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ADVANCE II PERSUAP Amendment 2: Request for Additional Insecticides for Fall Armyworm (FAW) Management in USAID/Ghana Feed the Future Programs Contract number AID-641-A-14-0001 Agricultural Development and Value Chain Enhancement Program (ADVANCE II) Additional to the original ADVANCE II PERSUAP Amendment #1 submitted to USAID Ghana in September 2016. Submitted to AFR BEO Feb. 2017 ACDI/VOCA-Ghana A&C Square, Jungle Road, East Legon, Accra P. O. Box KD138, Kanda, Accra

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Page 1: Revision of ADVANCE PERSUAP and Pesticide · Web viewContract number AID-641-A-14-0001 Agricultural Development and Value Chain Enhancement Program (ADVANCE II) Additional to the original

ADVANCE II PERSUAP Amendment 2:

Request for Additional Insecticidesfor Fall Armyworm (FAW) Management

inUSAID/Ghana Feed the Future Programs

Contract number AID-641-A-14-0001

Agricultural Development and Value Chain Enhancement Program

(ADVANCE II)

Additional to the original ADVANCE II PERSUAP Amendment #1 submitted to USAID Ghana in September 2016. Submitted to AFR BEO Feb. 2017

ACDI/VOCA-GhanaA&C Square, Jungle Road, East Legon, Accra

P. O. Box KD138, Kanda, Accra Tel: +233 302 520231/2

February 2017

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PROGRAM/ACTIVITY DATA:

Program/Activity Number: Aid-641-A-14-0001

Country/Region: Ghana/West Africa

Program/Activity Title: Agricultural Development and Value Chain Enhancement Feed the Future Activity (ADVANCE II). PERSUAP Amendment 2: Fall Armyworm

Funding: Ghana Feed the Future Program

Funding Begin: February 5, 2014 Funding End: Sept 30, 2018

LOP Amount: $37,556,780

PERSUAP Prepared by: Victor M. Mombu, Environmental Specialist (ADVANCE II) with additions by Walter Knausenberger (Ph.D. Entomologist), AFR/SD Sr. Env. Policy Advisor

Current Date: February 2017

PERSUAP Amendment (Y/N): Yes

ENVIRONMENTAL ACTION RECOMMENDED : (Place X where applicable) Categorical Exclusion: N/A Negative Determination: __X__Positive Determination: _N/A __ Deferral: _N/A__

ADDITIONAL ELEMENTS: (Place X where applicable)CONDITIONS: X_ PVO/NGO: X _ EMMP (SUAP): X _ ERR:

RELATED DOCUMENTATION:

1. Bilateral USAID Ghana Feed the Futurea. Ghana ADVANCE II PERSUAP, 2016. Amendment #1. Approved 5/11/2017 (ECD Link). Also

refer to BFS Programmatic PERSUAP for Fall Armyworm below (ECD Link).b. Ghana_ADVANCE_PERSUAP_071812  (DOCX) (PDF), approved 07/18/2012.c. Ghana Feed the Future Program, Agriculture Technology Transfer (ATT) PERSUAP (IFDC),

approved 04/17/2014. Details for file #Ghana_FTF_EE_2011_2015 (DOCX) (PDF). d. Ghana Commercial Agriculture Project (GCAP): Public Private Partnership, USAID & World Bank

co-financing. Pest Management Plan.e. USAID Ghana_FTF_EG_IEE_120611. (DOCX)

West Africa Regional Programs

a. West Africa Regional Programmatic PERSUAP (P-PERSUAP) Covering Nine Target Countries with USAID West Africa Programs: Sahel/Savannah zone (covered by CILSS/INSAH): Burkina

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Faso, Chad, Mali, Niger and Sénégal; Humid/Tropical zone: Benin, Côte d’Ivoire, Ghana and Liberia.  Approved 3/16/2015: (PDF)

b. West Africa PERSUAP for CORAF/WECARD - Feed the Future (FTF) Activities by National Agricultural Research Systems in eleven West African Countries. Details for file #West_Africa_CORAF_WECARD PERSUAP_2013_2017_BEOcleared (DOCX)(PDF), approved 04/17/2014. Operating Unit: West Africa. Countries: Benin, Burkina Faso, Cote d'Ivoire, Ghana, Liberia, Mali, Niger, Nigeria, Senegal, Sierra Leone, Togo.

Bureau for Food Security Central Programs in Ghana

a. Programmatic PERSUAP for Fall Armyworm Management in Africa. Version 1. May 2017. Approved 5/16/2017 (AFR, BFS & DCHA BEOs). Revised 5/22/2017. (ECD Link) (url: http://gemini.info.usaid.gov/document.php?doc_id=50065)

b. AGRA Scaling Seeds and Technologies Partnership in Africa (SSTP): PERSUAP, approved 01/29/2105. Details for file #BFS_AGRA_SSTP_PERSUAP (DOCX) (PDF). Approved 01/29/2015 Bureau Food Security. Countries / Operating Units:  Ethiopia, Tanzania, Ghana, Senegal, Malawi, Mozambique.

Purpose of This Document

This amendment #2 of the Ghana Feed the Future PERSUAP is intended to assist USAID Ghana programs support Fall Armyworm (FAW) pest management interventions as necessary, and as part of a comprehensive FAW Action Plan (Annex 3 & 4). It is to be seen as supplemental to the Programmatic PERSUAP for Fall Armyworm Management in Africa (May 2017), cited above. The FAW P-PERSUAP addresses FAW basic biology, distribution, and a discussion of possible control methods with a focus on Integrated Pest Management (IPM).

The present Ghana FtF PERSUAP Amendment (herein) approves all pesticides identified in the Ghana MOFA FAW Pest Management Decision Guide (PMDG) (Annex 1), and the FAW P-PERSUAP. Review the Annexes, esp. Annex 1. Ghana Fall Armyworm Pest Management Decision Guide (Dec. 2016), produced

by Ghana MOFA PPRSD & CABI Plantwise (Dec. 2016/March 2017), and Annex 3. Ghana Comprehensive Action Plan for Management of the Fall Armyworm (May

8, 2017)(source: CABI Plantwise)

Then develop a collaborative Safer Use Action Plan to support FAW control operations, appropriate to the partners and localities where the Action Plan will be implemented.

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A.SUMMARY

This document is a request for approval of Spinosad for the control of the newly invasive Fall Armyworms (Spodoptera frugiperda) under the USAID Ghana Feed the Future ADVANCE II project. It also includes a revised Safer Use Actions Plan for the ADVANCE PERSUAP. In January 2015, the ADVANCE project submitted for approval, a PERSUAP for the second phase of the ADVANCE project (ADVANCE II). A revised version of the PERSUAP was submitted requesting the approval of 36 new products made of 19 active ingredients (submitted to AFR BEO Sept. 26, 2016). Table 1 represents a side-by-side listing of the insecticides approved for control of insect pests in field crops in USAID supported programs in Ghana.

TABLE 1. SUMMARY LIST OF APPROVED ACTIVE INSECTICIDES IN THE ADVANCE II PERSUAP AMENDMENT (2016)1 & FTF AGRICULTURAL TECHNOLOGY TRANSFER (ATT, 2014) PERSUAP2

ADVANCE II FtF Ag. Tech. Transfer

No.

Active ingredient/Chemical

Commercial Product Names in Ghana

Active ingredient/Chemical

Commercial Product Names in Ghana

Insecticides Insecticides

1. Abamectin Bomec EC Abamectin Mektin 1.8EC

2. Acetamiprid + Cypermethrin

Chemiprid 88EC acetamiprid + cypermethrin

Clomaprid 88 (actamiprid)16 + cypermethrin 72)

3. acetamiprid +lambda-cyhalothrin

K-Optimal acetamiprid + lambda-cyhalothrin

Optimal 170 (acetamiprid 20 + lambda-cyhalothrin 150)

4. acetamiprid + bifenthrin

Aceta Star 46EC

5. Bifenthin 10%EC & 2.5% ULV6. acetamiprid Golan SL acetamiprid (systemic) Golan 20SL7. Cypermethrin Cymethrin

8. cypermethrin + dimethoate

Cymetox Super 280 (cypermethrin 30+ dimethoate 250)Cydim 45EC (cypermethrin 15% + dimethoate 30%)

1 Ghana ADVANCE II PERSUAP (2016), http://gemini.info.usaid.gov/document.php?doc_id=50081 2 Ghana ATT FtF PERSUAP: http://gemini.info.usaid.gov/repository/pdf/39950.pdf

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ADVANCE II FtF Ag. Tech. Transfer

No.

Active ingredient/Chemical

Commercial Product Names in Ghana

Active ingredient/Chemical

Commercial Product Names in Ghana

Cymethoate Super9. Deltamethrin Deltapaz 12.5%10. dimethoate Dimeking EC Dimethoate11. fenvalerate Sanitox 20EC Fenvalerate Sumicidin

12. imidacloprid (systemic) Confidor 200SCAkape

13. imidacloprid Consider Supa, Dimiprid 20SL

imidacloprid + beta-cyfluthrin

Vector 210 + beta-cyfluthrin 90 WP

14. imidacloprid + thiram Insector TDS15. indoxacarb +

acetamipridViper 46EC

16.

lambda-cyhalothrin Sunhalothrin, Lambda Super, Lambdacot,Striker, Lambda Master, Rainlambda

lambda-cyhalothrin: Lambda Super 2.5EC, Kombat 2.5EC, Sunhalothrin 2.5EC, Kilsect 2.5EC, Icon 10CS, Zap 2.5,K-Optimal

17. lambda-cyhalothrin + thiamethoxam

Eforia 45EC

18. Malathion EnviGold Malathion Envigold 70 SL for stored grain pests

19. mineral oil EOS white mineral oil

20. neem seed artisanal extract

natural neem seed extract plus soap and water

21. Thiamethoxam Do no not spray when plants in flower due to pollinator risk

Table 2. Proposed for Addition to List for Fall Armyworm Control in Ghana with this PERSUAP Amendment (March 2017)

Active ingredient/Chemical proposed by ADVANCE II

Commercial Product Names in Ghana

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22. Spinosad [Fermentation product of Saccharopolyspora spinose]

Success, Appat

The purpose of this amendment to the revised ADVANCE II PERSUAP (dated September 2016) is to seek approval to add spinosad to the list of approved pesticides. Spinosad is needed to help control an anticipated infestation of armyworm in Ghana during the upcoming wet season3.

