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US Agency for International Development (USAID)USAID/Georgia

Amendment to Initial Environmental Examination (IEE)

Program/Project/Activity Data

Activity/Project Name: Restoring Efficiency to Agriculture Production (REAP)The Zrda

Assistance Objective: Economic GrowthProgram Area:Country(ies) and/or Operating Unit: GeorgiaOriginating Office: Economic Growth Date: September 22, 2017

PAD Level IEE: Yes NoSupplemental IEE: Yes NoRCE/IEE Amendment: Yes No

DCN of Original RCE/IEE:

REAPDCN: 2013-GEO-010ZrdaDCN: 2015-GEO-034

DCN of Amendment(s):

REAPDCN: 2013-GEO-010DCN: 2014-GEO-019DCN: 2014-GEO-027DCN: 2017-GEO-004ZrdaDCN: 2017-GEO-017

If Yes, Purpose of Amendment (AMD):Request for approval of the 2017 Pesticide Evaluation Reports and Safe Use Action Plan (PERSUAP) and the analysis of the updated list of pesticides.

DCN(s) of All Related EA/IEE/RCE/ER(s): PERSUAP: DCN: 2015-GEO-033Implementation Start/End: LOP: FY 2013-FY 2021Funding Amount: LOP Amount: $42,000,000

Contract/Award Number (if known): Reap: AID-114-C-13-00002Zrda: AID-114-A-16-00004

Recommended Environmental Determination:Categorical Exclusion: Positive Determination: Negative Determination: Deferral:

Additional Elements:Conditions: Local Procurement: Government to Government: Donor Co-Funded:

1. Purpose of Amendment1.1. Purpose of Amendment is the approval of the 2017 PERSUAP for REAP and Zrda projects.

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1.2. All conditions of the original IEEs and amendments remain in effect. With this Amendment, all existing reporting requirements shall remain in place.

1.3. The goal of the Restoring Efficiency to Agriculture Production (REAP) activity is to enhance the ability of the agriculture sector to stimulate inclusive, sustainable economic growth in Georgia through increased incomes and employment.

The REAP Activity will make grants and technical assistance (TA) available to existing and newly-formed private enterprises in the agriculture sector, including input suppliers, machinery service providers, storage facilities, sorting/grading centers, and small- and medium-scale processors. Grants and TA may also be provided to primary production businesses, cooperatives, or associations. Grant applicants meeting certain criteria will be provided with TA to develop viable business plans, and selected applicants will receive matching grants and additional TA to implement their business plans. Additional TA will be provided to farmers and non-grantee SMEs to improve technical and business skills and facilitate improved linkages between input suppliers, farmers, valueadding enterprises, and end markets (both domestic and international).

The goal of the Zrda (Zrda means growth in the Georgian language) activity is to promote inclusive and sustainable economic growth in targeted regions. The activity purpose is to improve livelihoods and resilience in targeted communities in Georgia. The activity’s sub-purposes are to: a) improve Micro – Small – and Medium –sized Enterprise (MSME) development and growth, b) increase productivity of rural households, c) facilitate market linkages between producers and buyers, and d) promote local economic development by establishing networks. The program will work at the national level to integrate rural communities with economic networks and is required to work with a minimum of 50 communities in areas that are either 1) in proximity to the administrative boundary lines with Abkhazia and South Ossetia, or 2) have ethnically or religiously diverse or marginalized populations. Cross-cutting objectives include: a) assisting economic actors to adapt to changes in laws and standards related to Georgia’s Deep and Comprehensive Free Trade Area (DCFTA) with the European Union; and b) promoting gender equity and opportunities for youth. The methodology of identification of the products, sectors, municipalities

The purpose of this document is to conduct an amendment (to 2017) Pesticide Evaluation Report (PER) and Safe Use and Action Plan (SUAP) to bring USAID-funded projects into compliance with USAID’s environmental regulations (Title 22 of the Code of Federal Regulations (CFR), part 216, or Regulation 216.3) on pesticide use, as well as its 1990 Policy on use of Integrated Pest Management (IPM). It is an update of the last PERSUAPs written for Georgia in 2015, and now applies to all the current agriculture projects for Georgia.

1.4. This project is currently in compliance.

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2017 GEORGIA AGRICULTURE SECTOR PERSUAP APPROVALS PAGE

Approval: _______________________________________ Date: __________USAID/Georgia Mission Director, Douglas Ball

Approval: _______________________________________ Date: __________USAID/Georgia MEO, Gocha Lobzhanidze

Approval: _______________________________________ Date: __________USAID/Georgia A/COR, Shamenna Gall

Concurrence: _______________________________________ Date: _9/22/2017____USAID E&E BEO, Mark Kamiya

Distribution: IEE files Mission Environment Officer (MEO) Administrative/Contracting Officer’s Representative (A/COR) E&E Bureau Environmental Officer (BEO) Restoring Efficiency to Agriculture Production (REAP) Other 2017 Georgia Economic Growth and Agriculture Projects

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INITIAL ENVIRONMENTAL EXAMINATIONPESTICIDE EVALUATION REPORT AND SAFE USE AND ACTION PLANUSAID/GEORGIA RESTORING EFFICIENCY TO AGRICULTURAL PRODUCTION

PER

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May 6, 2023 This publication was produced for review by the United States Agency for International Development. It was prepared by CNFA.

INITIAL ENVIRONMENTAL EXAMINATION PESTICIDE EVALUATION REPORT AND SAFE USE AND ACTION PLANRESTORING EFFICIENCY TO AGRICULTURAL PRODUCTION (REAP)CONTRACT NUMBER: AID-114-C-13-00002CNFA USAID/GEORGIASEPTEMBER 22, 2017

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DISCLAIMER

The author’s views expressed in this publication do not necessarily reflect the views of the United States Agency for International Development or the United States Government.

2017 Updated Georgia CNFA Programmatic PERSUAP(Pesticide Evaluation Report and Safe Use Action Plan)

Covering Georgia Crops:

Cereals/Small Grains: Wheat/Winter Wheat, Barley/Winter Barley, Rye, Oats, Triticale,Corn/Maize, and Sorghum

Cole Crops/Crucifers/Brassicas and Lettuces: Cabbages, Cauliflower, Brussels sprouts, Broccoli, Mustards, Turnips, Radish, Lettuces

Solanaceous Crops: Tomato, Potato, Peppers/Paprika, and EggplantAlliums: Onions, Garlic, Leeks, Chives, and Shallots

Cucurbits: Cucumbers, Squashes, Pumpkins, Melons, and WatermelonUmbelliferous Crops: Carrots, Parsnip, Celery, Fennel, Parsley, Coriander, Cilantro, and Chervil

Grape Vines: Wine grapes, Table grapes, and Raisin grapesPome Fruits: Apple, Pear, Loquat, and Quince

Stone Fruits: Apricot, Peach, Plum, Prune, Cherry, and AlmondCitrus: Lemons, Mandarins

Specialty fruits: Kiwi, FeijoaOil and Seed Crops: Sunflower, Safflower, and Sesame

Forage Legumes: Alfalfa/Lucerne, Clovers, Vetches, and TrefoilsTree Nuts: Walnut and Hazelnut

Berries: Blueberries, Greenhouse StrawberriesBeets (fodder and sugar)

Oil Crop: Rape Seed/Canola

2017

Drafted by:

Alan Schroeder, PhD, MBASocial and Agricultural EntrepreneurEnvironmental Compliance Specialist

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E-NoeTec ConsultingUSA: 703-859-1676

Belgium: 32-32-47-850-5584e-mail: alanschroeder99@gmail.com

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ACRONYMS

AI Active Ingredient (when pesticide reference)A/COR Administrative/Contracting Officer’s RepresentativeBMP Best Management PracticeBT Bacillus thuringiensis (a bacterium that produces a toxin used as a pesticide)BRC British Retail ConsortiumCAR Central Asian RepublicsCFR Code of Federal RegulationsCIS Commonwealth of Independent StatesCITES Convention on International Trade in Endangered Species of Wild Fauna & Flora CNFA Citizen’s Network for Foreign AgricultureCOP Chief of PartyDCN Document Control Number (USAID Environmental Compliance)DS Powders for dry seed treatment (pesticide formulation)E&E Europe and Eurasia Bureau (USAID)EA Environmental AssessmentEC Emulsifiable Concentrate (pesticide formulation)EC50 Effective Concentration 50 (acute toxicity measure)EDD Environmental Due DiligenceEMMP Environmental Mitigation & Monitoring Plan EPA US Environmental Protection Agency (also known as USEPA)EU European UnionF2F Farmer to Farmer (USAID/Georgia Project)FAO Food and Agriculture Organization (United Nations)FSC Farm Service CenterFDA Food and Drug Administration (US)FIFRA Federal Insecticide, Fungicide and Rodenticide ActFS Flowable concentrate for Seed treatment (pesticide formulation)GAP Good Agriculture PracticeGAPI Georgia Agricultural Policy Initiative (USAID/Georgia Project)GDP Gross Domestic ProductGEF Global Environmental Facility (part of UNEP)GEL Georgian Lari (Georgia’s currency)GlobalGAP Global Good Agriculture Practices, a certification systemGMO Genetically Modified OrganismGUP General Use PesticideHa hectaresHT Highly ToxicID IdentificationIEE Initial Environmental ExaminationIGR Insect Growth RegulatorIPM Integrated Pest ManagementIVM Integrated Vector ManagementIWM Integrated Weed Managementkm kilometersLC50 Lethal Concentration 50 (acute toxicity measure)LD50 Lethal Dose 50 (acute toxicity measure)M&E Monitoring and Evaluation

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MD Micro Dispersion (pesticide formulation)MEO Mission Environmental OfficerMOA Ministry of AgricultureMRL Maximum/Minimum Residue Level/LimitMSDS Material Safety Data Sheetmsl meters above sea levelMT Moderately ToxicNAT Not Acutely ToxicNCAT National Center for Appropriate TechnologyNEO New Economic Opportunities Initiative (USAID/Georgia Project)NEPA National Environmental Policy Act (US)NIFA National Institute of Food and Agriculture (US)PEA Programmatic Environmental AssessmentPER Pesticide Evaluation ReportPERSUAP Pesticide Evaluation Report and Safe Use Action PlanpH log of Hydrogen concentration, measure of acidityPHI Pre-Harvest IntervalPIC Prior Informed Consent (a treaty, relates to toxic pesticides)POPs Persistent Organic Pollutants (a treaty, relates to toxic persistent pesticides)PMP Pest Management PlanPNT Practically Non-ToxicPPE Personal Protection EquipmentR&D toxin Reproductive and Developmental toxinREA Regional Environmental AdvisorREAP Restoring Efficiency to Agriculture ProductionREI Re-Entry Interval (safety period after pesticide spraying)RUP Restricted Use PesticideS&C Standards and CertificationSC Suspension Concentrate (pesticide formulation)SEAS Strengthening Extension and Advisory Services (USAID/Georgia Project)SME Small and Medium EnterpriseSPU safe pesticide useST Slightly ToxicSUAP Safe Use Action PlanUC University of CaliforniaUN United NationsUNDP UN Development ProgramUNEP UN Environment Program USAID United States Agency for International DevelopmentUSDA United States Department of AgricultureUSEPA US Environmental Protection Agency (also known as EPA)VHT Very Highly ToxicWFP World Food Program (UN)WHO World Health OrganizationWP Wettable Powder (pesticide formulation)WS Water dispersible powder for Slurry treatment (pesticide formulation)

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TABLE OF CONTENTS

Table of ContentsACRONYMS...................................................................................................................................6EXECUTIVE SUMMARY...........................................................................................................11PERSUAP FINDINGS, RECOMMENDATIONS AND CONDITIONS FOR MITIGATION...13PRIMARY RESULTS OF PESTICIDES PROPOSED FOR PERSUAP ANALYSIS: APPROVED PESTICIDES...........................................................................................................14POLICY RECOMMENDATIONS...............................................................................................19RECOMMENDATIONS TO USAID PROJECTS TO MITIGATE PESTICIDE RISKS...........19HOW TO USE THE PERSUAP EFFICIENTLY.........................................................................20UPDATE THE REPORT ANNUALLY AND AMEND THE REPORT IN TWO YEARS (2019).......................................................................................................................................................20SECTION 1: INTRODUCTION.............................................................................................221.1 Purpose, Scope & Orientation...........................................................................................221.2 Regulation 216...................................................................................................................221.3 The Pesticide Evaluation Report and Safe Use Action Plan (PERSUAP)........................231.4 Integrated Pest Management—USAID Policy..................................................................231.5 USAID/Georgia Agriculture Sector PERSUAP Methodology.........................................24SECTION 2: BACKGROUND.....................................................................................................252.1 Country Background..........................................................................................................252.2 Georgia Agriculture Projects Background.........................................................................262.3 Georgia International Obligations Related to Pesticides...................................................272.4 Georgia Pesticide Regulations...........................................................................................282.5 Pesticide Use Sectors in Georgia Agriculture Sector........................................................292.6 Evaluation of Georgia Pesticide Risks near Project Sites.................................................312.7 Climate Change and Georgia Climate Smart Agriculture.................................................332.8 Good Agriculture Practices and IPM for Georgia Project Crops......................................34SECTION 3: PESTICIDE EVALUATION REPORT..................................................................353.1 Factor A: USEPA registration status of the proposed pesticide........................................353.2 Factor B: Basis for Selection of Pesticides........................................................................373.3 Factor C: Extent to which the proposed pesticide use is, or could be, part of an IPM program..........................................................................................................................................383.4 Factor D: Proposed method or methods of application, including the availability of application and safety equipment..................................................................................................393.5 Factor E: Any acute and long-term toxicological hazards, either human or environmental, associated with the proposed use, and measures available to minimize such hazards..................413.6 Factor F: Effectiveness of the requested pesticide for the proposed use...........................443.7 Factor G: Compatibility of the proposed pesticide use with target and non-target ecosystems.....................................................................................................................................453.8 Factor H: Conditions under which the pesticide is to be used, including climate, geography, hydrology, and soils....................................................................................................473.9 Factor I: Availability of other pesticides or non-chemical control methods.....................51

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3.10 Factor J: Host country’s ability to regulate or control the distribution, storage, use, and disposal of the requested pesticide................................................................................................523.11 Factor K: Provision for training of users and applicators..................................................53

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3.12 Factor L: Provision made for monitoring the use and effectiveness of each pesticide.....534.1 Introduction to SUAP........................................................................................................564.2 USAID/Georgia Pesticides Requested for Analysis..........................................................564.3 USAID requirement...........................................................................................................564.4 Compliance Requirements (Safe Use Measures)..............................................................56Introduction to Annex 1, Integrated Pest Management Matrix: Concept, Methods, Information, Errors and Refinement...................................................................................................................58Annex 1: Integrated Pest Management Matrix..............................................................................60Annex 2: Guidelines for PMPs for Georgia Crops and Beneficiaries & Elements of IPM Program.......................................................................................................................................................85

What is a PMP.......................................................................................................................85Annex 3: Elements of IPM Program.............................................................................................88Annex 4: Acute Toxicity of Pesticides: EPA and WHO Classifications.......................................91Annex 5a: Analyses of Active Ingredients in Pesticides Registered in Georgia and Approved by this PERSUAP...............................................................................................................................93Annex 5b: Compilation of Pesticide AIs and Georgia Registered Products Containing Them and Approved by this PERSUAP.........................................................................................................99Annex 6: Training Topics and Safe Pesticide Use Web Resources............................................103Annex 7: Farm Record Keeping Form Examples for Pest Management with Pesticides...........105Agricultural pesticide application details....................................................................................105Annex 8: Form for projects to monitor farmer best practices including GAP, IPM including pesticide options..........................................................................................................................106Annex 9: Form for projects to monitor risk reduction success and use of BMPs on Projects and report to USAID/Georgia............................................................................................................107Annex 10: PERSUAP References...............................................................................................111Annex 11: Summary of Pesticide AIs Registered in Georgia and Rejected by this PERSUAP Analysis.......................................................................................................................................112

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ACKNOWLEDGEMENTS

The USAID funded, CNFA implemented Georgia REAP project staff members were invaluable for arranging and accompanying Dr. Schroeder on missions to the field in Georgia to meet farm managers, farmers, farmer’s fields, agriculture input importers/distributors and farm input retail stores. Dr. Schroeder especially appreciates that assistance of CNFA home office experts for backstopping all the logistical needs. Many REAP staff members assisted the team while it was in Georgia, and their efforts are highly appreciated as the mission flowed along smoothly from day to day. Special appreciation is reserved for Dr. Nino Inasaridze for her contributions to this report.

USAID Project Manager, Office of Economic Growth David Tsiklauri and Mission Environmental Officer Gocha Lobzhanidze provided essential USAID support and Georgia context for the study and recommended important contact persons for interview by the team. Farm Service Center owners and staff were helpful in giving tours of their stores, and numerous farmers and farm managers were kind to let us tour their farms and answer our questions.

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EXECUTIVE SUMMARY

Purpose

The purpose of this document is to conduct an updated Pesticide Evaluation Report (PER) and Safe Use Action Plan (SUAP) to bring USAID/Georgia-funded projects into compliance with USAID’s environmental regulations (Title 22 of the Code of Federal Regulations (CFR), part 216, or Regulation 216.3) on pesticide use. Beyond compliance, this document offers a selection of best practices and pest prevention tools to help ensure that projects can use as a base for adapting and adoption, with their own local best practices and pest monitoring levels. If a project desires to promote or use a pesticide rejected by this PERSUAP analysis, it will be required to perform a Scoping Statement and Environmental Assessment (SS/EA) to evaluate, in detail, the potential environmental and human health impacts of the use of those chemicals, as well as how to reduce those risks. USAID must approve the SS/EA prior to use of such pesticide(s) being evaluated.

This 2017 Georgia PERSUAP was developed for and under the direction of CNFA’s Restoring Efficiency to Agriculture Production (REAP) Activity. It is an update of the last three PERSUAPs written/approved for Georgia in 2011, 2013, 2015 and now applies to all the current or forthcoming (until 2019) economic growth and agriculture projects for Georgia. This ‘programmatic’ approach was used to economize resources such that each USAID project would not need to duplicate costs to produce their own PERSUAP report. Moreover, the objective is to have one document, which can guide and inform the work of the Administrative/Contracting Officer’s Representatives (A/CORs) and the Mission Environmental Officer (MEO) where pest management and pesticides are, or could be, involved in any project in Georgia.

Risks

Risks are inevitably present with the use of pesticides used for agricultural crop production. In addition to required compliance, this PERSUAP provides project implementers with the most common risks discovered and likely to be encountered. Projects can then use these risks to inform and guide their own development of environmental risk monitoring, mitigation and reporting plan (EMMP), as USAID requires. Annexes 8 and 9 of this document provides forms for projects to use and adapt for monitoring farmer activities and for tracking mitigation success as well as a basic Environmental Mitigation and Monitoring Plan (EMMP) for adapting and use by USAID/Georgia projects.

2017 Georgia PERSUAP target crops

The following crops currently or potentially supported in the future by USAID were included in previous PERSUAPs. There are no updates to this list in 2017.

Cereals/Small Grains: Wheat/Winter Wheat, Barley/Winter Barley, Rye, Oats, Triticale Corn/Maize, Sorghum Cole Crops/Crucifers/Brassicas and Lettuces: Cabbages, Cauliflower, Brussels Sprouts, Broccoli,

Mustards, Turnips, Radish, Lettuces Solanaceous Crops: Tomato, Potato, Peppers/Paprika, and Eggplant Alliums: Onions, Garlic, Leeks, Chives, and Shallots Cucurbits: Cucumbers, Squashes, Pumpkins, Melons, and Watermelon Umbelliferous Crops: Carrots, Parsnip, Celery/Celeriac, Fennel, Parsley, Coriander, Cilantro, and

Chervil

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Grape vines: Wine grapes, Table grapes, and Raisin grapes Fruit Trees: Pomes Fruits: Apple, Pear, Loquat, Quince, and Stone Fruits: Apricot, Peach, Plum,

Prune, Cherry, Almond Citrus: Lemons, Mandarins Specialty fruits: Kiwi, Feijoa Oil and Seed Crops: Sunflower, Safflower, and Sesame Forage legumes: Alfalfa/Lucerne, Clovers, Vetches, Trefoils Tree Nuts: Walnut, Hazelnut Berries: Blueberries, Greenhouse Strawberries Beets (fodder and sugar) Oil Crop: Rape Seed/Canola

Pesticides

For the purposes of this PERSUAP, the word pesticide is used, following EPA’s guidelines1, for the following: fumigants, insecticides, miticides/acaricides, nematicides, molluscicides, fungicides, antimicrobials, bactericides/biocides, microbicides/antibiotics, herbicides, rodenticides, avicides, algicides, ovicides (kill eggs), disinfectants/sanitizers and anti-fouling agents (chemicals that repel or kill things like barnacles that attach to boats). Even biological agents such as biopesticides, microbial pesticides, attractants/pheromones, repellents, defoliants, dessicants, insect growth regulators and plant growth regulators are included as pesticides.

Low-risk Pesticide AIs not requiring approval under this PERSUAP

Note that some particularly low-risk AIs (primarily extracts from plants, often artisanal or homemade by smallholder farmers) are exempt from regulation under the US Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and therefore may be made and used by beneficiary farmers without approval via this PERSUAP.

Some of these products are labeled as Minimum Risk Pesticides (MRP) and are listed at:http://www.epa.gov/sites/production/files/2015-12/documents/minrisk-active-ingredients-tolerances-2015-12-15.pdf. A list of pesticide Inert Ingredients that are exempt from FIFRA is at:http://www.epa.gov/sites/production/files/2015-01/documents/section25b_inerts.pdf.

And, so-called Commonly Consumed Food Commodities (CCFC), which include spices, herbs and oils that may be used by smallholder farmers as homemade pesticides are found at: https://www.epa.gov/minimum-risk-pesticides/commonly-consumed-food-commodities.

Insect Pheromones

Pheromones, even though listed/categorized as biochemical pesticides (biopesticides) by EPA, are covered under EPA's new "Pheromone Regulatory Relief" as lower risk, and therefore, are not subject to regulation under FIFRA, and as such, are exempt from EPA registration, and PERSUAP analysis.   See https://www.epa.gov/sites/production/files/2015-08/documents/biopesticide-oversight-chapter_0.pdf, and https://www.epa.gov/pesticide-registration/pesticide-registration-manual-chapter-3-additional-considerations.  

Currently, pheromone technology is used on a small scale in Georgia, and could become a focus of use on USAID projects, where it makes sense. Parts of Annex 1 recommend the use of some pheromone pest

1 http://www.epa.gov/pesticides/about/types.htm

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traps. Pheromones could become particularly useful in the fight against the moths of many Lepidopterous pests and caterpillars, like the Tuta absoluta tomato destroyer.

Note that EPA’s classification system for determining pesticide acute toxicity varies from World Health Organization (WHO) system. The differences between the two systems are highlighted in Annex 4. EPA’s system applies to pesticide producers, and retailers selling to farmers in the USA, and by extension, Regulation 216; however, pesticide producers, sellers and farmers in all other countries use the WHO system, providing an unanticipated (by Regulation 216 drafters) conundrum. Ideally, USAID projects would prohibit use of EPA Class I and WHO Classes Ia and Ib products.

What report findings do and do not mean

USAID projects can promote, purchase or donate PERSUAP-approved pesticides, training, advice and equipment if the risks associated with them have been evaluated in a PERSUAP. Note that farmers can—with their own funding—buy and use the pesticides they want, if they or their farm (as in demo farm) are not part of (not funded by) a USAID project, not used in USAID-procured equipment, and the treated produce does not enter a USAID-funded export, marketing or sales program. Farmers should be trained to read and follow pesticide bottle label instructions on use and safety.

Before errors (such as human poisonings) occur, it is the responsibility of USAID project implementers to put risk reduction (mitigation) recommendations into action, as soon as possible. Implementers will then monitor changes in risks, impacts and mitigation success using EMMPs (see Annex 9 as a guide). Finally, the implementers will report positive or negative changes from risk reduction success baselines in semi-annual reporting instruments.

How this report is organized

The report begins with sections that evaluate background and risks across the inputs sectors in Georgia, including treatment of agricultural crops. And, it promotes the use of Integrated Pest Management (IPM) and Good Agriculture Practices (GAPs). Annex 3 provides guidance for setting up an IPM program, based upon FAO’s Farmer Field Schools methodology.

After the Introductory and Background sections build the case for risks to Georgian beneficiaries, farmers and their resources, and the use of best practices, then the PER section addresses the 12 informational factors (a through l) required in the Agency’s Pesticide Procedures, under 22 CFR 216.3 (b)(1)(i). Finally, the SUAP puts the conclusions and recommendations reached in the PER into a plan of action. Projects are then expected to assign responsibility for implementation of each recommendation to appropriate staff members connected with risk mitigation and/or monitoring, and develop a timetable and a budget for doing this (see Annex 9 for ideas on how to do this).

PERSUAP FINDINGS, RECOMMENDATIONS AND CONDITIONS FOR MITIGATION

In accordance with 22CFR 216.3 (b) Pesticide Procedures, the 2017 updated Georgia PERSUAP addresses the needs of current and near-future (2017-2018) USAID-funded agriculture activities that will or may involve potential promotion, financing or use of pesticides. This PERSUAP addresses the following key findings and recommendations for pesticide “support”2 by project resources/staff (Implementing Partners or IPs), including the prime award recipient and sub-grantees/partners):

2 Support is defined as including any of the following by project as well as any sub-grantees/partners: procurement directly or through financing/credit, promotion during training or use on farmer field days or on demo farms.

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PERSUAP/Allowed Pesticides: This 2017 USAID/Georgia Agriculture Sector PERSUAP evaluates pesticides that could be potentially “supported” with project resources (including conditions), as well as those that cannot be supported, including justifications for rejection.

Safety Training/Equipment: Recommend that USAID-funded programs that support the use of pesticides on demo trials promote safe pesticide use (SPU) by performing pesticide safety training and ensuring the availability and use of the Personal Protection Equipment (PPE) recommended on pesticide labels (for example: gloves, mask, goggles, overalls, boots).

Good Agriculture Practices: Recommend that USAID agriculture projects’ IPs promote the use of state of the art Good Agriculture Practices (GAPs) for each of their target crops, including use of high yielding and quality clean resistant seed, soil fertility testing and conservation, soil moisture testing and proper water use, plant nutritional needs to grow healthy crops, crop rotation, and field sanitation. Annex 6 provides a list of IPM and SPU training topics.

Pest Management Plans/Integrated Pest Management: Recommend that USAID IPs promote the use of state of the art (used by many international, national and USA state extension services) pest management plans (PMPs) containing major pests/diseases/weeds of each target crop, with preventive non-chemical IPM tools/tactics, registered synthetic pesticides, as well as any artisanal and registered natural pesticides available.

Spray Services: Recommend that USAID IPs promote and support the concept and use of pesticide spray services that have well-trained and PPE-protected spray personnel.

PRIMARY RESULTS OF PESTICIDES PROPOSED FOR PERSUAP ANALYSIS: APPROVED PESTICIDES

USAID/Georgia and REAP requested an analysis of pesticides registered by Georgia, imported, desired by farmers, and currently available for purchase for use on target crops. The active ingredients in each of those pesticides are analyzed in the PER analysis and the regulatory traits and characteristics for approved pesticide active ingredients (AIs) are compiled in Annex 5. Pesticide AIs rejected by the PER analysis are found in Annex 11. Tables in Annex 5b and below compile Georgia-registered commercial pesticide product names that contain those approved AIs, alone or in mixtures with other approved pesticides (with specific conditions for use in parentheses) that may be promoted or supported by USAID/Georgia agriculture and economic growth projects.

Insecticide AIs and products registered by Georgia, and recommended by this PERSUAP for BEO approval for use in USAID Projects (with the condition that label instructions be followed and that specific conditions for use, shown in parentheses, are followed)

acetamiprid (recommended for use during vegetative growth, not flowering3) (Mosetam 20 WDG; Ace SP; Goldplan 20 Sp; Efdal Afitrid 20 SP; Escape 20 SP; Pascal, 20 SP; Rocket 20 SP; Agroplan 20 SP)

Bacillus thuringiensis/BT, subsp. Kurstaki (Lepidocide SC; Foray 76 SC; Foray 76 B; Lepidin SC)

Beauveria bassiana, Strain Bb-1 (Nostalgist BL, SL)4

bifenthrin5 (also miticide; approved only for emergency use on Brown Marmorated

3 Spraying during flowering may impact honeybee colonies4 Note that biofungicide strain Bb-1 of Beauveria bassiana is not EPA registered; however other very closely related strains are. Since it is a biofungicide, with low risks, and is a genus/species registered by EPA, PERSUAP drafters/reviewers agree that it should be permitted as an additional choice for Georgian farmers. 5 All synthetic pyrethroid pesticide AIs found in more than half of those registered by EPA as RUP (Restricted Use Pesticides), or not registered for field agriculture/horticulture use, were rejected by this analysis. One synthetic

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Stink Bug) (Talstar 10 EC, Insakar 10 EC, Zonder 10 EC) dimethoate (also miticide) (Bi 58; Biital EC; Dingo 40 EC; Bi Fosfini EC; Dimevit EC,

Kemidon EC, Alpgor, EC, Fos-Bi, EC, Vertical 40 EC, Bingo, 40 EC; Dumble 40 EC) fenpyroximate (also miticide) (Ortus 5 SC) flupyradifurone (Sivanto Praime SL 200) horticultural oil (also miticide) (Efdal Sunol EO; Key, EC; EKO OIL SPRAY, EW;

Sipcamol E, EO; Trinol-2; Hektolineum; Agromineral oil, Summer Oil) imidacloprid (recommended for use during vegetative growth, not flowering) (Imidor

Max, WG; Nuprid 600 SC; Sultan SL; Confidor Maxi, WG 70; Sidoprid 600 FS; Confidor SL 200; Resume WS; Gortca WS; Efdal Imidrid 70 WS; Confiprid, WDG; Imidagold 350 SC; Nuprid 200 SL; Gaucho FS 600; Midash WS; Imidor Max, WG)

indoxacarb (Avanti, EK; Kaiser SC) malathion (Malafos EC) spinosad (Spintor, SC) spiromesifen (also miticide) (Oberon 240, SC) spirotetramat (also miticide) (Movento SC 100) Steinernema feltiae (Geo-Nema NSS, Nemycel P) thiamethoxam (recommended for use during vegetative growth, not flowering) (Medal,

WG; Actara WG; Renova 25 WG)

Miticide AIs and products registered by Georgia, and recommended by this PERSUAP for BEO approval for use in USAID Projects (with the condition that label instructions be followed and that specific conditions for use, shown in parentheses, are followed)

clofentezine (also ovicide—kills mite eggs) (Apollo, SC) dimethoate (also insecticide) (Bi 58; Biital EC; Dingo 40 EC; Bi Fosfini EC; Dimevit EC,

Kemidon EC, Alpgor, EC, Fos-Bi, EC, Vertical 40 EC, Bingo, 40 EC; Dumble 40 EC) etoxazole (Zoom 11 SC) fenpyroximate (also insecticide) (Ortus 5 SC) horticultural oil (also insecticide) (Efdal Sunol EO; Key, EC; EKO OIL SPRAY, EW;

Sipcamol E, EO; Trinol-2; Hektolineum; Agromineral oil, Summer Oil) pyridaben (also insecticide) (Sammaite WP) spirodiclofen (Envidor, SC 240; Smach, SC 240; Contier SC) spiromesifen (also insecticide) (Oberon 240, SC) spirotetramat (also insecticide) (Movento SC 100) sulfur (also fungicide) (Thiovit Jet WG; Cosavet, 80 WG; Power Sulfur, WG; Sulphex Gold,

WG; Finesulfur 80 WG; Kumulus DF, WG)

Fungicides AIs and products registered by Georgia, and recommended by this PERSUAP for BEO approval for use in USAID projects (with the condition that label instructions be followed and that specific conditions for use, shown in parentheses, are followed)

azoxystrobin (Doris, SC; Azox WG; Qvadris SC) Bacillus subtilis, Strain QST 713 (Serenade ASO SC 1.34%) boscalid (Cantus, WG; Signum, WG; in a mixture + kresoxim-methyl: Collis, SC) captan (approved on seed that has already been treated by PPE-protected professionals;

not for smallholder farmer seed treatment, or from packages with WHO Class 1a or 1b acute toxicity classifications written on them, or labels with red bands on them; granular

pyrethroid AI, bifenthrin, was requested for approval by REAP for support on a campaign to control the Brown Marmorated Stink Bug. A similar 10% EC bifenthrin product was identified as EPA-registered and non-RUP.

