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Initial Environmental Examination Amendment

MALI AEG PESTICIDE EVALUATION REPORT & SAFER USE ACTION PLAN(PERSUAP)

PROGRAM/ACTIVITY DATA:

Country/Region: MaliProgram/Activity Title: Accelerated Economic Growth, Feed the Future, Mali Climate

Change Adaptation programs

Funding Begin: FY 2011 Funding End: FY 2019

PERSUAP Prepared By: GEMS/The Cadmus Group.

Current Date: August 2014 Expiration Date: December 31, 2020

Submitted By (Project Point-of-Contact): Aminata Diarra

IEE Amendment (Y/N): Y, amends the 2012 Accelerated Economic Growth (AEG) Portfolio IEE and the 2014 Mali Climate Change Adaptation Program (M-CCAP) IEE

ENVIRONMENTAL ACTION RECOMMENDED: (Place X where applicable)Categorical Exclusion: Negative Determination: X Positive Determination: Deferral:

ADDITIONAL ELEMENTS: (Place X where applicable)CONDITIONS X PVO/NGO:

This PERSUAP addresses the pesticide safer use and handling issues for activities included in the Accelerated Economic Growth (AEG) Feed the Future (FtF) strategy, approved in April of 2011, and designed to guide the implementation of agriculture and nutrition interventions between 2011 and 2015 and the Mali Climate Change Adaptation Program (M-CCAP), approved in January of 2014, and designed to be implemented between 2014 and 2019.

SUMMARY OF FINDINGS

Scope:

A. This Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP) covers activities included in the Accelerated Economic Growth (AEG) Feed the Future (FtF) strategy and the Mali Climate Change Adaptation Program (M-CCAP).

The FtF strategy focuses development interventions on three core value chains including sorghum/millet rice and livestock. Other supported crops include maize, potatoes, cowpea,

“fonio” digitaria exilis/iburua, and vegetable gardening. Supported animal husbandry activities include cattle, small ruminants, and fisheries.

The M-CCAP will complement the agricultural efforts of the FtF program, with detailed climate information and farmer and community-scale agricultural interventions such as soil and water conservation and agro-forestry. In total, the PERSUAP assesses 75-100 pesticides commonly available in Mali and West Africa.

The specific crops addressed are: Sorghum Millet (including “Fonio”) Rice Maize Vegetables Potato Peanuts/groundnuts Cowpeas

Interventions in the livestock value chain are also part of the FtF Strategy. The specific animal husbandry activities for pesticide application are:

Cattle Small Ruminants (Sheep and goats) Fish farming/rice fish farming1 (future)

The USAID team proposed eight veterinary pesticides for the FtF and M-CCAP. These pesticides were proposed based on potential requirements of the livestock program, which had not commenced as of the date of this document. As a result, if additional pesticides, not included here are required, an amendment to this PERSUAP would be necessary.

M-CCAP activities include the training on and the dissemination of information on climate change adaptive practices including the use of drought tolerant seeds, the implementation of soil and water conservation techniques, and the use of fodder banks and other agroforestry practices. The illustrative list of trees and fodder to be used in M-CCAP is included in Annex V. The USAID team did not propose pesticides specific to M-CCAP, though it appears that many of the pesticides proposed for the value chain crops will be applicable for M-CCAP activities.

1 Fish farming and combined fish and rice farming activities have not been initiated at the time of preparation of the current PERSUAP. Rice fish farming has been indirectly considered in this PERSUAP in as much as IPM methods and pesticides have been evaluated for rice cultivation (see Exhibit 5 in Section 3.6). In addition, pesticides which are potentially toxic to fresh water fish are evaluated in Section 3.7.

Purpose:

In compliance with USAID’s Pesticide Procedures (22 CFR 216.3(b)), this PERSUAP:

Establishes the set of pesticides for which support is authorized in USAID/Mali AEG activities.

Establishes requirements attendant to support for these pesticides to assure that pesticide use/support (1) embodies the principles of safer pesticide use and, (2) per USAID policy, is within an Integrated Pest Management (IPM) framework.

These requirements come into effect upon approval of the PERSUAP. The set of authorized pesticides and requirements for safer use are established through

the first sections of the document, the Pesticide Evaluation Report (PER), which culminates with an assessment of 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, definitive 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. Each project subject to this PERSUAP must complete this SUAP template and submit to its AOR/COR.

.

List of Approved Pesticides:

This PERSUAP addresses pesticide use in agriculture, and veterinary use of pesticides.

Approved pesticides. Upon approval of this PERSUAP, the below-listed pesticides are permitted for use/support in USAID/Mali AEG and M-CCAP projects.

CSP Reference No. Product Name Active Ingredient Conc. WHO Classification2 Approve/Reject Restrictions on Accepted

ProductsListe Globale des Pesticides Autorises par le CSP Version de Novembre 2013 (The list below includes products from the November 2013 list that are identified for the value chains in this PERSUAP and excludes those products that are identified for non-target crops (e.g., cotton and sugar cane) as well as public-health products for control of mosquitoes and other insects).Insecticides

233 TITAN 25 EC acetamiprid 25 g/L II ApproveOnly as seed treatment on pre-treated seeds or when plants are in vegetative state.

22 BATIK WG Bacillus thuringiensis

32.000 UI/mg III Approve

204 RELDAN 40 EC chlorpyrifos-methyl 400 g/L III Approve 66 DECIS 25 EC deltamethrin 25 g/L II Approve

229 TAMEGA deltamethrin 25 g/L II Approve 231 TIMAYE deltamethrin 0,6 g/kg II Approve

246ZEROFLY LIVESTOCK FENCE

deltamethrin 4 g/kg III Approve

187 PROTECT DP deltamethrinpirimiphos-methyl

1 g/kg15 g/kg III Approve

67 DELTACAL 12,5 EC* deltamethrin 12,5 g/L II Approve

INSAH Registration for green beans and for tomato expires May 2016.

2 The toxicity of the product is determined by the CSP INSAH committee during the registration approval process and is based on the WHO Classification system.

CSP Reference No. Product Name Active Ingredient Conc. WHO Classification Approve/Reject Restrictions on Accepted

Products


INSAH Registration for green beans and for tomato expires May 2016.

164 METHOATE 40 EC dimethoate 40 g/L II Approve Not to be used on cowpeas.

234 THUNDER 145 O-TEQ

imidaclopridbeta-cyfluthrin

100 g/L45 g/L II Approve

Only as seed treatment on pre-treated seeds or when plants are in vegetative state.

166 MOMTAZ 45 WS imidaclopridthiram



243 VIPER 46 EC indoxacarbacetamiprid



245 ZALANG 20 UL lambda-cyhalothrin 20 g/L II Approve

179 PACHA 25 EC lambda-cyhalothrinacetamiprid



120 GREEN MUSCLEMetarhizium flavoviride anisopliae

5.1010 spores/g III Approve

7 ACTELIC SUPER DUST

permethrinpirimiphos-methyl


To be used only for treatment of commodities stored indoors; not to be formulated or used as an outdoor spray.

154 LASER 480 EC spinosad 480 g/L III Approve

222 SPINTOR POUDRE I ,25 spinosad 1,25 g/kg III Approve

226 SUCCSESS APPAT0 0,24 CB spinosad 0,24 g/L III Approve

4 ACTARA 25 WG thiamethoxam 250 g/kg III Approve Only as seed treatment on pre-


Productstreated seeds or when plants are in vegetative state.

56 CRUISER EXTRA COTON 362 FS

thiamethoxamfludioxonylmetalaxyl-M (mefenoxam)

35 g/L8,34 g/L3,34 g/L

III ApproveOnly as seed treatment on pre-treated seeds or when plants are in vegetative state.

163 MARIGOLD thyme oiltagetes oil

5,52 g/L5,52 g/L U Approve

Insecticides/fumigants None

Insecticides/acaracides

I ACARIUS abamectin 18 g/L II Approve Use only Toxicity Category II or III products; not Category I.

27 BOMEC 18 EC abamectin 18 g/L II Approve Use only Toxicity Category II or III products; not Category I.

241 VERTIMEC 18 EC abamectin 18 g/L II Approve Use only Toxicity Category II or III products; not Category I.

Insecticides/fungicides

135 INSECTOR T imidaclopridthiram



28 CAIMAN ROUGE P

permethrinthiram

25 g/kg250 g/kg II Approve

Only as seed treatment on pre-treated seeds; not to be used in any field-spray applications.

14 APRON STAR 42 WS

thiamethoxammefenoxam (metalaxyl-M)difenoconazole

200 g/kg200 g/kg20 g/kg

III ApproveOnly as seed treatment on pre-treated seeds or when plants are in vegetative state.

Fungicides 177 ORTIVA 250 SC azoxystrobin 250 g/L III Approve


Products18 AZOX azoxystrobin 250 g/L III Approve 47 COGA 80 WP mancozeb 800 g/kg III Approve 77 DITHANE M 45 mancozeb 800 g/kg III Approve

228 SYSTHANE 240 EC myclobutanil 240 g/L III Approve

116 GOLDEN BLUE 985 SG

Copper sulfate pentahydrate 985 g/kg II Approve Use only Toxicity Category II or

III products; not Category I.Nematicide

None Rodenticide

242 VERTOX PELLETS brodifacoum 0,005% by wt. III Approve

Approved only for Acute Toxicity Category III products sold as baited traps.

Herbicides

123 HERBALM 720 SL 2,4-D amine 720 g/L III Approve

39 CALLIHERBE 720 SL

2,4-D dimethyl-ammonium salt 720 g/L II Approve

238 TOPEXTRA 720 SL 2,4-D amine salt 720 g/L II Approve

128 HERBIRIZ 10 WP bensulfuron-methyl 100 g/kg III Approve

215 SAMORY bensulfuron-methyl 100 g/kg III Approve

217 SELECT 120 EC clethodim 120 g/L III Approve

106 GALAXY 450 EC clomazonependimethalin

150 g/L300 g/L III Approve

127 HERBIMAIS 240 OF

dicambanicosulfuron


221 SUN 2,4 AMlNE Dichlorophenoxiac 720 g/L II Approve


Products

720 SLetate, dimethyl-amine (2,4-D amine)

65 DANGOROBA glyphosate 360 g/L III Approve

72 DlGA FAGALAN (FINISH 360 SL glyphosate 360 g/L III Approve

78 DOUMA WORO glyphosate 480 g/L II Approve 98 FINISH 68 SG glyphosate 680 g/L III Approve

101 FOURALAN 480 SL glyphosate 480 g/L III Approve

108 GLYCEL 410 SL glyphosate 410 g/L II Approve 109 GLYCEL 710 SG glyphosate 710 g/L II Approve

110 GLYPHADER 75 SG glyphosate 750 g/L III Approve

112 GL YPHALM 360 SL glyphosate 360 g/L III Approve

113 GL YPHONET 360 SL glyphosate 360 g/L III Approve

114 GL YPHOGAN 480 SL glyphosate 480 g/L III Approve

115 GLYPHOTROP 480 SL glyphosate 480 g/L II Approve

124 HERBASATE glyphosate 360 g/L III Approve

137 IPROSATE 41% SL glyphosate 41% U Approve

138 KALACH 360 SL glyphosate 360 g/L III Approve

139 KALACH EXTRA 70 SO glyphosate 700 g/L III Approve

143 KILLER 480 SL glyphosate 480 g/L U Approve

162 MAMBA 360SL glyphosate 360 g/L III Approve


Products(DOMINATOR 360 SL)

207 RIVAL 360 SL glyphosate 360 g/L III Approve

209 ROUNDUP BIOSEC 68 SG glyphosate 680 g/L III Approve

210 ROUNDUP 360 K glyphosate 360 g/L III Approve

211 ROUNDUP 360 SL glyphosate 360 g/L III Approve

212 ROUNDUP 450 TURBO K glyphosate 450 g/L III Approve

213 ROUNDUP POWERMAX glyphosate 540 g/L III Approve

237 TOUCHDOWN FORTE 500 SL glyphosate 500 g/L III Approve

II AKIZON 40 SC nicosulfuron 40 g/L III Approve 168 NICOMAIS 40 SC nicosulfuron 40 g/L III Approve 169 NICONET 40 SC nicosulfuron 40 g/L IV Approve 158 MAlA 75 WG nicosulfuron 750 g/kg III Approve 159 MAIA SUPER nicosulfuron 60 g/L III Approve 142 KELION 50WG orthosulfamuron 500 g/kg III Approve

31 CALLISTAR 250 EC oxadiazon 250 g/L III Approve

178 OXARIZ 250 EC oxadiazon 250 g/L III Approve 206 RISTAR 250 EC oxadiazon 250 g/L III Approve

8 ACTIVUS 500 EC pendimethalin 500 g/L III Approve 224 STOMP 455 CS pendimethalin 455 g/L III Approve 117 GRANITE 240 SC penoxsulam 240 g/L II Approve 203 RAINBOW 25 OD penoxsulam 25 g/L III Approve

93 EUREKA (PROP A 360) propanil 360 g/L III Approve


Products

235 TOPRANIL 480 EC propanil 480 g/L III Approve

19 BACCARA propanil2,4-D


205 RICAL 345 EC propanilthiobencarb


21 BARAKA 432 EC propaniltriclopyr

360 g/L72 g/L U Approve

35 CALRIZ propaniltriclopyr


119 GRANSTAR 75 WG tribenuron-methyl 750 g/kg III Approve

240 TRICLON 480 EC triclopyr 480 g/L II Approve

107 GARIL 432 EC triclopyrpropanil


Summary of Conditions:

A. Only pesticides approved by this PERSUAP may be supported with USAID funds in USAID/Mali AEG and M-CCAP activities. These pesticides are enumerated above. Pesticide “SUPPORT” means procurement, use, recommending for use, or otherwise facilitating the use of a pesticide.

B. Pesticide support must be governed by a set of locally adapted, crop- and pest-specific IPM-based pest management plans and observe enumerated use restrictions. (The PERSUAP provides key information for IPs to develop these plans.)

C. Appropriate project staff & beneficiaries must be trained in safer pesticide use and pesticide first aid;

D. To the greatest degree practicable, projects must require use & maintenance of appropriate Personal Protective Equipment (PPE)—as well as safe pesticide purchase, handling, storage and disposal practices;

E. Projects must conduct pesticide-related record-keeping and monitoring in a clear logical manner.

These conditions are detailed in the included mandatory SUAP template for assigning responsibilities and timelines for implementation of these requirements, and for tracking compliance. Each project subject to this PERSUAP must submit a completed SUAP template to its AOR/COR 30 days before the implementation of the activity and provide an annual update. 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.

APPROVAL OF THE RECOMMENDED ENVIRONMENTAL ACTION (2014 MALI AEG PERSUAP):

CLEARANCE:Mission Director Signed: _____________Date: ___________

CONCURRENCE:Africa Bureau Environmental Officer Signed:______________Date: ___________

Brian Hirsch

ADDITIONAL CLEARANCES:

AEG Office Director Signed:_____________________ Date: ___________

Mission Environmental Officer Signed: _____________________Date: ___________

Mali Legal Advisor Signed: ____________________ Date: ___________

Deputy Mission Director Signed: ____________________Date: ___________

Regional Environmental Advisor Signed: ____________________Date: ___________USAID/West Africa

PESTICIDE EVALUATION REPORT AND SAFER USE ACTION PLAN (PERSUAP)MALI ACCELERATED ECONOMIC GROWTH (AEG) FEED THE FUTURE (FtF) STRATEGY AND MALI CLIMATE CHANGE ADAPTATION PROGRAM

PREPARED IN ACCORDANCE WITH THE REQUIREMENTS OF THE INITIAL ENVIRONMENTAL EXAMINATION AND 22 CFR 216

This publication was produced for review by the United States Agency for International Development. It was prepared by The Cadmus Group, Inc.

Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP)

Mali Accelerated Economic Growth (AEG) Feed the Future (FtF) Strategy and Mali Climate Change Adaptation Program (M-CCAP)

Prepared in Accordance with the Requirements of the Initial Environmental Examination and 22 CFR 216

Prepared by: The Cadmus Group, Inc.John Martin, M.S.

Moulaye Farota, Ph.D.James Jolley, P.E.

Prepared for: Mali Accelerated Economic Growth Office

October 2014DISCLAIMER“This document was prepared by The Cadmus Group, Inc. under USAID’s Global Environmental Management Support Program. The contents are the sole responsibility of the authors and do not necessarily reflect the views of USAID or the United States Government.”

Mali AEG – PERSUAP October 2014

ABBREVIATIONS AND ACRONYMSft feetkm kilometerm metermm millimetermg/L milligrams per literAEG Accelerated Economic GrowthA.I. Active ingredientAIP Alatona Irrigation ProjectCFC ChlorofluorocarbonCFR Code of Federal Regulations (U.S.)ChE CholinesteraseCILSS Comité permanent Inter-Etats de Lutte contre la Sécheresse

dans le Sahel (Permanent Interstate Committee for Drought Control in the Sahel)

CNGP Comité National de Gestion des Pesticides (National Pesticide Management Committee)

CSP Comité Sahélien des Pesticides (Sahelian Pesticide Committee)FAO Food and Agriculture Organization of the United NationsFtF Feed the Future (Mali)GAP Good Agricultural PracticesM-CCAP Mali Climate Change Adaptation ProgramGDP Gross Domestic ProductGNI Gross National IncomeICRAF International Center for Research in AgroforestryICRISAT International Crops Research Institute for the Semi-Arid-TropicsIEE Initial Environmental ExaminationIER Institut d’Economie Rurale (Rural Economic Institute)INSAH Institute of the SahelIP Implementing PartnerIPM Integrated Pest ManagementMoA Ministry of Agriculture (Mali)MPC Mali Protection des Cultures (Mali Protection of Cultivated Land)MRL Maximum Residue LimitMSDS Material Safety Data SheetPASP-Mali Programme Africain de Gestion des Stocks de Pesticides

Obsolètes (African Program for Management of Obsolete Pesticide Stocks)

PBI Plant-back IntervalPERSUAP Pesticide Evaluation Report and Safer Use Action PlanPHI Pre-harvest IntervalPOP Persistent organic pollutantPPE Personal Protective EquipmentRED Reregistration Eligibility Decision (USEPA)REI Restricted Entry IntervalRUP Restricted Use PesticideULV Ultra Low VolumeUSAID United States Agency for International DevelopmentUSD United States Dollars

i


USEPA United States Environmental Protection AgencyWHO World Health Organization

ii


TABLE OF CONTENTSABBREVIATIONS AND ACRONYMS.............................................iLIST OF EXHIBITS.................................................................... iii1.0 INTRODUCTION.................................................................12.0 COUNTRY AND ENVIRONMENTAL INFORMATION..............43.0 PESTICIDE EVALUATION REPORT......................................63.1 USEPA REGISTRATION STATUS OF THE PROPOSED PESTICIDES..........................63.2 BASIS FOR SELECTION OF THE PESTICIDES.........................................................73.3 EXTENT TO WHICH THE PROPOSED PESTICIDE USES ARE, OR COULD BE, PART

OF AN IPM PROGRAM........................................................................................213.4 PROPOSED METHOD OR METHODS OF APPLICATION, INCLUDING THE

AVAILABILITY OF APPLICATION AND SAFETY EQUIPMENT.................................213.5 ANY ACUTE AND LONG-TERM TOXICOLOGICAL HAZARDS, EITHER HUMAN OR

ENVIRONMENTAL, ASSOCIATED WITH THE PROPOSED USE, AND MEASURES AVAILABLE TO MINIMIZE SUCH HAZARDS.........................................................23

3.5.1 GENERAL HYGIENIC PROCEDURES....................................323.5.2 PESTICIDE STORAGE, CLEANUP AND DISPOSAL................323.5.3 CHRONIC TOXICITY: USEPA’S APPROACHES TO CARCINOGENICITY.....................................................................34

3.6 EFFECTIVENESS OF THE REQUESTED PESTICIDES FOR THE PROPOSED USE.....353.7 COMPATIBILITY OF THE PROPOSED PESTICIDE USES WITH TARGET AND NON-

TARGET ECOSYSTEMS.......................................................................................403.8 CONDITIONS UNDER WHICH THE PESTICIDES ARE TO BE USED, INCLUDING

CLIMATE, FLORA, FAUNA, GEOGRAPHY, HYDROLOGY, AND SOILS....................443.8.1 SOIL CHARACTERISTICS IN MALI......................................453.8.2 HYDROLOGICAL CHARACTERISTICS IN MALI....................45

3.9 AVAILABILITY OF OTHER PESTICIDES OR NON-CHEMICAL CONTROL METHODS 473.10 HOST COUNTRY’S ABILITY TO REGULATE OR CONTROL THE DISTRIBUTION,

STORAGE, USE, AND DISPOSAL OF THE REQUESTED PESTICIDES....................483.11 PROVISION FOR TRAINING OF USERS AND APPLICATORS................................50

Phase I – Train the Trainers;................................................51 Phase II – Train Beneficiary Farmers; and...........................51 Phase III – Annual Refresher Training for program staff, leader farmers and participant farmers.....................................52

3.12 PROVISION MADE FOR MONITORING THE USE AND EFFECTIVENESS OF PESTICIDES.......................................................................................................53

4.0 SAFER USE ACTION PLAN................................................544.1 INTRODUCTION...................................................................................................544.2 ALLOWED PESTICIDES........................................................................................544.3 SUMMARY OF COMPLIANCE REQUIREMENTS......................................................62Pesticide Safer Use Action Plan and Compliance Tracker......................................................64ANNEX I: WHO ACUTE TOXICITY CLASSIFICATIONS AND USEPA ACUTE TOXICITY CATEGORIES...............................................I-1ANNEX II – PESTICIDE EVALUATION AND SELECTION............II-1ANNEX III – INTEGRATED PEST MANAGEMENT, MALI............III-1

iii


ATTACHMENT 1: MITIGATING POTENTIAL PESTICIDE DANGERS..............................III-3ATTACHMENT 2: GENERAL IPM PLANNING AND DESIGN PROTOCOL......................III-5ANNEX IV – TRAINING COURSE OUTLINE.............................IV-1ANNEX V – ILLUSTRATIVE LIST OF TREES AND FODDER FOR GLOBAL CLIMATE CHANGE...................................................V-1ANNEX VI – IPM/IVM PREVENTIVE AND CURATIVE TOOLS AND TACTICS FOR LIVESTOCK.....................................................VI-1ANNEX VII – LEGISLATIION ON PESTICIDE MANAGEMENT IN MALI (FRENCH VERSION)....................................................VII-1

LIST OF EXHIBITS

Exhibit 1: Map of Mali............................................................................................5Exhibit 2: Approved Pesticides by Product Name, Active Ingredient, Acute

Toxicity Classification, Approval and Comments.......................................9Exhibit 3: Rejected Pesticides, Product Name, Active Ingredient, Acute Toxicity

Classification, Approval and Comments...................................................17Exhibit 4: Approved Pesticides, Toxicity Classification and Recommended PPE.24Exhibit 5: Pesticides for Which USAID Approval is Being Requested: Target

Crops, Pests and IPM.................................................................................36Exhibit 6: Agro-Ecological Characteristics of the AEG Intervention Regions.....46Exhibit I-1: WHO – The Globally Harmonized System of Classification and

Labeling of Chemicals (GHS).................................................................II-1Exhibit I-2: EPA Acute Toxicity Categories......................................................II-2Exhibit II-1: Approved Pesticides, USEPA Registration Status, RUP Designation

and Acute Toxicity Classification............................................................II-1Exhibit II-2: Approved Livestock Pesticides, USEPA Registration Status, RUP

Designation and Acute Toxicity Classification.......................................II-4

iv


1.0 INTRODUCTION1.1 PURPOSE AND SCOPE

In compliance with USAID’s Pesticide Procedures (22 CFR 216.3(b)), this 2014 Mali Accelerated Economic Growth (AEG) Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP):

Establishes the set of pesticides for which support is authorized on USAID/Mali AEG activities.

