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PESTICIDE EVALUATION REPORT AND SAFER USE ACTION PLAN (PERSUAP)USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II) Initial Environmental Examination (IEE) Amendment

PROJECT/ACTIVITY DATAProject/Activity Name: MultipleAmendment (Y/N): YGeographic Location(s) (Country/Region):

USAID Senegal/Sahel Regional Office (SRO)

Implementation Start/End: FY2018-FY2023Solicitation/Contract/Award Number:

Multiple

Implementing Partner(s): MultipleTracking ID/link: Sahel RISE II PERSUAP

https://ecd.usaid.gov/document.php?doc_id=52469 Tracking ID/link of Related RCE/IEE (if any) (expiration date):

RISE II Project Appraisal Document (PAD) Programmatic IEE [07/30/2023]- https://ecd.usaid.gov/document.php?doc_id=51010

Food for Peace (FFP) FY18 Request for Applications (RFA) IEE [FY2023]- https://ecd.usaid.gov/document.php?doc_id=50497

Tracking ID/link of Other, Related Analyses:

Programmatic PERSUAP for Fall Armyworm Management v2 [04/2024]- https://ecd.usaid.gov/document.php?doc_id=52069

FFP Niger Agricultural Crop, Livestock, and Commodity Storage PERSUAP [7/2/2015] - https://ecd.usaid.gov/repository/pdf/46041.pdf

FFP Burkina Faso ViM PERSUAP [6/11/2014] - https://ecd.usaid.gov/repository/pdf/46326.pdf

USAID/Food for Peace Burkina Faso and Niger Activity PERSUAPsREGIS PERSUAP [12/2020] -https://ecd.usaid.gov/repository/doc/51005.docx

USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II) i

https://ecd.usaid.gov/repository/pdf/46326.pdf

https://ecd.usaid.gov/repository/pdf/46041.pdf

https://ecd.usaid.gov/document.php?doc_id=52469

USAID/Food for Peace Burkina Faso and Niger Activity IEEs [see multiple IEEs]REGIS PERSUAP [12/2020] -https://ecd.usaid.gov/repository/doc/51005.docx

ORGANIZATIONAL/ADMINISTRATIVE DATAImplementing Operating Unit(s): (e.g. Mission or Bureau or Office)


Funding Operating Unit(s): (e.g. Mission or Bureau or Office)


Funding Account(s): VariousFunding Amount: VariousAmendment Funding Date:Other Affected Unit(s): Bureau for Food Security (BFS)Lead BEO Bureau: AFR and DCHAOriginal prepared by:Amendment prepared by:

Adapted from REGIS PERSUAP prepared by Alan Schroeder https://ecd.usaid.gov/repository/doc/51005.docxby: Stella Siegel [email protected] Neigh [email protected]

Date Prepared: August 2019

ENVIRONMENTAL COMPLIANCE REVIEW DATA Analysis Type: IEE Amendment / PERSUAPEnvironmental Determination(s):

Negative Determination (with Conditions)

Expiration Date: 31 December 2020Additional Analyses/Reporting Required:

Safer Use Action Plan (SUAP)/Integrated Pest Management (IPM) Plan Development, Implementation and Reporting by Partner; Integration into an Environmental Mitigation and Monitoring Plan (EMMP); Pesticide Implementation Field Evaluation

Climate Risks Identified (#):

Low risk through PERSUAP Expiration (31 December 2020)

Climate Risks Addressed (#):

Yes

INTRODUCTION The intent of this Resilience in the Sahel Enhanced II (RISE II) Pesticide Evaluation Report Safer Use Action Plan (PERSUAP) is to serve as a programmatic PERSUAP USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II)

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document for activities commencing in 2019 under the RISE II project and the Niger and Burkina Faso Democracy, Conflict and Humanitarian Assistance (DCHA)/Food for Peace (FFP) Development Food Security Assistance (DFSA) projects. RISE II is the follow-on to Resilience and Economic Growth in the Sahel-Enhance Resilience (REGIS-ER) and Resilience and Economic Growth in the Sahel – Accelerated Growth (REGIS-AG), collectively known as REGIS or RISE I.

Both RISE II and FFP implementing partners (IPs) plan on implementing actions involving the “procurement or promotion of, or training in use of pesticides, including herbicides, insecticides, acaricides, and fungicides”, which per their governing parent Initial Environmental Examinations (IEEs), require the development of a PERSUAP, pursuant to 22CFR Regulation 216.3 (b)—USAID pesticide procedures. The governing parent IEEs can be found at:

● RISE II Project Appraisal Document (PAD) Programmatic IEE [expires 07/30/2023] https://ecd.usaid.gov/document.php?doc_id=51010

● Food for Peace (FFP) FY18 Request for Applications (RFA) IEE [expires FY2023] https://ecd.usaid.gov/document.php?doc_id=50497

The RISE II Project and this PERSUAP build upon the existing REGIS-ER and REGIS-AG actions in the Sahel as well as predecessor FFP projects, targeting vulnerable populations in Burkina Faso and Niger to bring them out of poverty along sustainable pathways, for which there was an existing PERSUAP set to expire December 31, 2020 (approved 2017 - https://ecd.usaid.gov/repository/doc/51005.docx) and referred to herein as the “2017 REGIS PERSUAP”. The 2019 PERSUAP, presented here, relies heavily on the narrative and analysis of that 2017 REGIS PERSUAP since RISE II covers the same value chains , similar activities, and similar operational areas. The 2019 PERSUAP has notable updates and edits to make the information current and fully applicable to the RISE II and FFP projects, specifically:

(1) Supposition of all previous PERSUAPs (2017 REGIS PERSUAP) for this 2019 RISE II PERSUAP.

(2) Revision of project descriptions, values chains, and sectoral use (e.g., public health, construction) planned for RISE II and FFP projects in Burkina Faso and Niger based on a survey distributed to partners.

(3) Integration of additional pesticides recommended in the Programmatic PERSUAP for Fall Armyworm (FAW) Management in Africa, 2019 – found at https://ecd.usaid.gov/document.php?doc_id=52069 and recommendations in the 2018 Fall Armyworm Integrated Pest Management (IPM) Guide in Africa (https://www.usaid.gov/sites/default/files/documents/1867/Fall-Armyworm-IPM-Guide-for-Africa-Jan_30-2018.pdf).

(4) Updating the approvals/rejected list of the REGIS PERSUAP to align with the 2018 Institute du Sahel (INSAH) Comité Sahélien des Pesticides (CSP) registration list based on AIs only.

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(5) Simplification and collection of recommendations and conditions for follow-on reporting to improve readability and comprehension of the document.

(6) Alignment of the follow-on requirements of this PERSUAP with the parent IEEs for each of the activities.

THRESHOLD DECISION MEMORANDUM AND SUMMARY OF FINDINGS

PURPOSE AND SCOPEThis 2019 RISE II PERSUAP addresses the requirements of 22 CFR 216.3(b) (“Pesticide Procedures”) regarding assistance for the procurement and/or use of pesticides (“pesticide support”) in USAID funded projects and activities implemented in the Sahel Region (i.e., Burkina Faso, Niger), described under “scope” below. As such, it:

● Establishes the set of unrestricted same and similar uses pesticide Active Ingredients (AIs) for which support to procurement and/or use is authorized by these projects/activities.

● Establishes the conditions under which pesticide products containing the authorized AIs may be procured, used, or their use supported to best ensure user, consumer and environmental safety.

As such, it amends the following Programmatic IEEs and Programmatic Environmental Assessment (PEA) [signature date]:

● RISE II Programmatic IEE [12 July 2018] https://ecd.usaid.gov/document.php?doc_id=51010

● FFP FY18 RFA IEE [9 March 2018] https://ecd.usaid.gov/document.php?doc_id=50497

● Programmatic PERSUAP for Fall Armyworm Management_v2 [30 May 2019] https://ecd.usaid.gov/document.php?doc_id=52069

● PEA for Phosphine Fumigation of Stored Agricultural Commodities [November 2013] http://www.usaidgems.org/fumigationPEA.htm

Each Programmatic IEE or PEA also requires supplemental or activity-level analysis. This PERSUAP, and its follow-on requirements, will serve as the activity-level supplement to those tiered IEEs.

USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II) iv

https://ecd.usaid.gov/document.php?doc_id=52069

BEO1 Specific-Conditions of Approval

As noted here in the “BEO-Specific Conditions”, upon approval of this document, USAID/FFP and USAID Senegal/Sahel Regional Office (SRO) will begin a process of consultation and examination of usability, implementation, and monitoring of safe pesticide use practices in the field in order to contribute to USAID’s ongoing PERSUAP revision process, and to develop targeted and usable PERSUAP tools for Sahel programming. This longer-term effort is intended to engage IPs in several rounds of dialogue on 1) pesticide use as part of a broader IPM framework; 2) finding a means to meet USAID and host country pesticide regulatory requirements; and 3) at the field-level, communicating pesticides approved for use and implementing the use more safely. In this future effort, the IPs, USAID, and other stakeholders will have an opportunity to also address challenges, such as, but not limited to, identification of counterfeits and products, identification of restricted use pesticides (RUP), procurement of personal protective equipment (PPE), training and dissemination of safe application methods, and proper disposal of pesticides. Progress toward these ends will be integrated into the activity designs and implementation.

This RISE II PERSUAP will serve as a bridge document for RISE II IPs in the Sahel to meet the requirements of 22CFR216.3(b)-Pesticide Procedures. In approval of this PERSUAP, the BEOs require the following to be completed by December 31, 2020, the expiry date for this RISE II PERSUAP, at which time a new PERSUAP will be approved and available. The BEO is available for consultation and engagement in the planning and development process of these deliverables over the next year.

USAID AORs/CORs will ensure that:

1. RISE II IPs fully comply with specific Programmatic Conditions of their funding Bureau (see Table 1).

2. Each RISE II IP will develop a Safer Use Action Plan (SUAP) in accordance with Section 5 of this document that meets the 12-criterion noted therein (see also Threshold Decision/SUAP Conditions of this Executive Summary, page 10).

3. RISE II IPs will be required to complete a pesticide implementation field evaluation, which will assess successes and lessons during either a) previous implementation of RISE II activities (for incumbents) or b) the current contract activity period to date (new awardees). This evaluation will be administered in the form of a questionnaire/survey provided by the SRO. **(These evaluations will be used to inform training and monitoring needs over the course of the remaining implementation period and for updating the PERSUAP in 2020.)

4. RISE II IPs are required to invest in training of their core staff managing and monitoring actions that procure, utilize, train, or support pesticide use. The training will also develop materials for training of trainers and for ensuring oversight and monitoring of staff and beneficiaries at the field level using tools, such as checklists.

1 “BEO” refers to any and all affected BEOs. This may include AFR, DCHA, BFS, etc.USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II)

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5. Before expiry, the PERSUAP will be revisited and drafted to conform with the revised AFR PERSUAP template (forthcoming), lessons learned from the pesticide implementation field evaluation, and further stakeholder consultations over the next 12 months.

Programmatic Conditions of Funding Bureau IEEs and Relationship with this PERSUAP

In the Programmatic IEEs associated with RISE II activities, the “Assistance for the procurement and/or use of pesticides” is defined as: direct procurement, transportation, storage, mixing, loading, application, disposal, demonstrations, promotion, technical assistance, provision of samples, special payments, donations, subsidies and other forms of financial support for purchase of pesticides, including credit provision and credit guarantees.

Each of the Programmatic IEEs for which this RISE II PERSUAP amends, specifies conditions to be met at the activity-level by implementing partners as well as tiered requirements for additional requirements for pesticide analysis. The conditions of each Programmatic IEE, the activities or programs governed by those Programmatic IEEs, analysis of how this PERSUAP complies with those conditions, and any follow-on requirement for partners are noted in Table 1. IPs should note the specific requirements of their IEE and discuss means of meeting those requirements for their Agreement/Contracting Officer’s Representative (A/COR) in addition to the specific BEO conditions noted above.

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USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II) vii

TABLE 1. CROSS-WALK OF PROGRAMMATIC IEE CONDITIONS AND FOLLOW-ON REQUIREMENTSPROJECT ACTIVITY NAME -

IMPLEMENTING PARTNER

GOVERNING PARENT IEE CONDITIONS

HOW THIS PERSUAP COMPLIES WITH CONDITIONS

FOLLOW-ON REQUIREMENTS OF IPS

FFP FY18 RFA IEEFFP NigerFFP Burkina Faso

Hamzari - CAREGirma – Catholic Relief Services (CRS)Wadata - Save the ChildrenViM Plus - ACDI/VOCA

1. Develop an activity-specific PERSUAP or PERSUAP tiered from a Mission-wide PERSUAP

2. Approval of PERSUAP by the DCHA Bureau Environmental Officer (BEO)

3. No use of banned pesticides

4. Develop a SUAP specific to the activity

5. For fumigation, use the Fumigation PERSUAP template and Fumigation Management Plan (FMP) template (see Fumigation PEA link above)

1. The RISE II PERSUAP address specific actions of the FFP activities through a consultation with IPs (i.e., survey distributed in May 2019).

2. RISE II is approved by the DCHA BEO

3. No banned pesticides are approved by the PERSUAP

4. Requires an activity-specific SUAP be developed by IPs

5. Requires a FMP and completion for each fumigation site and approval of the PERSUAP template

1.Develop an activity -specific SUAP

2.Use only approved AIs

3.Report on PERSUAP implementation using the SUAP tracker

4.For fumigation activities: Complete the PERSUAP template, and for each fumigation location, complete an FMP

RISE II PAD Programmatic IEE

Water Security Resilience (WSR) - WinRockMarket and Nutrition activity – To be Determined (TBD)Health Services Delivery - TBDYouth Livelihoods - TBDSocial and Behavior Change Communication - Breakthrough-ActionInvest - TBDKeo Global Development Alliance (GDA) - TBDASTER (land tenure) - Government of Burkina Faso

1.Procurement or use of pesticides, including herbicides, insecticides, acaricides, and fungicides, is disallowed until such time that a PERSUAP is completed pursuant to 22CFR Regulation 216.3 (b)—USAID pesticide procedures— and duly approved.2.Actions involving pesticide safer use training, IPM measures, and extension outreach, but not procurement or use of pesticides, may proceed with an approved Environmental Mitigation and Monitoring Plan (EMMP) in place.

1. The RISE II PERSUAP approves AIs for direct procurement and use actions. 2. The RISE II PERSUAP requires partners to develop an EMMP that addresses indirect support for pesticides.

1. Develop an activity-level SUAP for direct procurement or use of pesticides

2. Use only approved AIs

3. Report on PERSUAP implementation using the SUAP tracker

4. Develop an EMMP for actions involving training, IPM, and extension outreach.

5. Report on the EMMP implementation with regular reporting cycles.

FAW Programmatic PERSUAPv2

Global Bureau for Food Security (BFS) Activities and Crop Protection Activities

1.Confirm existence of country-Mission-activity PERSUAP2.Confirm whether FAW PERSUAP and RISE II PERSUAP approve the AI for FAW for your crop

1.This RISE II PERSUAP serves as the guiding Mission PERSUAP

2.This RISE II PERSUAP considered FAW PERSUAPs for

1.Develop a SUAP for FAW control (see page 15 of the FAW PERSUAP)

2.Develop an activity-level SUAP for direct procurement or use of pesticides

USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II) viii

Scope. This PERSUAP covers pesticide support for the below-listed value chains, use types, locations, and actions of programs funded by USAID/SRO, USAID/FFP, and USAID/BFS.

Covered actions/use types: Crop protection

● Agricultural crop production and crop protection, including home gardens, commercial operations, and no-till

● Crop protection and control of invasive species: Fall armyworm ● Private sector support which directly relates to agrodealers selling, training

farmers, and promoting specific pesticide inputs for crop protection and livestock

● Training and direct support to extension workers, including provision of training materials, to advise farmers on pesticide use

● Seed procurement, multiplication, and seed treatments● Post-harvest storage and protection of commodities

Natural Resource Management● Community-based natural resource management and farmer-managed

natural regeneration● Nursery operations and agroforestry activities

● Fodder production

● Boundary markingResearch

● Research activities in a controlled but in-situ settingLivestock/poultry husbandry

● Livestock pest control (cattle, small ruminants, poultry) Aquaculture

● Treatment and disease preventatives for fish farmingWater and sanitation

● Potable water treatment for small-scale sources/systems using liquid or solid chlorine or other disinfectants/sterilants.

Structural pest control● Pesticide use in construction (e.g. used for wood treatment/termite

protection), including needs for latrine and water point construction ● Rodent and/or insect control in facilities other than crop storage/food

commodity warehouses● Fumigation of commodities● Treatment of animal pens

Addressed crops value chains:

USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II)IX

● Zea mays: Maize● Poaceae: Millet, Sorghum, Sugarcane, Rice, forage crop (Andropogon

gayanus, Pannicum sp, Cenchrus sp,..)● Euphorbiaceae: Cassava● Fabaceae/legumes: Groundnuts, Soybean, Cowpea, Bambara Groundnut

(vigna subterranean) [Voandzou], Dolique Asperge bean (Vigna unguiculata sesquipedalis), alfalfa/Lucerne-forage crop

● Asteraceae: Lettuce ● Amaranthaceae: Amaranthus leaves● Cucurbitaceae: Pumpkins, Squashes, Watermelon (Cucumis melo),

Cucumbers● Brassicaceae: Cabbage● Apiaceae: Carrots● Solanaceae: Tomato, Sweet potato, Irish potato, Eggplant, Sweet pepper,

Chili pepper● Allium: Onion, Garlic● Pedaliaceae: Sesame● Mallow: Okra/Gombo (Abelmoschus esculentus), Hibiscus (Bissap)● Rutaceae/citrus: Orange, Lemon● Anacardiaceae: Mango● Caricaceae: Papaya● Rhamnaceae: Apple of the Sahel (Ziziphus mauritiana)

● Moringaceae: Moringa (Moringa oleifera)

● Arecaceae: Date palm● Livestock/Fowl: Poultry, guinea fowl, small ruminants [sheep, goats]

Addressed geographies: Sahel Regional Office countries: Niger, Burkina Faso

USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II)X

FIGURE 1. ZONE OF RISE II AND FOOD FOR PEACE INTERVENTIONS COVERED UNDER THE RISE II PERSUAP.

Actions involving pesticides covered by other documentation: ● Long-lasting insecticidal treated nets, larviciding, indoor residual spraying,

insecticidal treated clothing, and treated hammocks are addressed separately under the Integrated Vector Management for Malaria Vector Control (MVC) PEA (2017) available at: https://ecd.usaid.gov/repository/pdf/50060.pdf

● American Schools and Hospitals Abroad (ASHA) Termiticide Programmatic PERSUAP - [Add ECD when available]

USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II)XI

● PEA for the Manufacture and Use of AflasafeTM in Sub-Saharan Africa [Feb 2015] available at: https://ecd.usaid.gov/repository/pdf/43836.pdf.

THRESHOLD DECISION/SUAP CONDITIONSA Negative Determination is issued for assistance with procurement and/or use of pesticides within the above-enumerated scope, subject to the CONDITION of full compliance with the Safer Use Action Plan (SUAP) that comprises Section 5 of this document.

SUAP criteria required to fulfill conditional requirements of this PERSUAP:

1. Restrict the procurement, use, and support of pesticides in the covered activities to ONLY those pesticides containing the AIs listed in facesheet Table 2 below OR identified by the U.S. Environmental Protection Agency (USEPA) as exempt from regulation under the U.S. Federal Insecticide, Fungicide and Rodenticide Act (FIFRA).* For products which contain mixtures of AIs, all AIs in the mixture must be approved in order for that product to be approved under this PERSUAP.

Procurement, use of, or support for these pesticides is limited to the uses, geographies, and actions covered by this PERSUAP and must comply with (1) AI-specific restrictions and conditions in Table 2; and (2) all other requirements of the SUAP.

For pesticide products containing more than one AI, all AIs must be approved, and specific uses and conditions for all product AIs apply. Ultimately, the product label and the product safety data sheet (SDS), formerly known as a Material Safety Data Sheet (MSDS) are the appropriate sources of hazard communication, accounting for all aspects of product formulation, concentration, and potential synergy between AIs. The SDS must be obtained from the product manufacturer.

* These particularly low-risk AIs (primarily essential oils and other plant extracts) are listed at: http://www.epa.gov/sites/production/files/2015-12/documents/minrisk-active-ingredients-tolerances-2015-12-15.pdf

2. Do NOT support pesticide products with high acute toxicity except when use is conducted by professional applicators, trained and certified appropriately. Do NOT support products that are, or are highly similar to, products classified as RUPs by USEPA, except for aluminum phosphide in conformity with condition 3, below.

“High acute toxicity” applies to any product labeled as USEPA Acute Toxicity Category I or equivalent (e.g., those labeled with skull and crossbones, the word DANGER and/or POISON, or equivalent indications) or containing World Health Organization (WHO) AIs Class 1A and 1B.RUPs are pesticide products that are determined by USEPA as not appropriate for use by the general public for reasons of acute, long-term or ecological

USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II)XII

toxicity. In the United States, pesticides products that are labeled RUP can only be sold to and used by certified applicators or persons under the direct supervision of certified applicators, and only for those purposes covered by the applicator's certification (such as for row crops, tree crops, or structural pests). “Professional applicators” are defined as those holding a host country professional pesticide applicator certification, when such a certification program exists, an appropriate U.S. or EU certification, or as approved by the USAID Mission Environment Officer (MEO), and in the absence of an MEO, as approved by the USAID Regional Environmental Officer (REO).

Where pesticide product labels and SDSs specify inert ingredients, do not support pesticide products with inert ingredients removed from the currently approved inert ingredient list. The list can be found at: http://src.bna.com/kUm .

3. Assure that phosphine fumigation, if supported, is conducted in conformity with USAID’s PEA for Phosphine Fumigation of Stored Agricultural Commodities (i.e., “Fumigation PEA”) http://www.usaidgems.org/fumigationpea.htm

4. Ensure that commercial pesticide products procured, used, or recommended for use are properly labeled in a national language or in the country’s official language and include required essential information. Training in reading and understanding labels is a mandatory requirement for safer pesticide use.