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formulations should be favored) (Merpan 80 WG; Ondar, WP; Efdal Captanim 50 WP; Mass Captan, WP; Sim Captan 50 WP)

copper/cupric hydroxide (smallholder farmers use products with less than 50% AI and SC, WG or WDG formulations) Bordo Flow New SC; Iroco 40, WG; Kocaide 2000 WDG)

copper oxychloride (Cuproflow, SC; Hektas Bakir, WP; Airon, WG; Super Copper, EC; Abiga-Pik, SL; Neoram 37,5 wxgr; Ossiclor 50 WP)

copper sulfate, basic (Cuperval 20 WP; Cuproxat SC; Cuprosulf SG 25; Copper Sulfate, WP; Poltiglia 20 WP; Copper Sulphate P)

cymoxanil (in mixtures + mancozeb: Curzeb 50, WP; Rapid Gold 72, WP; Corz Super 50 WP; Valsalaxyl C Plus, WP; Sprinti 50 WP; Efdal Cymoxazeb 50 WP; Larzep 50 WP; Maxalin, WP; Super Star, WP; Erfruit 50 WP; Cymozeb, WP; Corseb, WP; Rambler 50 WP; Cimo Super 50 WP); (in mixtures + copper oxychloride: Expert Team, WP; Curzate R, WP; Ordan, WP; Efdal Mocan, WP); (in a mixture + metalaxyl: Zakhyst WP); (in a mixture + famoxadone: Tanos, WG)

cyproconazole (in a mixture + difenoconazole: Dividend Star 036 KS) cyprodinil (Chorus WG; Cyipro Plus, WG; Korus 75 WG; Strazh, SC; Carpaz 50 WG;

Atlet 750 WG); (in a mixture, + fludioxonil: Swich 62,5) difenoconazole (Funix 25, EC; Skaf, EC; Scandal 259 EC; Rayok, EC; Efdal Donazole

250 EC; Izoldifecor 250 EC; Scorpi, EC; Story 250 EC; Scorpion 250 EC; Scort 25% EC); (in mixtures: + mandipropamib: Revus Top 500 SC); (in mixtures + propiconazole: Taspa, 500 EC; Harbor 300 EC; Broader 30 EC; Efdal Difenpro 30 EC); (in a mixture + kresoxim-methyl: Samshyt, SC); (in a mixture + cyproconazole: Dividend Star 036 KS)

dimethomorph (in mixtures + mancozeb: Lider, WG; Avangard WP; Efdal Akrobot MZ, WP; Cambaz MZ, WP; Carmen MZ, WP; Actormen MZ, WP; Dimanco 9, 60, WP); (in a mixture: + copper oxychloride: Faighter blu, WP)

famoxadone (in a mixture + cymoxanil: Tanos, WG) fenhexamid (Teldor 50, WG) fluazinam (Nando SC) fludioxonil (in mixtures + thiamethoxam + difenoconazole: Celest top 312,5 FS); (in a

mixture + cyprodinil: Swich 62,5) flutriafol (Foris SC) fluxapyroxad (Sercadis SC) fosetyl aluminum (in a mixture + propamocarb hydrochloride: Previcur Energy SL 840) iprodione (Rovral 50 WP) kresoxim-methyl (Kambit WG; Stroby 500 WG; Strobstar, WG; Efdal Kresdit 50 WG;

Jako 50 WG; in mixtures + boscalid: Collis, SC; + difenoconazole: Samshyt, SC) mancozeb (Ditan M-45, WP; Sakozebi M-45, WP; Mancosh 80, WP; Valsazeb, WP;

Mangrif 75 WG; Draco Blue 80, WP; Mankozate MZ, WP; Efdal maco M-45, WP; Kingcozeb M-45 WP); (in mixtures + cymoxanil: Curzeb 50, WP; Rapid Gold 72, WP; Corz Super 50 WP; Valsalaxyl C Plus, WP; Sprinti 50 WP; Efdal Cymoxazeb 50 WP; Larzep 50 WP; Maxalin, WP; Super Star, WP; Erfruit 50 WP; Cymozeb, WP; Corseb, WP; Rambler 50 WP; Cimo Super 50 WP); Efdal Cymoxazeb 50 WP; Larzep 50 WP; Maxalin, WP; Super Star); (in mixtures + metalaxyl: Trooper 72, sf; Maximo, WDG; Universal, WP; Ridonet MZ 72, WP; Victor WP; Mancolaxyl, WP; Ridozeb MZ 72 WP; Metalaxan, WP; Armetil M, WP; Malzeb, WP; Patamil 72 WP; Efdal Mantalax, WP); (in mixtures + dimethomorph: Lider, WG; Avangard WP; Efdal Akrobot MZ, WP; Cambaz MZ, WP; Carmen MZ, WP; Actormen MZ, WP; Dimanco 9+ 60, WP; Maximum, Wp); (in a mixture + mefenoxam: Ridomil Gold MZ, WG); (in mixtures + cymoxanil + copper oxychloride: Rapid Gold plus, WP)

mandipropamide (in mixtures + copper oxychloride: Pergado C, WG); (in a mixture +

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difenoconazole: Revus Top 500 SC) mefenoxam (Apron XL, ES); (in mixtures + tebuconazole: Serticor 50 SC; + mancozeb:

Ridomil Gold MZ, WG); in a mixture + copper oxychloride: Ridomil gold plusi 42,5 Wp)

metalaxyl (in mixtures + mancozeb: Maximo, WDG; Universal, WP; Ridonet MZ 72, WP; Victor WP; Ridozeb MZ 72 WP; Metalaxan, WP; Armetil M, WP; Malzeb, WP; Patamil 72 WP; Efdal Mantalax, WP; Mancolaxyl, WP); (in a mixture + copper oxychloride: Metcopper, WP)

myclobutanil (Nimbus 24 EC) propamocarb hydrochloride (Previcur SL 607; Propacurn N, SL; Botrin, SL; Efdal

Procar 722 SL; Evakur SL); (in a mixture + fosetyl-aluminum: Previcur Energy SL 840) propiconazole (Tiltust, EC; Bumper 25 EC; Propconazole, EC; Procure EC); (in

mixtures + difenoconazole: Taspa, 500 EC; Harbor 300 EC; Broader 30 EC; Efdal Difenpro 30 EC)

pyraclostrobin (in a mixture + boscalid: Signum, WG) pyrimethanil (Rhythm, SC; Pyrus 400 SC) sulfur (also miticide) (Thiovit Jet WG; Cosavet, 80 WG; Power Sulfur, WG; Sulphex

Gold, WG; Finesulfur 80 WG; Kumulus DF, WG) Tea tree oil (Timorex Gold EC) tebuconazole (Rodolit Super, EW; Unicorn, WG; Gizmo FS; Rodolit Exttra, WDG;

Raxil Ultra FS 120; Gensil FS 060; Mystic 250 EW; Tebuji 060 FS; Heksil DS 2; Efdal Tebuzol 2 DS); (in a mixture + trifloxystrobin: Nativo 75, WG); (in a mixture + sulfur: Unicorn, WG); (in a mixture + mefenoxam: Serticor 50 SC)

thiram (approved on seed that has already been treated by PPE-protected professionals; not for smallholder farmer seed treatment) (Thiram Granulflow, WG)

Trichoderma harzianum, Strain T-22 (Trianum G, GR)6

trifloxystrobin (Zato WG 50; Tride, WG; Gurador WG)

Herbicide and Plant Growth Regulator (PGR) AIs and products registered by Georgia, and recommended by this PERSUAP for BEO approval for use in USAID projects (with the condition that label instructions be followed and that specific conditions for use, shown in parentheses, are followed)

bromoxynil octanoate (Buctril EC 327.5) carfentrazone-ethyl (Rivet 24, EC) clopyralid (Lion 300 SL) dimethenamid-P (Frontier Optima, EC) fenoxaprop-p-ethyl (Puma Super EW 144) florasulam (Belerina SE, Efdal SE) fluazifop-p-butyl (Fusilade-Forte, EC; Brace Super, EC; Fluent, EC; Tangra, EC;

Fluzitop, EC) glyphosate (glyphosan, SL 360; Tornado 500 SL; Glyn, SL; Sonround 48 SL; Roundup

Extra, SL; RoundupMax, SL; Smerch, SL) glyphosate, isopropylamine salt (klini SL; Gliphovit SL; Clean-Up, L; Sanforce 48 SL;

Boxer 48 SL; Rumbo SL 36; Knockdown, SL; Efdal Isofosat, SL) linuron (Afalon 45, SC) metribuzin (Banderilla 70 WP; Barnelaceli 70, WDG; Sencor Liquid SC 600; Surdone

70 WG; Majestic WG; Efdal Mebuzin, WP; Metribuzine 700 g/kg; Antysapa, WG;

6 The T. harzianum registered in Georgia (strain T-22) is registered in the US, but coded as KRL-AG2. These two codes are used as synonyms (https://www.law.cornell.edu/cfr/text/40/180.1102).

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Antysapa, WG; Laguun 70 WP; Super Cankor WP; Banderilla 70 WP) nicosulfuron (Eliminator, SC; Nicophuron, SC; Sulfoni, SC 40; Ikanos 40 OD; Miladar,

SC; Fullspeed, SC; Efdal Alson, SC; Sunstep SC; Nifuron, SC; Vain, SC; Nikoni SC) oxyfluorfen (Efdal Ocmost 240 EC; Galaxy 240 EC; Goal 2E, EC; Pekss 24 EC;

Paroxyfen 24 EC; Koltar, EC) pendimethalin (Stomp, EC; Pandora 330 EC; Pendigan 330 EC; Stop EC; Valsatop, EC;

Herbimate 330 EC; Panda 330 EC; Efdal Penalin 330 EC; Resort 33 EC; Sponsor 330 E) rimsulfuron (Pilot, WG; Maize DF; Titus, DS; Eskudo, WG; Weedager, WG; Aisi 642

WG; Arpad, WDG)

Molluscicide AI and products registered by Georgia, and recommended by this PERSUAP for BEO approval for use in USAID projects (with the condition that label instructions be followed and that specific conditions for use, shown in parentheses, are followed)

metaldehyde (Metadex Pellet GR, Pel.; Efdal Kimtoks, GR)

SAFE PESTICIDE USE

Beyond the use of GAPs and IPM, to safely use the above-approved pesticides, this document provides brief guidelines and references to more detailed guidelines on basic SPU, including safe labeling, transport, storage, use, first aid and disposal, as well as associated training to reinforce these principles. USAID-funded projects and/or their sub-grantees and partners that support pesticide use (including but not limited to: purchase, or in any way finance through credit or voucher schemes, together, promote during training, or use on demonstration trials) are recommended to provide such safety training and annual refresher training. Annex 6 provides a list of training topics.

PERSUAP users may access any of these resources for SPU: EPA’s Worker Protection Safety (WPS)7 program EPA’s Using Pesticides Safely8 program EPA’s Human Health Issues9 website and Emergency Information10 website EPA’s website on Personal Protection Equipment11 provides guidance on safety equipment

needed for pesticide use United Nations (UN) Food and Agriculture Organization (FAO) provides Guidelines for Good

Practice for Ground Application of Pesticides12

World Health Organization’s SPU resources13

POLICY RECOMMENDATIONS Continue to control and stop Farm Service Centers (FSCs) from sub-dividing pesticides from large

containers to small containers, including water and juice bottles that do not contain essential label and safety information. Pesticides must only be sold in manufacturer-sealed containers.

7 http://www.epa.gov/pesticides/health/worker.htm 8 http://www.epa.gov/pesticides/health/safely.htm 9 http://www.epa.gov/pesticides/health/human.htm 10 http://www.epa.gov/pesticides/health/emergency.htm 11 http://www.epa.gov/oppfead1/safety/workers/protective-equipment.html 12 http://www.fao.org/docrep/006/y2767e/y2767e00.htm13 http://www.who.int/water_sanitation_health/resources/vector385to397.pdf

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Develop a system for return of empty plastic pesticide containers to FSCs, using incentives like a rebate system. FSCs may triple-rinse empty containers, puncture them so they are not re-used, and properly dispose of them with municipal waste or into a plastic recycling system.

Donor projects work to develop crop-specific, state of the art PMPs, if possible with input from Georgian Ministry of Agriculture (MOA) extension experts.

Subsidize purchase of PPE for all project farmer beneficiaries. Subsidize farm certification costs, like GlobalGAP, as appropriate.

RECOMMENDATIONS TO USAID PROJECTS TO MITIGATE PESTICIDE RISKS

Immediate Actions Recommended for Risk ReductionEnsure that implementers and beneficiaries do not procure or use certain pesticides rejected by this analysis. These rejected pesticide AIs are listed in Annex 11, at the end of the report.

Perform IPM and SPU training (on at least two or more occasions to ensure that training works and is sustainable) for all Georgia assistance project implementers and beneficiaries that use or procure pesticides with project assistance (see Annex 6 for training topics).

Subsidize recommended PPE for all Georgia assistance project implementers and beneficiaries that use or procure pesticides with project assistance (see PPE websites referred and linked to herein). See SPU websites, above.

Maintain in project files a copy of the list of pesticides currently registered and available in FSCs for purchase and use, as well as copies of the Material Safety Data Sheets (MSDS) for each of the pesticide products commonly used by farmer beneficiaries, and approved by this PERSUAP.

Translate into a local language the most critical PERSUAP sections and Annexes for a more efficient use of PERSUAP findings.

Action Recommended by October 2017 for REAP, or within 6 months from project start up for other agriculture projects

Work to make provisional Pest Management Plans (PMPs) for each Project crop (use Annexes 1, 2 and 3, as well as local field technician and farmer knowledge). These will provide project field agriculture managers and farmers with a tool to predict, prevent and manage pests throughout the season (see excellent PMP examples at http://www.ipm.ucdavis.edu/PMG/crops-agriculture.html, website). On this website, under “Index by crop” find a green checkmark that indicates “Year-Round IPM Programs” for many crops, from the USA’s most agriculturally advanced state of California. Also see guidance for making a PMP attached as Annex 2.

Continuous Actions Recommended for Risk Reduction/Best Management Practices (BMPs)Do hands-on and workshop training (using pieces of Annex 6 as a topical guide) that encourages project-assisted farmers to use PPE, pesticide safety best practices, and apply pesticides only during the appropriate times of day (late afternoon when honeybees are finished foraging, low wind, and no rain as well as no rain in the 24-hour forecast).

Check the list of registered pesticides every 6 months to obtain new pesticide registrations & regulatory changes.

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Introduce beneficiary farmers to crop, pest and pesticide record-keeping concepts and tools following GlobalGAP or other internationally accepted Best Management Practices (BMPs) procedures. See Annex 7 for farmers to use in designing farm pesticide use records.

Program Management Actions on ComplianceMonitor FSCs and beneficiary farmers for their understanding and use of best practices/preventive tools and tactics found in Annex 1, organized by crop, as well as each pest, disease, and weeds of each crop. Also, use Annex 8 as a guide for monitoring beneficiary farms and farmers.

Report on monitoring in Annual Reports to USAID COR and MEO, under a heading titled “Environmental Mitigation and Monitoring” and/or as part of EMMPs.

Report on any changes in Georgia pesticide regulations and registrations.

Annually participate in the amending of this PERSUAP to contain new IPM tactics discovered and analyze any new pesticides registered or available (to amend and augment Annex 1).

Write the names of pesticides that cannot be supported or used with USAID assistance into any future grant or sub-contract (see these listed in Annex 11).

Take relevant actions drawn from the SUAP contained herein and ensure that these actions are included in EMMPs (see Annex 9), with ways to mitigate the most common risks, and follow progress on success of risk reduction/mitigation measures.

HOW TO USE THE PERSUAP EFFICIENTLY

Most USAID-funded projects will focus on one or more of the crops covered by this PERSUAP. The best way to use this document is to focus on the parts that apply to the crops produced, the known pests and diseases of each and the preventive and curative tools and tactics, including pesticides. To do this efficiently, search this document for the specific crops or even pests (common or scientific name) using the Word computer program’s “Find” feature, which allows one to enter the word or phrase desired, and then takes one to the exact parts of the report where the word or phrase is emphasized or used. Pesticide AIs can be found using the same method.

UPDATE THE REPORT ANNUALLY AND AMEND THE REPORT IN TWO YEARS (2019)

It is important to note that the development of new pesticides, new EPA and international pesticide regulations and registrations, as well as new international market requirements for pesticide residues on food are all highly dynamic, changing regularly. And, new human health and environmental data is produced continuously. For these reasons, and others, this PERSUAP should be updated—at least annually—and amended after two years to remain current and accurate. SECTION 1: INTRODUCTION

This section introduces the purpose, scope, compliance context and methodology of the 2017 Georgia REAP Programmatic PERSUAP study.

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1.1 Purpose, Scope & Orientation

PurposeTo maintain compliance with USAID’s Pesticide Procedures (22 CFR 216.3(b)), this 2017 PERSUAP for CNFA’s REAP Project and other USAID/Georgia Economic Growth and Agriculture Projects:

Establishes the pesticides registered in Georgia for which support is authorized for ‘use’ (see below) on USAID/Georgia agriculture sector and value chain projects and activities.

Establishes requirements associated with support for these pesticides to assure that pesticide use/support (1) per USAID policy, within an IPM framework and (2) embodies the principles of SPU.

These requirements come into effect upon approval of the PERSUAP.

ScopeThis PERSUAP document covers the REAP project agriculture activities, as well as all near-future USAID/Georgia agriculture sector supported activities and projects, their sub-grantees (like FSCs), partners, financiers and beneficiaries.

Orientation The set of authorized pesticides and requirements for safe use are established through Section 3 of the document, the Pesticide Evaluation Report (PER), which assesses the 12 pesticide risk evaluation factors (a through l) required by 22 CFR 216.3(b).

The Safe Use Action Plan in Section 4 provides a succinct, stand-alone statement of compliance recommendations for pesticides, risk reduction, as synthesized from the 12-factor analysis.

1.2 Regulation 216

From 1974 to 1976, over 2,800 Pakistani malaria spray personnel were poisoned (5 to death) by insecticide mishaps on a USAID/WHO anti-malaria program14. USAID was sued by a coalition of environmental groups, and in response to the lawsuit, drafted 22 CFR 216 (Reg. 216). According to Regulation 216, all USAID activities are subject to analysis and evaluation via – at minimum – an Initial Environmental Examination (IEE), and – at maximum – an Environmental Assessment (EA). USAID/Georgia has produced IEEs to cover all agriculture sector/economic growth projects and activities. In 2017 USAID/Georgia recommended that a new updated PERSUAP be written to cover all agriculture sector and value chain projects like REAP. This 2017 Georgia PERSUAP responds to that recommendation.

A large part of Regulation 216 – part 216.3 – is devoted to pesticide use and safety. Part 216.3 requires that if USAID is to provide support for pesticides in a project, 12 pesticide factors must be analyzed and recommendations must be written to mitigate or reduce risks to human health and environmental resources. This plan must be followed up with appropriate training, monitoring and reporting for continuous improvement on risk reduction. The adoption of IPM is USAID policy, and international best practices for crop production, protection and pesticide use safety are strongly encouraged.

USAID “Support for Pesticide Use” Definition

14 http://www.ncbi.nlm.nih.gov/pubmed/74508

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“Support for pesticide use” by the USAID Projects, sub-grantees and financing partners was defined and agreed upon at the outset of this PERSUAP study as potentially including:

Purchase directly by a USAID/Georgia project, or indirectly through a USAID project’s sub-grantees, partners, or financing mechanisms.

Support for promotion or use during agronomic or SPU training of farmers by a USAID/Georgia Project or its sub-grantees or partners.

Use or support by USAID projects, sub-grantees, partners or farmers on farmer field days or demonstration farms.

Use in USAID-funded equipment or infrastructure.

Pesticides rejected by this PERSUAP analysis (Annex 11) cannot be ‘supported or used’ for or by any of the above project activities, unless an EA is performed.

1.3 The Pesticide Evaluation Report and Safe Use Action Plan (PERSUAP)

In the late 1990s, a USAID Bureau for Africa, East Africa Regional Environmental Advisor (REA) and the USAID Uganda MEO developed the Pesticide Evaluation Report and Safe Use Action Plan (PERSUAP) concept as a tool to efficiently analyze many pesticides and pesticide systems or sectors in any given country or territory. The PERSUAP tool focuses on the circumstances, crops, pests and IPM/pesticide choices of a project or program. This approach analyzes the pesticide sector or system from registration to import through use to disposal, and develops a country-specific pesticide risk profile based on the analysis. A PERSUAP is recommended by and submitted as an amendment to the project IEE, or an EA.

1.4 Integrated Pest Management—USAID Policy

In the early 1990s, USAID adopted the philosophy and practice of IPM as official policy. IPM is also strongly promoted and required as part of Regulation 216.3. Since the early 2000s, IPM—which includes judicious and safe use of pesticides—has been an integral part of Good Agriculture Practices (GAPs) and is increasingly considered to constitute best management practices in agriculture.

A good definition of IPM from University of California (UC)-Davis15 follows: “Integrated pest management (IPM) is an ecosystem-based strategy that focuses on long-term prevention of pests or their damage through 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 [pesticides] are selected and applied in a manner that minimizes risks to human health, beneficial and nontarget organisms, and the environment.”

Another good definition of IPM from Organization for Economic Cooperation and Development (OECD)16 follows:

“Integrated pest management (IPM) is an approach to the management and control of agricultural pests which relies on site- and condition-specific information to manage pest populations below a

15 http://www.ipm.ucdavis.edu/IPMPROJECT/about.html 16 http://stats.oecd.org/glossary/detail.asp?ID=1379

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level that causes economic injury and that minimizes risks to humans and the natural environment.

Although any among a wide range of pest control agents may be used (including chemical sprays), IPM generally stresses the use of alternatives, such as crop rotations, mechanical cultivation, and biological agents, where such methods are deemed to be effective.”

1.5 USAID/Georgia Agriculture Sector PERSUAP Methodology

This PERSUAP study took place from March to May 2017, prior to the primary agriculture season startup. Inputs stores, where seeds, pesticides, fertilizers and tools were sold, were beginning to plan the year’s field season inventory. To begin the study the International Expert sent requests for crop, pest and pesticide data to REAP staff.

In mid-March, a two-week field visit was made to Georgia, around Tbilisi, and the Black Sea coast. Visits were made with USAID/Georgia, REAP staff, Georgia government officials, other USAID agriculture projects, agrochemical importers and distributors, agrochemical retail FSCs, and medium- and small-scale farmers. Information was collected on risks present in the agriculture sector, ways to mitigate those risks, primary pests of each target crop, and IPM tools that farmers use, as well as favored and registered pesticides used against select pests and diseases of target crops.

Next, the International Expert analyzed pesticide AIs registered in Georgia for US Environmental Protection Agency (USEPA) registration and restrictions status, and then began to analyze key pests of each target crop for preventive IPM tools and tactics as well as for curative pesticides that could be used for each (the results of these analyses are found in Annex 1, a Georgia IPM matrix for target crops and key pests).

At the outset of the original PERSUAP study in 2011, USAID/Georgia requested a broad analysis of all current and potential crops that could be supported, pests, diseases and weeds of those crops, and an analysis of all pesticides registered as of then for import and use in Georgia. This 2017 PERSUAP updates the list of registered pesticides. The emphasis of the 2011, 2013, 2015 and the current 2017 PERSUAP shifted from solely supporting REAP to supporting all other economic growth and agriculture sector projects funded as well as those to be funded in the near term by USAID/Georgia. This PERSUAP is meant to be used by these activities and projects to assist them in identifying preventive IPM tools and tactics (as consolidated from numerous sources) as well as least toxic pesticides and mitigation measures; and can be used in the future by USAID to help design agriculture programs and by (Implementing Partners (IPs) to guide implementation. The information in this PERSUAP should be updated annually.

The complexity of the tasks needed for this study required that the consultants provide accurate interpretation of 22 CFR 216.3 as well as cutting-edge knowledge of IPM, agronomic, entomological, phytopathological, rodentological, weed, agribusiness and chemical topics. Past PERSUAP studies chose pesticide AIs as the specific common denominator for analysis, leaving the knowledge- and sustainability-building activity of matching them to product commercial names to IPs. Now, USAID/W desires that all PERSUAPs also include the product names of each pesticide containing each approved AI.

This PERSUAP contains as many links to websites with agriculture and pesticide best practices as possible, both to make it easier to use (reduce the report’s length) and more up-to-date or accurate (as websites are updated continually, but static information is not). So, instead of having numerous annexes containing SPU equipment recommendations or practices, hot-linked websites now take their place. However, if USAID/Georgia-supported project participants do not have access to the Internet, the projects

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should reproduce and distribute key updated information in written form. A detailed outline of such websites, as well as what is contained in them, is provided in Annex 10.

SECTION 2: BACKGROUND

2.1 Country Background

Georgia, between Russia to the north and Turkey, Armenia and Azerbaijan to the south is largely mountainous with Great Caucasus Mountains in the north and Lesser Caucasus Mountains in the south; Kolkhet'is Dablobi (Kolkhida Lowland) opens to the Black Sea in the west; Mtkvari River Basin in the east; good soils in river valley flood plains, foothills of Kolkhida Lowland.

Map of Georgia

Natural resources include forests, hydropower, manganese deposits, iron ore, copper, minor coal and oil deposits; coastal climate and soils allow for important tea and citrus growth. Arable land accounts for 11.5% of the territory and permanent crops comprise 3.8%. Georgia's main economic activities include the cultivation of agricultural products such as grapes, citrus fruits, and hazelnuts; mining of manganese and copper; and output of a small industrial sector producing alcoholic and nonalcoholic beverages, metals, machinery, and chemicals. Key agricultural products include citrus, grapes, tea, hazelnuts, vegetables, blueberries, and livestock.

Georgia has made significant progress in improving the economic environment and building the economy. However, the next needed steps to achieve broad-based sustainable economic growth will be more complex. Critical constraints to improving Georgia’s economic competitiveness include fragmented markets, a lack of economic information, and low productivity. Solutions to these issues will require addressing fundamental issues in public and private sector economic institutions; sustained and coordinated capacity building initiatives; and development of systems to enable the flow of economic and technical information.

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Agriculture accounts for approximately 9% of GDP, but provides income to more than half the population of Georgia. According to data from the Ministry of Agriculture, Georgia has 656,000 farms with an average size of 1.70 hectares. Of these, there are 16,000 farms of 4 hectares or greater, which represent 40% of arable cropland in private hands (owned or leased). For farm households, monthly income from sale of farm products averages just 27.2 Georgian Lari (GEL), or less than $200 per year. This low level of productivity and income is the result of several factors including:

Small land plots which do not allow for the efficient use of machinery and technology Traditional commodity products with low market value Abandonment of farms and flight to cities by youth in search of better skills, jobs and income Low quality of products, further reducing market value and export potential, caused by poor

productivity skills Inefficient post-harvest handling, resulting in loss of output and market value Poorly developed value chains which keep male and female farmers from realizing full potential

value of the output Lack of extension service resources Lack of information about markets and weak to no linkages to domestic, regional and global

markets Lack of access to agricultural machinery and technologies

2.2 Georgia Agriculture Projects Background

Restoring Efficiency to Agriculture Production (REAP)

USAID/Georgia’s REAP is a five-year (September 2013 to September 2018), $19.5 million program operated by CNFA that is designed to increase income and employment in rural areas by delivering firm-level investment and technical assistance to expand the operation of existing smallholder farmers and rural enterprises. The project will facilitate the entry of new agribusinesses and input suppliers, including machinery service providers, storage facilities, sorting/grading centers, and small and medium scale processors to improve the availability of high-quality inputs and services, and strengthen markets for agricultural goods and services.

Also, REAP will catalyze increased private investment and commercial finance to the sector, mitigate risk for rural Small and Medium enterprises (SMEs) and entrepreneurs, and expand commercially sustainable linkages between service providers, producers, post-harvest enterprises and local consulting firms. The program will deliver 120 matching grants worth of $6 million; leverage at least $14 million in private matching investment; and provide technical assistance to all grantee enterprises, impacting at least 150,000 individuals, including 37,500 women. The SMEs assisted by REAP will help to generate at least 750 new rural jobs; $15 million in sales of inputs and services to 135,000 smallholders; and assist in developing new cash markets worth of $10 million for 2,500 producers.

2.3 Georgia International Obligations Related to Pesticides

The following are international agreements concerning pesticides. First a description of each treaty or agreement is given, and then Georgia’s status with each is given, below.

The Stockholm Convention on Persistent Organic Pollutants (POPs, Stockholm Convention) covers POPs chemicals that are toxic, persistent in the environment, and liable to bio-accumulate. These chemicals are among the most dangerous and highly toxic pollutants released into the environment every

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year by human activity. Their effects on humans can include cancer, allergies and hypersensitivity, damage to the central and peripheral nervous systems, reproductive disorders, and disruption of the immune system. Some POPs are also considered to be endocrine disrupters, which, by altering the hormonal system, can damage the reproductive and immune systems of exposed individuals as well as their offspring; they can also have developmental and carcinogenic effects.

The Stockholm Convention was established to eliminate or restrict the production and use of POPs.  Through the World Bank’s Global Environment Fund (GEF), countries are creating sustainable capacity and ownership to meet their obligations under the Stockholm Convention including preparation of POPs National Implementation Plans. A National Implementation Plan describes how each country will meet its obligations under the Convention to phase-out POPs sources and remediate POPs contaminated sites.

The Rotterdam Convention on the Prior Informed Consent (PIC) Procedure for Certain Hazardous Chemicals and Pesticides in International Trade, more commonly known simply as the Rotterdam Convention, is a multilateral treaty to promote shared responsibilities in relation to importation of hazardous chemicals, commonly referred to as PIC chemicals. The convention promotes open exchange of information and calls on exporters of hazardous chemicals to use proper labeling, include directions on safe handling, and inform purchasers of any known restrictions or bans. Signatory nations can decide whether to allow or ban the importation of chemicals listed in the treaty, and exporting countries are obliged make sure that producers within their jurisdiction comply.

The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal, usually known as the Basel Convention, is an international treaty that was designed to reduce the movements of hazardous waste between nations, and specifically to prevent transfer of hazardous waste from developed to less developed countries. It does not, however, address the movement of radioactive waste. The Convention is also intended to minimize the amount and toxicity of wastes generated, to ensure their environmentally sound management as closely as possible to the source of generation, and to assist LDCs in environmentally sound management of the hazardous and other wastes they generate.

The Montreal Protocol on Substances that Deplete the Ozone Layer (a protocol to the Vienna Convention for the Protection of the Ozone Layer) is an international treaty designed to protect the ozone layer by phasing out the production of numerous substances believed to be responsible for ozone depletion. The treaty was opened for signature on September 16, 1987, and entered into force on January 1, 1989, followed by a first meeting in Helsinki in May 1989. Since then, it has undergone seven revisions. It is believed that if the international agreement is adhered to, the ozone layer is expected to recover by 2050. Methyl bromide used for agricultural fumigation is one of the protocol chemicals being phased out worldwide.

