EGO PERSUAP.pdf

PESTICIDE EVALUATION REPORT

& SAFER USE ACTION PLAN

(PERSUAP)

USAID/SENEGAL ECONOMIC GROWTH

AGRICULTURAL ACTIVITIES

July 2016

This document has been developed by The Cadmus Group, Inc. under the GEMS II contract (award number AID-OAA-M-13-

00018) for USAID review. Until and unless this document is approved under the processes established by 22 CFR 216, it may not represent the views of USAID or the United States Government.

PESTICIDE EVALUATION REPORT & SAFE USE ACTION PLAN (PERSUAP) | USAID/Senegal Agricultural Activities 2015-2020 III

EXECUTIVE SUMMARY

USAID/SENEGAL AGRICULTURAL PORTFOLIO

Senegal is one of the countries where the USAID Feed the Future (FtF) program is being implemented. FtF is a

Multi-Year Strategy that outlines the five-year strategic plan for the U.S. Government’s global hunger and food security initiative. FtF program activities under USAID/Senegal’s Development Objective (DO) 1, “Increased, Inclusive Economic Growth.” contribute to USAID/Senegal’s goal to increase the agriculture sector’s contribution to economic growth through an inclusive, private sector-led value chain approach. Specifically, USAID/Senegal’s primary FtF goal is to establish formal agriculture production and market systems in three selected value chains: rice, maize and millet. USAID funded nutrition programs in Senegal focus on other crops including cereals, legumes, tubers, green leafy vegetables, vegetables, fruit and also on livestock.

PEST MANAGEMENT NEEDS OF USAID/SENEGAL DO1 AGRICULTURAL

ACTIVITIES

Effective pest management is required to achieve intended development outcomes in these USAID/Senegal agricultural activities. Even in the context of USAID’s policy commitment to integrated pest management (IPM), effective pest management often requires the use of products defined as pesticides by the US Environmental Protection Agency (USEPA).

Pest management needs for USAID/Senegal target crops are detailed in Annex A: Pests & Diseases of Target Crops &

Available & Recommended Control Methods, Annex A in this PERSUAP.

PURPOSE & SCOPE OF THIS PERSUAP

Procurement or use of pesticides on USAID-funded or managed activities requires compliance with the Agency’s pesticide procedures, 22 CFR 216.3(b). In compliance with these procedures, this Pesticide Evaluation Report and

Safer Use Action Plan (PERSUAP):

Establishes the set of pesticides for which procurement, use or support for use is authorized for agricultural activities across the USAID/Senegal portfolio.

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

These requirements come into effect upon approval of the PERSUAP, which addresses the following production value chains: rice, maize, millet, legumes, tubers, green leafy vegetables, vegetables, fruit and livestock. In addition to production, seed treatment and post-harvest storage are addressed.

In addition to current USAID/Senegal agricultural projects/activities, this PERSUAP is designed to provide for the needs of future USAID/Senegal agricultural activities addressing these production value chains.

Should future—or current—activities address different value chains or require the procurement, use or support to use of pesticide active ingredients (AIs) not authorized by this PERSUAP or for uses not authorized by this PERSUAP, an amendment to this PERSUAP will be necessary.

PESTICIDE EVALUATION REPORT & SAFE USE ACTION PLAN (PERSUAP) | USAID/Senegal Agricultural Activities 2015-2020 IV

A PERSUAP pertinent to Senegal was produced for the USAID/ US Global Development Lab’s project Cotton

Activities In Four Target Countries Implemented By The Better Cotton Initiative (BCI)1, in India, Pakistan, Mozambique and

Senegal, and was approved 11/23/2016.

STRUCTURE

Sections 1 and 2 provide an introduction to the PERSUAP purpose and scope and pesticide management needs of agricultural activities across the USAID/Senegal portfolio.

Section 3 gives a brief account of the Senegal environmental context, agricultural practices, and the system of environmental protection and pesticide regulation.

The Pesticide Evaluation Report (PER, Sections 4 and 5) establishes the set of authorized pesticides and requirements for safer use, which culminates with an assessment of the 12 pesticide risk evaluation factors (a through

l) required by 22 CFR 216.3(b).

The Safer Use Action Plan (SUAP; Section 6) provides a succinct, definitive stand-alone statement of compliance requirements, synthesized from the 12-factor analysis. It also provides a mandatory template (sub-section 6.4) for assigning responsibilities and timelines for implementation of these requirements. Each project subject to this

PERSUAP must complete this SUAP template and submit to its Agreement/Contract Officer's Representative

(A/COR) and Mission Environmental Officer (MEO) for approval.

BASIS OF SELECTION AND RESTRICTIONS THAT APPLY TO PESTICIDES

APPROVED FOR USE/SUPPORT VIA THIS PERSUAP

Upon approval of this PERSUAP, pesticides containing the Active Ingredients (AIs) listed in Table 1 (at end of this Executive Summary) are permitted for procurement/use/support by USAID/Senegal agricultural activities. These pesticides have an identified use within an Integrated Pest Management (IPM)scheme; are registered by the US Environmental Protection Agency (EPA) and by the CILSS-CSP2, and are chosen conservatively with respect to their environmental and human health risk profiles*3.

Table I specifies AI- and product-specific risk-reducing conditions. Two of these restrictions are as follows:

No Acute Toxicity Class I Products. While these AIs have been chosen conservatively with regard to their risk profiles, some products with these approved AIs may nonetheless be EPA Acute Toxicity class 1 or equivalent on the basis of their acute oral, dermal or inhalation toxicity. All products in which methanol

(methyl alcohol used as a solvent) is present at 4 percent or more are also Class I. Such products are marked with the skull and crossbones symbol and the word “POISON” or “DANGER” or equivalent.

Under this PERSUAP, such products may ONLY be used by professionally trained certified and registered pest control specialists and NEVER by smallholder farmers. This restriction is set out prominently at the

1 http://gemini.info.usaid.gov/repository/pdf/49770.pdf

2 Senegal is a member of the Comité permanent Inter-Etats de Lutte contre la Sécheresse dans le Sahel (CILSS) – the Permanent Interstate Committee for

Drought Control in the Sahel. Through its Comité Sahélien des Pesticides (CSP) – the Sahelian Pesticides Committee, CILSS addresses registration and regulation of pesticides of its members, including Senegal, Therefore, AIs approved under this PERSUAP are all CSP-CILSS registered.

