Attachment_2-_Various_PERSUAP_DCN_2017-GEO-022_(1)_(2).pdf

DCN: 2017-GEO-022

US Agency for International Development (USAID) USAID/Georgia

Amendment to Initial Environmental Examination (IEE)

Program/Project/Activity Data

Activity/Project Name:

Restoring Efficiency to Agriculture Production (REAP) The Zrda

Assistance Objective: Economic Growth

Program Area:

Country(ies) and/or Operating Unit: Georgia Originating Office: Economic Growth Date: September 22, 2017

PAD Level IEE: Yes No Supplemental IEE: Yes No RCE/IEE Amendment: Yes No

DCN of Original RCE/IEE:

REAP

DCN: 2013-GEO-010

Zrda

DCN: 2015-GEO-034

DCN of Amendment(s):

REAP

DCN: 2013-GEO-010

DCN: 2014-GEO-019

DCN: 2014-GEO-027

DCN: 2017-GEO-004

Zrda

DCN: 2017-GEO-017

If Yes, Purpose of Amendment (AMD):

Request for approval of the 2017 Pesticide Evaluation Reports and Safe Use Action Plan (PERSUAP) and the analysis of the updated list of pesticides.

DCN(s) of All Related EA/IEE/RCE/ER(s): PERSUAP: DCN: 2015-GEO-033

Implementation Start/End: LOP: FY 2013-FY 2021

Funding Amount: LOP Amount: $42,000,000

Contract/Award Number (if known):

Reap: AID-114-C-13-00002 Zrda: AID-114-A-16-00004

Recommended Environmental Determination:

Categorical Exclusion: Positive Determination:

Negative Determination: Deferral:

Additional Elements:

Conditions: Local Procurement:

Government to Government: Donor Co-Funded:

1. Purpose of Amendment

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

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

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

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

The goal of the Zrda (Zrda means growth in the Georgian language) activity is to promote inclusive and sustainable economic growth in targeted regions. The activity purpose is to improve livelihoods and resilience in targeted communities in Georgia. The activity’s sub-purposes are to:

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

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

1.4. This project is currently in compliance.

2017 GEORGIA AGRICULTURE SECTOR PERSUAP APPROVALS PAGE

Approval: _______________________________________ Date: __________ USAID/Georgia Mission Director, Douglas Ball

USAID/Georgia MEO, Gocha Lobzhanidze

USAID/Georgia A/COR, Shamenna Gall

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

Distribution:

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

INITIAL ENVIRONMENTAL EXAMINATION

PESTICIDE EVALUATION REPORT AND

SAFE USE AND ACTION PLAN

USAID/GEORGIA RESTORING EFFICIENCY TO

AGRICULTURAL PRODUCTION

PER

September 22, 2017 This publication was produced for review by the United States Agency for International Development. It was prepared by CNFA.

INITIAL ENVIRONMENTAL EXAMINATION

PESTICIDE EVALUATION REPORT AND

SAFE USE AND ACTION PLAN

RESTORING EFFICIENCY TO AGRICULTURAL

PRODUCTION (REAP)

CONTRACT NUMBER: AID-114-C-13-00002

CNFA

USAID/GEORGIA

SEPTEMBER 22, 2017

DISCLAIMER

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

2017 Updated Georgia CNFA Programmatic PERSUAP

(Pesticide Evaluation Report and Safe Use Action Plan)

Covering Georgia Crops:

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

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

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

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

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

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

Specialty fruits: Kiwi, Feijoa Oil and Seed Crops: Sunflower, Safflower, and Sesame

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

Berries: Blueberries, Greenhouse Strawberries Beets (fodder and sugar)

Oil Crop: Rape Seed/Canola

Drafted by:

Alan Schroeder, PhD, MBA Social and Agricultural Entrepreneur Environmental Compliance Specialist