Establishes requirements attendant to support for these pesticides to assure that pesticide use/support (1) embodies the principles of safer pesticide use and, (2) per USAID policy, is within an Integrated Pest Management (IPM) framework.

These requirements come into effect upon approval of the PERSUAP.

The set of authorized pesticides and requirements for safer use are established through the first sections of the document, the Pesticide Evaluation Report (PER), which culminates with an assessment of 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.

This PERSUAP addresses the activities included in the Accelerated Economic Growth (AEG) Feed the Future (FtF) strategy, approved in April of 2011 and designed to guide the implementation of agriculture and nutrition interventions between 2011 and 2015. It also addresses the activities in the Mali Climate Change Adaptation Program (M-CCAP) program approved in January 2014. The FtF strategy focuses development interventions on three core value chains including sorghum/millet, rice and livestock. Other supported crops include maize, potatoes, cowpea, “fonio” digitaria exilis/iburua, and vegetable gardening. Supported animal husbandry activities include cattle, small ruminants, and fisheries. The M-CCAP will complement the agricultural efforts of the FtF program, with detailed climate information and farmer and community-scale agricultural interventions such as soil and water conservation and agro-forestry. In total, the PERSUAP assesses 75-100 pesticides commonly available in Mali and West Africa.

This PERSUAP has been prepared as a requirement of the 2012 Initial Environmental Examination (IEE) for USAID AEG programs, and in accordance with 22 CFR 216.3(b). It supersedes the 2009 FtF PERSUAP. This PERSUAP enumerates the pesticides being requested for use to help address pest management needs in AEG activities and sets out safer use measures to be taken to protect workers, communities, and environmental resources from the potential adverse effects of pesticide use.

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Upon approval of this PERSUAP, the requested pesticides become approved for use, subject to MANDATORY implementation of the safer use measures set out herein. Pesticides not approved for use via this PERSUAP may not be procured, used or recommended for use on or by AEG activities.

The specific crops addressed are:

Sorghum Millet (including “Fonio”) Rice Maize Vegetables Potato Peanuts/groundnuts Cowpeas

Interventions in the livestock value chain are also part of the FtF Strategy. The specific animal husbandry activities for pesticide application are:

Cattle Small Ruminants (Sheep and goats) Fish farming/rice fish farming3 (future)

The USAID team proposed eight veterinary pesticides for the FtF and M-CCAP. These pesticides were proposed based on potential requirements of the livestock program, which had not commenced as of the date of this document. As a result, if additional pesticides, not included here are required, an amendment to this PERSUAP would be necessary.

M-CCAP activities include the training on and the dissemination of information on climate change adaptive practices including the use of drought tolerant seeds, the implementation of soil and water conservation techniques, and the use of fodder banks and other agroforestry practices. The illustrative list of trees and fodder to be used in M-CCAP is included in Annex V. The USAID team did not propose pesticides specific to M-CCAP, though it appears that many of the pesticides proposed for the value chain crops will be applicable for M-CCAP activities.

1.2 REGULATORY REQUIREMENTS, THE PERSUAP CONCEPT, AND ANALYTICAL APPROACHRegulatory Requirements Attendant to USAID-funded Support for Pesticides.

All USAID-funded activities are subject to pre-implementation environmental review, starting with a screening process that determines the level of environmental scrutiny that is required. Activities considered as having moderate or unknown risks 3 Fish farming and combined fish and rice farming activities have not been initiated at the time of preparation of the current PERSUAP. Rice/fish farming has been indirectly considered in this PERSUAP in as much as IPM methods and pesticides have been evaluated for rice cultivation (see Exhibit 5 in Section 3.6). In addition, pesticides which are potentially toxic to fresh water fish are evaluated in Section 3.7.

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are subjected to an Initial Environmental Examination (IEE). USAID’s pre-implementation environmental review procedures are defined by 22 CFR 216, a US federal regulation.

Pesticides are any agent used to kill or control any pest, including insects, rodents or birds, unwanted plants (weeds), fungi, or microorganisms such as bacteria and viruses. Though often misunderstood to refer only to insecticides, the term pesticide also applies to herbicides, fungicides, micro- biocides, rodenticides and various other substances used to control pests. Pesticides are by design poisons, and their use entails a degree of risk to humans, birds, fish, bees, and other living things, as well as to the environment.

If USAID funds are to be used to procure, directly fund or support the use of pesticides, 22 CFR 216.3(b) requires that 12 factors be analyzed as the basis for approving the use of any pesticides, and as the basis for establishing the requirements attendant to that use to control risks to human health and the environment.

It is important to note that USAID defines pesticide “use” broadly to include direct or indirect use including the handling, transport, storage, mixing, loading, application and disposal of pesticides and their containers, as well as recommending pesticides for use via extension or other agricultural assistance.

USAID Policy: Integrated Pest Management

In addition, since the early 1990s USAID has been committed to the philosophy and practice of Integrated Pest Management (IPM) as official policy. There is not a single standard international definition for IPM, but there is wide agreement on its basic elements. Under IPM:“First line” defenses against pest damage are a combination of techniques such as biological control, habitat manipulation, modification of cultural practices, and use of resistant varieties. Pesticides are used only after monitoring indicates they are needed according to established guidelines, and treatments are made with the goal of removing only the target organism. Pest control materials are selected and applied in a manner that minimizes risks to human health, beneficial and non-target organisms, and the environment.

IPM is strongly promoted as part of Regulation 216.3 Factor C.

The PERSUAP

USAID Africa Bureau has adopted the PERSUAP, which formally constitutes an amendment to a project’s IEE, to address the requirements of 22 CFR 216.3(b) with particular emphasis on assuring that pesticide use occurs within an IPM framework.

A PERSUAP consists of two core parts, a “PER” and a “SUAP.” The PER first characterizes pest management needs for the subject USAID projects, and pesticides availability, pesticides awareness among potential beneficiaries, and the

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critical local context. This information then provides input to the assessment of the 12 pesticide risk evaluation factors (a through l) required by 22 CFR 216.3(b). The PER thereby establishes the set of authorized pesticides and requirements for safer use.

The Safer Use Action Plan or 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. Each project subject to this PERSUAP must complete this SUAP template and submit to its AOR/COR.

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2.0 COUNTRY AND ENVIRONMENTAL INFORMATION 2.1 COUNTRY OVERVIEW

Mali is a land-locked country located in West Africa occupying an area of 122 million hectares with a population of approximately 15 million.4 Mali’s neighbors include Mauritania and Senegal to the west, Algeria to the north, Burkina Faso and Niger to the east, and Guinea and Côte d’Ivoire to the south. Mali is divided into eight regions, which are (from Northeast to Southwest): Kidal, Tombouctou, Gao, Mopti, Segou, Koulikoro, Kayes, and Sikasso. There is also a capital region, Bamako, which is enveloped by the Koulikoro region.

According to the United Nations Food and Agricultural Organization, Mali is comprised of four ecological zones. The largest ecological zone is Northern Mali (including Tombouctou, Kidal, and Gao), which is extremely arid, classified as Saharan or tropical desert5 and receives an average annual rainfall of 0 to 200 millimeters (mm) per year. From the southern edge of Tombouctou and extending to southern Mopti is the second ecological zone, the Sahel, or tropical scrubland6 with an average rainfall of 250 to 800 mm per year. Continuing further south to the capital city, Bamako, is the third zone, Soudanian, or tropical dry forest where annual rainfall ranges from 500 to 1400 mm.7 The fourth ecological zone, Soudano-Guinean, an area of tropical moist deciduous forest, extends to all remaining points south of Bamako and receives an average annual rainfall of 1000 to 1400 mm. The Niger River Delta, a fresh water wetland, passes through the latter three ecological zones.

With the 22nd-fastest population growth rate in the world8, at 3.2 percent per year, Mali needs to adequately support its increasing population. This hurdle looms particularly large as Mali finds itself among the 25 poorest countries in the world, with a per capita Gross National Income (GNI) of approximately $1,0009, and ranked 175 out of 187 countries on the United Nations Human Development Index. Mali’s ranking remains far below the world average, and notably below the average for both sub-Saharan Africa and the marker for Low Human Development.1011

To help ensure that Mali sustains its strong economic growth in a manner that properly supports its projected population growth, the Mali FtF campaign has focused improvements on three primary value chains which are of fundamental importance to the country: millet-sorghum production; rice for growth in household incomes and food security; and livestock, for growth in household incomes, nutrition, and for national gross domestic product (GDP) growth.12 These value chains represent key areas of economic, social, and agricultural strength in Mali.4 World Bank 20105 Food and Agricultural Organization of the United Nations (FAO-UN) (2000)6 Ibid7 Ibid8 Ibid9 World Bank 201010 UN Human Development Index 201211 World Bank 201012 U.S.G/Mali Feed-the-Future FY 2011-2015

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2.2 LOCATIONS AFFECTED

The FtF regional focus includes 113 communes concentrated within three of Mali’s eight regions and includes Timbuktu, Mopti and Sikasso, along with two communes in Segou that encompass the focus of the MCC Alatona Irrigation Project (AIP). The FtF communes were selected on the basis of agricultural potential, poverty and the nutritional status of the population as indicated by stunting and wasting indices. Due to both the agricultural potential and the tremendous need, it is expected that FtF interventions will have the greatest impact within these regions. Approximately 3.15 million people live within the FtF intervention zone, and an estimated 300,000 people will be directly affected by the FtF initiative, while approximately 1.3 million will indirectly benefit.

The FtF program originally focused on 143 communes but was reduced to 113 based on the security situation and political instability of March 2012 in Timbuktu and the northern portion of Mopti. In the future the program may be expanded to serve the original 143 communes. The M-CCAPM-CCAP overlaps geographically with FtF zones, but also includes other areas in Mopti. Therefore, the entire Mopti region is covered by this PERSUAP.

Exhibit 1: Map of Mali13.

13 The World Factbook 2013-14. Washington, DC: Central Intelligence Agency, 2013. https://www.cia.gov/library/publications/the-world-factbook/index.html

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https://www.cia.gov/library/publications/the-world-factbook/index.html


2.3 THE ROLE OF PESTICIDE MANAGEMENT

The FtF and GCC Programs will involve agricultural and livestock improvement efforts in all four of Mali’s major ecological zones, including tropical desert, tropical scrubland, tropical dry forest, and tropical moist deciduous forest. The primary concerns of the PERSUAP are protection of the following:

farmers who apply the pesticides; and non-targeted organisms and natural resources, including:

– honeybee populations;– other beneficial insects;– bird populations;– mammalian populations;– aquatic vertebrates (freshwater and marine/estuarine);– aquatic invertebrates (freshwater and marine/estuarine);– aquatic plants; and– shallow ground water and/or ground water underlying permeable soils.

Thus, the goal of this PERSUAP is to identify pesticides that will be effective for crop protection and minimize adverse effects on humans, non-targeted organisms and natural resources (e.g., ground water). This PERSUAP will also designate pesticides that have been suggested for possible use in Mali by the AEG team but will not be included in those pesticides for which USAID approval is being requested due to Restricted use designations by USEPA, acute toxicity classifications/categorizations of I (most acutely toxic), or if less acutely toxic alternatives are available. It is critical to AEG management to have a list of effective, safe pesticides for possible use over the next several years.

3.0 PESTICIDE EVALUATION REPORT3.1 USEPA REGISTRATION STATUS OF THE PROPOSED PESTICIDES

The USEPA registers pesticides based on the active ingredient (A.I.) but confers either “General Use” or “Restricted Use” designations based on the pesticide product formulation. USEPA institutes both re-registration and registration review for pesticides. If a pesticide was first registered after 1984, the process of re-registration does not apply, but the pesticide is subject to registration review. In either case, the process is similar in that it involves the collection of data to fill possible data gaps and documents use patterns and potential risks associated with the pesticide. Pesticides that are either undergoing re-registration or registration review are considered to be registered in the U.S.

Occasionally, registered uses for a pesticide may be cancelled by USEPA. This cancellation may result from either: (1) a request for voluntary cancellation of uses by the manufacturer or; (2) USEPA concerns over the toxicity of a pesticide. If the intended use of a pesticide for the FtF and M-CCAPM-CCAP has been cancelled or if all uses of a suggested pesticide have been cancelled by USEPA, then approval for use of the pesticide will not be requested in this PERSUAP.

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The registration status of the pesticides requested for approval in the FtF and M-CCAPM-CCAP is presented in Exhibits II-1 and II-2 in Annex II. Additional supporting information, including acute toxicity classifications from the World Health Organization (WHO) and USEPA, along with additional pesticide-specific information, is presented to explain why these pesticides are acceptable for use in the FtF and M-CCAPM-CCAP. The complete list of pesticides requested for approval (and those specifically rejected for approval request) in the FtF and M-CCAPM-CCAP are presented in Exhibits 2 and 3 in Section 3.2. Comments are presented in Exhibits 2 and 3 to explain why certain pesticides are not acceptable for use in the FtF and M-CCAPM-CCAP.

3.2 BASIS FOR SELECTION OF THE PESTICIDES

An extensive list of pesticide active ingredients (A.I.) and/or pesticide formulations was proposed by FtF and M-CCAPM-CCAP staff for consideration and review during preparation of this PERSUAP. The list of proposed pesticides was extracted from the list of registered pesticides approved by the Sahelian Pesticide Committee (Comité Sahélien des Pesticides (CSP)) of the Institute of the Sahel (INSAH) dated November 2013. The proposed list excludes those products on the CSP INSAH list that are identified for non-target crops (e.g., cotton and sugar cane) as well as public-health products for control of mosquitoes and other insects. In addition, the FtF and M-CCAPM-CCAP requested consideration of a short list of four pesticides for livestock and agroforestry a few of which were not necessarily on the CSP INSAH list of registered pesticides.

The list of proposed pesticides was developed in consultation with FtF and M-CCAPM-CCAP staff and regional experts. As noted during these consultations, it is difficult to predict which pesticides will be needed for each element of the program over the future course of the FtF and M-CCAPM-CCAP as many activities have not been initiated. In order to address this issue, the FtF and M-CCAPM-CCAP staff proposed the complete list of pesticides authorized by the INSAH CSP for potential needs that might arise.

In order to capture the potential pesticides required for the M-CCAPM-CCAP, regional experts were contacted and interviewed. Based on interviews with experts at the International Center for Research in Agroforestry (ICRAF), the International Crops Research Institute for the Semi-Arid-Tropics (ICRISAT), and the Programme Ressources Forestières, Institut d’Economie Rurale (IER) - Sotuba/Bamako, the pesticides Furadan and Decis were recommended as potential pesticides for agroforestry pest control. (Furadan was rejected as noted in Exhibit 3 and Decis was approved as noted in Exhibit 2.) Similarly, regional experts and members of the FtF and M-CCAPM-CCAP staff14 were consulted to develop a list of pesticides suitable for use with livestock/animal husbandry. (From this initial list, two pesticides, Tick Stop and Vectocid, were selected as noted on Exhibit 2. Two pesticides, Ectosip and Bayticol, were rejected as indicated in Exhibit 3.) These livestock pesticides are not currently approved by INSAH CSP. It is recommended that temporary approval "for research and development" be requested according to the Mali Ministry processes.

14 Mr. Yacouba, Santara, USAID/Bamako Livestock Expert.

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The use of these pesticides will be restricted to formulations containing less than 5% of the active ingredient, and can only be applied as a pour-on product

Exhibits 2 and 3 summarize the proposed pesticides, whether the AEG team is seeking approval from USAID for use, and the reasons for which they were rejected or approved. These pesticides were initially chosen by the AEG team based on availability and efficacy for the crops and pests in question. Exhibits II-1 and II-2 in Annex II summarize the approved pesticides, their USEPA Registration status, WHO and USEPA Acute Toxicity Classification/Category (see Annex I for more information on the criteria used by WHO and USEPA), and the restricted use pesticide (RUP) designation.

Pesticides that have any acute toxicity classification of I and RUPs are not selected for approval of use in this PERSUAP. Note that RUP status is based on product formulation and not A.I.; hence, some pesticides that were initially selected for potential use may have certain formulations that are RUPs and other formulations that are not RUPs. In these cases, only the non-RUP formulations are proposed for use in the FtF and the GCC Programs. Those pesticides that are not selected for approval of use in this PERSUAP (based on acute toxicity classifications, cancellation by USEPA, RUP status, or based on a weight-of-evidence for substantial risk) are dropped from this analysis and are not addressed in subsequent sections of this PERSUAP. Only the pesticides that are listed in Exhibit 2 are included in the remainder of this PERSUAP.

Because the commercial infrastructure in Mali is not robust, there are a limited number of pesticides that can be procured from reliable sources. As a result, some pesticides that are categorized by USEPA and/or WHO as Acute Toxicity Category/Class II are included in this PERSUAP for approval by USAID. To reduce the risk to farmers but in consideration of ecological receptors, possible alternates to the Acute Toxicity Category/Class II pesticides are considered in Section 4.3 of this PERSUAP. Training in proper pesticide procurement, application, and safety measures is an important part of the FtF and GCC Program and will be used to minimize risks to human health and the environment. More information on training is presented in Section 3.11 and Annex IV.

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Exhibit 2: Approved Pesticides by Product Name, Active Ingredient, Acute Toxicity Classification, Approval and Comments.

CSP Reference No. Product Name Active Ingredient Conc.WHO

Classification15

Approve/Reject Restrictions on Accepted Products

Liste Globale des Pesticides Autorises par le CSP Version de Novembre 2013 (The list below includes products from the November 2013 list that are identified for the value chains in this PERSUAP and excludes those products that are identified for non-target crops (e.g., cotton and sugar cane) as well as public-health products for control of mosquitoes and other insects).Insecticides

233 TITAN 25 EC acetamiprid 25 g/L II ApproveOnly as seed treatment on pre-treated seeds or when plants are in vegetative state










INSAH Registration for green beans expires Mai 2014; INSAH Registration for tomato expires Mai 2016

15 The toxicity of the product is determined by the CSP INSAH committee during the registration approval process and is based on the WHO Classification system.

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Products



164 METHOATE 40 EC dimethoate 40 g/L II Approve Not to be used on cowpeas




Only as seed treatment on pre-treated seeds or when plants are in vegetative state
















To be used only for treatment of commodities stored indoors; not to be formulated or used as an outdoor spray




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Products

4 ACTARA 25 WG thiamethoxam 250 g/kg III ApproveOnly as seed treatment on pre-treated seeds or when plants are in vegetative state



35 g/L8,34 g/L3,34 g/L

III ApproveOnly as seed treatment on pre-treated seeds or when plants are in vegetative state





I ACARIUS abamectin 18 g/L II Approve Use only Toxicity Category II or III products; not Category I

27 BOMEC 18 EC abamectin 18 g/L II Approve Use only Toxicity Category II or III products; not Category I

241 VERTIMEC 18 EC abamectin 18 g/L II Approve Use only Toxicity Category II or III products; not Category I





28 CAIMAN ROUGE P

permethrinthiram


Only as seed treatment on pre-treated seeds; not to be used in any field-spray applications

14 APRON STAR 42 WS


200 g/kg200 g/kg20 g/kg


Fungicides 177 ORTIVA 250 SC azoxystrobin 250 g/L III Approve

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Products18 AZOX azoxystrobin 250 g/L III Approve 47 COGA 80 WP mancozeb 800 g/kg III Approve 77 DITHANE M 45 mancozeb 800 g/kg III Approve


116 GOLDEN BLUE 985 SG

Copper sulfate pentahydrate 985 g/kg II Approve Use only Toxicity Category II or

III products; not Category I.Nematicide

None Rodenticide


Approved only for Acute Toxicity Category III products sold as baited traps

Herbicides











dicambanicosulfuron


221 SUN 2,4 AMlNE Dichlorophenoxiac 720 g/L II Approve

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Products

720 SLetate, dimethyl-amine (2,4-D amine)



78 DOUMA WORO glyphosate 480 g/L II Approve 98 FINISH 68 SG glyphosate 680 g/L III Approve













162 MAMBA 360SL glyphosate 360 g/L III Approve

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Products(DOMINATOR 360 SL)













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Products














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Livestock Pesticides

Not approved by INSAH TICK STOP amitraz III

Approve Only product containing less than 5% of the active ingredient, and only pour-on product.