The Convention on Environmental Impact Assessment (EIA) in a Transboundary Context (Espoo, Finland, 1991), commonly known as the 'Espoo (EIA) Convention', sets out the obligations of Parties to assess the environmental impact of certain activities at an early stage of planning. It also lays down the general obligation of States to notify and consult each other on all major projects under consideration that are likely to have a significant adverse environmental impact across boundaries.

Georgia Status on International Treaties and Obligations on Pesticides

Stockholm Convention on Persistent Organic Pollutant (POPs) (ratified 4 October 2006)17

17 http://treaties.un.org/pages/ViewDetails.aspx?src=TREATY&mtdsg_no=XXVII-15&chapter=27&lang=en

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Rotterdam Convention on Prior Informed Consent (PIC) Procedure for Certain Hazardous Chemicals and Pesticides (accession on 27 February 2007)18

Basel Convention on the Control of Transboundry Movement of Hazardous Wastes and their Disposal (accession on 20 May 1999)19

Montreal Protocol on Substances Depleting Ozone Layer (accession on 21 March September 1996)20

Espoo Convention on Environmental Impact Assessments in a Transboundary Context (Georgia has not yet decided)21

In addition, Georgia was a party to the Convention on Biological Diversity22 since June 2, 1994 as an accession, but not a signatory. A Draft National Biosafety Framework was developed under a UN Environment Program (UNEP)-Global Environmental Facility (GEF) Biosafety Project in 2005 and was published in Georgia in 2007. Georgia ratified the Cartagena Protocol on Biosafety23 on November 4, 2008 and it entered into force on February 2, 2009. Georgia acceded to the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES)24 on September 13, 1996 and entered into force on December 12, 1996.

From 2005 to 2008, donors led by the Dutch cleaned up large stockpiles of obsolete pesticides, including POPs and PIC chemicals in Georgia25. To prevent future stockpiles, the MOA, shopkeepers and farmers need to know how to deal with leftover and obsolete pesticides. The following website http://www.epa.gov/oppfead1/labeling/lrm/chap-13.htm provides pesticide disposal options.

2.4 Georgia Pesticide Regulations

On May 1, 1999, Georgian law No. 1420-IIs on hazardous chemical substances entered into force. This Law regulates the development, testing, standardization, registration, production, packing, marking and labeling, transportation, use, export and import, processing, rendering harmless, prohibition and elimination of hazardous chemical substances. It also establishes the rules for state and department supervision over such substances.

The purposes of the Law are: (a) regulate the legal relationship between authorities and natural and legal persons (regardless of the property or organizational or legal type) regarding the safe use of hazardous chemical substances; (b) prohibit the unsystematic or unauthorized use of hazardous chemical substances; (c) require the identification and registration of hazardous chemical substances; (d) regulate the use of hazardous chemical substances and prevent their harmful effects on human health and the environment; (e) regulate the notification processes for hazardous chemical substances intended for sale, their testing and official expertise, standardization, registration, packing, marking, import and export; and (f) keep the population informed and raise public awareness regarding the risks of hazardous chemical substances. To appraise their effects on human health and the environment, the classes of toxicity and risks of hazardous chemical substances are specified.

18 http://www.pic.int/Countries/Statusofratifications/tabid/1072/language/en-US/Default.aspx 19 http://www.basel.int/Countries/StatusofRatifications/PartiesSignatories/tabid/1290/Default.aspx20 http://ozone.unep.org/new_site/en/treaty_ratification_status.php 21 https://treaties.un.org/Pages/ViewDetails.aspx?src=TREATY&mtdsg_no=XXVII-4&chapter=27&lang=en 22 http://www.cbd.int/convention/parties/list/ 23 http://bch.cbd.int/about/countryprofile.shtml?country=ge 24 http://www.cites.org/eng/disc/parties/alphabet.shtml 25 http://obsoletepesticides.net/

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At present, the MOA considers that if OECD has tested and approved a pesticide, it is redundant to repeat the exact same tests. As such, Georgia permits pesticides already tested by OECD to be registered in Georgia, without repeating tests. Until about 2007, very few agricultural inputs had been used inGeorgia. And, there are still not sufficient funds for a fully-functioning extension service. Pesticide shopkeepers make pesticide usage and dosage recommendations to farmers.

Copies of Georgia’s pesticide regulations are not available in English; they are only available in Georgian, and were not translated for this study. In general, conversations with government officials note that their regulations closely mirror FAO’s recommended list of pesticide regulations, which was designed exactly for providing developing countries with a template of SPU practices to put into policy, and hopefully enforce.

2.5 Pesticide Use Sectors in Georgia Agriculture Sector

Seed Treatment with Pesticides

USAID agriculture projects donate or assist with acquisition of quality hybrid crop seed for farmers they serve. Almost all this seed, as well as nearly all modern vegetable seeds are treated with pesticides.

Most commercial seed treatment, by volume, is done by the company that produces and packages the seed, and is not by donors or farmers. And almost all treated seed is colored to show that it has been treated—this is so that it is not confused with food grain, cooked and eaten.

Many farmers in Central Asia and Caucasus, including Georgia, save seed from season to season and may try to treat it themselves. This practice should not be permitted on USAID projects because seed treatment should be done by trained specialists with the proper seed treatment equipment and PPE to protect themselves. Most smallholder farmers do not have such equipment, or knowledge.

Advantages of Seed Treatments

Since they are used at very small amounts of active ingredient per seed and thus per unit of land, and take the chemical directly to the pest or disease, seed treatments with permitted pesticides fit nicely within an IPM program. They exert a much lighter impact on the environment than spraying an entire field. They protect the seed from numerous soil and seed-borne fungal, bacterial and insect pests, so that germination and seedling growth can proceed unimpeded. And, there are some biological seed treatments available and some new ones being developed.

Risks from Treating Seed with Pesticides On-Farm

Treating seed involves many of the same risks as for mixing concentrated pesticide products and applying them to field or greenhouse crops. First, it assumes that the farmer knows the principle soil diseases and pests present and what to use against them. And, it also assumes that farmers understand the risks associated with treating, packaging, labeling, storing and planting the seed.

Ideally, seed would be treated in a specialized “seed treater” composed of a mixing tank, treater head and coating chamber to apply precisely-measured quantities of pesticide. Proper PPE must be used by the applicator and unused pesticide and residues must be properly disposed of. Next, the treated seed must be properly labeled as “Treated” with the common (Active Ingredient) and trade (Product) names of the pesticide used, health hazards of the pesticide such as skin or eye irritant, or if it is a carcinogen. For

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highly toxic chemicals, the statement “This seed is treated with a poison” and for toxic chemicals, the statement “Do not use for food, feed or oil purposes” should be used.

Seed treated for planting should be stored separately from grain to be used for food, animal feed or oil extraction. Storage should be in a dry, well-ventilated space. Farmers should keep treated seed out of reach of small children.

USAID implementing partners are effectively limited to promoting or purchasing and donating only seed already treated with pesticides registered by EPA for same or similar uses. For this reason, this PERSUAP evaluates in Annex 5 all the AIs commonly found in foliar/seed/soil treatment pesticides for EPA registration, human health and environmental risks, among other factors. Note again that the AIs commonly found in concentrated and formulated seed treatment pesticide products will present more application risks than seed already treated, due to a dilution effect.

Field Agriculture Pesticide Use

Many USAID development projects focus on increasing agricultural production in countries where agriculture still consumes most of a country’s labor, natural resources and GDP output. Inevitably, these projects work to provide farmers access to improved varieties and tools, best practices and inputs. These inputs primarily include fertilizers and pesticides. Pesticides generally include insecticides, miticides/acaricides, nematicides, molluscicides, fungicides, herbicides, bactericides, avicides and rodenticides. Insecticides that are gaseous or produce toxic gas are called fumigants. Most fumigants are for soil treatment used for high value crops (like strawberries in the USA) that kills almost everything in the soil, and are Class I toxins (the most toxic), and cannot be promoted to smallholder farmers.

Advantages of Field Agriculture Pesticide Treatments

Some pests significantly reduce yield and yield potential of most crops. Pesticides, if used wisely and safely in an IPM program, can reduce pests to tolerable levels, leading to lower pest damage risks and protected yield.

Risks from Field Agriculture Pesticide Treatments

Risks from use of pesticides in the field are numerous, but the highest risk is encountered when the container of pesticide is opened because of the potential for contact with a high concentration of the AI. Once the AI becomes mixed with water and sprayed, risk decreases somewhat, but not completely, due to dilution. Risk goes up with higher concentrations of AI and with higher AI acute toxicity classes.

As noted in the introduction, AID implementing partners are effectively limited to promoting, purchasing or donating only pesticides approved by this PERSUAP.

Greenhouse Pesticide Use

At present, USAID/Georgia supports agriculture projects that focus at least in part on greenhouse production. Greenhouse environments provide a variety of benefits for plant production; however, many greenhouses favor pest development as well. The warm, humid conditions and abundant food are ideal for pest build-up and outbreaks.

Natural enemies that serve to keep some pests under control in the field are usually absent in the greenhouse, unless intentionally introduced. For these reasons, pest problems often develop more rapidly and are more severe in these enclosed systems. Greenhouses generally tend most likely to be infested

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with very small crop pests like spider mites, scales, mealy bugs, whiteflies, aphids, leaf miners, fungus gnats and thrips. Common greenhouse diseases include powdery and downy mildews.

Advantages for Greenhouse Production

Greenhouses allow for off-season production of certain crops. The primary advantage of using pesticides in a greenhouse is that the pests are trapped and cannot leave, increasing the chance that they will be poisoned. The use of biological controls (predators, parasites or diseases that attack pests) can be effective for the same reason. The website26 maintained by the National Sustainable Agriculture Information Service contains numerous biological control resources for greenhouse production. And, many small pests can be excluded (and biological controls kept in) by using fine mesh screens on greenhouse openings.

Risks from Treating Greenhouses with Pesticides

The risk of phytotoxicity—the injury to plants by pesticides—is greater in greenhouses where plants grow rapidly and are exceptionally succulent, and not hardened by outside environmental factors like sun, wind and dust abrasion. The greenhouse environment is, in some ways, more challenging than the field in that it is an enclosed space where pesticides can become concentrated in the air, with little room for error for applicator safety.

Concentrated liquid formulations are generally more hazardous to the applicator than dry formulations as they may be easily absorbed through the skin. Aerosols and fogs usually penetrate dense foliage better than conventional sprays so better pest control is achieved, but they pose greater risk of exposure through the eyes or by inhalation.

Many pesticides labeled for field use are prohibited for greenhouse use because of concerns about worker safety, phytotoxicity leading to crop injury, and/or pesticide resistance management. Regulation 216 applies to greenhouse production in the same way that it applies to field uses. Beneficiary farmers need to read and understand the pesticide label, to see which uses are permitted and which are not. During training, they should be cautioned to use pesticides labeled for use in greenhouses.

2.6 Evaluation of Georgia Pesticide Risks near Project Sites

Georgia presently has a pesticide registration system, and a list of registered (permitted) pesticides to guide famers and others. Pesticides found in most FSCs come primarily from name-brand Western companies and exporters as well as some multinationals including Bayer, DuPont, Syngenta, and others, but in the region, there are also pesticides produced in China, some of which may work well and a few of which are likely of questionable quality. Since there is limited analytical capability in Georgia, pesticides containing additional byproducts and unauthorized chemicals may be registered and are likely to enter Georgia undetected.

No pesticides are formulated in Georgia; however, some are re-packaged. Chinese and Italian backpack sprayers are available. Small, single-use pesticide sachets are available and are a best practice because there are no leftover pesticide issues and little packaging to deal with. Scarce safety equipment is available, and any that is available is relatively very expensive. According to numerous sources, most small and medium-scale farmers do not have, and will not use, PPE. Larger commercial farms tend to be able to afford and ensure use of PPE by hired laborers.

26 http://attra.ncat.org/attra-pub/gh-ipm.html

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In every country or region, there exist factors that increase or decrease the risk profile of the agrochemical inputs sector. Following conversations with sector experts in Georgia, and others, these risks have been categorized into groups and enumerated below as “Factors that Increase Risks from Pesticides” and “Factors that Reduce Risks from pesticides.” Most of the farmers producing crops being promoted by the USAID projects in Georgia will have the potential to use some riskier pesticides as the sector becomes more developed.

Factors that indicate Increase risks from pesticides

Problems, constraints or risks in the Georgia pesticide cycle of use

Recommendations for donors and USAID projects

USAID Priority

Farm Service Centers are still sub-dividing pesticides from large containers to empty water and drink bottles

Government disincentives and incentives provided to reduce this behavior. Do not permit with project funding

High

Lower quality, illegal & pirated Chinese pesticides present in relatively low quantities

Do repeated training on choosing pesticides from known quality companies and vendors

High

Certified analytical capacity for analyzing and monitoring pesticides and residues is insufficient

Donors and produce exporters and authorities combine resources

High

Limited resources for pesticide regulations enforcement

Taxes to be levied from the agriculture sales and export sector

Low

Limited resources for extension Do demonstration farms and field days HighLimited farmer knowledge of pest Identification (ID) & IPM tools

To increase knowledge, do repeated training on pest ID and IPM

High

Pesticide shops with limited or no PPE available

Train shop-keepers on pesticide safety and need for providing PPE

Low

Pesticides stored in the farmers’ homes Do repeated training on proper pesticide storage

High

Limited use of PPE by pesticide appliers Do training on proper PPE to use; provide or subsidize PPE

High

Over- and under-applications of pesticides and no record-keeping

Do repeated training on calibration & application. Use spray and record-keeping services attached to cooperatives. Keep farm records (see Annex 7)

Med

Pesticides applied at wrong time of day (mid-day) and with winds too high, leading to drift and loss of pesticide

Do repeated training on application times risks

Med

Wrong pesticide applied for pest Do repeated training on pesticide choice HighBack-pack sprayers leak onto spray applicators

Do repeated training on sprayer maintenance

High

Increased chronic health issues in past (according to interviewees)

Do repeated training on pesticide acute and chronic toxicities & PPE

Low

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Obsolete pesticides & container disposal Do repeated training on proper disposal. Donors already target this need.

High

Factors that Reduce risks from pesticides Georgia has developed and amended detailed pesticide regulations and registration procedures in

place, and now regularly updates a list of registered pesticides. Except for some small grains like wheat, there has not, until recently, been a culture of heavy

reliance on pesticides to produce fruits and vegetables, so unsafe use behavior patterns have not been set, moreover GAP behavior patterns may be easier to set.

There are some ‘natural’ pesticide products registered and available that contain microbes or extracts from microbes, as well as products containing sulfur.

Some pesticide sellers understand the most important crop production pests, pesticides/dosages to use against the pests, risks that come with pesticide use, and the need for PPE.

Fewer FSCs subdivide pesticides from original manufacturer containers into smaller unlabeled containers in 2017, as compared with observations from 2011-2015.

There is no field evidence of pesticide misuse leading to poisonings of domestic animals or environmental poisoning (like fish kills).

Various development project activities will involve demonstrations to farmers by well-trained staff, so there is a possibility for the transfer of IPM and SPU practices.

Although there are a few positive factors, there remain numerous issues that can and do increase the risk for pesticide errors to occur in Georgia. This situation increases the risk of exposing small-scale farmers, laborers and farm family members to dangerous poisons, and polluting their environment. Thus, the pesticide risk profile is higher than might be encountered in more developed countries, so extra care is required.

2.7 Climate Change and Georgia Climate Smart Agriculture

According to a World Wildlife Fund report27, “the Southern Caucasus region already shows climate induced changes with increasing temperatures, shrinking glaciers, sea level rise, reduction and redistribution of river flows, decreasing snowfall and an upward shift of the snowline. More extreme weather events have also characterized the last ten years with flooding, landslides, forest fires and coastal erosion with significant economic losses and human casualties as a result. Reported damages due to flooding, frost and drought in the three countries amounted to more than US$ 175 million, and from the Azerbaijan part of the Caspian Sea, more than US$ 2 billion of damages from coastal erosion and flooding were reported during a 20-year period. The current trends in the region will continue with large-scale changes of ecosystems in both lowlands and mountains and negative impacts on economic activities, especially agriculture and food production, but also health further aggravated.”

Many unique species are dependent on alpine habitats in the Lesser Caucasus where the amount of living space will dramatically reduce, and species confined to already fragmented habitats like the southern Caucasus contain a plethora of biodiversity and wetlands will suffer.

Water shortages could (and in the case of Uzbekistan, already do) result in drought and spark regional conflicts. Depletion of the soil organic carbon pool due to extensive tillage exacerbates carbon dioxide emissions to the atmosphere. Soil degradation decreases methane uptake by agricultural soils.

27 http://assets.wwf.no/downloads/climate_changes_caucasus___wwf_2008___final_april_2009.pdf

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Waterlogging and indiscriminate use of nitrogen-containing fertilizers increases nitrous oxide emissions from croplands. These may increase the rate of organic matter decomposition and soil degradation. Challenges include finding land use strategies and crops that restore degraded ecosystems and soils by improving water use efficiency, enhancing soil quality and sequestering carbon in soil biomass.

Increases in temperatures will favor the spread of insect and disease pests further toward more northerly and southerly extremes. Many pests, which would die while overwintering, will now survive. The increase in crop pests will lead to the use of more pesticides, which will increase the resistance of pests to these pesticides. And, human diseases such as malaria have increased in recent years and are moving steadily northward in their vector’s range.

2.8 Good Agriculture Practices and IPM for Georgia Project Crops

IPM – without synthetic chemicals – has generally been a basic philosophy and strategy for Organically-grown crops and markets for over 20 years. Since the early 2000s, IPM practices have been making their way into market-driven GAPs (GlobalGAP, British Retail Consortium-BRC, Fair Trade, Organic and others) Standards and Certification (S&C) systems. Food safety incidents and food poisoning deaths have been publicized in domestic and international news, and have hastened the pace for GAP adoption. GAPs are also referred to as agriculture and pesticide use Best Management Practices (BMPs).

The use of GAPs ensures the production of strong, vigorous plants (that can resist or tolerate pest damage) and safe food, while IPM focuses on decreasing risks from certain pests and other constraints to production.

GAPs emphasize maintaining proper plant health, and thus prevention of problems, through use of: Quality hybrid pest- and constraint-resistant treated seed; Proper land preparation and tillage such as sowing in raised-bed plantings; Soil fertility testing, monitoring and management; Water and soil moisture testing and management to avoid salinity, bacterial and chemical

contaminants, and soil-borne diseases; Nutrient management through use of combinations of biological and mineral fertilizers; Organic matter management through use of manures, composting, and mulching; Proper pesticide choice, storage, use and disposal.

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SECTION 3: PESTICIDE EVALUATION REPORT

This part of the PERSUAP, the PER (Pesticide Evaluation Report), addresses pesticide choices based upon environmental and human health issues, uses, alternate options, IPM, biodiversity, conservation, training, PPE options, monitoring and mitigation recommendations according to the twelve Regulation 216.3(b)(1) Pesticide Procedures Factors, outlined and analyzed below.

Reg. 216.3(b)(1)(i) stipulates: “When a project includes assistance for procurement or use, or both, of pesticides registered for the same or similar uses by USEPA without restriction, the Initial Environmental Examination for the project shall include a separate section evaluating the economic, social and environmental risks and benefits of the planned pesticide use to determine whether the use may result in significant environmental impact. Factors to be considered in such an evaluation shall include, but not be limited to the following:” (see box, right)

Pesticides can be home-made (artisanal) or synthesized in a factory, and may contain either natural extracts from plants, microbes, spices, oils, minerals, or synthesized chemicals, or occasionally both. Pesticides generally contain more than just the AI; they also contain a carrier (organic solvent, oil, or emulsion), emulsifiers, synergists, safeners, adhesives and other components.

Commercial pesticide products (pesticides) generally contain just one AI, but can contain more than one AI, in a mixture. When produced commercially, each pesticide is made, marketed and sold with a product commercial name. This name, in addition to artisanal products, is the “pesticide” to which Regulation 216 refers. These pesticide names can be ubiquitous (like Roundup for Monsanto products containing the AI glyphosate) or can be given different names in different countries or regions depending upon cultural and linguistic differences and clever marketing.

3.1 Factor A: USEPA registration status of the proposed pesticide

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THE 12 PESTICIDE FACTORSFactor A. USEPA Registration Status of the Proposed Pesticides

Factor B. Basis for Selection of Pesticides

Factor C. Extent to which the proposed pesticide use is, or could be, part of an IPM program

Factor D. Proposed method or methods of application, including the availability of application and safety equipment

Factor E. Any acute and long-term toxicological hazards, either human or environmental, associated with the proposed use, and measures available to minimize such hazards

Factor F. Effectiveness of the requested pesticide for the proposed use

Factor G. Compatibility of the proposed pesticide use with target and non-target ecosystems

Factor H. Conditions under which the pesticide is to be used, including climate, geography, hydrology, and soils

Factor I. Availability of other pesticides or non-chemical control methods

Factor J. Host country’s ability to regulate or control the distribution, storage, use, and disposal of the requested pesticide

Factor K. Provision for training of users and applicators.

Factor L. Provision made for monitoring the use and effectiveness of each pesticide

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USAID/Georgia project activities are effectively limited to mentioning during training, promoting, recommending, buying or permitting on demonstration farms pesticides containing AIs in products registered in the host country and in the US by the EPA for the same or similar uses. Emphasis is placed on “similar use” because a few of the crops and their pest species found overseas are not present in the US, and therefore pesticides may not be registered for the exact same use, but often are registered for similar pests and pest situations. Annex 5 provides EPA registration status for each PERSUAP-approved AI registered in Georgia, imported, desired by farmers and available for target crops.

The USEPA classifies pesticides according to actual toxicity of the formulated products, taking formulation types and concentrations into account, thus generally making the formulated product less toxic than the active ingredients alone would be. This method of classifying acute toxicity is accurate and representative of actual risks encountered in the field. By contrast, the WHO acute toxicity classification system is based on the active ingredient only. For a comparison of USEPA and WHO acute toxicity classification systems, see Annex 4.

The USEPA categorizes pesticides as either “registered” or “not registered.” Pesticides containing AIs that are not registered in any products in the USA are not permitted on USAID projects.

In the USA, some specific commercial pesticide products are labeled as Restricted Use Pesticides (RUPs) due to inordinate risks. And, for each AI which may be in several RUP products, there are generally additional or other products, formulations and uses—with the exact same AI—which do not possess the same risks and are thus labeled or determined to be General Use Pesticides (GUP)—that is—not RUP. Ergo, for each AI, there may be RUP and non-RUP products depending upon risks they do or do not pose. This PERSUAP judges each AI by the relative number of registered products that are RUP; if the overwhelming number are RUP, this PERSUAP rejects such AIs. This PERSUAP also rejects pesticide AIs that are in an overwhelming number of Class I (EPA) or Class Ia or Ib (WHO) products.

To research pesticide AIs for EPA compliance, the following websites were used by this study: https://www.epa.gov/safepestcontrol/search-registered-pesticide-products (EPA’s official website for searching registered AIs or products); http://www.pesticideinfo.org/List_ChemicalsAlpha.jsp (a reasonable EPA proxy website linked to USEPA websites—note however that this website is not being regularly updated, so some information on it may be out of date); http://sitem.herts.ac.uk/aeru/ppdb/en/atoz.htm (a website with good ecotoxicological information for each AI).

Georgia-registered pesticide AIs that passed this Factor A analysis are listed in the Executive Summary and further analyzed in Annex 5 for human and environmental health issues characteristic to each AI. Moreover, Annex 5 provides information on EU registration of each AI, an addition since the 2011 PERSUAP. The EU pesticides registration status is found at the website: http://ec.europa.eu/sanco_pesticides/public/?event=activesubstance.selection&language=EN. This information is provided to projects because some of their beneficiary farmers are exporting produce to Europe and need this sort of information to avoid residue issues, and potential shipment rejection.

The pesticide AIs that failed this Factor A analysis, with the reason they failed, are listed in Annex 11. Thus, they are rejected for support by or on USAID-funded projects.

Compliance Requirements USAID/Georgia-funded agriculture sector and value chain projects/sub-grantees shall not promote,

finance and use on demonstration farms, pesticides containing AIs rejected by this analysis.

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If a USAID/Georgia-funded agriculture sector and value chain project wishes to recommend/use any non-EPA registered, RUP or Class I pesticide product, including use on any demonstration farm, a full SS/EA must be done and approved by the BEO.

USAID/Georgia-funded agriculture sector and value chain project/sub-grantees shall obtain and retain copies of the MSDS for each pesticide that their beneficiary farmers use frequently.

3.2 Factor B: Basis for Selection of Pesticides

This procedure generally refers to the practical, economic and/or environmental rationales for choosing a pesticide. In general, best practices and USAID – which promote IPM as policy – dictate that the least toxic pesticide that is effective is selected. Fortunately, as a general but important trend, the more toxic pesticides (Class I) are decreasing in number worldwide and the numbers of the less toxic pesticides (EPA Classes III and IV; WHO Classes III and U) are increasing.

Pesticide Treatment of Crop Seeds, Field Crops and Greenhouse Crops

Up until recently, the bases for selection of pesticides have most often been availability, efficacy, and price; not environmental or human safety. Farmers have wanted a pesticide that has rapid knock-down action to satisfy the need to defeat the pest quickly and visibly – farmers want to see insect pests immediately drop on their back with their legs twitching and flailing in the air as they die.

Farmers who use GAP systems for export crops or high-value local markets will focus more on factors such as human safety and low environmental impact, by necessity to fulfill S&C requirements as much as by choice. Such lower toxicity pesticides may take longer to kill the pest – usually after the farmer has left the field – but they are effective, nevertheless. Another factor of importance is the abeyance of pesticide-specific PHIs (pre-harvest intervals) and MRLs (maximum residue levels), which can be influenced by choosing products with rapid post-application degradation. The three most common bases for traditional farmer pesticide selection for crops in Georgia are currently price, availability and efficacy.

Some pesticides found in Georgia are formulated and labeled specifically for seed treatment; however, the demand and market for specifically labeled greenhouse pesticides is presently too small, so no specially formulated greenhouse pesticides have been found available. Greenhouse producers often just use pesticides labeled for field use.

UN’s Codex Alimentarius Commission

The Codex Alimentarius Commission was created in 1963 by the UN (FAO and WHO) to develop food standards, guidelines and related texts such as codes of practice under the Joint FAO/WHO Food Standards Program. The main purposes of this Program are protecting health of the consumers and ensuring fair trade practices in the food trade, and promoting coordination of all food standards work undertaken by international governmental and non-governmental organizations. Its website is www.codexalimentarius.net.

Issue: Most beneficiaries do not consider factors such as:

Reducing risks to human health by using products that contain active ingredients with low acute human toxicity or few to no chronic health risks;

Reducing risks to scarce and valuable water resources on the surface and underground; Reducing risks to biodiversity and environmental resources, and the services they provide.

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Recommendations for Mitigation

Project staff shall train farmers to choose and use pesticides with low human and environmental risk profiles (see decision matrix in Annex 5, MSDSs, and pesticide labels).

During training courses (see training topics in Annex 6), project staff shall include training on pesticide selection factors based on findings and recommendations of this report, material found in MSDSs and pesticide labels, and material found on pest management in Annex 1.

3.3 Factor C: Extent to which the proposed pesticide use is, or could be, part of an IPM program

USAID promotes training in, and development and use of, integrated approaches to pest management tools and tactics whenever possible. This section emphasizes how commercially used preventive tools and tactics can be incorporated into an overall IPM strategy that includes pesticides.

The susceptibility of crop plants to pests and diseases is greatly influenced by the general health of the plant, as discussed above in Section 2.8. Therefore, good crop management practices can strongly affect IPM, and good agronomic or cultural practices are the most basic and often the most important prerequisites for an effective IPM program. A healthy crop optimizes both capacity to prevent or tolerate pest damage while maintaining or increasing yield potential.

Issue: Most Georgia beneficiaries are not aware of all the IPM tactics available

Many Georgian farmers use some of the following IPM tactics: Pest resistant/tolerant seed Use of seed already treated with pesticides Soil nutrient, texture and pH testing Soil moisture measurements Following seeding rate & thinning recommendations Use of organic fertilizers (manure, compost). Note that smallholders use manure. Combinations of organic and mineral fertilizers Crop rotation Use of green manure crops Early/late plantings/harvestings to avoid pests Use of trap crops to trap and destroy pests Pest monitoring with yellow sticky traps Use of pheromone traps to monitor moth pest levels Weekly field scouting to assess pest/disease levels/damage Raised-bed planting techniques Plastic or organic mulches Pruning and sanitation of diseased plants/trees Ability to correctly identify diseases Mechanical weed control by hoe or tiller Spot treatment of pest hotspots with pesticides (instead of area-wide spraying) Crop residue destruction at end of season (mostly by burning, which is not recommended;

rather, crop residues can be composted to destroy pests, diseases and weed seeds)

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The analysis shows that farmers use several preventive tools. The challenge remaining is to spread information about these tools and tactics to additional farmers. Additional IPM tools and tactics that could be tried to include:

Use of purchased mineral fertilizers Solar soil sterilization Use of pheromone inundation to confuse moth mating Use of herbicides for weed control

Annex 1 shows a Crop-Pest-IPM-Pesticide matrix for each crop to be grown by Georgia project farmers, key pests of each crop, a list of preventive tools and tactics recommended for the same pests in countries with significant commercial production and lists of natural and synthetic chemical alternatives.

Recommendations for Mitigation

Project field staff members shall assist with the production of pest-specific PMPs, using the information in Annex 1 and organized by crop phenology, pest phenology or seasonality, and developed into field technical flyers or posters.

During training and field visits by projects field staff, these staff shall enhance understanding of, and emphasis on, IPM philosophy, tools and techniques for each crop-pest combination, with a focus on prevention and the use of the least toxic synthetic pesticides as a last resort.

3.4 Factor D: Proposed method or methods of application, including the availability of application and safety equipment

This section examines how the pesticides are to be applied, to understand specific risks with different application equipment available and application methodologies, and the measures to be taken (repeated training especially of younger future farmers, use of PPE) to ensure safe use for each application type. Pesticides can enter the body through the nose, mouth and eyes as vapors, through the skin by leaky sprayers, mixing spillage/splashing and spray drift, and mouth by accidental splashing or ingestion on food or cigarettes.

Field Crops

According to field visits, farmers use any of the following types of pesticide applicators: Hand-pump backpack sprayer with wand Motorized backpack sprayer for orchards Tractor-pulled spray tank and boom unit for field crops Tractor-pulled air-blast fan sprayers for vineyards and orchards

Few Georgia smallholder farmers use PPE. Project-supported beneficiaries will be promoting their use as a best practice. Pesticide labels should provide guidance on appropriate PPE to use, and EPA has such guidance on a dedicated website28.

Greenhouse crops

Hand-pumped backpack sprayers are used for most liquid pesticides applied in greenhouses. Although most Georgia farmers do not use PPE, project-supported beneficiaries will be promoting their use as a

28 www.epa.gov/oppfead1/safety/workers/protective-equipment.html

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best practice. Pesticide labels should provide guidance on appropriate PPE to use, and the EPA website noted above can be referenced to make training materials.

Issue: Leaky back-pack sprayers

Hand-pump backpack sprayers, used by small- and medium-scale farmers, among others, can and do eventually develop leaks at almost every junction where parts meet (filler cap, pump handle entry, exit hose attachment, lance attachment to the hose, and at the lance handle). These leaks soak onto exposed clothing and into exposed skin. Clothing serves as a wick to keep pesticides in continual contact with skin. In addition, the person wearing the pesticide contaminated clothing may physically contact other family members, exposing them to residues as well. Daily spraying concentrates the pesticides in the clothes, use after use, until the clothes are washed.