E-NoeTec Consulting

USA: 703-859-1676

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

ACRONYMS

AI Active Ingredient (when pesticide reference) A/COR Administrative/Contracting Officer’s Representative BMP Best Management Practice BT Bacillus thuringiensis (a bacterium that produces a toxin used as a pesticide) BRC British Retail Consortium CAR Central Asian Republics CFR Code of Federal Regulations CIS Commonwealth of Independent States CITES Convention on International Trade in Endangered Species of Wild Fauna & Flora CNFA Citizen’s Network for Foreign Agriculture COP Chief of Party DCN Document Control Number (USAID Environmental Compliance) DS Powders for dry seed treatment (pesticide formulation) E&E Europe and Eurasia Bureau (USAID) EA Environmental Assessment EC Emulsifiable Concentrate (pesticide formulation) EC50 Effective Concentration 50 (acute toxicity measure) EDD Environmental Due Diligence EMMP Environmental Mitigation & Monitoring Plan EPA US Environmental Protection Agency (also known as USEPA) EU European Union F2F Farmer to Farmer (USAID/Georgia Project) FAO Food and Agriculture Organization (United Nations) FSC Farm Service Center FDA Food and Drug Administration (US) FIFRA Federal Insecticide, Fungicide and Rodenticide Act FS Flowable concentrate for Seed treatment (pesticide formulation) GAP Good Agriculture Practice GAPI Georgia Agricultural Policy Initiative (USAID/Georgia Project) GDP Gross Domestic Product GEF Global Environmental Facility (part of UNEP) GEL Georgian Lari (Georgia’s currency) GlobalGAP Global Good Agriculture Practices, a certification system GMO Genetically Modified Organism GUP General Use Pesticide Ha hectares HT Highly Toxic ID Identification IEE Initial Environmental Examination IGR Insect Growth Regulator IPM Integrated Pest Management IVM Integrated Vector Management IWM Integrated Weed Management km kilometers LC50 Lethal Concentration 50 (acute toxicity measure) LD50 Lethal Dose 50 (acute toxicity measure) M&E Monitoring and Evaluation MD Micro Dispersion (pesticide formulation) MEO Mission Environmental Officer

MOA Ministry of Agriculture MRL Maximum/Minimum Residue Level/Limit MSDS Material Safety Data Sheet msl meters above sea level MT Moderately Toxic NAT Not Acutely Toxic NCAT National Center for Appropriate Technology NEO New Economic Opportunities Initiative (USAID/Georgia Project) NEPA National Environmental Policy Act (US) NIFA National Institute of Food and Agriculture (US) PEA Programmatic Environmental Assessment PER Pesticide Evaluation Report PERSUAP Pesticide Evaluation Report and Safe Use Action Plan pH log of Hydrogen concentration, measure of acidity PHI Pre-Harvest Interval PIC Prior Informed Consent (a treaty, relates to toxic pesticides) POPs Persistent Organic Pollutants (a treaty, relates to toxic persistent pesticides) PMP Pest Management Plan PNT Practically Non-Toxic PPE Personal Protection Equipment R&D toxin Reproductive and Developmental toxin REA Regional Environmental Advisor REAP Restoring Efficiency to Agriculture Production REI Re-Entry Interval (safety period after pesticide spraying) RUP Restricted Use Pesticide S&C Standards and Certification SC Suspension Concentrate (pesticide formulation) SEAS Strengthening Extension and Advisory Services (USAID/Georgia Project) SME Small and Medium Enterprise SPU safe pesticide use ST Slightly Toxic SUAP Safe Use Action Plan UC University of California UN United Nations UNDP UN Development Program UNEP UN Environment Program USAID United States Agency for International Development USDA United States Department of Agriculture USEPA US Environmental Protection Agency (also known as EPA) VHT Very Highly Toxic WFP World Food Program (UN) WHO World Health Organization WP Wettable Powder (pesticide formulation) WS Water dispersible powder for Slurry treatment (pesticide formulation)

TABLE OF CONTENTS

Table of Contents

ACRONYMS

EXECUTIVE SUMMARY

PERSUAP FINDINGS, RECOMMENDATIONS AND CONDITIONS FOR MITIGATION .. 14

PRIMARY RESULTS OF PESTICIDES PROPOSED FOR PERSUAP ANALYSIS:

APPROVED PESTICIDES

POLICY RECOMMENDATIONS

RECOMMENDATIONS TO USAID PROJECTS TO MITIGATE PESTICIDE RISKS

HOW TO USE THE PERSUAP EFFICIENTLY

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

SECTION 2: BACKGROUND

SECTION 3: PESTICIDE EVALUATION REPORT

program

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

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

ecosystems

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

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

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

Introduction to Annex 1, Integrated Pest Management Matrix: Concept, Methods, Information, Errors and Refinement Annex 1: Integrated Pest Management Matrix Annex 2: Guidelines for PMPs for Georgia Crops and Beneficiaries & Elements of IPM Program

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

ACKNOWLEDGEMENTS

The USAID funded, CNFA implemented Georgia REAP project staff members were invaluable for arranging and accompanying Dr. Schroeder on missions to the field in Georgia to meet farm managers, farmers, farmer’s fields, agriculture input importers/distributors and farm input retail stores. Dr.

Schroeder especially appreciates that assistance of CNFA home office experts for backstopping all the logistical needs. Many REAP staff members assisted the team while it was in Georgia, and their efforts are highly appreciated as the mission flowed along smoothly from day to day. Special appreciation is reserved for Dr. Nino Inasaridze for her contributions to this report.

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

EXECUTIVE SUMMARY

Purpose

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

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

Risks

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

2017 Georgia PERSUAP target crops

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

Cereals/Small Grains: Wheat/Winter Wheat, Barley/Winter Barley, Rye, Oats, Triticale Corn/Maize, Sorghum Cole Crops/Crucifers/Brassicas and Lettuces: Cabbages, Cauliflower, Brussels Sprouts, Broccoli, Mustards, Turnips, Radish, Lettuces Solanaceous Crops: Tomato, Potato, Peppers/Paprika, and Eggplant Alliums: Onions, Garlic, Leeks, Chives, and Shallots Cucurbits: Cucumbers, Squashes, Pumpkins, Melons, and Watermelon Umbelliferous Crops: Carrots, Parsnip, Celery/Celeriac, Fennel, Parsley, Coriander, Cilantro, and

Chervil Grape vines: Wine grapes, Table grapes, and Raisin grapes

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

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

Pesticides

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

Low-risk Pesticide AIs not requiring approval under this PERSUAP

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

Some of these products are labeled as Minimum Risk Pesticides (MRP) and are listed at:

http://www.epa.gov/sites/production/files/2015-12/documents/minrisk-active-ingredients-tolerances- 2015-12-15.pdf. A list of pesticide Inert Ingredients that are exempt from FIFRA is at:

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

And, so-called Commonly Consumed Food Commodities (CCFC), which include spices, herbs and oils that may be used by smallholder farmers as homemade pesticides are found at:

https://www.epa.gov/minimum-risk-pesticides/commonly-consumed-food-commodities.

Insect Pheromones

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

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

1 http://www.epa.gov/pesticides/about/types.htm traps. Pheromones could become particularly useful in the fight against the moths of many Lepidopterous pests and caterpillars, like the Tuta absoluta tomato destroyer.

Note that EPA’s classification system for determining pesticide acute toxicity varies from World Health Organization (WHO) system. The differences between the two systems are highlighted in Annex 4.

EPA’s system applies to pesticide producers, and retailers selling to farmers in the USA, and by extension, Regulation 216; however, pesticide producers, sellers and farmers in all other countries use the WHO system, providing an unanticipated (by Regulation 216 drafters) conundrum. Ideally, USAID projects would prohibit use of EPA Class I and WHO Classes Ia and Ib products.

What report findings do and do not mean

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

Before errors (such as human poisonings) occur, it is the responsibility of USAID project implementers to put risk reduction (mitigation) recommendations into action, as soon as possible. Implementers will then monitor changes in risks, impacts and mitigation success using EMMPs (see Annex 9 as a guide).