3 Human health and ecological toxicological summaries and U.S. Environmental Protection Agency (US EPA) registration status for each pesticide are presented in Table B-1 in Annex B.

http://gemini.info.usaid.gov/repository/pdf/49770.pdf

PESTICIDE EVALUATION REPORT & SAFE USE ACTION PLAN (PERSUAP) | USAID/Senegal Agricultural Activities 2015-2020 V top of Table 1.

Some Products Require Label Approval. Similarly, some approved AIs are present in products designated as Restricted Use Pesticides (RUPs) by EPA.4 Generally, AIs for which a significant percentage of US products are RUP have been rejected by this PERSUAP. However, a few such AIs are approved under this

PERSUAP where they meet an important pest management need for which there is no reasonable alternative.

For such AIs, the conditions in Table 1 require IPs to submit the label of the proposed product together with the intended use to USAID for COR and MEO approval prior to procurement or use. To approve the use, the MEO must verify that the closest US-registered analogue to the product is not RUP.

Low-risk AIs not requiring approval under this PERSUAP. Note that some particularly low-risk AIs are exempt from regulation under the US Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and therefore may can be used by implementing partners without approval via this PERSUAP. These are listed at http://www.epa.gov/sites/production/files/2015-12/documents/minrisk-active-ingredients-tolerances-2015-12-

15.pdf. (A list of pesticides Inert Ingredients that are exempt from FIFRA is available at:

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

In addition to these and other restrictions set out in Table 1, approval of the AIs listed in Table 1 is SUBJECT to conditions enumerated in the Safer Use Action Plan and Compliance Tracker (“SUAP Tracker”) provided in Section 6.4. In summary these conditions are as follows:

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

Implementing Partners (IPs) to develop these plans.)

B. Appropriate project staff and beneficiaries must be trained in safe pesticide use and pesticide first aid;

C. Projects must require the use and maintenance of appropriate Personal Protective Equipment (PPE)—as well as safe pesticide purchase, handling, storage and disposal practices;

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

Mandatory use of the “SUAP Tracker.” Any project subject to this PERSUAP must submit a completed SUAP

Tracker to its AOR/COR and MEO 30 days before the implementation of the activity and must update it annually.

The tracker is a mandatory tool for assigning responsibilities and timelines for implementation of PERSUAP requirements, and for tracking compliance

Note: With respect to pesticides, the SUAP Tracker satisfies the requirement for an environmental mitigation and monitoring plan (EMMP). Project EMMPs should simply incorporate the SUAP Tracker by reference

4 In the United States, the same AIs can be in products that are designated by EPA as Restricted Use Pesticides (RUP) as well as in products designated as

General Use Pesticides (GUP). RUPs are pesticides which are not available to the general public in the United States. The "Restricted Use" classification restricts a product to use by a certificated pesticide applicator or under the direct supervision of a certified applicator. This means that a license is required to purchase and apply the product. Certification programs are administered by the federal government, individual states, and by company policies that vary from state to state (see http://www2.epa.gov/pesticide-worker-safety/restricted-use-products-rup-report). Products can be designated RUP because of human acute (immediate) and chronic (long-term) toxicity/health risk, physical hazards such as risks of fire or explosion, and eco-toxicity hazards such as potential risks of water pollution and risk to flora and fauna.. Restrictions can apply to the particular crop, formulations, concentrations or uses.

http://www.epa.gov/sites/production/files/2015-12/documents/minrisk-active-ingredients-tolerances-2015-12-15.pdf http://www.epa.gov/sites/production/files/2015-12/documents/minrisk-active-ingredients-tolerances-2015-12-15.pdf http://www.epa.gov/sites/production/files/2015-01/documents/section25b_inerts.pdf http://en.wikipedia.org/wiki/United_States http://www2.epa.gov/pesticide-worker-safety/restricted-use-products-rup-report

PESTICIDE EVALUATION REPORT & SAFE USE ACTION PLAN (PERSUAP) | USAID/Senegal Agricultural Activities 2015-2020 VI

LIST OF APPROVED AIs WITH CAUTIONS AND RESTRICTIONS

IMPORTANT NOTE: any product containing these AIs that is marked with skull and crossbones or the words

“danger” or “poison” or equivalent may ONLY be used by professionally trained certified and registered pest control specialists and NEVER by smallholder farmers.

Where required by the Advisory column in the table below, IPs must submit pesticide product label to MEO/A/COR for review and approval against USEPA restrictions. MEO/A/COR will review product label against USEPA guidance for restricted use pesticides provided at https://www.epa.gov/pesticide-worker-safety/restricted-use-products-rup-report

IPs must review pesticide label's PPE requirements and environmental hazards statement. Always keep pesticides away from water sources. AIs that have been identified as potential groundwater contaminants are identified in the

Advisory column below.

TABLE 1. PESTICIDES (AIs) APPROVED WITH CAUTIONARY ADVICE AND MANDATORY

RESTRICTIONS (BASED ON INFORMATION PROVIDED IN ANNEX B)

HERBICIDES ADVISORY

2,4-D acid, ester or salts Possible carcinogen, suspected endocrine disruptor, potential groundwater contaminant

Salt and acid forms can be extreme eye irritants

Many products containing this AI are RUP—IPs must submit the product label with description of the proposed use to the COR for MEO approval prior to procurement or use.

Acetochlor Potential groundwater contaminant

All products in combination with Atrazine are RUP.

Few other products are also RUP.

IPs must submit the product label with description of the proposed use to the COR for MEO approval prior to procurement or use.

Bensulfuron methyl Potential groundwater contaminant.

Bispyribac sodium Potential groundwater contaminant

Clethodim Potential groundwater contaminant

Clomazone Potential groundwater contaminant

Dicamba Potential groundwater contaminant, potential developmental/reproductive toxin.

Included in many RUP products. Check all ingredients for approval.