5. Implement pesticide support in conformity with a set of locally adapted, crop- and pest-specific IPM plans and observe enumerated use restrictions. IPs must utilize preventive IPM tools and tactics Annex 1 of the 2017 REGIS PERSUAP2, which is an IPM plan draft containing some key information for IP’s use for most value chains covered in this PERSUAP. Before resorting to use of PERSUAP-approved pesticides, IPs must develop more extensive and detailed IPM plans that address major pests in their respective value chains and preventive non-chemical IPM tools and tactics. Pest control and pesticide use must be part of an IPM scheme governed by crop- and pest-specific IPM-based plans and should be used only as the last resort after all preventive tools have been exhausted.

6. Train appropriate IP staff and beneficiaries in safer pesticide use and pesticide first aid. IPs must provide training in pesticide safer use and compliance with this PERSUAP to their staff and beneficiaries, including those using, selling, financing, providing extension services, or demonstrating pesticides with USAID funding. This training must include all topics listed in Annex A.1. During implementation, USAID will also work with IPs to build capacity on pesticide management and also to support training of trainers, who will then have the ability to work directly with beneficiaries in the field on safe pesticide use.

7. Ensure use per label, including the correct use of appropriate PPE for all pesticide use under IPs direct control. Otherwise, IPs must ensure access to, proper

2 Available at: https://ecd.usaid.gov/repository/doc/51005.docx

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use of, maintenance of appropriate PPE, and use per label, to the greatest degree feasible.

8. Require safer handling of pesticides and use and maintenance of appropriate PPE. To the greatest degree practicable, IPs must require safer pesticide purchase, transportation, handling, storage, and disposal practices, and proper use and maintenance of appropriate PPE.

9. Systematically document and monitor all activity associated with any procurement, use of both of pesticides, including, where possible, monitoring for pest resistance.

10. Certify that any proposed procurement of pesticides is compliant with this PERSUAP and provide other information specified in the SUAP for review and clearance by the A/COR and the MEO (or REO if no MEO is designated) as requested.

11. Complete and use the “SUAP Tracker”, where mandatory (see Table 1), IPs must implement SUAP conditions and monitor and report such implementation using a tracking tool provided in Section 5.4. Any activity subject to this PERSUAP requirement must submit a completed SUAP Tracker to their A/COR and MEO (or REO) at least 30 days before the implementation of the activity and must then update it annually. The tracker is a mandatory tool for assigning responsibilities and timelines for implementation of PERSUAP requirements, and for tracking compliance.

Note: With respect to pesticides, the SUAP Tracker, where required, satisfies the requirement for an EMMP. Activity EMMPs should simply incorporate the SUAP Tracker by reference.

12. Pass down all requirements to subcontractors and grantees. Prime contractors must incorporate pesticide compliance requirements, as presented above, into each grant or subcontract that will involve assistance for pesticide procurement or use. Grants and subcontracts must also require reporting on compliance with these requirements.

The SUAP requires that USAID Bureau(s) implementing RISE II activities:1. Announce the approved PERSUAP to all relevant teams.2. When pesticide registration changes take place amend this PERSUAP as

necessary. 3. Ensure that all relevant USAID staff receive an internal short-format (~1–2

hour) training on the requirements established by this PERSUAP. 4. A/CORs and MEO (or REO) review and approve IP pesticide procurement

requests as necessary.5. Put in place effective internal procedures to review SUAP Trackers

submitted by IPs. The Tracker template is provided in Section 5.4.6. A/CORs assure that the IP conditions summarized above are funded,

implemented, and monitored (per ADS 204.2 and 204.3.4.). 7. Ensure that contract and award language for each relevant activity

requires compliance with the IP conditions summarized above (per ADS

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204.3.4). Note: USAID requirements may be expanded/changed based on the level of control USAID would like to exercise.

CLEARANCE AND REVIEW INFORMATIONAIs approved by this PERSUAP listed in Table 2 below are found in U.S.-registered pesticide products by USEPA for unrestricted, same and similar uses. These AIs are also registered by the CSP as of May 2018. CSP is the body in charge of the implementation of the Permanent Interstate Committee for Drought Control in the Sahel (CILSS) members states Common Regulations for pesticides registration. CILSS is the technical arm of the Economic Community of West African States (ECOWAS). It is a committee of the INSAH. CSP has been operational since 1994, and reviews registration dossiers submitted by firms dealing with pesticides to be granted authorization for sale in the CILSS Member States. These AIs are chosen in this RISE II PERSUAP are based on demonstrated needs in selected sectors and crops and where at least one product with that AI is registered by CSP. The pesticides are chosen conservatively with respect to their environmental and human health risk profiles, with risk-reducing conditions specified as appropriate. Notably, most products registered by the CSP contain more than one AI. All AIs in a product must be approved in this PERSUAP for the product to be approved. A list of products registered by the CSP for the CILLS member countries is available in Annex B.

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TABLE 2. ACTIVE INGREDIENTS APPROVED BY THIS PERSUAPActive Ingredients Type of AI and common uses for crop

protectionExample of approved products registered by INSAH containing this AI

Issues and concerns related to AI and its products*Refer to Section 5.5 for recommended best practices and conditions of safe use given any environmental concerns.

2,4-D (acid) Selective, systemic herbicide for broad-leaved weeds, in crop applications used mostly for orchards and cereals. Secondary plant growth regulator.

Binbefla Plus 720 Herbexbar 720 SLSoundiata 720 SLTopextra 720 SL

For rice only:BaccaraHerbafor 720 SLMalo BinfagaSahel 2D

May persist in aquatic systems under certain conditions. Moderately toxic to mammals. May have negative effects on reproduction and development and is considered to be a neurotoxin and an irritant. Moderately toxic to birds and most aquatic species as well as bees and earthworms.

2,4-D (salts and esters)

The salt and ester forms are derivatives of the parent acid.

Calliherbe 720 SLDekadeSun-2,4-D Amine

Products vary in their chemical properties and environmental behavior, but to a lesser extent in their toxicity.

Abamectin Acts as a selective acaricide, nematicide and insecticide for use in a wide variety of crops. This AI is recommended for control of Fall Armyworm by the FAW PERSUAPv2.

Abalone 18 ECBomec 18 ECVertimec 18 EC

High oral toxicity to mammals and some evidence that it may induce negative reproduction effects at high doses. It exhibits high or medium toxicity to most fauna and flora.

Acetamiprid Used for the control of Hemiptera spp. in fruit and vegetables, especially aphids, but also thrips, mirids, spider mites, flies, leaf miners, and leaf hoppers. This AI is recommended for control of Fall Armyworm by the FAW PERSUAPv2.

Titan 25 EC Moderately toxicity to bees, but high toxicity to birds and earthworms. Do not use when birds or poultry are foraging.

Aluminum phosphide Insecticide and rodenticide fumigant used during the storage of food commodities.

Highly toxic to all mammals and can result in fatalities if not properly handled. Suspected developmental/reproductive toxin. It is highly toxic to birds, fish and bees and moderately toxic to aquatic invertebrates, algae and earthworms. Use of this fumigant must comply with the USAID

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PEA for Phosphine Fumigation of Stored Agricultural Commoditieshttp://www.usaidgems.org/fumigationpea.htm . Consult the MEO for more information.

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Aspergillus flavusstrains: MO11-8; GO18-2; M109-2; M110-7Aspergillus flavusstrains: SS19-14; MS 14-19; M2-7; M21-11

Mitigating aflatoxin contamination of maize and groundnut using atoxigenic strains of Aspergillus flavus as a biocontrol.

Aflasafe BF 01

Aflasafe SN 01

See the PEA for the Manufacture and Use of AflasafeTM in Sub-Saharan Africa [Feb 2015] available at: https://ecd.usaid.gov/repository/pdf/43836.pdf. https://ecd.usaid.gov/repository/pdf/43836.pdf

Azoxystrobin Broad spectrum fungicide used mainly for cereals.

AzoxOrtiva Top

Low mammalian toxicity but may bioaccumulate. Skin and eye irritant. Moderately toxic to birds, most aquatic life, bees and earthworms.May leach to groundwater under certain conditions. Do not use pesticides with potential 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.

Bromadiolone Rodenticide mainly used for indoor applications.

Maki Block May cause damage to blood and reduce the clotting ability of blood if swallowed, inhaled or absorbed through skin.

Bt/ Bacillus thuringiensis Kurstaki

Used for control of Lepidopteran larvae and other vegetable and woodland pests such as Diptera or Coleoptera. This AI is recommended for control of Fall Armyworm by the FAW PERSUAPv2.

Batik WGBio K 16

Moderately toxic to fish and low to moderate toxicity to bees.

Chlorothalonil Fungicide used to control a wide range of diseases on a broad range of crops, cereals, vegetables, tubers, fruit and other crops.

Jumper 75 WG Probable human carcinogen. Suspected reproductive/ developmental toxin. Highly toxic to fish and aquatic organisms, and moderately toxic to bees. Do not use near surface waters where runoff is possible.

Chlorantraniliprole Insecticide used to control a broad spectrum of pests on a range of crops including potatoes, grain, fruit and cotton.This AI is recommended for control of Fall Armyworm by the FAW

Coragen 20 SC (for use on cotton only)

Moderately toxic to most organisms, but highly toxic to aquatic organisms. Do not use near surface waters where runoff is possible.

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PERSUAPv2.

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Chlorpyrifos methyl Storage, grain bin, and warehouse insecticide

Reldan 40 EC Organophosphate insecticide. Highly toxic to mammals but classified as a neurotoxicant. Skin irritant and sensitizer. Highly toxic to fish, aquatic invertebrates and bees, and moderately toxic to birds, aquatic plants, algae and earthworms. Do not use near surface waters where runoff is possible.

Clethodim Herbicide used to control annual and perennial grasses for use on cereals, herbs, vegetables, groundnuts and other crops

Select 120 EC Potential skin irritant. Low to moderate toxicity to most organisms.

Clomazone Herbicide used for control of broad-leaved weeds and grasses in a range of crops.

Sniper (for rice only)

Moderately toxic to mammals and other organisms. Highly soluble in water and non-persistent in soil.

Cyantraniliprole Insecticide for management of sucking and chewing insects that can be vectors for certain plant diseases. Used for foliar applications to bulb, legume and tuberous and corm vegetables; oil seed crops, groundnuts.

Benevia 10 OD No significant health issues have been identified. Highly toxic to bees, moderately toxic to earthworms and most aquatic species. Do not apply insecticides from 10 am to 4 pm when honeybees are foraging.

Deltamethrin Used to control a wide range of sucking and chewing pests. The AI has applications in agriculture, storage, veterinary use, and public health.

Protect DP(for warehouse use only)

Zero fly storage bag

Suspected neurotoxin. Highly toxic to most aquatic organisms and bees. Do not use near surface waters where runoff is possible.

Difenoconazole Fungicide used for disease control in many fruits, vegetables, cereals and other field crops

Ortivia Top

Apron Star 42 WS(for seed treatment only)

Persistent in soil and in the aquatic environment with concerns for bioaccumulation. Moderately toxic to humans, mammals, birds and most aquatic organisms.

Diflubenzuron Insecticide used to control a wide range of leaf-eating insects mostly in fruit crops. This AI is recommended for control of Fall Armyworm by the FAW PERSUAPv2.

Beluga 480 SCOrtiva topBeluga 480 SCDimilin OF 6

Low mammalian toxicity. Moderately toxic to fish, bees and earthworms, but higher toxicity to aquatic invertebrates. Can persist in water but not persistent in soil. Do not use near surface waters where runoff is possible.

Dimethoate An insecticide and acaricide used to Methoate 40 EC Volatile organophosphate. Moderately

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control a wide range of pests including Aphididae, Coleoptera and Lepidoptera for use in wide variety of crops including fruit, nuts, vegetables, cereals and other crops. This AI is recommended for control of Fall Armyworm by the FAW PERSUAPv2.

toxic to mammals but may have serious health implications for humans as it is an acetyl cholinesterase inhibitor and may cause reproduction or development effects. Possible human carcinogen. Highly toxic to birds and bees, moderately toxic to most aquatic species and earthworms. Do not apply insecticides from 10 am to 4 pm when honeybees are foraging.

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Glyphosate and glyphosate salts

Non-selective broad-spectrum herbicide used in a wide range of cropping, utility and industrial situations for control of weeds and grasses.

Douma Woro 480Fouralan 480 SLGlycel 410 SLGlyphader 75 SGGlyphalm 360 SLGlyphogan 480 SLGlyphonet 360 SLGlyphotrop 480 SLHerbasateKalach 360Heros 360 Killer 480 SLLamachette 360 SLLamachette 757 SLMamba 360 SLRival 360 SLRoundup 680 BioseTouchdown Forte 500 SL

Other glyphosate products registered for rice.

Moderately toxic to humans and a skin and eye irritant. Moderately toxic to birds, most aquatic organisms, earthworms and bees. Suspected carcinogen, maybe endocrine disruptor.

Imidacloprid Insecticide used to control sucking and soil insects in crops such as rice, cereals, maize, potatoes and other crops. This AI is recommended for control of Fall Armyworm by the FAW PERSUAPv2.

Calthio Mix 485 WSInsector T(both for seed treatment by professionals only)

Persistent in soil. Highly toxic to birds and bees. Moderately toxic to mammals and earthworms. Non-toxic to fish. Do not apply insecticides from 10 am to 4 pm when honeybees are foraging. Do not use when birds or poultry are foraging.

Indoxacarb Used on a wide range of crops including vegetables and fruit for control of certain Lepidoptera, also used for control of roaches and ants. This AI is recommended for control of Fall Armyworm by the FAW PERSUAPv2.

Avaunt 150 ECSteward 150 ECViper 46 EC

Highly toxic to birds and bees. Do not apply insecticides from 10 am to 4 pm when honeybees are foraging. Do not use when birds or poultry are foraging.

Kaolin clay/aluminum silicate

Substance with no pesticidal properties but sometimes used in pesticide product formulations to form a barrier film preventing target pests from reaching

Surround WP Crop Protectant

Low toxicity

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plant. Used against flea beetles, Japanese beetles, sawflies, codling moth, aphids, weevils, psyllids, and thrips in fruit and other crops.

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Malathion An insecticide and acaricide used to control a wide range of pests. This AI is recommended for control of Fall Armyworm by the FAW PERSUAPv2.

Fyfanon 880 ECInvader-B-Lock

Moderately toxic to mammals, suspected to be a cholinesterase inhibitor and a neurotoxin. Highly toxic to bees and aquatic species with the exception of algae. Moderately toxic to birds and earthworms. Do not use near surface waters where runoff is possible. Do not apply insecticides from 10 am to 4 pm when honeybees are foraging.

Mancozeb Fungicide for control of a wide range of pathogens including blights and scabs on a wide range of crops.

Dithane M45Manco 80 WPCoga 80 WPManga PlusIvory 80 WP

Associated with adverse reproduction/ development effects. Highly toxic to fish and aquatic invertebrates. Do not use near surface waters where runoff is possible.

Mefenoxam (Metalaxyl M)

Fungicide used to control diseases caused by air- and soil-borne pathogens mostly in vegetables.


Eye and skin irritant

Metalaxyl Fungicide used to control diseases caused by air- and soil-borne Peronosporales in a variety of crops.

Calthio Mix 485 WS(for seed treatment by professionals only)

Skin irritant

Nicosulfuron A post-emergence herbicide mostly used to control annual grass weeds in maize crops.

Akizon 40 SCAkoumais 40 SCKababin 40 SCMaia 75 WGMaia SuperNico Top 40 ADNicodaf 40 SCNicokaba 40 SCNicomais 40 SCNiconet 40 SCNicosuper 40 SCSegaibaana 40 SCSofa 40 SC

Eye and skin irritant, respiratory tract irritant. High solubility and high leachability potential; and therefore, may contaminate groundwater. Do not use pesticides with potential 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.

Oxadiazon A pre-emergent or early post-emergent herbicide used to control some annual broad-leaved weeds.

Oxo - OXARIZ 250 EC (for rice only)

Suspected reproductive/ development toxin, possible human carcinogen, respiratory tract irritant.

Oxyfluorfene A broad-spectrum, pre- and post-emergent herbicide used to control certain broad- leaved annual weeds in

Goal 2E Possible human carcinogen.

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vegetables, fruit and other crops.

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Pendimethaline Herbicide used to control most annual grasses and common weeds in cereals, fruit and vegetables.

Alligator®Pencal 500 ECParagon 500 ECPendaf 500 ECPendinet 500 ECPendistarPenditrop 500 ECStomp CSAlligator® unik

Sniper(for rice only)

Potential reproductive/ development toxin, possible human carcinogen, skin, eye and respiratory tract irritant. Highly toxic to fish, moderately toxic to most organisms. Do not use near surface waters where runoff is possible.

Permethrin Insecticide active against a wide range of pests including Lepidoptera and Coleoptera.

Caiman Rouge P(for seed treatment by professionals only)

Antouka 19 DP

Moderately toxic to humans, may be a neurotoxicant. Highly toxic to most aquatic species and bees but is not highly toxic to birds or earthworms. No longer approved in EU and in the US uses are mostly for storage, public health and low concentration domestic products.

Pirimiphos methyl An organophosphate fumigant insecticide used to control a wide range of insects and mites in storage.

Protect DPActellic Gold DustAntouka 19 DP(all for storage warehouses use only)

Possibly neurotoxic, suspected endocrine/developmental toxin, skin and eye irritant, respiratory trac irritant. Highly toxic to aquatic organisms and to bees.

Rimsulfuron Herbicide used for annual grass and annual broad-leaved weed control in maize, vegetables and fruit.

Ricomais 25 WGSaphir

Low to medium toxicity. May cause irritation of the eyes, skin, and respiratory tract. High leachability potential.

Spinosad Insecticide derived from naturally occurring soil fungi used for control of Lepidoptera in maize, vegetables, fruit and other crops. This AI is recommended for control of Fall Armyworm by the FAW PERSUAPv2.

Laser 480 ECSpintor PoudreSuccess Appat 0.24 CB

Highly toxic to aquatic organisms and to honeybees, low to medium toxicity to other organisms. Do not apply insecticides from 10 am to 4 pm when honeybees are foraging.

Spinetoram Insecticide with activity against a wide range of common insect pests including moths, thrips, and other pests used in fruit and other crops. This AI is

Radiant 120 SCExalt 120 SC

Possible reproductive/developmental toxin. Low to medium toxicity to most organisms, but highly toxic to bees and some aquatic organisms. Some products

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recommended for control of Fall Armyworm by the FAW PERSUAPv2.

are skin irritants.

Tebuconazole Fungicide effective against various foliar diseases in cereals and other field crops.

Nativo 300 SC Possible human carcinogen. Suspected reproductive/ developmental toxin. Moderately toxic to most organisms.

Thiamethoxam Insecticide used to control a wide range of common pests such as aphids, whiteflies, thrips, lacewings, leafhoppers, mealybugs, wireworms, ground beetles, fire & carpenter ants and others. This AI is recommended for control of Fall Armyworm by the FAW PERSUAPv2.


Actellic Gold Dust(for storage only)

Likely to be carcinogenic to humans. Highly toxic to bees.

Thiram Fungicide which is also used as a mammal repellent.

Calthio Mix 485 WSCaiman Rouge PInsector T(all for seed treatment by professionals only)

Skin and eye irritant. Highly toxic if inhaled. Is suspected of long-term chronic effects including reproductive/developmental toxicity and endocrine disruption.

Trifloxystrobin Fungicide that is foliar applied for control of certain foliar, stem and root diseases such as Alternaria, Black root, Black spot, Botrytis, Downy mildew, Powdery mildew, Leaf spot, Rust, Rhizoctonia stem and root rot; Scab, Blossom blight and others.

Nativo 300 SC Low mammalian oral toxicity but there is some evidence that it may cause negative reproduction or fertility effects. Highly toxic to bird, fish and aquatic invertebrates, but less toxic to bees and earthworms. Do not use near surface waters where runoff is possible. Do not use when birds or poultry are foraging.

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HOW TO USE THIS DOCUMENTThis PERSUAP serves both a regulatory and a practical function for USAID Mission staff and IPs. While the entire document is important, certain parts of this document are an explicit directive for partners in their selection and safer use of pesticides as part of an IPM plan. The PERSUAP also includes guidelines for monitoring and reporting on pesticide use to USAID.

This 2019 RISE II PERSUAP heavily relies on information provided in the 2017 REGIS PERSUAP available at: https://ecd.usaid.gov/document.php?doc_id=51005. To reduce redundancy, information available in the 2017 PERSUAP was not included in the 2019 version. IPs therefore, should refer to tools presented in the 2017 REGIS PERSUAP for supporting information.

BECOMING FAMILIAR WITH THE PERSUAPFor IPs to better understand the requirements for using, procuring, and training on pesticides safely in their activities, the following sections are important to review.

1. Read the conditions established for BEO approval of the PERSUAP relevant to your activity implementation. These are the conditions pertaining to safer pesticides use that you must meet as an IP per your parent IEE (see Table 1). 2. Read the terms and conditions listed in the PERSUAP and the requirements for development of an activity specific SUAP (Section 5.3).3. Consider the recommended best practices and safe use conditions (Section 5.5).5. Review the list of approved AIs and AI-specific conditions for use of these AIs (Table 2). 6. Perform a field evaluation to capture the status, success, and challenges for pesticide use, monitoring, and reporting.7. Develop a system for training and tools development for safe pesticide use and handling for core staff, field staff, and beneficiaries. Consider needs for the training of users and applicators and the mandatory contents of training modules for users and applicators (Annex A).