Recommendations for Mitigation

If projects provide pesticides and/or sprayers, they shall, during training, also promote repair and maintenance of application equipment, and help farmers develop a management program that includes oversight of repair and maintenance by a selected member of a farmer cooperative or association.

Issue: Pesticide granules and powders applied by hand

Many farmers that use pesticides formulated as granules or powders apply these by hand, without benefit of gloves. PPE must be used for these applications.

Recommendations for Mitigation

Project staff shall ensure that farmers that use powders or granules do so only with label-recommended PPE.

Issue: Farmers do not use PPE

Reasons that many Georgia farmers do not use PPE to reduce pesticide exposure risks include:

1. Farmers and workers either discredit or do not completely understand the potential health risks associated with pesticides. Since they do not associate health problems with pesticide exposure, they continue to take risks;

2. Climatic conditions (particularly heat) make it uncomfortable to use the safety equipment (even though it is recommended that many pesticides should be applied very early in the morning when it is cool and there is a lack of wind and rain);

3. Appropriate PPE (especially carbon cartridge respirators necessary for filtering organic chemical vapors) equipment is generally not available at all and if it is available, it is too expensive;

4. Farmers may not read or understand either the warning labels or pictograms provided on pesticide labels.

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Recommendations for Mitigation

Project training shall include descriptions of health risks to spray operators, their families, and their village (see risks for each pesticide AI in Annex 5).

Training shall include advice on minimizing discomfort from wearing PPE, like spraying in early morning before it becomes hot, or late in the afternoon when it is cooler, honeybees are not present, and when there is little wind and no rain.

Project staff shall ensure that (i.e., budget for) protective clothing (carbon-filter respirator mask, gloves, frequently-washed long-sleeved shirt and pants or Tyvec29 outfit, boots, and goggles if indicated on the label) recommended for the most commonly-used pesticides are available to farmers and farm workers involved with pesticide use. General examples of PPE to be used for different types of pesticide are found in the following website: ww.epa.gov/oppfead1/safety/workers/protective-equipment.html. The 3M30 company, which makes and sells carbon filter cartridges and masks, provides detailed advice for how to use, and when to replace, such filters.

Project staff shall provide training on the need for exclusion times and zones for areas that are being or have been sprayed. Include information about sensitive populations (pregnant women, children, elderly and sick).

Project staff shall put into place sprayer equipment maintenance procedures, proper spray techniques that reduce sprayed area walk-through, as well as frequent washing of application clothing.

If farmer illiteracy issues exist, project-sponsored training shall use and explain pictogram representations. Some general mitigation measures to ensure safe pesticide use are contained in Chapter 13 of the following website: http://pdf.usaid.gov/pdf_docs/PNADK154.pdf.

Project staff shall, together with other USAID/Georgia agriculture and economic growth projects, coordinate and set out a schedule, and budget for annual refresher training in safe handling and use of pesticides – including aspects included in Annex 6 such as types and classes of pesticides, human and environmental risk associated with pesticides, use and maintenance of PPE, understanding information on labels and proper disposal of pesticide containers and packaging.

3.5 Factor E: Any acute and long-term toxicological hazards, either human or environmental, associated with the proposed use, and measures available to minimize such hazards

This section of the PERSUAP examines the acute and chronic toxicological risks associated with the proposed pesticides. The pesticide AI analysis matrix in Annex 5 contains information on acute and chronic human and environmental toxicological risks for approved pesticide AIs. USAID-supported projects must be limited to EPA-registered pesticides, and decisions should be biased toward those pesticides with lower human and environmental risk profiles. Nevertheless, pesticides are poisons, and nearly all of them present acute and/or long-term toxicological hazards, especially if they are used incorrectly.

Issue: Pesticide Active Ingredients on POPs and PIC lists

The Stockholm Convention on Persistent Organic Pollutants (POPs) and Rotterdam Convention’s Prior Informed Consent (PIC) procedure which list banned and highly regulated toxic chemicals, respectively, were not known when Regulation 216 was written, so there is no language directly governing their use on

29 http://www.dupont.com/products-and-services/personal-protective-equipment/chemical-protective-garments/brands/tyvek-protective-apparel.html 30 http://multimedia.3m.com/mws/media/565206O/3m-cartridge-and-filter-replacement-faqs.pdf

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USAID projects. Nevertheless, they present high risks to users and the environment, due to persistence and toxicity. It is thus prudent that they be discussed. The following websites contain current lists of all POPs and PIC chemicals: http://www.pops.int; http://www.pic.int.

Recommendations for Mitigation

Project staff shall ensure that none of these POPs or PIC pesticides, listed on the POPs and PIC websites should be used on Georgia projects beneficiary farms.

Issue: Very high acute toxicity

A few of the pesticides found in Georgia contain active ingredients that are EPA Class I or WHO Class Ia or Ib (the highest toxicities by mg/kg of body weight), which are too toxic for small-scale, unaware and uninformed farmers to use. Less toxic alternatives, including preventive tactics and tools (Annex 1), and several curative pesticide choices, including some that are less toxic than Class I chemicals (EPA Classes II, III and IV and WHO Classes II, III and U, for instance), also found in Annex 1, exist, and should thus be used in place of Class I pesticides.

Recommendations for Mitigation

Project staff shall ensure that beneficiaries do not use products that are WHO Class 1a or 1b, or products that are classified by EPA as Class I.

Issue: Moderate acute toxicity

All pesticide products that have at least acute WHO and EPA toxicity ratings of II (see Annex 5) are too toxic for use without farmer training and proper use of PPE.

Recommendations for Mitigation

Pesticide products containing active ingredients with Class II acute toxicity ratings (see Annex 5) shall not be recommended by project staff unless there are no safer effective alternatives (Class III or IV).

Moreover, recommendations shall not be made to use such products unless it can be ascertained that appropriate training and PPE are available and will be used.

Issue: Lower acute toxicity pesticides

Even EPA Class III and IV and WHO Class III and U pesticides will present acute and chronic human health and environmental risks (see decision matrix in Annex 5). In sufficiently high doses, any of them may kill or harm humans, or the environment. Thus, pesticide safe use and handling training and practice are required for their use.

Recommendations for Mitigation of Human Toxicological Exposures

Most pesticide poisonings result from careless handling practices or from a lack of knowledge regarding the safer handling of pesticides. Pesticides can enter the body in four major ways: through the skin, the mouth, the nose, and the eyes. Chapter 13 in the website resource http://pdf.usaid.gov/pdf_docs/PNADK154.pdf contains measures to reduce risks of exposure via oral, dermal, respiratory and eyes. The time spent learning about safer procedures and how to use them is an investment in the health and safety of oneself, one’s family, and others.

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Project field staff shall, during training, encourage demonstration farmers and beneficiaries with whom they work to not use POPs or PIC products or products containing very highly toxic active ingredients.

Project field staff shall train beneficiaries and provide posters/flyers on pesticide safe-use BMPs. For each group of farmers to be trained, staff shall identify the pesticides most likely to be used on their specific crops, and then identify the human health risks associated with each by using information on pesticide labels, in the attached Annex 5, and on MSDSs.

Project field staff shall provide training on, and follow basic first aid for pesticide overexposure. To do this, they shall train managers and farmers on basic pesticide overexposure first aid, while following recommendations found in Chapter 13 of http://pdf.usaid.gov/pdf_docs/PNADK154.pdf, as well as any special first aid information included on labels and MSDSs for commonly used pesticides.

Recommendations for Mitigation of Exposures to Environmental Resources

Adhering to the following do’s and don’ts can mitigate ecotoxicological exposures:

Do’s Emphasize and use IPM practices in crop production Read and follow pesticide label instructions Choose the pesticide least toxic to fish, honeybees, birds, aquatic and other organisms (see Annex

5) and read the pesticide label Protect field borders, bodies of water and other non-crop habitats from pesticide exposure Completely cover pesticide granules with soil, especially spilled granules at the ends of rows Minimize chemical spray drift by using low-pressure sprays and nozzles that produce larger

droplets, properly calibrating and maintaining spray equipment, and use a drift-control agent Properly dispose of empty pesticide containers (provide training on what this means locally) Maintain a 2.5 to 5 km buffer no-spray zone around national parks, water bodies or other

protected areas Warn beekeepers of upcoming spray events so that they may cover or move their hives

Don’ts Do not spray over ponds and drainage ditches Never wash equipment or containers in streams or irrigation canals where rinse water could enter

ponds or streams Do not use pesticides with potential or known groundwater risks near drinking water sources, nor

where the water table is less than 2 meters, and not on sandy soils with high water tables Do not apply pesticides in protected parks Do not spray when wind speeds are more than 13 kph Do not apply granular pesticides in fields known to be frequented by migratory waterfowl Do not apply insecticides from 10 am to 4 pm when honeybees are foraging; insecticides are best

applied late in the day when it is cool with no wind or rain, and when honeybees are finished foraging for the day.

3.6 Factor F: Effectiveness of the requested pesticide for the proposed use

This section of the PERSUAP requires information like that provided previously, but more specific to the actual conditions of application and product quality. This section considers the potential for use of low-quality products as well as the development of pest resistance to proposed pesticides, both of which will decrease effectiveness (efficacy).

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Local knowledge is essential to choosing the correct pesticides. Local farmers know what has or has not worked for them in the past, and Georgia projects can increase local knowledge as to what is available, possibly effective, and presents the lowest risk.

The development of resistance of pests to pesticides used on Georgia projects crops will likely occur with increased use. Many farmers still over- and under-dose and use non-selective pesticides, all of which increases chances for resistance development. The primary tool in the battle against the development of resistance is to rotate among available chemical classes and/or modes of action, preceded by using preventive IPM tools and tactics.

Issue: Lack of knowledge and information on pesticide effectiveness

At some point, project field staff and demonstration farmers may begin to note that some products no longer work well to control pests in their field, and will likely begin to blame pesticide manufacturers for a weaker product. This could be the development of insecticide resistance, improper dosing or use of cheap generic products from unreputable companies. Farmers should be trained to monitor for the development of insecticide resistance, and project implementers should be on the lookout for it during their field visits.

Ways to address and manage or mitigate pest resistance in the field:

Use IPM to minimize pesticide use: Minimizing pesticide use is fundamental to pesticide resistance management. IPM programs incorporating pest monitoring in USA show reductions in pesticide use with an increase in crop quality. IPM programs will help determine the best application timing for pesticides (when they will do the most good), thus helping to reduce the number of applications. The use of nonchemical strategies, such as pest exclusion (e.g., screening, micro tunnels, greenhouses), host-free periods, crop rotation, biological control, and weed control may reduce the need to use chemicals and consequently slow the development of pesticide resistance.

Avoid Knapsack Mixes with Same Mode of Action: Never combine two pesticides with the same mode of action in a tank mix. Such a 'super dose' often increases the chances of selection for resistant individuals. In some cases, mixing pesticides from two different classes provides superior control. However, long-term use of these two-class pesticide mixes can also give rise to pesticide resistance, if resistance mechanisms to both pesticides arise together in some individuals. Continued use of the mixture will select for these multiple-pesticide-resistant pests.

Avoid Persistent Chemicals: Insects with resistant genes will be selected over susceptible ones whenever insecticide concentrations kill only the susceptible pests. An ideal pesticide quickly disappears from the environment so that persistence of a 'selecting dose' does not occur. When persistent chemicals must be used, consider where they can be used in a rotation scheme to provide the control needed and with a minimum length of exposure.

Use Long-term Pesticide Rotations: Resistance management strategies for insects, weeds, and fungal pathogens all include rotating classes of pesticides. Pesticides with the same modes of action have been assigned group numbers by their respective pesticide resistance action committees, Insecticide Resistance Action Committee (IRAC)31, Fungicide Resistance Action Committee

31 http://www.irac-online.org/

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(FRAC)32 and Herbicide Resistance Action Committee HRAC33. These group numbers have been included in the treatment tables of these committee’s guidelines (see foot-noted websites, below) to help clarify which pesticides can be rotated.

The strategies used for rotations differ by type of pesticide: For example, with fungicides, classes should be rotated every application. With insecticides, a single chemical class should be used for a single generation of the target pest followed by a rotation to a new class of insecticide that will affect the next generation and any survivors from the first generation. Longer use of a single chemical class will enhance the chance of resistance since the survivors of the first generation and the next will most likely be tolerant to that class. Rotating through many chemical classes in successive generations will help maintain efficacy.

Recommendations for Mitigation

Through training, project field staff shall increase local knowledge on the classes of pesticides available, effective, and present the lowest risk (see Annex 5).

Project field staff shall teach farmers and other beneficiaries to rotate pesticides to reduce the build-up of resistance.

Project field staff shall monitor for resistance by noting any reduction in efficacy of each pesticide product.

3.7 Factor G: Compatibility of the proposed pesticide use with target and non-target ecosystems

This section examines the potential effect of the pesticides on organisms other than the target pest. Non-target species of concern include endangered species as well as fish, honeybees, birds, earthworms, aquatic organisms, and beneficial insects. The potential for negative impact on non-target species should be assessed and appropriate steps identified to mitigate adverse impacts; and this would be included in Georgia projects’ EMMPs (see Annex 9).

Annex 5 shows the relative known risks to the different types of terrestrial and aquatic organisms referred to for each pesticide active ingredient approved and likely to be used, so that informed product choices can be made if the pesticide is to be used in or near sensitive areas or resources. Maps below show natural resources.

Issue: Protected Areas and Biodiversity

According to EarthTrends34, Georgia has 244,000 hectares of Nature Reserves, Wilderness Areas, and National Parks (of categories I and II) and 46,000 hectares of Natural Monuments, Species Management Areas, Protected Landscapes and Seascapes (categories III, IV, and V). The number of protected areas totals 34.

Georgia has the following: 4,350 total species of higher plants; 107 mammals (of which 13 are endangered); 208 species of breeding birds (of which 3 are endangered); 61 reptiles (of which 7 are endangered); 15 amphibians (one of which is endangered) and 49 species of fish (of which 6 are endangered).

32 http://www.frac.info/33 http://www.hracglobal.com/34 http://earthtrends.wri.org/pdf_library/country_profiles/bio_cou_268.pdf

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Georgia has the following nature reserves/protected areas35: Ajameti Algeti Babaneuri Batsara Bichvinta-Miusera Borjomi Gumista Kazbegi Kintrishi Kolkheti Lagodekhi Liakhvi Mariamjvari Ponto Pskhu Ritsa Saguramo Sataplia Skurcha Tsiskara Tusheti Vashlovani

This PERSUAP study finds that there are no project sites within 10 kilometers of these protected areas, which is a sufficient buffer zone36. If this changes over the course of USAID projects implementation, consider putting a buffer zone to protect natural resources in these important sites.

Issue: Pesticide Persistence

The effect of each pesticide on non-target ecosystems will depend on how long it stays in the environment, or rather its rate of breakdown, or half-life. Half-life is defined as the time (in days, weeks or years) required for half of the pesticide present after an application to break down into degradation products. The rate of pesticide breakdown depends on a variety of factors including temperature, soil pH, soil microbe content and whether the pesticide is exposed to light, water, and oxygen.

Many pesticide breakdown products are themselves toxic, and each may also have a significant half-life. Since pesticides break down with exposure to soil microbes and natural chemicals, sunlight and water, there are half-lives for exposure to each of these factors.

In the soil, types and numbers of microbes, water, oxygen, temperature, pH, and soil type (sand, clay, loam) all affect the rate of breakdown. Most pesticides also break down, or photo-degrade, with exposure to light, especially ultraviolet rays. Lastly, pesticides can be broken down, or hydrolyzed, with exposure to water by hydrolysis. Pesticides with a long residual period (that are labeled persistent and last for years) include atrazine herbicide and organochlorine pesticides. Many of the newer carbamate,

35 http://enrin.grida.no/htmls/georgia/soegeor/english/biodiv/reserves/prot.htm 36 http://www.cerium.ca/IMG/pdf/Primitive_ideas.pdf

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organophosphate and synthetic pyrethroid pesticides break down much quicker, generally within weeks, in the environment.

Recommendations for Mitigation

During training, project field staff shall teach farmers to:

consider the toxicity, half-life and breakdown products of pesticides during the selection process, and choose pesticides that are less toxic and break down quickly in the environment.

avoid using pesticides in or within a 2km buffer zone from protected areas or national parks and where endangered species are known to exist.

investigate the use of botanical and biological controls, as practical, or produce Organic crops near these valuable natural resources, if agricultural production is done within 10km up-wind or up-stream from a protected area.

minimize chemical spray drift by using low-pressure sprays and nozzles that produce large droplets, properly calibrating and maintaining spray equipment, and use of a drift-control agent.

warn beekeepers of upcoming spray events so that they may move or cover their hives. apply pesticides early late in the afternoon after honeybees have finished foraging. not to apply pesticides during heavy rains or winds, and follow instructions on pesticide

packaging. apply pesticides at least 35 meters from open water.

3.8 Factor H: Conditions under which the pesticide is to be used, including climate, geography, hydrology, and soils

In general, in addition to element G above, this requirement attempts to protect natural resources from the dangers of pesticide misuse and contamination, especially of groundwater resources. The following conditions apply, regardless of pesticide use sector, and thus the information here covers all seven sectors.

Georgia Climate37

Georgia's climate is affected by subtropical influences from the west and Mediterranean influences from the east. The Greater Caucasus range moderates the local climate by serving as a barrier against cold air from the north. Warm, moist air from the Black Sea moves easily into the coastal lowlands from the west. Climatic zones are determined by distance from the Black Sea and by altitude. Along the Black Sea coast, from Abkhazia to the Turkish border, and in the region known as the Kolkhida Lowlands inland from the coast, the dominant subtropical climate features high humidity and heavy precipitation (1,000 to 2,000 millimeters per year; the Black Sea port of Batumi receives 2,500 millimeters per year). Several varieties of palm trees grow in these regions, where the midwinter average temperature is 5° C and the midsummer average is 22° C.

The plains of eastern Georgia are shielded from the influence of the Black Sea by mountains that provide a more continental climate. Summer temperatures average 20° C to 24° C, winter temperatures 2° C to 4° C. Humidity is lower and rainfall averages 500 to 800 millimeters per year. Alpine and highland regions in the east and west, as well as a semiarid region on the Iori Plateau to the southeast, have distinct microclimates.

37 http://lcweb2.loc.gov/cgi-bin/query/r?frd/cstdy:@field%28DOCID+ge0034%29

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At higher elevations, precipitation is sometimes twice as heavy as in the eastern plains. In the west, the climate is subtropical to about 650 meters; above that altitude (and to the north and east) is a band of moist and moderately warm weather, then a band of cool and wet conditions. Alpine conditions begin at about 2,100 meters, and above 3,600 meters, snow and ice are present year-round.

Georgia Geography

Despite its relatively small surface area, Georgia has one of the most varied topographies of the former Soviet republics. Georgia lies mostly in the Caucasus Mountains, and its northern boundary is partly defined by the Greater Caucasus range. The Lesser Caucasus range, which runs parallel to the Turkish and Armenian borders, and the Surami and Imereti ranges, which connect the Greater Caucasus and the Lesser Caucasus, create natural barriers that are partly responsible for cultural and linguistic differences among regions.

Because of their elevation and a developing transportation infrastructure, many mountain villages are isolated from the outside world during the winter. Earthquakes and landslides in mountainous areas present a significant threat.

Map: Georgia Geography and Topography

Georgia Hydrology: Surface Waters of Georgia38

Georgia’s hydrology is best addressed by FAO’s 2009 Water Report39. It notes that Georgia is divided into two major watersheds, one that flows into the Black Sea and one that flows into the Caspian. The major rivers flowing into the Black Sea are the Inguri, Rioni and Chorokhi. The major rivers flowing into the Caspian are the Terek and the Andiyskoye, which rise in the north of the country, the Alazani, Iori and Kura, which rise in Georgia and flow into Lake Adzhinour before flowing southeast in Azerbaijan and then entering the Caspian Sea. In addition, Georgia has over 25,000 rivers, many of which are small streams of no more than 25 kilometers. Water is primarily used for power generation and irrigation.

38 http://enrin.grida.no/htmls/georgia/soegeor/english/water/surface.htm 39 http://www.fao.org/nr/water/aquastat/countries_regions/GEO/

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Wetlands that have a primary environmental importance are in central Kolkheti on both sides of the Rioni River mouth along the central part of the eastern Black Sea coast, and in the regions Guria and Samegrelo near the city of Poti. These sites contain many endemic species of flora and fauna. Ispani, one kilometre from the Black Sea coast near the city of Kobuleti in Adjara supports rare mammal species and migratory waterbirds of international importance. Both areas are coastal alluvial plain, composed of quaternary, lake-riverine and additional lake deposits.

For the Black Sea basin water bodies the hydrochemical observations are conducted for 43 rivers, 2 lakes and 2 reservoirs. Major artery is Rioni River. Hydrochemical observations are performed at 10 sections. Major pollutants are phenols. For the Caspian Sea basin water basin observations are conducted for 29 rivers, 4 lakes 3 reservoirs and 1 collector. Major artery is Mtkvari River, which polluted with ammonia.

Ground Waters of Georgia40

The country is rich of ground water resources (fresh, mineral, industrial and thermal). Total resources of fresh ground water are 560 cubic m/sec of which 100 cubic m/s is used. Georgia has plenty and diverse mineral water resources. Major factors affecting the quality of ground waters are the use of chemicals in agriculture and pollution of ground water from industrial facilities. And, the Republic of Georgia has numerous thermal water resources. Their exploitational capacity is 329,5 thousand cubic meters in 24 hours.

The main sources of groundwater pollution in the past were from the use of agrochemicals and wastewater spillage from industrial sources. During the former Soviet period the active use of fertilizers was 250,000 tons annually, half of which contained nitrogen. Additionally, 1000 tons of toxic and persistent chemicals were used. Large quantities of these chemicals were leached into the soil.

Soils of Georgia41

Spatial distribution of soils in Georgia is characterized by vertical variability. The Kolkheti lowland is dominated by swamp soils with an area of 200, 600 ha (3.0% of the countries territory). In Achara and 40 http://enrin.grida.no/htmls/georgia/soegeor/english/water/ground.htm 41 http://enrin.grida.no/htmls/georgia/soegeor/english/soils/soils.htm

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Guria foothills, at an elevation of 300-400 msl, there is red earth is the predominant type of soil with an area of 130, 400 ha.

In Imereti and Apkhazeti yellow earth soils are spread at 300-400 msl, 225 800 ha. In the southern part of Samegrelo the old sea terraces are dominated by subtropical podzolic soils covering 317, 600 ha (4.5% of Georgia). In western Georgia, at an elevation of 400-1000 msl non-calcareous parent rocks are covered by yellow and brown forest soils covering 106, 000 ha.

In Western and Eastern Georgia soil variability is observed only under 1000 msl. At high elevations, soil types are homogeneous. At the same time, the southern parts of the country are characterized by vertical variability. In Western and Eastern Georgia at an elevation of 1000-2000 msl soils are of a brown forest type covering about 1, 172, 200 ha (16.9%).

On the whole territory of the country 1800-2000 msl elevations are covered by mountain forest and meadow soils covering 492,000 ha; at 2000-3700 msl mountain meadow soils covering 1,477,200 ha (22.1%). Calcareous parent rocks above the 700 msl produce humic carbonate soils. In the East of the country (Gardabani and Marneuli districts), 350-500 msl, grey-cinnamonic and meadow-grey-cinnamonic soils cover the surface (7.3%).

Black earth soils dominate 266,800 ha (3.7%) in southeastern parts of the country. In Eastern Georgia and mainly on the Alazani lowland dominate salty soils covering 112,600 ha. The middle belts of the southern Georgia Mountains are covered by 157,600 hectares of black earth soils. And, along the rivers, soils of alluvial origin are present, total area being 351,400 ha (5.0%).

Issue: Pesticide Soil Adsorption, Leaching and Water Contamination Potentials

Each pesticide has physical characteristics, including solubility in water, ability to bind to soil particles and to be held (adsorbed) by soil so they do not enter the soil water layers and the ground water table, and their natural breakdown rate. This data can be found for the pesticides in Georgia by checking each pesticide on the following website: http://sitem.herts.ac.uk/aeru/ppdb/en/atoz.htm. The water solubility, soil adsorption and natural breakdown rates, if available, are included throughout the webpage, for each parent chemical.

In general, pesticides with water solubility greater than 3 mg/liter have the potential to contaminate groundwater; and pesticides with a soil adsorption coefficient of less than 1,900 have the potential to contaminate groundwater. In addition, pesticides with an aerobic soil half-life greater than 690 days or an anaerobic soil half-life greater than 9 days have the potential to contaminate groundwater. Moreover, pesticides with a hydrolysis half-life greater than 14 days have the potential to contaminate groundwater.

The potential for pesticides to enter groundwater resources depends, as indicated above, on the electrical charge contained on a pesticide molecule and its ability and propensity to adhere to soil particles, but this also depends on the nature and charge of the soil particles dominant in the agriculture production area. Sand, clay and organic matter, and different combinations of these, have different charges and adhesion potential for organic and inorganic molecules. Sandy soil often has less charge capacity than clay or organic matter, and will thus not interact significantly with and hold charged pesticide molecules. So, in areas with sandy soil, the leaching potential for pesticides is increased.

A pesticide’s ability to enter groundwater resources also depends on how quickly and by what means it is broken down and the distance (and thus time) it must travel to the groundwater. If the groundwater table is high, the risk that the pesticide will enter it before being broken down is increased. Thus, a sandy soil with a high-water table is the riskiest situation for groundwater contamination by pesticides.

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Groundwater contamination potential for each pesticide active ingredient available in Georgia is provided in Annex 5.

Recommendations for Mitigation

During training, project field staff shall teach farmers to:

ensure that pesticides labeled for certain types of use environments, or areas, are in fact used according to label recommendations.

to reduce farm soil erosion by using techniques such as terracing, employing ground covers between rows, planting rows perpendicular to the slope, using drip irrigation, organic mulches and raised-bed production.

not use herbicides or other pesticides with high leaching and groundwater pollution potential (see Annex 5) on highly sandy soils or soils with water tables close (2-3 meters) to the surface, and pay attention when spraying near waterways, so that pesticides do not enter surface water.

not spray synthetic pyrethroid or other pesticides with high toxicities to aquatic organisms before an impending rainstorm, as they can be washed into waterways before breaking down.

3.9 Factor I: Availability of other pesticides or non-chemical control methods

This section identifies less toxic synthetic, as well as non-synthetic or ‘natural’ pesticide options for control of pests, and their relative advantages and disadvantages. Many of these ‘natural’ pesticides can be toxic to humans, and some natural pyrethrum pesticides (not proposed or evaluated in this PERSUAP) are classified as RUP due to aquatic ecotoxicty risks; thus, safe pesticide use practices extend to these natural as well as synthetic (produced in laboratories or factories) pesticides.

Annex 1—the heart of this PERSUAP—contains numerous preventive non-chemical control tools and tactics for every major pest of every USAID-supported crop in Georgia. It is the intent of this PERSUAP that USAID projects dealing with agriculture use this valuable resource, which compiles known IPM tools and tactics for each pest, as recommended for the same crop-pest/disease pairings in other countries.

Issue: Natural pest controls availability

Natural chemicals: Georgia has registered several microbes and a microbial extract, spinosad, which are all considered to be natural, as defined locally. These include insecticides containing Bacillus thuringiensis/BT, Beauveria bassiana, fungicides Bacillus subtilis, Trichoderma harzianum, and entomopathogenic nematode Steinernema feltiae. Fortunately, Beauveria bassiana and Trichoderma harzianum registered in Georgia are registered by EPA, and can be promoted.

For commercial greenhouse operations, biological controls and beneficial organisms are available for purchase commercially and delivery by international delivery from two large international companies, Koppert of Holland and Biobest of Belgium. Koppert provides many biological controls useful against spider mites, beetles, leaf miners, mealy bugs, thrips, aphids, whiteflies, and moth and butterfly larvae. Koppert also provides the Koppert Side Effects List, a list of the side effects of pesticides on biological organisms, at http://www.koppert.com. Biobest of Belgium provides many of the same or similar biological controls as Koppert, and includes a control against leaf hoppers. Their website is: http://www.biobest.be. These are especially useful for greenhouse and seedling production systems. Both companies also sell live bumblebees for greenhouse pollination assistance.

Recommendations for Mitigation

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During training, project field staff shall teach farmers to:

consider using pesticides containing spinosad, BT and Bacillus subtilis.

3.10 Factor J: Host country’s ability to regulate or control the distribution, storage, use, and disposal of the requested pesticide

This section examines the host country’s existing infrastructure and human resources for managing the use of the proposed pesticides. If the host country’s ability to regulate pesticides is inadequate, the proposed action – use of pesticides – could result in greater risk to human health and the environment.

Agriculture Seed Treatment, Field Crops, Greenhouse crops

The Ministry of Agriculture in Georgia has produced updated pesticide regulations and an up-to-date list of permitted pesticides for agriculture. However, it has very limited resources available for research, extension, certified laboratories and enforcement services.

Issue: Limited resources to control pesticides

Georgia has limited systems and resources for enforcing the registration and regulation of the import, sale, and use of pesticides. Further, their ability to cover the country and eliminate banned, counterfeit or highly toxic chemicals is limited due to limited resources. The list of pesticides available contain some very highly toxic chemicals that should not be handled by illiterate, untrained, unprotected and often unaware small-holder farmers. Most farmers do not have access to and cannot afford PPE to follow GAPs.

Issue: Illegal Products from Neighboring Countries

“Leaky” country border crossings can be sources of pesticides that are not officially registered in Georgia or even Central Asian Republic (CAR) countries. Some PIC chemicals have been found in formal and informal markets in the region, as have some POPs chemicals, although the 2017 study found none of these present in USAID-supported FSCs; thus, progress is being made, through USAID training, to reduce this risk.

Issue: Disposal of Pesticide Containers

Some Georgian farmers retain empty and partially full plastic pesticide containers. Some use these to store water, milk, honey or cooking oil. Before disposal, the standard practice has been to triple-rinse the containers, puncture them to discourage re-use, and bury or burn them. Burning plastic bottles and single-use pesticide sachets can lead to the formation of toxic (and POPs) furans and dioxins, and is not recommended. GlobalGAP and other S&C systems require that empty pesticide containers are triple rinsed over a pesticide soak pit with layered soil, lime and carbon, or a bioactive pit with compost, and then properly stored in plastic drums in the field or storage shed, to await disposal or recycling. There is no pesticide container recycling activity occurring anywhere in the Caucasus. A WHO website footnoted below42 provides pesticide container disposal options.

Recommendations for Mitigation

Project field staff shall:42 http://www.who.int/whopes/recommendations/Management_options_empty_pesticide_containers.pdf

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as feasible, through contacts with the government of Georgia, encourage and follow developments in the regulation and registration of pesticides.

ensure that absolutely no POPs or PIC chemicals shall be used on Georgia projects. shall, during training, encourage and support the use of GlobalGAP best practices with pesticide

storage, use and disposal, whether certification is required for market access.

3.11 Factor K: Provision for training of users and applicators

USAID recognizes that, in addition to the use of PPE, safety training is an essential component in programs involving the use of pesticides. The need for thorough training is particularly acute in developing countries, where the level of education of applicators may typically be lower than in developed countries.

Issue: Farmers need intensive and repeated training

Training in Safe Pesticide Use and GAP/IPM are of paramount importance for Georgia projects farmers and farm laborers using pesticides. Georgia agriculture projects should focus strongly on providing GlobalGAP, IPM and SPU training. Additional and refresher training are superb means for changing beneficiary farmer behavior, now, as they continue to expand their agricultural opportunities, and before risky behaviors become further set.