Finally, the implementers will report positive or negative changes from risk reduction success baselines in semi-annual reporting instruments.

How this report is organized

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

After the Introductory and Background sections build the case for risks to Georgian beneficiaries, farmers and their resources, and the use of best practices, then the PER section addresses the 12 informational factors (a through l) required in the Agency’s Pesticide Procedures, under 22 CFR 216.3 (b)(1)(i).

Finally, the SUAP puts the conclusions and recommendations reached in the PER into a plan of action.

Projects are then expected to assign responsibility for implementation of each recommendation to appropriate staff members connected with risk mitigation and/or monitoring, and develop a timetable and a budget for doing this (see Annex 9 for ideas on how to do this).

PERSUAP FINDINGS, RECOMMENDATIONS AND CONDITIONS FOR MITIGATION

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

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

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

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

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

Annex 6 provides a list of IPM and SPU training topics.

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

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

PRIMARY RESULTS OF PESTICIDES PROPOSED FOR PERSUAP ANALYSIS: APPROVED

PESTICIDES

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

Insecticide AIs and products registered by Georgia, and recommended by this PERSUAP for BEO approval for use in USAID Projects (with the condition that label instructions be followed and that specific conditions for use, shown in parentheses, are followed) acetamiprid (recommended for use during vegetative growth, not flowering3) (Mosetam 20 WDG; Ace SP; Goldplan 20 Sp; Efdal Afitrid 20 SP; Escape 20 SP; Pascal, 20 SP;

Rocket 20 SP; Agroplan 20 SP)

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

Lepidin SC)

Beauveria bassiana, Strain Bb-1 (Nostalgist BL, SL)4 bifenthrin5 (also miticide; approved only for emergency use on Brown Marmorated

Stink Bug) (Talstar 10 EC, Insakar 10 EC, Zonder 10 EC)

3 Spraying during flowering may impact honeybee colonies 4 Note that biofungicide strain Bb-1 of Beauveria bassiana is not EPA registered; however other very closely related strains are. Since it is a biofungicide, with low risks, and is a genus/species registered by EPA, PERSUAP drafters/reviewers agree that it should be permitted as an additional choice for Georgian farmers.

dimethoate (also miticide) (Bi 58; Biital EC; Dingo 40 EC; Bi Fosfini EC; Dimevit EC, Kemidon EC, Alpgor, EC, Fos-Bi, EC, Vertical 40 EC, Bingo, 40 EC; Dumble 40 EC) fenpyroximate (also miticide) (Ortus 5 SC) flupyradifurone (Sivanto Praime SL 200) horticultural oil (also miticide) (Efdal Sunol EO; Key, EC; EKO OIL SPRAY, EW;

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

Max, WG; Nuprid 600 SC; Sultan SL; Confidor Maxi, WG 70; Sidoprid 600 FS;

Confidor SL 200; Resume WS; Gortca WS; Efdal Imidrid 70 WS; Confiprid, WDG;

Imidagold 350 SC; Nuprid 200 SL; Gaucho FS 600; Midash WS; Imidor Max, WG) indoxacarb (Avanti, EK; Kaiser SC) malathion (Malafos EC) spinosad (Spintor, SC) spiromesifen (also miticide) (Oberon 240, SC) spirotetramat (also miticide) (Movento SC 100) Steinernema feltiae (Geo-Nema NSS, Nemycel P) thiamethoxam (recommended for use during vegetative growth, not flowering) (Medal, WG; Actara WG; Renova 25 WG)

Miticide AIs and products registered by Georgia, and recommended by this PERSUAP for BEO approval for use in USAID Projects (with the condition that label instructions be followed and that specific conditions for use, shown in parentheses, are followed) clofentezine (also ovicide—kills mite eggs) (Apollo, SC) dimethoate (also insecticide) (Bi 58; Biital EC; Dingo 40 EC; Bi Fosfini EC; Dimevit EC, Kemidon EC, Alpgor, EC, Fos-Bi, EC, Vertical 40 EC, Bingo, 40 EC; Dumble 40 EC) etoxazole (Zoom 11 SC) fenpyroximate (also insecticide) (Ortus 5 SC) horticultural oil (also insecticide) (Efdal Sunol EO; Key, EC; EKO OIL SPRAY, EW;