Not approved by INSAH VECTOCID deltamethrin II

Approve Only product containing less than 5% of the active ingredient, and only pour-on product.

Additional products noted as approved:1. Copper sulfate pentahydrate (GOLDEN BLUE 985 SG) is approved as an alternative to Callicuivre (copper oxychloride), which is rejected.

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Exhibit 3: Rejected Pesticides, Product Name, Active Ingredient, Acute Toxicity Classification, Approval and Comments.

CSP Reference No. Product Name Active Ingredient Conc. WHO Classification Approve/Reject Reasons for Rejection


42 CAPT 88 EC acetamipridcypermethrin

16 g/L72 g/L II Reject Cypermethrin is RUP

70 DENIM FIT 50 WG (MATCH FIT 50 WG)

emamectin lufenuron benzoate

100 g/kg400 g/kg

III Reject

Agricultural/horticultural products containing emamectine benzoate are RUP

140 KART 500 SP cartap 500 g/kg III Reject Not registered by USEPA

189 PYCHLOREX 480 EC chlorpyrifos-ethyl 480 g/L II Reject Agricultural products are RUP190 PYRICAL5G chlorpyrifos-ethyl 50 g/kg II Reject Agricultural products are RUP191 PYRICAL 5 DP chlorpyrifos-ethyl 50 g/kg II Reject Agricultural products are RUP192 PYRICAL 480 EC chlorpyrifos-ethyl 480 g/L II Reject Agricultural products are RUP193 PYRICAL 480 EC chlorpyrifos-ethyl 480 g/L II Reject Agricultural products are RUP194 PYRICAL 240 UL chlorpyrifos-ethyl 240 g/L II Reject Agricultural products are RUP195 PYRICAL 480 UL chlorpyrifos-ethyl 480 g/L II Reject Agricultural products are RUP196 PYRIBAN 240 ULV chlorpyrifos-ethyl 240 g/L II Reject Agricultural products are RUP197 PYRIBAN 480 UL V chlorpyrifos-ethyl 480 g/L II Reject Agricultural products are RUP198 PYRIBAN 480 EC chlorpyrifos-ethyl 480 g/L II Reject Agricultural products are RUP201 PYRIGA 240 UL chlorpyrifos-ethyl 240 g/L II Reject Agricultural products are RUP202 PYRIGA 480 UL chlorpyrifos-ethyl 480 g/L II Reject Agricultural products are RUP79 DURSBAN 4 EC chlorpyrifos-ethyl 480 g/L II Reject Agricultural products are RUP80 DURSBAN 5% DP chlorpyrifos-ethyl 50 g/kg III Reject Agricultural products are RUP

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81 DURSBAN 5 G chlorpyrifos-ethyl 50 g/kg III Reject Agricultural products are RUP82 DURSBAN 450 ULV chlorpyrifos-ethyl 450 g/L II Reject Agricultural products are RUP83 DURSBAN 240 UL V chlorpyrifos-ethyl 240 g/L II Reject Agricultural products are RUP57 CYPRA 100 EC Cypermethrin 100 g/L II Reject RUP62 CYPERCAL 50 EC Cypermethrin 50 g/L III Reject RUP

90 EMIR 88 EC cypermethrinacetamiprid

72 g/L16 g/L II Reject Cypermethrin is RUP

74 DIMLIN OF 6 Diflubenzuron 60 g/L II Reject RUP

95 FENICAL 3 DP Fenitrothion 3 g/kg III Reject Not registered by USEPA for agricultural uses

96 FENICAL 400 UL Fenitrothion 400 g/L III Reject Not registered by USEPA for agricultural uses

104 FYFANON 925 UL Malathion 925 g/L III Reject RUP

214 SAVAHALER WP Methomyl 250 g/kg II Reject RUP

63 CYPERPRONET 690 EC

profenofoscypermethrin

600 g/L90 g/L II Reject Both profenofos and

cypermethrin are RUPsInsecticides/fumigants

69 DETIA GAS EX-B aluminum phosphide 570 g/kg Ib Reject RUP; USEPA Acute Toxicity

Category I

185 PHOSFINON 570 GE aluminum phosphide 570 g/kg Ib Reject RUP; USEPA Acute Toxicity

Category IInsecticides/acaracides

None Insecticides/fungicides

None Fungicides

None Nematicide

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244 VYTAL 310 SL Oxamyl 310 g/L Ib Reject RUP; USEPA Acute Toxicity Category I

Rodenticide None

Herbicides

125 HERBEXTRA 720 SL 2,4-D 720 g/L II RejectAssumed to be free acid; typically more hazardous than amine salts

161 MALO BINFAGA 720 SL 2,4-D 720 g/L II Reject

Assumed to be free acid; typically more hazardous than amine salts

208 RIVORMONE 720 SL 2,4-D 720 g/L II RejectAssumed to be free acid; typically more hazardous than amine salts

2 ACET0 900 EC acetochlor 900 g/L III RejectHighly concentrated emulsifiable concentrate; similar to RUPs

118 GRAMI 108 EC haloxyfop-R-methyl 108 g/L III Reject Not registered by USEPA122 HALONET I04 EC haloxyfop-R-methyl 104 g/L II Reject Not registered by USEPA

99 FOCON 750WG Hexazinone 750 g/L III Reject Hexazinone is toxic, mobile groundwater contaminant

129 HEXACANE 75 WDG Hexazinone 750 g/kg III Reject Hexazinone is toxic, mobile

gorundwater contaminant

148 LAGON 380 SC isoxaflutoleaclonifen

50 g/L333 g/L III Reject Aclonifen not registered by

USEPA

157LUMAX 537,5 SE(PRIMAGOLD 537,5 SE)

mesotrionemetolachlorterbuthylazine

37,5 g/L375 g/L125 g/L

III Reject Metolachlor is toxic, mobile gorundwater contaminant

40 CAMIX 500 SE mesotrionemetolachlor

83,3 g/L III Reject Metolachlor is toxic, mobile

gorundwater contaminant

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416,7 g/L

236 TOPSTAR 400 SC Oxadiargyl 400 g/L III Reject Not registered by USEPA220 SOFIT 300 EC Pretilachlor 300 g/L III Reject Not registered by USEPA

219 SOLITO 320 EC pyribenzoximpretilachlor

20 g/L300 g/L III Reject Pretilachlor not registered by

USEPA


Not approved by INSAH BAYTICOL 1 % Flumethrin unknown Reject not EPA registered

Not approved by INSAH ECTOSIP cypermethrin unknown Reject RUP

Additional products requested and rejected:1. Attakan is on the INSAH list as being used for cotton; therefore, it was not considered. However, it contains an RUP, cypermethrin, and thus would not be approved; EA required.2. Basudine is not on the INSAH list, nor are any other diazinon-containing products. Agricultural products are RUP and would not be approved; EA required.3. Furadan is not on the INSAH list, nor are any other carbofuran-containing products. All carbofuran products are RUP and would not be approved; EA required.4. Callicuivre is copper oxychloride and is not on the INSAH list. Copper oxychloride is USEPA Acute Toxicity Category I for irreversible eye damage, so it would not be approved. 5. Phostoxin is aluminum phosphide which is an RUP and would not be approved; EA required.6. Dursban contains chlorpyrifos-ethyl; all agricultural products are RUPs and are rejected.7. Neem/azadirachtin appears in one product on the INSAH list, and is only approved for use on cotton. Therefore it is rejected.8. Livestock pesticide, Bayticol 1%, is rejected because its active ingredient, flumethrin, is not EPA Registered.9. Livestock pesticide, Ectosip, is rejected because its active ingredient, cypermethrin, is an RUP.Pesticides listed in Exhibit 3, Rejected Pesticides, are not to be procured, purchased or used for activities in the AEG Feed the Future (FtF) project .

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3.3 EXTENT TO WHICH THE PROPOSED PESTICIDE USES ARE, OR COULD BE, PART OF AN IPM PROGRAM

The AEG Team, for the FtF and GCC Program in Mali, has detailed their vision for the safe use of pesticides and other non-pesticidal practices to maximize the control of pests and crop yields while minimizing harmful effects on farmers, natural resources, and non-target ecological receptors. The FtF and GCC approach to Integrated Pest Management (IPM) is attached as Annex III. It is designed to be an on-going program that allows farmers in Mali to improve and adapt their farming techniques as the FtF and GCC Program unfolds. Rather than reiterating components of the AEG Team’s IPM strategy here, the reader is referred to Annex III.

The pesticides for which approval is being requested (see Exhibit 2 in Section 3.2) were selected on the basis of toxicity to humans and ecological receptors. More toxic pesticides were rejected when safer alternatives were available; however, some pesticides with significant toxicity (e.g., USEPA/WHO Acute Toxicity Category/Class II) are included in Exhibit II-1 in Annex II to allow for pesticide-based control methods for all of the crops and pests that are of concern. The AEG Team’s approach to IPM should, in particular, stress non-pesticidal measures in their IPM approach in cases where these more toxic pesticides represent the only chemical option for a given crop and/or pest.

3.4 PROPOSED METHOD OR METHODS OF APPLICATION, INCLUDING THE AVAILABILITY OF APPLICATION AND SAFETY EQUIPMENT

Many farmers in Mali are currently not using proper application techniques, using proper Personal Protective Equipment (PPE), safeguarding ecological resources, or focusing on the use of pesticides of lower toxicity. Results from the field visit in May 2014 indicated that a pesticide provider in the Sikasso region, who typically applied the pesticides for farmers, did not wear proper PPE. Thus, the combined goal of this PERSUAP and the FtF and GCC training program is to formalize the pesticides to be used and the procedures for using them safely.

Procedures for pesticide application and safe use (for human health and natural resources/ecological receptors) are generally described in Annex III and detailed on pesticide labels. These procedures will also be included in the FtF training program, as detailed in Section 3.11 of this PERSUAP. Recommended PPE for each pesticide are included in Exhibit 4 in Section 3.5. In addition, general procedures for hygiene when handling pesticides and spray drift management are described in Sections 3.5.1 and Section 3.5.2.

In the regions of intervention of FtF Mali, pesticide sprayer applicators and PPE may be available but are typically not used because they are too expensive for typical small holder farmers or may not be available at nearby markets. For example in Sikasso, the cost of PPE can be as high as 150,000 CFA (or approximately 310 USD). Oftentimes pesticides are applied, especially in vegetable farms, by hand or by using a brush or broom soaked with pesticide.

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However, authorized agricultural suppliers, with pesticide application equipment and PPE, are located in the regions of intervention. For example, the supplier, Mali Crop Protection (Mali Protection des Cultures (MPC)), is located in Sikasso, Koutiala, Mopti and Niono.

Based on the field visit completed in May 2014, it is noted that the beneficiary farmers may not typically purchase pesticides, application equipment, or PPE, directly from the agricultural suppliers. Rather, the subcontractors working for the implementing partners (IPs) may act as an interface between farmers and vendors, collecting orders for agriculture inputs, including pesticides (if recommended) from farmers and delivering these orders to vendors.

The proper methods of application of the approved pesticides include:

Motorized sprayers Backpack hand manual pump sprayers

This application equipment is available at suppliers like MPC in the majority of the regions of intervention as noted above.

The availability of these products is important, but only if the farmers are properly trained in their use and the reasons for their use. Typical obstacles to the use of proper application and safety equipment include:

The low literacy rate in Mali. Pesticide labeling is the cornerstone of USEPA’s pesticide registration process and labels are of little use to farmers who cannot read (other than the symbols that may be present on the labels). This is where the AEG team’s approach to training, which includes training of the trainers followed by training of the farmers, will play a major role in communicating the requisite information to the farmers;

The hot climate makes use of bulky PPE uncomfortable and inconvenient, even when it is available;

Poor storage practices; Poor cleanup and disposal practices; A lack of awareness of restricted entry intervals (REI), pre-harvest intervals,

(PHI), and plant-back intervals (PBI); and A lack of understanding that pesticide toxicity to humans may be very

different than the toxicity of a pesticide to non-target organisms.

All of these topics will be addressed in the AEG team’s three-phase approach to training as described in Section 3.11 of this PERSUAP. The AEG team should ensure the accessibility of PPE and application equipment by taking the following measures during training:

Emphasize the use of proper PPE and application equipment for each pesticide formulation being used;

Provide clear guidance on where to obtain the necessary PPE and application equipment and from only those vendors that are trusted;

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Provide clear guidelines for when PPE and application equipment must be replaced;

Provide clear steps for cleaning of PPE and application equipment after each use. Include instruction on how to manage wash water and washing applicator’s clothing separate from other household laundry. See general safety guidelines in Section 3.5 of this PERSUAP;

Provide clear instructions for the cleaning and destruction of used pesticide containers and instructions for how to manage wash water; and

Provide clear instructions for handling pesticide spills.

Several pesticides that have been requested for USAID approval in this PERSUAP must be used with PPE that is above and beyond baseline PPE (baseline PPE is long-sleeved shirt, long pants, and shoes plus socks), and is required for all pesticide handling. It is also the minimum standard for pesticides that are categorized by USEPA or classified by WHO as Acute Toxicity Category/Class IV). Extra PPE is required for any pesticides that are categorized by USEPA or classified by WHO as Acute Toxicity Category/Class II or III. The AEG team must ensure that the proper levels of PPE are provided, properly utilized, properly cleaned and replaced at appropriate intervals for all pesticide applications.

Toxicity Category/Class IV: Baseline PPE (long-sleeved shirt, long pants, and shoes plus socks;

Toxicity Category/Class III: Baseline PPE plus chemical-resistant gloves; and Toxicity Category/Class II: Baseline PPE, chemical-resistant gloves, plus

chemical-resistant apron/coveralls and chemical-resistant boots.– If the Acute Toxicity Category/Class is based on Primary eye irritation,

use goggles; and– if the Acute Toxicity Category/Class is based on inhalation, use nose

mist/dust mask.

Requirements for the application, use of PPE, storage practices, REIs, PHIs, PBIs and measures to protect both human health and ecological receptors and natural resources are detailed in pesticide labeling. Proper disposal procedures are an area of concern even though there is a pesticide disposal program in Mali. The AEG team will incorporate international practices for pesticide and container disposal and destruction, including WHO Guidance, into their training and implementation of this PERSUAP.

3.5 ANY ACUTE AND LONG-TERM TOXICOLOGICAL HAZARDS, EITHER HUMAN OR ENVIRONMENTAL, ASSOCIATED WITH THE PROPOSED USE, AND MEASURES AVAILABLE TO MINIMIZE SUCH HAZARDS

Acute and chronic risks to humans and ecological receptors (see also Section 3.7) are shown in Exhibits II-1 and II-2 in Annex II. Procedures to minimize these hazards (including use of PPE) are detailed below in Exhibit 4.

These topics will be included in the AEG team’s three-phase training program as described in Section 3.11 of this PERSUAP.

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http://www.who.int/whopes/recommendations/Management_options_empty_pesticide_containers.pdf


Exhibit 4: Approved Pesticides, Toxicity Classification and Recommended PPE.

No. from Annex Product Name Active Ingredient Conc. Tox. Recommended PPE

WHO

Tox

icity

Cla

ssifi

catio

n

Base

line:

Long

-sle

eved

shirt

, lon

g pa

nts,

sh

oes p

lus s

ocks

Chem

ical

-res

istan

t glo

ves

Chem

ical

-res

istan

t apr

on/c

over

alls

Chem

ical

-res

istan

t boo

ts

Gogg

les

Nos

e m

ist/d

ust m

ask

Insecticides 233 TITAN 25 EC Acetamiprid 25 g/L II Yes Yes Yes Yes Yes

22 BATIK WG Bacillus thuringiensis 32.000 UI/mg III Yes Yes Yes

204 RELDAN 40 EC chlorpyrifos-methyl 400 g/L III Yes Yes Yes Yes

66 DECIS 25 EC Deltamethrin 25 g/L II Yes Yes Yes Yes Yes229 TAMEGA Deltamethrin 25 g/L II Yes Yes Yes Yes Yes231 TIMAYE Deltamethrin 0,6 g/kg II Yes Yes Yes Yes Yes


Deltamethrin 4 g/kg III Yes Yes Yes Yes Yes


1 g/kg15 g/kg III Yes Yes Yes Yes Yes

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67 DELTACAL 12,5 EC* deltamethrin 12,5 g/L II Yes Yes Yes Yes Yes

68 DELTACAL 12,5 EC* deltamethrin 12,5 g/L II Yes Yes Yes Yes Yes

164 METHOATE 40 EC dimethoate 40 g/L II Yes Yes Yes Yes Yes Yes



100 g/L45 g/L II Yes Yes Yes Yes Yes Yes

166 MOMTAZ 45 WS

imidaclopridthiram

250 g/kg200 g/kg III Yes Yes Yes Yes Yes Yes


30 g/L16 g/L II Yes Yes Yes Yes Yes

245 ZALANG 20 UL lambda-cyhalothrin 20 g/L II Yes Yes Yes Yes Yes


15 g/L10 g/L II Yes Yes Yes Yes Yes

120 GREEN MUSCLE

Metarhizium flavoviride anisopliae

5.1010 spores/g III Yes Yes



3 g/kg16 g/kg III Yes Yes Yes

154 LASER 480 EC spinosad 480 g/L III Yes Yes

222 SPINTOR POUDRE I ,25 spinosad 1,25

g/kg III Yes Yes

226SUCCSESS APPAT0 0,24 CB

spinosad 0,24 g/L III Yes Yes

4 ACTARA 25 WG thiamethoxam 250 g/kg III Yes Yes

56 CRUISER EXTRA

thiamethoxamfludioxonyl

35 g/L8,34 g/L III Yes Yes Yes Yes Yes

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COTON 362 FS metalaxyl-M (mefenoxam) 3,34 g/L


5,52 g/L5,52 g/L U Yes Yes


Insecticides/acaracides I ACARIUS Abamectin 18 g/L II Yes Yes Yes Yes

27 BOMEC 18 EC Abamectin 18 g/L II Yes Yes Yes Yes

241 VERTIMEC 18 EC Abamectin 18 g/L II Yes Yes Yes Yes



350 g/kg100 g/kg III Yes Yes Yes Yes Yes

28 CAIMAN ROUGE P

permethrinthiram

25 g/kg250 g/kg II Yes Yes Yes Yes Yes Yes

14 APRON STAR 42 WS


200 g/kg200 g/kg20 g/kg

III Yes Yes Yes Yes

Fungicides Yes Yes

177 ORTIVA 250 SC azoxystrobin 250 g/L III Yes Yes

18 AZOX azoxystrobin 250 g/L III Yes Yes 47 COGA 80 WP mancozeb 800 g/kg III Yes Yes

77 DITHANE M 45 mancozeb 800 g/kg III Yes Yes

228 SYSTHANE 240 EC myclobutanil 240 g/L III Yes Yes

116 GOLDEN BLUE 985 SG copper sulfate pentahydrate 985 g/kg II Yes Yes Yes Yes

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Nematicide None

Rodenticide

242 VERTOX PELLETS brodifacoum 0,005%

by wt. III Yes Yes

Herbicides

123 HERBALM 720 SL 2,4-D amine 720 g/L III Yes Yes


2,4-D dimethylammonium salt 720 g/L II Yes Yes

238 TOPEXTRA 720 SL 2,4-D amine salt 720 g/L II Yes Yes

128 HERBIRIZ 10 WP bensulfuron-methyl 100 g/kg III Yes Yes

215 SAMORY bensulfuron-methyl 100 g/kg III Yes Yes

217 SELECT 120 EC clethodim 120 g/L III Yes Yes

106 GALAXY 450 EC

clomazonependimethalin

150 g/L300 g/L III Yes Yes


dicambanicosulfuron


221 SUN 2,4 AMlNE 720 SL

Dichlorophenoxiacetate, dimethyl-amine (2,4-D amine)

720 g/L II Yes Yes Yes Yes

65 DANGOROBA glyphosate 360 g/L III Yes Yes

72

DlGA FAGALAN (FINISH 360 SL

glyphosate 360 g/L III Yes Yes

78 DOUMA WORO glyphosate 480 g/L II Yes Yes Yes Yes

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98 FINISH 68 SG glyphosate 680 g/L III Yes Yes

101 FOURALAN 480 SL glyphosate 480 g/L III Yes Yes

108 GLYCEL 410 SL glyphosate 410 g/L II Yes Yes Yes Yes

109 GLYCEL 710 SG glyphosate 710 g/L II Yes Yes Yes Yes

110 GLYPHADER 75 SG glyphosate 750 g/L III Yes Yes

112 GL YPHALM 360 SL glyphosate 360 g/L III Yes Yes

113 GL YPHONET 360 SL glyphosate 360 g/L III Yes Yes

114 GL YPHOGAN 480 SL glyphosate 480 g/L III Yes Yes

115 GLYPHOTROP 480 SL glyphosate 480 g/L II Yes Yes Yes Yes

124 HERBASATE glyphosate 360 g/L III Yes Yes

137 IPROSATE 41% SL glyphosate 41% U Yes Yes

138 KALACH 360 SL glyphosate 360 g/L III Yes Yes

139 KALACH EXTRA 70 SO glyphosate 700 g/L III Yes Yes

143 KILLER 480 SL glyphosate 480 g/L U Yes Yes

162

MAMBA 360SL(DOMINATOR 360 SL)

glyphosate 360 g/L III Yes Yes

207 RIVAL 360 SL glyphosate 360 g/L III Yes Yes 209 ROUNDUP glyphosate 680 g/L III Yes Yes

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BIOSEC 68 SG

210 ROUNDUP 360 K glyphosate 360 g/L III Yes Yes

211 ROUNDUP 360 SL glyphosate 360 g/L III Yes Yes

212 ROUNDUP 450 TURBO K glyphosate 450 g/L III Yes Yes

213 ROUNDUP POWERMAX glyphosate 540 g/L III Yes Yes

237 TOUCHDOWN FORTE 500 SL glyphosate 500 g/L III Yes Yes

II AKIZON 40 SC nicosulfuron 40 g/L III Yes Yes

168 NICOMAIS 40 SC nicosulfuron 40 g/L III Yes Yes

169 NICONET 40 SC nicosulfuron 40 g/L IV Yes Yes

158 MAlA 75 WG nicosulfuron 750 g/kg III Yes Yes 159 MAIA SUPER nicosulfuron 60 g/L III Yes Yes 142 KELION 50WG orthosulfamuron 500 g/kg III Yes Yes

31 CALLISTAR 250 EC oxadiazon 250 g/L III Yes Yes

178 OXARIZ 250 EC oxadiazon 250 g/L III Yes Yes

206 RISTAR 250 EC oxadiazon 250 g/L III Yes Yes

8 ACTIVUS 500 EC pendimethalin 500 g/L III Yes Yes

224 STOMP 455 CS pendimethalin 455 g/L III Yes Yes

117 GRANITE 240 SC penoxsulam 240 g/L II Yes Yes Yes Yes

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203 RAINBOW 25 OD penoxsulam 25 g/L III Yes Yes

93 EUREKA (PROP A 360) propanil 360 g/L III Yes Yes

235 TOPRANIL 480 EC propanil 480 g/L III Yes Yes





21 BARAKA 432 EC

propaniltriclopyr

360 g/L72 g/L U Yes Yes Yes Yes


360 g/L72 g/L II Yes Yes Yes Yes

119 GRANSTAR 75 WG tribenuron-methyl 750 g/kg III Yes Yes

240 TRICLON 480 EC triclopyr 480 g/L II Yes Yes Yes Yes


72 g/L360 g/L II Yes Yes Yes Yes

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Not approved by INSAH TICK STOP amitraz III Yes Yes Yes Yes

Not approved by INSAH VECTOCID deltamethrin II Yes Yes Yes Yes

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In addition to the use of pesticide formulation-specific PPE detailed above in Exhibit 4, general hygienic procedures, applicable to all pesticide-use scenarios, are presented here. The following general hygienic procedures for worker safety from USEPA’s Reregistration Decision (RED) document for cryolite16 can be generally applied for all pesticide application scenarios. However, the label of the pesticide may specify details that differ from these general measures or additional measures (particularly for worker protection), and must be consulted.

