraged to look at the label of potential pesticide choices to determine the AIs contained in them and then use this Annex as a quick reference guide to attributes and issues with each chemical. The pesticide attributes include pesticide class (to manage resistance by rotating chemicals from different classes), EPA registration and Restricted Use Pesticide (RUP) status (to comply with Regulation 216) and acute toxicity (judged by this document to be safe, or not, for smallholder farmers most Class I chemicals are not considered safe for smallholder farmers to use). Annex 7 also presents chronic health issues, water pollution potential, and potential toxicities to important non-target organisms like fish, honeybee pollinators, birds and several aquatic organisms. Further, Annex 7 contains basic pieces of human safety and environmental data needed for the various analyses required throughout the PER; ergo it is referred to throughout this document. And it provides data used to produce the projectcritical information contained in Annexes 8 and 9. Thus, this PERSUAP provides useful tools for evaluating and choosing among IPM options, including natural and synthetic pesticides, while adhering to 22 CFR 216, as well as aiming at the market-driven best practices found in Standards and Certification (S&C) systems the highest international standards available. See Annex 7 Matrix, below. Key to matrix: Red shading: Do not promote products containing AIs shaded in red strikethrough color on USAID-supported plots or wood processing Green shading: Can be promoted on USAID-supported plots Yellow shading color: Some products accepted; some products rejected RUP: Few = one or two products; Some = a third of products; Most/All = most or all products WHO Acute Toxicity Classes: O = Obsolete; Ia = Extremely Hazardous; Ib = Highly Hazardous; II = Moderately Hazardous; III = Slightly Hazardous; U = Unlikely to present acute hazard in normal use EPA Acute Toxicity Classes: I = Extremely Toxic; II = Highly Toxic; III = Moderately Toxic; IV = Slightly Toxic Chronic Human Toxicity: KC = Known Carcinogen; PC = Possible Carcinogen; LC = Likely Carcinogen; ED = Potential Endocrine Disruptor; RD = Potential Reproductive & Development Toxin; P = Risk of Parkinson s Ecotoxicity: NAT = Not Acutely Toxic; PNT = Practically Not Toxic; ST = Slightly Toxic; MT = Moderately Toxic; HT = Highly Toxic; VHT = Very Highly Toxic References used to find pieces of data contained in Annex 7: See references at the end of the report 2013 USAID/Bangladesh AIP PERSUAP 84

102 Bangladesh Pesticide Active Ingredients in Products Registered 2013 Bangladesh Insecticides List Active Ingredients Class EPA Registered Restricted Use Pesticide WHO Acute Toxicity Class EPA Acute Toxicity Classes Chronic Toxicity Groundwater contaminant fish bees birds amphibians Ecotoxicity worms Mollusks Crustaceans Aquatic Insects Plankton abamectin/avermectin microbial extract yes some NL II, III ED, RD no data ST HT PNT MT HT VHT VHT acephate organophosphate yes no III II, III PC, ED potential MT HT MT ST ST ST acetamiprid neonicotinoid yes no NL III NL potential NAT MT HT NAT alpha cypermethrin synthetic pyrethroid no no II II, III PC no data HT HT PNT MT VHT VHT VHT aluminum phosphide inorganic yes all NL I NL no data HT HT HT MT amitraz formamidine yes no III III PC, ED, RD no data MT PNT ST ST NAT ST beta cypermethrin synthetic pyrethroid yes some NL II, III PC, ED no data HT HT ST HT bifenthrin synthetic pyrethroid yes some II II, III PC, ED, RD no data VHT HT MT HT buprofezin insect growth regulator yes no U II, III PC no data MT ST MT NAT MT cadusafos organophosphate no no Ib NL NL no data HT HT HT HT HT HT carbaryl carbamate yes no II II, III KC, PC, ED potential MT HT PNT MT VHT ST HT HT MT carbofuran carbamate yes most Ib I, II ED potential MT HT HT ST MT MT HT HT VHT carbosulfan carbamate no no II II NL no data HT HT HT HT HT cartap hydrochloride nereistoxin no no II II NL no data MT MT chlorantraniliprole/rynaxypyr anthranilic diamide yes no NL III NL no data NAT MT MT MT HT chlorfenapyr pyrazole yes no II III PC no data HT HT HT chlorpyrifos (ethyl) organophosphate yes some II II, III ED no data HT HT HT MT PNT MT VHT HT MT cypermethrin synthetic pyrethroid yes some NL II, III PC, ED, RD no data HT HT PNT MT VHT VHT VHT deltamethrin synthetic pyrethroid yes some II I, II, III ED no data HT MT VHT NAT VHT VHT diazinon organophosphate yes some II II, III ED, RD potential MT HT VHT MT MT MT HT HT HT dimethoate organophosphate yes no II II PC, ED, RD potential ST VHT VHT HT MT VHT HT VHT MT emamectin benzoate botanical yes some NL I, II, III NL potential HT MT HT HT HT endosulfan organochlorine no some II I, II ED no data VHT MT MT MT MT MT HT HT MT esfenvalerate synthetic pyrethroid yes few II II, III ED no data VHT HT ST VHT ST HT ethion organophosphate no no II II, III NL no data MT MT MT ST VHT VHT VHT fenazaquin unclassified no no II II NL no data HT MT MT MT HT HT HT HT fenbutatin oxide organotin yes most U III ED, RD no data VHT NAT MT MT HT VHT fenitrothion organophosphate yes no II II, III ED no data MT HT MT MT MT MT VHT HT MT fenthion organophosphate no no II II ED potential MT MT VHT VHT HT HT VHT VHT fenvalerate synthetic pyrethroid no no II III ED no data VHT HT ST HT VHT HT HT HT VHT fipronil pyrazole yes some II II, III PC, ED potential HT HT HT HT HT flubendiamide benzene dicarboxamide yes no NL III NL no data HT NAT MT MT HT 2013 USAID/Bangladesh AIP PERSUAP 85

103 2013 Bangladesh Insecticides List gamma cyhalothrin pyrethroid yes some III I, II, III ED no data HT HT ST HT imidacloprid neonicotinoid yes no II II, III NL potential NAT MT VHT indoxacarb, S isomer oxadiazine yes no O III NL no data MT HT HT NAT MT isoprocarb/mipc carbamate no II NL no data MT ST ST VHT lambda cyhalothrin synthetic pyrethroid yes some II II, III ED no data VHT HT PNT VHT VHT VHT VHT lufenuron (lofenoron) benzoyl urea yes no NL III NL no data MT ST MT MT HT ST malathion organophosphate yes no III II PC, ED potential MT HT MT HT ST VHT MT VHT HT methomyl* carbamate yes few Ib I, III ED potential MT HT HT ST HT ST HT VHT HT monomehypo nereistoxin no no NL NL no data phenthoate organophosphate no no II II ED no data HT HT MT MT HT VHT VHT phosphorous acid inorganic yes no U III NL no data ST phoxim organophosphate no no II NL NL no data HT HT PNT MT VHT VHT profenofos organophosphate yes all II III NL potential HT VHT VHT VHT pymetrozine triazine yes no III III PC, ED potential MT ST MT MT MT quinalphos organophosphate no no II II ED no data HT HT HT MT spinosad microbial yes no U III NL no data MT HT PNT ST HT MT spirotetramat keto-enol yes no NL II, III NL no data MT MT MT MT thiacloprid neonicotinoid yes no II II PC no data MT ST MT VHT ST thiamethoxam neonicotinoid yes few NL III PC no data PNT HT PNT PNT PNT PNT PNT thiodicarb carbamate yes most II II, III PC no data MT MT PNT MT VHT HT triazophos organophosphate no no Ib NL NL no data HT MT HT MT HT validamycin carbohydrate no no U NL NL no data NAT HT ST NAT zeta cypermethrin pyrethroid yes some Ib II, III PC, ED no data VHT VHT NAT NAT VHT VHT VHT 2013 Bangladesh Miticides/Acaricides List Active Ingredients Class EPA Registered Restricted Use Pesticide WHO Acute Toxicity Class EPA Acute Toxicity Classes Chronic Toxicity Groundwater contaminant fish bees birds amphibians Ecotoxicity worms Mollusks Crustaceans Aquatic Insects Plankton abamectin/avermectin microbial yes no NL II, III RD no data ST HT PNT HT VHT VHT bromopropylate benzilate no no III, U IV NL no data MT ST MT MT MT MT MT cyhexatin organotin no no none I RD no data VHT ST VHT VHT ethion/diethion organophosphate no II NL no data MT MT MT ST VHT VHT VHT hexythiazox insect growth regulator yes no U III PC no data HT NAT MT MT MT mos propargite unclassified yes t NL I PC, RD no data HT PNT HT NAT HT sulfur/sulphur inorganic yes no U III NL no data NAT NAT NAT NAT NAT 2013 USAID/Bangladesh AIP PERSUAP 86

