PESTICIDE EVALUATION REPORT AND SAFER USE ACTION PLAN (PERSUAP) FOR USAID/GDL-FUNDED COTTON ACTIVITIES IN FOUR TARGET COUNTRIES

IMPLEMENTED BY THE BETTER COTTON INITIATIVE

APRIL-JUNE, 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.

FRONT COVER: Cotton production in Pakistan and Senegal Photo credit Sources: pakagrifarming.blogspot.com and www.thetimes.co.uk

USAID GLOBAL DEVELOPMENT LABORATORY (GDL)

INITIAL ENVIRONMENTAL EXAMINATION (IEE) ATTACHMENT

PESTICIDE EVALUATION REPORT AND SAFER USE ACTION PLAN (PERSUAP)

For USAID/GDL-Funded Cotton Activities in Four Target Countries

Implemented by the Better Cotton Initiative

PROJECT NAME: USAID/GDL Better Cotton Initiative (BCI)

REGION/COUNTRY: Africa: Mozambique, Senegal

Asia: India, Pakistan

PROGRAM/ACTIVITY NUMBER: ____________________

PROGRAM/ACTIVITY TITLE: Economic Opportunities Increased

ASSISTANCE OBJECTIVE: Economic Growth (EG)

PROGRAM AREA: Agriculture

IEE AMENDMENT: Yes

IEE FILENAME/DATE: Initial Environmental Examination (IEE) for USAID funding to the Better Cotton Initiative: Improving Livelihoods and Economic Development in Cotton‐Producing Areas / August 5, 2016

PREPARED BY: Alan Schroeder, PhD, MBA, Environmental Compliance Specialist

Ashley Fox, CADMUS GEMS

USAID GDL Clearance: Daniel M. Evans, PhD, Environmental Protection Specialist and Bureau Environmental Officer

BCI IMPLEMENTATION START: September 2016

BCI LOP AMOUNT: $1,000,000

BCI IMPLEMENTATION END: September 2019

ENVIRONMENTAL ACTIONS RECOMMENDED: (Place X where applicable)

Categorical Exclusion: ____ Negative Determination with Conditions: _X _

Positive Determination: ____ Deferral: ____

ADDITIONAL ELEMENTS: (Place X where applicable)

CONDITIONS: _X_ SUAP: X PVO/NGO: ___

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EXECUTIVE SUMMARY

The US Global Development Lab (USAID/GDL) brings together a diverse set of partners to discover, test, and scale breakthrough solutions to achieve human progress. Launched on April 3, 2014, USAID/GDL seeks to increase the application of science, technology, innovation, and partnerships to accelerate the Agency’s development impact in helping to end extreme poverty. The Lab does this by working closely with colleagues across the Agency and by bringing together a diverse set of partners to find innovations, tools, and approaches to solve development challenges more effectively and sustainably. The Lab serves as a central hub for shared learning on science, technology, innovation and partnerships and works across USAID and with international partners to mainstream proven solutions to reach global impact.

The USAID/GDL is providing support to the Better Cotton Initiative (BCI) for establishment and management of country-level programs to produce 'Better Cotton'. BCI works with strategic and implementation partners in a number of cotton producing countries. Currently, USAID supports BCI in India, Mozambique, Pakistan, and Senegal.

The Better Cotton Initiative (BCI) is a private, non-governmental, not-for-profit membership association whose long-term objective is to promote best farming practices, high quality products and managerial responsibility, while minimizing the use of agrochemical products and protecting workers’ rights through a participatory stakeholder approach. BCI exists in order to respond to the current impacts of cotton production worldwide. BCI aims to promote measurable improvements in key environmental and social impacts of cotton cultivation worldwide to make it more economically, environmentally, and socially sustainable.

Use of pesticides in cotton production. Cotton represents nearly half the fiber used to make clothes and other textiles worldwide. Pesticides and similar chemicals are heavily used in cotton production; this poses risks to human health and the environment, including severe health impacts on agricultural field workers and significant impacts on ecosystems that receive run-off from farms.

BCI production principles include a focus on Integrated Pest Management (IPM). BCI promotes non-chemical preventive tools and tactics for management of serious pests and diseases of cotton. BCI also promotes rational pesticide choice and use decisions by its cotton farmer clients, and BCI analyses pesticides used by their farmer clients in specific target countries. To promote and establish its approach to better cotton production, BCI does much of its work through local national counterpart implementing partner (IP) sub-grantee experts in its target countries.