Several documents that detail steps (especially non-chemical measures) that can be taken to identify armyworm and to effectively combat this potential infestation are available. These resources are included in Annex I and include:

Pest Management Decision Guide, Fall Armyworm on Maize4

Proposed Fall Armyworm (FAW) emergency action plan for affected countries (Ghana) How to Identify Fall Armyworm (two versions)5

For any pesticide not addressed in the submitted PERSUAP, a Negative Determination with

Conditions is recommended pursuant to §216.3 (b)(1)(i)(a - l). More specifically, §216.3 (b)(1)(v) requires that “If the project includes assistance for the procurement or use, or both of pesticides but the specific pesticides to be procured or used cannot be identified at the time the IEE is prepared, the procedures outlined in §216.3(b)(i) through (iv) will be followed when the specific pesticides are identified and before procurement or use is authorized”.

All issues related to pesticides, safer use of pesticides, and Integrated Pest Management have been fully and thoroughly discussed in the PERSUAP already submitted. Included in the said document is a full discussion of the 12 factors related to pesticides mandated by §216.3(b)(1)(i)(a - l). Only the new pest and pesticide issues, not already addressed in the original PERSUAP are discussed in this document. Table 3 below shows the progress made so far with implementation of the safer use actions outlined in the submitted PERSUAP.

TABLE 3: PROGRESS WITH IMPLEMENTATION OF SAFER USE ACTIONS

Objective/Issues Interventions required Progress of implementation

A. PESTICIDE RISK AWARENESS

3 Centre for Agriculture and Bioscience International (CABI). 2017. Scientists discover new crop-destroying Armyworm is now “spreading rapidly” in Africa. February 6, 2017. http://www.cabi.org/news-and-media/2017/scientists-discover-new-crop-destroying-armyworm-is-now-spreading-rapidly-in-africa/4 Plantwise. 2016. Pest Management Decision Guide, Fall Armyworm on Maize. Find at: http://www.plantwise.org/FullTextPDF/2017/20177800275.pdf.5 CABI/Plantwise. How to Identify Fall Armyworm. http://www.plantwise.org/KnowledgeBank/SearchResults.aspx?q=Spodoptera%20frugiperda.

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Objective/Issues Interventions required Progress of implementation

A1.Reduce reliance on pesticides.

Local pest control options are limited.

Pesticides are costly and may not be used safely.

Follow GAPs recommendations

Use of IPM Practice crop rotation Select resistant

varieties

In collaboration with private companies the project promoted 2 striga tolerant maize see varieties (Wang-data and Senzalsima).

All GAPs trainings include training on integrated pest management.

A2.Promote use of PPEs

Farmers do not fully appreciate the importance of PPEs

Farmers do not fully appreciate the potential hazards of using pesticides.

Continuous education of farmers on the importance of PPEs

Promote use of less hazardous agrochemicals

The number of farmers using PPEs is on the increase. Between 2015 and 2016 the increases were as follows:- Gloves: 28% to 58%- Overalls: 35% to 55%- Boots: 74% to 85%- Hat: 24% to 62%- Goggles: 17% to 42%- Nose mask: 16% to 51%

A3.Discourage re-use of pesticide containers

Containers are used to store household items including food.

Farmers are unaware of the dangers involved.

A sustained campaign to discourage re-use of containers.

Provide a central point for collecting and disposing containers.

The project has, in collaboration, with the EPA developed a radio jingle to educate farmers against re-using pesticide containers. The jingle which was aired on 8 radio stations in local languages, reached on 3million listeners. These radio jingles will be repeated this year.

Out of 262 communities where demos were located in the 2016 crop season, only one community reported evidence people re-using pesticide containers. In 2015 the number of communities with reported evidence of container re-use was 8.

A4.Discourage women and children from pesticide application

Limited farm labour compelling women to apply pesticides.

Inability of women to pay for SSP services.

Provide special training to women on the effects of pesticides on women and children.

The project has, in collaboration, with the EPA developed a radio jingle to educate women against pesticide applications. The message in the jingle particularly targets pregnant and lactating mothers. The jingle which was aired on 8 radio stations in local languages, reached on 3million listeners. These radio jingles will

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Objective/Issues Interventions required Progress of implementation

be repeated this year.

B. PREVENT ENVIRONMENTAL POLLUTION & DAMAGE TO HUMAN HEALTH

B1.Promote safe disposal of pesticide containers

Empty pesticide containers are either left on farms or re-used for domestic purposes.

Some farmers are not aware of the proper methods of disposal.

Set up container collection centers with NFs where all containers used by out-growers will be collected.

Destroy and bury containers or return to manufacturers for re-use.

As part of our SSP programs trained persons are required to have large plastic bags for retrieving empty pesticide containers for safe disposal. A total of 9,802 containers were safely disposed of in the 2016 crop season by burning the containers in a pit and burying the ashes.

Out of 275 beneficiary farms monitored in the 2016 crop season, 244 (88.7%) of them had no pesticide containers disposed on their farms.

B2.Minimize ground and surface water contamination.

Pesticide use near water bodies.

Pesticide use on wet fields with flowing water.

Pesticide use immediately after rainfall.

Reduce soil disturbance through reduced tillage.

Leave a buffer of at least 5m to rivers and streams when spraying:- Flat land: 5m- Gentle slope: 10m- Slope >30o: 15m

The project has so far promoted minimum tillage practices by introducing farmers to ripping. In the 2016 crop season farmers were exposed to the benefits of ripping through 36 demo plots, 5 cover crop systems, 19 model farms and 43 outgrower farms.

Environmental Review Reports for 33 tractor grant recipients included mitigation actions for farms near rivers and streams to observe the recommended distances during land preparation and pesticide applications.

B3.Follow Spray Drift Management Protocols Impacts to bee

colonies Impacts to surface

water bodies and aquatic

Do not spray in areas of blooming foliage or when bees are actively foraging

Do not apply to any perennial water body

7

John Martin, 02/24/17,
I cannot speak to this. Can the authors add anything?
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Objective/Issues Interventions required Progress of implementation

invertebrates

B4.Minimize potential for using pesticides more than necessary.

Farmers may apply pesticides, especially for storage grain, without actually encountering the threat of a pest invasion leading sometimes to avoidable high cost of agrochemicals and over application of pesticides.

Promote GAPs and IPM to reduce over reliance on pesticides.

Together with GAPs and IPM trainings through field days, the project is also promoting patronage of SSPs who have been trained on proper knapsack calibration to minimize the potential to apply wrong doses of pesticides.

C. ACTIONS TO ENSURE COMPLIANCE

C1.Conduct safe pesticide use training

Farmers and other persons who handle pesticides have inadequate knowledge of pesticide products and labels.

Develop training content targeting specific groups – farmers, women, dealers, partners etc.

All farmers who attend GAPS training are trained on safe pesticide use.

GAPs trainings are supported by radio jingles on safe pesticide use in local language

C2.Promote the services of SSPs

Farmers may do their own spraying because they have no access to trained spray service providers.

Work with NFs and FBOs to include spray services in their extension support to out-growers.

Provide regular training to SSPs on environmental safety procedures.

One hundred and eighty (180) individuals have so far been trained and equipped to provide commercial spray services to farmers. In the 2016 crop season they provided services to 3,724 farmers (38% of them being women)

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Objective/Issues Interventions required Progress of implementation

Farmers who do their own spraying often do not wear PPEs and may apply more chemical than needed.

C3.Avoid the use of highly toxic products

Farmers do not appreciate the short and long term consequences of very toxic products on their health and the environment.

Some farmers simply do not know the toxic levels of the products they use and the need to avoid them.

Train farmers to read and understand the symbols and colours on pesticide labels.

Promote use of non-chemical pest control option

The project continues to use PERSUAP recommended chemicals as a guide for farmers. As part of pesticide use monitoring on demos, pesticide active ingredients used on demos were compared with those used by farmers who hosted demos to determine the extent to which farmers are adopting pesticide use practices on demos. Except for 2 active ingredients, farmers used the same active ingredients on their farms.

List of Annexes: Additional Resources for Combatting Armyworm Infestation Annex 1. Ghana Fall Armyworm Pest Management Decision Guide (Dec. 2016), produced by Ghana

MOFA PPRSD & CABI Plantwise (Dec. 2016/March 2017) Annex 2. African Armyworm Pest Management Decision Guide (March 2016), by Ghana MOFA

PPRSD & CABI Plantwise Annex 3. Ghana Comprehensive Action Plan for Management of the Fall Armyworm (May 8, 2017)

(source: CABI Plantwise) Annex 4. Synoptic Proposed Fall Armyworm (FAW) Emergency Action Plan for Affected Countries

(generic)(source: CABI Plantwise. Feb. 2017). Annex 5: Matrix of Ghana FTF Agricultural Technology & Trade (ATT) Crops with Primary Production

Constraints, PERSUAP-Recommended Pest Prevention GAP/IPM Tactics & PERSUAP-Recommended Curative Tools and Tactics (ATT PERSUAP 2014).