Supporting information presented in the 2017 REGIS PERSUAP, which can be found at https://ecd.usaid.gov/document.php?doc_id=51005, includes the following resources:

● IPM Plan Capacity Building: Draft IPM Matrix (Annex 1); Guidelines for Drafting Pest Management Plans (Annex 2); Elements of an IPM program (Annex 3)

● Selection of Quality Pesticide Products (Annex 5)● Training tools in French (Annex 6)

DEVELOPMENT AND IMPLEMENTATION OF A SAFER USE ACTION PLAN

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As described in Section 5.3, the IPs must develop a SUAP specific to their actions and use the SUAP tracker to document implementation (see Table 4 and 5). The SUAP provides guidance on how to ensure products are selected and used in a safe manner by IP staff and beneficiaries. Per the Programmatic IEEs, Table 1 reiterates requirements to complete SUAPs for the activities covered by this PERSUAP. SUAPS must be completed by all FFP and BFS activities. RISE II IPs who are using, procuring, or are directly assisting with procurement or use pesticides must also develop SUAPs. RISE II IPs who are training on general safe use or IPM only need to document those actions as part of a standard EMMP (consult the Agreement/Contracting Officer’s Representative (A/COR) for further direction).

SELECTION AND USE OF PESTICIDE PRODUCTSPesticide products should be selected for use based on a detailed location, crop and pest specific IPM plan, and as guided by the SUAP. In selection of a pesticide in accordance with this PERSUAP, the IP should:

● Identify which pesticide product is necessary for treatment of the pest of economic concern through consultation with agronomists, crop protection experts, and extension staff.

● Confirm that all AIs listed on the product label are approved for use in this PERSUAP (Table 2). If one or more AIs are not approved by the PERSUAP, the IP cannot use the product with the approval of the MEO. Consult the A/COR and MEO for more information.

● Note any restrictions or cautions for those AIs in the PERSUAP and develop mitigation measures to ensure implementation (e.g., AIs that are toxic to aquatic organisms should not be used near water bodies).

● Read the label to ensure the product has a registration number from INSAH.● Identify recommendations for personal protective equipment on the label of

the product. ● Follow all instructions and application rates found on the label ● Keep a register that documents all pesticide procurement and use by the

projects and document pesticide use type, quantity used, purposes of use, manner in which it was applied, as well as effectiveness of the pesticide, proving as much detail as possible when using pesticides for demonstrations, pilots, and staff use of the product.

● Keep detailed record of any spills, accidents or health problems associated with use of pesticides

● Establish pesticide procurement, transportation, storage, mixing and application, and disposal monitoring methods and indicators for all pesticide use, including when product will be demonstrated, recommended, or in any


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other way target beneficiaries including lead farmers and extension providers.


XXX

APPROVAL OF ENVIRONMENTAL ACTIONS2019 USAID Senegal/Sahel Regional Office RISE II Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP)

Clearance: __________________________________________________Peter Trenchard, Mission Director

_______________Date

Concurrence: __________________________________________________Brian D. Hirsch, Africa Bureau Environmental Officer (BEO)IEE File Name: Sahel Regional Office RISE II PERSUAP

_______________Date

Concurrence: __________________________________________________Erika Clesceri, Democracy Conflict and Humanitarian Assistance (DCHA) BEO

_______________Date

Concurrence: __________________________________________________William Thomas, Bureau for Food Security (BFS) BEO

_______________Date

Additional Clearance:

__________________________________________________Abdourahmane Ndiaye, Mission Environmental Officer

_______________Date

Additional Clearance:

__________________________________________________Samantha Wapnick, Regional Environmental Officer

_______________Date

DISTRIBUTION:

1. Project files2. CORs/AORs Food for Peace Niger and Burkina Faso and Sahel Regional Office3. COs/AOs, Team Leads, and Office Chiefs4. Implementing Partners

1

TABLE OF CONTENTSIntroduction iiiThreshold Decision Memorandum and Summary of Findings iv

Purpose and scope ivThreshold Decision/SUAP Conditions xiiClearance and Review Information xivHow to Use this Document xxii

Becoming familiar with the PERSUAP xxiiDevelopment and implementation of A SAFER USE ACTION plan xxiiSELECTION and Use OF PESTICIDE Products xxii

APPROVAL OF ENVIRONMENTAL ACTIONS 1Table of Contents 2Acronyms 5Section 1: Introduction 8Section 2: Environmental Context and Background 11

2.1 Geography 11Climate Change 11Activity summary 12Resilience in the Sahel Enhanced II (RISE II) 12Food for peace (FFP) development Food Security Assistance (DFSA) 14Other Mission Buy-Ins To Field Mechanisms 14

Section 3: PERSUAP Methodology and Analysis of Pesticides 153.1 Methodology of PERSUAP development 153.2 Pesticides Analysis in accordance with EPA and sahel pesticide framework 15

Pesticides Registered by USEPA 15Low-risk Pesticide AIs not requiring approval under this PERSUAP 16Sahel pesticide Regulatory Framework: Pesticides Registered by Comite Sahelien des pesticides (CSP) of INSAH 16Pesticides used for Pest Outbreaks and Emergencies 19

Section 4: Pesticide Evaluation Report (PER) 204.1 Factor A: USEPA Registration Status of the Proposed Pesticides 20

registration summary 204.2 Factor B: Basis for Selection of Pesticides 21

selection for analysis in this persuap 21real-world considerations for pERSUAP users 22

2

4.3 Factor C: Extent to Which the Proposed Pesticide Use is, or Could be, Part of an IPM Program 224.4 Factor D: Proposed Method or Methods of Application, Including the Availability of Application and Safety Equipment 234.5 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 23

Pesticide Active Ingredients on Persistant Organic Pollutants (POPs) and Prior Informed Consent (PIC) lists 24Acute toxicity 24Lower acute toxicity pesticides 24Risks to Humans 24

4.6 Factor F: Effectiveness of the requested pesticide for the proposed use 254.7 Factor G: Compatibility of the proposed pesticide use with target and non-target ecosystems 264.8 Factor H: Conditions under which the pesticide is to be used, including climate, geography, hydrology, and soils 264.9 Factor I: Availability and Effectiveness of Other Pesticides or Non-Chemical Control Methods 264.10 Factor J: Host country’s ability to regulate or control the distribution, storage, use, and disposal of the requested pesticide 274.11 Factor K: Provision for training of users and applicators 28

Targets and Training Overview 28Weaknesses to be address in Training 29

4.12 Factor L: Provision made for monitoring the use and effectiveness of each pesticide 29

Section 5: Pesticide Safe Use Action Plan (SUAP) 305.1 Introduction to SUAP 305.2 RISE II Pesticides Requested for Analysis 305.3 SUAP COMPLiANCE REQUIREMENTS FOR IPs 305.4 SUAP Tracker 335.5 recommended best practices and safe use conditions 40

Selecting pesticides judiciously 40Promoting IPM Planning and Implementation 40Improving Method of Pesticide Applications 40Enforcing Measures for Mitigation of Risks to Environmental Resources 41Managing and mitigating pesticide resistance in the field 41Positive factors already in practice that need reinforcement in Burkina Faso and Niger 43

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Annex A: Training Topics and Safe Pesticide Use Web Resources 45A.1 MANDATORY ELEMENTS OF PESTICIDE SAFE USE TRAINING 45A.2 Integrated Pest Management 45A.3 Understanding Pesticide Risks 46A.4 Understanding Pesticide Label and Material Safety Data Sheet 47A.5 Pesticide Safety and Use of Protective Clothing and Equipment 48A.6 Proper Spray Technique: Protecting Against Pesticide Spray Drift 49A.7 Pesticide Transport and Storage 50A.8 First Aid for PEsticide Poisoning 51A.9 Proper Pesticide Container Disposal 52A.10 Proper Disposal of Obsolete and Unused Pesticides 53A.11 Monitoring and Data Record Keeping 53

ANNEX B. INSAH Registration (2018) 54AnNEX C. PERSUAP References 69

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ACRONYMSA/COR Agreement/Contracting Officer’s Representative AI Active Ingredient ASHA American Schools and Hospitals AbroadBEO Bureau Environmental Officer BFS Bureau for Food SecurityBT Bacillus thuringiensis CFR Code of Federal RegulationsCILLS Permanent Interstate Committee for Drought Control in the Sahel CRS Catholic Relief ServicesCSP Comité Sahélien des PesticidesDCHA Bureau for Democracy, Conflict and Humanitarian AssistanceDFSA Development Food Security AssistanceDP dusting powderEA Environmental Assessment ECOWAS Economic Community of West African StatesEMMP Environmental Mitigation and Monitoring Plan FAO Food and Agriculture OrganizationFAW Fall ArmywormFFP Food for PeaceFIFRA Federal Insecticide, Fungicide and Rodenticide ActFMP Fumigation Management PlanGAP Good Agriculture PracticeGDA Global Development AllianceGH Global HealthGlobalGAP Global Good Agriculture Practices, a quality certification systemGUP General Use PesticideIEE Initial Environmental ExaminationIITA International Institute for Tropical AgricultureINSAH Institute du SahelIP Implementing Partner IPM integrated pest managementISO International Standards Organization LDC Louis Dreyfus Commodities

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LOP Life of ProjectMEO Mission Environmental OfficerMOA Ministry of AgricultureMRP Minimum Risk PesticidesMSDS Material Safety Data SheetMVC Malaria Vector ControlNGO Non-Governmental OrganizationPAD Project Appraisal DocumentPAN Pesticide Action NetworkPEA Programmatic Environmental AssessmentPER Pesticide Evaluation ReportPERSUAP Pesticide Evaluation Report and Safer Use Action PlanPGR Plant Growth RegulatorPHI Pre-Harvest IntervalPIC Prior Informed ConsentPOP Persistent Organic Pollutants PPE Personal Protective EquipmentREO Regional Environmental OfficerRFA Request for ApplicationsReg 216 Regulation 216 (USAID Environmental Procedures under 22 CFR 216.3 (b))REGIS-AG Resilience and Economic Growth in the Sahel - Accelerated Growth REGIS-ER Resilience and Economic Growth in the Sahel - Economic ResilienceREI Re-Entry Interval RFA Request for ApplicationsRISE Resilience in the Sahel Enhanced RUP Restricted Use PesticidesSAPHYTO African Society of Phytosanitary Products and InsecticidesSBC social and behavior changeSDS Safety Data SheetsSRO Sahel Regional OfficeSUAP Safe Use Action PlanTBD To be DeterminedUSG United States GovernmentUSAID US Agency for International Development

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USEPA US Environmental Protection Agency WASH Water, Sanitation, and HygieneWFP World Food ProgramWHO World Health OrganizationWSR Water Security Resilience

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SECTION 1: INTRODUCTION This 2019 Resilience in the Sahel Enhanced (RISE) II Pesticide Evaluation Report Safer Use Action Plan (PERSUAP) addresses the requirements of 22 CFR 216.3(b) (“Pesticide Procedures”) regarding assistance for the procurement and/or use of pesticides (“pesticide support”) in USAID funded projects and activities implemented in the Sahel Region (i.e., Burkina Faso, Niger), described under “scope” below. As such, it:

● Establishes the set of unrestricted same and similar uses pesticide Active Ingredients (AIs) for which support to procurement and/or use is authorized by these projects/activities.

● Establishes the conditions under which pesticide products containing the authorized AIs may be procured, used, or their use supported to best ensure user, consumer and environmental safety.

These requirements come into effect upon approval of the PERSUAP. Coverage areas and activities are noted in the facesheet for programs supported by the USAID/Senegal/Sahel Regional Office (SRO) in Niger and Burkina Faso. This PERSUAP coverage is valid until year 2023.

The set of authorized pesticides and requirements for safe use are established through the first sections of the document, the Pesticide Evaluation Report (PER), which culminates with an assessment of the 12 pesticide risk evaluation factors (a through l) required by 22 CFR 216.3(b) (see Box 1).

The Safer Use Action Plan (SUAP) in Section 5 provides a succinct, stand-alone statement of compliance requirements, synthesized from the 12-factor analysis. It also provides a mandatory template for assigning responsibilities and timelines for implementation of these requirements USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II)

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BOX 1. THE 12 PESTICIDE ANALYSIS FACTORS

A. U.S. Environmental Protection Agency (USEPA) registration status of the proposed pesticides

B. Basis for selection of pesticides

C. Extent to which the proposed pesticide use is part of an integrated pest management (IPM) program

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

E. Any acute and long-term toxicological issues with the proposed use, and measures available to minimize such hazards

F. Effectiveness of the requested pesticide for the proposed use

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

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

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

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

K. Provision for training of users and applicator

based on the parent IEEs for each activity covered under this PERSUAP (see Table 1). Where required, activities subject to this PERSUAP must complete this SUAP template and submit to its Agreement Officer’s Representative/Contracting Officer’s Representative (A/COR), and Regional Environmental Officer (REO).

Review of Selected Products: This PERSUAP meets the regulatory requirements for the approval of AIs per USAID’s standard of practice. However, products registered and available in the Sahel may contain more than one AI in a mixture; and therefore, all AIs in the mixture must be approved by this PERSUAP in order for an implementing partner (IP) to use the product. Products within Table 2 are those registered by Institute de Sahel (INSAH), and were reviewed for applicability. They are provided as examples, but IPs must review all labels and follow the label instructions for all products selected.

Covered actions/use types: Crop protection

● Agricultural crop production and crop protection, including home gardens, commercial operations, and no-till

● Crop protection and control of invasive species: Fall armyworm ● Private sector support which directly relates to agrodealers selling, training

farmers, and promoting specific pesticide inputs for crop protection and livestock

● Training and direct support to extension workers, including provision of training materials, to advise farmers on pesticide use

● Seed procurement, multiplication, and seed treatments● Post-harvest storage and protection of commodities including the current use

and registration status of aflasafeTM and fumigation seed treatmentsNatural Resource Management

● Community-based natural resource management and farmer-managed natural regeneration

● Nursery operations and agroforestry activities

● Fodder production

● Boundary markingResearch

● Research activities in a controlled but in-situ settingLivestock/poultry husbandry

● Livestock pest control (cattle, small ruminants, poultry) Aquaculture

● Treatment and disease preventatives for fish farmingWater and sanitation

● Potable water treatment for small-scale sources/systems using liquid or solid chlorine or other disinfectants/sterilants.

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Structural pest control● Pesticide use in construction (e.g. used for wood treatment/termite

protection), including needs for latrine and water point construction ● Rodent and/or insect control in facilities other than crop storage/food

commodity warehouses● Fumigation of commodities● Treatment of animal pens

Addressed crops value chains: ● Zea mays: Maize● Poaceae: Millet, Sorghum, Sugarcane, Rice, forage crop (Andropogon

gayanus, Pannicum sp, Cenchrus sp,..)● Euphorbiaceae: Cassava● Fabaceae/legumes: Groundnuts, Soybean, Cowpea, Bambara Groundnut

(vigna subterranean) [Voandzou], Dolique Asperge bean (Vigna unguiculata sesquipedalis), alfalfa/Lucerne-forage crop

● Asteraceae: Lettuce ● Amaranthaceae: Amaranthus leaves● Cucurbitaceae: Pumpkins, Squashes, Watermelon (Cucumis melo),

Cucumbers● Brassicaceae: Cabbage● Apiaceae: Carrots● Solanaceae: Tomato, Sweet potato, Irish potato, Eggplant, Sweet pepper,

Chili pepper● Allium: Onion, Garlic● Pedaliaceae: Sesame● Mallow: Okra/Gombo (Abelmoschus esculentus), Hibiscus (Bissap)● Rutaceae/citrus: Orange, Lemon● Anacardiaceae: Mango● Caricaceae: Papaya● Rhamnaceae: Apple of the Sahel (Ziziphus mauritiana)

● Moringaceae: Moringa (Moringa oleifera)

● Arecaceae: Date palm● Livestock/Fowl: Poultry, guinea fowl, small ruminants [sheep, goats]


SECTION 2: ENVIRONMENTAL CONTEXT AND BACKGROUND

2.1 GEOGRAPHYBurkina Faso is a landlocked West African country, bordered by Mali in the north and west, Niger in the East, and Benin, Togo, Ghana, and Côte d’Ivoire in the south. Burkina Faso covers a land area of 274,200 km2.

Much of Burkina Faso lies on a savanna plateau, 200-300 meters above sea level, and is generally characterized by a tropical climate of the Sudanese and Sahelian categories, with a long dry season from October to April, and a short rainy season from May to September. The arid Sahelian zone covers the northern part of the country, and has an annual rainfall that does not exceed 350-500 mm in most areas. The Sudanese zone is less arid and covers the southern part of the country, receiving annual rainfall that varies from 700 mm to 1200 mm.

Most Burkina Faso's streams are seasonal, with only the Mouhoun, the Comoé, and the Pendjari having perennial flows. Major seasonal streams include the Nazinon, the Nakambé, and the Sirba. Other perennial bodies of water include Bam and Dem lakes, Mare aux Hippopotames, the Oursi Pond, and the artificial lakes of Kompienga, Bagré, and Ziga. Since 2006, the latter has served as a major supplementary source of drinking water for Ouagadougou and its surrounding localities.

Burkina Faso’s economy is dominated by subsistence agriculture in which 90% of the population engages (accounting for 37% of the gross domestic product). Principle crops include sorghum, millet, maize, rice, cowpea, groundnuts, sesame, cassava, Irish potatoes and sweet potatoes. Cash crops include cotton, tobacco and sugarcane.

Niger is a land-locked country with a land area of 1,267,000 km2. Seven other countries surround it, with Nigeria to the south, Chad to the east, Algeria to the north-northwest, and Mali to the west. Niger also has short borders in its far southwest frontier with Burkina Faso and Benin, and to the north-northeast Libya.

Niger's climate is largely hot and dry, with primarily desert in the north. Niger receives most of its rain between June and September, and rainfall totals of more than 500 mm during this season typically provide enough water for crops and livestock. Only 15% of Niger’s land is arable, and that is mostly located along the southern border with Nigeria. In this extreme south, there is a sub-tropical climate along the edges of the Niger River Basin. The terrain further north is predominantly desert plains and sand dunes, with flat to rolling plains to the south and hills in the north.

Agricultural lands in Niger are used as arable, especially near water sources, and as pasture. There are some forests and woodland in the south and around desert wadis (oases). Recurring droughts are a challenge in Niger. The 2012 Sahel drought, which led to failed crops, increased insect plagues, high food prices and conflicts continue to affect Niger, and often leads to acute food shortages. USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II)

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Agriculture in Niger accounts for 40% of gross domestic product and employs over 90% of the workforce. Primary crops and livestock include cowpeas, cotton, peanuts, millet, sorghum, cassava, rice; cattle, sheep, goats, camels, donkeys, horses, poultry.

CLIMATE CHANGE3,4

The rising levels of CO2, temperatures and precipitation, and increases in severe weather events such as floods and droughts can have direct effect on pests and diseases. In Burkina Faso and Niger conditions are already very conducive to pest breeding and survival and high temperatures, particularly under poor storage conditions can adversely affect effectiveness of some pesticides. Any changes in these climatic factors will further act in a synergic or opposing manner depending on the pest or pathogen concerned. Decreased plant tolerance due to severe weather event may increase risks of pest and disease outbreaks. The risks inherent to climate change are addressed by ongoing pest monitoring that is an integral measure of Integrated Pest Management (IPM) and by Factor L: Provision made for monitoring the use and effectiveness of each pesticide.5

ACTIVITY SUMMARY

This PERSUAP provides coverage for activities across USAID/Senegal/SRO’s portfolio including RISE II activities (both awarded and future), USAID/Food for Peace (FFP) activities in Niger and Burkina Faso (awarded), and Bureau for Food Security (BFS) activities (both awarded and future).

RESILIENCE IN THE SAHEL ENHANCED II (RISE II)The RISE II Project builds upon the existing RISE I actions in the Sahel, targeting vulnerable populations in Burkina Faso and Niger to bring them out of poverty along sustainable pathways. The goal of USAID’s RISE II is to assist chronically vulnerable populations in Burkina Faso and Niger, supported by resilient systems, to effectively manage shocks and stresses and pursue sustainable pathways out of poverty. The activities supporting this goal will all incorporate cross-cutting issues of gender, youth, risk management, and governance. Table 3 summarizes the awarded and planned activities under RISE II that may be required to comply with USAID’s 22 CFR 216.3(b) pesticide procedures because their actions involve pesticides.

TABLE 3. RISE II ACTIVITY INFORMATIONACTIVITY PURPOSE IMPLEMENTER COUNTRIES

Water Security Resilience (WSR)

To “Enhance social and ecological risk management systems” through three components:

− Improved water security.− Enhanced sustainable

Winrock Niger-Burkina Faso

3 USAID Climate Risk Profiles: Climate Risks in Food for Peace Geographies Niger4 USAID Climate Risk Profiles: Climate Risks in Food for Peace Geographies Burkina Faso5 FRI. Literature Review: Impact of Climate Change on Pesticide Use. (2015). https://www.sciencedirect.com/science/article/abs/pii/S0963996914006309USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II)

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https://www.sciencedirect.com/science/article/abs/pii/S0963996914006309

https://www.climatelinks.org/sites/default/files/asset/document/20170807_USAID%20ATLAS_FFP_BurkinaFaso.pdf

https://www.climatelinks.org/sites/default/files/asset/document/2017_USAID%20ATLAS_Climate%20Risks%20in%20Food%20for%20Peace%20Geographies%20Niger.pdf

TABLE 3. RISE II ACTIVITY INFORMATIONproductive land use.− Improved management of shocks risks and stresses.

Market and Nutrition activity

To Be Determined (TBD) TBD Niger-Burkina Faso

Health Services Delivery

Improve access to quality health service delivery in the RISE II zones and action research on evidence-based social behavior change interventions tailored to local contexts to improve health, family planning and nutrition outcomes in the regions.

TBD Niger-Burkina Faso

USAID Hamzari 1: Extreme vulnerability reduced for vulnerable women, youth and marginal households in Maradi.

2: Improved health and nutritional status of pregnant and lactating women, children under two years of age, and adolescent girls.

3: Improved access and use of equitable and sustainable Water Sanitation and Hygiene (WASH) services for all community households.

4: Improved sustainable, diversified livelihood opportunities and adaptive capacities of women, youth and vulnerable households.