104 2013 Bangladesh Fungicides Active Ingredients Class EPA Registered Restricted Use Pesticide WHO Acute Toxicity Class EPA Acute Toxicity Classes Chronic Toxicity Groundwater contaminant fish bees birds amphibians Ecotoxicity worms Mollusks Crustaceans Aquatic Insects Plankton azoxystrobin strobin yes no U III NL potential MT MT MT MT MT VHT benalaxyl xylylalanine no no U none none no data MT MT ST MT MT benalaxyl-m phenylamide no no U none none no data MT ST ST MT MT carbendazim benzimidazole yes no U III PC, ED no data MT NAT ST ST ST HT carboxin oxathiim yes no U III RD no data MT MT NAT MT NAT chlorothalonil chloronitrile yes no NL II, III PC potential VHT HT ST VHT MT MT copper inorganic yes no NL I, II, III NL no data MT HT PNT HT HT VHT ST ST copper/cupric hydroxide inorganic yes no II I, II, III NL no data HT MT MT MT HT NAT HT HT copper oxychloride inorganic yes no NL II, III NL no data MT MT MT MT VHT copper sulfate (basic) inorganic yes no II I, II, III NL no data MT HT PNT HT HT VHT ST ST cymoxanil unclassified yes no III II, III NL no data MT MT ST MT MT MT ST cyproconazole azole yes no III III PC no data MT MT MT MT MT dicloran/dcna chlorophenyl yes no U II NL potential MT MT MT MT MT MT difenoconazole azole yes no III III PC, ED no data MT MT ST MT MT HT dimethomorph morpholine yes no U III NL potential MT MT MT MT ST diniconazole triazole no no III NL NL no data MT MT MT MT edifenphos/edifenfos organophosphate no Ib NL no data MT MT HT epoxiconazole triazole no no NL NL PC, ED no data MT MT MT MT fenamidone (phenamidone) unclassified yes no NL II, III NL no data MT MT MT MT MT flusilazole azole no no III III NL no data MT MT MT MT MT fosetyl aluminum unclassified yes no NL II, III NL potential NAT ST ST MT NAT MT hexaconazole azole no no U IV PC no data MT HT NAT MT MT NAT iprodione dicarboximide yes no U III LC, ED potential MT NAT ST HT iprovalicarb(e) unclassified no no U none LC no data MT ST MT MT isoprothiolane phosphorothiolate no no III III NL no data MT ST ST MT kasugamycin antibiotic no no U NL NL no data ST ST MT ST ST mancozeb dithiocarbamate yes no U III PC, ED, RD no data MT MT ST HT NAT mandipropamid mandelamide yes no NL III NL potential MT MT ST MT MT metalaxyl benzanoid yes no III II, III NL potential ST PNT PNT ST metiram dithiocarbamate yes no U III PC, ED, RD potential ST PNT ST MT MT MT propamocarb carbamate no U III NL no data ST NAT NAT 2013 USAID/Bangladesh AIP PERSUAP 87

105 2013 Bangladesh Fungicides propamocarb hydrochloride carbamate yes no NL III NL potential MT MT MT MT MT propiconazole azole yes no II II, III PC, RD potential MT MT ST MT MT propineb dithiocarbamate Zn no no U NL RD no data MT PNT PNT MT MT MT MT pyraclostrobin strobin yes no NL II, III NL potential ST MT MT MT HT quaternary ammonium inorganic no no NL NL NL no data st(r)eptomycin sulfur (sulfate) antibiotic yes no NL III RD no data NAT tebuconazole azole yes no III II, III PC, ED potential MT MT MT MT MT MT HT tetraconazole triazole yes no II III PC potential MT MT MT MT MT MT tetracycline HCl carboxamide yes no NL III RD no data NAT MT NAT NAT thiophanate methyl benzamidazole yes no U III PC, RD potential MT PNT NAT ST thiram/tmtd (diothio) carbamate yes no III III ED, RD no data HT NAT PNT VHT HT NAT HT HT tricyclazole azole no no II II NL no data MT MT MT ST MT ST tridemorph morpholine no no II NL NL no data MT ST MT VHT MT trifloxystrobin strobin yes no NL III NL no data ST ST MT MT zineb dithiocarbamate no no U II, III ED, RD no data MT MT MT NAT MT NAT ST ST ST 2013 Bangladesh Rodenticides List Active Ingredients Class EPA Registered Restricted Use Pesticide WHO Acute Toxicity Class EPA Acute Toxicity Classes Chronic Toxicity Groundwater contaminant fish bees birds amphibians Ecotoxicity worms Mollusks Crustaceans Aquatic Insects Plankton bromadiolone coumarin yes no Ia III NL no data MT MT MT zinc phosphide inorganic yes yes Ib I, II, III RD no data HT VHT HT MT 2013 USAID/Bangladesh AIP PERSUAP 88

106 2013 Bangladesh Herbicides List Active Ingredients Class EPA Registered Restricted Use Pesticide WHO Acute Toxicity Class EPA Acute Toxicity Classes Chronic Toxicity Groundwater contaminant fish bees birds amphibians Ecotoxicity worms Mollusks Crustaceans Aquatic Insects Plankton 2 4 D chlorophenoxy acid yes no II III PC, ED potential ST HT MT ST NAT NAT NAT ST ST acetochlor chloroacetanilide yes most III II, IIII PC, ED potential MT MT ST MT MT bensulfuron methyl sulfonyl urea yes no U II, III NL potential NAT MT ST MT ST NAT butachlor chloroacetanalid no no U III PC no data HT MT NAT MT MT MT HT MT carfentrazone ethyl triaolinone yes no III III NL no data MT NAT NAT MT MT MT cyhalofop-butyl (as cyhatopbutyl) phenoxypropionate yes no U II, III NL no data MT MT NAT MT MT ethoxysulfuron sulfonylurea no no NL NL NL no data MT ST MT MT fenoxaprop-p-ethyl propionic acid yes no NL I, II, III NL no data MT ST PNT ST MT MT glyphosate phosphonoglycine yes no U II, III NL potential ST ST NAT PNT MT ST isoproturon urea no no III NL NL no data MT ST MT MT HT MCPA chlorophenoxy acid yes no II II, IIII PC no data ST PNT NAT ST ST NAT NAT ST mefenacet oxyacetamid yes no U IV NL no data MT NAT MT MT metribuzin triazinone yes no II II, III ED, RD potential MT NAT MT MT ST ST nicosulfuron sulfonylurea yes no U II, III NL potential MT MT MT MT MT orthosulfamuron pyrimadinylsulfonyl urea yes no NL III PC potential NAT NAT MT MT oryzalin (as orzatin) dinitoaniline yes no U III PC, RD potential MT MT MT MT HT HT oxadiargyl unclassified no no NL NL NL no data MT NAT MT MT NAT oxadiazon oxidiazole yes no U II, III PC, RD no data MT MT ST MT MT ST HT paraquat bipyridylium yes most II I, II P potential ST NAT MT ST ST ST NAT ST pendimethalin dinitroanaline yes no III III PC, ED no data MT NAT ST MT MT penoxysulam triazolopyrimidine yes no U III PC potential MT MT MT NAT NAT pretilachlor chloroacetanilide no no U NL NL no data MT MT ST MT propanil analide yes no III II, III PC potential MT NAT MT ST NAT ST ST ST pyrazosulfuron-ethyl sulfonylurea no no U NL NL no data NAT MT NAT NAT quinolinecarboxylic quinclorac acid yes no U III NL potential MT NAT MT MT quizalfop-p-ethyl a propionic acid yes no NL I, III NL no data MT MT MT MT MT triasulfuron sulfonylurea yes no U III PC, RD potential MT MT NAT MT MT 2013 USAID/Bangladesh AIP PERSUAP 89

107 2013 USAID/Bangladesh AIP PERSUAP 90

108 Annex 8. Training Topics 36 and Safer Pesticide Use Web Resources, and Bangladesh PPE sourcing GAP/IPM Pest identification: How to recognize common important pests and diseases Monitoring (use Annexes 9 and 10): The importance of frequent crop monitoring for pests, diseases and weeds GAP and IPM concepts, tactics and tools found in Annex 1 that can reduce pesticide use and associated risks on specific pests of Bangladesh IP target crops PMPs Pest Management Plans (use Annexes 1 and 2): Creating and using these farm crop-management tools Pesticides Understanding pesticides: Quality, types, classes and acute toxicities of common pesticides Regulations: US, EU and Bangladesh laws that guide pesticide registration and use Natural pesticides: Raise awareness of and promote the use of natural pesticides found in Annexes 1, 4, 5 and 7 as well as green-label synthetic pesticides with relatively low risks Spot Treatments: The importance of spot treatments if needed (instead of crop-wide treatments) MSDS: How to use MSDSs for pesticide-specific information on risks and risk reduction measures REI Re-Entry Intervals: Pesticide-specific risks associated with entering a sprayed field too soon after the spray operation PHI Pre-Harvest Interval: Pesticide-specific risks associated with harvesting a crop before pesticides have had a chance to break down MRL Maximum Residue Level: Risks associated with pesticide residues on human food Vulnerable individuals: The importance of keeping children, pregnant women, elderly and infirm away from the field while spraying and kept out after spraying Human and environmental risks: Risks associated with more commonly-used pesticides (use information from MSDSs and Annex 7) When to spray: Early in the morning, late in the afternoon, or night without wind or rain Use of recommended PPE: Why it is used (see product MSDSs, product labels and web reference below) Proper use and maintenance of sprayers, including proper sprayer calibration and spray nozzle choice Proper clean-up & post spray hygiene Safe Use: How to purchase, transport, store and use pesticides safely ( safe purchase requires quality, brandname products) Maintenance: of PPE and sprayers Monitoring for the development of pesticide resistance Proper collection and disposal of pesticide rinseate and packaging (see disposal web reference below and MSDSs) The use of pesticide spray buffer zones near schools, water resources, organic crop production, apiaries, bird sanctuaries, biodiversity enclaves, national parks or other sensitive areas. How to reduce and mitigate risks to critical environmental resources and biodiversity (found in PER Factors E and G) 36 See analysis of Crop Life Asia s training materials as Annex 14 and Communications Strategy Annex USAID/Bangladesh AIP PERSUAP 91