PESTICIDE EVALUATION REPORT & SAFE USE ACTION PLAN (PERSUAP) | USAID/Senegal Agricultural Activities 2015-2020 VII

TABLE 1. PESTICIDES (AIs) APPROVED WITH CAUTIONARY ADVICE AND MANDATORY

RESTRICTIONS (BASED ON INFORMATION PROVIDED IN ANNEX B)

Diuron

Known water pollutant, use care around open water

Fluazifop-P-butyl Potential developmental/reproductive toxin

Fluometuron

Glyphosate and Glyphosate salts Some Glyphosate products are classified as Acute

Toxicity I due to potential for eye irritation and are

RUP.

Do not use products that have Danger sign. In 2015, Glyphosate was identified as a potential carcinogen by

USEPA.

Glyphosate-isopropyl ammonium products are RUP.

IPs must submit the product label with description of the proposed use to the COR for MEO approval prior to procurement or use.

Nicosulfuron Potential groundwater contaminant.

When combined with Atrazine, this AI is RUP. Do not use.

Orthosulfamuron Potential groundwater contaminant, possible carcinogen

Oxadiazon Potential carcinogen and developmental/reproductive toxin

Pendimethalin Possible carcinogen, suspected endocrine disruptor.

Highly toxic to fish and aquatic invertebrate.

Penoxysulam/penoxsulam

Potential groundwater contaminant, possible carcinogen

Prometryn Potential ground water contaminant

Propanil Possible carcinogen, suspected endocrine disruptor.

Moderately toxic to birds and aquatic organisms.

Tembotrione Possible carcinogen

Terbutylazine Also microbicide and algaecide

Tribenuron methyl Possible carcinogen

Triclopyr Slightly to moderately toxic to aquatic organisms

RUP when combined with Picloram (potassium salt), PESTICIDE EVALUATION REPORT & SAFE USE ACTION PLAN (PERSUAP) | USAID/Senegal Agricultural Activities 2015-2020 VIII do not use

FUNGICIDES ADVISORY

Azoxystrobin

Potential groundwater contaminant

RUP when combined with some ingredients. All product ingredients must be approved for use.

IPs must submit the product label with description of the proposed use to the COR for MEO approval prior to procurement or use.

Difenoconazole Possible carcinogen, suspected endocrine disruptor

(used in treated seed)

Copper hydroxide Microbicide, nematicide and fertilizer

Copper sulfate (pentahydrate) Use only acute toxicity Class II or III products; not

Class I

Iprodione Highly toxic to crustaceans

Mancozeb Potential groundwater contaminant, carcinogen and developmental/reproductive toxin

Mefenoxam/ Metalaxyl-M Potential groundwater contaminant (used in treated seed)

Miclobutanil Likely developmental/reproductive toxin, suspected endocrine disruptor

Tebuconazole Potential ground water contaminant, possible carcinogen, suspected endocrine disruptor

RUP in combination with Lambda-cyhalothrin, do not use

INSECTICIDES ADVISORY

Abamectin (Avermectin) Potential reproductive and developmental toxin, suspected endocrine disruptor.

Many products are RUP. IPs must submit the product label with description of the proposed use to the COR for MEO approval prior to procurement or use.

Acetamiprid Do not use during flowering to protect foraging honeybees

When combined with Bifenthrin RUP, do not use http://www.pesticideinfo.org/List_Chemicals.jsp?ChemUseList=Microbiocide&dUseList=y&dDPR_Chem_Code=y&dEPA_PCCode=y&dCAS_No=y&dClassList=y&ChemRegList=&ChemUseList=&dS_BA=y&dEPA_Reg=y http://www.pesticideinfo.org/List_Chemicals.jsp?ChemUseList=Nematicide&dUseList=y&dDPR_Chem_Code=y&dEPA_PCCode=y&dCAS_No=y&dClassList=y&ChemRegList=&ChemUseList=&dS_BA=y&dEPA_Reg=y

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D-phenothrin Highly toxic to fish and aquatic organisms, suspected endocrine disruptor

Azadirachtin (botanical neem extract) also nematicide

Suspected endocrine disruptor

Bacillus thuringiensis (Bt)

Bacillus sphaericus

Beta-cyfluthrin Use only formulations of 10% or less AI, most formulations below 10% are GUP, and above 10% are

RUP

Chlorantraniliprole Potential groundwater contaminant

When combined with Lambda-cyhalothrin RUP, do not use

Chlorothalonil Do not use products with acute toxicity I for eye irritation. Potential groundwater contaminant, likely carcinogen, Cyantraniliprole

Cypermethrin

Cypermethrin (alpha)

Cypermethrin (beta)

Possible carcinogen, potential endocrine disruptor

Many products are RUP. IPs must submit the product label with description of the proposed use to the COR for MEO approval prior to procurement or use.

Most Zeta-cypermethrin products are acute toxicity I, do not use

Deltamethrin Highly toxic to some aquatic organisms

Some products are RUP for some crops and applications. IPs must submit the product label with description of the proposed use to the COR for MEO approval prior to procurement or use.

Flubendiamide Highly toxic to fish

Fludioxinil Potential groundwater contaminant

Insecticidal soap Recommended to use natural soaps and not to use detergents, dish soaps, or any products with degreasers, skin moisturizers, or synthetic chemicals.

Indoxacarb, S-isomer High toxicity to bees and birds

PESTICIDE EVALUATION REPORT & SAFE USE ACTION PLAN (PERSUAP) | USAID/Senegal Agricultural Activities 2015-2020 X

Imiprothrin Highly toxic to fish

Imidacloprid Linked to honey-bee colony collapse disorder. Should not be used during flowering, only during vegetative growth and for seed treatment.

Several products and AI combinations are RUP. IPs must submit the product label with description of the proposed use to the COR for MEO approval prior to procurement or use.

Lambda-cyhalothrin High toxic to fish and other aquatic organisms, toxic to bees.

Many products and AI combinations are RUP. IPs must submit the product label with description of the proposed use to the COR for MEO approval prior to procurement or use.