Recommendations for Mitigation

Project field staff shall:

implement GAP, IPM and Pesticide Safe Use training for Georgia projects staff and beneficiaries. use Annex 1 to produce and promote the use of Pest Management Plans for farmers to anticipate

and better manage primary pests.

3.12 Factor L: Provision made for monitoring the use and effectiveness of each pesticide

Evaluating the risks, impacts and benefits of pesticide use should be an ongoing, dynamic process. Pest resistance is one of the risks for which this element is intended, as well as human health and safety and environmental effects.

Record keeping should track quantities and types of pesticides used (see Annexes 7 and 8 for forms and ideas on how to make farm pest and pesticide use records). Making notes on effectiveness of individual pesticides and pest numbers will help develop a more sustainable pesticide use plan for each beneficiary producer. Records of farmers, as well as Georgia projects agronomists, will need to make note of any reductions in pesticide efficacy experienced, which is the first indication that resistance may be developing, and then a strategy needs to be in place to determine a shift to a different pesticide class, and rotation among classes, to overcome resistance development.

Georgia projects and Farm Record-Keeping

On Georgia projects proposed demonstration farms, pesticide use documentation is either little used or not retained from year to year. Developing a more systemized approach to record keeping will allow

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seasonal and annual comparison of pesticide effectiveness, pest numbers, crop production, maintenance of safety equipment, and so on.

Recommendations for Mitigation

The following aspects shall be included in the record keeping system, for a USAID-funded program:

Local, EPA and EU regulatory compliance: A list of country, EPA and EU laws related to the use of agrochemicals for plant protection, short notes on the relevance of the law, dates the laws come into or exit force and MRLs for each crop-pesticide combination.

A pesticide checklist: This list allows agronomists to ensure that the pesticides they are using are not banned or highly restricted by international treaties (POPs, PIC) and registered through the USEPA. It should also provide notes on special safety requirements.

GAPs/IPM measures tried/used (see Annex 1): Georgia project agronomists should try to incorporate a minimum of at least three new IPM measures per annum and document their success or failure.

PPE: Lists of the types of equipment made available to applicators, number of pieces, prices and contact details of suppliers, dates when equipment needs to be washed, maintained or replaced. PPE should be numbered or personally assigned to applicators to ensure that it is not taken home where (as a contaminated material) it could pose a risk to family members.

Monitoring/recording pests: Agronomists should incorporate into their records regular field pest monitoring and identification. This could be done by the agronomists themselves, or if properly trained, by farmers (see Annexes 7 and 8).

Environmental conditions: Field conditions should be incorporated into the record keeping system (for example; precipitation, soil analyses and moisture, soil pH, temperatures and so on, see Annex 7 on farm/farmer records).

Information should be transmitted at least annually and Georgia projects should report to USAID on this progress in pesticide safety and GAP/IPM use in annual reports.

Recommendations for Mitigation

Monitoring by Georgia project field staff and farmers shall detect, record and report:

Resistance: Pesticide resistance development among pests has likely occurred and could eventually occur more, and will be noted by farmers complaining that the spray no longer works as it once did.

Human poisonings and any incidences of significant chronic health issues. Farm animal and livestock deaths. Any incidences of water pollution. Fish, bird, frog, wildlife or honeybee kills.

Any of the above items should be reported immediately to USAID. Other information should be transmitted at least annually to USAID, and Georgia projects should report on this progress in pesticide environmental and human health safety in annual reports.

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SECTION 4: Pesticide Safe Use Action Plan (SUAP) for Georgia projects

4.1 Introduction to SUAPThis Safe Use Action Plan, is the definitive statement of USAID/Georgia economic growth agriculture sector projects pesticide compliance requirements and is synthesized from the PER analysis:

Section 4.2, immediately below, cites the locations in this PERSUAP where users can find the allowed pesticides.

Section 4.3 establishes USAID field monitoring requirements for compliance with safe use conditions

Section 4.4 summarizes the recommended best practices and safe use conditions to be used/supported with these pesticides.

Each USAID/Georgia agriculture sector or value chain project will be required to insert into an EMMP the foreseeable risks and the appropriate recommendations from the PER that are applicable to their project that will reduce the risks. Project-specific EMMPs should also include indicators of mitigation success, monitoring timetable and responsible people/groups for implementation of these requirements, and for tracking compliance. Project-specific EMMPs should include details on who will be trained, in what topics, and how often. EMMPs should have measurable and monitorable indicators to be reported on in progress reports to USAID.

4.2 USAID/Georgia Pesticides Requested for AnalysisUpon approval of this PERSUAP, the pesticide active ingredients (AIs) listed as “allowed” in the Executive Summary and Annex 5—and ONLY those AIs—may be supported by the USAID/Georgia projects and their sub-grantees covered by this PERSUAP. Such support is subject to the safe use conditions summarized below and set out in detail in the SUAP, section 4 of this PERSUAP.

Allowed pesticides are those that passed the 12-factor analyses, particularly Factor A (EPA & Georgia Registration and Restricted Use Pesticide—RUP Status) & Factor E (Acute/Chronic Toxicological Hazards), as analyzed and summarized in Annex 5a. Synthesizing across the PER analysis, ONLY the pesticide AIs in Annex 5a, 5b and the Executive Summary—and with the implementation of specific noted conditions for any of the chemicals—are permitted for use/support in USAID/Georgia agriculture sector and value chain projects and their sub-grantees.

4.3 USAID requirementIn addition to continuous monitoring by USAID/Georgia agriculture sector projects like REAP and their sub-grantees/environmental compliance staff and others delegated, USAID/Georgia’s AOR, MEO and/or BEO should at least two times annually, make inspection visits to several randomly selected farms receiving project assistance/finance to check for compliance with the IPM and safe use measures summarized in section 4.4 below, and detailed data collection forms found in Annexes 7 and 8.

4.4 Compliance Requirements (Safe Use Measures)The allowed pesticide AIs can only be used in compliance with the safe use measures and recommendations specified in the PER. The most important of these can be summarized as follows:

A. Only pesticides approved by this PERSUAP may be “supported” with USAID/Georgia funds;

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Pesticide “support” = any of the following: use of USAID funds to: purchase pesticides; directly fund the application of pesticides; recommend pesticides for use; facilitate or enable the application or purchase of pesticides via provision of application equipment, credit support, or other means by the IPs, their sub-grantees, partners or providers of finance.

B. If pesticide use is supported, appropriate project staff, sub-grantees & beneficiaries must be trained in IPM (Annex 1), safe pesticide use & pesticide first aid (Each IP shall provide details in their project-specific EMMP of their plans for training);

C. To the greatest degree practicable, if pesticide use is supported by USAID/Georgia projects or their sub-grantees they must require use & assure maintenance of appropriate PPE—as well as safe pesticide purchase, handling, storage and disposal practices. (Each IP shall provide details in their project-specific EMMP of how they will implement the relevant recommendations from the PER, and if this SUAP is revised, as recommended, each EMMP will have to be revised as well.)

Additional PERSUAP recommendations are found under each of the Factor a- analyses, under Section 3, the PER analysis, and shall be implemented by project staff.

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Introduction to Annex 1, Integrated Pest Management Matrix: Concept, Methods, Information, Errors and Refinement

The following are notes to introduce the concepts, methods, information sources and requests for researching and evaluating the information found in Annex 1, for continuous learning and improvement.

Development Concept

The information contained in Annex 1, below, is presented for donor projects, NGOs and governments to adopt and adapt to local conditions, as they see fit. It is provided for them to test and accept, or reject, preventive tools and tactics that do, or do not, work well in the local milieu. It is not exhaustive, by design, leaving room for local learning and testing, which enhances sustainability, a USAID goal. Moreover, if taken seriously, the matrix provides a baseline for local experts to add local tools and tactics that only they and their farmer clients know about and use. They can also add pest/damage descriptions.

Furthermore, by design, this IPM matrix omits technologies that will not, at present, fit the local resource environments and capabilities. For instance, weather stations linked to computer models that can predict pest or disease outbreaks may not work well in a country where funds for equipment maintenance are lacking, and farmers do not have easy access to computers, or do not know how to use them. One way to fix this would be to provide fee-based services so the farmer can make the decision on how useful, or not, they are, and either pay for them, or choose not to. This approach, in turn, puts pressure on the computer model service provider to make their product or service present a better value proposition to farmers, to be sustained.

Methods

The following preventive IPM tools/tactics recommendations are researched, analyzed, paraphrased, condensed, and bulleted, first and foremost, from USA state extension service websites that report on IPM tools. The USA was the first in the world to develop the concept of state research extension services and stations, and the first to formally commit funds and develop pest management plans for state farmers, homeowners, commercial applicators, and others. More importantly, these USA websites often include links to EPA-approved pesticides. Further, they generally cover the exact same crop-pest/disease species combinations as those found in other countries.

From the author’s professional experience, approximately 95% of pest species found in any one country are the same species found world-wide. A few are in the same genus, but of a different species, so similar IPM tools may or may not work to manage them. And even fewer are completely unique to a specific region of the world, like the Sunn Pest, Eurygaster integriceps, that attacks cereals in Central Asia, and until recently, the tomato destroyer, Tuta absoluta, which used to exist only in Latin America, but is now spreading from continent to continent.

The second source of IPM information comes from regional extension service websites run by NGOs, because, since they are from the region, it is assumed that these regional experts know their pests and preventive tools best. Finally, and third, IPM information is sourced and cross-checked from international websites like those provided by NGOs and other donors, because, in general, it is assumed that they have done a good job copying and compiling these practices from other websites and sources. However, most of these regional and international websites are not linked to EPA-approved pesticides, and are sometimes linked to pesticides that a PERSUAP rejects; thus, their usefulness for a PERSUAP analysis is limited.

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Sound IPM Information Sources and Bullets

Most commercially-useful—read profitable—preventive IPM tools and tactics that work well for a great number of crops come from the two largest commercially valuable agricultural states in the USA, California and Florida. Both states are blessed with sub-temperate and sub-tropical climates, not unlike those found in countries where USAID works. And, both have state university experiment station experts who produce websites with sound IPM recommendations, linked to EPA-approve pesticides. Information on uniquely tropical crops (coffee, cacao, pineapple, papaya, for example) and their pests/diseases can be found on the Hawaii state extension service website. Information on commercially-valuable temperate crops grown in certain USA states can be sourced from those state’s extension service websites. For instance, quality IPM information for blueberries is found on North Carolina and Michigan state extension websites; information on cherry pests and IPM is found on New York and Michigan state extension service websites, and so on.

Even though it is assumed that natural enemies of crop pests, diseases and weeds are part of all IPM plans for each crop-pest combination, these state extension websites continue to list them as natural interventions that, if understood and managed properly, provide a level of pest/disease management, particularly when combined with other preventive tools. The same goes for monitoring, a basic tenet for IPM to work well. Many sites repeat phrases “use yellow sticky traps to monitor” or “use commercially-available pheromone traps to monitor and control”. Thus, repeating them in this PERSUAP’s IPM matrix seems reasonable.

Moreover, IPM information is provided in bullets so that well-trained and motivated field technicians, their supervisors, as well as policymakers can read them quickly, and implement them. Writing long academic treatises on each pest and IPM tool could serve to do the opposite—not get read—which is why that approach is avoided here. Interested parties can use Google searches to look up additional background information on their crops, pests and diseases, as desired.

Error Rate and Correction for Continuous Improvement

Due to the overwhelming quantity of crops, pests, diseases, weeds, preventive IPM tools/tactics, pesticide AI choices, pesticide product choices, each with their own unique formulations and concentrations designed for the great diversity of uses, as well as EPA regulatory decisions, there is a high likelihood for errors to enter IPM matrices and pesticide analyses. This “error rate” is due either, first, because the sources of information contain errors, which are interpreted and transcribed directly without being cross-checked; or second, consultants are using memory instead of looking up and checking for facts and alternatives; or, third, the fatiguing time crunch to quickly produce such information, analyses, and PERSUAP documents leads to errors in understanding, transcribing or cross-checking.

Inevitable “error rate” is likely a consequence of all the above. The goal of the PERSUAP drafter, and reviewers, as a team, is to push this error rate down as far as is possible and reasonable, given time and resource constraints. We need to keep in mind that lower error rates and quality details cost time and money to look up and evaluate for accuracy and usefulness.

Review, Error Correction, and IPM Matrix Refinement

It is contingent upon all who work on a PERSUAP document to push the error rate down to increase accuracy and exhaustiveness of the analyses. This includes reviewers as well as drafters. It is not sufficient to blankly note that this or that piece of information is in error, or an analysis is insufficient or incomplete. It is more productive and efficient for the reviewer to fill in what is missing, or correct which

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piece of information is incorrect, and note where that missing or correct piece of information was found, so that the drafter can improve their searches, search techniques or interpretations in the future.

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Primary Pests Preventive management IPM tools/tactics to integrate Curative management IPM tools/tacticsGeneral best preventive and curative practices for all crops

For most pests Do pest, predator and parasite monitoring, survey and proper identification to understand the risks of spraying pesticides.

Natural parasites, predators and diseases attack and control many pests, diseases, and weeds of project crops. Over-applications of pesticides can kill these beneficial organisms, leading later to outbreaks of the pests as well as outbreaks of secondary pests.

Frequent monitoring of the crop is one of the most-recommended tactics for identifying and preventing outbreaks of pests/diseases, and ultimately reducing the amount of pesticides needed.

Use treated and certified clean (pest/disease/weed-free) seed from pest/disease-resistant or tolerant cultivars, hybrids or varieties.

Do soil tests for soil structure, pH, macronutrient & micronutrient levels for precision soil amendment targeting.

Regularly test soil moisture levels to manage soil-borne diseases and potentially reduce amount of irrigation water used.

Use raised-bed or bund production to better manage water use, soil moisture and speed seedling growth.

Use minimum and no-tillage, cover crops, terracing and contour plowing to conserve soil.

Maintain a vigorous plant by properly watering and fertilizing following soil test and moisture results.

Rotate crops and intercrop different crop types. Use organic mulches and cover crops to suppress weeds, conserve irrigation

water, manage soil moisture, and thus protect soil from rapid salinization. To add organic nitrogen and structure to the soil, use green manures or rotate

with nitrogen-fixing legume crops, use inter-planting with legumes and agroforestry techniques.

Use manures and compost to increase soil organic matter and nutrition, decrease soil-borne pathogens, sequester carbon, hold moisture and decrease need for increasingly more expensive synthetic nitrogen fertilizers derived from fossil fuels.

Sanitation: After harvest, destroy crop residues and weeds in and near field. Have a pest management plan, organized chronologically by season or crop

stage, which combines all or parts of these preventive and curative tactics with other production tactics.

Most weeds are managed by smallholder farmers by hoeing, or hand-pulling.

Always read and follow instructions and risk-reduction measures printed on the pesticide label and MSDS, if available. Some labels and MSDSs also have crops, pests and dosage recommendations.

To reduce the risk of pests/diseases/weeds gaining resistance to a certain pesticide or type of pesticide, always rotate among classes of pesticides with different modes of action, if possible.

Most herbicides are too expensive for smallholder farmers to afford. Herbicides are primarily registered for larger-scale commercial farmers.

Following are names of recommended pesticide AIs—for the names of commercial products containing them, as registered in Georgia, please see the list of this PERSUAP’s approved pesticides in the Executive Summary, which matches each AI with local product names containing these approved AIs.

For how and when to use each pesticide, train farmers to read and follow the label instructions.

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Cereals/Small Grains: Wheat/Winter Wheat, Barley/Winter Barley, Rye, Oats, TriticaleAphids: Wheat Aphid (Diuraphis noxia) and Aphis species. Aphids transmit BYDV (Barley Yellow Dwarf Virus)

Maintain adequate soil moisture and fertilization (Plants stressed for water or nutrients, or over-fertilization with nitrogen, are more susceptible to and suffer greater damage from aphids). Use regular monitoring, yellow sticky traps.

Use resistant varieties. Sanitation: Field disking and destruction of crop residues are important for

control of aphid pests to reduce their migration into nearby crops. Avoid early planting. Avoid excessively high soil nitrogen levels.

Treatments horticultural oils malathion dimethoate thiamethoxam imidacloprid flupyradifurone

Wheat thrips (Haplothrips tritici)

Growing of early-ripening wheat cultivars. Use early wheat sowing and early two-phase harvesting. Early deep plowing. Use crop rotation.

Synthetic pesticides are not economical to control wheat thrips (but are economical for other pests).

Barley flea beetle (Phyllotreta vittula)

Use living mulches or polycultures. Trap crops: Interplant field and margins with giant mustard or radish and

destroy these plants once heavily infested. White and yellow sticky traps placed every 15 to 30 feet of row. Sanitation: Clean up and compost plant debris from the field and around the

field.

spinosad malathion

Turnip moth (Agrotis = Scotia segetum)

Use crop rotation. Removal of weeds in and around fields will reduce egg-laying sites and will

help in the prevention of cutworm infestation. Do this at least 2-3 weeks before planting to reduce the incidence of cutworm larvae transferring to newly planted crops.

Use pheromone traps. Sunflowers and cosmos can also be planted as a trap crop in or around fields. Plow and harrow fields properly before planting. This will destroy eggs and

expose larvae to chicken, ants, birds, and other predators.

Bacillus thuringiensis/BT, subsp. Kurtaski (sprayed or used in bran baits; make sure the chosen Bt product is effective against this species)

Beauveria bassiana

Hessian Cereal Fly (Mayetiola destructor)

Use resistant or tolerant varieties. Use crop rotation away from wheat. Disk wheat stubble after harvest. Delay winter wheat planting until after first freeze.

thiamethoxam imidacloprid

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integriceps and other species)

Rotate crops. Monitor for presence of natural enemies. Destroy alternate host plants near fields.

this pest.

Wheat grain beetle/wheat chafer (Anisoplia austriaca)

Vernalization and early sowing of cereal grain crops. Soil cultivation and inter-row treatment in spring and in early summer as a

method of destroying pupae. Quick two-phase harvesting at the beginning of grain ripening. Early post-harvesting plowing of soil.

Insecticides are not economical against this pest.

Cereal cyst nematode (Heterodera avenae)

Use of resistant cultivars Use crop rotation, deep plowing, fallowing and avoid mono-cropping. Rotate with broccoli, cauliflower, sorghum, flax, Sudan grass, rape, and

mustard seed which are resistant to nematodes. Use of organic fertilizer and composts to add organic matter and soil structure

to sandy soils.

Not economical or safe for smallholder farmers to control with synthetic nematicides.

Instead, do “biofumigation” of the soil by growing, shredding and plowing under crucifers, and covering the soil with mulch or plastic, if available, until just before planting crop. Rotting crucifers produce toxic gasses that kill nematodes, and covering with plastic increases efficacy.

Smuts (Wheat covered smut and loose smut)Tilletia caries and Tilletia foetida, Ustilago hordeiUstilago tritici , Ustilago nuda, Ustilago nigra

Use certified smut-free seed. Hot water treatment can eliminate smut fungi from contaminated seed, but it

must be used carefully to avoid reducing seed vitality. For covered smut, which is on the outside of the seed, treatment of seed with

contact-type fungicides can control the pathogen. For loose smut, which resides inside the seed, seed treatment with systemic

fungicides is necessary.

mancozeb metalaxyl thiram (treated seed) tebuconazole difenoconazole (treated seed) ludioxonil Bacillus subtilis, Strain QST 713

Powdery Mildews: Blumeria graminis (Erysiphe graminis f. sp. tritici) infects wheat, Erysiphe graminis f. sp. hordei infects barley, Erysiphe graminis f. sp. avenae infects oats and wild oats

Use certified disease-free seed. Resistant cultivars of barley and wheat are available.

Crop rotation. Elimination of crop residue. Control of volunteer grains and weed hosts reduce inoculum survival from

one season to the next.

Tea tree oil cyproconazole propiconazole pyraclostrobin tebuconazole fluxapyroxad Bacillus subtilis, Strain QST 713

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Rusts: Leaf and Brown: Puccinia recondita and Puccinia triticana (wheat)Stem rust/black rust (Puccinia graminis)Glume rust (Puccinia glumarun) and Yellow or Stripe rust (Puccinia striiformis)

Use certified disease-free resistant hybrid seed. Resistant cultivars of barley and wheat are available.

Tea tree oil mancozeb, propiconazole cyproconazole difenoconazole pyraclostrobin fluxapyroxad Bacillus subtilis, Strain QST 713

Septoria spot (Septoria tritici

Use certified disease-free resistant hybrid seed. Crop rotation will not work. The presence of the airborne ascospores that can

spread long distances very quickly in the wheat growing regions means that crop rotation will not allow wheat to escape from the source of inoculum.

Later plantings of wheat (Nov. to Dec.) are less likely to be severely affected. The impact of the disease is most severe in early-planted wheat (October) because the plants are exposed to the pathogen over a longer period during a period when weather conditions are frequently favorable to disease development.

mancozeb propiconazole difenoconazole pyraclostrobin Bacillus subtilis, Strain QST 713

Cereals Weeds: Deploy integrated weed management. Adequate drainage is necessary for fields planted to small grains. Excessive

moisture in low areas creates and aggravates problems such as stand loss, loss of soil nutrients, reduced oxygen supply, and root diseases. Chiseling the soil before seedbed preparation increases drainage and root development.

Use pre-irrigation or first rain to germinate weed seeds and remove them by tilling before planting or by applying postemergent herbicides, land preparation.

Under dryland conditions, after the first autumn rainfall, primary fall tillage with a disk, chisel plow, or moldboard plow usually follows to eliminate germinating winter weed seedlings.

For fallow period, use glyphosate. Preplant, use glyphosate. Post-plant, wheat, use pendimethalin. Post-plant, wheat, use bromoxynil-

octanoate, fenoxaprop-P-ethyl, carfentrazone-ethyl, clopyralid.

Post-plant, barley, use bromoxynil-octanoate, carfentrazone-ethyl, fenoxaprop-P-ethyl, clopyralid.

Post-plant oats, use bromoxynil-octanoate, carfentrazone-ethyl, clopyralid.

Post-emergence: florasulam.

Corn/Maize, SorghumCorn stalk borers (Ostrinia nubilalis)

Use borer-resistant varieties. Use crop rotation and intercrop maize with legumes. Plow deeply and harrow.

Given the difficulties in application once larvae enter the stem, control with pesticides is generally incomplete;

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Plant early at the beginning of rains or within 2 weeks. Sanitation: Remove and destroy stalks by burning, feeding to cattle or

composting. Scouting is key to determining corn borer populations and controlling first-

generation larvae. Timing of insecticide applications for second generation is more difficult.

however systemic pesticides may provide some control.

Seed treated with imidacloprid or thiamethoxam.

Bacillus thuringiensis/BT, subsp. kurstaki

spinosad ndoxacarb

Turnip moth (Agrotis = Scotia segetum)

Use crop rotation--plant alfalfa or beans. Removal of weeds in and around fields will reduce egg-laying sites and will

help in the prevention of cutworm infestation. Use pheromone traps. Sunflowers and cosmos can also be planted as a trap crop in or around fields. Plow and harrow fields properly before planting. This will destroy eggs and

expose larvae to chicken, ants, birds, and other predators.

Bacillus thuringiensis/BT, Strain Kurtaski

Beauveria bassiana

Aphids: corn leaf aphid (Rhopalosiphum maidis

Grow different crops or grow crops in rotation every cropping season. This practice provides food, shelter, and it increases the number of natural enemies that prey on aphids.

Plant trap crops such as lupine, nasturtiums, and timothy grass near the crop to be protected (plow under or spray). Anise, chives, garlic, onions, and radish are good companion crops.

Control ants that protect aphids. Avoid using heavy doses of highly soluble nitrogen fertilizers. Instead apply

fertilizer into 3 phases: during seeding, vegetative, and reproductive stages of plant growth.

Use yellow sticky board traps placed in field (spread used motor oil on yellow painted plastic, thick cardboard or wood).

dimethoate flupyradifurone

Maize Weeds: Proper seed selection. When possible use high quality seeds and certain crop varieties that out-compete weeds.

Narrow row spacing makes the crop more competitive than the weeds, Place the fertilizer in such a way that the crop has access to it but the weeds

do not. This allows the crop to be more competitive with weeds. Maintain cleanliness on the irrigation canals. Keep the surroundings of your farm free of weeds, unless they are maintained

and intended as habitats for natural enemies. Regularly clean farm tools.

Before planting, use glyphosate. At planting, use glyphosate,

pendimethalin. After planting, use nicosulfuron,

pendimethalin, glyphosate, bromoxynil-octanoate, metribuzin, carfentrazone-ethyl.

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Use green manure, which chokes out weeds. Use intercropping. Hand weeding and composting Hoeing, mowing, and cutting.

Cole Crops/Crucifers/Brassicas and Lettuces: Broccoli, Cabbages, Cauliflower, Brussels Sprouts, Mustards, Turnips, Radishes, LettucesAphids: Cabbage aphid (Brevicoryne brassicae)

Carefully manage nitrogen levels so that they are neither too high (which significantly attracts aphids) nor too low (which impedes plant growth).

Inter-planting with clover (as a “living mulch”) reduces aphid populations. Use trap crops: Plant mustards or collards on field margins or inter-planted

and destroy these plants once heavily infested.

acetamiprid flupyradifurone

Caterpillar pests: Diamondback moth (Plutella xylostella)Imported cabbage worm (Pieris rapae, Pieris brassicae)Armyworm (Mamestra brassicae)

Use of pheromone misters and emitters to disrupt mating in larger hectarages. Use of pheromone traps to monitor populations of these pests to determine the

best time to spray insecticides. Use of floating row screen or mesh covers to exclude egg-laying moths.

Bacillus thuringiensis/BT Beauveria bassiana spinosad indoxacarb

Spring cabbage fly/maggot (Delia radicum)Summer cabbage fly (Delia floralis)

Use compost and straw mulches to reduce maggot populations by excluding egg-laying flies.

Intercrop with clovers or other legumes to reduce open soil available for egg-laying flies.

Use of floating row screen or mesh covers to exclude egg-laying flies.

spinosad

Cabbage bacterial rotPectobacterium carotovorum subsp. carotovorum (Syn. Erwinia carotovora, Erwinia aroideae)

Use of certified disease-free propagation material. Do weed control in and around field. Use resistant or tolerant varieties. Plant in well-drained soils, avoid over-irrigation (particularly during head

development). Remove and destroy diseased plants.

Treat with only class II or III copper-containing compounds:

o copper hydroxide,o copper oxychloride,o copper sulfate (basic).

Use copper compounds sparingly, note that copper can accumulate in the soil and cause eventual soil toxicity.

Black leg (Phoma lingam)

Clean, certified or hot-water treated seed. Good soil drainage. Rotation with non-brassica type crops.

iprodione yraclostrobin

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Control of brassica-type weeds. Planting resistant varieties.

Downy mildew (Peronospora = Hyaloperonospora brassicae)

Promote good soil drainage. Increasing spacing for better aeration. Control brassica-type weeds. Using resistant varieties. Rotating with non-cole crops. Sanitation: After harvest, deep plow or destroy plant debris.

Copper compounds dimethomorph fluazinam mefenoxam fosetyl-aluminum mandipropamide pyraclostrobin

Cole Crops Weeds Monitor and identify weed species present. Use fallow practices. Sanitation: To reduce seed production, disc or mow harvested fields before

weeds flower and produce seeds. Cultivation equipment and irrigation water must also be kept free of weed seeds and vegetative propagules to avoid spreading weed populations. Cultivate areas around the field such as field edges, fence lines, roadsides, and irrigation ditches regularly to prevent weed seed production. To reduce seed production, disc or mow harvested fields before weeds flower and produce seeds.

Preplant plowing, followed by irrigation and one or two diskings before bed formation, will destroy many weeds.

Regularly clean farm tools to remove soil that has seeds. Use green manure, which chokes out weeds. Use intercropping. Hand weeding during their earlier growing period. Do not let the weeds

flower (do not compost weeds that have flowered and set seed). Hoeing, mowing, and cutting.

glyphosate

Solanaceous Crops: Tomato, Potato, Peppers/Paprika, Eggplant

Tomato leafminer(Tuta absoluta)

Nursery Management and Clean Propagation Material: Use only nursery-produced seedlings that are completely free from Tuta leaf infestation.

Sanitation: Remove and destroy (tillage, deep burial) infested tomatoes and plant residues, especially in greenhouse production, immediately following last harvest.

Monitor using pheromone/water traps and yellow sticky traps. Mass Trapping using pheromones mixed with small quantities of insecticide

may control Tuta. Rotation: Rotate to non-Solanaceous crops.

Bacillus thuringiensis/BT, subsp. kurstaki

spinosad indoxacarb imidacloprid

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Potato aphid (Macrosiphum euphorbiae)

Use resistant varieties. Use regular monitoring with yellow sticky traps to detect presence and

relative numbers. Field disking and destruction of crop residues are important for control of

aphid pests of leafy vegetables to reduce their migration into nearby crops.

imidacloprid spirotetramat flupyradifurone

Colorado Potato Beetle (CPB) (Leptinotarsa decemlineata)

Use resistant varieties. Use crop rotation to reduce population build-up. Do mulching with wheat or rye straw. Use floating row covers to exclude CPB.

spinosad, thiamethoxam imidacloprid

Potato tuber worm moth (Phthorimaea operculella)

Use pheromone traps. Shallow setting varieties are generally more susceptible than varieties that set

tubers deep. Any practice that reduces the exposure of tubers to egg-laying female moths

will reduce tuberworm damage. Prevention of soil cracking in the beds will reduce tuberworm damage. Thus,

Furrow-irrigated fields have a much greater potential to become infested than sprinkler-irrigated fields (cracking of the soil is less severe under sprinkler irrigation than with furrow irrigation).

Prompt, thorough harvest and sanitation are also essential. Sanitation: Destroy cull piles and volunteer potatoes. Piles of cull potatoes

provide a year-round breeding site for tuberworm.

spinosad indoxacarb

Potato stem borer (Hydraecia micacea)

Sanitation: Destruction of weeds on fields and adjacent sites early in the season and removal of plant residues after harvest.

Generally, no insecticides are recommended or economical for control of this pest.

Turnip moth (Agrotis = Scotia segetum)

Use crop rotation--plant alfalfa or beans after tomato. Removal of weeds in and around fields will reduce egg-laying sites and will

help in the prevention of cutworm infestation. Do this at least 2-3 weeks before planting to reduce the incidence of cutworm larvae transferring to newly planted crops.

Use pheromone traps to determine when to spray. Interplant main crops with onion, garlic, peppermint, coriander, or garlic

every 10-20 rows to repel cutworms. Sunflowers and cosmos can also be planted as a trap crop in or around fields. Plow and harrow fields properly before planting. This will destroy eggs and

Bacillus thuringiensis/BT, subsp. kurstaki

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expose larvae to chicken, ants, birds, and other predators.

Nematodes: Potato cyst nematode (Globodera rostochiensis)Potato Rot Nematode (Ditylenchus destructor)

Use of resistant cultivars and grow healthy plants (use appropriate seed, spacing, watering, weeding and fertilizer).

Use Soil solarization using plastic. Use crop rotation, deep plowing, fallowing and avoid mono cropping. Rotate

with broccoli, cauliflower, sorghum, Sudan grass, rape, and mustard seed which are resistant to nematodes.

Sanitation: Remove and compost crop debris. Use of organic fertilizer particularly chicken manure and composts to add

organic matter and soil structure to sandy soils Growing flax, a tropical herb, is good for controlling root knot nematodes. African and French marigold (Tagetes minuta and T. patula, respectively)

plowed under the soil also suppress and reduce nematodes. Plant and plow into soil 2 months later.

Not economical or safe for smallholder farmers to control with synthetic nematicides.

Instead, do “biofumigation” of the soil by growing, shredding and plowing under crucifers, and covering the soil with mulch or plastic, if available, until just before planting crop. Rotting crucifers produce toxic gasses that kill nematodes, and covering with plastic increases efficacy.