Annex 6. Guidelines for Pest Management Plans (PMPs) for Ghana Crops and Beneficiaries (from USAID Ghana ATT PERSUAP)

Annex 7. Elements of Integrated Pest Management (IPM) Program (USAID Ghana ATT PERSUAP)

Note: Also refer to Programmatic PERSUAP for Fall Armyworm Management in Africa. Version 1. May 2017. Approved 5/16/2017 (AFR, BFS & DCHA BEOs). Revised 5/22/2017. ECD Link:

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http://gemini.info.usaid.gov/document.php?doc_id=50065

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APPROVAL OF THE RECOMMENDED ENVIRONMENTAL ACTION:

CLEARANCE:

USAID/Ghana Mission Director: cleared parent Amendm #1 Date: 8/25/16 Andy Karas

CONCURRENCE:

AFR Bureau Environmental Officer: ___________________________ Date: 5/25/2017 Brian D. Hirsch

Approved:

Disapproved:

Filename: Ghana ADVANCE II PERSUAP Amendment 2 Fall Armyworm_FAW_(May2017)

ADDITIONAL CLEARANCES:

AOR/COR: ________signed original amendment _______ Date: 5 June 16

Pearl Ackah

Mission Environmental Officer: _______________________ Date:

Justice Odoi

AFR/SD/ Regional Environmental Officer: ______n/a_____________ Date: n/a

(Washington, D.C.) Walter Knausenberger

EG Office Director: signed original amendment Date: 7 July 2016

  Kevin Sharp

CC:

ADVANCE II CoP, Technical Officers

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B.PESTICIDE EVALUATION REPORT FOR SPINOSAD

1. USEPA and Ghana EPA registration status of proposed pesticide

Spinosad is registered in Ghana under the trade name Success Appat and distributed by Chemico Ghana Ltd based on the current Ghana EPA register of pesticides (December 2015). The USEPA registration status of Spinosad was also verified from the USEPA pesticides database for projects in Africa6. Table 1 provides a summary of the registration status of spinosad.

TABLE 1: REGISTRATION STATUS OF PROPOSED PESTICIDE

Active Ingredient

CommercialProduct Name

in Ghana

USEPA Registration

Status

USEPA Toxicity

Class

Gh EPARegistration

Status

Gh EPAToxicity

Class

Target Crops

Spinosad (0.24g/l)

Success Appat

GUP III GUP U Maize, Rice, Soya

2. Basis for selecting the recommended pesticide

Spinosad is a biologically rational pesticide with low toxicity to the environment and users. It will be used in alternation with other products such as lambda-cyhalothrin to reduce the potential for insect resistance in fall armyworm control.

3. Acute and long term toxicological hazards associated with the proposed use, and measures available to minimize hazards

THE ACUTE AND CHRONIC HAZARDS ASSOCIATED WITH THE USE OF SPINOSAD ARE SUMMARIZED IN Table 2 BASED ON THE AFRICA PRODUCT LIST DATABASE MENTIONED ABOVE (THIS DATABASE IN NOT DEFINITIVE, AND HAS NOT BEEN UPDATED SINCE 2009).

TABLE 2: USER AND ENVIRONMENTAL HAZARDS ASSOCIATED WITH THE PROPOSED PESTICIDE

6 http://www.encapafrica.org/pesticide_database.htm

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Active ingredient/Chemical

CommercialProduct Names in Ghana

Acute/Chronic Toxicity

Eco-toxicity Groundwater Contamination Potential

Spinosad (0.24g/l)

Success Appat May cause slight irritation to eyes

Slightly toxic to earthworms,

Moderately toxic to fish,

Highly toxic to bees.

Very low potential for ground water contamination

4. Extent to which the proposed pesticide use will be part of an IPM Program

Spinosad will be used to control fall armyworms in their early stages of development. ADVANCE will use pheromone traps to detect when armyworm moths begin egg laying. This will serve as an early worming system to farmers and a monitoring system for armyworms through the year. At the early stages of egg laying farmers will be advised to apply Spinosad. Farmers will be advised to alternate the use of spinosad with other products such as lambda-cyhalothrin to prevent insect resistance. See

Agricultural Production Officers will include education on distinguishing the Fall armyworm (newly introduced invasive species, Spodoptera frugiperda) from the historically present African armyworm (Spodoptera exempta) preventive measures in GAPs training including the following recommended actions by CABI Plantwise for preventing African and Fall armyworm outbreaks:

For preventing Fall armyworm7:

Avoid late planting. Plant early to avoid peak immigration of adults Remove and destroy all crop residues after harvest Deep plough the soil to bury the larvae and the pupae Regularly weed the field and surroundings Ensure optimum fertilization is used for your maize crop: Recommended fertilizer rates (4

bags or 200kg of NPK 15:15:15 per ha) to increase the growth vigour.

For African armyworms, the following prevention measures are recommended8:

Remove weeds such as Amaranthus and wild grass species that harbour armyworm larvae

Avoid planting close to overgrazed grasslands which provide food and refuge for caterpillars

Grow low value grain crops such as finger millet as trap crops to attract armyworms

7 Beseh, P. 2017. (Ghana MOFA, PPRSD) Fall Armyworm Pest Management Decision Guide: Green and Yellow List, CABI, 2017, English language. Find at: http://www.plantwise.org/FullTextPDF/2017/20177800275.pdf 8 Chipambala, F. K.; Badii, B. K.; Nuamah, H.; Braimah, H. African Armyworm Pest Management Decision Guide: Green and Yellow List, CABI, 2016, English language. Available at http://www.plantwise.org/FullTextPDF/2017/20177800134.pdf

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John Martin, 02/24/17,
Is lambda-cyhalothrin approved in the previous PERSUAP? All uses are RUP, so I question the statement “Farmers will be advised…” since if allowed, lambda-cyhalothrin must only be used by trained and certified applicators.
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Remove alternate host plants such as millet, sorghum, rice, leafy vegetables etc.

5. Proposed Methods of Application, Availability of Appropriate Application and Safety Equipment

Pesticide applications are carried out with lever operated knapsack sprayers. The number of farmers who are using protective clothing is increasing. Recommended protective clothing includes: safety glasses, chemical-resistant gloves, long sleeved shirts, long pants, shoes, socks, and coveralls. The program also envisages that with the establishment of spray service providers in all implementation Regions, farmers will be able to employ trained applicators

6. Pesticide effectiveness

Spinosad provides highly efficacious control of many caterpillars of lepidopteran insects on

numerous crops.

7. Compatibility of the Proposed Pesticides with target and non-target ecosystems

Based on information from the US pesticide information Centre9, Spinosad is practically non-toxic to moderately toxic to fish depending on the species; slightly to moderately toxic to aquatic invertebrates; practically non-toxic to slightly toxic to birds, based on studies with bobwhite quail and mallard ducks; and moderately toxic to earthworms. Spinosad is very highly toxic to certain aquatic invertebrates. N-desmethyl degradates of spinosad are likely as toxic or more toxic than spinosad, especially to aquatic invertebrates. Spinosad is however very highly toxic to bees. However, evidence suggests that spinosad has little or no effect on honey bees and other beneficial insects after sprays have dried. Sprays will be limited to farms to minimize the likelihood of contact with bees. Spraying of spinosad must not be performed in areas of blooming foliage, when bees are actively foraging, or to any perennial water body.

There are several important factors that affect spray drift, including wind speed, wind direction, temperature, relative humidity, and method of application. Read and follow all directions regarding spray drift on the product label. If guidelines are minimal, use the following guidelines:

Wind speed and temperature inversions: Do not apply when wind speeds favor drift beyond the area to be treated. This is typically when wind speeds are greater than 15 mph (24 kph) at the application site.

If applying at wind speeds less than 3 mph (4.8 kph), the applicator must determine if a) conditions of temperature inversion exist, or b) stable atmospheric conditions exist at or below nozzle height. The application will not make applications into areas of temperature inversions.

9 http://npic.orst.edu/factsheets/spinosadgen.html#wildlife

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John Martin, 02/24/17,
Two things should likely be added here, which I have done:Requirement that spraying cannot be conducted in areas of blooming foliage or while bees are actively foraging. Spray Drift Management
John Martin, 02/24/17,
Require rather than recommend.
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Droplet size: Apply as a medium or coarser spray American Society of Agricultural and Biological Engineers (ASABE) standard 572), and the minimum volume mean diameter (VMD) for spinning atomizer nozzles.

Ground Spray Applications: Apply using a nozzle height of no more than 4 feet above the ground.

Swath Adjustment: When applications are made cross-wind, the swath will be displaced downwind. The applicator must compensate for this displacement at the downward edge of the application area. Leave at least one swath unsprayed at the downwind edge of the treated area to account for drift.

Yano et al (2002)10 documented several environmental beneficial features of Spinosad including low toxicity to beneficial insects and rapid degradation in the environment. Yano et al (2002) also observed that Spinosad has low acute mammalian toxicity (oral LD50 3738 mg/kg for male rats and > 5000 mg/kg for female rats and male and female mice, rabbit dermal LD50 > 5000 mg/kg, and rat inhalation LC50 > 5.18 mg/l air), and does not cause significant dermal or ocular irritation in rabbits.