CARE Niger

Girma Improve and sustain food and nutrition security and resilience of extremely poor and chronically vulnerable households in Magaria and Dungass departments in Niger.

Catholic Relief Services (CRS)

Niger

Wadata Governance of local institutions, livelihood diversification, natural resources management, and agriculture activities.

Save the Children

Niger

ViM Plus Purpose 1: Enhanced Inclusive Governance of Institutions and Organizations Support Vulnerable Households in their Pathway to Food Security and Resilience

Purpose 2: Health and Nutrition of Vulnerable Households, Especially PLW and Children in the First 1,000 Days, is Improved

ACDI/VOCA Burkina Faso


TABLE 3. RISE II ACTIVITY INFORMATION

Purpose 3: Improved Adoption of Household WASH Practices, Especially Reduced Open Defecation

Purpose 4: Diversified Livelihoods– Economic Wellbeing of Vulnerable Head of Households Increased and Sustained

Purpose 5 (Cross-cutting): Social Inclusion – Enhanced Social, Economic and Political Agency and Empowerment of Women and Male and Female Youth

Youth Livelihoods This is a skills-building program targeted at youth in Tillaberi, Niger. The IP will work to train youth in life/soft skills and connect them to job and finance opportunities, including in the WASH sector.

TBD Niger

Breakthrough-Action (Social and Behavior Change [SBC] Communication)

Development of a SBC strategy for RISE II to achieve improved health, family planning, and nutrition outcomes among populations in select regions of Burkina Faso and Niger.

Breakthrough-Action

Burkina Faso-Niger

Invest This will be an access to finance activity targeted at providing subsidies to banks to incentivize them to lend to USAID beneficiaries

TBD Burkina Faso-Niger

Keo Global Development Alliance (GDA)

This GDA is technology-focused and will provide smartphones to beneficiaries pre-loaded with educational audio and video.

TBD Burkina Faso-Niger

ASTER (land tenure)

Improve land tenure security (land access and land rights)

Assistance to the Government

Burkina Faso

FOOD FOR PEACE (FFP) DEVELOPMENT FOOD SECURITY ASSISTANCE (DFSA)Separate FFP investments contributing to RISE II are under the purview of the Bureau for Democracy, Conflict, and Humanitarian Assistance (DCHA) Bureau Environmental Officer (BEO), but pesticide actions of those activities are covered by this PERSUAP.

For Burkina Faso and Niger Development Food Security Activities, FFP investments will contribute to the achievement of the Government of Burkina Faso’s National Plan for Economic and Social Development or the Government of Niger’s Resilience Strategy, as well as USAID’s FFP Strategy. They will also serve as the foundation for


USAID’s RISE II initiative, which aims to help “chronically vulnerable populations in Burkina Faso and Niger, supported by resilient systems, effectively manage shocks and stresses and pursue sustainable pathways out of poverty.” FFP investments will work in coordination with other investments by the U.S. Government (USG), the World Food Program (WFP), the host country governments, and other donors to collectively benefit chronically vulnerable populations in the RISE II zone.

FFP development food security activities in Burkina Faso and Niger are intended to build resilience in populations vulnerable to chronic hunger and repeated hunger crises, and to reduce their future need for ongoing or emergency food assistance. To these ends, the FFP office supports the procurement, protection, and distribution of food commodity, including fumigation, as well as a range of program areas and elements.

OTHER MISSION BUY-INS TO FIELD MECHANISMS

Likewise, RISE II also contributes to some centrally-managed Bureau for Global Health (GH) activities under the purview of the Global Health BEO and the BFS BEO. Those activities which will involve pesticides also fall under the direction of this PERSUAP.


SECTION 3: PERSUAP METHODOLOGY AND ANALYSIS OF PESTICIDES

3.1 METHODOLOGY OF PERSUAP DEVELOPMENTThe RISE II Project and this PERSUAP builds upon the existing Resilience and Economic Growth in the Sahel - Economic Resilience (REGIS-ER) and Resilience and Economic Growth in the Sahel - Accelerated Growth (REGIS-AG) actions in the Sahel as well as predecessor FFP projects, targeting vulnerable populations in Burkina Faso and Niger, for which there was an existing PERSUAP is set to expire December 31, 2020 (approved 2017 - https://ecd.usaid.gov/repository/doc/51005.docx, herein referred to as the “2017 REGIS PERSUAP”). This 2019 PERSUAP relies heavily on the narrative and analysis of that 2017 REGIS PERSUAP since RISE II covers the same value chains , similar activities, and similar operational areas. The 2019 PERSUAP has notable updates and edits to make the information current and applicable to the RISE II and FFP projects being:

(1) Supposition of all previous PERSUAPs (2017 REGIS PERSUAP) for this 2019 RISE II PERSUAP.

(2) Revision of project descriptions, values chains, and sectoral use (e.g., public health, construction) planned for RISE II and FFP projects in Burkina Faso and Niger based on a survey distributed to partners.

(3) Integration of additional pesticides recommended in the Programmatic PERSUAP for Fall Armyworm (FAW) Management in Africa, 2019 – found at https://ecd.usaid.gov/document.php?doc_id=52069 and recommendations in the 2018 Fall Armyworm Integrated Pest Management (IPM) Guide in Africa (https://www.usaid.gov/sites/default/files/documents/1867/Fall-Armyworm-IPM-Guide-for-Africa-Jan_30-2018.pdf).

(4) Updating the approvals/rejected list of the REGIS PERSUAP to align with the 2018 Institute de Sahel INSAH registration list based on AIs only (see Annex B)

(5) Simplification and collection of recommendations and conditions for follow-on reporting to improve readability and comprehension of the document.

(6) Alignment of the follow-on requirements of this PERSUAP with the parent IEEs for each of the activities.

Beyond compliance, the previous document offered 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. These tools can be found in the predecessor PERSUAP at the following link: https://ecd.usaid.gov/repository/doc/51005.docx.

3.2 PESTICIDES ANALYSIS IN ACCORDANCE WITH EPA AND SAHEL PESTICIDE FRAMEWORK


PESTICIDES REGISTERED BY USEPACode of Federal Regulations (CFR) §216.3(b)(l)(i) through (v) requires evaluating the economic, social and environmental risks and benefits of the planned pesticide use requires, among other factors, the evaluation of the USEPA registration status of the requested pesticide. To that end, all pesticides registered by the INSAH were evaluated with respect to pesticides registered for the same or similar uses by USEPA without restriction.6,7

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:

● http://www.epa.gov/sites/production/files/2015-01/documents/ section25b_inerts.pdf

And, so-called Commonly Consumed Food Commodities, 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 USEPA, are covered under USEPA's new "Pheromone Regulatory Relief" as lower risk, and therefore, are not subject to regulation under FIFRA, and as such, are exempt from USEPA 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.

6 USEPA. 2017. Restricted Use Summary Report. October. Available at: https://www.epa.gov/sites/production/files/2017-10/documents/rup-report-oct2017.pdf. 7 Pesticide Action Network. Pesticides Database. Available at: http://www.pesticideinfo.org/Search_Chemicals.jsp. Accessed June 2019. USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II)

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SAHEL PESTICIDE REGULATORY FRAMEWORK: PESTICIDES REGISTERED BY COMITE SAHELIEN DES PESTICIDES (CSP) OF INSAHPesticide registration for West African francophone countries is done regionally through INSAH. The most recent (2018) INSAH list of approved (homologized) pesticides is found in Annex B. This list primarily serves commercial agricultural interests in West Africa.

INSAH Registry Summary. Most pesticides registered or homologized by INSAH are authorized for use on high-value cash crops, primarily cotton, followed closely by sugar cane and rice followed by tomatoes, maize, groundnuts, mangoes and onions. Some are registered for use on ‘cereals’ which can include sorghum and millet. Few are registered specifically for use on 'garden crops' ('cultures', or maraîchage in French), other vegetables and fruits, due to lack of economic importance.

Despite INSAH's "authorized uses" for each pesticide, the labels on the bottles these pesticides are sold in contain lists of other crops and pests that each can be used on, and Sahel farmers use them on these other crops and pests. For this reason, this PERSUAP approves use on these additional crops. Further, a certain amount of technical decision-making latitude, built into and afforded by Regulation 216's "same or similar use" language, is also brought to bear on the uses for which each pesticide is registered, particularly where fruits and vegetables are concerned, since they are not well covered by INSAH's focus on more valuable commercial crops. This document uses both English and French spellings of each AI, interchangeably.

Natural Artisanal Pesticides. Few natural pesticide products are registered by INSAH, but farmers and small-scale operations produce their own artisanal concoctions that work well as repellents and disease suppressants. These include extracts from neem tree seed, both the combined neem oil fraction, useful against plant diseases and some small pests, and the aqueous fraction containing azadirachtins, which are both antifeedants or repellents and biotoxins. Additionally, extracts of garlic, chili, onion, citrus skin essential oils and fire ashes are produced as repellents. One group based in Fada-N'gourma, Burkina Faso, Bioprotect, produces these extracts on a small scale for sale to farmers, and labels them as "biostimulants" instead of biopesticides. Often, these extracts can be used to push pest and disease organism numbers and damage down sufficiently such that they do not require further treatment with synthetic pesticides.

Pheromones. Currently, pheromone technology is used on a small scale in Niger and Burkina Faso, and could become a focus of use on USAID projects, where it makes sense. Pheromones could become particularly useful in the fight against the moths of many Lepidopterous pests and caterpillars, like the Tuta absoluta tomato leaf miner.

Fumigants. INSAH only registers one fumigant, Aladin, containing the Active Ingredient (AI), aluminum phosphide (phosphure d’aluminium), in pellet/tablet form, for use on stored grain. The gas produced by these pellets/tablets, phosphine, is highly toxic, requiring the use of specialized and expensive equipment and training, which smallholder farmers do not possess. For this reason, smallholder farmers should be discouraged from buying, and not allowed to use, this chemical for on-USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II)

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farm/home grain storage. Use of fumigants by professionals is covered separately under the Programmatic Environmental Assessment (PEA) for Phosphine Fumigation of Stored Agricultural Commodities [November 2013] http://www.usaidgems.org/fumigationPEA.htm.

Fungicides. INSAH registers products containing fungicide AIs, mostly for use on cotton and tomatoes, followed, in order of importance by groundnut, rice, mango and garden crops.

Many fungicide products are formulated and registered for use as seed treatments, primarily on cereals, and should only be applied by professional with personal protective equipment (PPE) used by employees who understand the risks. The issue with these other fungicide seed treatments is that they contain thiram in powdered/dust form, which if inhaled, can be quite toxic to humans.

Unfortunately, INSAH’s registered copper fungicide/bactericide products are too high a concentration and thus too toxic for project smallholder farmers to safely use. USEPA rates most of these as Class I acute toxicity. Copper products must also be used with care, to avoid over- or repeat-applications, which can increase soil copper toxicity. For these reasons, copper-containing products are not approved for promotion to smallholder farmers. If, in the future, professional spray services with proper PPE and training are formed, Class I chemicals could be used by them. And, this PERSUAP could be amended to permits such use.

Two natural or biological fungicides containing non-toxic Aspergillus flavis fungal strains can be used to compete with and reduce the natural levels of aflatoxin-producing A. flavis strains found in the field on maize and groundnuts, thus reducing aflatoxin contamination. Strains of this fungus are very location-specific, so the ones produced for, and registered in, the American market may be different than those useful for and registered in West Africa. Thus, decision-making latitude is again used to approve West African strains different from, but sufficiently like, those registered by USEPA.

Seed Treatment Products. Almost all vegetable seed found for sale in farm stores contains treatments of fungicides and sometimes in combination with an insecticide, not all of which are INSAH-registered. The most common chemicals found on factory-treated vegetable seed were thiram, iprodione, thiophanate-methyl and insecticide imidacloprid, all of which are USEPA-registered AIs. Some maize seed is treated as well with insecticide thiamethoxam. INSAH only registers pesticides for treatment or use, not those that enter member countries already on treated seed.

Generally, PERSUAPs do not permit seed treatment by smallholder farmers due to lack of technical skill, proper bulk mixing equipment and know-how, and PPE. However, the one seed treatment approved by this PERSUAP, Apron Star 42 WS, which contains a mixture of two fungicides and an insecticide is produced, formulated and packaged in single-use sachets by Syngenta specifically for smallholder farmer use, with instructions for use on an easily measured quantity of seed.


Herbicides. INSAH registers products containing herbicide/plant growth regulator (PGR) AIs, mostly for use on cotton and rice, followed, in order of importance by maize, sugar-cane, onions, groundnuts, garden crops and cereals. Many of these AIs are not registered by USEPA, and therefore, cannot be permitted for use here.

INSAH registers many herbicides for cash crops such as rice, sugar cane, and cotton only. Table 2 identifies instances when the AI is registered for a limited set of crops, as IPs should ALWAYS utilize pesticides in accordance with their labelled instructions.

Numerous products containing glyphosate are registered for burning down vegetation prior to planting maize, but some are also registered for general use.

Insecticides. INSAH registers products containing insecticide AIs, including synthetic pyrethroids registered for use in the health sector against mosquitoes and/or general residential use against mosquitoes and household pests. Pesticides registered solely for use against mosquitoes and/or household pests are rejected for use in the agriculture sector. Most of the remaining synthetic pyrethroids are registered for use in the cotton sector in mixtures with systemic neonicotinoids. The USEPA has designated most synthetic pyrethroid products as restricted use pesticides (RUPs), due to very high risk to aquatic organisms should the pesticide enter surface water. All these are also rejected for promotion or use by programs in the Sahel by smallholder farmers.

Molluscicides. INSAH registers no products containing molluscicides.

Nematicides. INSAH registers nematicides with only 2 AIs, both of which are rejected for support or use due to being highly toxic RUPs.

Rodenticides. INSAH registers one rodenticide with one AI, bromadiolone.

Avicides (kill birds). INSAH registers no products containing avicides.

PESTICIDES USED FOR PEST OUTBREAKS AND EMERGENCIES Burkina Faso and Niger have always been subjected to outbreaks of locust and grasshopper outbreaks. Generally, donated and government-managed resources and pesticides are brought to bear to manage such outbreaks. More recently, pests such as the tomato destroyer moth/larva, Tuta absoluta, have become a serious pest in the region. And, Huang Long Bing citrus 'greening disease' moved to South Africa from Asia, and spread throughout Africa since.

Presently, FAW, Spodoptera frugiperda, has invaded and moved across the Sahel. In an effort to streamline approvals for quickly responding to FAW, USAID/BFS developed a Programmatic PERSUAP for FAW Management Version 28, which provides recommendations on IPM practices and prescreens AIs which may combat FAW. As noted in Table 1, additional requirements, including screening for

8 USAID Programmatic PERSUAP for Fall Armyworm Managementv2, Available at https://ecd.usaid.gov/document.php?doc_id=52069 . USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II)

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registration at the country-level, are required in order to utilize these AIs. Where applicable, Table 2 notes AIs recommended for use against FAW in the PERSUAP.


SECTION 4: PESTICIDE EVALUATION REPORT (PER) This section analyzes the 12 factors required by 22 CFR 216.3(b) for each candidate pesticide to assess the appropriateness of use or support with USAID funds, and to determine the specific conditions attendant to their use.

4.1 FACTOR A: USEPA REGISTRATION STATUS OF THE PROPOSED PESTICIDES

REGISTRATION SUMMARY

USAID project activities are effectively limited to promoting during training, recommending, buying, subsidizing, financing or permitting on demonstration farms, pesticides and seeds coated with pesticides containing AIs in products fully registered in 2018 by INSAH as well as in the US by the USEPA for the same or similar uses, without restriction. Emphasis is placed on “similar use” because occasionally the crops or livestock 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 the same or similar crops and livestock, pests, formulations, methods of application, and pest situations.

The USEPA classifies pesticides according to actual toxicity of the formulated products, taking formulation types and concentrations into account, thus generally making the formulated product less toxic than the concentrated or technical AIs alone would be. This method of classifying acute toxicity is accurate and representative of actual risks encountered in the field.

It is important to note that all emerging market countries in which USAID works, as well as the labels on the pesticides sold in them, use the World Health Organization (WHO) acute toxicity classification system, not the USEPA system. The US (and by extension Regulation 216) is the only country to use the USEPA acute toxicity classification system.

In the US, some specific commercial pesticide products are labeled as RUPs due to inordinate risks, usually under specific circumstances of use, such as formulation, concentration or commodity. However, for each AI, which may be present in several RUP products, there are generally additional or other products, formulations and uses—with the exact same AI—that do not pose the same risks and are thus labeled or determined to be General Use Pesticides (GUPs)—that is—not a RUP. Ergo, for each AI, there may be RUP and General Use Pesticide, GUP (or non- RUP) products depending upon risks they do or do not pose.

INSAH registers pesticides annually, primarily for the health and commercial agriculture sectors, which require and can afford them. This list is provided as a poorly scanned pdf file on INSAH's website, which has been converted to an excel file presented in Annex B.

To research INSAH-approved pesticide AIs for USEPA compliance, toxicity and ecotoxicity, the following websites were extensively used by this study, with follow-ups on USEPA websites for questions or concerns: http://www.pesticideinfo.org;


http://sitem.herts.ac.uk/aeru/ppdb/en/atoz.htm; https://iaspub.epa.gov/apex/pesticides/f?p=PPLS:1; https://www.epa.gov/sites/production/files/2017-10/documents/rup-report-oct2017.pdf.

SPECIAL CONSIDERATIONS

This PERSUAP is tasked with evaluating and making risk-reduction decisions, first based upon an understanding of the local milieu, smallholder farmer needs, and the level of risk present (which can only be determined by visiting Burkina Faso and Niger, government institutions, pesticide importers and retailers and smallholder farmers), second by understanding and interpreting USEPA’s and Regulation 216’s intentions on risk reduction, and third, by common sense reasoning and arguments. This PERSUAP study uses each of these. In addition to rejecting unregistered and restricted pesticides, the PERSUAP team used the technical interpretation liberties granted by Regulation 216’s “same or similar use” language to make decisions based upon additional technical and social information collected, such as differences in concentration, formulation, potential versus known carcinogenicity, exceptionally smaller scale of Burkina Faso and Niger smallholder farmer pesticide use needs and patterns versus use patterns experienced in the US, and potential food security risks of not approving certain chemicals which fall into this gray area.

Using this reasoning, one pair of chemicals analyzed herein falls into this gray area, open for interpretation. The insecticide AI pirimiphos-methyl, an organophosphate chemical most commonly available in dusting powder (DP) formulations, is used either alone or in mixtures with a synthetic pyrethroid like permethrin, as a treatment on, or admixture to, bags of stored whole grains (not grain flours). These treatments protect the grain from pests like very small beetles, weevils, and moth larvae that feed on and in grain and on grain dust. These pesticides are ubiquitous in Africa in very small affordable quantities and are used by many smallholder farmers, as well as in larger quantities by highly-skilled warehouse grain storage pest management companies.

In the US, the USEPA registers only one stored grain protection product with the exact same AI and name, Actellic, but with a pirimiphos-methyl concentration of 57% and accompanying acute toxicity classification of Class I, the most toxic. Furthermore, American grain storage warehouses have a plethora of additional and less toxic options and chemicals to choose from for pest control.

In Burkina Faso and Niger, as in most of Africa, however, actellic is one of the few options available and affordable, and it is usually formulated with a much lower concentration of the AI pirimiphos-methyl (also spelled pyrimiphos-méthyl), in Burkina Faso and Niger at 10% to 20%, or in combinations with a synthetic pyrethroid, thus rendering a much lower class of acute toxicity listed on the label, WHO Class III, which makes sense for smallholder farmers/users with different needs, fewer options, and a relatively higher risk environment. Rejecting its use by smallholder farmers because of USEPA’s toxicity class for a product with the same name, but much higher concentration, would increase risks of grain losses for these farmers. Instead, the PERSUAP approves it, because of the lower concentration, lower acute toxicity class, small bag size, availability, affordability and needs of our smallholder beneficiary farmers.


4.2 FACTOR B: BASIS FOR SELECTION OF PESTICIDES

SELECTION FOR ANALYSIS IN THIS PERSUAPAIs recommended for approval in this PERSUAP are recommended on the following basis:

1. AIs with products that are currently registered in the US and by INSAH. The USEPA registration serves as a proxy for efficacy for the authorized uses enumerated in the Table 2.

2. Products containing this AI are registered by USEPA for the same or similar use and have identified pest management needs in this PERSUAP.

3. In the US, products containing the subject AI are NOT largely restricted use pesticide (RUP). (No RUP Products are authorized by this PERSUAP except aluminum phosphide that is authorized for use only by Food Aid programs using professionally trained fumigators based on the USAID PEA for Phosphine Fumigation of Stored Agricultural Commodity.)

4. AIs are chosen conservatively with respect to risk profile; AIs with notably high human or eco-toxicity are excluded.

REAL-WORLD CONSIDERATIONS FOR PERSUAP USERS

The basis for the selection of pesticides is made by most farmers when they buy vegetable seeds already treated with pesticide coatings; the decision is made for them. Most of these seeds are also improved hybrid varieties with resistance to pests and diseases as well as certified as clean from seed-borne disease organisms, a triple benefit requiring little extension work and technical know-how to use.

Most smallholder farmers in Burkina Faso and Niger cannot afford and do not use a range of synthetic pesticides, unless they work for Village Brigades. Those few that do use pesticides choose them based primarily upon the advice of neighbors, retailers, donors, and occasionally extension agents. They also use products in quantities they desire and can afford to make decisions when buying pesticides from retail shops.

Commercial farmers, on the other hand, have more resources and purchase both quality generic as well as newer (and more expensive) products from more reputable regional providers: Arysta Life Sciences/SAPHYTO (African Society of Phytosanitary Products and Insecticides), with a formulation plant in Bobo-Dioulasso, Burkina Faso and offices in Ouagadougou, SAPHYTO-AGRIMEX, headquartered in Niamey, with a franchise Maradi, and LDC (Louis Dreyfus Commodities), a Dutch company; as well as multinationals Bayer, BASF, Dupont, Dow, Syngenta, Machteshim Agan and Monsanto. Generally, large commercial producers purchase their pesticides directly from importers/wholesalers/distributors, in bulk, to save money, often bypassing smaller retail shops in the countryside outside of Niamey and Ouagadougou.