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

Fungicides AIs and products registered by Georgia, and recommended by this PERSUAP for BEO approval for use in USAID projects (with the condition that label instructions be followed and that specific conditions for use, shown in parentheses, are followed) azoxystrobin (Doris, SC; Azox WG; Qvadris SC) Bacillus subtilis, Strain QST 713 (Serenade ASO SC 1.34%) boscalid (Cantus, WG; Signum, WG; in a mixture + kresoxim-methyl: Collis, SC)

5 All synthetic pyrethroid pesticide AIs found in more than half of those registered by EPA as RUP (Restricted Use Pesticides), or not registered for field agriculture/horticulture use, were rejected by this analysis. One synthetic pyrethroid AI, bifenthrin, was requested for approval by REAP for support on a campaign to control the Brown Marmorated Stink Bug. A similar 10% EC bifenthrin product was identified as EPA-registered and non-RUP.

captan (approved on seed that has already been treated by PPE-protected professionals;

not for smallholder farmer seed treatment, or from packages with WHO Class 1a or 1b acute toxicity classifications written on them, or labels with red bands on them; granular formulations should be favored) (Merpan 80 WG; Ondar, WP; Efdal Captanim 50 WP;

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

WDG)

copper oxychloride (Cuproflow, SC; Hektas Bakir, WP; Airon, WG; Super Copper, EC;

Abiga-Pik, SL; Neoram 37,5 wxgr; Ossiclor 50 WP) copper sulfate, basic (Cuperval 20 WP; Cuproxat SC; Cuprosulf SG 25; Copper Sulfate, WP; Poltiglia 20 WP; Copper Sulphate P) cymoxanil (in mixtures + mancozeb: Curzeb 50, WP; Rapid Gold 72, WP; Corz Super 50 WP; Valsalaxyl C Plus, WP; Sprinti 50 WP; Efdal Cymoxazeb 50 WP; Larzep 50 WP; Maxalin, WP; Super Star, WP; Erfruit 50 WP; Cymozeb, WP; Corseb, WP;

Rambler 50 WP; Cimo Super 50 WP); (in mixtures + copper oxychloride: Expert Team, WP; Curzate R, WP; Ordan, WP; Efdal Mocan, WP); (in a mixture + metalaxyl:

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

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

250 EC; Izoldifecor 250 EC; Scorpi, EC; Story 250 EC; Scorpion 250 EC; Scort 25% EC); (in mixtures: + mandipropamib: Revus Top 500 SC); (in mixtures + propiconazole:

Taspa, 500 EC; Harbor 300 EC; Broader 30 EC; Efdal Difenpro 30 EC); (in a mixture + kresoxim-methyl: Samshyt, SC); (in a mixture + cyproconazole: Dividend Star 036 KS) dimethomorph (in mixtures + mancozeb: Lider, WG; Avangard WP; Efdal Akrobot MZ, WP; Cambaz MZ, WP; Carmen MZ, WP; Actormen MZ, WP; Dimanco 9, 60, WP);

(in a mixture: + copper oxychloride: Faighter blu, WP) famoxadone (in a mixture + cymoxanil: Tanos, WG) fenhexamid (Teldor 50, WG) fluazinam (Nando SC) fludioxonil (in mixtures + thiamethoxam + difenoconazole: Celest top 312,5 FS); (in a mixture + cyprodinil: Swich 62,5) flutriafol (Foris SC) fluxapyroxad (Sercadis SC) fosetyl aluminum (in a mixture + propamocarb hydrochloride: Previcur Energy SL 840) iprodione (Rovral 50 WP) kresoxim-methyl (Kambit WG; Stroby 500 WG; Strobstar, WG; Efdal Kresdit 50 WG;