8. Conditions under which the pesticide will be used, including climate, flora, fauna, geography, hydrology and soils.

The conditions under which Spinosad will be used have been discussed in detail in the ADVANCE PERSUAP. The area of implementation has not changed and hence these conditions remain relevant and the same for the target crops. All of agro-ecological zones offer favorable conditions for pesticide use under appropriate training and supervision.

9. Availability of other products and non-chemical methods

Non-chemical options are recommended in Tables 2-3, 2-4 and 2-5 of the ADVANCE PERSUAP. Additional non-chemical options will be adopted from Annex 1 of the ATT approved PERSUAP 201411, including the use of neem seed extracts.

10. Ability of Government of Ghana to regulate or control the distribution storage, use and disposable of the recommended pesticide

Pesticide evaluations and registration is the sole responsibility of the Ghana EPA, it also has the responsibility to regulate the use of agrochemicals in the country. Details of the responsibilities of the Ghana EPA have been discussed in the ADVANCE PERSUAP. The Ghana EPA is

10 B. L. Yano; D. M. Bond; M. N. Novilla; L. G. McFadden; M. J. Reasor (2002): Spinosad Insecticide: Subchronic and Chronic Toxicity and Lack of Carcinogenicity in Fischer 344 Rats. https://doi.org/10.1093/toxsci/65.2.288.

11 http://gemini.info.usaid.gov/repository/pdf/39950.pdf

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supported by the Plant Protection and Regulatory Service Division (PPRSD) of the Ministry of Food and Agriculture (MOFA). The responsibilities of the PPRSD have also been outlined in the ADVANCE PERSUAP.

11. Provision for training of users and applicators

The ADVANCE project has engaged an experienced entomologist (Dan McGrath) from Oregon and California to train project staff on identification fall armyworms, and management options, including the use of spinosad. The entomologist will also work with selected farmers and project officers on the field to set up pheromone traps and monitor the fall armyworm. This year the project will train and equip over 200 individuals to become commercial spray service providers. The training will include procedures for applying spinosad to ensure effectiveness.

12. Monitoring use and effectiveness

The effects of fall armyworms on maize crops in the 2016 crop season will likely drive farmers to over apply pesticides. To forestall such panic, the project will deploy pheromone traps to advise farmers on the need to spray and when to spray. Using SMS technology and radio the project will keep farmers informed on a daily basis on the incidence or otherwise of fall army worms. The effectiveness of spinosad will monitored as part of the annual pesticide use monitoring conducted on demos by the project. The pesticide use monitoring data collection tool is in Annex 4 of the PERSUAP submitted April 2016.

C.SAFER USE ACTION PLAN

The ADVANCE submitted PERSUAP summarizes the project’s Pesticide management efforts in 3-fold based on the issues identified in the PER as follows:

a. Promote safe use of agrochemicals through pesticide use awareness;b. Prevent environmental pollution as a result of improper pesticide applications and disposal;c. Ensure compliance with Title 22 of the Code of Federal Regulations section 216.

The recommended safer use actions have been summarized based on these objectives in Table 3.

Note that Table 3 and Table 4 are not limited to the current evaluation report. They apply to all previous evaluations as contained in the submitted PERSUAPs of January 2015 and April 2016 and the present evaluation report.

TABLE 3: SUMMARY OF SAFER USE ACTIONS

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Objective Issues Interventions required Outputs

A. PESTICIDE RISK AWARENESS

A1. Reduce reliance on pesticides.

Local pest control options are limited.

Pesticides are costly and may not be used safely.

Follow GAPs recommendations

Use of IPM Practice crop rotation Select resistant

varieties

Reduced incidence of diseases and pests.

More farmers adopt IPM.

A2. Promote use of PPEs

Farmers do not fully appreciate the importance of PPEs

Farmers do not fully appreciate the potential hazards of using pesticides.

Continuous education of farmers on the importance of PPEs

Promote use of less hazardous agrochemicals

Increased use of PPEs by farmers

A3. Discourage re-use of pesticide containers

Containers are used to store household items including food.

Farmers are unaware of the dangers involved.

A sustained campaign to discourage re-use of containers.

Provide a central point for collecting and disposing containers.

Reduced number of people using pesticide containers

A4. Discourage women and children from pesticide application

Limited farm labor compelling women to apply pesticides.

Inability of women to pay for SSP services.

Provide special training to women on the effects of pesticides on women and children.

Reduced cases of women applying pesticides

B. PREVENT ENVIRONMENTAL POLLUTION & HUMAN HEALTH RISK FROM PESTICIDE USE

B1. Promote safe disposal of pesticide

Empty pesticide containers are either left on farms or re-used for

Set up container collection centers with NFs where all

Reduced incidence empty

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Objective Issues Interventions required Outputs

containers domestic purposes. Some farmers are not

aware of the proper methods of disposal.

containers used by out-growers will be collected.

Destroy and bury containers or return to manufacturers for re-use.

containers littered on farms.

B2. Minimize ground and surface water contamination.

Pesticide use near water bodies.

Pesticide use on wet fields with flowing water.

Pesticide use immediately after rainfall.

Reduce soil disturbance such as reduced tillage.

Leave a buffer of at least 5m to rivers and streams when spraying:- Flat land: 5m- Gentle slope: 10m- Slope >30o: 15m

Farmers adopt conservation farming methods.

B3. Follow Spray Drift Management Protocols

Impacts to bee colonies Impacts to surface water

bodies and aquatic invertebrates

Do not spray in areas of blooming foliage or when bees are actively foraging

Do not apply to any perennial water body

Reduced risk to bees

Reduced risk to aquatic invertebrates

B4. Minimize potential for using pesticides more than necessary.

Farmers may apply pesticides, especially for storage grain, without actually encountering the threat of a pest invasion leading sometimes to avoidable high cost of agrochemicals and over application of pesticides.

Promote GAPs and IPM to reduce over reliance on pesticides.

More farmers able to interpret pesticide labels

C. ACTIONS TO ENSURE COMPLIANCE

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Objective Issues Interventions required Outputs

C1.Conduct safe pesticide use training

Farmers and other persons who handle pesticides have inadequate knowledge of pesticide products and labels.

Develop training content targeting specific groups – farmers, women, dealers, partners etc.

Training contents developed

C2.Promote the services of SSPs

Farmers may do their own spraying because they have no access to trained spray service providers.

Farmers who do their own spraying often do not wear PPEs and may apply more chemical than needed.

Work with NFs and FBOs to include spray services in their extension support to out-growers.

Provide regular training to SSPs on environmental safety procedures.

Training programs for SSPs conducted

C3.Avoid the use of highly toxic products

Farmers do not appreciate the short and long term consequences of very toxic products on their health and the environment.

Some farmers simply do not know the toxic levels of the products they use and the need to avoid them.

Train farmers to read and understand the symbols and colors on pesticide labels.

Promote use of non-chemical pest control option

Farmers adopt IPM approaches

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TABLE 4: SAFER USE MONITORING PLAN

Monitoring the recommended Safer Use Actions

Objective Issues Interventions required

Responsible party

Indicators Means of verification

Frequency

A. PESTICIDE RISK AWARENESS

A5.Reduce reliance on pesticides.

Local pest control options are limited.

Pesticides are costly and may not be used safely.

Follow GAPs recommendations

Use of IPM Practice crop

rotation Select resistant

varieties

Agric Production Officers

No. of farmers adopting IPM.

Proportion of farmers using improved seed and recommended fertilizers from Gross Margin reports

Yearly

A6.Promote use of PPEs

Farmers do not fully appreciate the importance of PPEs

Farmers do not fully appreciate the potential hazards of using pesticides.

Continuous education of farmers on the importance of PPEs

Promote use of less hazardous agrochemicals

Agric Production Officers

Environmental Specialist

Proportion of farmers using PPEs

Pesticide use monitoring report.

Inventory of pesticides used on demos.

Yearly

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Monitoring the recommended Safer Use Actions

Objective Issues Interventions required

Responsible party

Indicators Means of verification

Frequency

A7.Discourage re-use of pesticide containers

Containers are used to store household items including food.

Farmers are unaware of the dangers involved.

A sustained campaign to discourage re-use of containers.

Provide a central point for collecting and disposing containers.

Agric Production Officers

Environmental Specialist

Number of communities using pesticide containers

Radio jingle reports

Pesticide use monitoring report

Yearly

A8.Discourage women and children from pesticide application

Limited farm labour compelling women to apply pesticides.

Inability of women to pay for SSP services.

Provide special training to women on the effects of pesticides on women and children.

APOs Environmental

Specialist Gender

Specialist Outreach

Specialist

Reduced cases of women applying pesticides

Radio jingle reports

Pesticide use monitoring report

Yearly

B. PREVENT ENVIRONMENTAL POLLUTION & DANGER TO HUMAN HEALTH

B5.Promote safe disposal of pesticide

Empty pesticide containers are either left on

Set up container collection centers with NFs where

Agric Production

Reduced incidence of empty

Radio jingle reports

Yearly

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Monitoring the recommended Safer Use Actions

Objective Issues Interventions required

Responsible party

Indicators Means of verification

Frequency

containers farms or re-used for domestic purposes.

Some farmers are not aware of the proper methods of disposal.

all containers used by out-growers will be collected.

Destroy and bury containers or return to manufacturers for re-use.

Officers Environmental

Specialist Nucleus

Farmers

containers on farms.

Pesticide use monitoring report

B6.Minimize ground and surface water contamination.