Bacterial (black) wilt and canker (Pectobacterium carotovorum subsp. carotovorum (Syn. Erwinia carotovora)

Use of certified disease-free propagation material. Do weed control. Use resistant or tolerant varieties. Plant in well-drained soils and avoid over-irrigation. Use deep well water for irrigation. Remove and destroy diseased plants. Rotate with non-solanaceous crops.

Treat with only class II or III copper-containing compounds:

o copper hydroxideo copper oxychlorideo copper sulfate (basic,

tribasic) Use sparingly, note that copper can

accumulate in the soil and cause eventual soil toxicity.

Late blight or Downy mildew (Phytophthora infestans)

Use tolerant varieties and raised-bed production Drain the growing field adequately before planting Follow proper planting date, do not plant late Farmers use sticks and lines to raise tomato plants and fruit into the air to

aerate the plant and raise the leaves and fruit away from the soil

metalaxyl Propamocarb-hydrochloride azoxystrobin cymoxanil famoxadone mancozeb dimethomorph pyraclostrobin mandipropamide fluazinam

Weeds of Solanaceous Crops

Herbicide expenses make farmers use hand weeding, hoeing or cultivation. At end of the harvest, manual removal of weeds. Clean weeds along irrigation canals that can transmit weeds to the field.

Tomato In fall beds, before weeds emerge, use

synthetic herbicides containing 70

DCN: 2017-GEO-022Primary Pests Preventive management IPM tools/tactics to integrate Curative management IPM tools/tactics

Use crop rotation. Use transplants which can out-compete weeds quicker. Use soil solarization. Use soil mulches and pruning. Continue hoe and hand weeding. Can use drip irrigation to regulate water in the crop and avoid weed

emergence.

metribuzin, oxyfluorfen. After weeds emerge, use glyphosate. Pre-plant, use pendimethalin. Post-plant before weeds emerge, use

rimsulfuron. Post-plant after weeds emerge, use

metribuzin, rimsulfuron.Potato Pre- and Post-plant, use dimethenamid-P,

glyphosate, pendimethalin, rimsulfuron.Eggplant/Pepper On preformed beds, use glyphosate,

carfentrazone-ethyl. Post-plant, use synthetic carfentrazone-

ethyl.

Alliums: Onions, Garlic, Shallots, Leeks, Chives,Onion fly: Delia antiqua Control soil moisture.

Floating row covers exclude onion fly. During the growing season, minimize damage to bulbs caused by insects and

diseases. Provide for quick drying following topping, especially if temperatures are

high. Rotate 3 to 4 years out of onions, garlic, and leeks. Control other soil insects and foliage diseases that cause wounds entered by

onion fly larvae. Harvest only after onion tops are well matured, cure onions properly before

storage and store onions at cool temperatures since infection is favored by warm conditions.

Sanitation: Clean up all cull and volunteer onions out of fields before planting.

Use fall plowing to destroy pupae.

malathion

Leek moth (Acrolepiopsis assectella)

If economical and available, use pheromone traps to monitor. Row covers provide an alternative strategy and these are used to cover crops

during the adult flight periods, preventing gravid females from laying eggs.

Bacillus thuringiensis/BT, subsp. kurstaki

spinosad

Tulip bulb mite (Aceria tulipae)

Use certified clean propagation material/bulbs. Hot water treatment before planting may reduce mite infestation.

sulfur

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Avoid planting successive and rapid onion, leek or garlic crops. Sanitation: Plow under crop residues especially decaying cole crops like

cauliflower, which may harbor very high bulb mite populations. Practice fallow fields to allow complete decomposition of organic matter, this

reduces field populations of the mite. Flood irrigation or heavy rains during the winter may reduce mite levels in the

soil.

Onion stem nematode (Ditylenchus dipsaci)

There are currently no resistant cultivars available. Use certified clean propagation material. Rotate or alternate alliums with nonhost crops such as carrots and lettuce for

several years. Sanitation: Avoid infesting new fields by cleaning machinery and equipment

with water, and preventing movement of infested soil.

Not economical or safe for smallholder farmers to control with synthetic nematicides.

Instead, do “biofumigation” of the soil by growing, shredding and plowing under crucifers, and covering the soil with mulch or plastic, if available, until just before planting crop. Rotting crucifers produce toxic gasses that kill nematodes, and covering with plastic increases efficacy.

Downy mildew (Peronospora destructor)

Plastic mulch covering to avoid plant contact with soil and minimize weeds that enhance microclimate conditions favorable to disease dispersion.

Heat treatment of bulbs at 35 to 40 °C for 4 to 8h reduces the disease significantly.

Eliminate crop residues, plant during dry season, avoid irrigation during heat of the day.

Use crop rotation. Use certified seed and good drainage.

metalaxyl captan (granular formulation) dimethomorph fosetyl-aluminum mancozeb mandipropamide copper oxychloride

Weeds of Alliums Use the most weed-free field possible. To avoid buildup of weed seed in the soil, cultivate weeds before they set seed

in rotation crops. Clean cultivate the field or plant a green manure crop to limit weed

infestations after onion harvest. Irrigate the field before planting to germinate weed seeds and afterwards

cultivate the soil killing the weeds. After pre-irrigation, cultivate shallow so that weed seed is not brought up

from deeper soil layers. Maintaining deep furrows keeps the bed tops from becoming overly wet while maintaining adequate soil moisture for the crop

At pre-plant, use glyphosate. At post-plant before weeds and crop

emerge, use pendimethalin, bromoxynil-octanoate, oxyfluorfen, fluazifop-P-butyl.

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(by keeping the bed tops drier, fewer weeds are likely to germinate in the soil surface).

To avoid excessive competition with the onions and to make removal easier, cultivate when weeds are small. Hand weeding is a very efficient method for weed control.

Use soil solarization.

Cucurbits: Cucumbers, Squashes, Pumpkins, Melons, WatermelonAphids (Several including melon or cotton aphid, Aphis gossypii, Pea aphid, Acyrthosiphon pisum)

Use resistant varieties Use regular monitoring with yellow sticky traps

Sanitation: Field disking and destruction of crop residues are important for control of aphid pests of leafy vegetables to reduce their migration into nearby crops.

If control is needed, treat when aphids are found to be reproducing, particularly when second and later generation wingless females have started reproduction. Aphid populations are easier to control before the plants begin to cup.

imidacloprid spirotetramat flupyradifurone

Mangold flea beetle (Chaetocnema concinna)

Use proper water and fertilization to grow vigorous plants and eliminate plant stress from insufficient moisture and powdery mildew.

imidacloprid

Downy mildew (Pseudoperonospora cubensis)

Resistant varieties are available for control. Avoid overhead irrigation.

Tea tree oil mancozeb metalaxyl dimethomorph fosetyl-aluminum propamocarb-hydrochloride,

mandipropamide, mefenoxam famoxadone cymoxanil

Powdery mildew (Sphaerotheса fuliginea, Erysiphe cichoracearum)

Control irrigation water to not over-water. Resistant varieties are available for control. Use crop rotation. Sanitation: Remove and destroy heavily diseased and dead plants. Control weeds in and around field. Increase light intensity by planting at proper recommended intervals.

Tea tree oil sulfur azoxystrobin trifloxystrobin kresoxym-methyl tebuconazole

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Weeds of Cucurbits Cultivate weeds under before they set seed in rotation crops.

Pre-irrigate before planting crop and cultivate or spray weeds that emerge. Plant or transplant cucurbits into uniform beds and use a precision planting

system that puts crop in straight line that will allow cultivation close to the seed line.

Use mulches to smother weeds near plants.

Before planting, use glyphosate, carfentrazone-ethyl, oxyfluorfen.

Umbelliferous Crops: Carrots, Celery/Celeriac, Fennel, Parsley, Coriander, Cilantro, Parsnip, ChervilCarrot rust fly (Psila rosae)

Monitor with yellow sticky traps. Floating row covers exclude rust fly. Use crop rotation to non-Umbellifers.

spinosad thiamethoxam imidacloprid

Weeds of Umbellifers Monitor and identify predominant weeds to make a management plan. Avoid planting carrots in fields last planted to cereals or in fields with known

infestations of perennial weeds. To prevent the buildup of weed seed in the soil, cultivate weeds before they

set seed in rotation crops. Soil solarization can be used to control most weeds in carrots. Carrots should be planted in the most weed-free fields. Do not practice close cultivation with machinery or hoe (risk of damage to

roots is too high).

Pre-plant, use glyphosate. Post-plant, before crop emerges, use

linuron or pendimethalin. After crop emerges, use linuron,

fluazifop-P-butyl.

Grape vines: Wine grapes, Table grapes, Raisin grapesVine Mealybugs (Planococcus ficus)

During regular monitoring, take note of and map mealybug infestations. Control honeydew-seeking ants using tillage and common vetch cover crops. Peel back the thin bark on spurs in the current season's prunings and look for

the presence of mealybug crawlers (larvae), if 20% of samples show crawlers apply a delayed dormant insecticide.

imidacloprid spirotetramat dimethoate

Grape Leafroller (Sparganothis pilleriana),Apple leafroller (Choreutis pariana)

Use pheromone traps to monitor and trap adult moths. Sanitation: Control weeds in and around orchard. Disc under grape mummy

clusters and weeds.

Bacillus thuringiensis /BT, subsp. kurstaki

spinosad

Grape vine moth (Lobesia botrana)

Can use pheromone traps to monitor. Can use mating disruption with pheromone inundative releases, but only on

large scale orchards of more than 10ha.

Bacillus thuringiensis /BT, subsp. kurstaki

spinosad

Soft scale of Control honeydew-seeking ants near and in orchard. narrow-range horticultural oils74

DCN: 2017-GEO-022Primary Pests Preventive management IPM tools/tactics to integrate Curative management IPM tools/tactics

grapes/wooly vine scale (Neopulvinaria innumerabilis)

Provide plants with good growing conditions and proper cultural care especially appropriate irrigation.

Prune off heavily infested twigs and branches to eliminate scales when infestations are on limited parts of the plant.

Pruning to open vine canopies helps to control some scale species.

imidacloprid spirotetramat

Grape phylloxera (Viteus vitifoliae)

Resistant rootstocks are available for this pest. For new vineyards, use only clean propagating material and do not hold clean

material in infested areas before planting.

imidacloprid spirotetramat

Silverleaf whitefly (Bemisia tabaci)

Do weed control in orchard. Avoid or remove plants that repeatedly host high populations of whiteflies. Aluminum foil or reflective mulches can repel whiteflies. Yellow sticky traps can reduce whitefly populations.

Beauveria bassiana Horticultural oils imidacloprid thiamethoxam spirotetramat flupyradifurone

Mites: Grape Erineum Mite or Vine Leaf Blister Mite (Colomerus vitis).Garden Spider Mite (Eotetranychus pruni)

Apply water to reduce dust on roads in the plantation. Maintain resident vegetation or other cover in the middle of the plantation to further reduce dust.

Irrigate in a manner that will avoid stressing vines. Overhead watering has been shown to reduce mite problems, but it can increase some diseases.

sulfur narrow range horticultural oils clofentezine etoxazole fenpyroximate pyridaben spirodiclofen

Anthracnose (Elsinoe = Sphaceloma ampelina)

Use resistant varieties. Prune out and destroy (remove from the vineyard) diseased plant parts during

the dormant season. This includes infected shoots, cluster stems, and berries. Eliminate wild grapes near the vineyard. Prune the vines so that air and sunlight can enter the canopy.

myclobutanil cyproconazole mancozeb difenoconazole

Downy Mildew (Plasmopara viticola)

Splashing rain and wind disperse the pathogen. Use effective soil drainage and reduction of sources of overwintering

inoculum. If sprinkler irrigation is used, extend the intervals between sprays.

Tea tree oil Mancozeb azoxystrobin dimethomorph pyraclostrbin boscalid kresoxim-methyl mefenoxam trifloxystrobin

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mandipropamide

Powdery Mildew (Uncinula necator)

Monitor in spring to decide when to treat. Use sanitation: Clean up and destroy crop residues.

sulfur horticultural oils tebuconazole cyproconazole cyprodinil myclobutanil azoxystrobin trifloxystrobin kresoxim-methyl yraclostrobin boscalid

Gray mold or bunch rot (Botrytis cinerea)

Use sanitation: Clean up and destroy crop residues. Avoid over-head sprinkler irrigation.

cyprodinil fludioxonil iprodione mancozeb rifloxystrobin

Weeds of Grape Vines Use mulches to suppress weeds or black plastic to kill them. Use mechanical cultivation to cut and bury weeds. Furrow-irrigated

vineyards are amenable to in-row cultivation. Geese can be released into vineyard to control weeds. Grow cover crops to choke out unwanted weeds.

For established weeds and site preparation, use glyphosate, glyphosate-isopropylamine salt, fluazifop-P-butyl, oxyfluorfen.

Pre-Emergence, after planting, use oxyfluorfen, pendimethalin or rimsulfuron.

Fruit Trees: Pomes Fruits: Apple, Pear, Loquat, Quince, and Stone Fruits: Apricot, Peach, Plum, Prune, Cherry, Almond

Codling moth (Cydia = Laspeyresia pomonella)

Sanitation: Remove infested & dropped apples. Mass trapping and mating disruption using pheromone traps. Pruning tree for height and spraying efficacy. Remove host trees in nearby abandoned orchards (apple, pear, and walnut) to

destroy reservoirs of codling moth. Remove props, picking bins, and fruit piles from the orchard.

spinosad horticultural oilcetamiprid

Fruit trees: Fall webworm (Hyphantria cunea)

Hand removal and destruction of webbing nests in fall. Bacillus thuringiensis/BT, subsp. kurstaki .

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Gypsy moth (Lymantria dispar)

Maintain tree vigor by watering and fertilizing properly. Use sticky bands or burlap bands around tree trunks to trap and destroy

migrating larvae.

Bacillus thuringiensis/BT, subsp. kurstaki .

Soft and armored scales (Ceroplastes japonicus)

Prune branches to open them up to light, sun and predators. Sanitation: Prune off and destroy heavily infested branches. Manage ants that tend the scales by placing tanglefoot around the tree trunk.

horticultural oil midacloprid

Mites: Brown fruit mite (Bryobia redicorzevi)Red spider mite (Panonychus ulmi)

Fruit tree spider mite (Tetranychus viennensis)

Do weed control in orchard. Control dust near orchard by watering or oiling dirt roads. Prevent water stress by irrigating or watering orchard during dry times. Broad-spectrum insecticide treatments for other pests frequently cause mite

outbreaks, so avoid these when possible.

sulfur horticultural oils fenpyroximate clofentezine etoxazole pyridaben spirodiclofen spiromesifen

Pear blister moth (Leucoptera malifoliella)

Sanitation: Use autumn plowing and digging of soil around trunks for destruction of wintering pupae, collection and destruction of fallen leaves in autumn or in early spring, and cleaning of old bark.

Use of insecticides is not economical for this pest.

Leaf miners (Lyriomyza species)

Do not apply large amounts of nitrogen while miners are present. Sanitation: remove crop debris and weeds.

malathion imidacloprid

Pear leaf blister mite (Eriophyes = Phytoptus pyri)

Resistant varieties with naturally russetted surfaces (Bosc, Hardy, Winter and Nelis) do not show the effects of blister mite attack.

Monitor and treat in fall or dormant season.

sulfur horticultural oil fenpyroximate spiromesifen

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Sawflies: Pear Fruit Sawfly (Hoplocampa brevis)Cherry slug/Pear fruit sawfly (Caliroa cerasi)Plum Sawfly (Hoplocampa flava)Black Plum Sawfly (Hoplocampa minuta)Apple Sawfly (Hoplocampa testudinea)

Field trials have found that sticky-coated, non-ultraviolet-reflecting white rectangles to be the most effective trap for capturing and monitoring adult sawfly populations.

Cultivation around tree base to destroy pupae. On small hectarage orchards, hand-pick larvae.

spinosad horticultural oil

Apple scab (Venturia inaequalis)

Use a fall foliar fertilizer application of zinc sulfate and urea to hasten leaf fall and speed decomposition of fallen leaves (reduces the level of overwintering apple scab inoculum).

Sanitation: cultivate leaves into soil.

Copper compounds flutriafol sulfur myclobutanil trifloxystrobin pyrimethanil kresoxim-methyl mancozeb fluazinam cyprodinilmancozeb (use only up to

bloom),

Pear scab (Venturia inaequalis and Venturia pyrina)

Fall foliar fertilizer application. Sanitation: cultivate leaves into soil.

flutriafol sulfur fluazinam kresoxim-methyl pyrimethanil rifloxystrobin

Powdery mildew (Podosphaera leucotricha)

Sanitation: Prune away and destroy infected shoots during dormancy or early spring.

lutriafol sulfur myclobutanil trifloxystrobin pyrimethanil

Monilia fruit rot (Monilia fructigena)

Reduce mechanical wounding of fruit. Sanitation: Removal and destruction of infected mummy fruits.

propiconazole iprodione

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fenhexamid pyraclostrobin boscalid pyrimethanil cyprodinil myclobutanil azoxystrobin

Shot-hole disease (Stigmina carpophila; syn. Clasterosporium carpophilum)

Sanitation: Prune out dead plant material and material with lesions and dead buds, Removal and destruction of infected fruits and leaves.

Copper compounds pyroclostrobin boscalid captan pyrimethanil trifloxystrobin iprodione azoxystrobin cyprodinil

Citrus: Lemons, MandarinsWhite flies (Dialeurodes citri)

Use yellow or blue sticky traps for detection. A regularly maintained program of hedging and topping can help reduce

whitefly problems. Prune branches to open them up to light, sun and predators. Parasitic wasps and fungi generally provide some control.

Beauveria bassiana horticultural oil spirotetramat imidacloprid acetamiprid flupyradifurone

Citrus leaf miner (Phillocnistis citrella)

Avoid pruning live branches more than one time a year, to reduce new leaf flushes.

Do not apply large amounts of nitrogen while miners are present. Remove ‘water sprouts’ (vigorous shoots that grow above graft unions) and

‘suckers’ (grow below graft unions). Sanitation: remove crop debris and weeds. Use pheromone traps for monitoring and mass trapping.

imidacloprid horticultural oils pirotetramat

Mealybugs: Obscure mealybug (Pseudococcus obscurus), Citrus mealy bug (Pseudococcus gahani)

During regular monitoring, note taking and mapping of mealbug infestations. Control honeydew-seeking ants using tillage and common vetch cover crops. Peel back the thin bark on spurs in the current season's prunings and look for

the presence of mealybug crawlers (larvae), if 20% of samples show crawlers apply a delayed dormant insecticide.

imidacloprid dimethoate spirotetramat Narrow range oil

Scales: Chinese wax scale Provide plants with appropriate irrigation. Horticultural oil79

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(Ceroplastes sinensis), Citrus scale (Lepidosaphes beckii)

Prune branches to open them up to light, sun and predators. Sanitation: Prune off and destroy heavily infested branches. Manage ants that tend the scales by placing sticky Tanglefoot around the tree

trunk.

imidaclorpid spirotetramat

Mites: Citrus red mite (Panonychus citri), Citrus rust mite or Silver mite (Phyllocoptruta oleivora)

Do weed control in orchard. Control dust near orchard by watering dirt roads. Prevent water stress by irrigating or watering orchard during dry times. Broad-spectrum insecticide treatments for other pests frequently cause mite

outbreaks, so avoid these when possible.

sulfur narrow range horticultural oils fenpyroximate pyridaben spirodiclofen

Specialty Fruits: Kiwi, FeijoaThrips (Heliothrips haemorrhoidalis)

Do routine monitoring using sticky card (with blue colors) inspections. Control weeds in and around orchard.

spirotetramat Steinernema feltiae

Aphids (various species) Carefully manage nitrogen levels so that they are neither too high (which significantly attracts aphids) nor too low (which impedes plant growth).

Inter-planting with clover (as a “living mulch”) reduces aphid populations.

horticultural oil acetamiprid spirotetramat flupyradifurone

Sclerotinia fruit spot (Sclerotinia spp.)

Maintain relatively open shelter and vine canopies to keep moisture levels low within the canopy.

iprodione fludioxonil Trichderma harzianum

Oil and Seed Crops: Sunflower, Safflower, SesameSunflower mildew (Plasmopara halstedii)

Use resistant varieties. Provide good air circulation. Do crop rotation. Control weed hosts near field. Avoid wetting foliage, use drip irrigation if possible.

azoxystrobin mancozeb fluxapyroxad

Weeds of Sunflower: Sunflower broomrape (Orobanche cumana) and others

Control measures include the use of resistant cultivars with obligatory crop rotation.

Perform thorough land preparation (soil tillage, fertilizer, and water management).

Narrow row spacing makes the crop more competitive than the weeds, use

pendimethalin as pre-emergence

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intercropping. Place the fertilizer in such a way that the crop has access to it but the weeds

do not. This allows the crop to be more competitive with weeds. Maintain cleanliness on the irrigation canals. Keep the surroundings of your farm free of weeds, unless they are maintained

and intended as habitats for natural enemies. Regularly clean farm tools. Use green manure which chokes out weeds. Use intercropping. Hand weeding and composting (do not compost weeds that have flowered and

set Hoeing, mowing, and cutting.

Forage legumes: Alfalfa/Lucerne, Clovers, Vetches, TrefoilsCurculios and Weevils: Alfalfa Snout Beetle (Otiorhynchus ligustici)

Alfalfa seed weevil (Tychius aureoles)

A Fungal disease infects weevils and several tiny wasp species parasitize weevil larvae and provide a level of control.

After weevil larvae are present, monitor every 2-4 days. Use early cutting of the plant at the bud stage if weevil damage seems

imminent. Closely monitor alfalfa re-growth for the second cutting to detect feeding

damage.

malathion

Tree Nuts: Walnut, HazelnutBrown Marmorated Stink Bug (BMSB, Halyomorpha halys) Note: BMSB also attacks grapes, corn, cane berries, orchard fruits and some vegetables

Collect and destroy BMSB adults that congregate on man-made structures (houses, barns, outhouses) in the fall.

Place BMSB aggregation pheromone traps on sides of the orchard facing woodlots or human structures (where they overwinter), to monitor spring movement of adults, and summer presence of nymphs.

Biocontrol: BMSB-specific egg parasitoids from northeast Asia, that control BMSB in their natural habitat, have not yet migrated or been introduced into the Caucasus. Some generalist predators may provide a modest level of control.

Action thresholds have not been developed. Any control measures should not be initiated until bugs are present in fields or orchards, and the crop has initiated fruit development.

bifenthrin Note: Synthetic pyrethroids: are highly toxic to aquatic organisms; Do

not use near swamps, streams, ponds, or places with high water tables;

may cause destruction of natural enemies such as arthropod predators and parasitoids that control these and other pests;

may cause outbreaks of secondary pests such as green peach aphids, melon aphids, thrips and spider mites;

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selection for pyrethroid-resistance in pest populations. Some common vegetable pests that have shown resistance to pyrethroids include: diamondback moth, beet armyworm, eastern Colorado potato beetle populations (in USA), western flower thrips, melon aphid, green peach aphid, and corn earworm.

Gypsy moth (Lymantria = Ocneria dispar)

Remove objects around the outside of the home that provide shelter for gypsy moth larvae and pupae, such as flaps of bark, dead tree branches, dead trees, boxes, cans, or old tires.

Use barrier bands, consisting of commercially available double-sided sticky tapes, or sticky material such as Tanglefoot, petroleum jelly, or grease, to prevent larvae from crawling up the trunks of susceptible trees. These products should be applied to the surface of an impermeable material, such as duct tape or tar paper, and not applied directly to the bark.

Bacillus thuringiensis/BT, subsp. kurstaki

Fall webworm (Hyphantria cunea)

Hand removal and destruction of webbing nests in fall. On small trees, cut out and destroy infested twigs.

Bacillus thuringiensis/BT, subsp. kurstaki

Caterpillars: Leaf-tiers (Machimia tentoriferella), Leaf-rollers (Calpodes ethlius and Choristoneura rosaceana),

Can use pheromone traps to monitor. Sanitation: destroy dropped leaves.

Bacillus thuringiensis/BT, subsp. kurstaki

spinosad

Aphids: Filbert aphid (Corylobium avellanae)

Maintain adequate soil moisture and fertilization (Plants stressed for water or nutrients are more susceptible to and suffer greater damage from aphids). Do not over-fertilize with nitrogen.

Use regular monitoring, yellow sticky trapsA.

horticultural oils spirotetramat flupyradifurone

Filbert big bud mites (Phytocoptella (syn.Phytoptus) avellanae)

Maintain proper plant watering and nutrition for a vigorous plant. Collect and burn infested buds in winter.

narrow range horticultural oils fenpyroximate clofentezine etoxazole pyridaben, spirodiclofen

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BlueberryLeafrollers (Choristoneura rosaceana and others)

Use pheromone traps to monitor for adult moths. Consider control if more than 5% of the terminal growth and floral parts have

larvae or larval damage. Pruning effectively will help reduce leafroller numbers by removing over

wintering sites Sanitation: Do weeding in and near fields to remove alternate hosts for this

pest.

Bacillus thuringiensis/ BT, subsp. kurstaki

Chafers: adult beetles feed on foliage and white C-shaped grubs feed on roots (Macrodactylus subspinosus, Japanese beetle, Popillia japonica and oriental beetle, Anomala orientalis)

Treatment of nearby lawn areas should reduce the numbers of beetles. Reduce or fully compost all organic material used around blueberry plants.

imidacloprid malathion

Weevils: Plum curculio (Conotrachelus nenuphar), Cranberry weevil/ blueberry blossom weevil (Anthonomus musculus)

Sanitation: Clean cultivation and destruction of trash on surrounding land helps reduce the number overwintering.

Remove any wild blueberries that are nearby.

malathion Steinernema feltiae

Blueberry maggot (Rhagoletis mendax)

In small plantings, it may be possible to control this pest with yellow sticky traps.

malathion

Mummy berry (Monilinia vaccinii-corymbosi)

The blueberry varieties Jersey, Dixi, Darrow, Collins, and Bluetta are considered resistant.

Sanitation and culture are very important for disease control and help to avoid the buildup of the fungus.

If possible, rake and remove mummified berries from the vicinity of the planting.

Alternative measures include covering fallen mummies with approximately 2 inches of soil or mulch or disking the soil beneath the planting to bury the mummies. These steps should be completed before budbreak.

fludioxonil

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Botrytis blight and berry rot (Botrytis cinerea)

Pruning and removing any dead twigs or branches during the dormant season. Cultural practices such as adjusting soil pH and avoiding over-fertilization

(rapidly growing, over-fertilized shoots are prone to infection) help to minimize the effects of this disease.

Tea tree oil fenhexamid fludioxonil fluazinam

StrawberryClick beetle/Wire worm (Agriotes species)

Avoid planting in fields with a history of wireworm damage. Avoid planting strawberries in fields immediately following clover, grass,

pasture, or weedy alfalfa. Summer fallow will reduce wireworm numbers by drying the soil. Low-lying, sandy fields tend to have the most problems, and click beetles

seem to return to the same fields to lay eggs. Use good soil tillage practices.

imidacloprid thiamethoxam

June beetle/White grub (Phyllophaga species)

Soil solarization and tillage. Light trapping of adults. Sanitation: Remove crop residues.

Beauveria bassiana imidacloprid thiamethoxam

Mites: Red mite/Two-spotted spider mite (Tetranychus urticae) andCarmine spider mite (Tetranychus cinnabarinus)

Preplant chilling (vernalization) directly promotes plant vigor. Fall transplant, nursery location, preharvest chilling, nursery harvest date, and length of pretransplant supplemental cold storage can all affect a plant's vernalization.

Use proper planting density. Can release predatory mites Phytoseiulus persimilis to control spider mites. Do weed control in and around field.

sulfur narrow range horticultural oils. etoxazole fenpyroximate spiromesifen

Slugs (Arion hortensis, Deroceras reticulatum and other species)

Sanitation: Clean up and destroy all plant debris, and remove rocks, boards and logs where slugs hide.

Trapping with buried gallon plastic containers containing beer, with 1 trap every 3 meters.

Remove boards, stones and things that slugs hide under.

metaldehyde

Anthracnose fruit rot (Colletotrichum sp.)

Use drip irrigation and clean planting stock. Use good cultural practices to prevent disease inoculum from entering field. Use soil solarization. Use crop rotation to non-host plants. Sanitation: Wash all soil off plant crowns before transplanting and clean soil

off all equipment from one field to another. Remove and destroy all weed remains.

Remove crop residues and do annual plantings.

azoxystrobin cyproconazole fludioxonil yrimethanil

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Gray mold (Botrytis species)

Use resistant cultivars. Do regular monitoring for gray mold. Use sanitation: Clean up and destroy crop residues. Avoid over-head sprinkler irrigation.

Tea tree oilfludioxonil yrimethanil

Beets (fodder and sugar)Turnip moth (Agrotis = Scotia segetum)

Removal of weeds in and around fields will reduce egg-laying sites and will help in the prevention of cutworm infestation. Do this at least 2-3 weeks before planting to reduce the incidence of cutworm larvae transferring to newly planted crops.

Interplant main crops with onion, garlic, peppermint, coriander, or garlic every 10-20 rows to repel cutworms.

Use pheromone traps. Sunflowers and cosmos can also be planted as a trap crop in or around fields. Plow and harrow fields properly before planting. This will destroy eggs and

expose larvae to chicken, ants, birds, and other predators.

Bacillus thuringiensis/BT, Strain Kurtaski

Beauveria bassiana

Sugar beet flea beetle (Chaetocnema breviuscula)

Sanitation: Keep fields and field margins free from weeds, especially mustards and field bindweed.

Heavily damaged fields may require re-planting.

imidacloprid

Sugarbeet weevil (Bothynoderes (= Asproparthenis) punctiventris)

Weevil parasitoids exist and exert significant control. Plant a parsley trap crop to attract and destroy with cultivation. Clean weeds from field and field margins. Use crop rotation to non-Umbellifers. Sanitation: Disc or plow under parsley after first cutting.

spinosad thiamethoxam imidacloprid

Sugar beet root aphid (Pemphigus fuscicornis)

A fungus and a fly larva generally provide good control of sugarbeet root aphid.

Use proper irrigation and avoid water stress. Sanitation: Clean up and destroy all weeds (especially redroot pigweed and

lambsquarters) and in and around field and beet roots left in field after harvest.

Crop rotation: Rotate out of sugar and table beets, spinach and chard for 3 years.

Clean all equipment and implements before moving from an infested to a non-infested field.

flupyradifurone

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fabae) Use resistant varieties. Field disking and destruction of crop residues are important for control of

aphid pests of leafy vegetables to reduce their migration into nearby crops.

acetamiprid flupyradifurone

Beet leaf miner (Pegomyia hyoscyami)

Sanitation: Control weeds in and around field. Do crop monitoring. Use crop rotation.

spinosad

Sugar beet cyst nematode (Heterodera schachtii)

Use resistant cultivars. Striving for optimum growing conditions by addressing plant stress factors

such as soil moisture, nutrition, insect pests, and other diseases may minimize nematode damage.

Monitor and positively identify the nematode species present. Clean soil from equipment with water before moving from infested to

noninfested fields. Clean fallow and green manure will help to reduce populations of root knot

nematodes. Growing cover crops of oats (cv. Saia), marigolds, rattlebox (Crotalaria spectabilis), hairy indigo (Indigo hirsuta) is known to reduce populations of plant parasitic nematodes.

Deep plowing, fallowing, and solarization can further reduce nematode population levels.

Not economical or safe for smallholder farmers to control with synthetic nematicides.

Instead, do “biofumigation” of the soil by growing, shredding and plowing under crucifers, and covering the soil with plastic, if available, until just before planting crop. Rotting crucifers produce toxic gasses that kill nematodes, and covering with plastic increases efficacy.