109 Honeybees: Ensuring pesticide applicators notify beekeepers about spray activities, and spray early morning or late afternoon when no heavy winds or rain are present Water Pollution: Raise awareness of pesticides (especially some herbicides) with high ground water contamination potential where water tables are high or easy to reach (use Annex 7 and MSDSs) Exposure routes: Ways pesticides enter the body and ways to mitigate entry Basic first aid: Understanding how to treat pesticide poisonings (see first aid web reference and MSDSs) Record-keeping: Pesticide used, when used, which crop, how applied, who applied Web Safer Pesticide Use Training Resources: General Mitigation of Potential Pesticide Dangers General Measures to Ensure Safe Use: Chapter 13 EPA Recommended Worker Protection Standards: (all types of PPE) (respiratory PPE) Routes of Pesticide Exposure and Mitigation of Risks: Chapter 13 Basic First Aid for Pesticide Overexposure: Chapter 13 International PIC & POPs Lists: PIC Pesticides and Industrial Chemicals ( POPs Pesticides and Chemicals ( Pesticide Disposal Options: Training on USAID pesticide management: Training module for Pesticide Risks, Safer Use and Compliance by Global Environmental Management Support Project (GEMS): Identification of comment pests in Bangladesh with pictures: Sources of PPE in Bangladesh: In Bangladesh there are no specific suppliers or dealers of PPE for pesticide spraying, use, or handling who sell solely these types of products. There are however suppliers and dealers who sell or supply medical, laboratory, or scientific equipment in addition to other products, mainly long rubber gloves, respiratory masks, and safety goggles. The addresses of two such suppliers are: 1. ALPHA SCIENTIFIC Mr. Khafil Uddin Hatkhola, Motejheel, Dhaka Mobile: kbsohail2009@gmail.com 2013 USAID/Bangladesh AIP PERSUAP 92

110 2. F.M. SCIENTIFIC COMPANY Md. Saddam Hossain (Faysal) 33/3, Hatkhola Road (Tikatuly), Dhaka Mobile: , USAID/Bangladesh AIP PERSUAP 93

111 Annex 9. Field Monitoring Form for Farmer Best Practices including GAP and IPM options (in English; Bangla translation follows) Name of USAID Contractor/Grantee Staff Responsible for Monitoring Demonstration Farms: Name of Demonstration Farmer: Crop: Date: What are the major pests encountered by the farmer?: Which of the attached Preventive and Curative GAP and IPM tools and tactics are used by farmer? Are pesticides used by demo farmer? Yes No How are pesticides applied? backpack sprayer other What are the names of the pesticides used?: Which PPE does farmer have and use? gloves overalls boots respirator goggles Has the farmer had IPM and Safe Pesticide Use training? Yes No Are there any empty pesticide containers scattered in the field? Yes No Are there signs that the backpack sprayer has leaks? Yes No Does the farmer understand the pesticide label information? Yes No Is the pesticide stored safely out of the house or away from kids? Yes No Does the farmer use gloves for mixing the pesticide with water? Yes No What times of the day are the pesticides applied? Are pesticides applied during rain or windy conditions? Yes No Are women or children permitted to apply pesticides? Yes No Are empty pesticide containers are used to store water? Yes No Does the farmer rinse equipment away from streams and open water? Yes No Does the farmer wash clothes after applying pesticides? Yes No How does the farmer dispose of empty pesticide containers? puncture/bury burn Is there any evidence that pesticides are becoming less effective? Yes No 2013 USAID/Bangladesh AIP PERSUAP 94

112 Annex 9 : ক ষ ত পযর ব ণ ফমর ক ষ ক র সর প ত ( জএ প এব আই পএম অ ভ র ) ইউএসএআই ড কত র ক নয পযর ব কর ন ম দশর ন ক ষ ক র ন ম ফসল ত রখ ১ ক ষ ক কত র ক চ ত ধ ন ধ ন ক টসম হ ২ ক ষ ক কত র ক বয বহ ত জএ প/আই পএম প ত ক. খ. গ. ৩ দশর ন ক ষ ক ক টন শক বয বহ র ক রন কন? হয ন ৪ ক টন শক য় গ প ত বয কপয ক অনয নয ৫ বয বহ ত ক টন শ কর ন ম ৬ ক ষ ক বয গত র সর ম দ বয বহ র ক রন কন? হয ন ৭ ক ষ ক ক ধর নর বয গত র সর ম দ বয বহ র ক রন? হয ভস ওভ র ক ট ব ট ম চশম ৮ ক ষ ক আই পএম এব নর পদ ক টন শক বয বহ রর শ ণ প য় ছন কন? ৯ ক ষ ত ক ন খ ল ক টন শক কন টইন র প ড় আ ছ কন? হয হয ন ন ১০ বয কপয ক য় র ক ন ছ ব ট আ ছ কন? হয ন ১১ ক ষ ক ল ব ল ন দর শত তথয ব ঝ ত প র ছন কন? হয ন ১২ ক টন শক নর প দ এব শশ দর থ ক দ র স র ণ কর হ য় ছ কন? হয ন ১৩ প নর স থ ক টন শক মশ ন র সময় ক ষ ক হয ভস বয বহ র ক রন কন? হয ন ১৪ দ নর ক ন সময় ক টন শক য় গ ক র থ কন? ১৫ ব ব অ ধক ব ত সর ম ধয ক টন শক য় গ ক রন কন? হয ন ১৬ ন র ও শশ র ক টন শক য় গ ক রন কন? হয ন ১৭ খ ল ক টন শক ক ইন র প ন স র ণ বয বহ র কর হয় কন? হয ন ১৮ ক ষ ক বয বহ ত সর ম দ উ জল শ য় ধ ত ক রন কন? হয ন ১৯ ক টন শক য় গর পর ক ষ ক ত র ক পড় ধ ত ক রন কন? হয ন ২০ খ ল ক ইন র কভ ব বয ব পন ব অপস রণ ক রন? ম ট চ প দ য় প ড় য় ফ ল ২১ ক টন শ কর ক যর ক রত ক ম য ওয় র ক ন ন জর আ ছ কন? হয ন 2013 USAID/Bangladesh AIP PERSUAP 95

113 Preventive and Curative GAP and IPM options: Preventive Preventive Curative Soil nutrient, texture and ph testing Farmer ability to correctly identify pest predators, parasitoids and diseases Pest resistant/tolerant seed/plant variety Early/late plantings or harvestings to avoid pests Seed treatment with pesticides Soil moisture testing Raised-bed production or mounding Irrigation and drip irrigation Use of natural fertilizers (manure, compost) Use of purchased mineral fertilizers Combinations of organic and mineral fertilizers Crop rotation Use of green manure crops Farmer ability to correctly identify pests and their damage Weekly field scouting to assess pest levels/damage Use of trap crops to trap and destroy pests Removal/pruning of diseased or heavily infested plants/tree branches Planting parasite-attracting plants on field margins Put baits and use other practices to encourage predator/parasite buildup Use of pheromone traps to monitor pest levels Inter-planting crops with aromatic herbs (celery, cilantro, parsley, dill or local plants) that repel pests Mulching with organic materials or plastic to control weeds Plant living barriers or bamboo/tree barriers on windward edge of field Exclude insect pests by using vegetable tunnels and microtunnels Use of biodiversity or energy conservation practices Crop stalks, residue and dropped fruit destruction/composting season end Mechanical insect control by hand picking Farmers make & apply local artisanal plant extracts (neem, pyrethroid, garlic, chili, other) Weed control by machine cultivation, hoe or hand Purchase and release of predators or parasitoids to control major pests Use of pheromone traps to reduce overall pest levels Use of pheromone inundation to confuse pest mating Spot treatment of pest hotspots with insecticides, miticides or fungicides Area spraying (complete field coverage) using synthetic and natural insecticides, miticides or nematocides Use of synthetic and natural fungicides or bactericides Use of herbicides for weed control Farm use of a locked storage building for pesticides Farmer use of pesticide in-ground compost trap for depositing and capturing spilled or leftover pesticides Farmer use of receptacle for empty pesticide bottle disposal 2013 USAID/Bangladesh AIP PERSUAP 96

114 Annex 10: Farm and Project Record Keeping Associated with Pesticide Use (English version; Bangla version immediately follows) These should be customized, simplified and translated by AIP 2013 USAID/Bangladesh AIP PERSUAP 97