Pesticide use near water bodies.

Pesticide use on wet fields with flowing water.

Pesticide use immediately after rainfall.

Reduce soil disturbance such as reduced tillage.

Leave a buffer of at least 5m to rivers and streams when spraying:- Flat land: 5m- Gentle slope:

10m- Slope >30o:

15m

Agric Production Officers

Environmental Specialist

No. of farmers exposed to conservation farming methods.

Demo log sheets Demo report

Yearly

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Monitoring the recommended Safer Use Actions

Objective Issues Interventions required

Responsible party

Indicators Means of verification

Frequency

B7.Minimize potential for using pesticides more than necessary.

Farmers may apply pesticides, especially for storage grain, without actually encountering the threat of a pest invasion leading sometimes to avoidable high cost of agrochemicals and over application of pesticides.

Promote GAPs and IPM to reduce over reliance on pesticides.

Agric Production Officers

Environmental Specialist

More farmers able to interpret pesticide labels

GAPs training attendance sheets

Yearly

C. ACTIONS TO ENSURE COMPLIANCE

C4.Conduct safe pesticide use training

Farmers and other persons who handle pesticides have inadequate knowledge of pesticide

Develop training content targeting specific groups – farmers, women, dealers, partners etc.

Environmental Specialist

ATT project EPA

Training contents developed

Training materials

Once

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Monitoring the recommended Safer Use Actions

Objective Issues Interventions required

Responsible party

Indicators Means of verification

Frequency

products and labels.

C5.Promote the services of SSPs

Farmers may do their own spraying because they have no access to trained spray service providers.

Farmers who do their own spraying often do not wear PPEs and may apply more chemical than needed.

Work with NFs and FBOs to include spray services in their extension support to out-growers.

Provide regular training to SSPs on environmental safety procedures.

Environmental Specialist

Agric Production Officers

Training programs for SSPs conducted

Training reports SSP records

Yearly

C6.Avoid the use of highly toxic products

Farmers do not appreciate the short and long term consequences

Train farmers to read and understand the symbols and colours on

Environmental Specialist

Regional Coordinators

Snr Agric

Farmers adopt IPM methods

Training reports Yearly

24

Walter Knausenberger, 05/11/17,
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Monitoring the recommended Safer Use Actions

Objective Issues Interventions required

Responsible party

Indicators Means of verification

Frequency

of very toxic products on their health and the environment.

Some farmers simply do not know the toxic levels of the products they use and the need to avoid them.

pesticide labels. Promote use of

non-chemical pest control option

Production Specialist

Agric Production Officers

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ANNEXES: Additional Resources for Combatting Armyworm InfestationContents:Annex 1. Ghana Fall Armyworm Pest Management Decision Guide (Dec. 2016), produced by Ghana MOFA PPRSD & CABI Plantwise (Dec. 2016/March 2017)

Annex 2. African Armyworm Pest Management Decision Guide (March 2016), by Ghana MOFA PPRSD & CABI Plantwise

Annex 3. Ghana Comprehensive Action Plan for Management of the Fall Armyworm (May 8, 2017)(source: CABI Plantwise)

Annex 4. Synoptic Proposed Fall Armyworm (FAW) Emergency Action Plan for Affected Countries (generic)(source: CABI Plantwise. Feb. 2017).

Annex 5: Matrix of Ghana FTF Agricultural Technology & Trade (ATT) Crops with Primary Production Constraints, PERSUAP-Recommended Pest Prevention GAP/IPM Tactics & PERSUAP-Recommended Curative Tools and Tactics (ATT PERSUAP 2014).

Annex 6. Guidelines for Pest Management Plans (PMPs) for Ghana Crops and Beneficiaries (from USAID Ghana ATT PERSUAP)

Annex 7. Elements of Integrated Pest Management (IPM) Program (USAID Ghana ATT PERSUAP)

Note: Also refer to Programmatic PERSUAP for Fall Armyworm Management in Africa. Version 1. May 2017. Approved 5/16/2017 (AFR, BFS & DCHA BEOs). Revised 5/22/2017. ECD Link: http://gemini.info.usaid.gov/document.php?doc_id=50065.

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Annex 1. Fall Armyworm Pest Management Decision Guide (12/2016), by Ghana MOFA PPRSD & CABI Plantwise. Opensource link: http://www.plantwise.org/FullTextPDF/2017/20177800275.pdf

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Annex 2. African Armyworm Pest Management Decision Guide (March 2016), by Ghana MOFA PPRSD & CABI Plantwise. Opensource link: http://www.plantwise.org/FullTextPDF/2017/20177800134.pdf

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Annex 3. Fall armyworm response in Ghana: Stakeholder workshop. Comprehensive Action Plan. Ghana MoFA/PPRSD Report by J. Godwin, W. Hevi and R. Day, CABI, May 2017. Can be used to inform USAID Ghana IPs’ SUAP.

Theme Activities Who is involved Who already has plans Time Line

SHORT-TERM ACTIVITIES

Coordination and

collaboration

Identify key stakeholders and establish a steering committee with balanced representation of men, women and youth

PPRSD/MOFA-Lead/CABI/ Farmers(men, women and youth)/Researchers/Input dealer/solution providers/ Development partners/Civil societies/Non-governmental org/The media/District assemblies/Funding agents/Private sector groups

MOFA/PPRSDCABIACDI/ADVANCE (USAID)GIZETC

21st to 30th April,2017

Networking with all stakeholders to enhance information flow. Who to contact, how to organize the information, dissemination, how regular is the information flow, where to locate this platform

Policy makers (PPBD,PPRSD,EPA,CSD and DAES), NGO’s, FBO’s, GAIDA, CSO’s, ECOWAS, Donors, AU, CSIR, Farmers AEAs, General public and the Universities

PPRSD/CABI, ADVANCE, AGRA, FAO, USAID

End of May

Organize stakeholder foraIdentify roles and responsibilities of the various responsibilities(TOR)

PPRSD -MOFA/ CABIPPRSD-MOFACABI

1ST -2ND WEEK OF MAY

Identify collaborating institutions such as EPA, GSA, GES, Information services, NGO’s, Funding Partners, (Ghana should consider public funding of armyworm control for maize growers. (Example: partial subsidy for

PPRSD-MOFA/CABIPPRSD-MOFACABI

1ST -2ND WEEK OF MAY

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Theme Activities Who is involved Who already has plans Time Line

biologically rational pesticides like Bt and Spinosad.)Ghana should consider public funding for armyworm insecticide spray trials.)

Develop an Action Plan. Formation of operational committees to implement the action plan. Field activities (trials)

Steering Committee Steering CommitteePeriods within the next six months.

Awareness raising

Capacity building (training and equipping) for various competency levels (frontline/extension staff, data analyst, farmers, etc) on identifying the moths (with or without pheromone traps), identifying early damage (field scouting) and checking field edges (sweep net sampling).

MoFA-PPRSD, Dept of Agriculture, Regional Agric Dept, CSIR, Universities, NGOs (ADVANCE, GIZ, etc), Data Analyst

MoFA-PPRSD, ADVANCE (USAID), CABI

Q2 2017 onwards

Talk show/jingles on radio (and TV if possible) programs in English and major local languages

Farmers, General public, AEAS, ADVANCE, Farm Radio, PPRSD, CABI ADVANCE, DADU, RADU,NADU, CABI, PPRSD

ADVANCE (USAID) have plans to do jingles on 8 radio Stations in 11 local languages; CABI could potentially organize some radio announcement

End of May

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Theme Activities Who is involved Who already has plans Time Line

Announcement using information vans and during public meetings including worship programs (churches, mosque etc.), similar to plant health rallies from Plantwise

MoFA, DA, CABI, PPRSD, (PPBD, EPA,CSD and DAES), media partners NGO’s, FBO’s, CSO’s, AU, CSIR, Farmers AEAs and Universities

Organized before October 2017

Develop and disseminate identification, monitoring/ field scouting guide on FAW and its management(including resistance management.

MoFA-PPRSD, CABI, DAES, Dept of Agriculture, Regional Agric Dept, CSIR, Universities, NGOs (ADVANCE, GIZ, etc), Data Analyst /ADVANCE/Solidaridad West Africa, NGOs/Research

ADVANCE (USAID) have plans to do jingles on 8 radio Stations in 11 local languages; CABI could potentially organize some radio announcement

Short articles in selected newspapers (electronic or print)on social and economic emplications of FAW in Ghana

Scidev.net; local media partners; international media outlets, international newsletters PPRSD, CABI

Scidev.net, GNA; Graphic business

All year round

Workshops and seminars for farmer groups and AEAs, country reps and organizations in all regions:

Solidaridad W/A, CABI, ECOWAS,FAO, CYMMIT, ADVANCE, PPRSD, Farmers, FBOs and AEAs; international donors and organizations

ADVANCE (USAID) training for monitoring traps, CABI/MoFA/ECOWAS & CIMMYT have international meetings planned

June to October

Establish a user-friendly feedback system (communication mechanisms)

Steering committees, All stakeholders, Operational committee members, etc.

From all angles, specifically;   Farmers,

Apr-17

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Theme Activities Who is involved Who already has plans Time Line

for extension officials in various communities. WhatsApp, Facebook groups/platforms. Media (Radio+ICT)

Media, Etc.

