Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP)

Transcription

1 September 2014 Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP) What F2F Implementers Should Know Volunteers for Economic Growth Alliance 1726 M Street, NW Suite 800 Washington, DC Tel: info@vegaalliance.org Would doing a volunteer assignment covering homemade pesticides made from dish soap or wood ash trigger the PER- SUAP requirement to vet the syllabus with the local USAID Mission? Homemade pesticides, such as wood ash and dish soap, are considered organic pesticides; USAID s Pesticide Procedures do not distinguish organic pesticides from other pesticides. Natural pesticides, bio-pesticides, botanicals, and biological pesticides are treated the same way as chemical pesticides, and the PERSUAP requirements are triggered. How can a new chemical (pesticide active ingredient) be added to the PERSUAP's approved chemicals list? If an Active Ingredient (AI) is not on the approved list of chemicals, assistance cannot be provided for that AI. Before a new AI can be approved for use in the F2F Program, an amendment to the F2F PERSUAP must be prepared and approved by the USAID Bureau of Food Security (BFS) Bureau Environmental Officer (BEO). Until USAID approves the amendment, the AI can t be recommended or purchased or discussed during training. Please note that USAID approval of PERSUAP amendments is not likely to happen quickly. F2F country staff/ implementing partners (IPs) should compile a list of AIs that are needed but are not on the approved list, and send an amendment request to the USAID F2F Agreement Officer s Representative (AOR). This may be done as a separate request to the F2F AOR or as part of regular F2F reporting to

2 Page 2 Guidance for Implementers: How to do an Assessment of Pesticide Issues in their Countries and TORs for a Country Pesticide Safety Assessment Assessments of pesticide issues could be carried out by F2F volunteers, either with a relevant and interested host organization or by using an Administrative Assignment Volunteer. Each F2F country office must use the questionnaire on the main constraints to safe use of pesticides in their countries of service that were completed for the PERSUAP. Section 2.1 of the F2F PERSUAP summarizes the information from the questionnaires. F2F IP in-country office are required to keep the completed questionnaire for their country. The first step in planning an assessment of pesticide issues should be to review the questionnaires. As stated in the PERSUAP, the information from the questionnaires is intended to give a broad-brush view. F2F volunteer End of Trip Reports can be used to build on the information in the questionnaires. This general picture of pesticide safety issues can be used to develop a list of high priority countries to conduct the study, perhaps choosing a few countries to serve as models. The information in the questionnaires and volunteer End of Trip Reports can also be used to emphasize specific topics in the TORs. A list of local pesticide experts and/or a few CVs should be obtained. In some cases, it may be best to pair a local expert with an international expert. To conduct the assessment, the F2F pesticide safety specialist(s) should interview experts, and verify the information by going to the field to gather data firsthand. About 25% of time should be spent on interviews and reviewing documents and 75% should be spent in the field observing actual situations and gathering data. Is it possible to do an all-organic IPM assignment that does not recommend pesticide use without triggering the PERSUAP requirement to vet the syllabus with the local USAID Mission? Theoretically, yes, if the training includes no discussion of pesticides, the PERSUAP requirements would not be triggered, and the F2F volunteer would not be required to vet the syllabus with the Mission. However, F2F volunteers will want the flexibility to discuss as broad a range of topics as possible, and even for an all-organic IPM assignment, course participants will likely bring up pesticides. Providing the syllabus to USAID for information and comment should be routine and not difficult or a constraint to training. Also, certain pesticides (see page 1) are acceptable within an IPM/allorganic context, yet assistance for their procurement or use is still governed by the PERSUAP. Therefore, the PERSUAP would be triggered, including the requirement to vet the syllabus with the USAID Mission; this condition is intended to add value to the syllabus. Besides vetting the syllabus with USAID, the volunteer, even if focusing on organic production and IPM, should be familiar with the PERSUAP list of approved AIs and other Safe Use Action Plan requirements.