Retail stores in Niamey and Ouagadougou have available small 100ml bottles of pesticides, as well as 250ml sizes, which are more affordable to smallholder farmers than larger sizes (500ml, 1 liter). Smallholder farmers also have access to smaller (25-250g) foil-packs of powder formulations of fungicides containing mancozeb, and 50g of insecticides containing pirimiphos-methyl used on stored grain. These smaller quantities reduce the need for storing leftover quantities of pesticides in the home where children might be exposed. And, they are affordable for smallholders who may not require an entire liter of a pesticide on relatively small hectarage. Some retail stores in Niamey and Ouagadougou also had one-liter bottles of pesticides for sale.

It is important to note that, like most African Countries, Burkina Faso and Niger farmers receive shipments of fake (without active ingredients), adulterated (diluted active ingredients) and counterfeit (copies of brand name pesticides, but without quality controls on ingredients and formulation, and often with toxic hazardous manufacturing byproducts) pesticides. Major imports of pesticides into Burkina Faso and Niger come from both Ghana and Nigeria, sources of fake, adulterated and re-packaged pesticides, and China—known internationally as a primary source of counterfeit pesticides. It is imperative that the program recognize this issue and address it during training of beneficiary farmers.

4.3 FACTOR C: EXTENT TO WHICH THE PROPOSED PESTICIDE USE IS, OR COULD BE, PART OF AN IPM PROGRAM Burkina Faso and Niger smallholder farmers use intercropping and mixed cropping practices, which reduce overall pest and disease pressure on their crops. They also use hand hoeing to remove weeds. And, some make and use their own plant extracts to repel pests and reduce the incidence of diseases. Internationally, IITA (the International Institute for Tropical Agriculture, headquartered in Nigeria) has produced and introduced biological controls for cassava pests across the region, including in Burkina Faso and Niger. Both countries have IPM units in their Ministry of Agriculture (MOA), and do research on preventive and non-synthetic chemical controls. They support use of artisanal plant extracts, live-trapping of rodents, testing and use of resistant varieties, seed certification, crop rotation, biological control of cereal pest eggs by rearing and release of Trichogramma wasps, biological control of millet head miner by rearing and release of Habrobracon hebetor wasps, and others.

RISE II provides and promotes the use of improved, resistant, clean and treated seed, the principal IPM tools for pest and disease management. The program also promotes the use of Good Agriculture Practices (GAPs) for each crop. Some of the older generic chemicals being illegally imported into Burkina Faso and Niger are, unfortunately, broad-spectrum and may have developed resistance issues in other countries where use has been higher, in addition to being relatively inexpensive and affordable, which means that they are not the optimal choice for IPM programs.

In any case, the approved pesticides are recommended for use in specialized commodity-pest IPM plans (IPM plans to be developed by the IPs), but only if used wisely and judiciously, and as a last resort. Given the economic circumstances of most Burkina Faso and Niger smallholder farmers, the team considers it unlikely


that farmers will be able to afford any but small quantities of pesticides. This is even more reason to learn and use all available preventive IPM tools.

Agronomist field technical experts will need to ensure that farmers use as many preventive IPM practices as possible before deciding to use PERSUAP-approved synthetic chemicals, if they can afford them. Farmers who use pesticides will also need to be trained on how to determine proper dose and sprayer calibration, so as not to overdose, potentially killing important predators, parasites and parasitoids that attack and manage pest populations at tolerable levels. Annex 1 of the 2017 REGIS PERSUAP provides draft IPM plans for many of the value chains in the RISE II portfolio (see link in facesheet).

4.4 FACTOR D: PROPOSED METHOD OR METHODS OF APPLICATION, INCLUDING THE AVAILABILITY OF APPLICATION AND SAFETY EQUIPMENT Most pesticide labels contain specific crop-pest usage and dosage information, even beyond that authorized by INSAH, and farmers use these crop-pest recommendations. Pesticides in the smallholder farmer garden (maraichère) sector are applied by small 3-5-liter hand-pumped sprayers, and sometimes by dipping a branch into the pesticide mix and shaking it onto the crop, not a best practice. Smallholder farmers with more resources purchase 16-liter plastic lever-pumped backpack sprayers with spray wand for use in larger fields. Cheap Chinese respirators with single carbon filters, respirators with paper filters and paper face masks, gloves and plastic goggles were found available in several of the retail stores visited in Niamey, Maradi, Ouagadougou, Kaya and Fada N'gourma.

This PERSUAP proposes to further form and use farmer cooperatives to pool resources to be able to purchase sprayers, share and maintain them for more routine pests and diseases. The same could be done with some PPE. Each cooperative could identify a member with a skill for dosing and calibration and have that person do all the spraying for a small fee, or a barter of services or goods. Village Brigade members that have sprayers and PPE could be used to control more routine pests and diseases, using MOA resources. Other than Village Brigade members, most the smallholder farmers that do occasionally use pesticides do not use PPE due to cost of the PPE, and lack of training on pesticide risks.

4.5 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. Table 2 for approved AIs details specific human health or ecotoxicity risk associated. More information is also available in Annex 1 and 4 of the 2017 REGIS PERSUAP (see facesheet for link). USAID-supported projects must be limited to USEPA-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.

PESTICIDE ACTIVE INGREDIENTS ON PERSISTANT ORGANIC POLLUTANTS (POPS) AND PRIOR INFORMED CONSENT (PIC) LISTS


The Stockholm Convention on POPs and Rotterdam Convention’s 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 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 and http://www.pic.int.

ACUTE TOXICITY

WHO Class Ia and Ib and USEPA Class I pesticides are rejected for promotion to, or use by, project smallholder farmers. A few of the pesticides found in Burkina Faso and Niger contain active ingredients that are USEPA or WHO Class II acute toxicity (based on mg/kg of body weight); with less toxic alternatives, including preventive tactics and tools, and some curative pesticide choices, including some that are WHO Classes III and U. These should thus be promoted and used in place of Class II pesticides, when and where possible.

LOWER ACUTE TOXICITY PESTICIDES

Even USEPA Class III and IV and WHO Class III and U pesticides will present acute and chronic human health and environmental risks. In sufficiently high doses, any of them may kill or harm humans, or damage the environment and drinking water sources. Thus, pesticide safe use and handling training and practice are required for their use.

RISKS TO HUMANS For each PERSUAP approved pesticide AI, the WHO (used in Burkina Faso and Niger) and USEPA (used in the USA) acute human toxicity classifications, known chronic human toxicity, as well groundwater pollution potential (if known).

Pregnant women and children, as well as sick individuals, who are universally legislated to not be exposed to pesticides, should not spray or enter fields recently sprayed with chemicals that have chronic health risks such as endocrine disruption or reproductive and development toxin designations (see below).

Further, most INSAH-registered pesticides contain label and safety data sheet (SDS) information on the safe Re-Entry Interval (REI) and Pre-Harvest Interval (PHI) so farmers can be trained to look at the pesticide label information to determine when it is safe to both enter the field and harvest produce after spraying. Farmers who use pesticides repeatedly throughout the year may choose to avoid these risks, and will need to be trained on, and make the personal decision to buy and use PPE to protect themselves.

Each pesticide AI has physical and chemical characteristics, such as solubility in water and inherent ability to bind to soil particles and be held there (adsorbed). And each has a breakdown rate in nature, under both aerobic and anaerobic circumstances found in the soil. The ability of pesticide chemicals to make it intact all the way to groundwater is limited by these factors—and not just by solubility in water. If the chemicals are strongly held by soil, there is more time for them to be USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II)

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held and broken down by hydrolysis, oxygenation, and exposure to soil microbial digestion, and they do not enter the soil water interface and the groundwater table intact as easily. A listing of these properties for most of the pesticide AIs in use in Burkina Faso and Niger can be found by checking at this website: http://sitem.herts.ac.uk/aeru/ppdb/en/atoz.htm, searched by AI.

In general, known groundwater polluting pesticide AIs are well known, due to being found intact and persisting in groundwater in sufficient quantities through frequent testing in most developed countries. Herbicide AIs atrazine and metolachlor are common examples and glyphosate may persist in the soil and water longer than previously thought possible. Known groundwater pollutants are rejected for use; however, potential groundwater pollutants are not rejected for use, due to lack of sufficient evidence of presence in groundwater samples.

Beyond known groundwater pollutants, pesticide AIs with water solubility greater than 3 mg/liter have the potential to contaminate groundwater; and pesticide AIs with a soil adsorption coefficient of less than 1,900 have the potential to contaminate groundwater. In addition, pesticide AIs 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, pesticide AIs with a hydrolysis half-life greater than 14 days have potential to contaminate groundwater.

These factors, combined, allow groups like USEPA and Pesticide Action Network (PAN, a pesticide non-governmental organization [NGO]) to calculate groundwater pollution potential proxy values, which we use in our analyses. The potential for pesticides to enter groundwater resources depends, as indicated above--not on solubility alone--nor on the electrical charge contained on a pesticide molecule and its ability and propensity to adhere to soil particles, but on the nature and charge of the soil particles predominant in the agriculture production area. Sand, clay and organic matter, as well as different combinations of these, have different charges and adhesion potential for organic and inorganic molecules. Sandy soil generally has less charge capacity than clay or organic matter, and will thus not interact significantly with and hold charged pesticide molecules. So, in areas with sandy soil, the leaching potential for pesticides is increased, as is the velocity with which water and the pesticide AIs can migrate.

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

4.6 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). USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II)

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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 RISE II activities 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 value chains will likely occur with increased use. Many farmers still over- and under-dose and use non-selective pesticides, all of which increase 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 non-chemical IPM tools and tactics.

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 disreputable 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.

4.7 FACTOR G: COMPATIBILITY OF THE PROPOSED PESTICIDE USE WITH TARGET AND NON-TARGET ECOSYSTEMSThis 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 activity’s Environmental Mitigation and Monitoring Plans (EMMPs). Table 2 identifies 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. However, product labels and the SDS must be the primary sources of information for ensuring use compatible with target ecosystems. Therefore, the PERSUAP requires use per label and SDS, placing responsibility on IPs to choose and use pesticides in such a way as to minimize impacts on non-target organisms and ecosystems.

4.8 FACTOR H: CONDITIONS UNDER WHICH THE PESTICIDE IS TO BE USED, INCLUDING CLIMATE, GEOGRAPHY, HYDROLOGY, AND SOILSIn general, in addition to Factor G above, this requirement attempts to protect natural resources from the dangers of pesticide misuse and contamination, especially of soil and groundwater resources. These conditions, climate, geography, hydrology and soils are covered well in the above-referenced Biodiversity and Tropical Forestry Assessments. Please see these assessments to understand these conditions for each country.

4.9 FACTOR I: AVAILABILITY AND EFFECTIVENESS OF OTHER PESTICIDES OR NON-CHEMICAL CONTROL METHODS


RISE II activities plan to promote, as much as possible, IPM and GAPs in Burkina Faso and Niger. Each IP must prepare IPM plans which address target value chain with draft versions for reference found in Annex I of the 2017 REGIS PERSUAP (see facesheet for link). In this annex, many non-pesticide preventive tools are recommended as control measures, some of which are already being practiced by smallholder farmers. For many crop pests and diseases, only non-chemical controls are recommended. However, as established, effective pest management across the target crops, and activities, particularly at larger and more intensive production scales, is likely to require some chemical controls. As noted, pesticide use/support will be governed by activity-, crop- and pest-specific pest management plans. A major purpose of these plans is to assure a well-considered mix of non-chemical preventive and chemical controls.

Pest management should focus on improved crop management practices and crop varieties, and proper materials management and control, as well as biological, cultural, physical, mechanical, and other preventive IPM control methods discussed above, under Factor C. 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.

4.10 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.

Burkina Faso and Niger, as part of CILLS (Comité permanent inter-État de lutte contre la sécheresse au Sahel), helped produce a common regulation and pesticide registration through INSAH, and the MOA in each member country is responsible for implementation and enforcement of regulations. Issues with pesticide regulation and enforcement as identified in interviews with governments, pesticide wholesalers, retailers, and farmers are:

● Risks arise from the quantities of cheap fake, adulterated /diluted and counterfeit pesticides being imported illegally from Nigeria and Ghana. Smallholder farmers often cannot afford the newer, much costlier patent-protected pesticides, so they buy cheaper generics.

● Smallholder farmers who purchase re-packaged pesticides stored in empty water or juice bottles, or re-used pesticide containers take the risk of not knowing exactly what chemicals are in the bottle and on their produce, or how to respond if their child is poisoned.


● Many of the smallholder farmers who use pesticides do not use mandated PPE because most farmers do not have access to and cannot afford PPE to follow GAPs.

● Most farmers do not understand the importance of safely disposing of empty containers. Many Burkina Faso and Niger farmers simply throw the empty containers in the field, or reuse them.

● Governments budgets remain highly challenged to do comprehensive control of pesticides entering the country, auditory pesticide quality tests, and enforcement of regulations on safe distribution, storage, use and disposal.

● The MOAs in both Burkina Faso and Niger have limited resources available for research, extension, certified laboratories and enforcement services, including enforcing the registration and regulation of the import, sale, and use of pesticides.

● The MOAs 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 toxic chemicals that should not be handled by illiterate, untrained, unprotected and often unaware small-holder farmers.

Note: The best method for container disposal in Burkina Faso and Niger is to triple-rinse the containers, puncture them to discourage re-use, and bury them, dispose of them in municipal waste, or recycle them if such a facility exists. RISE II should strongly discourage burning plastic bottles and single-use pesticide sachets, which can lead to the formation of toxic fumes containing carcinogenic furans and dioxins. GlobalGAP and other Standards and Certification 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 in the Sahel. A WHO website footnoted below9

provides pesticide container disposal options.

4.11 FACTOR K: PROVISION FOR TRAINING OF USERS AND APPLICATORS USAID recognizes that, in addition to the promotion of IPM and use of PPE by the few smallholder farmers using pesticides, safety training is an essential component in programs involving the use of pesticides, be they artisanal or synthetic.

TARGETS AND TRAINING OVERVIEW

The need for thorough training is particularly critical in Burkina Faso and Niger, where the level of education of applicators may typically be low. Training is the chief mechanism for ensuring safer and effective pesticide use by USAID activities

9 http://www.who.int/whopes/recommendations/Management_options_empty_pesticide_containers.pdf USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II)

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and training of all relevant USAID and IP staff will be required. Relevant IP staff are defined as follows:

● IP staff who will apply or handle pesticides, or serve as extension agents;● Beneficiary farmers who will use or apply pesticides; ● Those being trained as extension agents under the activities;● Enterprises or cooperatives receiving USAID-funded loans or other credit

support that deal in or use pesticides; and● Beneficiary agro-input dealers.

Required training topics are detailed in Annex A and include:

● Definition of pesticides. ● Pesticide risks, the understanding that pesticides are bio-poisons. ● Risks associated with release of pesticides into the environment and

avoiding harmful effects.● Concepts of AIs versus formulated products. ● Classes of pesticides and the concept of broad spectrum versus narrow

spectrum, target specific pesticides.● Concept of proper application rates and pesticide resistance and techniques

for avoiding misapplication. ● Practice-focused training in the core elements of Safer Pesticide Use ● IPM (see A.2 Training in IPM) ● Reading and interpreting pesticide labels and SDS -- including understanding

PPE requirements and other precautions, dosage rates, and to identify AIs and expiration dates. (see A.3: Understanding Risks and A.4 Pesticide Labels and Material Safety Data Sheet)

● Use of proper PPE and its treatment and maintenance. (see A.5 Protective Clothing and Equipment)

● Proper use and maintenance of equipment including calibration of sprayers. Safer mixing and application of pesticides including ensuring compliance with Reentry and Pre-harvest intervals specified by the label/SDS. (see A.6 Proper Spray Technique: Protecting Against Pesticide Spray Drift)

● Safer Purchase, Transport, and Storage of pesticides. (see A.7 Pesticide Transport and Storage)

● Pesticide first aid and spill response. (see A.8 First Aid for Pesticide Poisoning)


● Clean-up and Disposal. (see A.9 Proper Pesticide Container Disposal and A.10 Proper Disposal of Obsolete and Unused Pesticides)

● Record keeping and monitoring. (see A.11 Monitoring and Data Record Keeping)

Training materials, emulation and schedules must be developed as a condition of this PERSUAP.

WEAKNESSES TO BE ADDRESS IN TRAINING

Choice to use or not use PPE. The decisions to use or not use PPE are made by individual farmers, based upon an understanding of risk as learned in training and read on pesticide labels, the amount of pesticides used, frequency of use, relative toxicities, local availability of PPE, cost of PPE, individually-acceptable levels of risk and risk reduction, and other factors irrespective of technical training and information received. Many times, suitable PPE is not available or affordable. Thus, one cannot consider farmers who choose not to use PPE as “untrained”. As with many non-commercial smallholder farmers in developed countries making these same decisions, many choose to assume the risks themselves by not buying and using PPE. The only way to fully enforce use of PPE is to subsidize it and make its use a condition for receiving assistance, which is unlikely to happen with USAID.

Continuous training. RISE II training must require any pesticide users to interpret product labels to understand product health risks, physical hazards, eco-toxicity and required safety measures. Continuous training requirements are specified in the attached SUAP.

A core strategy of many FFP projects is to promote knowledge about preventive IPM tools and tactics as well as pesticide use, risks, and safety among beneficiaries, and to strengthen the agricultural extension abilities and encourage farmers and other applicators to use them for advice. While most of the pesticide AIs put forward for approval by this PERSUAP are generally of toxicities at or lower than Class II, the pesticide toxicology profiles presented above under Factors E and F clearly show that use of any pesticides present some human health and environmental risks.

RISE II IPs will be responsible for providing appropriate PPE training and equipment for demonstration plot farmers and pesticide use trainees. IPs may, as appropriate, also encourage and work with retail agro-input supply stores on best practices and to increase PPE supplies and affordable use options for smallholder farmers. Field officers will continue to provide training and technical assistance to farmers on integrated pest management of fruit and vegetable plots.

Farmers need intensive and repeated training. Training is of dominant importance for Sahel projects farmers and farm laborers using pesticides. Sahel 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.


4.12 FACTOR L: PROVISION MADE FOR MONITORING THE USE AND EFFECTIVENESS OF EACH PESTICIDEEvaluating the risks, impacts and benefits of pesticide use should be an ongoing, dynamic process. Proper pesticide use and pest resistance are two of the risks that this factor is intended to address, as well as human health and safety and environmental effects.

On the farm, record keeping should track quantities and types of pesticides used, where they were used and what they were used for, with notes on efficacy. Notes on effectiveness of individual pesticides and pest numbers will help develop a more sustainable pesticide use plan for programs beneficiary farmers. Farmers will need to keep records of any reduction in pesticide efficacy experienced, which is the first indication that pest resistance may be developing. 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.


SECTION 5: PESTICIDE SAFE USE ACTION PLAN (SUAP)

5.1 INTRODUCTION TO SUAP This Safe Use Action Plan (SUAP), is the definitive statement of RISE II pesticide compliance requirements and is synthesized from the PER analysis:

● Section 5.2, immediately below, cites the locations in this RISE II PERSUAP where users can find the approved pesticides (i.e., Table 2).

● Section 5.3 identifies the compliance requirements for IPs upon approval of this PERSUAP. For IPs, they must meet the requirements of their parent IEEs noted in Table 1. For most RISE II IPs, the IEEs note that IPs must develop an activity-specific SUAP and report on implementation using the SUAP Tracker. The tracker helps IPs assign responsibilities and timelines for implementation of these requirements and track compliance, and for USAID to oversee this compliance as a mandatory element of activity implementation.

● Section 5.4 contains details of the mandatory “Pesticide Safer Use Action Plan and Compliance Tracker.”

● Section 5.5 summarizes the recommended best practices and safe use conditions to be used/supported with these pesticides that should be considered by IPs in the development of their SUAP and EMMP.

5.2 RISE II PESTICIDES REQUESTED FOR ANALYSIS Upon approval of this PERSUAP, the pesticide AIs and products listed as “approved” Table 2 may be supported by RISE II activities 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 activity’s SUAP. All products must be used in accordance to their labels. Approved pesticides are those that passed the 12-factor analyses, particularly Factor A (USEPA & INSAH Registration and RUP Status), Factor C, Factor E (Acute/Chronic Toxicological Hazards), and Factor F (Efficacy/Resistance) as analyzed and summarized under those factors.

5.3 SUAP COMPLIANCE REQUIREMENTS FOR IPS Each of the Programmatic IEEs for which this RISE II PERSUAP amends, specifies conditions to be met at the activity-level by IPs as well as tiered requirements for additional requirements for pesticide analysis. The conditions of each Programmatic IEE, the activities or projects governed by those Programmatic IEEs, analysis of how this PERSUAP complies with those conditions, and any follow-on requirement for partners are noted in Table 1. IPs should note the specific requirements of their IEE and discuss means of meeting those requirements for their A/COR.


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Details on SUAP development and the SUAP tracker are provided in Section 5.4. These documents are required of all FFP IPs, BFS funded activities, and RISE II activities which directly procure. use pesticides, or provide direct assistance for the purchase or use of pesticides. Section 5.5 identifies region specific needs and weaknesses that should be addressed, where applicable, by the IPs SUAPs.

RISE II actions only involving pesticide safer use training, IPM measures, and extension outreach, but not procurement or use of pesticides or direct assistance to purchase or use pesticides, may proceed with an approved EMMP in place rather than development of a SUAP and IPM plans. Those RISE II activities will be required to insert into an EMMP foreseeable risks and the appropriate recommendations from the PER that are applicable to their project that will reduce each of these risks. The EMMP should also include indicators of risk mitigation success, a monitoring timetable and responsible people/groups for implementation of these requirements, and for tracking compliance. RISE II EMMPs should include details on who will be trained, in which topics, and how often. The RISE II EMMPs should have measurable and monitorable indicators to be reported on in progress reports to USAID.