115 র স য় নক প ণয র ব ণ জয ক ন ম খ ম র র স য় নক মজ ত ববরণ স য় র স য় নক উপ দ ন ঘণম % বয পয কট তক র ক নব ন ন * শ ধ ম শ ত বয ই র স য় নক বয অন ম দন ও বয বহ র অন ম ত * ত লক ভ বয ত স হ হ লন গ দ কর ণ ক জ/ ল * ত র স য় নক বয র ধরন ও ওজন অন য য় ১ ট ক র ফরম বয বহ র কর ণ ম ক ন ত রখ বতরণ ক ত নত ন মজ ত ল/ ক জ র ক মজ ত ল/ ক জ ই স য ক ত মজ ত ল/ ক জ অন ম দ নর ক রন (ভ ম ন র ও বয বহ রর উ দ দশয উ খ কর ণ) বয বহ র পরবত মজ ত ল/ ক জ ইস য ক র (ন ম) র হণক র র ন ম র অব শ খ ল প ( ব ত প সহ) ক টন শক প স প ত ময় দ ৎত ণর র ত রখ ক টন শক প সক র ১ ২ ৩ ৪ ৫ ৬ ৭ ৮ ৯ ১০ অন ম ত দ নক র র স য় নক মজ ত ত রখ 2013 USAID/Bangladesh AIP PERSUAP 98

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118 1.- Control Card for Pesticides Use.- This card will stay with farmer, to keep a record on the use of pesticide by crop. CONTROL FORM FOR THE USE OF PERTICIDES GENERAL DATA FARMERS NAME Community: Municipality: Province: Altitude: USE OF PESTICIDES - 1st TREATMENT CROP: SURFACE: Pest to be treated Name of material Date and time of application Quantity used Environmental conditions: Justification for use Other recommended control measures Result of application NAME AND SIGNATURE OF IG AND NRM SUPERVISOR: USE OF PESTICIDES - 2nd TREATMENT CROP: SURFACE: Pest to be treated Name of material Date and time of application Quantity used Environmental conditions: Justification for use Other recommended control measures Result of application NAME AND SIGNATURE OF IG AND NRM SUPERVISOR: 2013 USAID/Bangladesh AIP PERSUAP 101

119 ১ কটন শক বয বহ রর জনয নয় ণ ফমর এই ক ডর ট শ সয ক টন শক বয বহ রর রকডর র খ ত ক ষ কর ক ছ থ ক ব ক টন শ কর বয বহ র নয় ণ ফমর স ধ রণ তথয ক ষ ক র ন ম ম ইউ নয়ন থ ন জল ক টন শক বয বহ রর থ মক বণর ন শসয ভ ম য ক ট দমন কর ব ক টন শ কর ন ম য় গর ত রখ ও সময় বয বহ ত প রম ণ প র বশগত অব বয বহ রর ব বচন অনয নয স প র শ ক ত ক টন শক নয় ণ প ত ক টন শক য় গর ফল ফল পযর ব কর ন ম ও র ক টন শক বয বহ রর ত য় বণর ন শসয ভ ম য ক ট দমন কর ব ক টন শ কর ন ম য় গর ত রখ ও সময় বয বহ ত প রম ণ প র বশগত অব বয বহ রর ব বচন অনয নয স প র শ ক ত ক টন শক নয় ণ প ত ক টন শক য় গর ফল ফল পযর ব কর ন ম ও র 2013 USAID/Bangladesh AIP PERSUAP 102

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121 Annex 11: 2013 Bangladesh AIP PERSUAP Country Visit Schedule, Contacts and Map of Visit Sites Trip Report (from to ) Barisal, Khulna and Jessore in a team (Alan Schroeder, Shakil Ahmed, Salahddin) SL Place/Farme r/retailer Shop 1 DAE, Barisal Mr. Monirul Islam, Horticulture Specialist; ; Nitto Ranjan Biswas, Crop Production Specialist, , Debanshu Kumar Shaha, PPS, Habib & Sons Propreitor: Aminul Islam Sarker, Uzzal Chandra, Manager Person met Latitude Longitude Error Software Vill Mouza Union Thana District Remarks 22 70'60.524" 90 36'98.665" ±3490 Location Tracker Barishal Shador Barishal Shador Barishal Shador 20 70'43.218" 90 37'34.229" ±2730 Location Tracker Hatkhola, Sharpotti Barishal Shador Barishal Shador Barishal Shador Barishal Shador Barisal Barisal 3 Charbaria Store Sajid Ahmed Sumon, '43.218" 90 37'34.229" ±2730 Location Tracker Hatkhola, Sharpotti Barishal Shador Barishal Shador Barishal Shador Barisal 4 Khan Enterprise Propreitor: Aminul Islam, Habib Store Shahid, '80.925" 90 37'68.077" ±3218 Location Tracker Hatkhola, Sharpotti 22 36'22.525" 90 33'93.768" ±2750 Location Tracker Pouro New Market Barishal Shador Potuakhali Shadar Barishal Shador Potuakhali Shadar Barishal Shador Potuakhali Shadar Barisal Potuakh ali 6 New Bauphal Beez Vandar 7 M/S Rupali Seeds, Dealer of Syngenta 8 Shorab Ali Hawlader, Fazlur Rahman Sikder, Propreitor: Amol Chandra Mali , Propreitor: Md. Tuhin Talukder , 22 35'97.906" 90 33'78.326" ±2937 Location Tracker Thanapara Potuakhali Shadar 22 35'97.906" 90 33'78.326" ±2937 Location Tracker Thanapara Potuakhali Shadar Potuakhali Shadar Potuakhali Shadar m GPS Status Amirabad Amirabad Mogor, ward -5 Potuakhali Shadar Potuakhali Shadar Nolcity Potuakh ali Potuakh ali Jhalokat hi 2013 USAID/Bangladesh AIP PERSUAP 104

122 Jubayer 9 Sultan Ali, Md. Jalal Uddin Hawlader 10 Abdul Latif, Rabiul Islam, Anupom Mondal, Ilias Ali 11 Anwar, Begum 12 Sirajul Morol, Shafiqul Islam 13 M/S Rupali Krishi Vandar m GPS Status Bacalia Bacalia Bacalia Kaukhali Pirojpur , '65.515" 90 35'39.494" ±3311 Location Tracker Gutudia Gutudia Gutudia, Ward m GPS Status Masagona Mazagona Korinia, Ward '26.804" 90 37'20.551" ±4005 Location Tracker Khornia Khornia Khornia, Ward-1 Propreitor: Md. Alal Uddin Morol , BAE, Jessore GM Abdur Rouf (Horticulture Specialist, ; Sumir Kumar Ghoshami ( Crop Production Specialist) ; Nirod Kumar dey (Plant Protection Specialist) Seed Processing Centre, BADC, Jessore 16 Abdur Razzak, Rafiqul, Jakir Shardar, Faruk, Hasan, Alamgir, Salim, Imdadul 17 Jononi Traders 18 BAE, Chougasa, Jessore Shahjahan Kabir, DD, Md. Jahangir, AHM Jahangir Alam, UAO, '18.198" 90 35'20.431" ±3702 Location Tracker Khornia Bazar Khornia Khornia, Ward m GPS Status Jessore Shadar Jessore Shadar Jessore Shadar Dmuria Dumuria Dumuria Dumuria Jessore Shadar 23 15'88.299" 89 23'13.453" ±2792 Location Tracker Jessore Shadar Jhumjhumpur Jhumjhumpur Jessore Shadar 23 24'80.442" 89 23'13.453" ±2752 Location Tracker Abdulpur Abdulpur Choramon Kathi, Ward ±2792 GPS Status Abdulpur Abdulpur Choramon Kathi, Ward- 7 Jessore Shadar Jessore Shadar m GPS Status Chuadanga Chuadanga Chuadanga Chuadanga Shadar Khulna Khulna Khulna Khulna Jessore Jessore Jessore Jessore Chuadan ga 2013 USAID/Bangladesh AIP PERSUAP 105

123 19 Dipu Enterprise 20 Shariful, Naser Md. Motiar Rahman, '97.337" 89 16'46.292" ±2847 Location Tracker Choramonkathi Bazar Choramonkathi Choramon Kathi '10.115" 88 85'79.694" ±3964 Location Tracker Garabaria Garabaria Shonkor Chandra Jessore Shadar Chuadanga Shadar Jessore Chuadan ga 21 Joardar & Brothers 22 M/S Sohel Enterprise 23 M/S Aminul & Brothers Md. Mojumder Rahman, ; Md. Monirul Islam, Kazi Sohel Uddin, ; Subhan (Farmer) Aminul Islam, m GPS Status Chuadanga Chuadanga Chuadanga Chuadanga Shadar m GPS Status Notun Hatkhola Notun Hatkhola Jhinaidah Jhinaidah shadar m GPS Status Notun Hatkhola Notun Hatkhola Jhinaidah Jhinaidah shadar Chuadan ga Jhinaida h Jhinaida h 2013 USAID/Bangladesh AIP PERSUAP 106