3.5.1 GENERAL HYGIENIC PROCEDURES

Application Restrictions: Do not apply this product in a way that will contact workers or other persons, either directly or through drift. Only protected handlers may be in the area during application;

User Safety Requirements: Follow manufacturer's instructions for cleaning/maintaining PPE. If no such instructions exist for washables, use detergent and hot water. Keep and wash PPE separately from other laundry; and

User Safety Recommendations: Users should wash hands before eating, drinking, chewing gum, using tobacco, or using the toilet. Users should remove clothing immediately if pesticide gets inside. Then wash thoroughly and put on clean clothing. If the user exhibits signs of exposure, first aid should be initiated and medical assistance should be obtained immediately. Users should remove PPE immediately after handling this product. Wash the outside of gloves before removing. As soon as possible, wash thoroughly and change into clean clothing.

In addition to these general hygienic procedures, most worker PPE scenarios involve the following levels of protection:

Baseline PPE: long-sleeved shirt, long pants, and shoes plus socks (USEPA Acute Toxicity Category II, III, and IV);

Additional protective items if USEPA Acute Toxicity Category II or III: – chemical-resistant gloves (USEPA Acute Toxicity Category II and III),– chemical-resistant apron/coveralls (USEPA Acute Toxicity Category II), – chemical-resistant boots (USEPA Acute Toxicity Category II), – goggles (USEPA Acute Toxicity Category II – if eye irritant),– nose mist/dust mask (USEPA Acute Toxicity Category II – if inhalation

hazard).

3.5.2 PESTICIDE STORAGE, CLEANUP AND DISPOSAL

Instructions on pesticide containers for storage, cleanup and disposal should be followed. Typical instructions are noted below:

Cleanup and Disposal: Do not contaminate water when disposing of equipment wash water or rinsate. Rinsate should be applied to crops in areas where the pesticide was applied. Triple rinse, puncture, crush, and bury (i.e.,

16 USEPA. 1996. Reregistration Eligibility Decision for Cryolite. EPA738-R-96-016. Available on the Internet at: http://epa.gov/oppsrrd1/REDs/0087.pdf

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in a locally established landfill or waste dump) or incinerate spent containers when a well-operating incinerator is available. . Do not reuse containers for any other purpose. Implementing partners should vet any waste dump to ensure that container disposal will not pose threats to nearby residents, water table or surface water, drinking water sources, livestock or other animals.

Storage: Avoid excessive temperatures (upper ranges may be around 30-38 degrees centigrade; see product label for detailed information) and direct sunlight; avoid excessive moisture and humidity; restrict child access. Store in original containers only with all labels intact.

These methods do not appear to be widely implemented at the field level in Mali. For example, during the May 2014 field visits in support of PERSUAP development, three methods of disposing of used pesticide containers were noted:

1. Burying the containers at depth;2. Burning the containers in open fires; and,3. Washing containers with soap and re-using them for drinking water or

milk.

The African Program for Obsolete Pesticide Stocks in Mali, or “Programme Africain de Gestion des Stocks de Pesticides Obsolètes” (African Program for Management of Obsolete Pesticide Stocks (PASP-Mali)), is the government entity in charge of managing and disposing of used or obsolete pesticide products. PASP-Mali is currently developing a network of pesticide container locations throughout the country at which the typical pesticide user can return obsolete pesticides or used pesticide containers.

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3.5.3 CHRONIC TOXICITY: USEPA’S APPROACHES TO CARCINOGENICITY

Included in Exhibit II-1 in Annex II is information regarding USEPA’s carcinogenicity assessments. USEPA has established several classification schemes for carcinogenicity17 since 1986. Since toxicological data for many pesticides have been published over the course of many years, there is no single carcinogenicity classification scheme that can be used to describe all of the pesticides in this PERSUAP.

USEPA’s current classification scheme consists of the following five elements:

Carcinogenic to humans; Likely to be carcinogenic to humans; Suggestive evidence of carcinogenic potential; Inadequate information to assess carcinogenic potential; and Not likely to be carcinogenic to humans

In 1999, USEPA established a draft classification scheme that closely-resembles the current (2005) scheme:

Carcinogenic to humans; Likely to be carcinogenic to humans; Suggestive evidence of carcinogenicity, but not sufficient to assess human

carcinogenic potential; Data are inadequate for an assessment of human carcinogenic potential; and Not likely to be carcinogenic to humans

In 1996, USEPA proposed an update to the 1986 scheme:

Known/likely; Cannot be determined; and Not likely

USEPA’s initial carcinogenicity classification scheme (1986) consisted of five primary classifications:

Group A - Human carcinogen; Group B1 and B2 - Probable human carcinogen

– Group B1 - limited evidence of carcinogenicity from epidemiologic studies

– Group B2 - sufficient evidence from animal studies, but inadequate evidence or no data from epidemiologic studies

Group C - Possible human carcinogen; Group D - Not classifiable as to human carcinogenicity; and Group E - Evidence of non-carcinogenicity for humans

17 USEPA. 2011. Evaluating Pesticides for Carcinogenic Potential; website. Last updated September 6, 2011; accessed June 22, 2014. Available on the Internet at: http://www.epa.gov/pesticides/health/cancerfs.htm#a

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For the purposes of this PERSUAP, no agricultural-use pesticides that are classified in the groups that appear above in bold italics are proposed for USAID approval for use in the FtF and M-CCAPM-CCAP. (Note that some recently-introduced pesticides may not have had a complete evaluation of carcinogenicity.).

One dozen pesticides that are classified as having “Suggestive evidence of carcinogenic potential” are proposed for USAID approval. These proposed pesticides are important options for the AEG team in that they offer high utility for target crops and pests:

Insecticides/Fungicides:1. dimethoate, (insecticide)2. permethrin, (insecticide, insecticide/fungicide)3. thiamethoxam, (insecticide, insecticide/fungicide)4. difenoconazole, (insecticide/fungicide)5. mancozeb, (fungicide)

Herbicides:6. 2,4-D amine, (herbicide)7. orthosulfamuron, (herbicide)8. oxadiazon, (herbicide)9. pendimethalin, (herbicide)10.penoxsulam, (herbicide)11.propanil, (herbicide), and 12.tribenuron-methyl, (herbicide).

The dozen pesticides/fungicides that are proposed for use on crops and have been classified by USEPA as having “Suggestive evidence of carcinogenic potential” offer benefits despite potential concerns regarding carcinogenicity. Note also that there are a limited number of products that are available to the AEG team given the economic conditions that currently exist in Mali.

If, during the evolution of the FtF and GCC Programs, less toxic alternatives can be identified, these alternatives will be presented to USAID for approval and the pesticides of greater risk will be eliminated from use in the FtF and GCC Programs.

3.6 EFFECTIVENESS OF THE REQUESTED PESTICIDES FOR THE PROPOSED USE

Exhibit 5 summarizes those pesticides for which USAID approval is being requested along with the crops and pests that are anticipated to be associated with their use. This exhibit also includes the recommended IPM methods. Similarly, Annex VI summarizes potential livestock pests, preventative tools and non-chemical and chemical curative tools.

The AEG team’s training program will include instruction that will aid farmers in recognizing the signs of potential pesticide resistance (i.e., a reduction in efficacy of pesticide products). Monitoring for resistance will be conducted and pesticide classes may be rotated if resistance is observed.

The IPs, and their agronomists, will assess the USAID-approved pesticides so that pesticide rotation, when needed, is best implemented to provide the greatest

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degree of crop protection while also protecting human health and ecological resources and receptors.

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Exhibit 5: Pesticides for Which USAID Approval is Being Requested: Target Crops, Pests and IPM18

Target Crop Pest and Disease IPM Product

Sorghum (including Fonio)

Termites (microtermes sp), grasshoppers, caterpillars (mythimna lorei), stem borers (sesamia calamistis), panicule bugs

Use of resistant cultivars, biological control (destruction of crop residues after harvest, early seeding, crop rotation)

None recommended

Millet Stem borersMillet head miner

Lepidoptera (lema planifrons Ws, sesamia sp, etc.)

Use of tolerant species, and biological control (selective release of bracon hebetor wasps)

None recommended

Rice Termites Implement crop rotation, remove and burn contaminated straw, remove existing host plants such as Digitaria marginata, Dinebra retroflexa et Panicum repens. Use traditional practices: use of bamboo stems, smoking the termite nest, use of salt, and flooding of termite nests with water.

None recommended

Weeds: Ageratum conyzoides, Cyperus difformis, Cyperus iria, Echinochloa colona, Echinochloa crus-galli, Fimbristylis miliacea, Ischaemum rugosum and Monochoria vaginalis.

Manual removal of weeds. Bacarra, Samory, Kalach 360 SL, Calriz , Calliherbe 720 SL, and additional herbicides in the Approved list of Pesticides, Exhibit 2.

18 Adapted from "Tableau 1: Pestes de quelques spéculations, " on page 18 of the report entitled, "Plan de Gestion des Pestes et des Pesticides, Rapport Final, December 2009", published by the Republic of Mali, Ministry of Agriculture, Cellule de Coordination Programme.

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Fungal Diseases: Rice blast, brown spot, cercospora leaf spot, sheath rot, and leaf scald.

Use clean seed, optimize the soil fertility, remove and burn contaminated plant, implement rice planting when pathogenic growth is minimized, remove typical hosts including Setaria sp., Leersia sp., et Echinochloa sp.

Apron star 42 WS, seed treatment, Caiman Rouge P, seed treatment, Cruiser Extra Coton 362 FS seed treatment.

Bacterial Diseases: Bacterial blight and bacterial sheath rot.

Use clean seed, optimize the soil fertility, remove and burn contaminated plant, implement rice planting when pathogenic growth is minimized, remove typical hosts including Setaria sp., Leersia sp., et Echinochloa sp.

Apron star 42 WS, seed treatment, Caiman Rouge P, Cruiser Extra Coton 362 FS seed treatment.

Maize Damping-off disease Seed treatment, crop rotation, biological control (Bacillius thuringiensis)

Apron star 42 WS, seed treatment, Caiman Rouge P, seed treatment, Cruiser Extra Coton 362 FS seed treatment..

Anthracnose Use of resistant cultivars, destruction of crop residues after harvest.

No recommended pesticides.

Fusarium head blight (scab)

Use of resistant cultivars, crop rotation out of cereals.


Brown spot Use of resistant cultivars, crop rotation, destroy infected plant debris.


Potatoes Potato blight Use resistant cultivars. Planting date to avoidperiod of heavy late blight infection, inter-cropping of non-host crops or low planting density.

COGA 80 WP and Dithane M45

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Brown rot (bacterial wilt) Plant clean seed tubers in clean soil. Use of resistant cultivars. Remove and burn potato residue. Remove contaminated plants, and weeds. Crop rotation.


Common scab Maintain high soil moisture during tuber initiation and for 6 to 8 weeks. Crop rotation with millet. Avoid soil application of animal wastes, Use clean seed tubers.


Charcoal rot Plant clean seed tubers. Harvest at tuber maturation and before soil temperature exceeds 82°F. Avoid injuring tubers during harvest. Crop rotation over several years.


Vegetables Bollworm (Helicoverpa) on tomatoes and green beans

Biological control (Bacillius thuringiensis)

Decis 25 EC

Aphids Spraying with neem extract, tabacco extract or soap solution.

Fruit flies, Lady Bugs (Henosepilachna argus)

Removal of lady bug larvae and adults by hand, application of wood ash, spraying with neem extract.

Fungal Diseases Crop rotation with less susceptible crops including sorghum, millet, maize, onions, garlic. Long term flooding of the fields.

COGA 80 WP, Dithane M45, and GOLDEN BLUE 985 SG

Peanuts/groundnuts Insects, caterpillars Spraying with Neem extract (Azadirachta indica) and papaya extract (Carica papaya). Removing and destroying plants and residue infected with insect larvae.


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Fungal diseases producing Alfatoxin, Aspergillus flavus and Aspergillus parasiticus

Three year crop rotation and intercropping, uprooting infesting plants to stop the disease spreading; destruction of any infested plant parts after the harvest.

Cowpea Insects, caterpillars Spraying with Neem extract (Azadirachta indica) and papaya extract (Carica papaya). Removing and destroying plants and residue infected with insect larvae, intercropping with maize and sorghum.


Cercospora leaf spot, fungal rot

Use clean seed, use resistant cultivars, and destruction of crop residues after harvest. See charcoal rot recommendations above.

Apron star 42 WS, seed treatment, Caiman Rouge P, seed treatment, Cruiser Extra Cotton 362 FS seed treatment.

Agroforestry19 Termites Use traditional practices: use of bamboo stems, smoking the termite nest, use of salt, and flooding of termite nests with water.

None recommended

Other pests Decis 25 EC

Livestock20 21 Tsetse flies, cattle ticks, mange mites, screw worm

See Annex VI See Annex VI Tick stop22

Vectocid23

19 During interviews with experts at ICRAF, ICRISAT, and the Programme Ressources Forestières, Institut d’Economie Rurale (IER) - Sotuba/Bamako, only Decis was recommended for agroforestry pest control.20 Animal husbandry pesticides were identified based on consultation with USAID team specialist, Yacouba Santara, and results of field visits.21 These pesticides are not currently approved by INSAH CSP (They are, however, registered by USEPA). It is recommended that temporary approval "for research and development" be requested according to the Mali Ministry processes.22 The use of these pesticides must be restricted to formulations containing less than 5% of the active ingredient, and can only be applied as a pour-on product.23 Ibid

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3.7 COMPATIBILITY OF THE PROPOSED PESTICIDE USES WITH TARGET AND NON-TARGET ECOSYSTEMS

Applying the pesticide with regard for the potential to impact non-target ecosystems is an important tool for minimizing risks to the environment. Considerations for minimizing adverse impacts to non-target ecosystems include:24

Spot treatments rather than widespread application (where possible); Application of some herbicides using wick or shield applicators; Pesticide spraying during low-wind conditions; Pesticide application at times other than immediately prior to irrigation or

precipitation unless product labeling specified irrigation post-application; Strict adherence to product application rates listed on product labels; Pesticide application in areas sufficiently far from water bodies per labeling

instructions; and Disposal of pesticides and/or cleanup washwater in accordance with FtF

training program. If Malian guidelines for pesticide cleaning and disposal operations become available, they will be integrated into the FtF and M-CCAPM-CCAP and included in the AEG team’s three-phase training program.

In certain situations (e.g., protection of rice paddies), application near water bodies cannot be avoided. In situations such as these, non-chemical control methods (see Section 3.9) must be considered as supplements to, or in lieu of, pesticide application.

An important issue for the FtF and GCC Programs will be to link the presence of natural resources and non-target organisms in the four ecological zones of Mali (as described in Section 2.1) with the crop locations and the proposed pesticide use within these areas. Natural resources/non-target organisms that may be adversely affected by pesticides include, but may not be limited to:

honeybee populations; other beneficial insects; bird populations; mammalian populations; aquatic vertebrates (freshwater and marine/estuarine); aquatic invertebrates (freshwater and marine/estuarine); aquatic plants; and shallow ground water and/or ground water underlying permeable soils.

These various natural resources/non-target organisms can be identified within the tropical desert, the tropical scrubland, the tropical dry forest and the tropical moist deciduous forest so that the appropriate safe use measures are included in the FtF and GCC training programs and are followed in the vicinity of non-target

24 UC IPM Online, 2012; Pesticides: Safe and Effective Use in the Home and Landscape. Website last updated February 16, 2012; accessed March 6, 2012. Available on the Internet at:http://www.ipm.ucdavis.edu/PMG/PESTNOTES/pn74126.html

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ecosystems. Safe use measures with respect to non-target ecosystems are described in Section 4.3 (less toxic possible alternative pesticides).

The following pesticides are of at least moderate acute toxicity to the ecological receptor indicated, have demonstrated chronic toxicity, or have the potential to leach to ground water (this information is also collected in Exhibit II-1 in Annex II). In some cases, the exposure duration (i.e., acute or chronic) is not specified. Note that some pesticides that have been registered more recently have incomplete ecological toxicity profiles. In these cases, concerns are noted where USEPA has not classified the degree of acute toxicity.

As noted in Exhibit 2 in Section 3.2, (and in Section 4.2) the use of many of the approved pesticide formulations is restricted as follows:

Insecticides Certain insecticides containing the active ingredients of acetamiprid,

imidacloprid, beta-cyfluthrin, thiram, indosacarb, lambda-cyhalothrin, thiamethoxam, fludioxonyl, metalaxyl-M (mefenoxam), namely TITAN 25 EC, THUNDER 145 O-TEQ, MOMTAZ 45 WS, VIPER 46 EC, PACHA 25 EC, ACTARA 25 WG, and CRUISER EXTRA COTON 362 FS, can only be used as seed treatment on pretreated seeds or when plants are in the vegetative state;

Insecticides containing deltamethrin, namely DELTACAL 12.5 EC, have registrations that may expire. Confirm the registration for green beans (renewed in May 2014) and for tomatoes (expires in May 2016) prior to usage;

One insecticide containing dimethoate, METHOATE 40 EC, cannot be used on cowpeas; and,

One insecticide containing permethrin and pirimiphos-methyl, ACTELIC SUPER DUST, can only be used for treatment of commodities stored indoors; not to be formulated or used as an outdoor spray;

Insecticides/acaracides Only the Toxicity Category II or III products, not the Category I products of

certain insecticides containing abamectin, namely ACARIUS, BOMEC 18 EC, and VERTIMEC 18 EC, can be used.

Insecticides/fungicides Certain insecticides containing imidacloprid, thiram, permethrin,

thiamethoxam, fludioxonyl, and metalaxyl-M (mefenoxam),namely INSECTOR T, CAIMAN ROUGE P, and APRON STAR 42 WS, can only be used as seed treatment on pretreated seeds or when plants are in the vegetative state;

Fungicides Only the Toxicity Category II or III product, not the Category I product of one

insecticide containing copper sulfate pentahydrate, GOLDEN BLUE 985 SG, can be used.

Rodenticide Only the Acute Toxicity Category III products sold as baited traps containing

brodifacoum, namely VERTOX PELLETS, can be used.

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The following risks associated with these pesticide formulations will be included in the FtF training program in the context of which pesticides whose use is to be restricted on crops that are planted in proximity of these ecological receptors and natural resources.