Lufenuron

Malathion Toxic to bees

When combined with gamma-Cyhalothrin RUP, do not use

Novaluron Insect Growth Regulator (IGR)

When combined with Bifenthrin RUP, do not use

Permethrin May NOT be used for crop and wide area applications such as nurseries. Such uses are RUP.

Weak carcinogen, suspected endocrine disruptor, Highly toxic to fish and aquatic organisms.

IPs must submit the product label with description of the proposed use to the COR for MEO approval prior to procurement or use.

Pyriproxyfen Insect Growth Regulator (IGR)

Pirimiphos-methyl May interfere with proper functioning of the nervous system

Spinosad Slightly to moderately toxic to some aquatic organism

Some products are RUP when combined with

Bifenthrin, or Lamda-cyhalothrin do not use

Spirotetramate

PESTICIDE EVALUATION REPORT & SAFE USE ACTION PLAN (PERSUAP) | USAID/Senegal Agricultural Activities 2015-2020 XI

Tagetes oil

Terbutryn Possible groundwater contaminant, possible carcinogen, possible endocrine disruptor

Thiamethoxam Potential ground water contaminant (used in treated seed)

Some products and used are RUP. IPs must submit the product label with description of the proposed use to the COR for MEO approval prior to procurement or use.

Thyme oil Exempt, not regulated

Trifloxysulfuron sodium Potential groundwater contaminant

RODENTICIDE ADVISORY

Brodifacoum Use in bait traps only, Required to be enclosed in bait stations that are inaccessible to children and non-target animal species.

FUMIGANT ADVISORY

Aluminum Phosphide EPA Toxicity Class I. All products are marked

DANGER. All warehouse pest control activities for protection of agricultural commodities must be performed only by trained and certified pest control specialists. Only products approved in Senegal for control of pests in warehouses and its surroundings can be used by the fumigators.

In addition, Aluminum Phosphide fumigation must comply with the USAID Programmatic Environmental

Assessment (PEA) for Phosphide Fumigation of Stored

Agricultural Commodity

(http://www.usaidgems.org/fumigationpea.htm); see

Annex T-1 for guide to compliance requirements.

PESTICIDES CONSIDERED AND REJECTED BY THIS PERSUAP

Only pesticides specifically approved (i.e., appearing in the “lists of approved pesticides” above) under this PERSUAP are authorized for use in USAID/Senegal agricultural activities. The tables below document pesticides (as AIs) that were specifically considered and rejected by the analysis undertaken in this PERSUAP. This information is provided to support evaluation of future requests for amendment of this PERSUAP.

PESTICIDE EVALUATION REPORT & SAFE USE ACTION PLAN (PERSUAP) | USAID/Senegal Agricultural Activities 2015-2020 XII

Toxicological summaries and US EPA registration status for each pesticide are presented in Table B-1 in Annex B.

Table 2. PESTICIDES REGISTERED BY CILSS BUT REJECTED BY THIS PERSUAP

PESTICIDES REJECTED REASON FOR REJECTION

Aclonifen Not registered by USEPA

Alletrin, d-trans allethrin Used mostly for control of mosquitos and flies in homes and gardens

Asulam Used mostly for cane sugar

Bendiocarb Acute toxicity

Bifenthrin Most products are RUP

Bromadiolone Anti-coagulant rodenticide, RUP, certified for use only indoors

Cartap Not EPA registered

Chlorpyrifos-ethyl Most products are RUP

Cycloxidim Not registered by USEPA

Cypermethrin (zeta) High acute toxicity

Diflubenzuron RUP, all products and uses

Dimefluthrin Not registered by US EPA

Emamectin benzoate Use mostly for ornamental trees, most products are RUP

Esbiothrin Not registered by USEPA

Fenitrothion Registered for use of ornamental crops only

Haloxyfop-R-mathyl Not registered by USEPA

Hexazynone Known groundwater contaminant, some products are acute toxicity I

Isoxadifen-ethyl Not registered by USEPA

Mepiquat chloride Plant growth regulator used exclusively on cotton

Mesothrione, Most products are RUP

Metolachlor, S-Metolachlor Most products are RUP

Methomyl All methomyl products, except the 1% bait formulations, are classified as restricted use pesticides.

Oxadiargyl No US Federally registered products containing this chemical

Oxamyl Oxamyl is a “restricted use" (RUP) chemical due to acute toxicity and toxicity to birds and mammals.

Pencycuron No US Federally registered products containing this chemical

Pyribenzoxim Not registered by USEPA

Profenofos Restricted to use on cotton solely

Pretilachlor Not registered by USEPA

Propaquizafop Not registered by USEPA

Pyriproxyfen Alleged (not substantiated) link to microcephaly

Teflubenzuron Not registered by EPA

PESTICIDE EVALUATION REPORT & SAFE USE ACTION PLAN (PERSUAP) | USAID/Senegal Agricultural Activities 2015-2020 XIII

Table 2. PESTICIDES REGISTERED BY CILSS BUT REJECTED BY THIS PERSUAP

PESTICIDES REJECTED REASON FOR REJECTION

Transfluthrin No US Federally registered products containing this chemical

TABLE 3. AIs BANNED BY STOCKHOLM CONVENTION THAT ARE BANNED IN SENEGAL

PESTICIDE COMMON USES

Aldrin Used mostly on corn and cotton

Chlordane Used on agricultural crops, lawns, and gardens and as a fumigant for termite control

DDT Malaria control

Dieldrin Used mostly on corn and cotton

Dioxins (polychlorinated) Byproduct of pesticides

Endrin Pesticide used to control insects, rodents, and birds

Furan (polychlorinated) By product of pesticides

Heptachlor Used in households and

Agriculture

Hexachlorobenzene Fungicide used on seeds

Mirex Insecticide and flame retardant

Toxaphen Insecticide used primarily on cotton

TABLE 4. AIs BANNED BY THE ROTTERDAM CONVENTION THAT ARE BANNED IN

SENEGAL

HERBICIDES

2,4,5-T and its salts and esters

Alachlor

Dinitro-ortho-cresol (DNOC) and its salts

Dinoseb and its salts and ester

FUNGICIDES

Benomyl (certain formulations)