124 2013 USAID/Bangladesh AIP PERSUAP 107

125 Map of Site Visits 2013 USAID/Bangladesh AIP PERSUAP 108

126 Annex 12: PERSUAP References Baker EL, Zack M, Miles JW, Alderman L, Warren M, Dobbins RD, Miller S, Teeters WR (1978) Epidemic malathion poisoning in Pakistan malaria workers. The Lancet, January: Websites: Website references used to develop the PERSUAP United States Government Title 22, Code of Federal Regulations 22, Part 216: United States Environmental Protection Agency and pesticides: International Treaties and Conventions: POPs website: PIC Website: Basel Convention: Montreal Protocol: Pakistan malaria poisonings: Pesticide poisonings: IPM and PMP websites: data/assets/pdf_file/0005/154769/cotton-pest-management-guide- 1.pdf Pesticide Research Websites: (Extoxnet Oregon State database with ecotox) (all types of application equipment) (pesticide Material Safety Data Sheets) (EPA Registration Eligibility Decisions) Ecotoxicity: 2013 USAID/Bangladesh AIP PERSUAP 109

127 (pesticide toxicity to honeybees) (pesticide toxicity to earthworms) Safety: (EPA regulated biopesticides) (IPM, PMPs and pesticide recommendations) (Restricted Use Pesticides) (EPA Health & Safety) (EPA pesticide product information) Personal Protection Equipment (PPE): (all types of PPE) (respiratory PPE) 2008 South Asia Regional IPM Collaborative Research Support Project PERSUAP, covering Bangladesh, India and Nepal 2013 Bangladesh DCHA Bureau (Democracy, Conflict and Humanitarian Assistance), FFP (Food for Peace), PROSHAR (Program for Strengthening Households Access to Resources) PERSUAP 2013 USAID/Bangladesh AIP PERSUAP 110

128 ANNEX 13: SCOPE OF WORK Position: Project Component: TDY/STTA Location: PERSUAP Consultant Environmental Compliance Dhaka, and Khulna, Barisal, Jhenaidah, Bangladesh Anticipated Start Date: 6/26/ Background: The Bangladesh Agricultural Inputs Project (AIP) aims to increase smallholder production and productivity in order to reduce poverty and improve food security in Bangladesh s southern delta. CNFA will achieve this goal through the following objectives: Establishment of Agro-Input Retailers Network: Creation of AIRN, with 3,000 certified retailers in 20 districts, supplying improved agricultural inputs to over 1 million farmers; Market Information Systems: Distribution of 200,000 Monthly Price Outlooks, developed through an innovative GIS-platform Input Market Information System; Quality Control and Standards and Regulatory Constraints: 50 input supply companies and 3,000 retailers adhering to 8 new input quality standards developed by industry associations through advocacy activities with public and private stakeholders; and Local Organizations Qualified to Receive Direct USAID Funding: At least 3 organizations qualified for direct USAID funding, no later than end of PY3. This scope of the project includes 500 plots and 5,000 registered chemicals. The consultant will visit enough farmers fields to gain an understanding of the array of agro-ecological zones in AIP s target areas, and the cropping patterns within them. He will be guided by local staff to identify common cropping patterns in at least 40 fields, possibly more time allowing. In addition, the consultant will work with local project staff to determine the most frequently-used registered chemicals that are available in Bangladesh, and will analyze those based on the 140 registered common product names (as indicated in the March 2013 publication called List of Registered Agricultural, Bio, and Public Health Pesticides in Bangladesh. 2. Objectives There are three major objectives for this assignment: Objective 1. Complete a Pesticide Evaluation Report (PER). The (PER) section addresses the 12 informational elements required in USAID s Pesticide Procedures. The 12 elements include: USEPA registration status of the proposed pesticide Basis for selection of the pesticide Extent to which the proposed pesticide use is, or could be, part of an IPM program Proposed method or methods of application, including the availability of application and safety equipment Any acute and long-term toxicological hazards, either human or environmental, associated with the proposed use, and measures available to minimize such hazards Effectiveness of the requested pesticide for the proposed use Compatibility of the proposed pesticide use with target and non-target ecosystems 2013 USAID/Bangladesh AIP PERSUAP 111

129 Conditions under which the pesticide is to be used, including climate, flora, fauna, geography, hydrology, and soils Availability of other pesticides or non-chemical control methods Host country s ability to regulate or control the distribution, storage, use, and disposal of the requested pesticide Provision made to local Environmental Specialist for training of users and applicators Provision made to local Environmental Specialist for monitoring the use and effectiveness of this pesticide Objective 2. Complete a Safer Use Action Plan (SUAP). The SUAP puts the conclusions reached in the PER into a plan of action, including assignment of responsibility to appropriate parties connected with AIP s pesticide activities. Objective 3. Address Outstanding Issues from Environmental Due Diligence Review. Some issues arose and were unable to be answered by the consultant who conducted the Environmental Due Diligence Review. This consultancy will address all remaining items resulting from that document. 3. Deliverables 1. Desk Study to include local environment regulations, the approved EDDR, and other relevant documents. 2. PERSUAP Scoping Statement for USAID approval 3. Upon arrival, kick-off meetings with relevant Dhaka officials government and associations, suppliers, etc. before field travel 4. Draft PERSUAP for USAID review and comment after field travel 5. Final PERSUAP for USAID approval within two weeks of departure 6. Implementation plan for AIP, detailing efforts to ensure compliance with the PERSUAP. This is the same as the SUAP. 7. Training course curricula regarding implementation of the PERSUAP. 8. Training course conducted for 1) CNFA staff (including sub-grantees and contractors) to support pesticide user, trainer and applicator compliance with the PERSUAP. 9. Before departure, briefing with USAID/Bangladesh on findings and recommendations 10. Appraisal of Crop Life Asia s Safe Use trainings and their relevance for training retailers 11. Advise Communications Specialist on how to incorporate safe use messaging into various media. AIP will assign a local environmental specialist or other designee if the local environmental specialist has not yet been hired to support the development of the PERSUAP and train as the ongoing project point of contact for implementation and updates. 4. Timeframe The consultancy, which will be comprised of a visit to Bangladesh at the beginning of July 2013 and work from home base, shall be conducted for working days (working days defined as Sunday to Friday) of international input and in conjunction with experts from the USAID-funded AIP USAID/Bangladesh AIP PERSUAP 112

130 Deliverable No. Description 1 Desk Study July Scoping Statement drafted and submitted to USAID/Dhaka July Draft Training Course July 1-12 Curricula (to be adapted to Bangladesh context incountry, following field visits) DRAFT Pesticide communication plan (contents and suggested medium) and its key messages (e.g. pictorial, written, and verbal considering literacy constraints and audiences) developed submitted to USAID for initial review 11 Appraisal of Crop Life Asia s Safe Use Trainings July 1-12 Travel to Bangladesh July (arrive July 14) Meeting with GOB, July suppliers and other relevant agencies PERSUAP Scoping Statement reviewed by USAID/Dhaka and forwarded to BEO July 16 planned Initial field visit July July 23 planned 3 PERSUAP Scoping Statement approved by BEO 9 Training Course Conducted in Dhaka and field offices (At least 2 field trainings and 1 for Dhaka staff) 10 Briefing with USAID on findings/recommendations 12 FINAL Pesticide communication plan based on field findings (contents and suggested medium) and its key messages (e.g. pictorial, written, and verbal considering literacy July Date TBD July USAID/Bangladesh AIP PERSUAP 113

131 constraints and audiences) developed with Communications Specialist and submitted to USAID for approval 5 Draft PERSUAP for USAID review and comment USAID reviews the draft PERSUAP 7 Implementation Plan (same as the SUAP) 6 Final PERSUAP for USAID approval August 11 August August 30 August Qualifications The international expert should have: Postgraduate degree in a relevant field Track record of completing PERSUAPs for USAID programs Familiarity with USAID s Pest Management Guidelines Work experience within the region would be an advantage Fluent in English Reference Documents: USAID Reg Agro-Inputs Project Environmental Due Diligence Review Bangladesh Environmental Laws and Regulations Other relevant documents 2013 USAID/Bangladesh AIP PERSUAP 114