PERSUAP REQUIREMENTS

BCI’s policy commitment to IPM and safer use of pesticides are generally consistent with the goals of 22 CFR 216 (Regulation 216). However, multiple aspects of BCI’s approach to pesticide use and the implementation of these commitments are less stringent than requirements established by Regulation 216. Therefore, this PERSUAP is designed to better address pesticide risks in the cotton sector, to assist in evaluating and selecting appropriate pesticides for farms of different sizes, and to develop strong IPM plans and a Safer Use Action Plan for BCI’s target countries. As such, this PERSUAP serves as a model for IPs to support the consistent treatment of pesticides across IPs and BCI target geographies.

PERSUAP intent. USAID-funded or managed activities that provide assistance for the procurement or use of pesticides must comply with the Agency’s pesticide procedures, 22 CFR 216.3(b). Accordingly, this Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP):

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• Establishes the set of pesticides for which procurement, use, or support for use is authorized for agricultural activities supported by USAID/GDL.

• Establishes the conditions under which the authorized pesticides may be procured, used, or their use supported to best ensure environmental safety and safety for users and consumers.

The requirements of this PERSUAP come into effect upon its approval. This PERSUAP:

• Is a part of the environmental compliance (EC) process addressed by the Initial Environmental Examination (IEE) for USAID funding to the Better Cotton Initiative: Improving Livelihoods and Economic Development in Cotton‐Producing Areas.

• Is as an attachment to the IEE that guides best practices for cotton production and pesticide use. • Implements the Regulation 216 procedures and analyses, with a strong focus on IPM, and puts them into an

action plan format.

Active Ingredients (AI) analysis. This PERSUAP analyzes AIs in all pesticide products that BCI farmers and other stakeholders are known to use in the four target countries (India, Mozambique, Pakistan, and Senegal). It establishes whether these AIs are registered by the US Environmental Protection Agency (USEPA) and in the country of their use for cotton. It also evaluates the prevalence of the AIs in products that the USEAP classifies as Restricted Use Products (RUP) because they pose heightened risks to humans and the environment.

This PERSUAP rejects pesticide AIs that:

• Are not registered by USEPA • Are in products that the USEPA classifies as RUP • Are found on international lists of banned or severely restricted pesticides, e.g., pesticides banned by the

Rotterdam and Stockholm conventions • Are found by USEPA to be known carcinogens because BCI cannot guarantee that smallholder farmers in its

network will use the necessary safety equipment

This PERSUAP accepts only pesticide AIs that have passed these analyses and screening procedures. Those pesticide AIs are listed below so that BCI, its national IPs, USAID Agreement/Contracting Officer’s Representatives (A/CORs), and environmental officers (EOs) understand clearly which may be promoted or used on USAID-supported activities.

Geographic focus. Because this PERSUAP includes the required analysis for potential activities across four countries (India, Mozambique, Pakistan, and Senegal), some level of generalization is necessary. The PERSUAP is intended to be supplemented with more country-specific information, as desired by Award/Contract Officer Representatives (A/CORs), the four country Mission Environmental Officers (MEOs), the USAID/GDL Bureau Environmental Officer (BEO), and/or the Bureau Environmental Officers (BEOs) in the Bureaus for Africa or Asia.

STRUCTURE OF THIS PERSUAP

Sections 1 and 2 provide an introduction to the PERSUAP purpose and scope and pesticide management needs of cotton production activities supported by USAID/GDL.

Section 3 gives a brief account of the environmental context in the four focal countries (India, Mozambique, Pakistan, and Senegal), including a discussion of relevant agricultural and cotton production practices and the countries’ approaches to environmental protection and pesticide regulation.

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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) provided in Section 6.

The Safer Use Action Plan (SUAP; Section 7) provides a succinct, definitive, stand-alone statement of compliance requirements, synthesized from the 12-factor analysis. It also provides a template (sub-section 7.4) 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 A/COR and BEO for approval.

Annexes: The PERSUAP Annexes provide a set of tools for SUAP implementation.