Binapacryl

Captafol

Thiram (certain formulations)

INSECTICIDE

Aldicarb https://en.wikipedia.org/wiki/2,4,5-T https://en.wikipedia.org/wiki/Alachlor https://en.wikipedia.org/wiki/Dinitro-ortho-cresol https://en.wikipedia.org/wiki/Dinoseb https://en.wikipedia.org/wiki/Benomyl https://en.wikipedia.org/wiki/Binapacryl https://en.wikipedia.org/wiki/Captafol https://en.wikipedia.org/wiki/Thiram https://en.wikipedia.org/wiki/Aldicarb

PESTICIDE EVALUATION REPORT & SAFE USE ACTION PLAN (PERSUAP) | USAID/Senegal Agricultural Activities 2015-2020 XIV

Aldrin

Carbofuran (certain formulations)

Chlordane

Chlordimeform

Chlorobenzilate

DDT

Dieldrin

1,2-dibromoethane (EDB)

Endosulfan

Hexachlorocyclohexane (mixed isomers, some are pesticides)

Heptachlor

Hexachlorobenzene

Lindane

Methamidophos (certain formulations)

Methyl parathion (certain formulations)

Monocrotophos

Parathion

Pentachlorophenol and its salts and esters

Phosphamidon (certain formulations)

Toxaphene

RODENTICIDE

Fluoroacetamide https://en.wikipedia.org/wiki/Aldrin https://en.wikipedia.org/wiki/Chlordane https://en.wikipedia.org/wiki/Chlordimeform https://en.wikipedia.org/wiki/Chlorobenzilate https://en.wikipedia.org/wiki/Dieldrin https://en.wikipedia.org/wiki/1,2-dibromoethane https://en.wikipedia.org/wiki/Endosulfan https://en.wikipedia.org/wiki/Hexachlorocyclohexane https://en.wikipedia.org/wiki/Heptachlor https://en.wikipedia.org/wiki/Hexachlorobenzene https://en.wikipedia.org/wiki/Lindane https://en.wikipedia.org/wiki/Methamidophos https://en.wikipedia.org/wiki/Methyl_parathion https://en.wikipedia.org/wiki/Monocrotophos https://en.wikipedia.org/wiki/Parathion https://en.wikipedia.org/wiki/Pentachlorophenol https://en.wikipedia.org/wiki/Phosphamidon https://en.wikipedia.org/wiki/Toxaphene https://en.wikipedia.org/wiki/Fluoroacetamide

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PESTICIDE EVALUATION REPORT & SAFE USE ACTION PLAN (PERSUAP) | USAID/Senegal Agricultural Activities 2015-2020

XVII

SENEGAL PESTICIDE EVALUATION REPORT

& SAFER USE ACTION PLAN (PERSUAP)

FOR

USAID/SENEGAL AGRICULTURAL ACTIVITIES

JULY 2016

Prepared for and submitted to:

USAID/Senegal, Dakar, Senegal.

Prepared under: The GEMS II contract (award number AID-OAA-M-13-00018)

Submitted by: The Cadmus Group, Inc.

100 Fifth Avenue, Suite 100

Waltham, MA 02451

617-673-7000 Fax 617-673-7001 www.cadmusgroup.com

DISCLAIMER

Until and unless this document is approved under the processes established by 22 CFR 216, its views are those of the author and may not represent the views of USAID or the United States Government http://www.cadmusgroup.com/

Pesticide Evaluation Report & Safe Use action Plan (PERSUAP) | USAID/Senegal Agricultural Activities xviii

Pesticide Evaluation Report & Safe Use action Plan (PERSUAP) | USAID/Senegal Agricultural Activities xix

TABLE OF CONTENTS

Executive Summary ................................................................................................................................................... iii

Acronyms.................................................................................................................................................................. xxii

Section 1: Introduction

1.1 Purpose and Scope

1.2 Regulatory Requirements, the PERSUAP concept, and Analytical Approach

1.3 Development of this PERSUAP

Section 2: Projects Covered by this PERSUAP

Section 3: Environmental Context

3.1 Priority Geographic Places/Areas of Project Intervention

3.2 Agriculture in Senegal

3.3 Pesticides and the Senegal Environment

Section 4: PER, Part 1—Pest Management Needs, Pesticides Available, and Management Capacity ... 10

4.1 Identification of Target Activities

4.2 Pest Management Needs for Target Activities

4.3 IPM Practices

4.4 Current Pesticide Use/Availability

4.5 Available Personal Protective Equipment (PPE) and Application Equipment

4.6 Pesticide Knowledge and Awareness

4.7 Agricultural Extension

4.8 List of Candidate Pesticides

Section 5: PER, Part 2—The 12-Factor Analysis

Factor A: US EPA Registration Status of the Proposed Pesticides

Factor B: Basis for Selection of Pesticides

Factor C: Extent to Which the Proposed Pesticide Use is Part of an IPM Program

Factor D: Proposed Method or Methods of Application, Including the Availability of Application and

Safety Equipment

Factor E: Any Acute and Long-Term Toxicological Hazards, either Human or Environmental, Associated with the Proposed Use, and Measures Available to Minimize Such Hazards

Pesticide Evaluation Report & Safe Use action Plan (PERSUAP) | USAID/Senegal Agricultural Activities xx

Factor F: Effectiveness of the Requested Pesticides for the Proposed Use

Factor G: Compatibility of the Proposed Pesticide use with Target and Non-Target Ecosystems

Factor H: The Conditions under which the Pesticide is to be Used, Including Climate, Flora, Fauna, Geography, Hydrology, and Soils

Factor I: The Availability and Effectiveness of other Pesticides or Non-Chemical Control Methods 34

Factor J: The Requesting Country’s Ability to Regulate or Control the Distribution, Storage, Use and

Disposal of the Requested Pesticide

Factor K: The Provisions Made for Training of Users and Applicators

Factor L: The Provisions Made for Monitoring the Use and Effectiveness of the Pesticides

Section 6: Safer Use Action Plan (SUAP)