132 Annex 14: PERSUAP Consultant Analyses of CLA s Training Materials with Recommendations Topic 1: Alan Schroeder review of Crop Life Asia s Safe Pesticide Use Training Video A 25-minute Safe Pesticide Use video, with English subtitles, depicting life and pesticide use in Rahamatganj Village, produced by Crop Life Asia (CLA), as a subsidiary of Crop Life International (CLI). Verbal Appraisal General findings: Appraisal of Crop Life Asia s Safe Use trainings and their relevance for training retailers. Done on , with verbal feedback to AIP staff, and feedback to USAID during de-brief. As they stand, the materials are not perfect none of the CLI materials ever have been but they are useful nonetheless; in any case CLI does good safety training, however AIP should not entrust IPM training to CLI their area of competence is chemicals. In addition, written comments are provided below, with clarification points that AIP should make during the showing of the video, to add more detail and clarifications where these are needed. Written Appraisal a. The plastic cover of jacket of the video shows Crop Lie Asia, instead of Crop Life Asia ; it is missing the f in Life. b. The video is missing any preventive IPM tools and tactics, and focuses primarily on pesticides and pesticide safety issues. The main message is safety. The video title includes and focuses on only pesticide safety, not IPM. This presentation is not designed to be about IPM; however it could do IPM more justice by strongly promoting it beyond just the concept. Slide presentations made by Dr. Schroeder, and presented to AIP staff, can be adapted and used to introduce and supplement IPM. Further, Annex 1 of the DRAFT PERSUAP is all about IPM tools for specific crop-pest combinations, and this detailed information can be used by AIP to make highly pest-specific power points for each important crop and main pest. Which is why we need to move at warp speed with the review and approval of that PERSUAP, so we can use it. Moreover, the IPM CRSP approach to IPM is based primarily upon an academic and not necessarily practical understanding and perspective. Local NGOs and international consultants who understand the practical aspects must be tapped for this, along with any commercial farmers producing for certified export markets, and using preventive IPM tools to reduce costs. c. The first four minutes of the video introduces the village, village life, and, at the 4-minute mark, pests reducing crop production. d. One family is doing well; another is not. e. At 5:40 minutes we learn that the family not doing well used pesticides inappropriately. (AIP also needs to mention that no one is fully taking preventive IPM tools into account). f. The family doing well with crops and production is celebrating a good harvest festival called Nabana. g. At 7:15 the video mentions that pests are destroying crops. h. At 7:20 the video mentions on the use of pesticides. i. At 7:50 the video mentions that an agriculture officer should be consulted for advice, which is true USAID/Bangladesh AIP PERSUAP 115

133 j. At 8:10 the video mentions that the appropriate dose of pesticide must be used, not too much, not too little, which is true. k. At 8:15 the video mentions that using the correct dose of pesticide is good for the environment, which is true, as too much will damage the environment more. l. At 8:30 the video mentions that the pesticide label must be consulted for pesticide use information, and that the use of too much pesticide is not good, both of which are true. m. At 9:20 the video mentions that pesticide timing and dose are both important, which is true. n. At 9:27 the video mentions that the use of excessive pesticides may make the crop poisonous, land fertility may fall and water may be polluted, all of which are true. o. At 9:30 the video mentions that use of too little pesticide is also not good, which is true, as pest resistance to pesticides may result (AIP can mention this point). p. At 15:25 we learn that hands must be washed before eating, and after using pesticides, which are both true. q. At 16:30 the video mentions that food should be taken after washing hands after washing the pesticide machine and hands, which is true, but is written in a very passive voice, which is probably cultural. The main point is that hands must be washed, not that food must be taken after hands are washed (AIP can emphasize that food does not always need to be taken after hands are washed after pesticide application). r. At 16:33 and 16:59 the video mentions that children and livestock should not enter a field that has been sprayed, which is quite true. s. At 16:55 the video mentions that farmers should mark the field somehow to show that no one should enter, which is true; however, it also mentions that farmers could demarcate the sprayed field with a piece of rope hung all the way around the perimeter of the field, which I have never witnessed. Good idea, but not sure how economically possible. t. At 17:06 the video mentions that pesticides should be stored up and out of reach of children, which is true. u. At 17:09 the video mentions that pesticides should, if possible, be kept under lock and key, which is true. v. At 17:15 the video mentions that empty pesticide containers should be buried, which is true; however the video does not mention that they should be triple-rinsed with water and punctured to prevent re-use, before burial (AIP can mention this point during video viewing). w. At 17:30 to 17:58 the video mentions the importance of observing the waiting period after spraying and before harvesting a crop (known as the Pre-Harvest Interval or PHI, which should be listed on the pesticide label AIP can mention this PHI during showing of the video) and washing produce to remove pesticide residues before cooking and consumption, all of which is true. x. At 18:30 the video reiterates the importance of choosing the correct pesticide, using the proper timing, does and method of application, all of which are true (and can be expounded upon by AIP staff during showing of the video). y. At 18:50 the video mentions that malfunctioning or leaking backpack sprayers must not be used, which is true. They need to be maintained and fixed if leaking (AIP can mention this during video showing and training). z. At 18:53 the video mentions that pesticides should not be sprayed into the wind, which is so true. aa. At 19:00 the video mentions the use of proper headwear, a cap, to prevent pesticides from landing on the hair, which is true. bb. At 19:06 the video mentions the use of some sort of protection to be worn over the mouth and nose, even if a piece of cloth wrapped over, to prevent pesticide mist from entering the body by this route, which is true USAID/Bangladesh AIP PERSUAP 116

134 cc. dd. ee. ff. At 19:15 the video mentions that if a largish quantity of pesticide spills on the ground, that it should be covered by soil or sand, which is true. At 19:42 the video mentions that one should always follow pesticide container label instructions, which is true. At 22:08 the video mentions that pesticides, like angry elephants, can harm people, which is true. The rest of the video from 22:08 to 25:01 is dedicated to reiterating that pesticides are beneficial, that they help increase yields and that every household needs to use them for their crops, which is marketing spin (here, AIP can mention during video showing and training that this is marketing spin, and reiterate the need for doing a bunch of preventive IPM tactics BEFORE getting to using pesticides). Consultant Opinion on all of this: AIP can show the video during training, and that it will be useful, albeit with the above-mentioned clarifications. Other information sources will be tapped and used for emphasizing and promoting preventive IPM tools. IPM should be presented, covered, discussed and promoted, before this Safe Pesticide Use video is shown. Topic 2: Alan Schroeder review of Crop Life Asia s Pest & Pest Management Training Video A 25-minute Pest & Pest Management video, in Bengali, without English subtitles, depicting crops and pests in Bangladesh, produced by Crop Life Asia (CLA), as a subsidiary of Crop Life International (CLI). Verbal Appraisal General findings: Appraisal of Crop Life Asia s Pest & Pest Management trainings and their relevance for training retailers. Done on , with verbal feedback to AIP staff, and feedback to USAID during de-brief. As they stand, the materials are not perfect none of the CLI materials ever have been but they are useful nonetheless; in any case CLI does good safety training, however AIP should not entrust IPM training to CLI their area of competence is chemicals. In addition, written comments are provided below, with clarification points that AIP should make during the showing of the video, to add more detail and clarifications where these are needed. To reiterate, CLA does pesticide safety well; IPM training is best left to others. After all, about twothirds of the IPM video is about pesticide use and safe use. What would probably work best for AIP is to do IPM training, using a multi-faceted approach and do this prior to showing and discussing the Safe Pesticide Use training using the best pieces of information from 1. The PERSUAP & PERSUAP Annex 1 practical approach (once the PERSUAP is approved, at warp speed, so that AIP and its beneficiaries can use it); 2. IPM CRSP academic approach; and 3. CLA s self-promotional commercial pesticide-marketing approach. Comparisons or contrasts of the 3 approaches could be done as well. Written Appraisal a. The plastic cover of jacket of the video shows Crop Lie Asia, instead of Crop Life Asia ; it is missing the f in Life. b. The video covers major crops and pests/diseases of each crop. Slide presentations made by Dr. Schroeder, and presented to AIP staff, can be adapted and used to 2013 USAID/Bangladesh AIP PERSUAP 117

135 introduce and supplement this IPM information. Further, Annex 1 of the DRAFT PERSUAP is all about IPM tools for specific crop-pest combinations, and this detailed information can be used by AIP to make highly pest-specific powerpoints for each important crop and main pest. Which is why we need to move at warp speed with the review and approval of that PERSUAP, so we can use it. Moreover, the IPM CRSP approach to IPM is based primarily upon an academic and not necessarily practical understanding and perspective. Local NGOs and international consultants who understand the practical aspects must be tapped for this, along with any commercial farmers producing for certified export markets, and using preventive IPM tools to reduce costs. c. The video is in Bengali, however Alan Schroeder watched it with a local colleague to get translations. d. Each local crop is presented with written lists of pests and diseases, for different regions growing different crops. e. The video presents tiny pests with a hand-lens view, which is good. f. The video discusses how to identify commonly found insect pests, mites, fungal diseases, viral diseases, bacterial diseases, and others. g. The video discusses the importance of contacting an extension agent for advice. h. At about 18 minutes, the video introduces pesticides as a pest control solution, and the purpose of this part of the video ceases to be about IPM and switches to Safe Pesticide Use. i. From the beginning of the pesticide use part of the video, several scenes show helpers and sprayers without appropriate PPE, which is essential for any and all persons mixing concentrated active ingredient from the manufacturer bottle, where it is most harmful (because it is concentrated). These parts either should not be shown or should be heavily commented on during training. j. The video focuses on proper nozzles and that pesticide appliers do not clean the nozzle by blowing it out by mouth. k. The video shows a field being marked with flags for spraying, and notes that the Pre-Harvest Interval (PHI) should be followed after spraying. l. The video notes that all animals should be kept out of the sprayed field, and not to rinse the sprayer in open bodies of water, where they can kill fish and ruin water. m. The video shows that pesticides should not be sub-divided into other containers like empty juice or water bottles, and that the empty bottles should be buried (but after triple rinsing and puncturing them). n. The video shows that spray personnel should wash well after pesticide use, that pesticides should be kept out of the reach of children, and that leaking sprayers need to be fixed and maintained. o. The last part of the video shows proper first aid, treatment and transport to hospital of poisoned spray personnel. Appraisal of Issues with the Video The latter part of this video could be misleading to training audiences. Without editing it should not be shown and used in training events. Alternatively this latter portion could be used on the condition that training facilitators were trained to stop the video at these scenes and point out the wrongness of the scenes. The particular scenes and their inappropriateness are as follows: Time Scene 18:57 Depicts appropriate proportions of water mixed with wettable fungicide powder 2013 USAID/Bangladesh AIP PERSUAP 118