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Pesticides that are of concern for honeybees include:

Insecticides acetamiprid - highly toxic beta-cyfluthrin- highly toxic chlorpyrifos-methyl - highly toxic deltamethrin – highly toxic (acute) dimethoate – very highly toxic imidacloprid - very highly toxic indoxacarb – highly toxic (contact) lambda-cyhalothrin – highly toxic pirimiphos-methyl – moderately toxic (acute) spinosad – highly toxic by direct spray (acute) permethrin – highly toxic thiamethoxam – very highly toxic

Insecticides/acaricides abamectine – highly toxic

Insecticides/fungicides imidacloprid – very highly toxic

Fungicides copper sulfate pentahydrate – highly toxic

Herbicides 2,4-D amine – highly toxic

Pesticides that are of concern for other beneficial insects include:

Insecticides permethrin – highly toxic

Pesticides that are of concern for bird populations include:

Insecticides acetamiprid- highly toxic dimethoate – very highly toxic indoxacarb – moderately toxic (acute oral) pirimiphos-methyl – very highly toxic (acute) spinosad – acute and chronic risks

Fungicide thiram – potential reproductive effects (chronic)

Pesticides that are of concern for mammalian populations include:

Insecticides indoxacarb – toxic pirimiphos-methyl – very highly toxic (acute)

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spinosad – chronic risks

Pesticides that are of concern for freshwater fish include:

Insecticides beta-cyfluthrin – highly toxic deltamethrin – very highly toxic (acute), reduced reproductive success

(chronic) indoxacarb and degradates – moderately to very highly toxic (acute) lambda-cyhalothrin – very highly toxic permethrin – very highly toxic pirimiphos-methyl – very highly toxic (acute)

Fungicides azoxystrobin – highly toxic thiram – moderately to very highly toxic (acute)

Pesticides that are of concern for freshwater invertebrates include:

Insecticides Bacillus thuringiensis subsp. kurstaki – moderately toxic (acute) chlorpyrifos-methyl – very highly toxic deltamethrin – very highly toxic, reduced reproductive success (chronic) dimethoate – very highly toxic indoxacarb and degradates – moderately to very highly toxic (acute) lambda-cyhalothrin – very highly toxic permethrin – highly toxic spinosad – toxic to highly toxic (acute)

Insecticides/acaricides abamectine – highly toxic

Fungicides azoxystrobin – highly toxic copper sulfate pentahydrate – very highly toxic thiram – highly toxic (acute)

Herbicides glyphosate – moderately toxic to some freshwater invertebrates

Pesticides that are of concern for marine/estuarine fish include:

Insecticides deltamethrin – very highly toxic (acute) indoxacarb and degradates – moderately to very highly toxic (acute) permethrin – highly toxic

Fungicides azoxystrobin – highly toxic thiram – moderately to very highly toxic (acute)

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Pesticides that are of concern for marine/estuarine invertebrates include:

Insecticides deltamethrin – very highly toxic (acute) indoxacarb and degradates – moderately to very highly toxic (acute) spinosad – toxic to highly toxic (acute) permethrin – highly toxic

Fungicides azoxystrobin – very highly toxic thiram – very highly toxic (acute)

Pesticides that are of concern for aquatic plants include:

Herbicide glyphosate – may cause adverse effects to non-target aquatic plants under

certain uses

Pesticides that are of concern for leaching to ground water and/or being mobilized by run-off include:

Insecticides acetamiprid dimethoate fludioxonyl metalaxyl-M (mefenoxam)

Insecticides/fungicides imidacloprid

Fungicides azoxystrobin Copper sulfate pentahydrate thiram – foliar applications may reach surface water

Herbicides (see Exhibit II-1 in Annex II as all but four proposed herbicides are of concern)

3.8 CONDITIONS UNDER WHICH THE PESTICIDES ARE TO BE USED, INCLUDING CLIMATE, FLORA, FAUNA, GEOGRAPHY, HYDROLOGY, AND SOILSThe FtF and M-CCAPM-CCAP in Mali intervenes in three regions (Sikasso, Mopti, and Tombouctou) and the area around Diabaly. These areas show great variety across agricultural production, climate, agro-ecology, soils, and hydrology

The three seasons in Mali can be characterized as follows: The rainy season (June to October) which supports cereal crops, and is

characterized by the Mousson winds;

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The cold dry cold season (November to February) which supports vegetable gardening; and,

The hot dry season (March to June) which does not support major crops and is characterized by the dry winds of the Harmattan winds.

Sections 3.8.1 and 3.8.2 (below) provide overviews of the soils and hydrological characteristics in Mali. Exhibit 6 then summarizes the agricultural production, the climate, the agro-ecology, soils and the hydrology of each region.

3.8.1 SOIL CHARACTERISTICS IN MALI25

Mali soils can be characterized as weakly ferralitic, ferruginous, arid, poorly developed, and vertisol soils.

The weakly ferralitic soils occupy nearly 2 million hectares (ha) in the extreme south of the country;

The tropical ferruginous soils cover more than 17 million ha in the northern Sudanian zone and southern Sahelian zone; their fertility potential is quite high;

The arid soils also occur in the northern Sudanian zone and southern Sahelian zone;

The poorly developed soils in the very dry climate, characterized by their denudated state, cover around 43 million ha (35% of the national territory); and,

The hydromorphic soils and vertisol soil characterized by excess water due to the temporary or permanent flooding of part of their profile are dominant in the depressions and basins and especially in the interior Niger River delta area.

3.8.2 HYDROLOGICAL CHARACTERISTICS IN MALI26

Approximately 47% of the total area in Mali is located in the Niger River watershed, 11% is located in the Senegal River watershed, and 41% is located in the interior basin of the Sahara. Only one percent is located in the Volta River watershed. The Niger River traverses Mali from southwest to northeast. It is one of the largest rivers in Africa. Approximately 1700 kilometers (km) of the Niger River’s entire 4200 km length crosses Mali. The principal tributaries to the Niger River include the Bani and the Sankarani Rivers. The Senegal River is composed primarily of its tributaries in Mali, the Bafing, Bakoye, Falémé and the Baoulé Rivers. The only river in the Volta basin in Mali is the Sourou River. Nine groundwater systems have been identified in Mali. These aquifer systems cover the entire territory and represent the principal potable water supply for the Malian population.

25 FAO, 2005, AQUASTAT global water information system, accessed June 2014: http://www.fao.org/nr/water/aquastat/countries_regions/mali/printfra1.stm26 FAO, AQUASTAT Country Profile, Mali, Accessed June 2014: http://www.fao.org/nr/water/aquastat/countries_regions/MLI/index.stm

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http://www.fao.org/nr/water/aquastat/countries_regions/MLI/index.stm

http://www.fao.org/nr/water/aquastat/countries_regions/mali/printfra1.stm


Exhibit 6: Agro-Ecological Characteristics of the AEG Intervention Regions

Region Agricultural Production

Ecological Zone Soil Characteristics Hydrologic Characteristics

Sikasso Strong, diverse and varied agricultural, production, corn, sorghum, millet, cowpea, and cotton are grown in upland areas, tubers, and rice in the lowland areas. Vegetable gardening is also common in this area.

Soudano-Guinean, or sub humid zone, tropical moist deciduous forest, and wooded savanna, with an average annual rainfall of 1000 to 1400 mm.27

At certain locations in the area, colluvial and alluvial deposits form loamy sandy soils.

The ferruginous, lateritic soils found in this area are of high agronomic value.

The region is drained by numerous tributaries to the Niger River: including the Wassoulou, the Baoulé, the Bagoé, and the Banifing and the Sakarani. In addition several tributaries to the Bani River traverse the area.

Mopti The primary crops are rice and millet. Onions are also grown in this area.

Sahel or tropical shrub land with an average annual rainfall of 250 to 800 mm. Includes the vast interior delta of the Niger River (a separate agro-ecology) with numerous seasonally flooded areas and rainfall agricultural areas.28

There are two types of soil in the area:1) Sandy-silty soils suited to cereal wintering crops, fodder crops, and vegetables.2) Silty-clay soils that are well suited to wintering cereal crops, and vegetables.

The Niger river and its tributary, the Bani, are the primary water courses for the region.

Diabaly (Alatona Irrigation Project)

Rice farming is practiced on hundreds of acres of channeled fields (including informal, illegal plots). Market gardening produces a variety of vegetables in lowland areas. Millet and sorghum are primarily grown in non-irrigated upland areas.

The Sahel, or tropical shrub land with an average annual rainfall of 250 to 800 mm. (See Mopti above)

The soils include primarily marsh and clay soil, with sandy soil in the northeast quadrant.

The area is irrigated by the Niger river. The wetland areas receive runoff from rice fields.

Tombouctou Crops include rice, millet, sorghum, wheat, cowpea, sweet potato and market vegetables. Production occurs on the shores of lakes and ponds, in the Niger River valley via traditional methods or

Saharan or tropical desert with an average annual rainfall of 0 to 200 mm.Temperatures are high to extremely high, with substantial variation between night and day and between

The soil types include :1) Stabilized dune soil : deep and well drained sandy soils2) Flat dune soil: sub-desertic, eroded, graded, deep, well drained sandy soils;3) Plains soils of fine silt: composed of silty materials, deep and well drained.

The Niger river is the primary water course for the region.

27 FAO, AQUASTAT Country Profile, Mali, Accessed June 2014: http://www.fao.org/nr/water/aquastat/countries_regions/MLI/index.stm28 Ibid

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http://www.fao.org/nr/water/aquastat/countries_regions/MLI/index.stm


irrigation. Agriculture is primarily rainfall fed. However, irrigated agriculture plays an important role in the region via village level irrigation districts (or PIV, Périmètres Irrigués Villageois).

the wet and dry seasons. The average temperatures range between 15 and 30°C in December and January to between 30 and 45°C in May and June.

4) Plains soil of sandy silts; composed of brown red soils, sub-arid, to well drained silty sands deep and well drained.5)Soils of the lateritic crust: composed of ungraded mineral soils from cuirass erosion 6) Hydromorphous earth: composed of soils from hydromorphic areas, partially flooded, deep with poor drainage.7) Submerged soils; composed of soils from seasonally flooded areas.8) Special soils from ancient lake beds.

3.9 AVAILABILITY OF OTHER PESTICIDES OR NON-CHEMICAL CONTROL METHODS

Alternatives to pesticide use are detailed in the IPM Plan in Annex III, and the tables in Exhibit 5, and Annex VI. Key components of the FtF IPM Plan include:

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, destruction of crop residues and pest refuge plants near fields and Good Agricultural Practices (GAP);

Pest scouting, monitoring, and identification for precision decision-making; Natural pest control by encouraging and protecting local and introduced

parasitoids, predators, and pest diseases by, among others, planting predator-attracting plants/flowers;

Mechanical weed or insect pest control using manual and machine practices; and

Chemical practices such as use of judicious, knowledgeable, and safe application of synthetic and “natural” (derived from nature, extracted from plants, microbes, and other organisms) pesticides.

The AEG team will also monitor international developments in IPM to evaluate whether new concepts and techniques might be included in their IPM strategy for Mali. See Annex III, Exhibit 5, and Annex VI for details on how IPM will be implemented for the FtF and M-CCAPM-CCAP and how the pesticides in this PERSUAP will be integrated into the IPM approach. Possible alternatives to the more toxic pesticides for which USAID approval is being sought are presented below.

As noted in Exhibits II-1 and II-2 in Annex II, certain approved pesticides are either classified/categorized as Acute Toxicity II or have suggested evidence of carcinogenicity. In certain situations, and given the current challenges associated with the procurement of pesticides from reliable vendors in Mali (see Attachment 3 of the IPM Plan in Annex III), there may be no other choice but to use these products

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and the safe use of these products is dependent upon effective training. However, less-toxic alternatives may be available. In most cases, potential risks to farmers must be weighed against risks to the environment. Consideration of the ecological receptors that are/are not present in a location where pesticides are to be applied will help to dictate whether the pesticide that is more acutely toxic to humans should be used (with higher-level PPE) or if it is acceptable to use one of the alternates if the sensitive ecological receptors are not present.

Note that less toxic alternatives may not be effective against all pests or appropriate for all crops for which the more toxic pesticide is generally used. Agronomists assigned to the FtF and M-CCAPM-CCAP, are highly-qualified to make these types of decisions and will lead the FtF training program to ensure that proper decisions are made in the area of pesticide selection.

3.10 HOST COUNTRY’S ABILITY TO REGULATE OR CONTROL THE DISTRIBUTION, STORAGE, USE, AND DISPOSAL OF THE REQUESTED PESTICIDESMali’s pesticide registration program is managed by the pesticide committee (CSP) at the Institute of the Sahel (INSAH). Mali is a member of the Comité permanent Inter-Etats de Lutte contre la Sécheresse dans le Sahel (Permanent Interstate Committee for Drought Control in the Sahel (CILSS)) which is comprised of INSAH and other research organizations. The provisions for this program are described in the Common Regulation for the Registration of Pesticides in CILSS Member States.29 According to the Common Regulation, the CSP committee reviews applications for registration and approves or rejects the application. The individual country, Mali in this case, is responsible for ensuring that pesticides are handled and applied in accordance with the Common Regulation post-registration.

The regulatory framework to enforce pest management in Mali is composed of the following specific laws:

Law Number 02-014 of 3 June 2002: Institutes the registration and regulation of pesticides in Mali – Chapter 5 promulgates penalties for non-compliance with pesticide regulations; and,

Decree Number 02-306/P-RM: Promulgates the modalities of application of Law 02-014 (above) – Created the Comité National de Gestion des Pesticides (National Pesticide Management Committee (CNGP)).

Additional general laws relevant to pesticide management in Mali are included in Annex VII.

The legislative framework includes several overlapping laws and decrees regulating the import, export, manufacturing, transportation, and commercialization of pesticides in Mali, whose enforcement is shared amongst several ministries. A number of the legislative texts have weak or nonexistent implementing decrees. As a result, the legislative framework lacks mechanisms for the proper management of pesticides in Mali.

29 Accessed at CILSS INSAH website. June 2014: http://www.insah.org/doc/pdf/RCenglish.pdf

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http://www.insah.org/doc/pdf/RCenglish.pdf


As noted above, though the CILSS INSAH registration program appears to be rigorous and comprehensive, the enforcement of the associated regulations for pesticide management is not well implemented in Mali.

As noted previously, the list of proposed pesticides requested for potential use in the FtF and M-CCAPM-CCAP, is based on the list of approved pesticides developed by INSAH CSP. Some of the proposed pesticides, primarily to be used for livestock, are not currently approved by INSAH CSP. The CILSS Common Regulation includes a provision for approval of pesticides to be used for research and development. It is recommended that, should FtF decide to use these livestock pesticides, an application for their use under this provision be submitted.

Plans for pesticide transport, packaging, storing and formulation selection for the pesticides proposed for use in the FtF and M-CCAPM-CCAP are addressed in Attachment 1 of the IPM Plan in Annex III and will be topics for worker training as part of the FtF and M-CCAPM-CCAP as outlined in Section 3.11 and Annex IV.

The AEG team is committed to using vendors that provide quality pesticide products in proper packaging and labeling, as well as in formulations that minimize risk to farmers and the environment. As mentioned in Section 3.4, the agricultural supply company, MPC, is one such vendor for pesticides, application equipment and safety equipment.

The AEG team will continue to identify vendors who meet their criteria for proper pesticide identification, packaging and labeling to assure use of the proper pesticide products. Specific issues that relate to the procurement of pesticides for which USAID approval is being sought include the following pesticides. The AEG team must ensure that all procurement operations adhere to the following restrictions:

Insecticides TITAN 25 EC, THUNDER 145 O-TEQ, MOMTAZ 45 WS, VIPER 46 EC, PACHA 25

EC, ACTARA 25 WG, and CRUISER EXTRA COTON 362 FS – Only use as seed treatment on pretreated seeds or when plants are in the vegetative state;

DELTACAL 12.5 EC – Confirm the registration for green beans (renewed in May 2014) and for tomatoes (expires in May 2016) prior to usage;

METHOATE 40 EC – This pesticide cannot be used on cowpeas; and, ACTELIC SUPER DUST- Limit use only for treatment of commodities stored

indoors; not to be formulated or used as an outdoor spray;

Insecticides/Acaracides ACARIUS, BOMEC 18 EC, and VERTIMEC 18 EC – Use only the Toxicity

Category II or III products, not the Category I product.

Insecticides/fungicides INSECTOR T, CAIMAN ROUGE P, and APRON STAR 42 WS – Only use as seed

treatment on pretreated seeds or when plants are in the vegetative state;

Fungicides GOLDEN BLUE 985 SG - Use only the Toxicity Category II or III products, not

the Category I product.

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Rodenticide VERTOX PELLETS - Use only the Acute Toxicity Category III products sold as

baited traps.

As discussed above, Mali has promulgated but not implemented a pesticide regulation program or a set of regulations for pesticide management (procurement standards, enforcement, proper use practices, or disposal). The AEG team is committed to the implementation of best management practices. The details for pesticide management presented throughout this PERSUAP and international standards for pesticide management, such as the WHO International Code of Conduct on Pesticide Management, will serve as guidance and models for the AEG team’s three-phase training program and all pesticide management during the implementation of the FtF and M-CCAPM-CCAP throughout Mali.

The pesticides for which USAID approval is being sought represent a compromise between those pesticides that are available from reliable vendors to the AEG team in Mali and the AEG team philosophy of using the least toxic pesticides for the intended applications. All pesticides for which USAID approval is being sought are registered by USEPA for uses that are similar to those proposed by the AEG team. Many low-risk pesticides have been selected, and lower-risk alternatives may be suggested as they become available in Mali. Cleanup procedures for each pesticide are detailed in the pesticide labels. Spill prevention and cleanup will also be covered in the FtF training program described in Section 3.11 and Annex IV of this PERSUAP.

Regarding spills, small containers are best-suited for use in the FtF and M-CCAPM-CCAP. Small containers provide:

Lower investment cost; Lower probability of waste; Lower probability of large spills; and, Easier to rinse and destroy spent containers.

The AEG team shall work with the Malian Ministry of Rural Development, as practical, in the implementation of the national pesticide disposal requirements. In addition to Malian regulations, the AEG team shall utilize international disposal requirements , including the OECD Guidance on Pesticide Compliance and Enforcement Best Practices and the WHO Guidance on Management Options for Empty Pesticide Containers, as models to ensure that used containers are properly cleaned and destroyed so that these containers cannot be reused for any other purpose and so that residual pesticides in wash waters and rinsates do not impact aquatic environments or endanger any ecological habitats that may be sensitive to the pesticide in question. See Section 3.7 and Exhibit II-1 in Annex II of this PERSUAP for details regarding the ecological hazards associated with the pesticides for which USAID approval is being requested.

3.11 PROVISION FOR TRAINING OF USERS AND APPLICATORS

In conjunction with use of the products evaluated in this PERSUAP, FtF shall implement a structured training and capacity development program with the goal of reducing pesticide-related risks for humans and non-target organisms. This program

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http://www.who.int/whopes/recommendations/Management_options_empty_pesticide_containers.pdf

http://www.oecd.org/env/ehs/pesticides-biocides/Pesticides_Compliance_Guidance.pdf

http://www.who.int/whopes/recommendations/International_Code_of_Conduct_on_Pesticide_Management_2014.pdf?ua=1

http://www.who.int/whopes/recommendations/International_Code_of_Conduct_on_Pesticide_Management_2014.pdf?ua=1


will be integrated as part of overall FtF implementation and will be monitored and reported on as one component of the project’s compliance with USAID Environmental Procedures (22 CFR 216 and related directives).

FtF’s pesticide training program will take a “cradle-to-grave” approach to ensure that all aspects of the product lifecycle are addressed, including storage, mixing, application, clean-up, and disposal - each stage presents particular environmental and human health risks. Specific initiatives will also be tailored to the educational level of trainees in order that illiteracy or a lack of basic math skills does not preclude effective capacity building. For example, training may be provided on interpretation of labels or other instructions, and common objects (condensed milk can, soda bottle, etc.) used to demonstrate ratios for accurate product mixing/dilution.

FtF will also promote and demonstrate PPE as fundamental to safer pesticide use. The project will make available to staff and partners an adequate supply of PPE for training and demonstration purposes. These materials will be retained at the IPs field offices, or provided to certain staff or partners on a long-term basis as needed (e.g., for remote extension workers). To ensure ongoing availability, an inventory shall be created of all FtF-owned PPE for use in project training and demonstration activities. The inventory shall be confirmed and updated on a quarterly basis and will encompass all PPE at the headquarters offices, as well as that in use in the field. These controls will assure accessibility to the correct PPE based on given training requirements.

Pesticide-related training and capacity building initiatives will be led by qualified agricultural, agro-input, or environmental management professionals. Potential instructors may be drawn from among FtF and M-CCAPM-CCAP staff, as well as partners, including sub-contractors and consultants. Instructors will have experience with—and understand the potential impact(s) of—the products on which FtF training in being provided. Most importantly, training design and delivery will be oriented to on-the-ground realities and will not seek to set expectations for pesticide use and management that cannot be met given Mali’s economic and regulatory challenges. Rather, training in safer pesticide use will focus on the most important elements for limiting risks to human health and the environment (e.g., product selection, use of PPE) and building capacity that is appropriate to local conditions and sustainable over the life of the project.