Zonate leaf spot (Phoma betae)

Use resistant varieties and clean, certified and hot water treated seed. Ensure good soil drainage. Sanitation: Remove and destroy weeds and crop residues at end of season.

copper oxychloride copper sulfate (basic) Bacillus subtilis, Strain QST-713

Oil Crop: Rape Seed/CanolaRape Bug (Eurydema oleracea)

Maintenance of crop rotation with spatial and temporal isolation of cruciferous crop plantations.

Destruction of cruciferous weeds before their flowering on fields, near fields, and on waste grounds.

malathion

Rape Pollen Beetle (Meligethes aeneus)

Eradication of weeds in and around field. Sanitation: Winter plowing to destroy plant residues. A trap crop of turnip rape (Brassica rapa var. silvestris) sown as a perimeter

strip of 6 to 12 m within the rape and then destroyed by plowing under traps and destroys beetles.

Not economical to spray this pest.

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Annex 2: Guidelines for PMPs for Georgia Crops and Beneficiaries & Elements of IPM Program

What is a PMP43?

Pest Management Plans or Guides provide field crop, livestock production or project decision-makers – farmers and farm managers – with best production practices recommendations, usually adapted by region, crop phenology and seasons. The aims of PMPs are to reduce the risks to production from pests by using a combination of best practices, including IPM, IVM and Integrated Weed Management (IWM), that maximize crop or livestock health, and thus resilience to or tolerance of pests, and without an over-reliance on pesticides needed when best practices are not followed. Thus, prevention of pests plays a strongly pivotal role in the PMP, followed closely by management of pests when prevention alone is not adequate for the level of control needed or desired.

Who are the PMP’s intended audiences and users?

Farm land preparation and crop production decision-makers Farmers Farm managers

Why is a PMP being done?

PMP Objectives:

Prevent or reduce pest damage risk to agricultural production or health Protect the health of farmers, farm family members, laborers and community members from

pesticide risks Maintain economically sound practices Reduce environmental pollution and degradation risks Enhance the overall quality and quantity of biodiversity on the sustainable farm work

environment Respond to foreign market demand for the use of agriculture sector best management practice

standards, also called Good Agriculture Practices (GAPs) which include IPM measures, to achieve farm and produce certification

Comply with local, regional, donor and international laws, conventions, and regulations

Organization of the PMP

The following pieces of crop- or livestock-specific background information are used to build a PMP base

General information on the crop/livestock/sector Crop/livestock common/species names: Crop/livestock developmental stages: Production regions and how they differ by soil type, pH, fertility, etc Overall concerns and priorities for crop/livestock production

43 PMPs or Year-Round (seasonal) IPM Programs are state of the art in many developed countries, and they help institutionalize IPM in planning and practice. PMPs provide agriculture managers and farmers with a tool to predict and prevent many crop pests of each crop throughout a season. See examples of PMPs at http://www.ipm.ucdavis.edu/PMG/crops-agriculture.html, with a green check mark next to the crop. identifies a “Year-Round IPM Program” for that crop.

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Crop/livestock cultural best practices Crop/livestock Good Agriculture Practices (GAPs) including some IPM (see PERSUAP section

on GAPS and IPM) recommendations

Individual Pest Prevention and Management Sections for each of the following pest types:

Invertebrate (Insects, Mites, Slugs/Snails, Nematodes) Diseases (Fungi, Bacteria, Viruses, Other) Weeds (annual grasses, broadleaves, perennial grasses, broadleaves, sedges, others) Vertebrates (birds, rodents, other)

For each pest type, first, identify overall priorities for pest prevention and management in the target crop or livestock.

Next, identify individual pest species noting the type of damage incurred; part of plant damaged: roots/rhizomes/tubers, stems/stalks, leaves, florescence, or seeds (field or stored); or if livestock, part of animal affected.

To best understand how to manage a pest, one needs to understand how, where, when and on what the pest parts of the plant or animal feeds. For field pests and stored grain/food pests, many PMPs are designed and outlined as follows, for each major species of pest (insects, mites, slugs/snails, nematodes):

Photographs of each pest, life stages Photographs of plant or livestock damage Description of the pest, life cycle and survival strategies44: Description of damage symptoms Best Prevention Practices

o Use any and all of the above GAPs including IPM o Country or region-specific information

Best Management Practiceso Focus on prevention (above) o Country or region-specific information

Information on PMP-recommended pesticides:

Information needed for each pesticide referenced in the above PMP, by pest (so the farmer/farm manager has the information at their fingertips and do not need to refer to other documents and tables to find it):

Pesticide essential information needed

AI name Product Trade names (with EPA and WHO Acute Toxicity Classifications in parenthesis) Amounts to use per hectare Price Pre-Harvest Interval (PHI) Special comments on best application methods and frequency

44 Survival strategies: All pests have survival strategies that allow them to live and breed in each crop’s farming systems. Knowing the survival strategies, including overwintering habit and alternate host plants, that are employed by the pest can help with decision making at the farming systems-level (e.g. choice of rotation crops) and also can help to anticipate pest outbreaks.

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Any resistance management strategies needed Pesticide application record sheet Guidelines for reducing spray drift Re-entry interval (REI): field safe re-entry period after spraying Maximum residue levels (MRL) permitted by markets Pesticide precautions with use including Reading the label Legal responsibilities and permitted registration uses Permit requirements for possession and use Recommended and obligated use of PPE and best practices First aid and antidotes Transportation best practices Storage best practices Safe use best practices Container disposal best practices Leftover pesticide disposal best practices Protection of non-pest animals, plants, endangered species and water body quality Protect natural enemies & honeybees: http://www.ipm.ucdavis.edu/PMG/r584310111.html Posting signage in treated fields Some chemicals not permitted on processed crops Potential for phytotoxicity (crop injury) on some crops Documentation and record-keeping on farms

Information needed on Natural Enemies of Pests:

Common Names of Predators and Parasitoids effective against above pests: For a list of common natural enemies of crop pests, see http://www.ipm.ucdavis.edu/PMG/NE/index.html. Genera will likely be the same around the world, with different species in different continents, filling similar niches.

Additional Information Needed:

Will there be an IPM Coordinator, an IPM Advisory Committee, Education and Licensing for Applicators, Currency and Approval of the PMP?

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Annex 3: Elements of IPM Program

Although farmers are likely using numerous IPM tactics, without really calling them that, IPM philosophy or planning is not generally an active part of crop production in most emerging market countries; thus, a basic understanding of the steps or elements needed in an IPM program are addressed below, as formulated by FAO45.

Step 1: Learn and value farmers’ indigenous IPM tactics.Most farmers are already using their own forms of GAPs and IPM, many of which are novel, self-created, adapted for local conditions, and many of which work well. These local tools and tactics need to be well understood and taken into account when making PMPs. Accurate assessments of these farmers’ GAP and IPM technologies, as well as an understanding of actual losses due to different constraints in farmers’ fields are required before designing a crop production and pest management program. Standards and Certification (S&C) farmers will have records of historical pesticide use and trends, as well as information on current use of artisanal or local IPM tactics.

Step 2: Identify key pests for each target crop. Although perhaps up to ten species of pests may impact a crop and yields at different plant growth stages, generally only two or three are considered serious enough to spend money controlling. Farmers should be encouraged to monitor their population size, their life cycle, the kind of damage they cause and actual losses. Note that crop loss figures based on farmers’ perceptions of damage and loss are often overestimated.

Step 3: Evaluate all management options. Use of best management practices, preventive measures, and “organic” options to control pest impacts may eliminate the need for synthetic pesticides.

Step 4: Choose IPM methods; identify Needs, and Establish Priorities.Continue dialog with project field staff, ministry extension staff and farmers when choosing methods to be used. Consider the feasibility of attractive methods, including the availability of resources needed, farmers’ perceptions of pest problems, their abilities to identify pests, their predators, diseases and parasitoids, and to act upon their observations.

Step 5: Do effective activities and training to promote IPM.Next, identify strategies and mechanisms for fostering the transfer of the needed IPM technology under various project and institutional arrangements, mechanisms, and funding levels. Define what is available for immediate transfer and what may require more adaptation and validation research. Set up an initial planning workshop (with a COP-supported and signed Action Plan) to help define and orient implementation activities, and begin to assign individual responsibilities.

Learning-by-doing/discovery training programs

The adoption of new techniques by small-, medium- and large-holder farmers occurs most readily when program participants acquire knowledge and skills through personal experience, observation, analysis, experimentation, decision-making and practice. At first, frequent (usually weekly) sessions are conducted for 10–20 farmers during the cropping season in farmers’ fields by trained instructors or extension agents.

45 http://www.fao.org/docrep/006/ad487e/ad487e02.htm; http://en.wikipedia.org/wiki/Farmer_Field_School; http://www.ipm.ucdavis.edu/PMG/crops-agriculture.html

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Smallholder support and discussion groups

Weekly meetings of smallholders, held during the cropping season, to discuss pest and related problems can be useful for sharing the success of various control methods. However, maintaining attendance is difficult except when there is a clear financial incentive (e.g., credit, advance knowledge of nearby infestations for early action leading to yield improvement).

Educational material

In many countries, basic written and photographic guides to pest identification and crop-specific management techniques are unavailable or out of date. Videos featuring graphic pictures of the effects of acute and chronic pesticide exposure, and interviews with poisoning victims can be particularly effective.

Youth education

Promoting and improving the quality of programs on IPM and the risks of synthetic pesticides has been effective at technical schools for rural youth. In addition to becoming future farmers, these students can bring informed views back to their communities.

Food market incentives (especially important in the last decade)

Promoting Organic, GlobalGAP, BRC, Fair Trade or other certification for access to the lucrative and rapidly growing S&C systems-driven international and regional food markets can be, and is, a strong incentive to adopt IPM.

Step 6: Partner successfully with other IPM implementers.The following design steps are considered essential.

Articulate the partnership’s vision of IPM

Organizations may forge partnerships based on a common commitment to “IPM” – only to discover too late that that their visions of IPM differ considerably. It is therefore highly important that partners articulate a common, detailed vision of IPM, centered on the crops and conditions the project will encounter.

Confirm partner institutions’ commitment

The extent of commitment to IPM integration into project, design, and thus implementation depends strongly upon the following key variables:

IPM program integration into larger project. The IPM program is likely to be part of a larger “sustainable agriculture” project. The IPM program must fit into a partner’s overall goals. The extent of this integration should be clearly expressed in the proposed annual work plan.

Cost sharing. The extent of funds (or in-kind resources) is a good measure of a genuine partner commitment.

Participation of key IPM personnel. Organizations should have staff with expertise in IPM. In strong partnerships, these staff members are actively involved in the partnership.

Step 7: Monitor the fields regularly.

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At minimum twice a week, farmers should monitor their fields for pests, as some pest populations increase rapidly and unexpectedly; this increase is usually related closely to the stage of crop growth and weather conditions, but it is difficult to predict the severity of pest problems in advance.

Step 8: Select an appropriate blend of IPM tools.A good IPM program draws from and integrates a variety of pest management techniques, like those presented in the above list. Flexibility to fit local needs is a key variable. Pesticides should be used only if no practical, effective, and economic non-chemical control methods are available. Once the pesticide has been carefully chosen for the pest, crop, and environment, it should be applied only to keep the pest population low, not necessarily eliminate it.

Step 9: Develop education, training, and demonstration programs for extension workers.Implementation of IPM depends heavily on education, training, and demonstration to help farmers and extension workers develop and evaluate the IPM methods. Hands-on training conducted in farmers’ fields (as opposed to a classroom) is a must. Special training for extension workers and educational programs for government officials and the public are also important.

Step 10: Monitoring, Record-Keeping and Evaluation (M&E).Develop data collection forms and checklists, collect baseline GAP/IPM data at the beginning of the project, and set targets.

For the use and maintenance of Good Agriculture Practices (that include safe pesticide storage, use and disposal), maintain farm or project files of: farmer and farm employee training records certification; farm soil, water, biodiversity, cropping and pesticide use maps; pesticide purchase and stock records; price increases or decreases, chemical application instructions including target pest, type of chemical applied, dosage, time of spray, rates at which pesticides were applied, harvest interval days, application machinery, PPE required and used, and any special instructions on mixing, exposure to children or dangers.

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Annex 4: Acute Toxicity of Pesticides: EPA and WHO Classifications

General Toxicity

Pesticides, by necessity, are poisons, but the toxicity and hazards of different compounds vary greatly. Toxicity refers to the inherent intoxicating ability of a compound whereas hazard refers to the risk or danger of poisoning when the pesticide is used or applied. Pesticide hazard depends not only on toxicity but also on the chance of exposure to toxic amounts of the pesticide. Pesticides can enter the body through oral ingestion, through the skin or through inhalation. Once inside the body, they may produce poisoning symptoms, which are either acute (from a single exposure) or chronic (from repeated exposures or absorption of smaller amounts of toxicant).

EPA and WHO Toxicity Classifications

Basically, there are two systems of pesticide toxicity classification. These are the USEPA and the WHO systems of classification. It is important to note that the WHO classification is based on the active ingredient only, whereas USEPA uses product formulations to determine the toxicity class of pesticides. So, WHO classification shows relative toxicities of all pesticide active (or technical) ingredients, whereas EPA classification shows actual toxicity of the formulated products, which can be more or less toxic than the active ingredient alone and are more representative of actual dangers encountered in the field. The tables below show classification of pesticides according to the two systems.

a) USEPA classification (based on formulated product = active ingredient plus inert and other ingredients)

Class Descriptive term Mammalian LD50 Mammalian

Inhalation

LC50

Irritation Aquatic invert/fish (LC50 or EC50)2

Honey bee acute oral (LD50)

Oral Dermal Eye1 Skin

I Extremely toxic 50 200 0.2 Corrosive Corrosive < 0.1

II Highly toxic 50-500 200-2000 0.2-2.0 Severe Severe 0.11-1.0 < 2 µg/bee

III Moderately toxic 500-5000 2000-20000 2.0-20 No corneal opacity

Moderate 1.1-10.0 2.1-11 µg/bee

IV Slightly toxic 5000 20000 20 None Moderate or slight

10.1-100

Relatively non-toxic 101-1000

94

DCN: 2017-GEO-022Practically non-toxic

1001-10,000 > 11 µg/bee

Non-toxic > 10,000

1 Corneal opacity not reversible within 7 days for Class I pesticides; corneal opacity reversible within 7 days but irritation persists during that period for Class II pesticides; no corneal opacity and irritation is reversible within 7 days for Class III pesticides; and Class IV pesticides cause no irritation2 Expressed in ppm or mg/l of water

b) WHO classification (based only on active or ‘technical’ ingredient)

Class Descriptive term

Oral LD50 for the rat (mg/kg body wt)

Dermal LD50 for the rat (mg/kg body wt)

Solids Liquids Solids Liquids

Ia Extremely hazardous 5 20 10 40

Ib Highly hazardous 5-50 20-200 10-100 40-400

II Moderately hazardous 50-500 20-2000 100-1000 400-4000

III Slightly hazardous 501 2001 1001 4001

U Unlikely to present acute hazard in normal use 2000 3000 - -

95

DCN: 2017-GEO-022

Annex 5a: Analyses of Active Ingredients in Pesticides Registered in Georgia and Approved by this PERSUAP

Introduction to Annex 5, below

Annex 5 below compiles the AIs in pesticides (natural and synthetic) registered for use in Georgia, as evaluated and approved by this PERSUAP. Pesticide AIs rejected by this PERSUAP analysis are at the end of the document in Annex 11. Project field technical decision-makers—especially those who interface at the field level with beneficiary farmers—are encouraged to look at the label of potential pesticide choices to determine the recommended uses, dosages and cautions. AIs contained in them and then use this Annex as a quick reference guide to human and environmental acute and chronic attributes and issues with each chemical.

The pesticide attributes include pesticide class (to manage resistance by rotating chemicals from different classes), EPA registration and Restricted Use Pesticide (RUP) status (to comply with Regulation 216) and acute toxicity (judged by this document to be safe, or not, for smallholder farmers—most Class I chemicals are not considered safe for smallholder farmers to use). Annex 5 also presents chronic health issues, water pollution potential, and potential toxicities to important non-target organisms like fish, honeybee pollinators, birds and several aquatic organisms.

Further, Annex 5 contains basic pieces of human safety and environmental data needed for the various analyses required throughout the PER 12-factor analysis; ergo it is referred to throughout this document. Thus, this PERSUAP provides useful tools for evaluating and choosing among IPM options, including natural and synthetic pesticides, while adhering to 22 CFR 216.

Key to Annex 5 matrix, below:

RUP: Few = one or two products; Some = a third of products; Most/All = most or all products containing the AI are labeled RUP by EPA

WHO Acute Toxicity Classes: O = Obsolete; Ia = Extremely Hazardous; Ib = Highly Hazardous; II = Moderately Hazardous; III = Slightly Hazardous; U = Unlikely to present acute hazard in normal use

EPA Acute Toxicity Classes: I = Extremely Toxic; II = Highly Toxic; III = Moderately Toxic; IV = Slightly Toxic

Chronic Human Toxicity: KC = Known Carcinogen; PC = Possible Carcinogen; LC = Likely Carcinogen; ED = Potential Endocrine Disruptor; RD = Potential Reproductive & Development Toxin; P = Parkinson’s Disease Risk

Ecotoxicity: NAT = Not Acutely Toxic; PNT = Practically Not Toxic; ST = Slightly Toxic; MT = Moderately Toxic; HT = Highly Toxic; VHT = Very Highly Toxic

Reference websites used to find pieces of data contained in Annex 5: See references at the end of the report, Annex 10.

96

DCN: 2017-GEO-0222017 Georgia PERSUAP-approved Insecticide Ais

Reg 216 Factors E & G: Ecotoxicity, Non-target ImpactsInsecticide Active Ingredients proposed for control of crop pest and thus proposed for Reg 216 analysis

Reg 216, Factor I Availability of Other Pesticide Options: AI chemical classes for rotation to avoid development of resistance, and reduction of effectiveness (Factor F)

Reg 216, Factor A

: Is AI EPA

R

egistered?

Reg 216, Factor A

: Any R

estricted U

se Pesticides with this A

I?

Reg 216, Factor A

: Is AI R

egistered in EU

?

Reg 216 Factor E: W

HO

Acute

Toxicity Class

Reg 216 Factor E: EPA

Acute

Toxicity Classes

Reg 216 Factor E: C

hronic Toxicity

Reg 216 Factors G

& H

(Non-target

ecosystem, H

ydrology): G

roundwater contam

inant

fish

bees

birds

amphibians

worm

s

Mollusks

Crustaceans

Aquatic Insects

Plankton

acetamiprid neonicotinoid yes no yes NL II, III NL no data NAT MT HT NAT

Bacillus thuringiensis kurstaki/BT microbial yes no yes III II, III NL no data MT PNT NAT NAT ST STBeauveria bassiana microbial yes no yes NL III NL no data NAT NAT NAT NAT NATbifenthrin (also miticide) synthetic pyrethroid yes some yes II II, III PC, ED, RD no data VHT HT MT HTdimethoate (also miticide) organophosphate yes few yes II II, III PC, ED, RD potential ST VHT VHT HT MT VHT HT VHT MTfenpyroximate (also miticide) pyrazole yes no yes NL II NL no data HT MT MT MT HTflupyradifurone butenolide yes no yes NL III NL no data MT ST MT MT MT

horticultural oil (also miticide) mineral yes no yes NL III NL no data NATimidacloprid neonicotinoid yes few yes II II, III NL potential NAT MT VHTindoxacarb oxadiazine yes no yes O II, III NL no data MT HT HT NAT MTmalathion organophosphate yes no yes III II, III PC, ED potential MT HT MT HT ST VHT MT VHT HTspinosad microbial extract yes no yes U II, III, IV NL no data MT HT PNT ST HT MTspiromesifen (also miticide) keto-enol yes no yes NL III NL no data HT ST MT MTspirotetramat (also miticide) keto-enol yes no yes NL II, III NL no data MT MT MT MT

thiamethoxam neonicotinoid yes no yes NL II, III PC no data PNT HT PNT PNT PNT PNT PNT

2017 Georgia PERSUAP-Approved Miticide AisReg 216 Factors E & G: Ecotoxicity, Non-target Impacts

Miticide Active Ingredients proposed for control of crop pest and thus proposed for Reg 216 analysis

Reg 216, Factor I Availability of Other Pesticide Options: AI chemical classes for rotation to avoid development of resistance, and reduction of effectiveness (Factor F)

Reg 216, Factor A

: Is AI EPA

R

egistered?

Reg 216, Factor A

: Any R

estricted U

se Pesticides with this A

I?

Reg 216, Factor A

: Is AI R

egistered in EU

?

Reg 216 Factor E: W

HO

Acute

Toxicity Class

Reg 216 Factor E: EPA

Acute

Toxicity Classes

Reg 216 Factor E: C

hronic Toxicity

Reg 216 Factors G

& H

(Non-target

ecosystem, H

ydrology): G

roundwater contam

inant

fish

bees

birds

amphibians

worm

s

Mollusks

Crustaceans

Aquatic Insects

Plankton

97

DCN: 2017-GEO-022clofentezine tetrazine yes no yes U III PC, RD no data ST PNT ST STdimethoate (also insecticide) organophosphate yes few yes II II, III PC, ED, RD potential ST VHT VHT HT MT VHT HT VHT MTetoxazole diphenyl oxazoline yes no yes NL III NL no data MT NAT MT MT HT MTfenpyroximate (also insecticide) pyrazole yes no yes NL II NL no data HT MT MT MT HT

horticultural oil (also insecticide) mineral yes no yes NL III NL no data NATpyridaben pyridazinone yes no yes II II, III NL no data VHT HT ST MT HT VHTspirodiclofen keto-enol yes no yes NL III PC no data MT HT NAT NAT MT MT MTspiromesifen (also insecticide) keto-enol yes no yes NL III NL no data HT ST MT MTspirotetramat (also insecticide) keto-enol yes no yes NL II, III NL no data MT MT MT MTsulfur (also fungicide) Inorganic yes no yes U II, III NL no data NAT NAT NAT NAT NAT

2017 Georgia PERSUAP-Approved Fungicide Ais

Reg 216 Factors E & G: Ecotoxicity, Non-target ImpactsFungicide Active Ingredients proposed for control of crop diseases and thus proposed for Reg 216 analysis

Reg 216, Factor I Availability of Other Pesticide Options: AI chemical classes for rotation to avoid development of resistance, and reduction of effectiveness (Factor F)

Reg 216, Factor A

: Is AI EPA

R

egistered?

Reg 216, Factor A

: Any R

estricted U

se Pesticides with this A

I?

Reg 216, Factor A

: Is AI R

egistered in EU

?

Reg 216 Factor E: W

HO

Acute

Toxicity Class

Reg 216 Factor E: EPA

Acute

Toxicity Classes

Reg 216 Factor E: C

hronic Toxicity

Reg 216 Factors G

& H

(Non-target

ecosystem, H

ydrology): G

roundwater contam

inant

fish

bees

birds

amphibians

worm

s

Mollusks

Crustaceans

Aquatic Insects

Plankton

azoxystrobin strobin yes no yes U II, III NL potential MT MT MT MT MT VHTBacillus subtilis microbial yes no yes U III, IV NL no data NAT ST NAT NAT NATboscalid carboximide (anilide) yes no yes NL II, III PC no data MT MT MT MT MTcaptan thiopthalamide yes no yes NL I, II, III KC (hi dose) no data HT NAT PNT MT MT NAT MT MTcopper/cupric hydroxide inorganic yes no yes II I, II, III NL no data HT MT MT MT HT NAT HT HTcopper oxychloride inorganic yes no yes NL I, II, III NL no data MT MT MT MT VHTcopper sulfate inorganic yes no yes II I, II, III NL no data MT HT PNT HT HT VHT ST STcymoxanil cyanoacetamid oxime yes no yes III II, III NL no data MT MT ST MT MT MT STcyproconazole azole yes no yes III III PC no data MT MT MT MT MTcyprodinil anilinopyrimadine yes no yes NL III NL potential MT ST MT MT MT MTdifenoconazole azole yes no yes III III PC no data MT MT ST MT MT HTdimethomorph morpholine yes no yes U III NL no data MT MT MT MT STfamoxadone oxazole yes no yes U III NL no data HT MT ST HTfenhexamid hydroxyanilide yes no yes U III NL potential MT MT MT MT MT MTfluazinam phenylpyridinamine yes no yes NL II, III PC no data VHT MT MT MT MTfludioxonil phenylpyrrole yes no yes U II, III NL potential MT MT MT MT MTflutriafol triazole yes no yes III III ED potential MT MT LT MT MTfluxapyroxad pyrazolium yes no yes NL III, IV NL no data MT NAT NAT NAT MTfosetyl aluminum unclassified yes no yes NL II, III NL potential NAT ST ST MT NAT MTiprodione dicarboximide yes no yes U II, III PC, ED potential MT NAT ST HTkresoxim-methyl strobin yes no yes U III PC potential ST ST ST MT MT VHTmancozeb dithiocarbamate yes no yes U III PC, ED, RD no data MT MT ST HT NATmandipropamide mandelamide yes no yes NL III, IV NL no data MT MT ST MT MT

98

DCN: 2017-GEO-022mefenoxam phenylamide yes no yes II II, III NL no data MT NAT MT MT MT

2017 Georgia PERSUAP-Approved Fungicide AIs, cont.Reg 216 Factors E & G: Ecotoxicity, Non-target Impacts

Fungicide Active Ingredients proposed for control of crop diseases and thus proposed for Reg 216 analysis

Reg 216, Factor I Availability of Other Pesticide Options: AI chemical classes for rotation to avoid development of resistance, and reduction of effectiveness (Factor F)

Reg 216, Factor A

: Is AI EPA

R

egistered?

Reg 216, Factor A

: Any R

estricted U

se Pesticides with this A

I?

Reg 216, Factor A

: Is AI R

egistered in EU

?

Reg 216 Factor E: W

HO

Acute

Toxicity Class

Reg 216 Factor E: EPA

Acute

Toxicity Classes

Reg 216 Factor E: C

hronic Toxicity

Reg 216 Factors G

& H

(Non-target

ecosystem, H

ydrology): G

roundwater contam

inant

fish

bees

birds

amphibians

worm

s

Mollusks

Crustaceans

Aquatic Insects

Plankton

metalaxyl benzanoid yes no yes III II, III NL potential ST PNT PNT STmyclobutanil azole yes no yes III I, II, III RD no data MT ST MT MT MT HTpropamocarb hydrochloride carbamate yes no yes NL III NL potential MT MT MT MT MTpropiconazole azole yes no yes II II, III PC, RD potential MT MT ST MT MTpyraclostrobin strobin yes no yes NL II, III NL no data ST MT MT MT HTpyrimethanil anilinopyrimidine yes no yes U III PC, ED no data MT PNT MT MT MT MTsulphur inorganic yes no yes U II, III NL no data NAT NAT NAT NAT NATtebuconazole azole yes no yes III II, III PC potential MT MT MT MT MT MT HTthiram (diothio) carbamate yes no yes III I, II, III ED, RD no data HT NAT PNT VHT HT NAT HT HTtrifloxystrobin strobin yes no yes NL II, III NL no data ST ST MT MT

99

DCN: 2017-GEO-0222017 Georgia PERSUAP-Approved Herbicide AIs

Reg 216 Factors E & G: Ecotoxicity, Non-target ImpactsHerbicide Active Ingredients proposed for control of weeds of crops and thus proposed for Reg 216 analysis

Reg 216, Factor I Availability of Other Pesticide Options: AI chemical classes for rotation to avoid development of resistance, and reduction of effectiveness (Factor F)

Reg 216, Factor A

: Is AI EPA

R

egistered?

Reg 216, Factor A

: Any R

estricted U

se Pesticides with this A

I?

Reg 216, Factor A

: Is AI R

egistered in EU

?

Reg 216 Factor E: W

HO

Acute

Toxicity Class

Reg 216 Factor E: EPA

Acute

Toxicity Classes

Reg 216 Factor E: C

hronic Toxicity

Reg 216 Factors G

& H

(Non-target

ecosystem, H

ydrology): G

roundwater contam

inant

fish

bees

birds

amphibians

worm

s

Mollusks

Crustaceans

Aquatic Insects

Plankton

bromoxynil-octanoate hydroxybenzonitrile yes no yes II II, III PC, RD no data ST MT MT MT MT VHTcarfentrazone-ethyl triaolinone yes no yes III III NL no data MT NAT NAT MT MT MTclopyralid pyridinecarbxilic yes no yes NL I, II, III NL potential PNT PNT PNT NATdimethenamid-P chloroacetamide yes no yes NL II, III NL no data MT NAT MT MT MT MTfenoxaprop-p-ethyl propionic acid yes no yes NL I, II, III NL no data MT ST PNT ST MT MTflorasulam triazolopyrimidine yes no yes U II, III NL known MT MT MT NAT NATfluazifop-p-butyl propionic acid yes no yes III II, III NL no data MT ST PNT STglyphosate phosphonoglycine yes no yes U II, III NL potential ST ST NAT PNT MT STglyphosate, isopropylamine salt phosphonoglycine yes no NL NL II, III NL potential ST ST NAT ST NAT NAT NATlinuron urea yes no yes U III PC, ED, RD potential MT NAT MT MT ST MT ST MTmetribuzin triazinone yes no yes II II, III ED potential MT NAT MT MT ST STnicosulfuron sulfonylurea yes no yes U II, III NL potential MT MT MT MT MToxyfluorfen diphehyl ether yes no yes U II, III PC no data HT PNT PNT HT HT HTpendimethalin dinitroanaline yes no yes III III, IV PC, ED no data MT NAT ST MT MTrimsulfuron sulfonylurea yes no yes U II, III NL potential NAT MT NAT MT NAT

100

DCN: 2017-GEO-022

2017 Georgia PERSUAP-Approved Molluscicide AIReg 216 Factors E & G: Ecotoxicity, Non-target Impacts

Molluscicide Active Ingredients proposed for control of slug or snail pests and thus proposed for Reg 216 analysis

Reg 216, Factor I Availability of Other Pesticide Options: AI chemical classes for rotation to avoid development of resistance, and reduction of effectiveness (Factor F)

Reg 216, Factor A

: Is AI EPA

Registered?

Reg 216, Factor A

: Any R

estricted Use

Pesticides with this A

I?

Reg 216, Factor A

: Is AI R

egistered in EU?