6.1 Introduction

6.2 Allowed Pesticides

6.3 Summary of Compliance Requirements

6.4 Pesticide Safe Use Action Plan & Compliance Tracker

References and Resources

Annex A: Pests and Disease of Target Crops and Available and Recommended Control Methods ... 65

Annex B: Pesticide profiles: Toxicology

B.1 Orientation: Pesticide toxicity and risk

B.2 Summary Toxicology Profiles of Pesticides Assessed by this PERSUAP

Annex C: Mandatory Elements of Pesticide Safe Use Training

C.1 Integrated Pest Management

C.2 Understanding Pesticide Risks

C.3 Understanding Pesticide Label and Material Safety Data Sheet

C.4 Pesticide Safety and Use of Protective Clothing and Equipment

C.5 Proper Spray Technique: Protecting Against Pesticide Spray Drift

C.6 Pesticide Transport and Storage

C.7 First Aid

C.8 Proper Pesticide Container Disposal

C.9 Monitoring and Data Record Keeping

Pesticide Evaluation Report & Safe Use action Plan (PERSUAP) | USAID/Senegal Agricultural Activities xxi

TABLES

TABLE 1. PESTICIDES (AIS) APPROVED WITH CAUTIONARY ADVICE (BASED ON INFORMATIN

PROVIDED IN ANNEX B) ......................................................................................................................................................... VI TABLE 2. PESTICIDES REGISTERED BY CILSS BUT REJECTED BY THIS PERSUAP .............................................. XII TABLE 3. AIs BANNED BY STOCKHOLM CONVENTION THAT ARE BANNED IN SENEGAL ................... XIII

TABLE 4. ACTIVE INGREDIENTS (AIS) BANNED BY THE ROTTERDAM CONVENTION THAT ARE

BANNED IN SENEGAL ............................................................................................................................................................ XIII

TABLE 5. ALS REQUESTED BY FTF

TABLE 6. US EPA TOXICITY CATEGORIES

TABLE 7: SENEGAL PROTECTED AREAS:

TABLE 8. PESTICIDES (AIS) APPROVED WITH CAUTIONARY ADVICE

TABLE 9. PESTICIDES REJECTED

TABLE 10. PERSISTENT ORGANIC POLLUTANTS (POPS) BANNED BY THE STOCKHOLM

CONVENTION

TABLE 11. ACTIVE INGREDIENTS (AIs) BANNED BY ROTTERDAM CONVENTION

TABLE 12. IPM/SAFE USE REQUIREMENTS AND RELEVANT RESOURCES

TABLE 13. PERSUAP COMPLIANCE TRACKER

TABLE 14. PEARL MILLET INTEGRATED PEST MANAGEMENT PLAN

TABLE 15. RICE INTEGRATED PEST MANAGEMENT PLAN

TABLE 16. MAIZE INTEGRATED PEST MANAGEMENT PLAN

TABLE 17. US EPA REGISTRATION STATUS & TOXICOLOGICAL PROFILE OF ANALYZED PESTICIDES

TABLE 18. HANDLER PPE FOR WORKER PROTECTION STANDARD PRODUCTS

TABLE 19. PROPER METHODS TO DISPOSE OF PESTICIDES AND THEIR EMPTY CONTAINERS

TABLE 20. EXAMPLE OF MONITORING AND RECORD KEEPING CHART

FIGURES

Figure 1. Senegal Administrative Map

Figure 2. FtF Target Regions Map

Figure 3. Nataal Mbey Geographic Coverage

Figure 4: Map of Senegal

Figure 5: Senegal Soils Map

Figure 6: Senegal River Basin Map

Figure 7: Senegal Vegetation Map

Figure 8: Senegal Protected Areas

Figure 9: Senegal Agricultural Land Use

Pesticide Evaluation Report & Safe Use action Plan (PERSUAP) | USAID/Senegal Agricultural Activities xxii

ACRONYMS

AFR/WA Africa/West Africa

AI Active Ingredient

ANCAR L’Agence Nationale de Conseil Agricole et Rural

AOR/COR

BEO

Agreement Officer Representative/Contracting Officer

Representative

Bureau Environmental Officer

CDCS

CFR

Country Development Cooperation Strategy

Code of Federal Regulation

CILSS Comité permanent Inter-Etats de Lutte contre la Sécheresse dans le

Sahel

CNCR

COMFISH

National Council for Rural Co-operation

Collaborative Management for a Sustainable Fisheries Future

CORAF/WECARD West and Central African Council for Agricultural Research and

Development

CSP Sahelian Pesticide Committee

DO

DPV

ECD

EGO

Development Objective

La Direction de la Protection des Végétaux

Environmental Compliance Database

Economic Growth Office

EMMP

ERA

Environmental Mitigation and Monitoring Plan

Education and Research in Agriculture

FAO Food and Agriculture Organization

FIFRA

FtF

GDP

GEMS

GoS

GUP

Federal Insecticide, Fungicide and Rodenticide Act

Feed the Future

Gross Domestic Product

Global Environmental Management Support

Government of Senegal

General Use Pesticides

IEE Initial Environmental Examination

IFAD International Fund for Agricultural Development

INSAH

IP

Institut du Sahel

Implementing Partner

IPM Integrated Pest Management

ISO

ISRA

ITCZ

International Standards Organization

Institut Sénégalais de Recherches Agricoles

Inter-Tropical Convergence Zone

MAB

MAER

MEO

Man and the Biosphere

Ministry of Agriculture and Rural Equipment

Mission Environmental Officer

Pesticide Evaluation Report & Safe Use action Plan (PERSUAP) | USAID/Senegal Agricultural Activities xxiii