In addition, the following conditions apply as noted in the facesheet of this document.

In summary, the SUAP requires that IPs:1. Restrict the procurement, use, and support of pesticides in the covered activities to ONLY those pesticides containing the AIs listed in facesheet Table 2 below OR identified by the USEPA as exempt from regulation under the U.S. FIFRA.* For products which contain mixtures of AIs, all AIs in the mixture must be approved in order for that product to be approved under this PERSUAP.

Procurement, use of, or support for these pesticides is limited to the uses, geographies, and actions covered by this PERSUAP and must comply with (1) AI-specific restrictions and conditions in Table 2; and (2) all other requirements of the SUAP.

For pesticide products containing more than one AI, all AIs must be approved, and specific uses and conditions for all product AIs apply. Ultimately, the product label and the product safety data sheets (SDS), formerly known as a Material Safety Data Sheet (MSDS) are the appropriate sources of hazard communication, accounting for all aspects of product formulation, concentration, and potential synergy between AIs. The SDS must be obtained from the product manufacturer.

* These particularly low-risk AIs (primarily essential oils and other plant extracts) are listed at: http://www.epa.gov/sites/production/files/2015-12/documents/minrisk-active-ingredients-tolerances-2015-12-15.pdf

2. Do NOT support pesticide products with high acute toxicity except when use is conducted by professional applicators, trained and certified appropriately. Do NOT support products that are, or are highly similar to, USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II)

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products classified as RUPs by USEPA, except for aluminum phosphide in conformity with condition 3, below.

“High acute toxicity” applies to any product labeled as USEPA Acute Toxicity Category I or equivalent (e.g., those labeled with skull and crossbones, the word DANGER and/or POISON, or equivalent indications) or containing WHO AIs Class 1A and 1B.RUPs are pesticide products that are determined by USEPA as not appropriate for use by the general public for reasons of acute, long-term or ecological toxicity. In the United States, pesticides products that are labeled RUP can only be sold to and used by certified applicators or persons under the direct supervision of certified applicators, and only for those purposes covered by the applicator's certification (such as for row crops, tree crops, or structural pests). “Professional applicators” are defined as those holding a host country professional pesticide applicator certification, when such a certification program exists, an appropriate U.S. or EU certification, or as approved by the USAID Mission Environmental Officer (MEO), and in the absence of an MEO, as approved by the USAID REO.

Where pesticide product labels and SDSs specify inert ingredients, do not support pesticide products with inert ingredients removed from the currently approved inert ingredient list. The list can be found at: http://src.bna.com/kUm .

3. Assure that phosphine fumigation, if supported, is conducted in conformity with USAID’s PEA for Phosphine Fumigation of Stored Agricultural Commodities (i.e., “Fumigation PEA”) http://www.usaidgems.org/fumigationpea.htm

4. Ensure that commercial pesticide products procured, used, or recommended for use are properly labeled in a national language and include required essential information. Training in reading and understanding labels is a mandatory requirement for safer pesticide use.

5. Implement pesticide support in conformity with a set of locally adapted, crop- and pest-specific IPM plans and observe enumerated use restrictions. IPs must utilize preventive IPM tools and tactics provided in Annex 1 of the 2017 REGIS PERSUAP10, which is an IPM plan draft containing some key information for IP’s use for most value chains covered in this PERSUAP. Before resorting to use of PERSUAP-approved pesticides, IPs must develop more extensive and detailed IPM plans that address major pests in their respective value chains and preventive non-chemical IPM tools and tactics. Pest control and pesticide use must be part of an IPM scheme governed by crop- and pest-specific IPM-based plans and should be used only as the last resort after all preventive tools have been exhausted.

10 Available at: https://ecd.usaid.gov/repository/doc/51005.docxUSAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II)

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6. Train appropriate IP staff and beneficiaries in safer pesticide use and pesticide first aid. IPs must provide training in pesticide safer use and compliance with this PERSUAP to their staff and beneficiaries, including those using, selling, financing, providing extension services, or demonstrating pesticides with USAID funding. This training must include all topics listed in Annex A.1. During implementation, USAID will also work with IPs to build capacity on pesticide management and also to support training of trainers, who will then have the ability to work directly with beneficiaries in the field on safe pesticide use.

7. Ensure use per label, including the correct use of appropriate PPE for all pesticide use under IPs direct control. Otherwise, IPs must ensure access to, proper use of, maintenance of appropriate PPE, and use per label, to the greatest degree feasible.

8. Require safer handling of pesticides and use and maintenance of appropriate PPE. To the greatest degree practicable, IPs must require safer pesticide purchase, transportation, handling, storage, and disposal practices, and proper use and maintenance of appropriate PPE.

9. Systematically document and monitor all activity associated with any procurement, use of both of pesticides, including, where possible, monitoring for pest resistance.

10. Certify that any proposed procurement of pesticides is compliant with this PERSUAP and provide other information specified in the SUAP for review and clearance by the A/COR and the MEO (or REO if no MEO is designated) as requested.

11. Complete and use the “SUAP Tracker”, where mandatory (see Table 1), IPs must implement SUAP conditions and monitor and report such implementation using a tracking tool provided in Section 5.4. Any activity subject to this PERSUAP requirement must submit a completed SUAP Tracker to their A/COR and MEO (or REO) at least 30 days before the implementation of the activity and must then update it annually. The tracker is a mandatory tool for assigning responsibilities and timelines for implementation of PERSUAP requirements, and for tracking compliance.

Note: With respect to pesticides, the SUAP Tracker, where required, satisfies the requirement for an EMMP. Activity EMMPs should simply incorporate the SUAP Tracker by reference.

12. Pass down all requirements to subcontractors and grantees. Prime contractors must incorporate pesticide compliance requirements, as presented above, into each grant or subcontract that will involve assistance for pesticide procurement or use. Grants and subcontracts must also require reporting on compliance with these requirements.


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The SUAP requires that USAID Bureau(s) implementing RISE II activities:1. Announce the approved PERSUAP to all relevant teams.2. When pesticide registration changes take place amend this PERSUAP as

necessary. 3. Ensure that all relevant USAID staff receive an internal short-format (~1–2

hour) training on the requirements established by this PERSUAP. 4. A/CORs and MEO (or REO) review and approve IP pesticide procurement

requests as necessary.5. Put in place effective internal procedures to review SUAP Trackers

submitted by IPs. The Tracker template is provided in Section 5.4.6. A/CORs assure that the IP conditions summarized above are funded,

implemented, and monitored (per ADS 204.2 and 204.3.4.). 7. Ensure that contract and award language for each relevant activity

requires compliance with the IP conditions summarized above (per ADS 204.3.4). Note: USAID requirements may be expanded/changed based on the level of control USAID would like to exercise.


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5.4 SUAP TRACKERFor every activity subject to use of the SUAP Tracker in Table 1, the IP must submit an adapted and completed SUAP Tracker (Table 4 is the Tracker facesheet and Table 5 is the tracker body) to the activity A/COR by the date specified and must provide an annual update. The tracker satisfies the requirement for an EMMP for pesticide support action. The activity EMMP should simply incorporate the SUAP by reference. Table 5 should be adapted to the specific safer use action measures implemented by the activity.

TABLE 4. PESTICIDE SAFE USE ACTION PLAN & COMPLIANCE TRACKER - FACESHEET

BASIC INFORMATION SUBMISSION DATES:

PRIME CONTRACTOR

INITIAL SUBMISSION:

ACTIVITY ANNUAL UPDATE #1

PESTICIDE COMPLIANCE LEAD & CONTACT INFORMATION

ANNUAL UPDATE #2

SUMMARY OF PEST MANAGEMENT NEEDS ON ACTIVITY

ANNUAL UPDATE #3

Note: pesticide “support” = use of USAID funds to: purchase pesticides; directly fund the application of pesticides; recommend pesticides for use; enable the application or purchase of pesticides via provision of application equipment, credit support, etc.


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TABLE 5. PESTICIDE COMPLIANCE TRACKER: USAID FUNDED ACTIVITIES IN THE SAHELREQUIRED COMPLIANCE (MITIGATION) MEASURE

TIMELINE INITIAL COMPLIANCE STATUS (IF NOT KNOWN, SO INDICATE)

ACTIONS PLANNED TO ACHIEVE & MAINTAIN COMPLIANCE (W/ DEADLINES)insert extra rows if needed

RESPONSIBLE PARTY

insert extra rows if needed

STATUS OF COMPLIANCE ACTIONSinsert extra rows if needed

Support only the pesticides authorized in Table 2, complying with AI-specific uses and restrictions in Table 2. Ensure NO SUPPORT for High-toxicity chemicals (USEPA Category I, WHO IA or IB, or equivalent) for smallholder farmers.

Immediately

Ensure that RUPs, as classified by USEPA are not used, unless full EA was conducted.

Immediately

Distribute copies of the list of allowed AIs and products to all activity field extension staff & advise them regarding the deadline for compliance.

To be implemented as soon as possible but not later than Date:

Assure that USAID-funded Pesticide support is limited to ONLY AIs APPROVED BY PERSUAP in conformity with AI-specific restrictions specified in Table 2.

To be implemented as soon as possible but not later than Date:Continue Verification over Life of


Program (LOP)Ensure that commercial pesticide products procured, used, or recommended for use are properly labelled

Ensure availability of product label and SDS.

Immediately and over LOP

Implement pesticide support for field agriculture in conformity with a set of locally adapted, crop- and pest-specific IPM plans and observe enumerated use restrictions.

Adopt/develop crop- and pest-specific IPM-based pest management plans (IPM plans). For chemical controls, IPM Plans must include the use restrictions specified in Table 2.

To be implemented by Date:

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

To be implemented by this Date:


Provide first-time training to appropriate IP staff, partners and beneficiaries in the IPM plans (See Annex A)

To be implemented by this Date:

Provide refresher training in the IPM plans annually.

From Date: Over LOP

Require and enforce IPM plan implementation in situations where the activity has direct control over pesticide use

Over LOP

Require and enforce that field extension under direct activity control be IPM-based.

Over LOP

Where activity control over extension or agricultural practice on the ground is less than complete, promote and support pesticide use in conformity with IPM plans to the greatest practicable extent.

Over LOP

Modify IPM plans over LOP, based on ground-truthing/field experience.

Over LOP

Train appropriate IP staff and beneficiaries in safer pesticide use and pesticide first aid in conformity with Section 5.Ensure that for all Immediately


beneficiaries that receive support for procurement and use of seed treated with pesticides, training in handling dressed seed is provided.

and over LOP

Ensure that for all beneficiaries that receive support for post-harvest storage of grains involving pesticides are trained in handling, disposal, and waiting periods before the treated commodities can be consumed.

Immediately and over LOP

Develop a Training Plan for Pesticide Safe Practices and IPM for activity staff

Before training

Develop or source curricula and training materials conforming to required training elements specified in Section 4, Factor K.

Before training

Implement training plan, providing first-time training to all relevant staff and beneficiaries

To be implemented Date:Than periodically as needed


Ensure the correct and safe use of pesticides and PPE per label for all pesticide use under direct control, otherwise ensure per label use to the greatest degree practicableFor pesticide use under direct IP control, implement core risk mitigation measures per label and as specified in Table 2.Where control is less complete, take all practicable measures to support and promote implementation of these measures.

Over LOP

Whenever providing, supporting, or recommending pesticides for use, assure that appropriate PPE is available and, to the degree possible, require its use.

Over LOP

Whenever directly using, procuring, or supplying pesticides, assure that quality application equipment is available and local capacity for application is available and maintained.

Over LOP

People who are not wearing PPE should not enter pesticide treated areas during Re-entry Intervals (REI) to perform tasks that involve contact with

Over LOP


pesticide treated surfaces. Each pesticide label specifies a REI usually ranging from 12 to 72 hours.Warning signs should be posted to warn people in advance about pesticide application and REI.

Over LOP

Products that are suspected to have potential to cause harm to unborn child will not be handled and applied by pregnant women. Pregnant women should not enter treated areas during application and REI.

Over LOP

Pre-harvest interval (PHI) is the time required between the last application of pesticides and the safe harvesting of edible crops for immediate consumption. Farmers will be trained about the importance of adhering to the PHI stated on the label to ensure no chemical residues are found on harvested crops.

Over LOP

To the greatest degree practicable, require safe pesticide purchase, transportation, handling, storage, and disposal practices, and use and maintenance of the appropriate PPE.


Ensure that all pesticides handling follows procedures addressed by Annex A.

Over LOP

Systematically document and monitor all activity associated with any support to pesticides, including monitoring for pesticide resistance.

Pesticide efficacy in demonstration must be evaluated

Over LOP

Any evidence of pesticide resistance development must be tracked and reported as detailed in Section 4, Factor L and Annex A.11.

Over LOP

Pass-down all requirements to subcontractors and granteesPrime contractors/grantees must write pesticide compliance requirements as set out above into each grant or sub-contract that will involve support for pesticide use.

As appropriate and over LOP

Ensure that Phosphine fumigation, if supported, is conducted in conformity with USAID’s PEA for Phosphine Fumigation of Stored Agricultural Commodities


Ensure Fumigation PEA compliance

As appropriate and over LOP


5.5 RECOMMENDED BEST PRACTICES AND SAFE USE CONDITIONSThe following are recommendations based on the PER analysis and stakeholder interviews and lessons learned from RISE I implementation. The issues should be reviewed by the IPs and considered in developing of their activity-specific SUAP and design of their agricultural actions.

SELECTING PESTICIDES JUDICIOUSLY

● Approved pesticide use must not promote, finance and use on demonstration farms, pesticides not registered by USEPA for same or similar use or those classified by USEPA as RUP products.

● RISE II activities should obtain and retain copies of the SDSs (i.e., MSDS) for each pesticide that their beneficiary farmers use frequently.

● Activities shall promote the use of brand-name pesticides of known quality, with complete label safety information, and shall caution smallholder farmer beneficiaries on use of pesticides imported from China, Ghana and Nigeria and not meeting local legislated standards.

● If activities wish to recommend or use on demonstration farms any pesticides not registered by USEPA or categorized by USEPA as a RUP product, then a full Scoping Study and Environmental Assessment (EA) must be done and approved by the BEO.

● Where alternatives (WHO Classes III and U) exist, do not recommend or use WHO acute toxicity Class II (as noted on the labels, and which are generally equivalent to USEPA Class II acute toxicity) pesticide products, except for use by highly trained, certified and protected staff of pest control companies.

PROMOTING IPM PLANNING AND IMPLEMENTATION

● Preventive IPM tools and tactics for each commodity-pest combination should be taught to, recommended to and used by beneficiary farmers before the use of synthetic pesticides. This adaptation of the information provided should be done by local experts who understand the cultural and social context, and know how to accomplish behavior change in their cultural milieu.

● Activities should continue to assist with the provision of new IPM tools/tactics/technologies like resistant and certified disease-free and treated seed.

● Activities should develop printed extension and IPM flyers, pheromone traps, pest prevention text messaging systems for farmer with cell phones.


● Burkina Faso and Niger would benefit from a national Pest Management Plan containing preventive tools and tactics to help reduce pests/diseases of major crops and livestock, as well as curative pesticides if needed.

● IPM plans be used as a pullout, stand-alone section that can be reproduced as necessary, and should be considered for adaptation, translation into the local language, laminated, and distributed to project field staff to help advise beneficiary farmers.

IMPROVING METHOD OF PESTICIDE APPLICATIONS

● Activities should train farmers on proper use of PPE as well as pesticide dosing, sprayer calibration, use, maintenance and empty container disposal by rinsing, puncturing and disposal by burial, municipal waste, or recycling.

● IPs should introduce the concept of use of spray service providers hired both inside and outside of cooperatives.

● All farmer seed that requires treating with powdered fungicide AI thiram, which is too toxic for smallholder use, should be done by government-certified pest control company staff who have proper PPE, bulk seed treatment equipment, and technical training.

ENFORCING MEASURES FOR MITIGATION OF RISKS TO ENVIRONMENTAL RESOURCES

Adhering to the following do’s and don’ts can mitigate (reduce) ecotoxicological exposures and risks:

Do’s

● Emphasize and use IPM practices in crop production● Read and follow pesticide label instructions● Provide pictograms on appropriate use and precautions for illiterate

users● Choose the pesticide least toxic to fish, honeybees, birds, aquatic and

other organisms (see Table 2) 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

● Prevent access to fields for children and pregnant women at the time of spraying

Don’ts

● Do not spray over ponds, irrigation canals 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 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 or evening when it is cool with no wind or rain, and when honeybees are finished foraging for the day.

● Do not spray in fallows that could be used as pasture● Do not promote pesticides with water pollution potential if farms are

located on high water tables with predominantly sand soil.

MANAGING AND MITIGATING PESTICIDE 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.


● Avoid backpack mixes with same mode of action. Never combine two pesticides with the same mode of action in a backpack mix, as this 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 11, Fungicide Resistance Action Committee 12 and Herbicide Resistance Action Committee 13. 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.

● Differ strategies used for rotations 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.

● Ensuring effectiveness in selection and application of pesticides. Through training, project field staff shall increase local knowledge on the classes of pesticides available, effective, and present the lowest risk. 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 heavily-used pesticide products.

11 http://www.irac-online.org/12 http://www.frac.info/13 http://www.hracglobal.com/


STRENGTHEN COUNTRY’S CAPACITY TO REGULATE PESTICIDES AND MONITOR COUNTERFEITS

● As feasible, through contacts with the government of Burkina Faso and Niger, encourage and follow developments in the regulation and registration of pesticides and registration of pesticides for non-commercial vegetables and fruit crops.

● Sensitize government officials about the threats to Niger and Burkina Faso’ trade potential due to banned POPs entering the countries illegally and conduct training on such.

● Upgrade MOA or other analytical laboratories to be able to test for AIs and byproducts.

● Randomly test samples of all products imported to determine amount and quality of AIs, potentially with funding combined from donor and export agents in the private sector.

● Do additional samples of suspect products.● Use databases of counterfeits to identify illegal pesticides.● Encourage the local government customs officials to seize illegal

pesticides. ● Encourage government officials to prosecute counterfeiters.● Levy resources for enforcement of pesticide regulations through taxes

in the agricultural sector.● Promote products from reputable stores or distributors during field

days and in pilots.● Train beneficiaries to avoid bargains from unknown suppliers .● Ensure product labels are also in the national language/s.● Avoid promoting non-registered products made in China or Malaysia

and conduct training on selecting quality pesticides.● Develop guidelines and resources for the safe disposal of pesticides

and their containers.● Ask for a receipt that includes accurate purchase details. ● If information relating to the sale of illegal products is found, contact

the relevant national authority.

Note: Two companies currently focus on detecting counterfeit pharmaceuticals, mPedigree (http://mpedigree.net/) and Sproxil (https://www.sproxil.com/about-us/). Both aim—in the future—to be able to detect counterfeit pesticides as well, and merit following and perhaps using for this purpose. One drawback of using these applications, is that they


market to and favor larger international producers who have sufficient financial resources, and could block legitimate smaller companies from producing legal, off-patent generic pesticides. In an ideal world, team and project would like to be able to identify all counterfeit chemicals for farmers, but without analytical capability by and funding for the MOA, or a regional International Standards Organization (ISO)-certified laboratory sub-contracted and paid to randomly check imported products for AI presence and concentration, as well as to check for other chemical contaminants or additions, this will continue to be challenging, if not impossible. None of these conditions exist. Kindly see http://www-pub.iaea.org/MTCD/Publications/PDF/te_1612_web.pdf. If USAID or DCHA wishes to eliminate all unsafe products, USAID must provide a special fund and operations—and accept full legal responsibility—for the testing and publishing results of such pesticide tests.

POSITIVE FACTORS ALREADY IN PRACTICE THAT NEED REINFORCEMENT IN BURKINA FASO AND NIGER

● INSAH helps regulate pesticide use and does pesticide registration for francophone countries including Burkina Faso and Niger.

● The international ban on pesticides containing endosulfan is slowly being implemented, reducing the amounts available and encountered in the field.

● Stockpiles of large quantities of old locust plague pesticides are being disposed of, with donor help.

● The number and quantity of highly toxic Class I and banned chemicals has decreased compared with just 10 years ago (personal observation), and many less toxic (Classes III and IV/U) products are being registered and used by farmers.

● To enhance village crop protection abilities, country MOAs in West Africa, including those in Burkina Faso and Niger, have organized groups of individuals, by village, with pesticide sprayers, PPE and training on safe pesticide use primarily for outbreaks of pests like locusts and grasshoppers that attack crops on a large scale across a village or region. These are not the same as private spray service applicators, who have even more training, information, skills and personal protection. Farmers that are organized into "Village Brigades" with pesticide backpack and ultra-low volume sprayers, PPE and training on IPM and safe pesticide use, helps manage pest and disease outbreaks with reduced risks.

● Availability of biologically-derived, effective and approved products like non-aflatoxin Aspergillus flavis, abamectine, BT/ Bacillus thuringiensis Kurstaki, kaolin clay/aluminum silicate, spinosad, Tagetes African Marigold oil and thyme oil.


● Presence of NGOs like Bioprotect and entrepreneurial farmers making extracts of neem tree seed, garlic, chili pepper, onion and citrus skins for use as insect, mite and disease organism reducers.

● The fact that Niger and Burkina Faso must follow European standard and certification systems to reach European markets with high-value produce. Many farms oriented for export are becoming more organized following standard and certification systems like GlobalGAP, Organic, Fair Trade and others, which inevitably contain recommended IPM measures that work as well as reduced-risk pesticide products and safe pesticide use requirements.

● The increasing availability and use of small, single-use sachets and smaller bottles of pesticides (as opposed to one and five liter bottles) with labels containing important and potentially life-saving information (in local languages) that are marketed by the formal pesticide importer/distributor sector. These small quantities and labels help resolve on-farm pesticide quantity storage, illegal subdividing and use issues.