Surveillance

Set up reporting channel (from frontline staff to regional to national level and back)

MoFA-PPRSD, DAES, Dept of Agriculture, Regional Agric Dept, Assistant RELC Coordinators, Research, Universities

MoFA Q2 2017

Develop standardized reporting format for district level frontline staff (Report should capture geographical area, area/extent of infestation, target crop, estimated yield loss, etc)

MoFA-PPRSD, DAES, Dept of Agriculture, Regional Agric Dept, Assistant RELC Coordinators, Research, Universities

CABI, MoFA Q2 2017

Identify canidate natural enemies and initiate classical biological control programme

PPRSD/MOFA, CABI, FAO Oct-17

Conduct laboratory efficacy test for recommended pesticides and Provide emergency or temporal registration of recommended pesticides. Registrant should provide supporting data from sources with fall history such as the America

PPRSD-MOFA, EPA, Input Dealers

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Theme Activities Who is involved Who already has plans Time Line

Regularly review recommendations for fall armyworm control and publish the changes promptly and widely

PPRSD-MOFA, EPA, Input Dealers, CABI-Plantwise CSIR-CRI

MEDIUM-TERM ACTIVITIIES

Awareness Creation

Establish a user-friendly feedback system (communication mechanisms). Toll free lines.   SMS alert /voice notes for mobile phone users,   IVR system

MoFA-PPRSD, CSIR, Universities Extension officers, NGOs (Farm Radio)

2018 onwards

Surveillance

Set up a national monitoring and Early Warning System

MoFA-PPRSD, DAES, Dept of Agriculture, Regional Agric Dept, CSIR, Universities

MoFA-PPRSD, CABI, ADVANCE (USAID), CSIR, Universities

Q2 and onwards

Establish and maintain a regional or national network of both pheromone traps and field scouting efforts.

Farmers/Public and Private Extension/Community Lead Farmers/Departments of Agric/PPRSD/

CABI/Plantwise System

PPRSD/CABI/Plantwise (ongoing)

Control, management and research

Insecticide Research

Comprehensive assessment of effective and available insecticides on the Ghanaian market for the fall armyworm management in Ghana

PPRSD/EPA, CABI, Research/Universities (CSIR-CRI, CSIR-SARI, BNARI/GAEC, UG, UDS,UCC) Input dealers, Farmer, NGOs

PPRSD/EPA, CSIR-CRI

End 2017

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Theme Activities Who is involved Who already has plans Time Line

(spray trials at different ecological zones on efficacy, application timing, number of applications, crop stage, etc)

Cost Control Research/Universities (CSIR-CRI, CSIR-SARI, BNARI/GAEC, UG, UDS,UCC)

2018

Assess armyworm insecticides in terms affordability, accessibility, and availability. Agricultural economist to study of the most cost effective methods of armyworm control.

Establish pesticide subsidies for the control of the fall armyworm

MOFA

Process and analyse information (link to other data sets); The data from pheromone traps and field scouting needs to be collected at a central point, analysed, and reported.

MoFA-PPRSD, CSIR, UniversitiesMoFA-PPRSD, CSIR, Universities, CABI

2018

LONG TERM

Insecticide Research

Low Tech Insecticide Strategies Research/Universities (CSIR-CRI, CSIR- 2018

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Theme Activities Who is involved Who already has plans Time Line

SARI, BNARI/GAEC, UG, UDS,UCC)

Develop effective, low toxicity, low technology strategies for insecticide applications by small farmers. (Example: mixing Bt or Spinosad with corn meal and dropping it, by hand, into the whorl.)

Armyworm Biology

Research/Universities (CSIR-CRI, CSIR-SARI, BNARI/GAEC, UG, UDS,UCC)

2018

Research-into Fall Armyworm biology, ecology and population dynamics, susceptibility to pesticides, subtle differences in life patterns that may affect insecticide strategy (for improved recommendations that may affect pesticide use

Cultural Controls

Research/Universities (CSIR-CRI, CSIR-SARI, BNARI/GAEC, UG, UDS,UCC

2018Research-based recommendations on how planting date affects risk of crop damage in the various maize production regions of Ghana.

Development of novel control strategies Research/Universities (CSIR-CRI, CSIR-

SARI, BNARI/GAEC, UG, UDS,UCC)2018

Research into new ways of controlling the Fall Armyworm. Strategies such

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Theme Activities Who is involved Who already has plans Time Line

as the sterile insect technique, GM crops, resistant varieties etc

Conservation Bio-Control PPRSD/MoFA

2018Research on the diseases and natural enemies of Fall Armyworm, especially indigenous diseases and natural enemies that may cross over from African to the Fall Armyworm

Parliamentary Select Committee on Agricultural/Development Partners/FAO

Evaluation/assessment of impact of the awareness and sensitization programs carried out in the country

PPBD, CABI Year ongoing

Insecticide Resistance Management

PPRSD/EPA/CABI/Research/Universities (CSIR-CRI, CSIR-SARI, BNARI/GAEC, UG, UDS,UCC)

End 2017

Research-based recommendation on how to slow armyworm insecticide resistance that involved pesticide dealers, agencies, farmer groups, and others.

NGOs/FBOs/Input dealers

Monitor resistance in Fall armyworm populations

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Annex 4. Synoptic Proposed Fall Armyworm (FAW) Emergency Action Plan for Affected Countries (Ghana)(source: CABI Plantwise, CABI, Feb 2017.).

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Annex 5: Matrix of Ghana FTF Agricultural Technology & Trade (ATT) Crops with Primary Production Constraints, PERSUAP-Recommended Pest Prevention GAP/IPM Tactics & PERSUAP-Recommended Curative Tools and Tactics (ATT PERSUAP 2014 http://gemini.info.usaid.gov/repository/pdf/39950.pdf).

Rice

Main Pests Pest Prevention GAP/IPM Tactics Curative Tools and Tactics

Rice gall midges (Orseolia oryzivora, Cricotopus sylvestris,Paralauterborniella subcincta,Paratanytarsus spp.)

Farmers use early planting/sowing Use resistant varieties Plow under ratoon from previous crop Remove off-season alternate host plants like wild rice Draining fields for 3-4 days controls the midge Seeding synchronously as soon as possible after flooding Seed parts of the field in sequence as they fill with water Avoid over-doses of fertilizer

In general, insecticide treatment for rice gall midge is ineffective.

Rice stem borers (Chilo zacconius, Coniesta ingnefusalis, Orseola oryzicola, Maliarpha separatella); Pink borer (Sesamia calamistis)

Use resistant and early-maturing varieties. Improved semi-dwarf varieties are generally more resistant to stem borers than the tall traditional ones.

Transplant & grow healthy rice seedlings and plants. Harvest at the very base of the plants, or plow stubble under and flood. Early/synchronized planting & water management

Use natural extracts of neem and chili peppers.

Rice leaf miners (Hydrellia griseola) (Trichispa species)

Several parasitic wasps attack the rice leafminer. Normally a combination of parasites, predators, and high temperatures cause leafminer populations to drop rapidly.

Level the field as accurately as possible. Manage water levels in the field to encourage the rice to emerge quickly and

grow erect. Use resistant varieties. Use crop rotation. Keep bunds and surroundings free from grass weeds Destroy stubble and avoid ratooning. Ensure balanced nutrition (avoid excessive nitrogen application). Removing weedy vegetation on the levees in spring near the time of seeding.

The synthetic insecticides containing deltamethrin or lambda-cyhalothrin may be used.

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Diopsid (stalk-eyed) fly (Diopsis longicornis, Diopsis thoracica, Diopsis spp.)

Use resistant varieties. Remove and dispose of dead-heart plants.

Farmers spray with insecticides containing pyrethroids like lambda-cyhalothrin or deltamethrin and neem-based materials.

Rice Caseworm (Nymphula depunctalis)

Use resistant varieties. Ensure balanced nutrition (avoid excessive nitrogen application). Removing weedy vegetation on the levees in spring near the time of seeding. Many predators control caseworm naturally. Use wider spacing and earlier planting.

Insecticides are not commonly used in northern Ghana against caseworm.

Maize

Pest Prevention GAP/IPM Tactics Curative Tools and Tactics

Maize stalk borers (Busseola fusca)

Natural enemies of larvae include parasitoids Braconid family of parasitic wasps, wasps of the genus Cotesia, and Tachinid fly larvae. Trichogramma parasitoids attack eggs of stalk borers. Predators include ground beetles, lacewing larvae and adults, praying mantis and weaver ants.

Use borer-resistant varieties. Use crop rotation and intercrop maize with cowpea or groundnut. Plant early at the beginning of rains or within 2 weeks. Sanitation: Remove and destroy stalks by burning, feeding to cattle or

composting.

Apply imidacloprid or thiamethoxam to seed or growing plant, or apply acetamiprid to the plant (but only when plants are in vegetative state, not when flowering due to risk to pollinators and honeybee colony collapse disorder).

If they become registered, use natural pesticides containing BT toxin (extract from soil microbes) between the egg stage and leaf-feeding stage (before they bore into the stem).

Can use synthetic insecticides containing lambda-cyhalothrin.

Corn earworm (Helicoverpa zea)

Use resistant varieties. Many predators and parasites attack corn earworm eggs, including several

species of Trichogramma. General predators include lacewings, minute pirate bugs, and damsel bugs eat corn earworm eggs and small larvae.

Monitor fields regularly. Two weeks before planting, remove weeds and grasses to destroy earworm

larvae and adults harboring in those weeds and grasses.

Use of organic botanical insecticides like neem seed extract.

Use of organic biopesticides or microbial controls consisting of Bacillus thuringiensis/BT.

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Practice crop rotation. Avoid planting crops successively that are hosts to cotton bollworm like corn, sorghum, tobacco, soybean, and tomato.