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

Mangrif 75 WG; Draco Blue 80, WP; Mankozate MZ, WP; Efdal maco M-45, WP;

Kingcozeb M-45 WP); (in mixtures + cymoxanil: Curzeb 50, WP; Rapid Gold 72, WP;

Corz Super 50 WP; Valsalaxyl C Plus, WP; Sprinti 50 WP; Efdal Cymoxazeb 50 WP;

Larzep 50 WP; Maxalin, WP; Super Star, WP; Erfruit 50 WP; Cymozeb, WP; Corseb, WP; Rambler 50 WP; Cimo Super 50 WP); Efdal Cymoxazeb 50 WP; Larzep 50 WP;

Maxalin, WP; Super Star); (in mixtures + metalaxyl: Trooper 72, sf; Maximo, WDG;

Universal, WP; Ridonet MZ 72, WP; Victor WP; Mancolaxyl, WP; Ridozeb MZ 72 WP;

Metalaxan, WP; Armetil M, WP; Malzeb, WP; Patamil 72 WP; Efdal Mantalax, WP); (in mixtures + dimethomorph: Lider, WG; Avangard WP; Efdal Akrobot MZ, WP; Cambaz

MZ, WP; Carmen MZ, WP; Actormen MZ, WP; Dimanco 9+ 60, WP; Maximum, Wp);

(in a mixture + mefenoxam: Ridomil Gold MZ, WG); (in mixtures + cymoxanil + copper oxychloride: Rapid Gold plus, WP) mandipropamide (in mixtures + copper oxychloride: Pergado C, WG); (in a mixture + difenoconazole: Revus Top 500 SC) mefenoxam (Apron XL, ES); (in mixtures + tebuconazole: Serticor 50 SC; + mancozeb:

Ridomil Gold MZ, WG); in a mixture + copper oxychloride: Ridomil gold plusi 42,5 Wp) metalaxyl (in mixtures + mancozeb: Maximo, WDG; Universal, WP; Ridonet MZ 72, WP; Victor WP; Ridozeb MZ 72 WP; Metalaxan, WP; Armetil M, WP; Malzeb, WP;

Patamil 72 WP; Efdal Mantalax, WP; Mancolaxyl, WP); (in a mixture + copper oxychloride: Metcopper, WP) myclobutanil (Nimbus 24 EC) propamocarb hydrochloride (Previcur SL 607; Propacurn N, SL; Botrin, SL; Efdal

Procar 722 SL; Evakur SL); (in a mixture + fosetyl-aluminum: Previcur Energy SL 840) propiconazole (Tiltust, EC; Bumper 25 EC; Propconazole, EC; Procure EC); (in mixtures + difenoconazole: Taspa, 500 EC; Harbor 300 EC; Broader 30 EC; Efdal Difenpro 30 EC) pyraclostrobin (in a mixture + boscalid: Signum, WG) pyrimethanil (Rhythm, SC; Pyrus 400 SC) sulfur (also miticide) (Thiovit Jet WG; Cosavet, 80 WG; Power Sulfur, WG; Sulphex

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

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

Unicorn, WG); (in a mixture + mefenoxam: Serticor 50 SC) thiram (approved on seed that has already been treated by PPE-protected professionals;

not for smallholder farmer seed treatment) (Thiram Granulflow, WG)

Trichoderma harzianum, Strain T-22 (Trianum G, GR)6 trifloxystrobin (Zato WG 50; Tride, WG; Gurador WG)

Herbicide and Plant Growth Regulator (PGR) AIs and products registered by Georgia, and recommended by this PERSUAP for BEO approval for use in USAID projects (with the condition that label instructions be followed and that specific conditions for use, shown in parentheses, are followed) bromoxynil octanoate (Buctril EC 327.5) carfentrazone-ethyl (Rivet 24, EC) clopyralid (Lion 300 SL) dimethenamid-P (Frontier Optima, EC) fenoxaprop-p-ethyl (Puma Super EW 144) florasulam (Belerina SE, Efdal SE) fluazifop-p-butyl (Fusilade-Forte, EC; Brace Super, EC; Fluent, EC; Tangra, EC;