3 Page 3 Sample TORs for a Pesticide Safety Assessment. BACKGROUND: In a rapid appraisal, the F2F Country Office found the following to be the key constraints to safe pesticide use (use is considered all steps from importation and manufacture to disposal): [FILL IN INFORMATION FROM THE F2F PESTICIDE QUESTIONNAIRE AND FROM F2F VOLUNTEER END OF TRIP REPORTS.] The F2F Country Office is undertaking this Pesticide Safety Assessment to build on the rapid appraisal, and to gain a better understanding of key constraints and possible solutions, which the F2F program could address in future volunteer recruitment. The international pesticide expert shall conduct the assessment of pesticide safety in [Country]. The Pesticide Safety Assessment Team should conduct interviews with knowledgeable sources and should verify the information by going to the field to gather data and make observations firsthand. The Assessment, not including annexes, should be approximately 40 to 50 pages in length. The Pesticide Safety Assessment Team should discuss and analyze the following topics/issues: the list is not all-inclusive; if additional topics are identified during the study, they should be included: Sources of Pesticides in the Country Pesticide importation (governance issues, cross border trade and control, etc.) Legal v. illegal sources Main countries and companies importing pesticides into the country Local manufacture of pesticides Local Pesticide Trade Main pesticide dealers in the country Types of locations where pesticides are bought/sold (large agro-input supply dealers, local markets, etc.) Availability of pesticides (low toxicity, different classes) Pesticide dealers/agro-input supply dealers and their knowledge of pesticides; are they trained, and do they receive continuous training? Sale of counterfeit pesticides, pesticides that are repackaged, pesticides without labels Do agro-input suppliers carry Personal Protective Equipment (PPE)? If not, why not? Do agro-input suppliers carry replacement parts for application equipment and are they knowledgeable about using the equipment, including calibration? Pesticide Use Accessibility of PPE: Do applicators/farmers use PPE? If not, why not? Does the country have a program to certify applicators? Do farmers apply pesticides on their fields or do they use trained applicators? Are applicators knowledgeable about maintenance of application equipment? Range of coverage and knowledge of extension officers What is the level of farmer knowledge about selecting, applying, storing, mixing, monitoring, and disposing of pesticides? Where do they get their information about pesticides? Are farmers familiar with and use IPM? Where do they get their information about IPM? How do farmers/applicators typically dispose of unused pesticides and containers? How do farmers/applicators clean and store application equipment? How do farmers/applicators store unused pesticides? Pesticide Governance How are pesticides registered/approved for use in the country? How often is the list of registered pesticides updated? Does government conduct compliance checks at supply dealers and markets? Does government train extension officers, applicators, or farmers in safe pesticide use and IPM? Does government produce and distribute information on IPM? Does the private sector provide information on safe use and IPM (do pesticide dealers provide support to applicators/farmers?) Does government adequately regulate import, distribution, use, and disposal of pesticides? How are obsolete pesticides dealt with in the country? Findings and Conclusions Analyze the situation for pesticide use and safety in the country and identify key findings. Recommendations Based on findings and conclusions, provide recommendations to the F2F Program, including recommendations that F2F could implement using volunteers; recommendations that F2F could suggest to the USAID Mission; and recommendations directed at government, private sector, and others.

4 Page 4 How to find out if there is a separate PERSUAP other than the F2F PERSUAP in effect in a given country. The F2F PERSUAP requires that USAID mission-wide or sector-wide PERSUAPs for a given country be kept in the F2F IP s country office. An IP can obtain mission-wide or sector-wide PERSUAPs from USAID. The IP s first line of contact for this should be the contact point at the local USAID Mission; if unable to obtain the PERSUAP through the Mission, the IP should contact the F2F AOR. IPs should send volunteers any PERSUAPs related to their assignment. Since there is no F2F country office for volunteers on flex assignments, the IP s home office is responsible for obtaining the governing PERSUAP(s). The IP should request relevant PERSUAPs for non-core countries, from the F2F AOR. Sometimes a PERSUAP can be found through an online search. However, if a volunteer finds a PERSUAP online, s/he should check with the IP to ensure that the PERSUAP is the current, governing PERSUAP. The IP should check with the F2F AOR on A Generic Syllabus for Type 1 and Type 2 Pesticide Related Volunteer Assignments. Below is a template for a syllabus for F2F volunteer training. The F2F volunteer should fill in the course-specific and technical aspects. This template provides text that can be used to 1) simplify syllabus reviews by USAID Missions, and 2) ensure that the training is in compliance with the F2F PERSUAP. SYLLABUS TEMPLATE FOR TRAINING UNDER THE FARMER TO FARMER PROGRAM COURSE TITLE: DATES OF COURSE: LOCATION OF COURSE: INSTRUCTOR S TITLE AND NAME: TARGET BENEFICIARY GROUPS FOR TRAINING: NUMBER OF COURSE PARTICPANTS (ESTIMATE): TYPE OF TRAINING (CLASSROOM, FIELD INSTRUCTION, ETC.): The Farmer-to-Farmer (F2F) volunteer, [NAME], whose expertise is [F2F VOLUNTEER S AREA OF EXPERTISE], will undertake the training program, [NAME OF THE COURSE/TRAINING TOPIC], with [HOST ORGANIZATION] on [APPROIXMATE DATES] in compliance with requirements of the F2F Initial Environmental Examination (IEE) and Pesticide Evaluation Report-Safer Use Action Plan (PERSUAP). The governing IEE (Farmer-to-Farmer, 2013) and F2F PERSUAP (December, 2013) state that: The syllabus for each training event that includes pesticide use will be submitted to the USAID F2F Activity Officer s Representative (AOR)/Contracting Officer s Representative (COR) and Mission Environmental Officer (MEO) for review and comment. The AOR/COR shall consult with the Bureau Environmental Officer (BEO) or relevant Regional Environmental Advisor (REA), as needed, in situations where there is no MEO. This syllabus is being submitted to USAID in compliance with the above requirement. The IEE and PERSUAP also state that: A representative from USAID (preferably the Mission) should attend the training sessions to the extent possible. This syllabus serves to notify the USAID Mission of the training event and to invite Mission participation. As required by the F2F PERSUAP, this training will be given within the context of an Integrated Pest Management (IPM) approach and pesticide safe use measures will be emphasized. To that end, the syllabus will include information from the Safe Use Action Plan s Attachments A through H: Attachment A: Compiled list of active ingredients allowed in F2F programs Attachment B: Guide to minimizing the impacts of pesticides to human health Attachment C: Guide to minimizing impacts of pesticides on the environment Attachment D: Guide to Host Country Registered Pesticides Attachment E: Pesticides of Global Concern Attachment F: Guide to IPM Practices Attachment G: Monitoring Pests and Pesticide Effects Attachment H: Key Websites for Pesticide and IPM Research In addition, only pesticides approved in the F2F PERSUAP will be recommended during the training course. Highly toxic pesticides (Attachment E) and those not approved by the F2F PERSUAP will be strongly discouraged. Below is an outline (syllabus) of the course. Material from the PERSUAP will be integrated into course topics. [VOLUNTEER SHOULD PROVIDE A BRIEF OUTLINE OR TABLE OF CONTENTS OF THE COURSE]