The cornerstone of FtF’s capacity building program will be a “Train the Trainers” course in pesticide safer use to be conducted at an appropriate time and frequency as described in the SUAP. The training will be scheduled to coincide with the general timeframe in which FtF may begin actively supporting pesticide use across the project’s three target value chains. Course enrollment will be required for FtF staff and partners directly involved in: a) pesticide procurement; and (b) the promotion of and training in use of pesticides among project beneficiaries. Participants are expected to include, at minimum, FtF Bamako office staff responsible for selection and/or purchase of the products evaluated in this PERSUAP, field office technical staff, value chain experts, FtF- extension agents, and project sub-contractors. An illustrative agenda for the Train the Trainers course in pesticide safer use is included as Annex IV. As demonstrated below, the Train the Trainers approach is Phase I of a three-phase approach, and serves as the basis for subsequent training

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of farmers and annual refresher training. Use of various PPE will be included in the training, and will be demonstrated by a qualified professional. This individual may or may not be the primary technical trainer, who will him/herself possess credentials as a pesticide expert and instructor

Attendees of the Train the Trainers course will propagate key aspects of pesticide safer use as they relate to project beneficiaries’ specific activities (e.g., sorghum/millet and rice cultivation, livestock production). This instruction will be provided in primarily field-based training exercises delivered by FtF over the life of the project as new farmers are engaged, products introduced, and cultivation practices refined. This second tier of more focused, value chain-specific trainings is expected to entail fewer products and will address particular pest concerns and local environmental conditions (e.g., upland vs. lowland, freshwater and estuarine aquatic habitats, honeybee populations, or urban vs. rural setting).

The Train the Trainers course and subsequent value chain-specific instruction will also both address the role and introduction of IPM methodologies. A three-phased approach to training will be employed:

Phase I – Train the Trainers; Phase II – Train Beneficiary Farmers; and Phase III – Annual Refresher Training for program staff, leader farmers and participant

farmersPhase 1: Using FtF-produced safe use training materials and posters, we will train program staff and participant farmers on the following topics:

The reasons for elimination from the FtF list of any pesticides containing active ingredients that are either not registered for same or similar use by EPA, formulations that are designated as Restricted Use Pesticides, or deemed very highly toxic (acute human toxicity Category I) with increased risk to project implementers and beneficiaries;

GAPs and IPM philosophy and specific tools and techniques that can be used for FtF crops;

The proper interpretation and use of MSDS information, pesticide label warnings/PPE recommendations, and proper use of PPE;

The requirements for safe use of high toxicity (acute human toxicity Category II) active ingredients,

Understanding and safe use (to set or change behavior in favor of best safe use practices) of pesticide products containing relatively lower toxicity (acute human toxicity Category III and IV) active ingredients, including the use of biological and natural pesticides;

The recognition that pesticides that are of lower acute human toxicity may still be toxic to humans on a sub-chronic (several months to several years) and/or chronic (many years) basis. Also, that pesticides that are of lower acute human toxicity may be highly toxic to non-target organisms, including honey bees, freshwater and marine/estuarine fish and invertebrates, mammals, birds, and non-target, crop-beneficial insects;

The recognition of natural resources and non-target organisms in the four ecological zones of Mali (as described in Section 2.1) with the crop locations and the proposed pesticide use within these areas.

The importance of sourcing pesticides from well-managed stores that do not sell illegal products or those containing very highly toxic active ingredients;

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Understanding and applying information contained in FtF-produced quick reference guides for all of the anticipated major or primary pests/production constraints, GAPs and IPM measures that can be used to strengthen and protect the crop, pesticides to be used on the project for each anticipated pest, with use rates, safety measures, environmental concerns, REIs, PHIs, PBIs, and maximum residue limits (MRLs) for export and local consumption;

The importance of monitoring for pest resistance by noting reduction in efficacy of pesticide products, and rotation among pesticide classes to reduce the build-up of resistance;

The importance of using pesticides with low ground water contamination potential where water tables are high or easy to reach; and

Basic first aid procedures (found on the product label and MSDS) for pesticide overexposure for the most commonly-used pesticides.

Phase 2: Following Phase 1, use program staff and participant farmers to train beneficiary farmers on the topics presented in Phase I of the training program.

Phase 3: Perform annual refresher training for program staff, leader farmers and participant farmers on all of the above topic areas and any new issues that may have arisen since the previous training.

3.12 PROVISION MADE FOR MONITORING THE USE AND EFFECTIVENESS OF PESTICIDES

The IPM Plan for the FtF and M-CCAPM-CCAP in Annex III contains clear provisions for the monitoring of pesticide effectiveness and possible adverse effects on human health, non-target organisms and ecosystems/ecological resources. Monitoring commences with pest and non-target organism identification and continues throughout the FtF and M-CCAPM-CCAP in areas that include:

Pesticide transport, packaging, storage and formulation data; Adherence to pest management procedures, including worker health, local

resident health, non-target organism, ecosystem, and natural resources health and vitality, efficacy on target crops for target pests, proper maintenance of pesticide containers and left-over product;

Monitoring of fields for pest levels, natural predators, soil microorganisms, and crop damage; and

Monitoring for pest resistance and rotating crops and pesticide use as needed.

The three-phase training program detailed in Section 3.11 of this PERSUAP describes training of trainers, training of farmers and refresher training that will help to ensure proper handling, use, and clean-up/disposal of pesticide by all who are involved in the FtF and M-CCAP. Note that the lack of the enforcement of formal regulations regarding pesticide management and disposal practices in Mali places a burden on the AEG team to properly manage pesticide procurement, use, and disposal.

The strong foundation of GAP, IPM, and the three-phase training program will allow the AEG team to implement the FtF and M-CCAP while maintaining safe working

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conditions for farmers and sensitive ecosystems in Mali. The IPM Plan in Annex III, coupled with the training program applies to all phases of pesticide use, from identification of products, procurement, transportation, storage, application, cleanup and disposal. An important part of the IPM Plan is to stay current with emerging alternatives to pesticides of greater toxicity and/or non-pesticidal measures.

Responsibility for safer pesticide use by the FtF and M-CCAP lies primarily with USAID/Mali in collaboration with the IP Chiefs of Party. In ensuring that requirements for safer pesticide use are defined, implemented, and enforced, the Chief of Party will rely on FtF and M-CCAP staff and partners, as well as input and guidance from the Government of Mali. The FtF Environmental Compliance Specialist, in particular, will play a pivotal role in designing and delivering SUAP-related training curricula. The Environmental Compliance Specialist will also provide ongoing technical assistance to ensure that the PERSUAP accurately reflects project activities as FtF evolves and new initiatives are proposed for implementation. FtF will also collaborate closely with private-sector entities such as the agro-input dealers who play a key role in importing and distributing the types of products addressed in the PERSUAP. FtF objectives include the strengthening of dealer networks and the promotion of less toxic pest-control alternatives. In this regard, dealer support will play a key long-term role in meeting SUAP requirements by making available the recommended pest control products across FtF target counties at affordable prices. These initiatives will be enhanced by working with other agriculture-sector projects in Mali, including those not funded by USAID or other United States Government entities.

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4.0 SAFER USE ACTION PLAN4.1 INTRODUCTIONThis Safer Use Action Plan is the definitive statement of IP pesticide compliance requirements and is synthesized from the PER analysis:

Section 4.2, immediately below, enumerates allowed pesticides. Section 4.3 summarizes the safer use conditions attendant to use/support of

these pesticides. These conditions are then detailed in the attached mandatory “Safer Use

Action Plan and Compliance Tracker” (“SUAP Tracker”) for assigning responsibilities and timelines for implementation of these requirements, and for tracking compliance.

Each project subject to this PERSUAP must submit a completed SUAP Tracker to its AOR/COR by 1 November 2014 (for activities in progress, otherwise prior to active implementation) and provide an annual update. (Please note that the implementation dates included here and in the SUAPTracker, highlighted in green, are tentative. They should be discussed with the implementing partner, finalized and approved by the MEO.)

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 PESTICIDESSynthesizing across the PER analysis only the below-listed pesticides of the larger candidate list are recommended for approval (See also Exhibit 2 which is repeated here). Upon approval of this PERSUAP, these pesticides and ONLY these pesticides are allowed for use/support in USAID/Mali FtF and M-CCAP projects.

Such use/support is allowed only in compliance with the safer use conditions summarized in the following section and detailed in the “Safer Use Action Plan and Compliance Tracker” that comprises the last section of this chapter.

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CSP Reference No. Product Name Active Ingredient Conc.WHO

Classification30

Approve/Reject Restrictions on Accepted Products


233 TITAN 25 EC acetamiprid 25 g/L II ApproveOnly as seed treatment on pre-treated seeds or when plants are in vegetative state













164 METHOATE 40 EC dimethoate 40 g/L II Approve Not to be used on cowpeas

234 THUNDER 145 imidacloprid 100 g/L II Approve Only as seed treatment on pre-30 The toxicity of the product is determined by the CSP INSAH committee during the registration approval process and is based on the WHO Classification system.

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Products

O-TEQ beta-cyfluthrin 45 g/L treated seeds or when plants are in vegetative state
















To be used only for treatment of commodities stored indoors; not to be formulated or used as an outdoor spray




4 ACTARA 25 WG thiamethoxam 250 g/kg III ApproveOnly as seed treatment on pre-treated seeds or when plants are in vegetative state



35 g/L8,34 g/L3,34 g/L


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Products





I ACARIUS abamectin 18 g/L II Approve Use only Toxicity Category II or III products; not Category I

27 BOMEC 18 EC abamectin 18 g/L II Approve Use only Toxicity Category II or III products; not Category I

241 VERTIMEC 18 EC abamectin 18 g/L II Approve Use only Toxicity Category II or III products; not Category I





28 CAIMAN ROUGE P

permethrinthiram


Only as seed treatment on pre-treated seeds; not to be used in any field-spray applications

14 APRON STAR 42 WS


200 g/kg200 g/kg20 g/kg


Fungicides 177 ORTIVA 250 SC azoxystrobin 250 g/L III Approve 18 AZOX azoxystrobin 250 g/L III Approve 47 COGA 80 WP mancozeb 800 g/kg III Approve 77 DITHANE M 45 mancozeb 800 g/kg III Approve


116 GOLDEN BLUE Copper sulfate 985 g/kg II Approve Use only Toxicity Category II or

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Products985 SG pentahydrate III products; not Category I.

Nematicide None

Rodenticide


Approved only for Acute Toxicity Category III products sold as baited traps

Herbicides











dicambanicosulfuron


221 SUN 2,4 AMlNE 720 SL

Dichlorophenoxiacetate, dimethyl-amine (2,4-D amine)

720 g/L II Approve



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Products78 DOUMA WORO glyphosate 480 g/L II Approve 98 FINISH 68 SG glyphosate 680 g/L III Approve













162MAMBA 360SL(DOMINATOR 360 SL)

glyphosate 360 g/L III Approve




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Products















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Products









.

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4.3 SUMMARY OF COMPLIANCE REQUIREMENTSIn summary, the mitigation Measures and restrictions specified in the PER are as follows:

A. Only pesticides approved by this PERSUAP may be supported with USAID funds in USAID/Mali FTF and M-CCAP activities. These pesticides are enumerated in section 4.2, above;

B. Pesticide “SUPPORT” means procurement, use, recommending for use, or otherwise facilitating the use of a pesticide;

C. Pesticide support must be governed by a set of locally adapted, crop- and pest-specific IPM-based pest management plans and observe enumerated use restrictions. (The PERSUAP provides key information for IPs to develop these plans.);

D. Appropriate project staff & beneficiaries must be trained in safer pesticide use and pesticide first aid;

E. To the greatest degree practicable, projects must require the use and maintenance of appropriate PPE—as well as safe pesticide purchase, handling, storage and disposal practices;

F. Projects must be systematic in their pesticide-related record-keeping and monitoring.

These conditions are DETAILED in the mandatory SUAP Tracker that constitutes the next section.

The PER and the annexes provide substantial resources to support compliance with these requirements, as detailed in the table below.

IPM/Safer Use Requirement Key Resources ProvidedPesticide recommendations and use must be governed by a set of crop- and pest-specific IPM-based pest management plans.(IPs are responsible for developing these plans.)

Exhibit 5, Section 3.6 and Annex VI: Includes crop- and pest-specific chemical and IPM methods to use as a basis for these plans. Annex II: Exhibits II-1 and II-2 provide toxicological data for each approved active ingredient including acute and chronic toxicities, groundwater pollution potential, eco-toxicities for non-target organisms such as fish, honeybees, birds and aquatic organisms. Annex III: Describes the proposed IPM program for FtF. Attachment 1 provides mitigation measures for potential pesticide dangers. Attachment 2 provides general IPM program planning design guidance.

Appropriate project staff and beneficiaries must be trained in safer pesticide use & pesticide first aid.

Annex IV: Includes the sample FtF pesticide training agenda for a three-day program on pesticide risks, safer use and compliance.

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To the greatest degree practicable, projects must require use and maintenance of appropriate PPE—as well as safe pesticide purchase, handling, and disposal practices.

Exhibit 4: Summarizes appropriate PPE for each approved pesticide.

Projects must be systematic in their pesticide-related record-keeping and monitoring.

The SUAP tracking template, below, provides the necessary guidance to ensure systemic record-keeping and monitoring.

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Republic of Mali/USAID – FEED THE FUTURE (FtF) PROGRAM

Pesticide Safer Use Action Plan and Compliance TrackerMust be completed by 1 November 2014 and annually updated thereafter.

BASIC INFORMATION SUBMISSION DATES:

Prime Contractor Initial submission 1 November 2014

Project Feed The Future (FtF) Program Annual Update #1

Pesticide Compliance Lead

& Contact Information

Annual Update #2

Summary of Pest Management

Needs on Project

Annual Update #3

Note: Pesticide “support” is defined as the use of USAID funds to: (1) purchase pesticides; (2) directly fund the application of pesticides; recommend pesticides for use; or (3) purposely facilitate or enable the application or purchase of pesticides via provision of application equipment, credit support, or other means.

Required Compliance (Mitigation) Measure

Initial Compliance Status (if not known or not applicable, so indicate)

Actions planned to achieve & maintain compliance(w/ deadlines & responsible party)

Status of compliance actions

SUPPORT ONLY THE PESTICIDES AUTHORIZED BY THE 2014 USAID/MALI FtF PERSUAP

Immediately

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Required Compliance (Mitigation) Measure

Initial Compliance Status (if not known or not applicable, so indicate)

Actions planned to achieve & maintain compliance(w/ deadlines & responsible party)

Status of compliance actions

Inventory Pesticides being supported and ensure NO SUPPORT for pesticides listed in Exhibit 3 of Section 3.2.

Not applicable Develop list of pesticides to be used in Mali by the FtF and M-CCAP.

Completed as of issuance of PERSUAP. List of authorized, approved pesticides in Exhibit 2 of Annex II.

Distribute copies of the list of allowed AIs with matching commercial product names to all project field extension staff & advise regarding the 1 October 2014 deadline for compliance (below)

Not known FtF/COP to distribute copies by 1 October 2014.

As soon as possible but not later than 1 October 2014

Assure that USAID-funded pesticide support is limited to ONLY PESTICIDES APPROVED BY PERSUAP. Continue verification throughout life-of-project

List of authorized, approved pesticides in Exhibit 2 of Section 3.2.

Assure that any pesticides directly purchased or applied are quality, brand-name products.

Develop or adapt existing procurement clearance process for each purchase of pesticides.

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Pesticide technical assistance and use must be governed by a set of locally adapted, crop-and-pest specific IPM-based pest management plans and observe enumerated use restrictions.

By 1 November 2014Identify any sensitive and protected areas near project sites.

Sikasso Region/1 November 2014

Mopti Region & Diabaly(Altona) Area/1 November 2014

Tombouctou Region/1 November 2014

Starting from the information in PERSUAP Exhibit 5, Section 3.6, and Annex VI, adopt/develop crop- and pest-specific IPM-based pest management plans (PMPs).

Use recommended IPM practices in Exhibit 5, Section 3.6. Review Exhibit II-1 in Annex II and the proposed IPM program in Annex III, for additional options.

Sorghum/Millet PMP/1 November 2014

Rice PMP/1 November 2014

Livestock PMP/1 November 2014

Maize PMP/1 November 2014

Potatoes PMP/1 November 2014

Cowpea PMP/1 November 2014

Peanuts PMP/1 November 2014

Vegetables PMP/1 November 2014

Proposed Trees PMP/1 November, 2014

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Translate PMPs into crop-specific field reference guides or posters for farmers to anticipate and manage pests.

Sorghum/Millet Poster/1 November, 2014

Rice Poster/1 November, 2014

Livestock Poster/1 November, 2014

Maize Poster/1 November, 2014

Potatoes Poster/1 November, 2014

Cowpea Poster/1 November, 2014

Peanuts Poster/1 November, 2014

Vegetables Poster/1 November, 2014

Trees Poster/1 November, 2014

By 1 September 2014

Provide first-time training to appropriate project staff, partners and beneficiaries in PMPs

See Annex III, for detailed approach for IPM training.

Five IPM Plan technical workshops/1 September 2014

Ten GAP technical workshops/1 September 2014

Provide refresher training annually.

Refresher training, 1 September 2015

From 1 November 2014

Require and enforce PMP implementation in situations where the project has direct control over pesticide use.

Enforce use restrictions

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enumerated below** in situations where the project has direct control over pesticide use.

Require and enforce that field extension under direct project control be PMP-based and fully comply with enumerated use restrictions.**

Where project control over extension or agricultural practice on the ground is less than complete, promote and support PMPs and enumerated use restrictions** to the greatest practicable extent.

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Ongoing over Life of Project (LOP)

Modify PMPs over LOP based on ground-truthing/field experience.

Develop planned focus groups to ground truth PMPs.

Appropriate project staff & beneficiaries must be trained in safer pesticide use & pesticide first aid.

By 1 November 2014

Develop a Training Plan for Pesticide Safe Practices and IPM for project staff and beneficiaries, including at least annual refresher training.*

Detailed approach for training is outlined in Annex IV.

Training Plan by 1 November 2014

Develop or source curricula conforming to required training elements*.

Detailed list of reports and publications to distribute and disseminate is available at the GEMS website.

Per training plan, provide first-time training to all relevant staff and beneficiaries

Detailed approach for training is outlined in Annex IV.

Train-the-Trainer technical workshops/1 November 2014

Training Events for Farmers and Families (schedule to be developed annually)

Refresher training/1 November 2015

To the greatest degree practicable, projects must require use and assure maintenance of appropriate PPE and application equipment—as well as safe pesticide purchase, handling, storage and disposal practices.Assure and require well-

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maintained sprayers and proper post-spray hygiene and facilities for pesticide use under direct project control.

Where pesticide use is not under project direct control, but the project is nonetheless supplying or directly supporting the purchase of pesticides or application equipment, assure that appropriate post-spray facilities for washing clothing and equipment, and proper disposal of wastes are in place

Where pesticide use is under direct project, assure that appropriate PPE is provided, is well-maintained, and properly utilized, and that good handling, storage, clean-up and disposal practices are followed. This includes the use of gloves for powder or granule application. (Appropriate PPE is as per pesticide labels.)

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Where pesticide use is not under project direct control, but the project is nonetheless supplying or directly supporting the purchase of pesticides or application equipment, assure that appropriate PPE is available and undertake all feasible measures to promote its use and good handling, storage, clean-up and disposal practices.

In extension activities, promote and support to appropriate PPE use and good handling, storage, clean-up and disposal practices to the greatest degree practicable.

For any support to commercial farms, encourage and support the use of Global GAP best practices with pesticide storage, use and disposal, whether or not certification is sought.

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Projects must be systematic in their pesticide related record-keeping and monitoring.

The following must be tracked and reported: Human poisonings and any incidences of chronic health issues; farm animal and livestock deaths; incidences of water pollution; Fish, bird, wildlife or honeybee kills; and any evidence of pesticide resistance development.

Develop or adapt existing record keeping and monitoring program.

Flow-down requirements

Prime contractors must write pesticide compliance requirements as set out above into each grant or sub-contract that will involve support for pesticide use.

* Required Pesticide Safer Use/IPM Training Elements: See Annex III and Annex IV.

**Use restrictions:1. Higher-toxicity and more persistent pesticides will not be used where endangered species are known to exist

2. A 2.5 to 5 km buffer no-spray zone will be observed around national parks or other protected areas

3. Neither spraying nor equipment rinsing will be conducted within 30 meters of ponds, drainage ditches, and surface waters.

4. Pesticides with high toxicities to aquatic organisms will not be sprayed when rain is likely.

5. Herbicides or other pesticides with high leaching and groundwater pollution potential, noted in Exhibits II-1 and II-2, will not be used near drinking water sources, on highly sandy soils or soils with water tables close (2-3 meters) to the surface.

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Annex I – WHO and USEPA Acute Toxicity CriteriaOctober 2014

ANNEX I: WHO ACUTE TOXICITY CLASSIFICATIONS AND USEPA ACUTE TOXICITY CATEGORIESRestricted Use Pesticides (RUPs) are designated as such by the USEPA. According to the USEPA, “the "Restricted Use" classification restricts a product, or its uses, to use by a certified pesticide applicator or under the direct supervision of a certified applicator.” For the purposes of PERSUAP documentation, RUPs are not approved for use in the FtF and M-CCAP as certified pesticide applicators are not available in Mali.