ANNEX A: TRAINING TOPICS AND SAFE PESTICIDE USE WEB RESOURCES

A.1 MANDATORY ELEMENTS OF PESTICIDE SAFE USE TRAININGPesticide safe use training must address the following minimum elements.

● Definition of pesticides.● Choice of high quality generic or patent-protected pesticides from reputable

companies● Avoidance of fake, diluted/adulterated or counterfeit pesticide products● Pesticide risks and the understanding that pesticides are bio-poisons.● Concepts of AIs vs. formulated products.● Classes of pesticides and the concept that specific pesticides are effective

against only certain classes of organisms. ● Concept of proper application rates and the concept of pesticide resistance and

techniques for preventing resistance. ● Concept that pesticides have specific organisms against which they are

effective.● Survey of the core elements of safe pesticide use: IPM, safe purchase,

transport, storage, mixing, application, re-entry and pre-harvest intervals, and clean-up and disposal, including specific treatment of PPE.

● Pesticide first aid and spill response.● Interpretation of pesticide labels, particularly to understand PPE requirements

and other precautions, dosage rates, and to identify AIs and expiration dates.● Proper sprayer operation and maintenance. ● Precautions before, during and after spraying.● The choice of appropriate times for spraying.

The following sections provide specific content notes on some of these topics.

A.2 INTEGRATED PEST MANAGEMENTIPM is an integral part of safe pesticide use and supporting the use of pesticides only within an IPM framework is a core requirement of this PERSUAP. Therefore, pesticide safe use training must build an understanding of IPM fundamentals.


The heart of IPM is an understanding of the relationship between pest injury, damage, yield loss, and economic loss. IPM was developed within the discipline of economic entomology. Farmers who are not trained in IPM may spray a crop upon seeing a single insect in a field or a few brown spots of a disease on a leaf. Pesticides are expensive and should only be used as a last resort and only when economically justified.

Threshold determination. Extension workers and farmers first need to understand the relationship between increasing injury levels and crop yield of each pest which is known as the damage function. A small amount of injury, in fact, can cause yield gain called overcompensation. In most cases, significant yield loss does not occur until a certain pest density occurs in the field because the crop can compensate for this level of damage. Then there is normally a linear decline in yield with increasing pest density. From this relationship, the economic injury level, economic threshold, or action threshold can be defined in the case of insect pests. Other methods to assess the threat of weeds and crop diseases will need to be developed based on field experience. Certain guidelines can be developed based on experience in neighboring countries.

IPM involves several tiers of integration. First there is the integration between control methods which must be harmonious. A non-harmonious example is the negative effect of pesticides on biocontrol agents. Biocontrol, which is the action of natural enemies against the pest, is free to the farmer so it behooves him not to upset this delicate balance unless necessary. The next tier of integration occurs between the different pest control disciplines. When one sprays an insecticide, herbivorous insects feeding on weeds are killed. Some fungicides also kill insect pests. Removing weeds forces army worms to feed on the crop. The third tier is integration with the cropping system and farming system. Crops that are well nourished can tolerate more damage. Many crop husbandry practices also affect pests, either positively or negatively. Application of nitrogen fertilizer is an example. On the one hand, it can stimulate plant diseases, but on the other nitrogen fertilizer can provide strength of the crop to tolerate insect pest damage.

Pests do not occur in isolation; thus, the crop must deal with multiple pests as well as multiple stresses. A crop that is weak from zinc deficiency or water stress cannot tolerate as much pest damage as a healthier crop. In fact, some sucking insect pests explode in abundance on a drought-stressed crop, further exacerbating the problem. The relationship between multiple pests and multiple stresses can be additive (1 + 1 = 2), antagonistic (1 + 1 = 1), or synergistic (1 + 1 = 3). This can occur in terms of yield loss from adding more pests or stresses, or can occur in terms of yield gain when one or more stresses are removed due to an effective curative control effort.

The IPM training will provide examples of the different pest control methods beginning with preventative ones, which start with quarantine and cultural crop husbandry methods based on good agronomic practices. These methods increase the crop’s tolerance for pest injury. Many of these methods fall under the rubric of cultural control. Host plant resistance is another good example of prevention. Other pest control methods can be physical (e.g., a fence to keep out animals), mechanical (e.g., using nets), or biological (e.g., parasitoids, predators,


pathogens). Biological methods include natural control and man-induced methods, such as purchasing and releasing natural enemies or using selective pesticides.

As a last resort, there is chemical control.

Farmers will need to be trained to recognize pests in the field and to be able to assess their densities, as well as know several methods of control for each. Training manuals with high-quality color photos will be essential in the training process. Government-approved, recommended practices need to be published and updated annually in guides given to extension officers.

Using PPE and clothing needs to be understood for each level of toxicity. This information is summarized below along with other information on the risks and hazards of transport, storage, and disposal of pesticides. Safety practices, such as the importance of pesticides not being stored in the home where children can find them, should also be understood and implemented.

A.3 UNDERSTANDING PESTICIDE RISKSMany times, non-chemical controls can be used to deal with pests. When deciding to use a pesticide, it is important to understand the risks associated with a specific product or treatment. No matter the treatment method, there is always a degree of risk associated with using a pesticide. Understanding the risk from specific pesticides can help determine whether a given pesticide is appropriate, or help choose between two different products.

Many people believe that some pesticides are “safe,” while others are “dangerous.” All chemicals, including all pesticides, have the potential to be hazardous. Even products that are considered low in toxicity, natural, or organic can be hazardous if someone or something encounters enough of the substance.

The toxicity of a pesticide, its formulation, and how much a person touches, ingests, inhales, or gets in contact with skin and eyes are all important considerations. The likelihood of experiencing some health effect because of using a product is referred to as the pesticide risk. The pesticide risk depends on which pesticide is used, how much is applied, frequency of application, and who or what has contact with the pesticide. The length of time the exposure occurred and how much of the substance gets on or in the body are important details in understanding the risk.14

Occupational exposure often occurs in cases of agricultural workers in fields, people living close to agricultural fields, and people working in the pesticide industry and working in structural pest control. Exposure of the general population occurs primarily through eating food and drinking water contaminated with pesticide residues. Water, soil, and air becomes contaminated from pesticides leaching into the ground, running off into rivers with rain water, or drifting as spray from pesticide applications.

14 http://npic.orst.edu/factsheets/WhatsMyRisk.pdf USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II)

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Ecological risk is risk posed by a pesticide to the wildlife and the environment. US EPA looks at ecological risks, including:

● Wildlife and aquatic organisms: How could the pesticide affect various animal species?

● Plant protection: How could the pesticide affect various plant species?● Non-target insect: How could the pesticide affect insects other than the

ones the pesticide is intended to kill?● Environmental fate: What happens to the pesticide in soil, water, and air

after being released into the environment?● Residue chemistry: How much pesticide is present in the environment over

time after application?● Spray drift: How much could the pesticide drift off-site when sprayed from

the air? This helps to determine exposure of non-target organisms.An adjuvant is any material that is added to a pesticide solution to enhance or modify the performance of the solution. Most pesticides are not flammable, but the solvents or diluents of liquid emulsion concentrates or oil solutions—xylene, kerosene, or other organic solvents—can be flammable and under some conditions explosive. Adjuvant can be inert but it can also significantly increase pesticide toxicity.

A.4 UNDERSTANDING PESTICIDE LABEL AND MATERIAL SAFETY DATA SHEET The label of a pesticide container must have all the information about risks as well as information needed for safe and effective use. Additional important details about risks of pesticide products and instructions about safe use can be found in the manufacturer’s MSDS. Labels and MSDS for some pesticides are available online at http://www.cdms.net and http://www.greenbook.net.

The label on a pesticide container has three main functions:

● To tell the user what pest the product can be used on. ● To tell the user how to handle, use, and store the pesticide safely.● To tell the user how and when to apply the pesticide for the best effect.

By law, pesticide labels must contain:

● The name of the product. ● Level of toxicity. ● Active ingredients.


● Other ingredients-co-formulates.● The pests which the product will control.● The rate of application of the product (how much of it to use). ● The time and method of application. ● Directions for handling the product safely. ● First aid procedures in case of an accident. ● Any special instructions or warnings about its use, transport, storage, or

disposal. ● The net contents (weight when packed) of the container.

The pesticide pictogram will provide information about risks and safety measures required including PPE.

All programs must review the MSDS and provide training on reading and understanding the pesticide label prior to using pesticides.

A.5 PESTICIDE SAFETY AND USE OF PROTECTIVE CLOTHING AND EQUIPMENTTraining must address the types of PPE, when they should be worn and why.

TABLE 4. HANDLER PPE FOR WORKER PROTECTION STANDARD PRODUCTSROUTE OF EXPOSURE

TOXICITY CLASSIFICATION BY ROUTE OF EXPOSURE OF END-USE PRODUCTI DANGER

II WARNING

III CAUTION

IV CAUTION

Dermal Toxicityor Skin Irritation Potential1/

Coveralls worn over long-sleeved shirt and long pants

Coveralls worn over long-sleeved shirt and long pants

Long-sleeved shirt and long pants

Long-sleeved shirt and long pants

Socks Socks Socks SocksChemical-resistant footwear

Chemical-resistant footwear

Rubber boots or shoes

Rubber boots or shoes

Chemical-resistant

Chemical-resistant

Chemical-resistant

No minimum4


Gloves2 Gloves2 Gloves2

Inhalation Toxicity Respiratory protection device3

Respiratory protection device3

No minimum4 No minimum4

Eye Irritation Potential

Goggles5 Goggles5 No minimum4 No minimum4

1 If dermal t1/Toxicity and skin irritation toxicity categories are different, PPE shall be determined by the more severe toxicity classification of the two. If dermal toxicity or skin irritation is category I or II, refer to the pesticide label/MSDS to determine if additional PPE is required. 2 Refer to the pesticide label/MSDS to determine the specific type of chemical-resistant glove.3 Refer to the pesticide label/MSDS to determine the specific type of respiratory protection.4 Although no minimum PPE is required for these toxicity categories and routes of exposure, some specific products may require PPE. Read pesticide label/MSDS.5 “Protective eyewear” is used instead of “goggles” and/or “face shield” and/or “shielded safety glasses” and similar terms to describe eye protection. Eye glasses and sunglasses are not sufficient eye protection.

Note: Where necessary, farmers can make their own PPE. For example, a plastic or water repellent apron from the waist to ankle length, can be fashioned from a large piece of plastic purchased in the local market (important if walking through the spray path).

Source: CropLife


A.6 PROPER SPRAY TECHNIQUE: PROTECTING AGAINST PESTICIDE SPRAY DRIFTMany farmers apply pesticides with a knapsack sprayer, which means that delivery of pesticides is either in front of the person spraying or to the side, not to the back as is the case with tractor-drawn sprayers. Inevitably pesticide drift will be carried by the wind and potentially settle on sensitive ecosystems such as national parks if they are nearby. Herbicides pose the greatest risk for environmental damage, especially when their drift lands on neighbors' crops and kills or severely damages them.

The potential for drift to travel long distances has been shown with highly residual chlorinated hydrocarbon pesticides, such as DDT, which have moved through the atmosphere and been found in measurable quantities at both poles on earth. Pesticides that can be transported to the earth’s distant poles are bound tightly to dust particles carried high into the atmosphere and transported by jet streams. Their presence only represents a very small percentage of the drift. Spray drift is a mostly local phenomenon, whereby spray droplets move to areas near the field.

There are several ways in which pesticide drift can be minimized:

Increase spray droplet size. Fog-sized droplets can travel three miles (4.8 km) while coarse droplets typically travel less than 10 feet (3 meters). To increase droplet size, the farmer can reduce spray pressure (e.g., 30 to 50 pounds per square inch [2-3.5 kg/cm2] with 5 to 20 gallons [19 to 76 liters] of water per acre [.4 ha]), increase nozzle orifice size, use special drift reduction nozzles, and purchase additives that increase spray viscosity.

Distance between nozzle and target. Reduce the distance between the nozzle and the target crop.

Temperature and relative humidity. As pesticides vaporize under high temperature, low relative humidity and/or high temperature will cause more rapid evaporation of spray droplets between the spray nozzle and the target. Evaporation also reduces droplet size, which in turn increases the potential drift of spray droplets. It is best not to spray in the heat of the day to avoid drift problems.

Avoid spraying when the wind speed > 10 mph (16 km/h). As drift occurs as droplets suspended in the air, it is best to minimize applications during windy days. If spraying must be done, however, the farmer should spray away from sensitive areas. Local terrain can influence wind patterns; thus, every applicator should be familiar with local wind patterns and how they affect spray drift.

Do not spray when the air is completely calm or when a temperature inversion exists. When the air is completely still, small spray droplets become suspended in the warm air near the soil surface and will be readily carried aloft and away from susceptible plants by vertical air movement. Temperature inversion occurs when air near the soil surface is cooler than the higher air. Temperature inversions restrict vertical air mixing, which causes small suspended droplets to remain in a concentrated cloud and impact plants two miles or more downwind. This cloud can move in unpredictable directions due to the light, variable winds common during inversions. USAID Senegal/Sahel Regional Office (SRO) Resilience in the Sahel Enhanced II (RISE II)

62

Application height. Making applications at the lowest height reduces exposure of droplets to evaporation and wind.

A.7 PESTICIDE TRANSPORT AND STORAGE Where IPs or beneficiary groups will be transporting pesticides, training must address the fundamentals of safe transport of pesticides. (Some of the largest accidents involving pesticides have occurred during transportation.) Drivers should be trained on how to deal with and contain spills and not to transport pesticides with food. Many of the agro-dealers are small and ship their stock individually in relatively small quantities. Agro-dealers should be sensitized about minimizing potential risks during transportation. Minimum elements of safe transport are:

● Keep pesticides away from passengers, livestock and foodstuffs; ● Do not carry pesticides in driver’s compartment;● Containers must be in good condition; ● Do not transport packages with any leakage; and,● Transport under cover and protected from rain, and direct sunlight.

Storing pesticides properly protects human and animal health, safeguards wells and surface waters, and prevents unauthorized access to hazardous chemicals. The pesticide label is the best guide to storage requirements for every product. The MSDS provides additional information on normal appearance and odor as well as flash point, fire control recommendations, boiling point, and solubility.

Preventative measures are required in pesticide warehouses to reduce cases of pilferage, exposure through leakages, theft, and expiration of pesticides. Where IPs or beneficiaries, including agro-dealers, will be maintaining pesticide stores, training must address these practices, as per the best management practices for pesticide storage highlighted in Food and Agriculture Organization (FAO) storage manual15 and summarized below:

● All primary pesticide storage facilities will be double-padlocked and guarded on a 24-hour basis.

● All the storage facilities will be located away from water sources, domestic wells, markets, schools, hospitals, etc. Wastewater from pesticide storage facilities must not be drained directly into public drains but should be pretreated on site.

● Soap and clean water will be available always in all the facilities.● A trained storekeeper will be hired to manage each facility.

15 "Pesticide Storage and Stock Control Manual." Pesticide Storage and Stock Control Manual. Web. 18 Aug. 2015. http://www.fao.org/docrep/v8966e/v8966e00.htm .


● Pesticides will be stacked as specified in the FAO Storage and Stock Control Manual.

● Inventory management will include recording expiration dates of all pesticides and maintaining a “first-in first-out” stocking system.

● All the warehouses will have at least two exit access routes in case of a fire outbreak.

● A non-water-based fire extinguisher will be available in the storage facilities, and all workers will be trained on how to use this device, and how to respond to fire (see below).

● Warning notices will be placed outside of the store in the local language(s) with skull and crossbones sign to caution against unauthorized entry.

Further, if IP-run pesticide stores exist in an area with fire or emergency services, local first responders must receive training on how to deal with pesticide fires. The smoke from such a fire is highly hazardous and effluent from water spray can do great harm to the environment. If fire fighters use water to put out a fire in a pesticide storage shed, the runoff will be highly toxic.

A.8 FIRST AID FOR PESTICIDE POISONINGIt is important to provide training on recognition of the symptoms of a pesticide poisoning so the victim will receive timely treatment. Contact information of the closest medical facility must be known and available if someone can be possibly poisoned with a pesticide. Quick action could save the victim's life. Farmers must be trained to make sure to take the label and if possible the MSDS on the chemical to the hospital. This will enable the medical professionals to treat the victim properly and promptly.

Training must include the basic elements of pesticide first aid, as per the table below. Wherever possible, personnel at local health facilities should participate in/receive such training.

TABLE 5. BASIC ELEMENTS OF PESTICIDE FIRST AID General Read the first aid instructions on the pesticide label, if possible, and

follow them. Do not become exposed to poisoning yourself while you are trying to help. Take the pesticide container (or the label) to the physician.

Poison on skin

Act quickly.Remove contaminated clothing and drench skin with water.Cleanse skin and hair thoroughly with detergent and water.Dry victim and wrap in blanket.

Chemical burn on skin

Wash with large quantities of running water.Remove contaminated clothing.Cover burned area immediately with loose, clean, soft cloth.


Do not apply ointments, greases, powders, or other drugs in first aid treatment of burns.

Poison in eye

Wash eye quickly but gently.Hold eyelid open and wash with gentle stream of clean running water.Wash for 15 minutes or more.Do not use chemicals or drugs in the wash water; they may increase the extent of injury.

Inhaled poison

Carry victim to fresh air immediately.Open all doors and windows so no one else will be poisoned.Loosen tight clothing.Apply artificial respiration if breathing has stopped or if the victim’s skin is blue. If victim is in an enclosed area, do not enter without proper protective clothing and equipment. If proper protection is not available, call for emergency equipment from your fire department (if available).

Poison in mouth or swallowed

Rinse mouth with plenty of water.Give victim large amounts (up to 1 quart) of milk or water to drink.Induce vomiting only if instructions to do so are on the label.

Procedure for inducing vomiting

Position victim face down or kneeling forward. Do not allow victim to lie on his back, because the vomit could enter the lungs and do additional damage.Put finger or the blunt end of a spoon at the back of victim’s throat or give syrup of ipecac.Collect some of the vomit for the physician if you do not know what the poison is.Do not use salt solutions to induce vomiting.

When not to induce vomiting

If the victim is unconscious or is having convulsions.If the victim has swallowed a corrosive poison. A corrosive poison is a strong acid or alkali. It will burn the throat and mouth as severely coming up as it did going down. It may get into the lungs and burn there also.If the victim has swallowed an emulsifiable concentrate or oil solution. Emulsifiable concentrates and oil solutions may cause severe damage to the lungs if inhaled during vomiting.

A.9 PROPER PESTICIDE CONTAINER DISPOSAL Once pesticides have been used, the empty containers need to be properly disposed of. Training must address proper disposal. This table gives a summary of the best practices for doing so.


TABLE 6. PROPER METHODS TO DISPOSE OF PESTICIDES AND THEIR EMPTY CONTAINERSCONTAINER TYPE DISPOSAL STATEMENTSMetal Containers (non-aerosol) Triple rinse. Then offer for recycling or

reconditioning, or puncture and bury.Paper and Plastic Bags Completely empty bag into application

equipment. Then bury empty bag.Glass Containers Triple rinse. Then bury.Plastic Containers Triple rinse. Then offer for recycling or

reconditioning, or puncture and bury.

A.10 PROPER DISPOSAL OF OBSOLETE AND UNUSED PESTICIDESMany developing countries rely informal disposal methods of pesticides which could lead to environmental degradation and negative impacts to human health. According to the FAO, potential methods for disposal of obsolete pesticides include:16

● high-temperature incineration;● chemical treatment; and,● engineered landfill (for immobilized materials, incinerator ash and slag).

Potential solutions are most likely limited to:

● Incineration in a properly operated and licensed cement kilns; and,● Packaging and shipping to licensed and properly operated pesticide disposal

facilities (falling into the categories above) in a country outside of the Sahel.

A.11 MONITORING AND DATA RECORD KEEPINGMany small-scale farmers and other beneficiaries, other than those doing export, do not keep records of information on crops grown, production, or activities, materials storage practices, pest attack, pesticides used, whether the pesticides worked well or not, pest resistance development and pre-harvest intervals to reduce pesticide residues. Projects must conduct training programs on monitoring and data record-keeping techniques for pest control and pesticide needs and/or effectiveness.