136 by a sprayer in PSE. For about a second, an observer/helper is in close proximity but with no PSE. 19:03 The same scene is repeated for about 2 seconds. 20:26 The sprayer over 4 5 seconds depicted donning PSE with the same helper apparently readying the backpack sprayer but without PSE. A similar scene shows the helper over 3 4 seconds assisting the sprayer by dipping water out of a bucket into the backpack sprayer with PSE. 21:35 The helper with PSE is handling fungicide powder 22:00 Same scene, again. 23:00 Spraying without gloves 24:26 Two persons walking through a freshly sprayed field, one with PSE and the other without PSE. 26:45 Depicts sprayer with no PSE USAID/Bangladesh AIP PERSUAP 119

137 Annex 15: Communications Media Plan for use by AIP s Communication Specialist for Marketing IPM and Pesticide Safe Use Information Media Plan of Action: 1. IPM Plan Extension Leaflets by Crop (can include best production practices for each crop as well as pest prevention and management): Copy and expand upon information contained above in Annex 1 as well as information contained in pest management plans and color crop-pest leaflets made by University of California Davis, for many of the same pests as follows: For adding local best production practices with IPM tools/tactics, if desired, AIP communication staff tasked with making leaflets would need to interview agronomists to understand all the production practices (soil tests, seed, sowing, soil water tension, weeding, tilling, fertilizing, irrigating, micronutrient applications and so on) recommended for an ideal crop yield. As practicable, choose from and emphasize the following topics: Soil quality and nutrition testing Resistant varieties Certified seed Seed treatment Soil solarization (heating under plastic with direct sun heat) Raised-bed production Use of plastic and organic mulches Proper seeding/thinning rate Soil moisture testing Organic fertilizers/compost Synthetic fertilizers Crop rotation Green manures Manipulate plant/harvest time Trap crops Pruning Farmscaping 38 Correct pest/disease ID Weekly monitoring Baited traps Sticky traps Pheromone traps Pheromone inundation Crop residue destruction Artisanal (home made) pesticides Conservation practices Mechanical weeding Spot pesticide treatments Production of natural microbial pesticides USAID/Bangladesh AIP PERSUAP 120

138 2. Pesticide Safety Extension Leaflets: Use AIP-adapted CLA materials and AIP-adapted pesticide safety slides sent by Alan Schroeder to make color extension leaflets or pamphlets. Use the following resources for additional pesticide risk mitigation best practices, and first aid recommendations: s/factsheets/pest_ti.htm. Emphasize the following topics: Pesticide types & uses Pesticide quality & choice factors Brand name, container integrity, respect expiration date No use of empty drink bottles for selling or storing pesticides Pesticides stored out of reach of children, under lock and key Pesticide label information Label pictograms Pesticide dose for pest Proper sprayer calibration Pest resistance development and management, rotation among classes/modes of action of pesticides For each commonly-used pesticide: Acute human health risks LD50 & acute human toxicities by WHO & EPA Re-Entry Interval (REI) Pre-Harvest Interval (PHI) Maximum Residue Level (MRL) Chronic human health risks Risks to honeybees Risks to fish and aquatic organisms Risks to birds/waterfowl Risks to protected environmental resources Empty container disposal Spray nozzle choices Sprayer parts and nozzle cleaning and maintenance How to reduce pesticide spray drift Pesticide breakdown pathways 3. Radio and Television Spots: Work with local extension service linkages to mass media to support IPM and safe pesticide use through already-established agriculture programs, or create a new agriculture program, as practicable. Emphasize the following topics: Each crop & primary pests/diseases Preventive IPM tactics & tools Natural (biological, organic) & Synthetic pesticides available Pesticide types & uses Pesticide quality & choice factors Brand name, container integrity, respect expiration date No use of empty drink bottles for selling or storing pesticides Pesticides stored out of reach of children, under lock and key Pesticide label information 2013 USAID/Bangladesh AIP PERSUAP 121

139 Label pictograms Pesticide dose for pest Proper sprayer calibration Pest resistance development and management, rotation among classes/modes of action of pesticides For each commonly-used pesticide: Acute human health risks LD50 & acute human toxicities by WHO & EPA Re-Entry Interval (REI) Pre-Harvest Interval (PHI) Maximum Residue Level (MRL) Chronic human health risks Risks to honeybees Risks to fish and aquatic organisms Risks to birds/waterfowl Risks to protected environmental resources Empty container disposal Spray nozzle choices Sprayer parts and nozzle cleaning and maintenance How to reduce pesticide spray drift Pesticide breakdown pathways 2013 USAID/Bangladesh AIP PERSUAP 122

140 2013 USAID/Bangladesh AIP PERSUAP 123

141 Annex 16: Mitigation and Monitoring Plan for IPM and Pesticide Safety Potential Environmental Risks & Impacts D= Demo plot suitability evaluation F= Field day T= Training Risks Associated with Pesticide Use Mitigation Measures & BMPs (Best Management Practices) Mitigation of Pesticide Risks Monitoring Indicators Indicators of Pesticides Best Management Practices Responsibility ES= Environmental Specialist CPRS= Communication and Public Relation Specialist STE= Senior Training Expert Responsible Staff to Train on Pesticide BMPs (T) & Monitor (Mon) Planned Mitigation (M) & Reporting (R) Frequency M = (as stated below) R = (Quarterly) (D) Use of non-epa registered pesticides, certain RUP pesticides, Class I pesticides, known carcinogens (D) Incorrect or improper pesticide selection (D) Groundwater (drinking water) & surface water contamination leading to aquatic ecotoxicity (fish kills) Training to Demo Plot Collaborators and retailers on banned, rejected and allowed pesticides: See PERSUAP Annex 7 and SUAP allowed and rejected pesticide AIs. Evaluate planned Demo plots for groundwater and surface water proximity + ecotoxicity of AIs Demarcate area of Demo plots for keeping pesticides out of ground and surface water, as follows: No mixing or rinsing sprayers in or near streams, ponds or rivers. All pesticide Active Ingredients (AIs) allowed as per PERSUAP No Class I pesticides used No pesticides containing endosulfan used Interviewed Demo Plot Collaborators understand choices & selection criteria Demo plot suitability evaluation checklists are signed by ES and COP and kept on record T= ES Mon= ES M = Oct Nov; Jan March; Sept R = Quarterly Mon= ES M = Oct Nov; Jan March; Sept R = Quarterly 2013 USAID/Bangladesh AIP PERSUAP 124

142 Keep pesticides at least 30 meters from drinking water sources. (F, T) Excessive pesticide quantities used Understand pests of each crop & available pest management tools Training to retailers on preventive tools/tactics in addition to curative pesticide tools, talks during field days F= ES T = STE Mon (F) = ES Mon (T) = STE M = Oct September R = Quarterly (F, T) Acute human poisoning leading to death Use of personal protective equipment (PPE): gloves for mixing, mask to protect mouth and nose from mist and vapors, rubber boots, hat, overalls. Training to retailers and messaging through print and electronic media on pesticide risks All recommended PPE present on demo sites and used (If a pesticide poisoning occurs, immediately inform health professional) Number of retailers attended in the safe use handling training T = STE Mon (F) = ES Mon (T) = STE Messaging= CPRS M = Oct September R = Quarterly (F, T) Chronic human poisoning leading to future health issues Training to retailers and messaging through print and electronic media on chronic health issues and use PPE (see Annex 7, draft PERSUAP, for chronic risks with each pesticide AI, pesticide label PPE recommendations, and types of PPE, above) PPE used during spraying Number of retailers attended in the safe use handling training T= STE Mon (F)= ES Mon (T) = STE Messaging= CPRS M = Oct September R = Quarterly (F, T) Death of pollinator honeybees Training to retailers and messaging through print and electronic media on methods for protecting honeybees from spray= Spray later afternoon after bees are in hive, or early morning. Number of retailers attended in the safe use handling training Interviewed trained retailers understand risks to honeybees T= STE Mon (F)= ES Mon (T) = STE Messaging= CPRS M = Oct September R = Quarterly 2013 USAID/Bangladesh AIP PERSUAP 125