5 Page 5 Would doing a volunteer assignment on pesticide equipment maintenance and repair trigger the PERSUAP requirement to vet the syllabus with the local USAID Mission? Yes, An assignment that involves pesticide equipment maintenance and repair is considered assistance for procurement or use of pesticides, and the PER- SUAP requirements are triggered, including the requirement to vet the syllabus with the USAID Mission. As above, vetting the syllabus with the USAID Mission is intended to add value to the syllabus and to the training in general and should not be a constraint to training Formats for reporting on PERSUAP implementation by F2F implementers. The Environmental Mitigation and Monitoring Plan (EMMP) for F2F IPs is the framework for reporting to USAID. Each PERSUAP mitigation measure listed in the EMMP will need to be monitored (see column 2 of the EMMP) and reported on (see column 3 of the EMMP). For reporting, a table format should be used, and two additional columns, Status of Mitigation Measure and Outstanding Issues, should be added to the EMMP table. The reporting template (with examples) is presented below: All mitigation measures in the EMMP should be monitored and reported on in Semi-Annual Progress Reports to USAID using the above as an example or using table format.

6 Training Attended by USAID (Type 1) Check for Yes Training Syllabus Sent to F2F AOR/ Mission Environmental Officer (Type 1) Check for Yes Work Directly with USAID Mission or Mission-funded Project (Type 4) Check for Yes PERSUAP Assignment Type Country F2F Project Country Volunteer Name Assignment (Trip) Number Page 6 F2F PERSUAP Guidance and Standard Language for USAID Reports Each F2F Semi-Annual and Annual report should include a PERSUAP annex, noting compliance with the F2F PER- SUAP guidelines. This annex should include: PERSUAP Implementation Experience F2F Assignments: Over the period covered by this report, the project has had the following experience in implementing the F2F PERSUAP: Assignments with Pesticides: The following Type 1 or 2 (or relevant Type 4) volunteer SOW were completed during the reporting period. (none or list as below) Volunteer XXX for Assignment XXX: One sentence general description of activities with pesticides Key findings and recommendations on limitations/successes of F2F PERSUAP Recommendations to F2F for additional support needed to improve pest and pesticide management practices Volunteer XXX for Assignment XXX: (etc.) Assignments with SOWs in IPM and pesticide safer use: The following volunteer SOWs in IPM and pesticide safer use were undertaken for the F2F regional program, country program, or country project area as a whole. These differ from the individual assignments addressing pesticide use with specific hosts, which should be included in the table below. These will be relatively limited. (none or list as below) Volunteer XXX for Assignment XXX: One sentence general description of activities with pesticides Key findings and recommendations on limitations/successes of F2F PERSUAP Recommendations to F2F for additional support needed to improve pest and pesticide management practices Volunteer XXX for Assignment XXX: (etc.) Needs for a PERSUAP amendment: The following needs for a PERSUAP amendment to add pesticides were identified during the reporting period. None or list F2F PERSUAP Assignment Data Table 1 : Counts:

7 Page 7 Certifications of assignment and office compliance with PERSUAP guidelines: A. PERSUAP Compliance F2F Assignments [Implementing partner] certifies that all volunteers have received the F2F Environmental Brochure. For all PER- SUAP Type 1, 2 and relevant Type 4 SOWs, [implementing partner] further certifies the following have been provided to and developed by the relevant volunteers: Provided to Volunteer Type 1 SOWs 2 Type 2 SOWs 2 F2F PERSUAP with Attachments A - H SUAP briefing with F2F field staff Implementing Partner F2F PERSUAP Questionnaire List of any IPM practices and any tools, forms, protocols, plans from previous volunteers Host country list of approved pesticides Approved pesticide list from any other applicable PER- SUAPs F2F PERSUAP with Attachments B, C, F, H SUAP briefing with F2F field staff Implementing Partner F2F PER- SUAP Questionnaire List of IPM practices from previous volunteers Developed/ Provided by Volunteer Syllabus for training event Material Safety Data Sheets (filed in field office) Any pesticides that the F2F program should be able to recommend/use which are included on an approved list Limitations/successes of F2F PERSUAP Recommendations for additional support on pesticide management practices Recommendations/feedback on local IPM practices Highly Toxic Pesticides (Attachment E)/poor pesticide practices witnessed Tools, forms, protocols, plans for implementation of pesticide-related recommendations Limitations/successes of F2F PERSUAP Recommendations for additional support on pesticide management practices Recommendations/feedback on local IPM practices B. PERSUAP Compliance F2F Offices [Implementing partner] certifies that all F2F staff have reviewed the F2F Environmental Brochure for staff the fiscal year and that the following have been updated and kept on file: Documents Updated and on File Home Office F2F Environmental Brochure for staff PERSUAP with Attachments A-I Any USAID Missionor sector-wide PER- SUAP(s) for relevant country/sector Field Office F2F Environmental Brochure for staff PERSUAP with Attachments A-I USAID Mission- or sector-wide PERSUAP(s) for relevant country/ sector Host country list of approved pesticides 3 Implementing partner F2F PERSUAP Questionnaire, with any volunteer additions Material Safety Data Sheets for relevant pesticides 4 Tools, forms, protocols, plans developed by volunteers 1 Required only for PERSUAP Type 1 & 2 SOWs, and for Type 4 SOWs that follow Type 1 & 2 requirements 2 If governed by F2F PERSUAP, Type 4 SOWs should follow requirements for Type 1, 2, or 3 SOWs, as most relevant 3 Or, letter from host country government stating that there is no list of government-approved pesticides and noting any specific measures that should be taken when F2F volunteers recommend pesticides 4 It is recommended that these documents be translated into local languages for distribution to relevant hosts and partners. Please note if they have been translated (in whole or in part), and if not, why.

8 Page 8 Standard files to be maintained in all F2F country offices to comply with the PERSUAP. F2F country offices should maintain the following files, some of which are required by the PERSUAP, while others are useful to have on hand and available for volunteers and the IP (for example, when preparing semi-annual progress reports to USAID). As described in the F2F PERSUAP, PERSUAP-related information should be made readily available to F2F volunteers and F2F volunteers should feel free to request the files below: F2F Environmental Brochures for IPs and for F2F volunteers A copy of the F2F PERSUAP (at headquarters as well as at country offices, and if possible, in local country language, at least for SUAP attachments A to H) National list of approved/registered pesticides In countries with no nationally approved list of pesticides (besides Angola, this might include flex assignment countries and other countries added over the life of F2F), a letter from the government stating that there is no list of government approved pesticides, and noting any specific measures that should be taken when F2F volunteers recommend pesticides. The F2F questionnaire submitted to develop the PERSUAP (The questionnaire requested information, specific to each F2F country, on IPM, availability of PPE, main challenges to safe use of pesticides, etc.) IPM practices, as described in the questionnaires submitted for this PERSUAP (to be revised/strengthened by F2F volunteers based on their field experience) Material Safety Data Sheets, translated into local languages, when necessary All tools, forms, protocols, and plans that volunteers develop such as: scouting protocols, IPM monitoring forms, and measures to monitor the efficacy of pesticides USAID mission-wide or sector-wide PERSUAPs for a given country AIs, not on the PERSUAP approved list of chemicals, that the F2F country program wishes to recommend, and for which an amendment to the PERSUAP will be requested Success stories and lessons learned on pesticide use, training, and IPM practices, and recommendations to help ensure wider implementation by F2F IPs of pesticide best practices Knowledge gaps in pesticide safe use, IPM, and other pesticide-related issues (including in implementation of the SUAP) Volunteer End of Trip Reports