16 FAO, 1996, Guidelines: Disposal of bulk quantities of obsolete pesticides in developing countries. The Food and Agriculture Organization of the United Nations (FAO), the United Nations Environment Programme, (UNEP) and the World Health Organization (WHO). Accessed at: http://www.fao.org/fileadmin/user_upload/obsolete_pesticides/docs/w1604e.pdf


ANNEX B. INSAH REGISTRATION (2018)

TABLE 7. LIST OF SAHEL PESTICIDES

Active Ingredients Trade NameUse Restrictions

2,4-D Baccara2,4-D Binbefla plus 720 SL2,4-D Herbafor 720 SL2,4-D Herbexbar 720 SL2,4-D Malo Binfaga2,4-D Sahel 2D2,4-D Soundiata 720 SK2,4-D Topextra 720 SL2,4-D Rivormone 720 SL2,4-D amine salt Calliherbe 720 SL2,4-D salt Dekade 720 SL2,4-D salt Dokat2,4-D salt Herbalm 720 SL2,4-D Salt dimethylamine Herbextra 720 SL2,4-D Salt dimethylamine Sun 2,4-D Amine 720 SLAbamectin abalone 18 ECAbamectin Bomec 18 ECAbamectin EmabaAbamectin Tetrakill 20 ECAcetamiprid Access 25 ECAcetamiprid aceta super 56 ECAcetamiprid AcuronAcetamiprid AlfacetaAcetamiprid Appach 152 ECAcetamiprid Battus GoldAcetamiprid BenjiAcetamiprid Califan ExtraAcetamiprid Capt 88 ECAcetamiprid Cobra 120 ECAcetamiprid Conquest C 176 ECAcetamiprid Conquest C 88 ECAcetamiprid CrotaleAcetamiprid DanayaAcetamiprid Diacotox 88 ECAcetamiprid EMA STAR 112 ECAcetamiprid EMA SUPER 56 DC


Acetamiprid Emapride 56 ECAcetamiprid Emir 88 ECAcetamiprid Emir Fort 104 ECAcetamiprid K-OptimalAcetamiprid Lamanet 46 ECAcetamiprid Lampride 46 ECAcetamiprid Optimal superAcetamiprid Pacha 25 ECAcetamiprid Pedia 62 ECAcetamiprid Protector Plus 56 ECAcetamiprid Razia 208 ECAcetamiprid Sauveur 62 ECAcetamiprid Lambdaquest 62 ECAcetamiprid TanganaAcetamiprid Thalis 56 ECAcetamiprid Thalis FTE 112 ECAcetamiprid Titan 25 ECAcetamiprid Viper 46 ECAclonifen Lagon 575 SCAclonifen Merlin Combi 575 SCAllethrin Kaltox Paalga Public healthAlpha cypermethrin AlfacetaAlpha cypermethrin M3 Fruit fly bait stationAlpha cypermethrin Nomax 150 SCAlpha cypermethrin Imunit 150 SCAluminum phosphide AladinAmetryne Krismat 075 WGAmicorbazone Dinamic Plus

Aspargillus flavus Aflasafe BF01

Aspargillus flavus Aflasafe SN01Azoxystrobin AzoxAzoxystrobin Ortiva topBensulfuron Methyl Herbiriz 10 WPBensulfuron Methyl Rimax 60% DFBensulfuron Methyl SamoryBensulfuron Methyl Thera 10 WPBeta cyflurthin Thunder 145 O-TEQBeta cyflurthin Solomon 145 O-TEQBifenthrin Appach 152 ECBifenthrin Battus Gold


Bifenthrin Callifan ExtraBispyribac sodium Rubis 200 SCBispyribac sodium WassaBromadialone Maki blockBt Batik WGBt Kurstaki Bio K 16Butachlor CitadelCamphor (oil of) Confo LiquidCamphor (oil of) Confo PommadeCartap hydrochloride Kart 500 SPChlofluazuron Corm 240 WGChlorantraniliprole Coragen 20 SCChlorimuron ethyl Imposter 750 WPChlorimuron ethyl Rebel 500 WGChlorothalonil Jumper 75 WG

Chlorpyrifos Askia 50 WSHousehold use

Chlorpyrifos ethyl Calthio C 50 WSChlorpyrifos ethyl Bella FTE 424 ECChlorpyrifos ethyl Combafos 48 ECChlorpyrifos ethyl Delchlor 424 ECChlorpyrifos ethyl Dursban 240 ULVChlorpyrifos ethyl Dursban 4 ECChlorpyrifos ethyl Dursban 450 ULVChlorpyrifos ethyl Dursban 5 DPChlorpyrifos ethyl Dursban 5 GChlorpyrifos ethyl Kaltox Paalga Public healthChlorpyrifos ethyl Pyriban 240 ULVChlorpyrifos ethyl Pyriban 480 ECChlorpyrifos ethyl Pyriban 480 ULVChlorpyrifos ethyl Pyrical 240 ULChlorpyrifos ethyl Pyrica 480 ECChlorpyrifos ethyl Pyrical 480 ULChlorpyrifos ethyl Pyrical 5 DPChlorpyrifos ethyl Pyrical 5 GChlorpyrifos ethyl Pyrifose 480 ECChlorpyrifos ethyl Pyrinexquick 212 ECChlorpyrifos ethyl Pyrinexquick 424 ECChlorpyrifos ethyl Saloum 500 DSChlorpyrifos ethyl Sultan 240 ULChlorpyrifos ethyl Sultan 480 ULChlorpyrifos ethyl Sunpyrifos 48%


Chlorpyrifos methyl Reldan 40 ECChlorthianidin Sumishield 50 WGCitronnelle (oil of) Confo LiquidClethodim Select 120 ECClomazone SniperClothianidin Fludora FusionCopper Hydroxide IdefixCopper Sulfate (II) Golden Blue 985 SGCyantraniliprole Benevia 100 ODCycloxydim Focus Ultra 100 ECCyfluthrin BaygonCyhalofop-butyl Garil PowerCypermethrin Attakan C 344 SECypermethrin Capt 88 ECCypermethrin Conquest C 88 ECCypermethrin Conquest C 176 ECCypermethrin Cypercal 50 ECCypermethrin Cypercal P 230 ECCypermethrin Cypercal P 690 ECCypermethrin Cypercal P 720 ECCypermethrin Cyperpro 720 ECCypermethrin Cyperpronet 690 ECCypermethrin Cypra 100 ECCypermethrin Diacotox 88 ECCypermethrin Emir 88 ECCypermethrin Emir Fort 104 ECCypermethrin Hitcel 440 ECCypermethrin Razia 208 ECCypermethrin Tangana

Cyprosulfamide Merlin Flexx 480 SCHerbicide safener

D-Allethrine Confu KingD-Allethrine Rambo Mosquito Coil Public healthDeltamethrin Aceta super 56 ECDeltamethrin Bella FTE 424 ECDeltamethrin Decis 25 ECDeltamethrin Decis Forte 100 ECDeltamethrin Delchlor 424 ECDeltamethrin Deltacal 12.5 ECDeltamethrin Deltacis 6.25 ULVDeltamethrin Fludora FusionDeltamethrin Gashinan 25 EC


Deltamethrin K-Othrine 250 WGDeltamethrin Legumax 12 SCDeltamethrin LifenetDeltamethrin Permanet 2.0Deltamethrin Permanet 3.0Deltamethrin Protect DP StorageDeltamethrin Pyrinexquick 212 ECDeltamethrin Pyrinexquick 424 ECDeltamethrin TamegaDeltamethrin Tequi Super Public health

Deltamethrin Zero Fly storage bagGrain storage

Dicamba Herbimais 240 OFDifenoconazole Apron Star 42 WSDifenoconazole Ortiva topDiflubenzuron Beluga 480 SCDiflubenzuron Dimilin OF 6Diflufenican Liberator 500 SCDifulbenzuron Dimilin GR 2Dimethenamid IntegrityDimethoate Dimetho 40 ECDimethoate Methoate 40 ECDiuron Action 80 DFDiuron Diablo 800 WGDiuron Diularm 80 WGDiuron Duranic 80 WGDiuron PowerDiuron Tempra 80 WGDiuron Thianaba

D-phenothrinInsecticide Double Action ORO

Emamectin Benzoate Almectine 20 ECEmamectin Benzoate Caiman B19Emamectin Benzoate Corm 240 WGEmamectin Benzoate EMA 19.2 ECEmamectin Benzoate EMA STAR 112 ECEmamectin Benzoate EMA SUPER 56 DCEmamectin Benzoate EmabaEmamectin Benzoate Emacot 019 ECEmamectin Benzoate Emacot 050 WGEmamectin Benzoate Emamecshi 19 ECEmamectin Benzoate Emapride 56 ECEmamectin Benzoate Emapyr


Emamectin Benzoate EmaronEmamectin Benzoate Imamex 19 ECEmamectin Benzoate KahiraEmamectin Benzoate Parimec 19 ECEmamectin Benzoate Thalis 56 ECEmamectin Benzoate Thalis FTE 112 ECEmamectin Benzoate Tropic Agro 19 ECEpoxyconazole OperaEsbiothrine Killing Mat Public healthEsbiothrine Rhake Public healthEsbiothrine Sweet Dream Public healthEsbiothrine Top one Public healthEsbiothrine Tequi Super Public healthEthoprophos SavanemEthoprophos Savanem 10 GEthoxysulfuron Council Activ 30 WGFenitrothion Fenical 400 ULFenitrothion LocustopFenitrothion Sumithion L-20Fenitrothion Sumithion L-50Fluazifop-p-butyl Fusilade Forte 150 ECFlubendiamide Belt Expert 480 SCFlubendiamide Tihan 175 O-TEQ

FlubendiamideMovento Total 175 O-TEQ

FludioxonilCruiser Extra Coton 362 FS

Flufenacet Liberator 500 SCFluometuron Callifor 500 SCFluometuron Callifor GFluometuron Cotochem 500 SCFluometuron Fluoralm P 500 SCFluopyram Velum Prime 400 SCFluroxypyr-meptyl Garil PowerGlyphosate Bere Rougi YereyereGlyphosate Binfla 360 SL

Glyphosate Binfla 720 WGHousehold use

Glyphosate Binfaga MassaHousehold use

Glyphosate Bintana 480 SLHousehold use

Glyphosate Callifor G


Glyphosate Diga FagalanGlyphosate Finish 360 SLGlyphosate Douma WoruGlyphosate Fouralan 480 SLGlyphosate Glycel 410 SLGlyphosate Glycel 710 SGGlyphosate Glypha Plus 360 SLGlyphosate Glyphader 360 SL Glyphosate LadabaGlyphosate Glyphader 75 SGGlyphosate Glyphalm 360 SLGlyphosate GlypheGlyphosate Glyphoba Super 450 SLGlyphosate Glyphobar 480 SLGlyphosate Ravage 480 SLGlyphosate GlyphochemGlyphosate Glyphodaf 360 SLGlyphosate Glyphogan 480 SLGlyphosate Glypholob 360 SLGlyphosate Glyphonet 360 SLGlyphosate Glyphotrop 480 SLGlyphosate Glyphotrop 680 WSGGlyphosate Glystar 360 SLGlyphosate HerbasateGlyphosate Herbo Total 360 SLGlyphosate Kalach 360 SLGlyphosate Heros 360 SLGlyphosate Kalach Extra 70 SDGlyphosate Killer 480 SLGlyphosate Lamachette 360 SLGlyphosate Lamachette 757 WGGlyphosate Mamba 360 SLGlyphosate Nwura wuraGlyphosate Piranha 360 SL Glyphosate Piranha 757 WGGlyphosate Prodas 360 SLGlyphosate Prodas DrysterGlyphosate Prodas PowerGlyphosate Raffal 480 SLGlyphosate Rival 360 SLGlyphosate Sunphosate G-WSGGlyphosate Toguna For 360 SL


Glyphosate Toguna For 450 SLGlyphosate Toguna For 680 WSGGlyphosate Touchdown Forte 500 SLGlyphosate Zoomer 390 SCGlyphosate Sunphosate 360 SLGlyphosate acid Roundup 360 XLGlyphosate sals of potassium Roundup 680 BiosecGlyphostate Tianaphosate 480 SLHaloxyfop-r-methyl Akafissa 108 ECHaloxyfop-r-methyl DangeleHaloxyfop-r-methyl Douna 180 ECHaloxyfop-r-methyl Gallant SuperHaloxyfop-r-methyl VerdictHaloxyfop-r-methyl Garmifort 104 ECHaloxyfop-r-methyl Grami 108 ECHaloxyfop-r-methyl Halodaf 108 ECHaloxyfop-r-methyl Halonet 104 ECHaloxyfop-r-methyl Hamechem 108 ECHaloxyfop-r-methyl Herbo Select 108 ECHaloxyfop-r-methyl IkokadigneHaloxyfop-r-methyl Koricol 108 ECHaloxyfop-r-methyl Lahidou 104 ECHaloxyfop-r-methyl Malik 108 ECHaloxyfop-r-methyl Vayan 108 ECHaloxyfop-r-methyl Dandy 108 ECHearSPNV Helitec SCImidacloprid Atakan C 344 SEImidacloprid Calthio Mix 485 WSImidacloprid Cotomence 450 WSImidacloprid Fox 45 WSImidacloprid Imidalm T 450 WSImidacloprid Insector TImidacloprid KachiImidacloprid Momtaz FloImidacloprid Monceren GT 390 FSImidacloprid Movento PlusImidacloprid Semnet 450 WSImidacloprid Thunder 145 O-TEQImidacloprid Solomon 145 O-TEQImiprothrin BaygonImiprothrin RaidImiprothrin Raid


Indoxacarb Ag-vantage 150 EC

Indoxacarb Asset 150 EC

Not registered as pesticide by USEPA

Indoxacarb Avaunt 150 EC

Indoxacarb Steward 150 EC

Not registered by USEPA

Indoxacarb CrotaleIndoxacarb Dalica 150 ECIndoxacarb Indo Pro 150 ECIndoxacarb Indo Max 150 SCIndoxacarb Indox 150 ECIndoxacarb IndoxanIndoxacarb Optimal superIndoxacarb Viper 46 ECIsoxadifen ethyl Laudis 630 SCIsoxaflutol Lagon 575 SCIsoxaflutol Merlin Combi 575 SCIsoxaflutol Merlin Flexx 480 SC

Kaolin (aluminum silicate)Surround WP Crop Propectant

Lambda cyhalothrin Access 25 ECLambda cyhalothrin Accero 84 ECLambda cyhalothrin DanayaLambda cyhalothrin Cotalm P 212 ECLambda cyhalothrin Ephoria 045 ZCLambda cyhalothrin Engeo 247 SCLambda cyhalothrin Alika 247 SCLambda cyhalothrin Icon 10 CSLambda cyhalothrin K-OptimalLambda cyhalothrin KachiLambda cyhalothrin Lamanet 46 ECLambda cyhalothrin Lambdacal P 212 ECLambda cyhalothrin Lambdacal P 636 ECLambda cyhalothrin Lambdacal P 648 ECLambda cyhalothrin Lambdalm 50 ECLambda cyhalothrin Lambdapro 636 ECLambda cyhalothrin Lambda Super 2.5 ECLambda cyhalothrin Lampride 46 ECLambda cyhalothrin Pacha 25 EC


Lambda cyhalothrin Pedia 62 ECLambda cyhalothrin Procytrine 215 ECLambda cyhalothrin Protector Plus 56 ECLambda cyhalothrin Sauveur 62 ECLambda cyhalothrin Lambdaquest 62 ECLambda cyhalothrin Sanhalotrin 2.5 % ECLambda cyhalothrin Thialam 247 ECLambda cyhalothrin Zalang 20 ULLufenuron AcuronLufenuron EmaronMalathion Djigikan 800 ECMalathion Fyfanon 925 ULMalathion Invader-B-LockMancozeb Coga 80 WPMancozeb Manga PlusMancozeb Dithane M 45Mancozeb Ivory 80 WPMancozeb Manco 80 WPMatrine BiopiqMCPA Destroy 400 SLMCPA Tornado 400 SLMefenoxam (Metalaxyl M) Apron Star 42 WS

Mefenoxam (Metalaxyl M)Cruiser Extra Coton 362 FS

Meperfluthrin BoxerMeperfluthrin Hassana

Mepiquat Chloride Pix 5% SLPlant growth regulator

Mesotrione Lumax 537.5 SEMesotrione Prima Gold 537.5 SEMetalaxyl Calthio Mix 485 WSMethomyl SavahalerMetolachlor Corignena 500 ECMetolachlor Cotonet 500 ECMetolachlor Guerrier 500 ECMetolachlor MeprodafMetolachlor Terbulor 500 ECMetolachlor Tericot 500 ECMetribuzin Imposter 750 WPMetribuzin PIC 480 SCMetribuzin Torpedo 480 SCMSMA Sabre 720 SL


Myclobutanil Systhane 240 EC

Nicosulfuron Akizon 40 SC

Use as film on water for mosquito control

Nicosulfuron Akoumais 40 SCNicosulfuron Herbimais 240 OFNicosulfuron Kababin 40 SCNicosulfuron Maia 75 WGNicosulfuron Maia superNicosulfuron Nico Top 40 ODNicosulfuron Nico Chem 60 ODNicosulfuron Nico Daf 40 SCNicosulfuron Nicokaba 40 SCNicosulfuron Nicolaban 40 SCNicosulfuron Nicomais 40 SCNicosulfuron Niconet 40 SCNicosulfuron Nicosuper 40 SCNicosulfuron Segaibaana 40 SCNicosulfuron Sofa 40 SCOxadiargyl Topstar 400 SCOxadiargyl Raft 400 SCOxadiazon Callistar 250 ECOxadiazon Oxanet 250 ECOxadiazon OxoOxadiazon Ristar 250 ECOxamyl Foxamyl 10 GOxamyl OxamaxOxamyl Vytal 310 SLOxyfluorfen Goal 2EOxyfluorfen Zoomer 390 SCPencycuron Monceren GT 390 FSPendimethalin Activus 500 ECPendimethalin AlligatorPendimethalin Bada 400 ECPendimethalin Diva 400 ECPendimethalin Farmethalin 500 ECPendimethalin Fist SuperPendimethalin Pencal 500 ECPendimethalin Paragon 500 ECPendimethalin Pendaf 500 ECPendimethalin Pendinet 500 EC


Pendimethalin Pendistar 500 ECPendimethalin Pendisuper 500 ECPendimethalin Penditrop 500 ECPendimethalin SniperPendimethalin Stomp CSPendimethalin Alligator unikPenoxsulam CitadelPenoxsulam Granite 240 ECPenoxsulam Rainbow 25 ODPermetrhin Antouka 19 DPPermetrhin Caiman Rouge PPermetrhin Forte Fog P Fumer

PermetrhinInsecticide Double Action ORO

Permetrhin Kaltox Paalga Public healthPermetrhin Olyset ClassicPermetrhin Olyset NetPermetrhin Olyset PlusPermetrhin Rambo NIS Public health

Permetrhin Rambo Power

Domestic uses for cockroaches

Permetrhin Wavetide Public healthPirimiphos methyl Actellic 300 CSPirimiphos methyl Actellic Gold DustPirimiphos methyl Antouka 19 DPPirimiphos methyl Protect DP StoragePolydimethylsiloxane (PDMS) Aquatain AMFPretilachlor Solito 320 ECProfenofos Arsenal 50 ECProfenofos Calfos 500 ECProfenofos Calife 500 ECProfenofos Cotalm P 212 ECProfenofos Curacron 500 ECProfenofos Cypercal P 230 ECProfenofos Cypercal P 690 ECProfenofos Cypercal P 720 ECProfenofos Cyperpro 720 ECProfenofos Cyperpronet 690 ECProfenofos Dalifos 500 ECProfenofos Fanga 500 ECProfenofos Fariman


Profenofos Hitcel 440 ECProfenofos Kophos 500 ECProfenofos Kotonphos 500 ECProfenofos Lambdacal P 212 ECProfenofos Lambdacal P 636 ECProfenofos Lambdacal P 648 ECProfenofos Lambdapro 636 ECProfenofos Procytrine 215 ECProfenofos Profenet 500 ECProfenofos Tango Plus 500 ECProfenofos Tenor 500 ECPrometryn Callifor 500 SCPrometryn Callifor GPrometryn Codal Gold 412.5 DCPrometryn Cotochem 500 SCPrometryn Cotoforce 80 WGPrometryn Fluoralm P 500 SCPrometryn MeprodafPrometryn Tericot 500 ECPropanil BaccaraPropanil CalrizPropanil Baraka 432 ECPropanil EurekaPropanil Propa 360Propanil Garil 432 ECPropanil Herbisahel 360 ECPropaquizafop Agil 100 ECPropineb Atracol 70 WPPropisochlor Dinamic PlusPyraclostrobin OperaPyrazosulfuron ethyl Amazone 100 WPPyribenzoxim Solito 320 ECPyriproxyfen EmapyrPyriproxyfen Piripro 100 ECRimsulfuron Ricomais 25 WGRimsulfuron SaphirSaflufenacil IntegrityS-metolachlor Codal Gold 412.5 DCS-metolachlor Dual Gold 960 ECS-metolachlor Lumax 537.5 SES-metolachlor Prima Gold 537.5 SES-metolachlor Metonyx


Spinetoram Cobra 120 ECSpinetoram Radiant 120 SCSpinetoram Exalt 120 SCSpinosad Laser 480 SCSpinosad Spintor poudreSpinosad Success Appat 0.24 CBSpiromesifen Oberon 240 SCSpirotetramat Movento PlusSpirotetramat Tihan 175 O-TEQ

SpirotetramatMovento Total 175 O-TEQ

Sulfoxaflor accero 84 ECTebuconazole Nativo 300 SCTebufenpyrad MasaiTeflubenzuron Nomax 150 SCTeflubenzuron Imunit 150 SCTeflubenzuron Nomolt 150 SCTembotrione Laudis 630 SCTerbuthylazine Lumax 537.5 SETerbuthylazine Prima Gold 537.5 SETerbutryn Corignena 500 ECTerbutryn Cotonet 500 ECTerbutryn Guerrier 500 ECTerbutryn Terbulor 500 EC

TetramethrinInsecticide Double Action ORO

Tetramethrin Kaltox Paalga Public healthThiacloprid Belt Expert 480 SCThiamethoxam Actellic Gold DustThiamethoxam Apron Star 42 WS

ThiamethoxamCruiser Extra Coton 362 FS

Thiamethoxam Ephoria 045 ZCThiamethoxam Engeo 247 SCThiamethoxam Alika 247 SCThiamethoxam Thialam 247 ECThiram Askia 50 WSThiram Caiman Rouge PThiram Calthio C 50 WSThiram Cotomence 450 WSThiram Calthio Mix 485 WSThiram Fox 45 WSThiram Imidalm T 450 WS


Thiram Insector TThiram Momtaz FloThiram Monceren GT 390 FSThiram Saloum 500 DSThiram Semnet 450 WSTiclopyr CalrizTiclopyr Garil 432 ECTiclopyr Vulture 480 EC

TransfluthrinRambo Inseciticide Paper Public health

Transfluthrin Rambo NIS Public healthTriafamone Council Activ 30 WGTriclopyr Baraka 432 ECTrifloxystrobin Nativo 300 SCTrifloxysulfuron Krismat 075 WGTrifloxysulfuron sodium Cotoforce 80 WG


ANNEX C. PERSUAP REFERENCESWebsites: Website references used to develop the Programmatic PERSUAP International Treaties and Conventions:POPs website: http://www.pops.intPIC 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.htmlIPM and PMP websites:http://ipm.ucanr.edu/http://edis.ifas.ufl.edu/topic_pest_managementPesticide 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.pdfPesticide Container Disposal Options:https://www.epa.gov/pesticide-worker-safety/pesticide-container


introduction - ecd.usaid.gov · web viewit is important to note that all emerging market countries...

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