The USAID Fumigation Programmatic Environmental Assessment: A Four Year Retrospective
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1 The USAID Fumigation Programmatic Environmental Assessment: A Four Year Retrospective Erika Clesceri, PhD, Bureau Environmental Officer, Bureau for Democracy, Conflict and Humanitarian Assistance, USAID Integrated Pest Management and Fumigation Safety Training January 24-26, 2017 Kansas State University, Manhattan, Kansas, USA
2 Purpose of the Fumigation PEA The Problem: Stored commodity losses due to insect infestation Ineffective fumigation is dangerous, with serious risks to human health and possible pesticide resistance PVOs raised concern about fumigant residues on fumigated commodity for beneficiaries The Solution: The Fumigation PEA BEO led, Food for Peace funded under GEMS contract Developed guidance, tools and templates for USAIDfunded projects
3 Content of the Fumigation PEA Main Body: Purpose, goals and methodology of the PEA Environmental and human health risk evaluation Mitigation measures for phosphine fumigation Annex A: Tools for implementation: Guidelines and templates for the fumigation Annex B: Background Information: Information collected and reports developed during the elaboration of the Fumigation PEA
4 Development Timeline 2011: Scoping Statement for Fumigation PEA 2013: Original PEA 2015: First Update to PEA (Template Improvements) 2016: Second Update to PEA (Applies to Entire Agency)
5 PEA Methodology PEA Team of experts in Environmental Impact Assessment, Fumigation, Social Sciences Surveying, Community Engagement, under GEMS project Stakeholder consultation of FACG members, including USAID staff, PVOs, World Food Program etc. Field Work in the USA (Manhattan, Kansas), Uganda, Ethiopia and Djibouti Human Health Risk Evaluation of phosphine fumigation for beneficiaries, fumigation service providers, warehouse workers, and nearby residents
6 Over 125 stakeholders consulted from: Supreme Fumigation Services Ltd Star Pest Control Smayaz Transact International Zollo Pest Control Gibe Freight Transporters Hebret F.T.O.A Compass Transport Tared Transport BMMI Djibouti and many more
7 Assessing Safety: Human Health Risk Evaluation (HHRE) Repeat application by fumigation providers, multiple acute exposure, chronic impacts?
8 PEA Findings: Environmental and Human Health Poor practices can affect the health of fumigant applicators, warehouse staff, and even nearby residents Beneficiary health impacts are not significant Poor fumigation will compromise the quality of food Solid Waste from Fumigation process + inadequate handling and disposal of fumigant and waste could present a danger, water reactive/explosive Recent domestic example in Texas where people died (2017)
9 Has USAID made any changes in policies and procedures as a result of this assessment?
10 Annex A: Tools for Implementation 1. Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP) 2. Fumigation Management Plan (FMP) 3. Solicitation and Contract Language
11 Annex A: PERSUAP Template Reduce redundancy globally Consistent template... Prepared PER... Focus on the SUAP and implementaion... Pesticide Evaluation Report & Safer Use Action Plan Analysis of toxicology, hazards, EPA registration, IPM Identifies actions for mitigation 22 CFR 216.3(b), USAID Pesticide Procedures
12 Annex A: Fumigation Management Plan (FMP) Template First ever for USAID Step by Step for safe, legal and effective fumigation Follow steps assures success Contents: Describes commodity and ownership Establishes emergency plan and safety Lists equipment and supplies Confirms steps are met for application and monitoring Confirms steps are met for disposal and cleanup
13 Annex A: FMP Template IPM section added to original template in 2016 Increase focus on nonchemical approaches Contents: Warehouse Inspection for clean, sealed warehouse and vacuuming underneath pallets Proper handling of commodity Guidelines for infested, damaged commodities Required actions to ensure a clean yard area surrounding the warehouse, free of weeds, trash and water ponds.
14 Annex A: Solicitation and Contracts Language Fumigation Service Quotation Request Model Contract Partners select betterqualified service providers
15 What are the gaps observed? are we correcting them?
16 Common Issues found in USAID Fumigation: PPE Painters Mask will not stop gas Big Obvious: No canister masks Bare hands (and feet) More Nuanced: Only one mask Expired canister masks Correcting.
17 Common Issues from Fumigation: Gas Monitoring Gas Monitoring Equipment: Efficacy (under tarps) Safety (outside of tarps) No gas equipment found in the entire country Imported from US, EU Custom Issues Draeger Tube Detectors Procured, but still use problems. Color-Metric Tube Detectors Direct Read-out Meter
18 Common Issues Found: Siting of Warehouse Safety of staff and nearby residents Warehouses not always sited at least 100m from nearest residential/human habitation/businesses Warehouse not always sealed during fumigation Nearby resident not always alerted before every fumigation Must have placard/post signs in English and local language, Drawings especially among illiterate populations or populations unfamiliar with fumigants Correcting.
19 Common Fumigation Issue: Tarps Procurement of Tarps that are too thin, not for phosphine Reuse of tarps for too long, damages Culture of Mending the tarps, challenges FAO, 2000 In Progress.
20 Common Issues, Gas Exposure: Duration and Concentration : Range of Standards and Practices PEA Recommendation: 5 days for 150ppm or 7 days for 100pm WFP Standard: 5 days at or above 150ppm Some PVOs, asked for shorter time periods, like 3 days due to program operations, without any sign of resistance Requirement: follow fumigant label instructions! In Progress.
21 Follow On Activities as a Result of PEA* Allocation of FFP ITSH funds for fumigant equipment >25 FFP programs with approved PERSUAPs Integration of PEA findings in: Nine (9) TOPS Commodity Management Workshops TOPS Warehouse Safety Handbooks and Posters TOPs Commodity Guide TOPs IPM & Fumigation Training and Webinar FFP required performance indicator for commodity *(as of August 2016)
22 Country Examples: Uganda Karamoja secondary warehouse High praise for the FMP Including the FMP in solicitation, used template language Avoided hiring a problematic FSP as a result, Shared with Mission and WFP Zimbabwe Coordination with WFP, Harare Zimbabwean PhD Entomologist heading FSP, Entomon Resistance monitoring FFP using same FSP
23 Other Impacts of the Fumigation PEA? As baseline for bagging technology research by MIT (Cambridge, MA) Higher Education Support Network (HESN) Comprehensive Initiative for Technology Evaluation (CITE) Interest by hermetically-sealed bags private industry and the Wall Street Journal commodities editor Agency resource for food security programs, esp. USAID s Bureau for Food Security (BFS) Ability for USAID to speak authoritatively with scientificevidence basis to justify, Leadership Spill over improvements in-country warehousing and market standards
24 With a special thanks to Dr. Bhadriraju Subramanyam (Subi) for his fumigation expertise! USAID Programmatic Environmental Assessment for Commodity Fumigation located at: Erika Clesceri DCHA Bureau Environmental Officer (BEO) eclesceri@usaid.gov
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