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

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

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

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

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

Antysapa, WG; Laguun 70 WP; Super Cankor WP; Banderilla 70 WP) nicosulfuron (Eliminator, SC; Nicophuron, SC; Sulfoni, SC 40; Ikanos 40 OD; Miladar, SC; Fullspeed, SC; Efdal Alson, SC; Sunstep SC; Nifuron, SC; Vain, SC; Nikoni SC) oxyfluorfen (Efdal Ocmost 240 EC; Galaxy 240 EC; Goal 2E, EC; Pekss 24 EC;

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

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

Molluscicide AI and products registered by Georgia, and recommended by this PERSUAP for BEO approval for use in USAID projects (with the condition that label instructions be followed and that specific conditions for use, shown in parentheses, are followed) metaldehyde (Metadex Pellet GR, Pel.; Efdal Kimtoks, GR)

SAFE PESTICIDE USE

Beyond the use of GAPs and IPM, to safely use the above-approved pesticides, this document provides brief guidelines and references to more detailed guidelines on basic SPU, including safe labeling, transport, storage, use, first aid and disposal, as well as associated training to reinforce these principles.

USAID-funded projects and/or their sub-grantees and partners that support pesticide use (including but not limited to: purchase, or in any way finance through credit or voucher schemes, together, promote during training, or use on demonstration trials) are recommended to provide such safety training and annual refresher training. Annex 6 provides a list of training topics.

PERSUAP users may access any of these resources for SPU:

EPA’s Worker Protection Safety (WPS)7 program EPA’s Using Pesticides Safely8 program EPA’s Human Health Issues9 website and Emergency Information10 website EPA’s website on Personal Protection Equipment 11 provides guidance on safety equipment needed for pesticide use United Nations (UN) Food and Agriculture Organization (FAO) provides Guidelines for Good

Practice for Ground Application of Pesticides12 World Health Organization’s SPU resources13

7 http://www.epa.gov/pesticides/health/worker.htm 8 http://www.epa.gov/pesticides/health/safely.htm 9 http://www.epa.gov/pesticides/health/human.htm 10 http://www.epa.gov/pesticides/health/emergency.htm 11 http://www.epa.gov/oppfead1/safety/workers/protective-equipment.html 12 http://www.fao.org/docrep/006/y2767e/y2767e00.htm 13 http://www.who.int/water_sanitation_health/resources/vector385to397.pdf

POLICY RECOMMENDATIONS

Continue to control and stop Farm Service Centers (FSCs) from sub-dividing pesticides from large containers to small containers, including water and juice bottles that do not contain essential label and safety information. Pesticides must only be sold in manufacturer-sealed containers.

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

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

Subsidize purchase of PPE for all project farmer beneficiaries.

Subsidize farm certification costs, like GlobalGAP, as appropriate.

RECOMMENDATIONS TO USAID PROJECTS TO MITIGATE PESTICIDE RISKS

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

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

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

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

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

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

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

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

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

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

Program Management Actions on Compliance Monitor FSCs and beneficiary farmers for their understanding and use of best practices/preventive tools and tactics found in Annex 1, organized by crop, as well as each pest, disease, and weeds of each crop.

Also, use Annex 8 as a guide for monitoring beneficiary farms and farmers.

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

Report on any changes in Georgia pesticide regulations and registrations.

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

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

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

HOW TO USE THE PERSUAP EFFICIENTLY

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

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

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

SECTION 1: INTRODUCTION

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

1.1 Purpose, Scope & Orientation

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

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

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

SPU.

These requirements come into effect upon approval of the PERSUAP.

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

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

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

1.2 Regulation 216

From 1974 to 1976, over 2,800 Pakistani malaria spray personnel were poisoned (5 to death) by insecticide mishaps on a USAID/WHO anti-malaria program14. USAID was sued by a coalition of environmental groups, and in response to the lawsuit, drafted 22 CFR 216 (Reg. 216).