Sanitation: After harvest, remove cotton stubble and destroy by burning, feeding to cows or composting.

Armyworms (Spodoptera exempta)

NB: this is different from the Fall (or American) armyworm, S. frugpiperda.

Natural enemies include parasitoid Braconid and Cotesia wasps and Tachinid flies as well as damsel bugs, ground beetles, lacewings and weaver ants.

Remove weeds from bordering fields and on field borders. Sanitation: Remove all plant debris after harvesting. Pheromone traps placed along the edges of fields may be used to monitor

adult moths. This is a particularly good technique for detecting large emergences or migrations occurring on weather fronts.

Start monitoring before seedlings emerge by checking for egg masses and young larvae in surrounding weeds.

Botanical and homemade water extracts include chili, garlic, and neem seed.

Use sprays of BT, if and when they become registered and available.

To reduce development of resistance, regularly rotate chemicals to different chemical families.

Can use synthetic insecticides containing lambda-cyhalothrin.

Termites Baits: wood stakes treated with borates Insecticide seed treatment. Use composted instead of fresh mulch. Hand dig out nest to kill queen, synthetic pyrethroid insecticides poured into

nest.

Can spray imidacloprid (but only when plants are in vegetative state, not when flowering due to risk to pollinators and honeybee colony collapse disorder).

Maize Leafhoppers (Cicadulina spp. Especially Cicadulina mbila (transmits MSV)

Maize Streak Virus (MSV)

Plant early and maintain a maize-free period over the winter months. Practice proper field sanitation. Many cereal crops and wild grasses serve as

reservoirs of the virus and the vectors. Free area of weeds and remove all plant debris after harvest to remove the possible breeding sites of adults.

Prepare a healthy soil to grow healthy plants. Healthy plants can withstand leafhoppers' feeding damage.

Practice crop rotation: do not plant maize after maize. Remove all volunteer maize plants that grow in new plantings of rotation crops.

Properly rotate crops that are not susceptible to leafhoppers. Use reflective mulches

Try botanical and homemade water extracts of garlic and neem.

No synthetic insecticides are recommended or cost-effective, however synthetic insecticides containing imidacloprid could be used (but only when plants are in vegetative state, not when flowering due to risk to pollinators and honeybee colony collapse disorder).

Grasshoppers Send kids to handpick. Natural predators control most grasshoppers. Control weeds around and in field.

Can use insecticides containing lambda-cyhalothrin or deltamethrin.

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Annual & Perennial Grass Weeds, Broad Leaf Weeds

Use an integrated weed management scheme:

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

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

Place the fertilizer in such a way that the crop has access to it but the weeds do not. This allows the crop to be more competitive with weeds.

Keep the surroundings of farm free of weeds, unless they are maintained and intended as habitats for natural enemies of crop pests.

Regularly clean farm tools. Use green manure, which chokes out weeds. Use intercropping. Hand weeding, hoeing, rototiller and composting (do not compost weeds that

have flowered and set).

Before planting, use non-selective herbicides containing glyphosate.

At planting or after planting, use synthetic herbicides containing glyphosate or pendimethalin.

Maize Storage weevils and grain borers

Do routine monitoring. Ensure good pest identification; understand pest biology, ecology, and behavior.

Use good sanitation and good grain storage practices, as follows: All grain stored off the floor on palates, with space between palates, well

ventilated/aerated and lighted, dispose of old containers. In empty shipping containers, thoroughly sweep or brush down walls,

ceilings, ledges, braces, and handling equipment, and remove all spilled debris.

Brush, sweep out and/or vacuum the truck beds, augers, and loading buckets to remove insect-infested grain and debris.

Remove all debris from fans, exhausts, and aeration ducts (also from beneath slotted floors, when possible).

Remove all debris and vegetation growing within ten feet of the warehouses (preferably the whole storage area).

Examine area to determine if rodent bait stations are required, and use if needed. Be sure to follow all label directions.

Spray cleaned area around bins with a residual herbicide to remove all undesirable weedy plants.

Remove all debris from the storage site and dispose of it properly. Frequent rotation of the stocks, "FIFO" (First In - First Out) rule applies.

If needed, can use synthetic insecticide powders or dusts containing pirimiphos-methyl. Pyrethrum/pyrethrins or pirimiphos-methyl+ permethrin may be used, if these products become available in north Ghana.

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Use sticky traps to monitor for presence and quantity.

Soybean

Pest Prevention GAP/IPM Tactics Curative Tools and Tactics

Armyworms (Spodoptera exempta)

NB: this is different from the Fall (or American) armyworm, S. frugpiperda. Seehttp://www.plantwise.org/FullTextPDF/2017/20177800275.pdf

Natural enemies include parasitoid Braconid and Cotesia wasps and Tachinid flies as well as damsel bugs, ground beetles, lacewings and weaver ants.

Remove weeds from bordering fields and on field borders. Sanitation: Remove all plant debris after harvesting. Pheromone traps placed along the edges of fields may be used to monitor

adult moths. This is a particularly good technique for detecting large emergences or migrations occurring on weather fronts.

Start monitoring before seedlings emerge by checking for egg masses and young larvae in surrounding weeds.

Botanical and homemade water extracts include chili, garlic, and neem seed.

Use sprays of BT, if and when they become registered and available.

To reduce development of resistance, regularly rotate chemicals to different chemical families.

Can use synthetic insecticides containing lambda-cyhalothrin.

Thrips—flower drop Use of soil mulches. Control weeds around fields. Sampling for thrips by examining early flower clusters. Remove weed and crop residues at end of season. Use yellow and blue traps to monitor or for mass trapping.

Use of neem seed extract. Can use insecticides containing

dimethoate, lambda-cyhalothrin and pyriproxyfen provide great reduction in thrips emergence.

Green stinkbugs (Nezara viridula)

Use resistant varieties Many parasitoids control GSB eggs and larvae, so do not use broad-spectrum

insecticides; monitor for parasitism levels and make treatment decision accordingly

Destroy weeds (legumes, thistles, mustards, and mallows) that are good overwintering hosts for adult stinkbugs around fields.

Can use homemade neem seed extract plus soap water.

Can use insecticides containing deltamethrin, imidacloprid or thiamethoxam (for imidacloprid and thiamethoxam, only when plants are in vegetative state, not when flowering due to risk to pollinators and honeybee colony collapse disorder).

Pre-Emergence Weeds Use an integrated weed management scheme:

Perform thorough land preparation (soil tillage, fertilizer, and water

Use herbicides containing glyphosate, 24D-amine, bentazon sodium salt, imazethapyr.

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

do not. This allows the crop to be more competitive with weeds. Keep the surroundings of farm free of weeds, unless they are maintained and

intended as habitats for natural enemies of crop pests. Regularly clean farm tools. Use green manure, which chokes out weeds. Use intercropping. Hand weeding, hoeing, rototiller and composting (do not compost weeds that

have flowered and set).

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Annex 6. Guidelines for Pest Management Plans (PMPs) for Ghana Crops and Beneficiaries (from ATT PERSUAP Schroeder 2014, http://gemini.info.usaid.gov/repository/pdf/39950.pdf)

What is a PMP12?

Pest Management Plans or Guides provide field crop, livestock production or project decision-makers – farmers and farm managers – with best production practices recommendations, usually adapted by region, crop phenology and seasons. The aims of PMPs are to reduce the risks to production from pests by using a combination of best practices, including IPM, Integrated Vector Management (IVM) and Integrated Weed Management (IWM), that maximize crop or livestock health, and thus resilience to or tolerance of pests, and without an over-reliance on pesticides needed when best practices are not followed. Thus, prevention of pests plays a strongly pivotal role in the PMP, followed closely by management of pests when prevention alone is not adequate for the level of control needed or desired.

Who are the PMP’s intended audiences and users?

Farm land preparation and crop production decision-makers Farmers Farm managers

Why is a PMP being done?

PMP Objectives:

Prevent or reduce pest damage risk to agricultural production or health Protect the health of farmers, farm family members, laborers and community members from pesticide risks Maintain economically sound practices Reduce environmental pollution and degradation risks Enhance the overall quality and quantity of biodiversity on the sustainable farm work environment

12 PMPs or Year-Round (seasonal) IPM Programs are state of the art in many developed countries, and they help institutionalize IPM in planning and practice. PMPs provide agriculture managers and farmers with a tool to predict and prevent many crop pests of each crop throughout a season. See examples of PMPs at http://www.ipm.ucdavis.edu/PMG/crops-agriculture.html, upper left corner under “Year-Round IPM Programs”.

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Respond to foreign market demand for the use of agriculture sector best management practice standards, also called Good Agriculture Practices (GAPs) which include IPM measures, to achieve farm and produce certification

Comply with local, regional, donor and international laws, conventions, and regulations

Organization of the PMP

The following pieces of crop- or livestock-specific background information are used to build a PMP base

General information on the crop/livestock/sector Crop/livestock common/species names: Crop/livestock developmental stages: Production regions and how they differ by soil type, pH, fertility, etc Overall concerns and priorities for crop/livestock production Crop/livestock cultural best practices Crop/livestock Good Agriculture Practices (GAPs) including some IPM (see PERSUAP section on GAPS and IPM) recommendations

Individual Pest Prevention and Management Sections for each of the following pest types:

Invertebrate (Insects, Mites, Slugs/Snails, Nematodes) Diseases (Fungi, Bacteria, Viruses, Other) Weeds (annual grasses, broadleaves, perennial grasses, broadleaves, sedges, others) Vertebrates (birds, rodents, other)

For each pest type, first, identify overall priorities for pest prevention and management in the target crop or livestock.