MoA Ministry of Agriculture

MoE Ministry of Environment

MoH Ministry of Health

MRL Maximum Residue Level

MSDS Material Safety Data Sheet

NARS

NGO

National Agricultural Research Systems

Non-Governmental Organization

PCE Project Croissance Economique

PER Pesticide Evaluation Report

PERSUAP Pesticide Evaluation Report and Safe Use Action Plan

PHI Pre-Harvest Interval

PIC Prior Informed Consent

PMP Pest Management Plan

POPs Persistent Organic Pollutants

PPE Personal Protective Equipment

REO Regional Environmental Officer

REI Restricted Entry Interval

RUP

SFZ

SPRING

SRV

Restricted Use Pesticide

Southern Forest Zone

Strengthening Partnerships, Results, and Innovations in Nutrition

Globally

Senegal River Valley

SUAP

ULV

UNESCO

Safe Use Action Plan

Ultra Low Volume

United Nations Educational, Scientific and Cultural Organization

USAID United States Agency for International Development

US EPA

USGS

United States Environmental Protection Agency

US Geographic Services

WHO World Health Organization

WN Wula Nafaa

WP Wettable Powder

Pesticide Evaluation Report & Safe Use action Plan (PERSUAP) | USAID/Senegal Agricultural Activities 1

SECTION 1: INTRODUCTION

1.1 PURPOSE AND SCOPE

In compliance with USAID’s Pesticide Procedures (under

22 Code of Federal Regulations (CFR) 216.3(b)), this

2015 Senegal Feed the Future (FtF) agricultural portfolio

Pesticide Evaluation Report and Safer Use Action Plan

(PERSUAP):

Establishes the set of pesticides for which support is authorized on USAID/Senegal agricultural programmatic activities.

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

These requirements come into effect upon approval of the PERSUAP.

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

216.3(b).

The Safer Use Action Plan (SUAP) in Section 6 provides a succinct, stand-alone statement of compliance requirements, synthesized from the 12-factor analysis. It also provides a template for assigning responsibilities and timelines for implementation of these requirements. Each project subject to this PERSUAP must complete this

SUAP template and submit to its Agreement Officer

Representative/Contracting Officer Representative

(AOR/COR), Deputy Mission Environmental Officer

(DMEO) and Mission Environmental Officer (MEO).

1.2 REGULATORY REQUIREMENTS, THE PERSUAP CONCEPT,

AND ANALYTICAL APPROACH

REGULATORY REQUIREMENTS ATTENDANT TO USAID-FUNDED SUPPORT FOR

PESTICIDES

All USAID-funded activities are subject to pre-implementation environmental review, starting with a screening process that determines the level of potential environmental risk. Activities considered as

BOX 1.

The 12 Pesticide ANALYSIS FACTORS

A. U.S. Environmental Protection Agency (US

EPA) registration status of the proposed pesticides

B. Basis for selection of pesticides

C. Extent to which the proposed pesticide use is part of an IPM program

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

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

F. Effectiveness of the requested pesticide for the proposed use

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

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

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

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

K. Provision for training of users and applicator

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

Pesticide Evaluation Report & Safe Use action Plan (PERSUAP) | USAID/Senegal Agricultural Activities 2 having moderate or unknown risks are subject to an Initial Environmental Examination (IEE). USAID’s pre-implementation environmental review procedures are defined by 22 CFR 216.

If USAID funds are to be used to procure, directly fund or support the use of pesticides, 22 CFR 216.3(b) requires that 12 factors be analyzed as the basis for approving the use of any pesticides, and as the basis for establishing the requirements attendant to that use to control risks to human health and the environment (see Box 1).5 The PER analyzes the 12 factors and SUAP establishes the attendant requirements or conditions for USAID-supported activities.

Pesticides are agents used to kill or control any pest, including insects, rodents or birds, unwanted plants

(weeds), fungi, or microorganisms such as bacteria and viruses. Though often misunderstood to refer only to insecticides, the term pesticide also applies to herbicides, fungicides, micro-biocides, rodenticides, and various other substances used to control pests.6 Pesticides are by design poisons, and their use entails a degree of risk to the environment including humans, animals, birds, fish, bees, and other living organisms.

USAID POLICY: INTEGRATED PEST MANAGEMENT

Since the early 1990s USAID has been committed to the philosophy and practice of IPM as official policy. There is not a single standard international definition for IPM, but there is wide agreement on its basic elements. Under IPM:

“First line” defenses against pest damage are a combination of techniques such as biological control, habitat manipulation, modification of cultural practices, and use of resistant varieties.

Pesticides are used only after monitoring indicates they are needed according to established guidelines, and treatments are made with the goal of removing only the target organism.

Pest control materials are selected and applied in a manner that minimizes risks to human health, beneficial and non-target organisms, and the environment.

IPM is strongly promoted as part of 22 CFR 216.3 Factor C.

THE PERSUAP

The USAID Africa Bureau initially developed the PERSUAP framework for pesticide compliance; the

PERSUAP was subsequently adopted by other USAID Bureaus. Formally the PERSUAP constitutes an amendment to a program’s or project’s IEE, to address the requirements of 22 CFR 216.3(b) with particular emphasis on assuring that pesticide use occurs within an IPM framework.

A PERSUAP consists of two core parts, a PER and a SUAP. The PER characterizes pest management needs for the subject USAID projects, the availability of pesticides, the level of pesticide awareness among potential beneficiaries, and the critical local context. This information then informs the assessment of the 12 pesticide risk evaluation factors (a through l, see box above) required by 22 CFR 216.3(b). The

PER thereby establishes the set of authorized pesticides and requirements for Safer Use.

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

6 "Types of Pesticides" About Pesticides. 05 Aug 2014. United States Environmental Protection Agency. 09 Aug 2015 http://www.epa.gov/pesticides/about/types.htm.

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

Pesticide Evaluation Report & Safe Use action Plan (PERSUAP) | USAID/Senegal Agricultural Activities 3

The SUAP (Section 6) provides a succinct, stand-alone statement of compliance requirements, synthesized from the 12-factor analysis. It also provides a template for assigning responsibilities and timelines for implementation of these requirements.

Each project subject to this PERSUAP must complete this SUAP template (found in Section 6.4) and submit to its AOR/COR, DMEO and MEO at the date specified by the MEO.

USAID/SENEGAL PEST MANAGEMENT NEEDS FOR AGRICULTURAL PROJECTS

This PERSUAP addresses the pesticide safer use and handling issues for activities under USAID/Senegal

CDCS DO 1. Under this strategy, the agricultural activities in key value chains are part of the latest in the series of investments under the FtF program. These USAID/Senegal investments provide technical assistance, training, materials, and other resources to improve food security through professionalization, strengthened agricultural production and market systems, improved access to finance, and rational management of natural resources under strong governance.