Exhibit I-1: WHO – The Globally Harmonized System of Classification and Labeling of Chemicals (GHS)31

Rat LD50 (mg/kg body weight)

WHO Class (note: for

technical grades)Oral Dermal

Ia Extremely Hazardous <5 <50

Ib Highly hazardous 5-50 50-200

II Moderately hazardous 50-2,000 200-2,000

III Slightly hazardous Over 2,000

UUnlikely to

present acute hazard

5,000 or higher

31 WHO. 2009. The WHO Recommended Classification of Pesticides by Hazard and Guidelines to Classification, 2009. World Health organization, 2010. Available on the Internet at: http://www.who.int/ipcs/publications/pesticides_hazard_2009.pdf

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http://www.who.int/ipcs/publications/pesticides_hazard_2009.pdf

Annex I – WHO and USEPA Acute Toxicity CriteriaOctober 2014

Exhibit I-2: EPA Acute Toxicity Categories32

Study Category I Category II Category III Category IV

Acute Oral Up to and including 50 mg/kg

>50 through 500 mg/kg

>500 through 5000 mg/kg >5000 mg/kg

Acute Dermal Up to and including 200 mg/kg

>200 through 2000 mg/kg

>2000 through 5000

mg/kg>5000 mg/kg

Acute Inhalation Up to and including 0.05 mg/liter

>0.05 through 0.5 mg/liter

>0.5 through 2 mg/liter >2 mg/liter

Eye Irritation

Corrosive (irreversible

destruction of ocular tissue) or

corneal involvement or

irritation persisting for more than 21

days

Corneal involvement or irritation

clearing in 8-21 days

Corneal involvement or irritation clearing in 7 days or less

Minimal effects clearing in less than 24 hours

Skin irritationCorrosive (tissue

destruction into the dermis and/or

scarring)

Severe irritation at 72 hours (severe erythema or

edema)

Moderate irritation at 72

hours (moderate erythema)

Mild or slight irritation (no irritation or

slight erythema)

Signal Word for Product Labeling DANGER WARNING CAUTION none required

Study Study results Study results

Dermal Sensitization Product is a sensitizer or is positive for sensitization

Product is not a sensitizer or is negative for sensitization

32 USEPA. 2002. Health Effects Test Guidelines OPPTS 870.1000 Acute Toxicity Testing— Background. EPA 712–C–02–189, Office of Prevention, Pesticides and Toxic Substances, December 2002. Available on the Internet at: http://iccvam.niehs.nih.gov/SuppDocs/FedDocs/EPA/EPA_870r_1000.pdf

USEPA. 2011. Regulating Pesticides, Module 2: Parts of the Label, Section 1: What is on the front panel? Website, last updated September 9, 2011; accessed February 29, 2012: http://www.epa.gov/pesticides/regulating/labels/pest-label-training/module2/page2.html

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http://iccvam.niehs.nih.gov/SuppDocs/FedDocs/EPA/EPA_870r_1000.pdf

Annex II - Pesticide Profiles October 2014

ANNEX II – PESTICIDE EVALUATION AND SELECTIONExhibit II-1: Approved Pesticides, USEPA Registration Status, RUP Designation and Acute Toxicity

Classification.

Active Ingredient Regulatory Status Human Toxicity Ecological Toxicity

Insecticides/Insecticide Active Components (e.g., fungicides)

USE

PA R

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WHO

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Insecticides acetamiprid Yes No NL III II NL potential NAT NAT HT HT Bacillus thuringiensis Yes No III III III NL no data MT ST PNT NAT NAT

beta-cyfluthrin Yes Some III, II, III, IV

II ED no data VHT ST HT PNT

chlorpyrifos-methyl Yes No U I, III III NL no data MT VHT HT MT MT

deltamethrin Yes Some II I, II, III II, III ED no data VHT VHT MT PNT VHT

dimethoate Yes No II III II PC, ED, RD potential ST HT-VHT VHT VHT HTfludioxonyl Yes No U III III NL potential MT MT MT MT

imidacloprid Yes No II II, III II, III NL potential NAT MT VHT MT

indoxacarb Yes No II II II NL no data MT MT HT HT

lambda-cyhalothrin Yes Some II II, III II ED no data VHT VHT HT PNT

metalaxyl-M (mefenoxam) Yes No II I, II, III NL potential MT MT NAT MT

Page II-1


IIIMetarhizium flavoviride anisopliae Yes No NL III III NL no data NAT NAT NAT NAT permethrin Yes Many II III II, III PC, ED no data VHT ST-VHT VHT PNT ST

pirimiphos-methyl Yes No II, III

I, II, III III NL no data MT HT MT

spinosad Yes No III III III NL no data MT MT HT PNT tagetes oil Yes No NL III U NL no data PNT PNT PNT PNT thiamethoxam Yes No NL III III PC no data PNT VHT ST thiram Yes No II II II, III ED, RD no data HT NAT PNT VHTthyme oil Yes No NL III U NL no data ST


abamectin Yes Some NL II, III II ED, RD no data ST HT HT PNT

Insecticides/fungicides imidacloprid Yes No II II II, III NL potential NAT VHT MT difenoconazole Yes No III III III PC, ED no data MT MT MT ST

mefenoxam (metalaxyl-M) Yes No II I, II, III III NL potential MT MT NAT MT

permethrin Yes No II III II, III PC, ED no data VHT ST-VHT VHT PNT STthiamethoxam Yes No NL III III PC no data PNT VHT ST thiram Yes No II II II, III ED, RD no data HT NAT PNT VHT

Fungicides azoxystrobin Yes No U III III NL potential MT MT MT MT mancozeb Yes No U III III PC, ED, RD no data MT MT ST HTmyclobutanil Yes No III III III ED, RD no data MT MT ST MT

copper sulfate pentahydrate Yes No II I, II, III II potential MT VHT HT MT

Rodenticide brodifacoum Yes No Ia I, III III no data MT

Herbicides

2,4-D amine Yes No NL I, III, II, III PC, ED potential ST NAT HT MT ST

Page II-2


IV

bensulfuron-methyl Yes No U II, III III NL potential NAT MT ST

clethodim Yes No NL II, III III NL potential MT MT MT MT

clomazone Yes No II II, III III NL potential MT MT MT NAT

dicamba Yes No IIII, III, IV

III RD potential ST ST PNT PNT

glyphosate Yes No III I, II, III II, III, U NL potential ST ST NAT

nicosulfuron Yes No U II, III III, IV NL potential MT MT MT MT

orthosulfamuron Yes No NL III III PC potential NAT NAT MT

oxadiazon Yes No U II, III III PC, RD no data MT ST MT ST MT

pendimethalin Yes No III III III PC, ED no data MT MT NAT ST penoxsulam Yes No U III II, III PC potential MT NAT MT MT

propanil Yes No II II, III II, III, U PC potential MT ST NAT MT ST

thiobencarb Yes No II III III NL potential NAT NAT MT MT

tribenuron-methyl Yes No NL III, IV III PC no data PNT PNT PNT

triclopyr Yes No III I, II, III II, U NL no data PNT-HT PNT-HT PNT NAT

1 The WHO Acute Toxicity Classifications and USEPA Acute Toxicity Categories are generic classifications/categories that are generally assigned to the technical active ingredients (typically 95% pure or greater). Many formulated products contain active ingredients at concentrations that are less than those in the technical active ingredient, which may result in a lower Acute Toxicity Classification/Category for the formulated product(s). This is reflected in the Acute Toxicity Categories listed in the "INSAH-Authorized Product Acute Toxicity Categories Approved in this PERSUAP" column (which also includes Acute Toxicity Categories for mixtures - other active ingredients may affect the ultimate Acute Toxicity Categories). NL = not listed.

Page II-3


Chronic toxicity: KC = Known Carcinogen; PC = Possible Carcinogen; LC = Likely Carcinogen; ED = Potential Endocrine Disruptor; RD = Potential Reproductive & Development ToxinEcological toxicity: NAT = Not Acutely Toxic; PNT = Practically Not Toxic; ST = Slightly Toxic; MT = Moderately Toxic; HT = Highly Toxic; VHT = Very Highly Toxic

Page II-4


Exhibit II-2: Approved Livestock Pesticides, USEPA Registration Status, RUP Designation and Acute Toxicity Classification33.

Active Ingredient Regulatory Status Human Toxicity Ecological Toxicity

Livestock: Insecticides/Insecticide

Active Components (e.g., acaracides)

USE

PA R

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?

RUP?

WHO

Acu

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oxic

ity

Clas

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trio

n1

USE

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Ca

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ries1

INSA

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Insecticides/acaracides amitraz yes no III II * PC, RD no data MT PNT ST STdeltamethrin yes few II II, III * none no data HT VHT MT VHT1 The WHO Acute Toxicity Classifications and USEPA Acute Toxicity Categories are generic classifications/categories that are generally assigned to the technical active ingredients (typically 95% pure or greater). Many formulated products contain active ingredients at concentrations that are less than those in the technical active ingredient, which may result in a lower Acute Toxicity Classification/Category for the formulated product(s). *These products are not authorized by INSAH CSP. It is recommended that, should they be used, an application for registration for research and development be submitted to CSP INSAH.Chronic toxicity: KC = Known Carcinogen; PC = Possible Carcinogen; LC = Likely Carcinogen; ED = Potential Endocrine Disruptor; RD = Potential Reproductive & Development ToxinEcological toxicity: NAT = Not Acutely Toxic; PNT = Practically Not Toxic; ST = Slightly Toxic; MT = Moderately Toxic; HT = Highly Toxic; VHT = Very Highly Toxic

.33 Adapted from Resilience and Economic Growth in the Arid Lands-Accelerated Growth (REGAL-AG) PERSUAP, Annex 2, USAID/Kenya, ACDI/VOCA, December 2013.

Page II-5

Annex III – Integrated Pest Management, Mali October 2014

ANNEX III – INTEGRATED PEST MANAGEMENT, MALISafer Use Practices, defined and assured

Integrated Pest Management (IPM) is a crop-oriented approach to minimizing the economic losses caused to the farmer by pests and diseases. These losses include not only the reduction in yield, but also the costs of control. IPM therefore seeks to take advantage of control by natural enemies and to balance carefully the gains from chemical treatment against both the financial cost of the chemical and the damage to natural enemies. IPM requires knowledge of the pests, the type of damage that they do, the effective control treatments available and the pests’ natural enemies. IPM is not something that can be worked out in advance and propagated in a prescriptive way to farmers. It is a methodology that FtF’s partner farmers will help develop with project staff and learn to apply for themselves.

Among the techniques available for IPM are: 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, destruction of crop residues and pest refuge plants near fields and GAP;

Pest scouting, monitoring, and identification for precision decision-making; Natural pest control by encouraging and protecting local and introduced

parasitoids, predators, and pest diseases by, among others, planting predator-attracting plants/flowers;

Mechanical weed or insect pest control using manual and machine practices; and

Chemical practices such as use of judicious, knowledgeable, and safe application of synthetic and “natural” (derived from nature, extracted from plants, microbes, and other organisms) pesticides.

IPM can also include use of natural chemical methods (by using attractants, repellents, sterilants, and growth inhibitors), genetic methods (propagation and release of sterile or genetically incompatible pests), and regulatory means (plant and animal quarantines, suppression and eradication programs) to the extent possible while permitting the safe integration of pesticides with farmers’ traditional management systems.

The strongest selling points for IPM beyond the health and environmental benefits are as follows:

IPM is more effective then synthetic Crop Protection Products in the long run; IPM is less damaging to essential soil health and nutrient cycling; IPM generally requires less capital (but more labor) investment; and IPM can be used preventatively to eliminate or minimize the need for

“responsive” controls (that is, applying pesticides after a pest outbreak occurs and much damage already has been done).

General GAP/IPM Tools and Techniques that Can Be Tried in Mali

Soil nutrient, texture and pH testing; Plant leaf analyses;

Page III-1


Pest-resistant/tolerant seed; Seed treatment with pesticides; Raised-bed planting technique; Soil sterilization using black plastic and sunlight; Follow seeding rate and thinning recommendations for certain vegetables; Soil moisture measurements and management via drip irrigation; Use of organic mulch; Use of plastic mulch; Use of organic fertilizers/soil structure amendments (manure, compost); Use of purchased mineral fertilizers; Combinations of organic and mineral fertilizers; Crop rotation with and use of green manure crops; Crop rotations among different families of vegetables; Early/late plantings/harvestings to avoid pests; Use of trap crops to trap and destroy pests; Weekly field scouting to assess pest levels/damage; Ability of farmers to identify pests correctly; Ability of farmers to identify predators, parasites, and pest diseases correctly; Pruning and sanitation of diseased plants; Do things to encourage predator/parasite build-up; Planting parasite-attracting plants on field margins; Mechanical weed control by hand hoe; Use of herbicides for weed control; Exclude insect pests by using vegetable tunnels and micro tunnels; Mechanical insect control by hand-picking larvae, pupae, or adults; Use of insecticides for insect control; Use of fungicides for control of fungus; Spot treatment of pest hotspots with insecticides, miticides, or fungicides; Use of pheromone traps to monitor moth levels; Use of pheromone inundation to confuse moth mating; Crop stalks and residue destruction at end of season; and Apply local plant extracts (neem, etc.) to kill pests.

FtF will investigate the use of additional GAP and IPM techniques that are not listed above. It will continue to follow international developments in IPM to find new techniques appropriate to the needs of Mali. FtF will encourage the use of non-chemical methods of control when they can be shown to be effective. FtF will also write GAP/IPM plans and/or technical sheets for each crop to be protected.

In addition: See Attachment 1 for General Mitigation Measures See Attachment 2 for General IPM Guidelines

Page III-2


ATTACHMENT 1: MITIGATING POTENTIAL PESTICIDE DANGERS

General measures to ensure safe useIf there are no feasible alternatives to pesticides, take the following measures to mitigate and reduce the risks to human health and the environment. Note that risk is a function of both toxicity and exposure. Reducing risk means (1) selecting less toxic pesticides and (2) selecting pesticides that will lead to the least human exposure before, during, and after use. The following protocols will be adopted, monitored, recorded and kept on file by FtF: Reducing exposure time or the degree of exposure

Before usingTransport:

Separate pesticides from other materials being transported.Packaging:

Follow international and national norms and guidelines; Use packaging (small containers) adapted to local needs; and Eliminate re-use of packaging materials.

Storing: Develop strict guidelines for village-level storage; Ensure permanent, well-marked labeling; Follow and respect national norms; and Use appropriate language and approved pictograms.

Formulating: Use appropriate type and concentration.

During useTraining:

Should be continuous; and Should identify level and audiences (distributors, farmers, transporters, etc.).

Use application equipment: Should be adapted to user needs and possibilities; and Should assure maintenance and availability of parts and service.

Use protective equipment and clothing: Should be adapted to local climatic conditions; Should be adapted to user needs and resource possibilities; and Should eliminate exposure rather than just reducing it, if at all possible.

Focus on “buffer zones” around the following: Housing; and Environment: water, sensitive areas – bee hives and foraging areas; bird and

mammalian habitats; aquatic (both freshwater and marine/estuarine) habitats

After using Know, enforce, respect exclusion or reentry periods after application; Assure proper cleaning and rinsing off of

– Applicators’ preparation and application equipment;– Applicators’ clothing; and storage containers;– Segregation of pesticide applicator laundry from other resident laundry

Develop a workable monitoring and evaluation system for:

Page III-3


– Adherence to national and international policies regarding pest management and pesticides;

– Health effects on applicators, the local population, and domestic animals;

– Efficacy on target pests;– Impact on the environment: above- and below-ground water, soils, air,

drift, biodiversity; and– Elimination of pesticide leftovers and containers (disposal).

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ATTACHMENT 2: GENERAL IPM PLANNING AND DESIGN PROTOCOL

An IPM program can be designed with all of the fundamental parts of any good management plan. The vital parts of a plan include a definition of the targeted primary (small or large-holder farmers) and secondary (marketers, processors, transporters, and consumers) beneficiaries, implementation partners (farmers, laborers, extension personnel, national, regional, and international organizations), listed production constraints (problem identification), and IPM strategies for dealing with them.

Elements of IPM ProgramSince IPM is not currently an active part of crop production practices in Mali, a basic understanding of the steps or elements needed in an IPM program is addressed below.

Step 1: Evaluate and use non-pesticide management options first.Use both preventive and responsive/curative options that are available to manage pest problems. Farmers may prevent pests (and avoid requiring pesticides) by the way they select plants, prepare the site, and plant and tend growing plants. Along with prevention, farmers may respond to or cure the problem via physical, mechanical, or biochemical methods.

General Preventive Interventions Plant selection

– Choose pest-resistant strains;– Choose proper locally adapted plant varieties;– Diversify plant varieties or inter-crop plants; and– Provide or leave habitat for natural enemies.

Site preparation and planting– Choose pest-free or pest-avoidance planting dates (e.g., early planting

in rainy season avoids stem borers);– Enhance/provide shade for shade-grown crops;– Assign crop-free (fallow) periods and/or rotate crops;– Install buffer zones of non-crop plants and/or physical barriers;– Improve soil health;– Use an appropriate planting density;– Rotate crops; and– Low-till, no-till.

Plant tending/cultivation practices– Fertilize and irrigate appropriately; and– Remove weeds while small and before sowing crop

Responsive/Curative Interventions Physical/mechanical control

– Remove or destroy diseased plant or plant parts and pests;– Weed; and– Install traps.

Biochemical control Pheromones (very effective, currently not easily accessible or economical,

but they arePage III-5


becoming more so); Homemade botanical pesticides; and Repellents.

Biological control Release or augment predators; Release or augment parasites/parasitoids; and Release or augment microbial pesticides.

Step 2: Assess IPM Needs and Establish Priorities.In planning an IPM project, consider crop protection needs, farmers’ perceptions of pest problems, pesticide use history and trends, availability of IPM technology, farming practices, access to sources of IPM expertise, support for IPM research and technical assistance, and training needs for farmers and project field extension workers.

Next, identify strategies and mechanisms for fostering the transfer of IPM technology under various institutional arrangements, mechanisms, and funding levels. Define what is available for immediate transfer and what may require rapid and inexpensive adaptation and validation research. During the planning stages of an IPM program, the inputs from experienced IPM specialists will be extremely useful. If possible, set up an initial planning workshop to help define and orient implementation activities and begin to assign individual responsibilities.

Step 3: Learn and value farmers’ indigenous IPM tactics, and link with and utilize all local resources/partners.Most farmers are already using their own forms of IPM, many of which are novel, self-created, adapted for local conditions, and work well. These include mechanical and physical exclusion; crop rotation, trap crops, cover crops, and green manures; local knowledge of strategic planting or harvesting times; water, soil, and fertilizer resource management; intensive intercropping with pest repellent plants; leaving refuge habitat for natural enemies; soil augmentation and care leading to healthy nutrient cycling; transplanting; and weeding.

Accurate assessments of these farmer technologies, as well as of actual losses due to different constraints in farmers’ fields are a must before designing a crop production and pest management program. Crop loss figures provided by small and large farmers alike and projected and reported by international organizations are often inaccurate and overestimated.

Step 4: Identify key pests for each target crop.Although hundreds of species of organisms can be found in a crop at any one time, only a few of them can cause substantial crop losses and are considered pests. Become familiar with the key pests of target crops, whether they are primary or secondary pests, and how to positively identify them.

Monitor their population size, the kind of damage that they cause, and their life cycle. These usually amount to a relatively small number of species on any one crop and can include any combination of insects, pathogens, weeds, diseases, and vertebrates. A few other species, known as secondary or occasional pests, attain

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damaging status from time to time, especially if over-spraying occurs and kills natural predators that naturally regulate their populations.

The vast majority of insect species found in any one crop are actually predators and parasites of the plant-feeding species. Many smallholder farmers are not aware of these distinctions and must be taught to identify the more common beneficial species, as well as pests, found in their crops.

Incorrect identification of beneficial insects, predators, or neutral insect species, may lead to unnecessary pesticide applications. This diagnostic phase requires sampling and careful observation. Usually, most key pests are fairly well known by local farmers and government extension personnel. However, a few species may be poorly known or understood because they occur at night, are hidden, or small. These include soil-inhabiting species such as nematodes and insect larvae (wireworms, white grubs, cutworms), mites, and pathogens (viruses, bacteria, mycoplasma, fungi). In addition, farmers usually do not understand the role of some insects as vectors of plant diseases.

Step 5: Do effective activities and training to promote IPM.Several activities are very effective in promoting IPM in developing countries:

Learning-by-doing/discovery training programs: Small- and large-holder farmers adopt new techniques most readily when they acquire knowledge and skills through personal experience, observation, analysis, experimentation, decision-making, and practice. First, trained instructors or extension agents should conduct frequent (usually weekly) sessions for 10 to 20 farmers during the cropping season in farmers’ fields. Because these IPM training sessions take place in the farmers’ own environment, they take advantage of the farmers’ own knowledge, and the farmers understand how IPM applies to their own farms.

Of these IPM training sessions, four or five analyze the agro-ecosystem. They identify and describe conditions such as soil type, fertility, and needs, weather, crop stage, each pest, their natural enemies, and relative numbers of both. Illustrations and drawings are provided, as necessary.

Extension workers apply the Socratic Method, guiding farmers with questions to discover important insights and supplying information only when absolutely necessary. Farmers may also experiment with insect zoos, where they can observe natural predators of their pests in action and the impact of pesticides on both. Knowledge and skills necessary for applying IPM are best learned and understood through practice and observation, understanding pest biology, parasitism, predation and alternate hosts; identifying plant disease symptoms; sampling population size; and preparing seed beds.

Recovering collective memory. Pest problems often emerge because traditional agricultural methods were changed or lost. These changes can sometimes be reversed. This approach uses group discussions to try to identify what changes might have prompted the current pest problem.

Smallholder support and discussion groups. Weekly meetings of smallholders, held during the cropping season, to discuss pest and related problems can be useful for

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sharing the success of various control methods. However, maintaining attendance is difficult except when there is a clear incentive.

Demonstration project. Subsidized experiments and field trials at selected farms can be very effective at promoting IPM within the local community. These pilots demonstrate IPM in action and allow comparison with traditional synthetic pesticide-supported cultivation.

Educational material. Basic written and photographic guides to pest identification and crop-specific management techniques are essential. Videos featuring graphic pictures of the effects of acute and chronic pesticide exposure, and interviews with poisoning victims can be particularly effective. A study in Nicaragua found videos to be the most important factor in motivating farmers to adopt IPM.

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.