Reg 216 Factor E: W

HO

Acute Toxicity

Class

Reg 216 Factor E: EPA

Acute Toxicity

Classes

Reg 216 Factor E: C

hronic Toxicity

Reg 216 Factors G

& H

(Non-target

ecosystem, H

ydrology): Groundw

ater contam

inant

fish

bees

birds

amphibians

worm

s

Mollusks

Crustaceans

Aquatic Insects

Plankton

metaldehyde aldehyde yes no yes II II, III PC potential NAT PNT MT PNT PNT HT PNT PNT PNT

101

DCN: 2017-GEO-022

Annex 5b: Compilation of Pesticide AIs and Georgia Registered Products Containing Them and Approved by this PERSUAP

Insecticide AIs and products registered by Georgia, and recommended by this PERSUAP for BEO approval for use in USAID Projects (with the condition that label instructions be followed and that specific conditions for use, shown in parentheses, are followed)

acetamiprid (recommended for use during vegetative growth, not flowering46) (Mosetam 20 WDG; Ace SP; Goldplan 20 Sp; Efdal Afitrid 20 SP; Escape 20 SP; Pascal, 20 SP; Rocket 20 SP; Agroplan 20 SP)

Bacillus thuringiensis/BT, subsp. Kurstaki (Lepidocide SC; Foray 76 SC; Foray 76 B; Lepidin SC)

bifenthrin (also miticide; approved only for emergency use on Brown Marmorated Stink Bug) (Talstar 10 EC, Insakar 10 EC, Zonder 10 EC)

dimethoate (also miticide) (Bi 58; Biital EC; Dingo 40 EC; Bi Fosfini EC; Dimevit EC, Kemidon EC, Alpgor, EC, Fos-Bi, EC, Vertical 40 EC, Bingo, 40 EC; Dumble 40 EC)

fenpyroximate (also miticide) (Ortus 5 SC) flupyradifurone (Sivanto Praime SL 200) horticultural oil (also miticide) (Efdal Sunol EO; Key, EC; EKO OIL SPRAY, EW;

Sipcamol E, EO; Trinol-2; Hektolineum; Agromineral oil, Summer Oil) imidacloprid (recommended for use during vegetative growth, not flowering) (Imidor

Max, WG; Nuprid 600 SC; Sultan SL; Confidor Maxi, WG 70; Sidoprid 600 FS; Confidor SL 200; Resume WS; Gortca WS; Efdal Imidrid 70 WS; Confiprid, WDG; Imidagold 350 SC; Nuprid 200 SL; Gaucho FS 600; Midash WS; Imidor Max, WG)

indoxacarb (Avanti, EK; Kaiser SC) malathion (Malafos EC) spinosad (Spintor, SC) spiromesifen (also miticide) (Oberon 240, SC) spirotetramat (also miticide) (Movento SC 100) Steinernema feltiae (Geo-Nema NSS, Nemycel P)47

thiamethoxam (recommended for use during vegetative growth, not flowering) (Medal, WG; Actara WG; Renova 25 WG)

Miticide AIs and products registered by Georgia, and recommended by this PERSUAP for BEO approval for use in USAID Projects (with the condition that label instructions be followed and that specific conditions for use, shown in parentheses, are followed)

clofentezine (also ovicide—kills mite eggs) (Apollo, SC) dimethoate (also insecticide) (Bi 58; Biital EC; Dingo 40 EC; Bi Fosfini EC; Dimevit EC, Kemidon

EC, Alpgor, EC, Fos-Bi, EC, Vertical 40 EC, Bingo, 40 EC; Dumble 40 EC) etoxazole (Zoom 11 SC) fenpyroximate (also insecticide) (Ortus 5 SC) horticultural oil (also insecticide) (Efdal Sunol EO; Key, EC; EKO OIL SPRAY, EW; Sipcamol E,

EO; Trinol-2; Hektolineum; Agromineral oil, Summer Oil) pyridaben (also insecticide) (Sammaite WP) spirodiclofen (Envidor, SC 240; Smach, SC 240; Contier SC)

46 Spraying during flowering may impact honeybee colonies47 EPA has determined that pest control organisms such as insect predators, nematodes, and macroscopic parasites are exempt from the requirements of FIFRA (40 CFR 152.20(a)). Thus, entomopathogenic nematodes are exempt from registration requirements in the US (https://www.epa.gov/pesticide-registration/pesticide-registration-manual-chapter-3-additional-considerations ).

102

DCN: 2017-GEO-022

spiromesifen (also insecticide) (Oberon 240, SC) spirotetramat (also insecticide) (Movento SC 100) sulfur (also fungicide) (Thiovit Jet WG; Cosavet, 80 WG; Power Sulfur, WG; Sulphex Gold, WG;

Finesulfur 80 WG; Kumulus DF, WG)

Fungicides AIs and products registered by Georgia, and recommended by this PERSUAP for BEO approval for use in USAID projects (with the condition that label instructions be followed and that specific conditions for use, shown in parentheses, are followed)

azoxystrobin (Doris, SC; Azox WG; Qvadris SC) Bacillus subtilis, Strain QST 713 (Serenade ASO SC 1.34%) Beauveria bassiana, Strain Bb-1 (Nostalgist BL, SL)48

boscalid (Cantus, WG; Signum, WG; in a mixture + kresoxim-methyl: Collis, SC) captan (do not use repeatedly without PPE) (Merpan 80 WG; Ondar, WP; Efdal

Captanim 50 WP; Mass Captan, WP; Sim Captan 50 WP) copper/cupric hydroxide (Bordo Flow New SC; Ossiclor 50 WP; Borecaf, WP; Best

Bakir 50 WP; Iroco 40, WG; Champion, WP; Kocaide 2000 WDG; Protect, WP; Hydromicron 77 WP; Funguran OH 50 WP)

copper oxychloride (Cuproflow, SC; Hektas Bakir, WP; Airon, WG; Super Copper, EC; Abiga-Pik, SL; Neoram 37,5 wxgr; Ossiclor 50 WP)

copper sulfate (Cuperval 20 WP; Cuproxat SC; Cuprosulf SG 25; Copper Sulfate, WP; Poltiglia 20 WP; Copper Sulphate P)

cymoxanil (in mixtures + mancozeb: Curzeb 50, WP; Rapid Gold 72, WP; Corz Super 50 WP; Valsalaxyl C Plus, WP; Sprinti 50 WP; Efdal Cymoxazeb 50 WP; Larzep 50 WP; Maxalin, WP; Super Star, WP; Erfruit 50 WP; Cymozeb, WP; Corseb, WP; Rambler 50 WP; Cimo Super 50 WP); (in mixtures + copper oxychloride: Expert Team, WP; Curzate R, WP; Ordan, WP; Efdal Mocan, WP); (in a mixture + metalaxyl: Zakhyst WP); (in a mixture + famoxadone: Tanos, WG)

cyproconazole (in a mixture + difenoconazole: Dividend Star 036 KS) cyprodinil (Chorus WG; Cyipro Plus, WG; Korus 75 WG; Strazh, SC; Carpaz 50 WG;

Atlet 750 WG); (in a mixture, + fludioxonil: Swich 62,5) difenoconazole (Funix 25, EC; Skaf, EC; Scandal 259 EC; Rayok, EC; Efdal Donazole

250 EC; Izoldifecor 250 EC; Scorpi, EC; Story 250 EC; Scorpion 250 EC; Scort 25% EC); (in mixtures: + mandipropamib: Revus Top 500 SC); (in mixtures + propiconazole: Taspa, 500 EC; Harbor 300 EC; Broader 30 EC; Efdal Difenpro 30 EC); (in a mixture + kresoxim-methyl: Samshyt, SC); (in a mixture + cyproconazole: Dividend Star 036 KS)

dimethomorph (in mixtures + mancozeb: Lider, WG; Avangard WP; Efdal Akrobot MZ, WP; Cambaz MZ, WP; Carmen MZ, WP; Actormen MZ, WP; Dimanco 9, 60, WP); (in a mixture: + copper oxychloride: Faighter blu, WP)

famoxadone (in a mixture + cymoxanil: Tanos, WG) fenhexamid (Teldor 50, WG) fluazinam (Nando SC) fludioxonil (in mixtures + thiamethoxam + difenoconazole: Celest top 312,5 FS); (in a

mixture + cyprodinil: Swich 62,5) flutriafol (Foris SC) fluxapyroxad (Sercadis SC) fosetyl aluminum (in a mixture + propamocarb hydrochloride: Previcur Energy SL 840) iprodione (Rovral 50 WP) kresoxim-methyl (Kambit WG; Stroby 500 WG; Strobstar, WG; Efdal Kresdit 50 WG;

Jako 50 WG; in mixtures + boscalid: Collis, SC; + difenoconazole: Samshyt, SC)

48 Note that strain Bb-1 of the biofungicide Beauveria bassiana is not EPA registered; however other closely related strains are. Since it is a biofungicide, with low risks, PERSUAP drafters/reviewers agree that it should be permitted as an additional choice for Georgian farmers.

103

DCN: 2017-GEO-022

mancozeb (Ditan M-45, WP; Sakozebi M-45, WP; Mancosh 80, WP; Valsazeb, WP; Mangrif 75 WG; Draco Blue 80, WP; Mankozate MZ, WP; Efdal maco M-45, WP; Kingcozeb M-45 WP); (in mixtures + cymoxanil: Curzeb 50, WP; Rapid Gold 72, WP; Corz Super 50 WP; Valsalaxyl C Plus, WP; Sprinti 50 WP; Efdal Cymoxazeb 50 WP; Larzep 50 WP; Maxalin, WP; Super Star, WP; Erfruit 50 WP; Cymozeb, WP; Corseb, WP; Rambler 50 WP; Cimo Super 50 WP); Efdal Cymoxazeb 50 WP; Larzep 50 WP; Maxalin, WP; Super Star); (in mixtures + metalaxyl: Trooper 72, sf; Maximo, WDG; Universal, WP; Ridonet MZ 72, WP; Victor WP; Mancolaxyl, WP; Ridozeb MZ 72 WP; Metalaxan, WP; Armetil M, WP; Malzeb, WP; Patamil 72 WP; Efdal Mantalax, WP); (in mixtures + dimethomorph: Lider, WG; Avangard WP; Efdal Akrobot MZ, WP; Cambaz MZ, WP; Carmen MZ, WP; Actormen MZ, WP; Dimanco 9+ 60, WP; Maximum, Wp); (in a mixture + mefenoxam: Ridomil Gold MZ, WG); (in mixtures + cymoxanil + copper oxychloride: Rapid Gold plus, WP)

mandipropamide (in mixtures + copper oxychloride: Pergado C, WG); (in a mixture + difenoconazole: Revus Top 500 SC)

mefenoxam (Apron XL, ES); (in mixtures + tebuconazole: Serticor 50 SC; + mancozeb: Ridomil Gold MZ, WG); in a mixture + copper oxychloride: Ridomil gold plusi 42,5 Wp)

metalaxyl (in mixtures + mancozeb: Maximo, WDG; Universal, WP; Ridonet MZ 72, WP; Victor WP; Ridozeb MZ 72 WP; Metalaxan, WP; Armetil M, WP; Malzeb, WP; Patamil 72 WP; Efdal Mantalax, WP; Mancolaxyl, WP); (in a mixture + copper oxychloride: Metcopper, WP)

myclobutanil (Nimbus 24 EC) propamocarb hydrochloride (Previcur SL 607; Propacurn N, SL; Botrin, SL; Efdal

Procar 722 SL; Evakur SL); (in a mixture + fosetyl-aluminum: Previcur Energy SL 840) propiconazole (Tiltust, EC; Bumper 25 EC; Propconazole, EC; Procure EC); (in

mixtures + difenoconazole: Taspa, 500 EC; Harbor 300 EC; Broader 30 EC; Efdal Difenpro 30 EC)

pyraclostrobin (in a mixture + boscalid: Signum, WG) pyrimethanil (Rhythm, SC; Pyrus 400 SC) sulfur (also miticide) (Thiovit Jet WG; Cosavet, 80 WG; Power Sulfur, WG; Sulphex

Gold, WG; Finesulfur 80 WG; Kumulus DF, WG) Tea tree oil (Timorex Gold EC) tebuconazole (Rodolit Super, EW; Unicorn, WG; Gizmo FS; Rodolit Exttra, WDG;

Raxil Ultra FS 120; Gensil FS 060; Mystic 250 EW; Tebuji 060 FS; Heksil DS 2; Efdal Tebuzol 2 DS); (in a mixture + trifloxystrobin: Nativo 75, WG); (in a mixture + sulfur: Unicorn, WG); (in a mixture + mefenoxam: Serticor 50 SC)

thiram (Thiram Granulflow, WG) Trichoderma harzianum, Strain T-22 (Trianum G, GR)49

trifloxystrobin (Zato WG 50; Tride, WG; Gurador WG)

Herbicide and Plant Growth Regulator (PGR) AIs and products registered by Georgia, and recommended by this PERSUAP for BEO approval for use in USAID projects (with the condition that label instructions be followed and that specific conditions for use, shown in parentheses, are followed)

bromoxynil octanoate (Buctril EC 327.5) carfentrazone-ethyl (Rivet 24, EC) clopyralid (Lion 300 SL) dimethenamid-P (Frontier Optima, EC) fenoxaprop-p-ethyl (Puma Super EW 144)

49 The T. harzianum registered in Georgia (strain T-22) is registered in the US, but coded as KRL-AG2. These two codes are used as synonyms (https://www.law.cornell.edu/cfr/text/40/180.1102).

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florasulam (Belerina SE, Efdal SE) fluazifop-p-butyl (Fusilade-Forte, EC; Brace Super, EC; Fluent, EC; Tangra, EC;

Fluzitop, EC) glyphosate (glyphosan, SL 360; Tornado 500 SL; Glyn, SL; Sonround 48 SL; Roundup

Extra, SL; RoundupMax, SL; Smerch, SL) glyphosate, isopropylamine salt (klini SL; Gliphovit SL; Clean-Up, L; Sanforce 48 SL;

Boxer 48 SL; Rumbo SL 36; Knockdown, SL; Efdal Isofosat, SL) linuron (Afalon 45, SC) metribuzin (Banderilla 70 WP; Barnelaceli 70, WDG; Sencor Liquid SC 600; Surdone

70 WG; Majestic WG; Efdal Mebuzin, WP; Metribuzine 700 g/kg; Antysapa, WG; Antysapa, WG; Laguun 70 WP; Super Cankor WP; Banderilla 70 WP)

nicosulfuron (Eliminator, SC; Nicophuron, SC; Sulfoni, SC 40; Ikanos 40 OD; Miladar, SC; Fullspeed, SC; Efdal Alson, SC; Sunstep SC; Nifuron, SC; Vain, SC; Nikoni SC)

oxyfluorfen (Efdal Ocmost 240 EC; Galaxy 240 EC; Goal 2E, EC; Pekss 24 EC; Paroxyfen 24 EC; Koltar, EC)

pendimethalin (Stomp, EC; Pandora 330 EC; Pendigan 330 EC; Stop EC; Valsatop, EC; Herbimate 330 EC; Panda 330 EC; Efdal Penalin 330 EC; Resort 33 EC; Sponsor 330 E)

rimsulfuron (Pilot, WG; Maize DF; Titus, DS; Eskudo, WG; Weedager, WG; Aisi 642 WG; Arpad, WDG)

Molluscicide AI and products registered by Georgia, and recommended by this PERSUAP for BEO approval for use in USAID projects (with the condition that label instructions be followed and that specific conditions for use, shown in parentheses, are followed)

metaldehyde (Metadex Pellet GR, Pel.; Efdal Kimtoks, GR)

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Annex 6: Training Topics and Safe Pesticide Use Web Resources

GAP/IPM

Pest, predator, parasite, disease identification: How to recognize common important pests and diseases, as well as the predators, parasites and diseases that attack and control them

Monitoring: The importance of frequent crop monitoring for pests, diseases and weeds GAP and IPM concepts, tactics and tools found in Annex 1 that can reduce pesticide use and

associated risks on specific pests of project target crops PMPs—Pest Management Plans: Creating and using these farm crop-management tools

Pesticides

Understanding pesticides: Quality, types, classes and acute toxicities of common pesticides Regulations: US, EU and Georgia laws that guide pesticide registration and use Natural pesticides: Raise awareness of and promote the use of natural pesticides found in Annexes 1,

4, 5 and 7 as well as green-label synthetic pesticides with relatively low risks Spot Treatments: The importance of spot treatments if needed (instead of crop-wide treatments) MSDS: How to use MSDSs for pesticide-specific information on risks and risk reduction measures REI—Re-Entry Intervals: Pesticide-specific risks associated with entering a sprayed field too soon

after the spray operation PHI—Pre-Harvest Interval: Pesticide-specific risks associated with harvesting a crop before

pesticides have had a chance to break down MRL—Maximum Residue Level: Risks associated with pesticide residues on human food Vulnerable individuals: The importance of keeping children, pregnant women, elderly and infirm

away from the field while spraying and kept out after spraying Human and environmental risks: Risks associated with more commonly-used pesticides (use

information from MSDSs and Annex 7) When to spray: Early in the morning, late in the afternoon, or night without wind or rain Use of recommended PPE: Why it is used (see product MSDSs, product labels and web reference

below) Proper use and maintenance of sprayers, including proper sprayer calibration and spray nozzle choice Proper clean-up & post spray hygiene Safe Use: How to purchase, transport, store and use pesticides safely (“safe purchase” requires

quality, brand-name products) Maintenance: of PPE and sprayers Monitoring for the development of pesticide resistance Proper collection and disposal of pesticide rinseate and packaging (see disposal web reference below

and MSDSs) The use of pesticide spray buffer zones near schools, water resources, organic crop production,

apiaries, bird sanctuaries, biodiversity enclaves, national parks or other sensitive areas. How to reduce and mitigate risks to critical environmental resources and biodiversity (found in PER

Factors E and G) Honeybees: Ensuring pesticide applicators notify beekeepers about spray activities, and spray early

morning or late afternoon when no heavy winds or rain are present

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Water Pollution: Raise awareness of pesticides (especially some herbicides) with high ground water contamination potential where water tables are high or easy to reach (use Annex 7 and MSDSs)

Exposure routes: Ways pesticides enter the body and ways to mitigate entry Basic first aid: Understanding how to treat pesticide poisonings (see first aid web reference and

MSDSs) Record-keeping: Pesticide used, when used, which crop, how applied, who applied

Web IPM and Safe Pesticide Use Training Resources

Pesticide poisonings: http://www.aljazeera.com/news/2017/03/200000-die-year-pesticide-poisoning-170308140641105.html

IPM and PMP websites:http://ipm.ucanr.edu/http://edis.ifas.ufl.edu/topic_pest_management

Pesticide Research Websites:http://extoxnet.orst.edu/pips/ghindex.html (Extoxnet Oregon State database with ecotox)http://www.greenbook.net/ (pesticide Material Safety Data Sheets)https://iaspub.epa.gov/apex/pesticides/f?p=PPLS:1 (EPA Registration)

Ecotoxicity:http://alamancebeekeepers.org/wp-content/uploads/2012/01/Hazardous-Pesticides.pdf (pesticide toxicity to honeybees)http://wihort.uwex.edu/turf/Earthworms.htm (pesticide toxicity to earthworms)

Safety:https://www.epa.gov/pesticides/biopesticides (EPA regulated biopesticides)http://ipm.ucanr.edu/index.html (IPM, PMPs and pesticide recommendations)https://www.epa.gov/pesticide-worker-safety/restricted-use-products-rup-report (Restricted Use Pesticides)https://www.epa.gov/safepestcontrol/citizens-guide-pest-control-and-pesticide-safety (EPA Health & Safety)http://www.epa.gov/pesticides/PPISdata/ (EPA pesticide product information)

Personal Protection Equipment (PPE):http://www.dupont.com/products-and-services/personal-protective-equipment/chemical-protective-garments/brands/tyvek-protective-apparel.html http://multimedia.3m.com/mws/media/565206O/3m-cartridge-and-filter-replacement-faqs.pdf

International PIC & POPs Websites:PIC Pesticides and Industrial Chemicals (http://www.pic.int)POPs Pesticides and Chemicals (http://www.pops.int)

Pesticide Container Disposal Options:https://www.epa.gov/pesticide-worker-safety/pesticide-containers

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Annex 7: Farm Record Keeping Form Examples for Pest Management with Pesticides

Agricultural pesticide application detailsWeather details (If product is being sprayed outdoors)

Contact details

Date of application

Product trade name

Application rate Crop/commodity

treated OR situation product was applied

Extent of use (area/volume /weight)

Location where product was used

Wind speed

Wind direction

Name and address of applicator and (if applicable) supervisor

Name and address of person for whom the application was carried out

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Annex 8: Form for projects to monitor farmer best practices including GAP, IPM including pesticide optionsName of Staff Responsible for Monitoring Demonstration Farms:

Name of Demonstration Farmer: Crop: Date:

What are the major pests encountered by the farmer?:

Which of the Preventive and Curative GAP and IPM tools in Annex 1 does farmer use?

Are pesticides used by demo farmer? Yes__ No__

How are pesticides applied? backpack sprayer__ other__

What are the names of the pesticides used?:

Which PPE does farmer have and use? gloves___ overalls___ boots___

respirator___ goggles___

Has the farmer had IPM and Safe Pesticide Use training? Yes__ No__

Are there any empty pesticide containers scattered in the field? Yes__ No__

Are there signs that the backpack sprayer has leaks? Yes__ No__

Does the farmer understand the pesticide label information? Yes__ No__

Is the pesticide stored safely out of the house or away from kids? Yes__ No__

Does the farmer use gloves for mixing the pesticide with water? Yes__ No__

What times of the day are the pesticides applied? ________

Are pesticides applied during rain or windy conditions? Yes__ No__

Are women or children permitted to apply pesticides? Yes__ No__

Are empty pesticide containers are used to store water? Yes__ No__

Does the farmer rinse equipment away from streams and open water? Yes__ No__

Does the farmer wash clothes after applying pesticides? Yes__ No__

How does the farmer dispose of empty pesticide containers? puncture/bury__ burn__

Is there any evidence that pesticides are becoming less effective? Yes__ No__

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Annex 9: Form for projects to monitor risk reduction success and use of BMPs on Projects and report to USAID/Georgia

Potential Environmental Risks & Impacts

Mitigation Measures & BMP (Best Management Practices)

Monitoring Indicators

M & E Responsibility

M & E Reporting Timeline

Pesticide Risks Mitigation of Pesticide Risks

Pesticides BMP Indicators

Pesticides BMP Responsible Staff Member

Frequency of Monitoring, Reporting

Dates by which Action Implemented

Integrated Pest Management (IPM) not known or understood or used

Repeated training and use of IPM

IPM tools and tactics understood and used

Records of trainings.

Project agronomists

Annual Within 6 months of completion of PERSUAP and annually thereafter.

Pest Management Plans (PMPs) not made

Understand pests of each crop, available pest management tools, develop and distribute PMPs.

Provide training on PMP.

Pest Management Plans (PMPs) present at field offices and on farms.

Records of training.

Project agronomists

Project technical staff

Every two years. Within 6 months of completion of PERSUAP, update every two years thereafter, training after each update.

Acute human poisoning leading to death

Training on pesticide risks and use of personal protective equipment (PPE).

Provide and maintain lists of the types of equipment made available to applicators, number of pieces, prices and contact details of suppliers,

All recommended PPE present on demo sites and used.

Training records maintained.

Records of PPE numbered or personally assigned to applicators.

If a pesticide poisoning occurs, immediately inform USAID activity manager.

Project technical manager

Training every 12 months.

Ongoing maintenance of records throughout duration of project.

Immediately and every 12 months thereafter.

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Mitigation Measures & BMP (Best Management Practices)

Monitoring Indicators

M & E Responsibility

M & E Reporting Timeline

Maintain detailed schedules of dates when equipment needs to be washed, maintained or replaced.

Chronic human poisoning leading to future health issues

Train on and use PPE

PPE used during spraying

Project technical staff

Demo Farmers Retailers

Annual training. Continuous use of

PPE.

Immediately and annually thereafter

Groundwater (drinking water) & surface water contamination leading to aquatic ecotoxicity (fish kills)

Training on methods for keeping pesticides out of ground and surface water

Interviewed farmers understand which pesticides have groundwater pollution potential & how to keep pesticides out of water

Project technical staff.

Annual training. Annual interviews

Interviews conducted within 6 months of project start.

Death of pollinator honeybees (from imidacloprid application)

Training on methods for protecting honeybees from spray

Interviewed farmers understand risks to honeybees

Project technical staff.

Annual Interviews conducted within 6 months of project start.

Mass-level local and migratory bird deaths

Training on pesticide choices & selection

Interviewed farmers understand pesticide choices and selection

Project technical staff.

Annual Interviews conducted within 6 months of project start.

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Mitigation Measures & BMP (Best Management Practices)

Monitoring Indicators

M & E Responsibility

M & E Reporting Timeline

criteria Incorrect pest

identification Resistance to

pesticides by pests.

Training on identification of most common pests.

Maintain records of regular field pest monitoring and identification.

Interviewed farmers can positively identify common pests, diseases and weeds.

Training records maintained.

Project technical staff.

Project agronomists, or if trained, beneficiary farmers.

Annual Interviews conducted within 6 months of project start.

Updated PERSUAP not available

All pesticide related activities should follow requirements of the PERSUAP

Updated PERSUAP present

Project technical staff.

Every 1 year. Update PERSUAP within 1 years of project start.

Amended PERSUAP not available

All pesticide related activities should follow requirements of the PERSUAP

Amended PERSUAP present

Project technical staff.

Every 2 years. Amend PERSUAP within 2 years of project start.

Sprayers leak at every parts junction

Training on sprayer maintenance

Sprayers well maintained, not leaking.

Training records maintained.

Project technical staff.

Interviews every 6 months.

Immediately

Use of non-EPA registered pesticides, certain RUP pesticides, Class I pesticides, known carcinogens

Incorrect or improper

Training on banned, prohibited and permitted pesticides.

Translation of list of approved pesticides to local languages.

Distribution of translated list with appropriate

All pesticide Active Ingredients (AIs) EPA registered

No Class I pesticides used (except copper products by certified applicators)

Interviewed farmers

Project technical staff.

Annual Immediately

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Mitigation Measures & BMP (Best Management Practices)

Monitoring Indicators

M & E Responsibility

M & E Reporting Timeline

pesticide selection

graphics. Development of

pesticide checklist with notes on safety requirements.

understand choices & selection criteria

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Annex 10: PERSUAP References

Baker EL, Zack M, Miles JW, Alderman L, Warren M, Dobbins RD, Miller S, Teeters WR (1978) Epidemic malathion poisoning in Pakistan malaria workers. The Lancet, January: 31–33.

Websites: Website references used to develop the Programmatic PERSUAP International Treaties and Conventions:POPs website: http://www.pops.int

PIC Website: http://www.pic.intBasel Convention: http://www.basel.int/

Montreal Protocol: http://ozone.unep.org/new_site/en/montreal_protocol.php

Pakistan malaria poisonings: http://pdf.usaid.gov/pdf_docs/PNACQ047.pdf.

Pesticide poisonings: http://www.aljazeera.com/news/2017/03/200000-die-year-pesticide-poisoning-170308140641105.html

IPM and PMP websites:http://ipm.ucanr.edu/http://edis.ifas.ufl.edu/topic_pest_management

Pesticide Research Websites:http://extoxnet.orst.edu/pips/ghindex.html (Extoxnet Oregon State database with ecotox)http://www.greenbook.net/ (pesticide Material Safety Data Sheets)https://iaspub.epa.gov/apex/pesticides/f?p=PPLS:1 (EPA Registration)

Ecotoxicity:http://alamancebeekeepers.org/wp-content/uploads/2012/01/Hazardous-Pesticides.pdf (pesticide toxicity to honeybees)http://wihort.uwex.edu/turf/Earthworms.htm (pesticide toxicity to earthworms)

Safety:https://www.epa.gov/pesticides/biopesticides (EPA regulated biopesticides)http://ipm.ucanr.edu/index.html (IPM, PMPs and pesticide recommendations)https://www.epa.gov/pesticide-worker-safety/restricted-use-products-rup-report (Restricted Use Pesticides)https://www.epa.gov/safepestcontrol/citizens-guide-pest-control-and-pesticide-safety (EPA Health & Safety)http://www.epa.gov/pesticides/PPISdata/ (EPA pesticide product information)

Personal Protection Equipment (PPE):http://www.dupont.com/products-and-services/personal-protective-equipment/chemical-protective-garments/brands/tyvek-protective-apparel.html http://multimedia.3m.com/mws/media/565206O/3m-cartridge-and-filter-replacement-faqs.pdf

Pesticide Container Disposal Options:https://www.epa.gov/pesticide-worker-safety/pesticide-containers

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Annex 11: Summary of Pesticide AIs Registered in Georgia and Rejected by this PERSUAP Analysis

The following lists contain Fumigant AI in products registered and imported by Georgia but Rejected for Training on, Promotion to, or Use on REAP Demonstration Trials by Smallholder Farmers (with reason for rejection)

aluminum phosphide/ Phostoxin 56% FT (Class I, RUP for all uses—Not safe for smallholder farmer or on-farm use)

Insecticide AIs in products registered by Georgia, and recommended by this PERSUAP for BEO rejection for use in USAID projects (with reason for rejection)

abamectin (also miticide) (RUP) alpha-cypermethrin (RUP) carbosulfan (not EPA registered) chlorpyrifos (not EPA registered for horticultural uses) chlorpyrifos ethyl (not EPA registered for horticultural uses) chlorpyrifos methyl (not EPA registered for horticultural uses) clothianidin (strongly implicated honeybee colony collapse disorder factor) cypermethrin (RUP, not EPA registered for horticultural uses) deltamethrin (RUP) diflubenzuron (RUP for most field horticulture uses) emamectin benzoate (RUP for all horticultural uses) esfenvalerate (RUP) ethoprophos (also nematicide) (RUP) fipronil (RUP) flubendiamide (no longer EPA registered) lambda-cyhalothrin (RUP) lufenuron (only registered by EPA for use on termites, not for field agriculture) metam sodium (also fungicide, nematicide) (RUP) methomyl (RUP for all horticulture uses) methyl-bromide (also nematicide) (Class I, RUP, Montreal Protocol phase-out chemical) oxamyl (also nematicide) (RUP) phosalone (not EPA registered) tau-fluvalinate (not EPA registered for field agriculture) teflubenzuron (not EPA registered) tefluthrin (RUP) thiacloprid (no longer EPA registered) zeta cypermethrin (RUP)

Miticide AIs in products registered by Georgia, and recommended by this PERSUAP for BEO rejection for use in USAID projects (with reason for rejection)

abamectin (also insecticide) (RUP) bromopropylate (not EPA registered) fenazaquin (not EPA registered) propargite (RUP, Class I) tebufenpyrad (no longer EPA registered)

Fungicide AIs in products registered by Georgia, and recommended by this PERSUAP for BEO rejection for use in USAID projects (with reason for rejection)

benalaxyl (not EPA registered)

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bitertanol (not EPA registered) carbendazim (not EPA registered for agriculture) cyflufenamid (not EPA registered) diniconazole (not EPA registered) dimoxystrobin (not EPA registered) dithianone (not EPA registered) epoxiconazole (not EPA registered) fluopyram (not EPA registered) flusilazole (not EPA registered) hexaconazole (not EPA registered) iprovalicarb (not EPA registered) metam sodium (also insecticide, nematicide) (RUP) methyl bromide (also insecticide, nematicide) (RUP, Montreal Protocol phase-out

chemical) metrafenone (not EPA registered) penconazole (not EPA registered) pencycuron (not EPA registered) procymidone (not EPA registered) propineb (not EPA registered) proquinazid (not EPA registered) tolylfluanid (not EPA registered) triadimefon (not EPA registered for agriculture) ziram (Class I, too toxic for smallholder farmers)

Herbicide and PGR AIs in products registered by Georgia, and Recommended by this PERSUAP for BEO rejection for use in USAID projects (with reason for rejection)

2 4 D amine (not EPA registered) acetochlor (RUP) amidosulfuron (not EPA registered) atrazine (known water pollutant) cloquintocet-mexyl (not EPA registered) cycloxydim (not EPA registered) haloxyfop-R-methyl (not EPA registered) ioxynil (not EPA registered) isoxadifen ethyl (not EPA registered) lucreazine PGR (not EPA registered) propaquizafop (not EPA registered) prosulfocarb (not EPA registered) quizalofop-p-ethyl (Class I) tritosulfuron (not EPA registered)

Rodenticide AI in products registered by Georgia, and recommended by this PERSUAP for BEO rejection for use in USAID projects (with reason for rejection)

flocoumafen (not EPA registered) zinc phosphide (locally registered formulations at 80%, Class I)

Nematicide AIs in products registered by Georgia, and recommended by this PERSUAP for

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BEO rejection for use in USAID projects (with reason for rejection) ethoprophos (also insecticide) (RUP) metam sodium (also insecticide, fungicide) (RUP) methyl bromide (also insecticide, fungicide) (RUP, Montreal Protocol phase-out

chemical) oxamyl (also insecticide) (RUP)

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