The assessment of “pesticide and pest management local context” that begins with the PER is a key feature of the PERSUAP approach. This assessment is needed because it provides essential input to the

12-factor analysis. The purpose of the 12-factor analysis is to select appropriate pesticides and safe use measures. This approach requires taking into consideration the context in which the products will be used, the particular elements of the program, and the different capacities of the partners and stakeholders involved.

1.3 DEVELOPMENT OF THIS PERSUAP

USAID/Senegal and its Implementing Partners (IPs) are currently implementing the FtF Naatal Mbay

("Flourishing Agriculture" in the Wolof language), Nutrition Led Agriculture Project Yaajeende, Education and Research in Agriculture Project (ERA), Collaborative Management for a Sustainable

Fisheries Future (COMFISH) Fisheries Project, and Strengthening Partnerships, Results, and Innovations in Nutrition Globally (SPRING) – Scaling Up Nutrition-Led Agriculture in Senegal. The “parent” IEE which this PERSUAP responds to is USAID Senegal’s Food Security and Natural Resource

Management IEE (Senegal_Food Security (DOCX) (PDF)7 was approved 04/22/2016.

While this PERSUAP is developed primarily to address the needs of these projects activities, it is envisioned to serve as a base for the needs of future agricultural projects. This PERSUAP is also meant to serve other possible future projects, including those that may support agricultural activities via grants or sub-grants.

This PERSUAP is developed based on the format developed by the core Global Environmental

Management Support (GEMS) team and draws from other documents developed for Senegal, such as the

PERSUAP developed for Projet Croissance Economique (PCE) and for Wula Nafaa (WN) projects.

Activities of the West and Central African Council for Agricultural Research and Development

(CORAF/WECARD) coordinated by FtF that are implemented by member National Agricultural

Research Systems (NARS) in West Africa, are covered by a separate PERSUAP developed in 2014 for

Activities Number #: 624-A-00-09-0037-00 and # 624-A-12-00007-00.

Regional West Africa activities are covered by the West Africa Regional Programmatic PERSUAP (P-

PERSUAP) Covering Nine Target Countries (including Senegal) with USAID West Africa Programs

7 http://gemini.info.usaid.gov/repository/doc/47126.docx javascript:%20f_open_document(47126);

http://gemini.info.usaid.gov/repository/doc/47126.docx http://gemini.info.usaid.gov/repository/pdf/47126.pdf http://gemini.info.usaid.gov/repository/doc/47126.docx

Pesticide Evaluation Report & Safe Use action Plan (PERSUAP) | USAID/Senegal Agricultural Activities 4 developed in 2014 on Purchase Order AID-624-O-14-000003 and can be found on the Environmental

Compliance Database (ECD) http://gemini.info.usaid.gov/egat/envcomp/repository/pdf/42966.pdf

Currently, USAID/Senegal funded projects determined to include pesticide procurement, use, or support to procurement or use include only FtF Senegal Naatal Mbay Cereal Value Chain activity and SPRING.

If other projects and activities have pesticide procurement or use needs that are not covered by this or

NARS activities PERSUAP, an Amendment to the this PERSUAP analyzing and approving the new pesticide active ingredient (AI) must be prepared and approved by the Office of West African Affairs

(AFR/WA) Bureau Environmental Officer (BEO) before that new pesticide may be procured, used, or promoted in FtF programs in Senegal.

The PERSUAP development is based on analyzing and characterizing the AIs of the subject pesticides with respect to: chemical class, Senegal registration status, US EPA registration, Restricted Use Pesticide

(RUP) status, European Union (EU) registration status, World Health Organization (WHO) and US EPA acute human toxicity classifications, chronic human health issues, groundwater pollution potential, and eco-toxicity to different classes of organisms. This phase also includes identification of potential IPM measures for specific pest-crop combinations, as recommended by international agricultural research centers and similar sources.

This PERSUAP reviews pesticides to be used for main production crops identified by USAID/Senegal.

The PERSUAP examines and determines whether each pesticide (i.e., Active Ingredients (AI)) is appropriate for USAID-supported activities.

The criteria for approval of pesticide use (broadly defined) for USAID support include:

Pesticide (AI and product) must be registered in Senegal;

Active ingredients must be registered by US EPA for same or similar use; and

Similar product containing this active ingredient(s) must be registered in the U.S.

Additional conditions apply to use of pesticides by smallholder farmers: RUPs and pesticides with US

EPA acute toxicity risk Classification I are not approved for use by smallholder farmers in Senegal. These pesticides can be used only by trained and registered pest control professionals and/or trained agricultural specialists. Training and certification must be recognized by the Senegalese government authorities.

SECTION 2: PROJECTS THAT WERE THE BASIS OF THIS

PERSUAP DEVELOPMENT

This PERSUAP was developed based on pest management and control needs of the following active projects:

Program/Activity: Nataal Mbay (Flourishing Agriculture)

Implementing Partner: Engility

Time Period of Implementation: 2015 – 2020

Basic objectives/Purpose: The Nataal Mbay project aims to strengthen and improve agricultural production, natural resource management and marketing in key agricultural value chains. Among other activities, Naatal Mbay supports the wide dissemination of technologies and best practices successfully introduced by its predecessor USAID/PCE (Economic Growth Project) so that they benefit a larger number of producers in the rice, corn and millet value chains.

http://gemini.info.usaid.gov/egat/envcomp/repository/pdf/42966.pdf

Pesticide Evaluation Report & Safe Use action Plan (PERSUAP) | USAID/Senegal Agricultural Activities 5

The project interventions include: Production of irrigated rice in the Senegal River Valley; millet, maize and some rain-fed rice in the center-south peanut basin zone; and rain-fed rice and maize in Casamance (forming what is called South Forest Zone with the center/south peanut basin).

Program/Activity: SPRING

Implementing Partner: John Snow Inc. (JSI)

Time Period of Implementation: 2015 – 2020

Basic objectives/Purpose: SPRING work on Senegal aims to deliver nutrition specific and nutrition sensitive agriculture interventions.