Organic food market incentive. Promoting organic certification for access to the growing Malian organic or natural food market can be a strong incentive to adopt IPM.

Step 6: Partner successfully with other IPM implementers.Many IPM programs consist of partnerships between two or more organizations, e.g., MOA staff, local NGOs. If these partnerships are not forged with care, the entire project may be handicapped. 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 important that partners articulate a common, detailed vision of IPM, centered on the crops and conditions the program will encounter.

Confirm partner institutions’ commitment. Often, organizations make commitments they do not intend to (or are unable to) fulfill completely. 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 part of a larger “sustainable agriculture” project. The IPM program must fit into the overall program. The extent of this integration should be clearly expressed in the 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. Large partner organizations should have staff with expertise in IPM who are assigned specifically to IPM work. In strong partnerships, these staff members are actively involved in the partnership.

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Step 7: Monitor the fields regularly.The growth of pest populations usually is closely related to the stage of crop growth and weather conditions, but it is difficult to predict the severity of pest problems in advance. The crops must be inspected regularly to determine the levels of pests and natural enemies and crop damage. Current and forecast weather should be monitored. Farmers, survey personnel, and agricultural extension staff can assist with field inspections. They can train other farmers to be able to separate pests from non-pests and natural enemies, and to determine when crop protection measures, are necessary.

Step 8: Select an appropriate blend of IPM tools.A good IPM program draws from and integrates a variety of pest management techniques. IPM does not require predetermined numbers or combinations of techniques, nor is the inclusion or exclusion of any one technique required for IPM implementation. 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. When dealing with crops that are already being treated with pesticides, IPM should aim first at reducing the number of pesticide applications through the introduction of appropriate action thresholds, while promoting appropriate pesticide management and use practices and shifting to less toxic and more selective products and nonchemical control methods. In most cases, NGOs or farmers groups will probably need to deal with low to moderate levels of pesticide use. Either way, an IPM program should emphasize preventive measures and protect a crop, while interfering as little as possible with the production process.

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: Monitor and Evaluate.First, develop data collection tools, and then collect baseline data at the beginning of the project to identify and determine the levels of all variables that will need to be tracked. These may include numbers and types of pests, predators, and soil microorganisms; relative numbers of all non-target animals (birds, lizards, etc.) that may be negatively impacted if pesticides are used; soil and water samples to determine levels of pesticide residue; soil samples to learn dominant soil types and to predict soil nutrition, requirements, and fertilizer/pesticide activities; pesticides, application and safety equipment available; and, amounts and type of training received by target audiences.

Develop methods for measuring the effectiveness of each IPM tactic used, and of their sum in reducing pest damage and crop losses. Also, develop methods for monitoring environmental health (maintaining and encouraging high levels of predators and soil microorganisms) and human health if pesticides are used. Kits

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are available for determining the level of cholinesterase-inhibiting pesticides to which farmers and applicators have been exposed. Make checklists for farmers to use when applying pesticides that indicate the type of application and safety equipment used, and the rates at which pesticides were applied.

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Annex IV – FtF Pesticide and IPM Training Course Outline October 2014

ANNEX IV – TRAINING COURSE OUTLINESample FtF Pesticide Training Agenda (3-Day Program), Pesticide Risks, Safer Use and ComplianceA training-of-trainers workshop for the Feed the Future (FtF) Mali Program (Example from Liberia FED Program)

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Session Name Objectives/content summary

Offi cial Opening & Facil itator Introductions

Orientation

Assure a common understanding of course motivation and purpose: provide course participants, who are mainly supervisory field extensionists, with a basic understanding of the requirements of FED’s mandatory Pesticides Safer Use Action Plan (SUAP) and their roles and responsibil ities in implementing it; to provide the core knowledge and ski lls regarding pesticide risks and safer use for SUAP implementation, and to initiate planning for this implementation.

Participant Introductions, Workshop Expectations

a. Faci litator Introductions, Roles and Responsibi litiesb. Participant Introductionsc. Overview of Agenda: Tools and Techniquesd. Logistical Issuese. Setting Expectations

Pests, Pesticides and Pesticide Risks

Build common vocabulary and concepts by defining (1) pests and pesticides as USAID uses the terms; and (2) what USAID means by “support to pesticide procurement and use.” Survey the following pesticide risks and how they arise across Liberia's four primary ecological zones:• human health• non-target organisms/natural resources (incl. honeybee populations and other beneficial insects, bird populations, mammalian populations, aquatic vertebrates and invertebrates [freshwater and marine/estuarine], aquatic plants, and shallow ground water and/or ground water underlying permeable soils)• agricultural productivity through damage to soi ls, pest resistance, damage to crop-beneficial “good bugs"• accumulation of impacts to humans on sub-chronic (several months to several years) and chronic (many years) basis• differences in impacts across humans and non-target organisms

US EPA Registration Status; US & Int’l Hazard Categorization

Understand the fundamentals of EPA registration status and Int’l Hazard Categorizations.

Liberia Pesticide Regulations Pesticide use by FED must conform to both USAID (SUAP) and Liberian requirements. This session provides an overview of Liberia's pesticide regulations.

Pesticide Label Exercise Learn the practical skill of reading a pesticide label. Hands-on practice in reading labels from Liberia and neighboring West African countries.

Principles of Safer Use 1: Fundamentals of IPM

Establish the 3 elements of Safer Use:• IPM• Safe Handling (transport, storage, preparation, application, spil l prevention and cleanup, equipment and container cleanup, and disposal)• Safe Purchase (including cases where certain formulations of a pesticide are not allowed)Define IPM, establish USAID’s policy commitment to IPM, survey the basic principles of IPM and the basic elements of an IPM program.

Morning Block 1

Coffee Break

Morning Block 2

Day 1

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Principles of Safer Use 2: Safe Purchase & Handling

Survey the basic elements of good practice for pesticide purchase & handling (transport, storage, preparation, application and disposal). Explain the reasoning behind these practices.

Safe Handling Practicum (includes tea break) Hands-on exercises: practice in safe handling, including demonstration of Personal Protective Equipment (PPE), methods of application, and Restricted Entry Intervals (REI).

SUAP Overview Participants understand the requirements of SUAP compliance, and the extent of their responsibil ity for advancing IPM and the Pesticide Selection Criteria and Safe Use Practices enumerated by the SUAP when their control over activities on the ground is less than complete.

Lunch

Afternoon Block 1

Day 1 (continued)

Review of Day 1, Orientation to Day 2a. Day One Review/What have we learned?b. Review of Expectationsc. Day Two at a Glance

SUAP Overview (cont'd) as above

Getting famil iar with th FED project PERSUAP The PERSUAP contains a large amount of information and resources, particularly in its annexes. This session will familiarize participants with these resources and the structure of the document.

FED Key Pest Issues:A session focusing on best-practice field management of 1 or 2 key crop pests that affect FED crops in Liberia. Risks to certain proximate ecological receptors and natural resources (e.g., honeybees, beneficial insects, etc.) will also be addressed. Discussion of pre-harvest intervals (PHI) and plant-back intervals (PBI).

Field Reference Guide ExerciseWorking in groups develop a draft Field Reference Guide/Poster. (Groups will choose crops and production region; each group to develop their own Field Reference Guide/Poster.)

Field Reference Guide report-out

Pesticide First Aid Become fami l iar with symptoms of pesticide poisoning and basic fi rst a id for pesticide exposure.

Managing Pesticide Spills Learn the basic principles and procedures of managing pesticide spi l ls .

SUAP Implementation PlanningUsing a SUAP implentation planning form, participants work individual ly to assess current s tatus of pest management/pesticide use within their activities against each of the key SUAP elements, suggest an approach or series of actions to achieve compl iance, and for these actions specify a timel ine and budget.

Field Visit Briefing

Coffee Break

Morning Block 1

Coffee Break

Morning Block 2

Lunch

Afternoon Block 1

Day 2

Afternoon Block 2

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Field VisitsObjectives TBD depending on sites selected. However, suggest that the site visit be approached by the participants as an "audit" of safer pesticide use: the objective is to find out as much as possible regarding pest management practices and pesticide use at the sites visited, covering as many of the key elements of safer use as possible.

Field Visit Follow-upField visit teams wil l report-out on their field visit observations. Wil l be structured according to the field visit objectives. E.g. participants could report-out on their observations regarding each key element of safer use.

Safer Use Communications Skil ls

Participants wi l l serve as points of contact for pesticide i ssues and leads for SUAP implementation. In the course of these duties , there wi l l be many occas ions when they are requi red to del iver briefi ngs or short-format trainings to col leagues and potential ly benefi ciaries . This session wi l l expose participants to a few basic faci l i tation/presentation/training principles, and each member of the training team wil l present a short topic from earl ier in the workshop to demonstrate different faci l i tation styles and techniques .

Final Q&A & Way Forward discussion Resolve questions remaining in the "parking lot;" open discussion between participants; USAID, and training team regarding the "way forward" for SUAP implementation.

Evaluations Fill in individual evaluation forms

Closing & Certificates.

Lunch

Afternoon Block 1

Coffee Break

Afternoon Block 2

Morning Block 1

Day 3

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Annex V – FtF Illustrative List of Trees and Fodder for Global Climate Change October 2014

ANNEX V – ILLUSTRATIVE LIST OF TREES AND FODDER FOR GLOBAL CLIMATE CHANGE Illustrative List of Trees and Fodder for Global Climate ChangeScientific name Main utilityGliricidia sepium fertilizer and fodder treeAcacia colei colei fertilizer treeAcacia nilotica fertilizer treeAcacia senegal fertilizer treeAcacia torulosa fertilizer treeAlbizia lebeck fertilizer treeCasia sieberiana fertilizer treeCenna spectablis fertilizer treeFaidherbia albida fertilizer treeTitonia diverstolia fertilizer tree Prosopis africana fertilizer and fodder treeSaba senegalensis fodder and fruit treeTerminalia africana fodder and fuel woodBauhinia rufecens fodder and life fence Afzelia africana fodder treeBalanites aegyptiaca fodder treeComiphora africana fodder treeFicus gnaphalocarpa fodder treeGuiera senegalensis fodder treeKhaya senegalensis fodder treeKigelia africana fodder treeLeucaena leococephala fodder treePterocarpus erinaceous fodder treePterocarpus lucens fodder treePterocarpus santalinoides fodder tree Adansonia digitata fruit and leafy tree Ziziphus micronata fruit and life fenceAnacardium occidentale fruit tree Annona squamosa fruit tree Detarium microcarpum fruit tree Diosphuros militiformis fruit tree Lanea microcarpa fruit tree

Page V-1

Annex V – FtF Illustrative List of Trees and Fodder for Global Climate Change October 2014

Manguifera indica fruit tree Parkia biglobosa fruit tree Sclerocarya birea fruit tree Tamarindus indica fruit tree Vitellaria paradoxa fruit tree Ziziphus mauritiana fruit tree Terminalia mantali fuelwoodMoringa oleifera leafy treeAcacia seyal life fenceJatropha curcas life fence and biofuelLawsonia inermis life fence and dyeing

Page V-2

Annex VI – IPM/IVM Preventive and Curative Tools and Tactics for Livestock October 2014

ANNEX VI – IPM/IVM PREVENTIVE AND CURATIVE TOOLS AND TACTICS FOR LIVESTOCK34 Livestock: Cattle, Sheep, Goats

Pest Species Preventive Tool and Tactics Curative ToolsTsetse flies (Glossina species)

Savannah and Riverine species

Tsetse flies transmit trypanosomes to livestock

Use, on an area-wide basis, odor baited traps and targets with insecticide to attract and kill savannah tsetse.

Use, on an area-wide basis, specially colored traps with insecticides to attract and kill savannah tsetse.

If available, the Sterile Insect Technique (SIT) can be used on an area-wide basis to reduce tsetse fly populations significantly.

Use fly repellents if the technology becomes available in Mali.

Use indigenous plant extracts to repel flies.

Rotate among pour-on formulations of insecticides containing deltamethrin, or spray-on formulations containing amitraz.

Inject anti-trypanosome drugs.

Cattle tick (Boophilus microplus) and other ticks

Ticks transmit several diseases to livestock

Use tick resistant cattle breeds. Use clean syringes if blood entry or

transfer occurs. Check animals routinely for ticks and

remove ticks by hand. Some local aromatic shrubs provide

extracts that can be used as tick repellents.

Preventive vaccination of cattle against tick-borne diseases.

Treat cattle with pour-on acaricides containing deltamethrin every 21 days.

34 From Resilience and Economic Growth in the Arid Lands-Accelerated Growth (REGAL-AG) PERSUAP, Annex 1, USAID/Kenya, ACDI/VOCA, December 2013.

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Brush removal and mowing the vegetation next to wooded areas.

Rotate livestock away from the pastures that are heavily infested with ticks.

Sanitation: Where animals are concentrated in night corrals, clean up and remove all weeds and animal waste.

Mange mites (Demodex and Sarcoptes species)

Don’t over-crowd animals. Provide animals with sufficient space, so they are not in close contact with each other.

Use indigenous knowledge and saltpan dips and washes to reduce mites.

Use indigenous plant extracts to reduce mites.

Use of miticides is rarely justified. However if desired, pour-on formulations containing deltamethrin, or amitraz used against ticks and flies will reduce mite populations.

Biting flies/TabanidsStable fly (Stomoxys calcitrans)

Some biting flies transmit trypanosomes to livestock

Eliminate development sites such as decomposing vegetation.

Sanitation: Clean up and remove all fresh animal manure and manure pats.

If compost piles of manure are maintained for horticultural use, put fresh grass clippings into them and turn them regularly to disrupt face fly breeding.

Use indigenous plant extracts to repel flies.

Chemical control is not usually cost-effective, as animals would need to be treated every other day with a pesticide like deltamethrin.

Face flies (Musca Sanitation: Clean up and remove all fresh Use of ear tags impregnated

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autumnalis) animal manure and manure pats. Find where the face flies aestivate

(usually in cracks and other spaces somewhere on the south or west sides of buildings warmed by dry season sun) and treat them there.

with synthetic insecticides like amitraz, and formulations containing deltamethrin.

Cattle screwworm (Cochliomya hominivorax)

Reduce any injuries to the livestock hides, skin or horns.

Monitor livestock daily for wounds or fly larvae.

Remove fly larvae manually.

Use pour-on formulations of insecticides containing deltamethrin or amitraz.

Brucelosis (Brucella abortus)

Use vaccination. Use great care so that this zoonotic

disease is not transmitted to people.

No disinfectants are recommended.

Mastitis bacteria (Streptococcus and Staphilococcus species)

Maintain clean technique when milking. Clean milking equipment daily.

Treat animal teats with a solution of chlorine or iodine and lanoline.

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Annex VII – Legislation on Pesticide Management in Mali (French Version) Ocotber 2014

ANNEX VII – LEGISLATIION ON PESTICIDE MANAGEMENT IN MALI (FRENCH VERSION) Dispositif juridique et institutionnel de la gestion des pesticides au Mali

Instrument Juridique (Type,

Référence, Année)Ministères ou Organisations

chargés de l’applicationCatégories de Produits Chimiques concernés

Objectifs de la Législation Principales Dispositions

Loi N°01-020 relative aux pollutions et aux nuisances

Ministère de l’Environnement et AssainissementMinistère de la SantéMinistère de l’AgricultureMinistère de l’Industrie et du Commerce

- Résidus de pesticides- Produits industriels, miniers,

artisanaux ou tout autre produit toxique

- Produit vétérinaire- Déchets dangereux

Protection de l’environnement et de la santé humaine.Protection de la santé animale

Chapitre X sur les substances chimiques : fixant les conditions d’importation, d’utilisation, de détention, de reconditionnement et de stockage des substances chimiques. et vétérinaires.

Loi N°02 – 014 du 03 JUIN 2002 instituant l’homologation et le contrôle des pesticides en République du Mali


Tous pesticides Protection de la santé humaine et de l’environnement

Chapitre V : de la constatation des infractions

Loi N°89-61/ANRM de la 02/09/89 portante répression de l’importation et du transit des produits toxiques


- Résidus de pesticides- Déchets résultant des

activités industrielles, artisanales, commerciales, agricoles ou scientifiques

- Produits pharmaceutiques

Protection de la santé humaine et de l’environnement

Tout déchet présentant un danger pour la santé et l’environnement (Art.1)Interdiction (Art.2, 3)Amende pour tout contrevenant (Art.4)Arrêté interministériel n°97-0276/MSSPA-MFC-SG du 13 mars 1993 fixant la liste des matières premières entrant dans la fabrication des médicaments en DCI

La Loi 86-64/AN RM du 26 juillet 1996 portant autorisation de l’exercice à titre

Ministère de l’Environnement et AssainissementMinistère de la SantéMinistère de l’Agriculture

Médicaments vétérinaires et vaccinsPesticides utilisés en santé animale

Protection de la santé animale

Arrêté interministérielle N° 96/1367 MDRE-MFE-MATS-MJGS relatif aux conditions d’attribution,

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privé de la profession vétérinaire.

Ministère de l’Industrie et du Commerce

d’exécution et de retrait du mandat sanitaire

La Loi 85-41/AN-RM du 22 Juin 1982 portant autorisation de l’exercice privé des professions sanitaires


Produits pharmaceutiquesProduits agro-pharmaceutiques


Arrêté N° 91-4318 MSP-AS-PF/CAB du 3 octobre 1991 fixant les modalités d’organisation de l’exercice privé des professions sanitaires dans le secteur pharmaceutique et d’opticiens, lunetiers- Fixe la liste des

substances des tableaux A, B et C prescrit par un chirurgien dentiste

- La liste des médicaments et accessoires pour dépôt de produits pharmaceutiques

- Les pratiques de bon stockage

Loi N°90-17/ANRM fixant le régime des eaux


- Barrages- Eaux courantes et souterraines- Puits, etc.

Protection, Utilisation, Développement et Conservation des Ressources en Eau

Toute activité de recherche, transport, stockage, utilisation et rejet des eaux doit être faite de manière à préserver le milieu naturel et la qualité de l’eau (Art.20)Interdiction de déverser les rejets, quelle que soit leur nature (Art.21)

Loi N°92-013/ANRM portant institution d’un Système National de

Ministère de l’Environnement et AssainissementMinistère de la SantéMinistère de l’Agriculture

- Tout produit de consommation et- Tout rejet en relation avec le cadre de vie et l’environnement

Elaboration des normes nationales à mettre à la disposition des producteurs et des

Les normes sont obligatoires lorsque des raisons d’ordre public, de sécurité publique, de

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Normalisation et de Contrôle de Qualité

Ministère de l’Industrie et du Commerce

consommateurs protection de la santé et de la vie des personnes ou de la protection de l’environnement sont en jeuMener toute action de promotion de la qualité

Décret N°02-306/P-RM du 03 JUIN 2002 fixant les modalités d’application de la loi instituant l’homologation et le contrôle des pesticides en République du Mali


Tous pesticides Protection de la santé humaine et environnement

Mise en place d’un comité National de Gestion des pesticides (CNGP)

Décret N° 01- 397 /P-RM du 06 SEP.2001 fixant les modalités de gestion des polluants de l’atmosphère.




- Produits vétérinaires- Déchets dangereux


Chapitre V sur les dispositions finales

Décret N° 01 394 / P-RM 06 SEP 2001 fixant les modalités de gestion des déchets solides




- Produits vétérinaires- Déchets dangereux


Chapitre V sur les dispositions spécifiques aux déchets dangereux

Chapitre VI sur l’importation, l’exportation et le transit des déchets non dangereux

Décret N°01-395/P-RM du 06SEP.2001 fixant les modalités

Ministère de l’Environnement et AssainissementMinistère de la Santé


artisanaux ou tout autre

Protection de l’environnement et de la santé humaine.

Chapitre V sur la construction et l’exploitation des installations de

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de gestion des eaux usées et des boues

Ministère de l’AgricultureMinistère de l’Industrie et du Commerce

produit toxique- Produits vétérinaires- Déchets dangereux

Protection de la santé animale

traitement des eaux usées et des boues

Décret N°90-355/PRM portant fixation de la liste des déchets toxiques et les modalités d’application de la Loi N°89-61/ANRM


Tout produit chimique pouvant sécréter des résidus à des doses dépassant le seuil de toléranceProduit vétérinaire

Protection de l’environnementProtection de la santé animale

Toute demande d’importation de produits chimiques doit comporter des renseignements sur la toxicité (Art.3)

Le Décret n°66/ PG-RM du 11 mars 1985 fixant nomenclature des médicaments essentiels


Tout produit chimique fabriqué ou importé au Mali, ainsi que les résidus


Arrêté interministériel N° 97 0276 MSSPA-MFC-SG du 13 mars 1997 fixant la liste des matières premières importées entrant dans la fabrication des médicaments en dénomination commune internationale

Décret N°92-235/PRM portant organisation et modalités de fonctionnement d’un Système National de Normalisation et de Contrôle de Qualité


Tout produit chimique importé ou fabriqué au Mali, ainsi que les résidus

Meilleure protection des opérateurs et des consommateurs

Tous les domaines d’activité sont concernés par les normes,Mener toute action de promotion de la qualité

Arrêté interministériel N°2708/MEATEU -MEF-MICT portant réglementation de l’importation et de l’utilisation des substances qui


Tout produit à base de CFC et/ou équipement contenant ces substances.

Protection de la santé humaine et environnement

Articles 1 et 2 du présent arrêté

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appauvrissent la couche d’ozone ainsi que des produits et équipements contenant ces substances.Arrêté N°269MICT-SG fixant la liste des produits prohibés à l’importation et à l’exportation


Tous les POPS; les CFC Protection de la santé humaine et de l’environnement

Les prohibitions à titre absolu et /ou à titre restrictif

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