143 (F, T) Mass-level local and migratory bird deaths (F,T) Sprayers leak at every parts junction (T) Incorrect pest identification (T) Integrated Pest Management (IPM) not known, or understood, or used Training to retailers on pesticide choices & selection= See draft PERSUAP Annex 7, bird toxicity. Training to retailers and messaging through print and electronic media on sprayer maintenance= Ensure that sprayer parts junctions do not leak with normal use; that proper nozzles are used for each application or pest. Training to retailers and messaging through print and electronic media on identification of most common pests= (draft PERSUAP Annex 1 for pests) Repeated training to retailers on use of IPM (use draft PERSUAP Annex 1 info) Interviewed Retailers understand pesticide choices & selection criteria Number of retailers attended in the safe use handling training Sprayers well maintained, not leaking Interviewed trained retailers can identify common pests, diseases and weeds IPM tools and tactics understood and used Number of trained retailers on IPM T= STE Mon (F)= ES Mon (T) = STE Messaging= CPRS T= STE Mon (F)= ES Mon (T) = STE Messaging= CPRS T= STE Mon= STE Messaging= CPRS T= STE, ES Mon= STE M = Oct September R = Quarterly M = Oct September R = Quarterly M = Oct September R = Quarterly M= Q4 R= Quarterly (T) Lack of understanding or use of pesticide retail BMPs Do training to retailers on: Security on shop outside and internal warehouse doors, windows Signage for warnings and fire procedures Operational (charged) fire extinguisher present Emergency contacts list present (fire, police, medical, poison control) Use of non-absorbent easily cleaned floor (tile) & shelf (metal/enamel) materials Number of trained retailers on shop-level retail storage and handling of pesticides T= ES, STE Mon= ES, STE M = June August R = Quarterly 2013 USAID/Bangladesh AIP PERSUAP 126

144 (T) PERSUAP BMPs not followed Pesticide spill cleanup materials (sawdust, broom/shovel, pail) Ventilation, no odors Pesticide types segregation Highly toxic pesticides stored up high out of reach of children No subdividing of pesticides from original containers to smaller empty containers Sprayers for sale Sprayer spare parts for sale Simple, cost-effective PPE available for sale No expired pesticides kept No leaking or corroded pesticide bottles kept No unregistered or illegal pesticides kept Pesticide label information legible without need for magnifying glass Sales personnel can identify common crop pests and diseases Sales personnel can offer advice on prevention of each pest/disease, and distinguish among control choices Proper inventory control and record keeping Good housekeeping, keep the shop clean and neat All pesticide related activities should follow requirements of the PERSUAP 12-factor analysis, using Schroeder Power Point presentations and PERSUAP present; Number of trained retailers, AIP staffs, Partner NGOs trained on advanced safe use and T= ES, STE Mon= STE Messaging= CPRS M = June August R = Quarterly 2013 USAID/Bangladesh AIP PERSUAP 127

145 CLA materials. During trainings to retailers, AIP staff, Partner NGOs, discuss: Each crop & primary pests/diseases Preventive tactics & tools Natural & Synthetic pesticides available Pesticide types & uses Pesticide quality & choice factors Brand name, container integrity, respect expiration date No use of empty drink bottles for selling or storing pesticides Pesticides stored out of reach of children, under lock and key Pesticide label information Label pictograms Pesticide dose for pest Proper sprayer calibration Pest resistance development and management, rotation among classes/modes of action of pesticides For each commonly-used pesticide= Acute human health risks LD50 & acute human toxicities by WHO & EPA Re-Entry Interval (REI) Pre-Harvest Interval (PHI) Maximum Residue Level (MRL) Chronic human health risks Risks to honeybees environmentally sound practices 2013 USAID/Bangladesh AIP PERSUAP 128

146 Risks to fish and aquatic organisms Risks to birds/waterfowl Risks to protected environmental resources Empty container disposal Spray nozzle choices Sprayer parts and nozzle cleaning and maintenance How to reduce pesticide spray drift Pesticide breakdown pathways 2013 USAID/Bangladesh AIP PERSUAP 129

147 Annex 17: PESTICIDE ACTIVE INGREDIENTS (AIS) REJECTED BY THIS PERSUAP The table below sets out all the Pesticide active ingredients considered but rejected along with the Reasons for rejection: Rejected Fumigant (AIs registered by Bangladesh DAE-PPW and considered but Rejected for Use by the AIP) FOR INFORMATION ONLY- NO USE Reasons for Rejection methyl bromide RUP, Montreal Protocol ozone depleting chemical being phased out internationally bristifluron not EPA registered Rejected Miticide (AIs registered by Bangladesh DAE-PPW and considered but Rejected for Use by the AIP) Reasons for Rejection bromopropylate not EPA registered cyhexatin mislabeled by DAE-PPW as insecticide; not EPA registered ethion not EPA registered propargite RUP Rejected Insecticide AIs registered by Bangladesh DAE-PPW and considered but Rejected for Use by the AIP Reasons for Rejection alpha-cypermethrin not EPA registered cadusafos not EPA registered carbofuran RUP, Class I carbosulfan not EPA registered cartap hydrochloride not EPA registered endosulfan RUP, being phased out as banned under POPs Treaty 39 ethion not EPA registered fenazaquin not EPA registered fenbutatin oxide RUP fenthion not EPA registered fenalerate not EPA registered isoprocarb not EPA registered monomehypo not EPA registered phenthoate not EPA registered phoxim not EPA registered profenofos RUP quinalphos not EPA registered thiodicarb RUP triazophos not EPA registered validamycin not EPA registered 39 Endosulfan (an organochlorine insecticide which is highly toxic and persists in the environment) is a USEPA restricted use pesticide which USAID/LAC no longer approves for any use. USEPA will completely phase out its use by USAID/Bangladesh AIP PERSUAP 130

148 Rejected Fungicide AIs registered by Bangladesh DAE-PPW and considered but Rejected for Use by the AIP Reasons for Rejection diniconazole not EPA registered edifenaphos not EPA registered flusilazole not EPA registered hexaconazole not EPA registered iprovalicarb not EPA registered isoprothiolane not EPA registered kasugamycin not EPA registered propamocarb not EPA registered propineb not EPA registered quaternary ammonium not EPA registered tricylclazole not EPA registered tridemorph not EPA registered zineb not EPA registered Rejected Herbicide AIs registered by Reasons for Rejection Bangladesh DAE-PPW and considered but Rejected for Use by the AIP acetochlor RUP butachlor not EPA registered ethoxysulfuron not EPA registered isoproturon not EPA registered metamifop not EPA registered oxadiargyl not EPA registered paraquat RUP pretilaclor not EPA registered pyrazosulfuron-ethyl not EPA registered Rejected Rodenticide AIs registered by Bangladesh DAE-PPW and considered but Rejected for Use by the AIP Not identified 2013 USAID/Bangladesh AIP PERSUAP 131

149 ANNEX 18: INITIAL ENVIRONMENTAL EXAMINATION OR REQUEST FOR CATEGORICAL EXCLUSION PROGRAM/ ACTIVITY DATA: Country Code: 388 Program Objective: Program Area: Program Element: Country/Region: Program/Activity Titles: Economic Growth 4.5 Agriculture 4.6 Private Sector Capacity Agricultural Enabling Environment Agricultural Sector Capacity Private Sector Capacity Bangladesh/ANE USAID/Bangladesh-Improved Food Security Funding Begin: 2011 Funding End: September 2015 LOP Amount: $262,395,209 Sub-Activity Amount: CE/IEE Prepared by: Nathan Martinez and Alamgir Hossain Date: January 11, 2012 IEE Amendment (Y/N): N If Yes, Date of Original IEE: ENVIRONMENTAL ACTION RECOMMENDED: (Place X where applicable) Categorical Exclusion: Deferral: Positive Determination: Negative Determination: With Conditions: Exemption: 1.0 Background and Activity Description: 1.1 Purpose and Scope of IEE: This IEE will cover the new food security Program of USAID/Bangladesh based on USAID/Bangladesh s Country Development Cooperation Strategy (CDCS) for FY Background: While Bangladesh has experienced steady advances in food production, including the tripling of rice production since the 1970s, it still faces considerable challenges to feed its growing population of approximately 150 million. Bangladesh is one of the most densely populated country in the world, and demographic trends indicate that the current population will grow to around 220 million by USAID/Bangladesh AIP PERSUAP 132

150 (UNFPA 2011). Increased land scarcity and volatile world food prices will pose challenges to improving national food security, specifically in the areas of food availability, access, and utilization. Feed the Future (FTF), the U.S. government s global hunger and food security initiative, renews the U.S. commitment to reduce hunger and poverty. The Bangladesh Feed the Future strategy has identified several major challenges hindering the country s food security, including: (1) insufficient productivity gains in agriculture to keep pace with an increasing population; (2) inability of the poor to buy food; and (3) poor food utilization or nutrition. As a result, the U.S. government has pledged over $325 million in foreign assistance over a five-year period to improve health, raise incomes and strengthen food security in Bangladesh. The Improved Food Security Project will address all three of these complex challenges through a combination of inter-related activities that will be implemented over a five-year period. The central goal is to increase the volume of food produced by Bangladesh s small farmers and increase the purchasing power of the food-insecure poor. DEVELOPMENT HYPOTHESIS: The results framework for Development Objective Two (DO2) of the USAID/Bangladesh Country Development Cooperation Strategy (CDCS) reflects the logical relationship of USAID/B efforts to improve food security. DO2 s develop hypothesis is: addressing constraints of availability, access, and utilization of food security will lead to positive outcomes for health and income security. GEOGRAPHIC FOCUS AND TARGETED BENEFICIARIES: 2013 USAID/Bangladesh AIP PERSUAP 133