Next, identify individual pest species noting the type of damage incurred; part of plant damaged: roots/rhizomes/tubers, stems/stalks, leaves, florescence, or seeds (field or stored); or if livestock, part of animal affected.

To best understand how to manage a pest, one needs to understand how, where, when and on what parts of the plant or animal the pest feeds. For field pests and stored grain/food pests, many PMPs are designed and outlined as follows, for each major species of pest (insects, mites, slugs/snails, nematodes):

Photographs of each pest, life stages Photographs of plant or livestock damage

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Description of the pest, life cycle and survival strategies13: Description of damage symptoms Best Prevention Practices

o Use any and all of the above GAPs including IPM o Country or region-specific information

Best Management Practiceso Focus on prevention (above) o Country or region-specific information

Information on PMP-recommended pesticides:

Information needed for each pesticide referenced in the above PMP, by pest (so the farmer/farm manager has the information at their fingertips and do not need to refer to other documents and tables to find it):

Pesticide essential information needed

Active Ingredient (AI) name Product Trade names (with EPA and WHO Acute Toxicity Classifications in parenthesis) Amounts to use per hectare Price Pre-Harvest Interval (PHI) Special comments on best application methods and frequency Any resistance management strategies needed Pesticide application record sheet Guidelines for reducing spray drift Re-entry interval (REI): field safe re-entry period after spraying Maximum residue levels (MRL) permitted by markets Pesticide precautions with use including Reading the label Legal responsibilities and permitted registration uses

13 Survival strategies: All pests have survival strategies that allow them to live and breed in each crop’s farming systems. Knowing the survival strategies, including overwintering habit and alternate host plants, that are employed by the pest can help with decision making at the farming systems-level (e.g. choice of rotation crops) and also can help to anticipate pest outbreaks.

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Permit requirements for possession and use Recommended and obligated use of PPE and best practices First aid and antidotes Transportation best practices Storage best practices Safe use best practices Container disposal best practices Leftover pesticide disposal best practices Protection of non-pest animals, plants, endangered species and water body quality Protect natural enemies & honeybees: http://www.ipm.ucdavis.edu/PMG/r584310111.html Posting signage in treated fields Some chemicals not permitted on processed crops Potential for phytotoxicity (crop injury) on some crops Documentation and record-keeping on farms

Information needed on Natural Enemies of Pests:

Common Names of Predators and Parasitoids effective against above pests: For a list of common natural enemies of crop pests, see http://www.ipm.ucdavis.edu/PMG/NE/index.html. Genera will likely be the same around the world, with different species in different continents, filling similar niches.

Additional Information Needed:

Will there be an IPM Coordinator, an IPM Advisory Committee, Education and Licensing for Applicators, Currency and Approval of the PMP?

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Annex 7. Elements of Integrated Pest Management (IPM) Program

IPM14

Although farmers are likely using numerous IPM tactics, without really calling them that, IPM philosophy or planning is not generally an active part of crop production in West Africa CORAF/WECARD plots; thus, a basic understanding of the steps or elements needed in an IPM program are addressed below.

Step 1: Learn and value farmers’ indigenous IPM tactics.

Most farmers are already using their own forms of GAPs and IPM, many of which are novel, self-created, adapted for local conditions, and many of which work well. These local tools and tactics need to be well understood and taken into account when making PMPs. Accurate assessments of these farmers’ GAP and IPM technologies, as well as an understanding of actual losses due to different constraints in farmers’ fields are required before designing a crop production and pest management program. Standards and Certification (S&C) farmers will have records of historical pesticide use and trends, as well as information on current use of artisanal or local IPM tactics.

Step 2: Identify key pests for each target crop.

Although perhaps up to ten species of pests may impact a crop and yields at different plant growth stages, generally only two or three are considered serious enough to spend money controlling. Farmers should be encouraged to monitor their population size, their life cycle, the kind of damage they cause and actual losses. Note that crop loss figures based on farmers’ perceptions of damage and loss are often overestimated.

Step 3: Evaluate all management options.

Use of best management practices, preventive measures, and “organic” options to control pest impacts may eliminate the need for synthetic pesticides.

Step 4: Choose IPM methods; identify Needs, and Establish Priorities.

14http://www.fao.org/docrep/006/ad487e/ad487e00.htm ; http://www.fao.org/docrep/006/ad487e/ad487e02.htm; http://en.wikipedia.org/wiki/Farmer_Field_School; http://www.ipm.ucdavis.edu/PMG/crops-agriculture.html

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Continue dialog with project field staff, ministry extension staff and farmers when choosing methods to be used. Consider the feasibility of attractive methods, including the availability of resources needed, farmers’ perceptions of pest problems, their abilities to identify pests, their predators, diseases and parasitoids, and to act upon their observations.

Step 5: Do effective activities and training to promote IPM.

Next, identify strategies and mechanisms for fostering the transfer of the needed IPM technology under various project and institutional arrangements, mechanisms, and funding levels. Define what is available for immediate transfer and what may require more adaptation and validation research. Set up an initial planning workshop (with a COP-supported and signed Action Plan) to help define and orient implementation activities, and begin to assign individual responsibilities.

Learning-by-doing/discovery training programs

The adoption of new techniques by small-, medium- and large-holder farmers occurs most readily when program participants acquire knowledge and skills through personal experience, observation, analysis, experimentation, decision-making and practice. At first, frequent (usually weekly) sessions are conducted for 10–20 farmers during the cropping season in farmers’ fields by trained instructors or extension agents.

Smallholder support and discussion groups

Weekly meetings of smallholders, held during the cropping season, to discuss pest and related problems can be useful for sharing the success of various control methods. However, maintaining attendance is difficult except when there is a clear financial incentive (e.g., credit, advance knowledge of nearby infestations for early action leading to yield improvement).

Educational material

In many countries, basic written and photographic guides to pest identification and crop-specific management techniques are unavailable or out of date. Videos featuring graphic pictures of the effects of acute and chronic pesticide exposure, and interviews with poisoning victims can be particularly effective.

Youth education

Promoting and improving the quality of programs on IPM and the risks of synthetic pesticides has been effective at technical schools for rural youth. In addition to becoming future farmers, these students can bring informed views back to their communities.

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Food market incentives (especially important in the last decade)

Promoting Organic, GlobalGAP, BRC, Fair Trade or other certification for access to the lucrative and rapidly growing S&C systems-driven international and regional food markets can be, and is, a strong incentive to adopt IPM.

Step 6: Partner successfully with other IPM implementers.

The following design steps are considered essential.

Articulate the partnership’s vision of IPM

Organizations may forge partnerships based on a common commitment to “IPM” – only to discover too late that that their visions of IPM differ considerably. It is therefore highly important that partners articulate a common, detailed vision of IPM, centered on the crops and conditions the project will encounter.

Confirm partner institutions’ commitment

The extent of commitment to IPM integration into project, design, and thus implementation depends strongly upon the following key variables:

IPM program integration into larger project. The IPM program is likely to be part of a larger “sustainable agriculture” project. The IPM program must fit into a partner’s overall goals. The extent of this integration should be clearly expressed in the proposed annual work plan.

Cost sharing. The extent of funds (or in-kind resources) is a good measure of a genuine partner commitment.

Participation of key IPM personnel. Organizations should have staff with expertise in IPM. In strong partnerships, these staff members are actively involved in the partnership.

Step 7: Monitor the fields regularly.

At minimum twice a week, farmers should monitor their fields for pests, as some pest populations increase rapidly and unexpectedly; this increase is usually related closely to the stage of crop growth and weather conditions, but it is difficult to predict the severity of pest problems in advance.

Step 8: Select an appropriate blend of IPM tools.

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A good IPM program draws from and integrates a variety of pest management techniques, like those presented in the above list. Flexibility to fit local needs is a key variable. Pesticides should be used only if no practical, effective, and economic non-chemical control methods are available. Once the pesticide has been carefully chosen for the pest, crop, and environment, it should be applied only to keep the pest population low, not necessarily eliminate it.

Step 9: Develop education, training, and demonstration programs for extension workers.

Implementation of IPM depends heavily on education, training, and demonstration to help farmers and extension workers develop and evaluate the IPM methods. Hands-on training conducted in farmers’ fields (as opposed to a classroom) is a must. Special training for extension workers and educational programs for government officials and the public are also important.

Step 10: Monitoring, Record-Keeping and Evaluation (M&E).

Develop data collection forms and checklists, collect baseline GAP/IPM data at the beginning of the project, and set targets.

For the use and maintenance of Good Agriculture Practices (that include safe pesticide storage, use and disposal), maintain farm or project files of: farmer and farm employee training records certification; farm soil, water, biodiversity, cropping and pesticide use maps; pesticide purchase and stock records; price increases or decreases, chemical application instructions including target pest, type of chemical applied, dosage, time of spray, rates at which pesticides were applied, harvest interval days, application machinery, PPE required and used, and any special instructions on mixing, exposure to children or dangers.

Further, for project staff, beneficiaries, produce processing facilities, food warehouses, seed multipliers, or farmers that store seed or food and deal

with stored seed and food pests, there are warehouse BMPs and monitoring reports that incorporate some IPM tactics. These monitoring forms

track, by location or warehouse, use of pallets, stacking, general hygiene and sanitation, damaged packages, actual infestations or signs of rodents,

molds, insects, drainage, locks and security measures, use of IPM tactics including least toxic chemicals and strict BMPs, including restricted access, for use of the pesticides approved in this PERSUAP.

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