Annexes 1, 2, and 3. In keeping with USAID’s policy and promotion of Integrated Pest Management (IPM), this document analyzes the preventive non-chemical IPM tools and tactics promoted by BCI and by national programs in the target countries. It also analyzes the preventive non-chemical IPM tools and tactics promoted for the same pests and diseases in other countries. To provide BCI and national IP sub-grantees with guidance for the development of recommended detailed pest management plans (PMPs) for each specific pest or disease, this PERSUAP compiles and presents best practices information in Annex 1. Annexes 2 and 3 provide IPM guidelines and describe PMP elements and IPM program implementation recommendations, respectively.

Annex 4 lists pesticides used by BCI in target countries and Annex 5 analyzes their toxicity to humans and their ecotoxicology. Subsequently, Annex 6 lists pesticides rejected by this analysis, with the reason(s) they are rejected.

Annex 7 lists recommended training topics in Safer Use of Pesticides.

Other SUAP tools for this PERSUAP can be found on the GEMS website: www.usaidgems.org

SAFER USE ACTION PLAN CONDITIONS

Approved pesticide AIs. Upon approval of this PERSUAP, the below-listed pesticide active ingredients (AIs) are permitted for use/support/promotion with USAID/GDL funds on BCI activities in the four target countries. This approval is subject to compliance with general conditions including no acute toxicity Class I products, no RUP products, following the pesticide container label and MSDS precautions, using appropriate Personal Protection Equipment (PPE), and any additional conditions listed for each AI in the Table below. BCI beneficiary cotton farmers in the four target countries are known to use the approved AIs listed below. The list is organized by type of pesticide (insecticides/miticides; herbicides/plant growth regulators (PGRs)/defoliants/desiccants; and fungicides).

INSECTICIDE AND MITICIDE AIS APPROVED

CONDITIONS/CAUTIONS (IN ADDITION TO FOLLOWING LABEL AND MSDS PRECAUTIONS, AND USING PPE)

• Abamectin • Only products with < 2% Active Ingredient are allowed

• acephate •

• Acetamiprid • Recommended for use as a seed treatment only; not during vegetative growth and not during flowering

• Bacillus thuringiensis/BT •

• beta-cyfluthrin • Only products with < 10% Active Ingredient are allowed

• beta-cypermethrin • Use all but 2.5 Emulsifiable Concentrate formulations

• Bifenthrin • Use only 10% Emulsifiable Concentrate and 2.5% Ultra-low-volume formulations

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• Buprofezin •

• Carbaryl •

• chlorantraniliprole •

• Cyfluthrin • Only products with < 10% Active Ingredient are allowed

• Diflubenzuron • Only products with < 25% Active Ingredient are allowed

• Dimethoate •

• Dinotefuran • Recommended for use as a seed treatment only; not during vegetative growth and not during flowering

• Esfenvalerate •

• etoxazole miticide/insecitide •

• Fenpyroximate •

• Flubendiamide •

• hexythiazox miticide •

• Imidacloprid • Recommended for use as a seed treatment only; not during vegetative growth and not during flowering

• indoxacarb, S isomer •

• lambda-cyhalothrin • Only products with < 10% Active Ingredient are allowed

• Malathion •

• methoxyfenozide •

• neem oil •

• Novaluron •

• Pyriproxyfen •

• Spinosad •

• Spiromesifen •

• sulfur miticide •

• Thiamethoxam • Recommended for use as a seed treatment only; not during vegetative growth and not during flowering

HERBICIDE, PLANT GROWTH REGULATOR (PGR), DEFOLIANTS AND DESICCANT AIS APPROVED

CONDITIONS/CAUTIONS

• 1-naphthylacetic acid (NAA) •

• chlormequat chloride •

• Cyclanilide •

• Ethephon •

• Fluometuron •

• Glyphosate •

• mepiquat chloride •

• Metolachlor • Keep away from water and groundwater sources

• Pendimethalin •

• Prometryn •

• pyrithiobac/pyrothiobac-sodium •

• quizalofop/quizalfop-p-ethyl •

• quizalofop-p-tefuryl •

• s-metolachlor • Keep away from water and groundwater sources

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• Thidiazuron •

• trifloxysulfuron (sodium) •

• Trifluralin •

FUNGICIDE AIS APPROVED

CONDITIONS/CAUTIONS

• Azoxystrobin •

• Difenoconazole •

• Mancozeb •

• Pyraclostrobin •

• Sulfur •

• Tebuconazole •

• Thiram •

Rejected pesticides. AIs rejected by this PERSUAP are listed in Annex 6 of this document. Reasons for each rejection are also listed in Annex 6. Low-risk AIs not requiring approval under this PERSUAP. Note that some particularly low-risk AIs (primarily essential oils and other plant extracts) are exempt from regulation under the US Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and therefore may 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 pesticide Inert Ingredients that are exempt from FIFRA is available at:

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

General conditions. This PERSUAP articulates the mitigating conditions of the BCI Initial Environmental Examination (IEE) Negative Determination regarding the potential use of pesticides, following 22CFR 216.3 (b) Pesticide Procedures. This PERSUAP will closely inform the technical assistance and capacity building for BCI USAID/GDL supported activities, as well as any partners/sub-grantees, and beneficiaries.

This PERSUAP establishes requirements for safer pesticide use (SPU), particularly the support and use of personal protection equipment (PPE) by any and all pesticide trainers, promoters, and users. Additionally, the PERSUAP identifies country-level requirements within the framework of a Safer Use Action Plan (SUAP). These and other conditions recommended in the body of this PERSUAP are highlighted and summarized below. They are conditions of the award from USAID to BCI:

1. Only pesticides approved by this PERSUAP (listed above) can be supported by USAID-funded BCI activities. BCI will promote only pesticides with AIs approved by this PERSUAP.

2. BCI USAID-funded activities must not support AIs rejected by this PERSUAP (Annex 6).

3. BCI should continue to promote Good Agricultural Practices (GAPs) and develop PMPs (see Annex 2) using recommended preventive IPM tools and tactics provided in Annex 1. BCI, as part of its mandate, will continue to promote the use of state-of-the-art crop production plans as well as expand and adapt Integrated Pest Management (IPM) plans included in Annex 1. BCI should develop more extensive and detailed PMPs that address major pests of cotton and preventive non-chemical IPM tools/tactics

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recommended to be used before using PERSUAP-approved pesticides. These pesticides should be used only as the last resort after all preventive tools have been exhausted.

4. BCI should take necessary steps to prevent the development of pest resistance by using and/or promoting tools recommended by this PERSUAP (in PER, Section 5, Factor F) such as rotating among different classes of each type of pesticide and monitoring and record keeping for detecting development of resistance.

5. Requirement for SPU Training. BCI Implementing Partner (IP) staff and beneficiaries who address pesticides through use of training materials, during training, and on demo trials, should promote Safe Pesticide Use (SPU) through explaining pesticide risks, promotion of pesticide best practices, and safety use training. Training should include all topics listed in Annex 7.

6. To the greatest degree practicable, pesticide-related activities that BCI supports and USAID funds must require use & maintenance of appropriate Personal Protection Equipment (PPE) – as well as safe pesticide purchase, transportation, handling, storage, and disposal practices

7. Flow down requirements. Prime contractors must write pesticide compliance requirements as set out above into each grant or sub-contract that will involve support for pesticide use, and sub-contractors or grantees will be responsible for reporting on risk and risk reduction to the IP.

In addition, it is recommended that BCI include the following activities in their programs:

Promoting professional and certified pest control services. BCI should promote and support the concept and use of farmer-cooperative or private-sector fee-based pesticide spray services that have well trained spray personnel protected with appropriate PPE.

Promoting Empty Pesticide Container (EPC) Recycling. BCI should promote and support the concept and use of EPC best practices, including triple rinsing after last use, puncturing to prevent re-use, return to collection sites, and recycling into agriculture plastics approved by the Government of the four target countries.

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Clearances:

GDL BEO ________________________________ Date _________________ Daniel M. Evans

AFR BEO ________________________________ Date _________________ Brian Hirsch

India MEO ________________________________ Date _________________ Monali Zeya Hazra

Mozambique MEO __________________________ Date _________________ Eduardo Langa

Pakistan MEO ______________________________ Date _________________ Howard Batson

Senegal MEO ______________________________ Date _________________ Abdourahmane Ndiaye

Cleared via email

Cleared via email

Cleared via email

Cleared via email

11/17/2016

11/17/2016

11/16/2016

11/23/2016

11/18/2016

11/18/2016

Cleared via email 11/17/2016

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2016 BETTER COTTON INITIATIVE

PROGRAMMATIC PESTICIDE EVALUATION REPORT AND SAFER USE ACTION PLAN Covering the following four countries receiving USAID/GDL assistance with cotton:

India

Mozambique

Pakistan

Senegal

August 2016

Prepared by:

Alan Schroeder, PhD, MBA

Social and Agricultural Entrepreneur

Environmental Compliance Specialist

E-NoeTec Consulting

703-859-1676

alanschroeder99@gmail.com

Ashley Fox

CADMUS/GEMS

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ACRONYMS AI Active Ingredient (reference to chemical/s in pesticides)

A/COR Agreement/Contracting Officer’s Representative (USAID)

BCI Better Cotton Initiative

BEO Bureau Environmental Officer (USAID)

BMP Best Management Practice

BT Bacillus thuringiensis (a bacteria that produces a toxin that is used as a pesticide)

CABI Commonwealth Agriculture Bureau International (UK)

CATERP Comité de Avaliação Técnica do Registo de Pesticidas (Mozambique)

CCD Colony Collapse Disorder

CFR Code of Federal Regulations (USA)

CGIAR Consultative Group for International Agriculture Research

CIBRC Central Insecticides Board and Registration Committee (India)

CLI Crop Life International (private sector pesticide companies’ trade association)

CMV Cassava Mosaic Virus

COP Chief of Party (USAID)

DAP Diammonium Phosphate

DCN Document Number (USAID documentation system)

DGIS Netherlands Ministry of Foreign Affairs (Dutch acronym)

DRC Democratic Republic of Congo

EA Environmental Assessment (USAID)

EC Emulsifiable Concentrate (pesticide formulation)

EC Environmental Compliance

EC50 Effective Concentration 50 (acute toxicity measure)

EDPRS Economic Development and Poverty Reduction Strategy

EG/A Economic Growth/Agriculture

EIA Environmental Impact Assessment

EMMP Environmental Mitigation and Monitoring Plan (USAID)

EPA Environmental Protection Agency (USA, also known as USEPA)

EPC Empty Pesticide Container

EPS/EO Environmental Protection Specialist and Environmental Officer (USAID/GDL)

ERC Environmental Review and Assessment Checklist

ETOA Environmental Threats and Opportunities Analysis

EU European Union

EW Emulsion in Water (pesticide formulation)

FAA Foreign Assistance Act

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FAO Food and Agriculture Organization (United Nations)

FDA Food and Drug Administration (USA)

FFB Farmer Field Book

FFS Farmer Field Schools

FIFRA Federal Insecticide, Fungicide and Rodenticide Act (USA)

FLO Fair Trade Labeling Organization

FRAC Fungicide Resistance Action Committee

FSSAI Food Safety and Standards Authority of India

G Granular (a pesticide formulation)

GAP Good Agriculture Practice

GDL Global Development Lab (USAID)

GDP Gross Domestic Product

GEF Global Environment Facility (part of World Bank)

GIZ Gesellschaft für Internationale Zusammenarbeit (German International Coop.)

GlobalGAP Global Good Agriculture Practices, a certification system

GMO Genetically Modified Organism

GUP General Use Pesticide

Ha Hectares

HACCP Hazard Analysis and Critical Control Points (processing standards system)

HRAC Herbicide Resistance Action Committee

HT Highly Toxic

ID Identification

IEE Initial Environmental Examination (USAID)

IFAD International Fund for Agriculture Development

IFDC International Fertilizer Development Center

IGR Insect Growth Regulator (type of pesticide)

IIAM Agricultural Investigation Institute (Mozambique)

IP Implementing Partner

IPM integrated pest management

IRAC Insecticide Resistance Action Committee

IRS Indoor Residual Spraying

IVM Integrated Vector Management

LC50 Lethal Concentration 50 (acute toxicity measure)

LDC Lesser Developed Country

LD50 Lethal Dose 50 (acute toxicity measure)

LOP Life of Project

MAF mean annual flow (hydrology)

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M&E Monitoring and Evaluation

MEO Mission Environmental Officer (USAID)

MISAU Ministry of Health (Mozambique)

MITADER Ministry of Land, Environment, and Rural Development (Mozambique)

MOA Ministries of Agriculture

MOE Ministries of Environment

MOH Ministries of Health

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 (USA)

NEPA National Environmental Policy Act (USA)

NGO Non-Governmental Organization

NIFA National Institute of Food and Agriculture (USA)

NIP National Implementation Plan (POPs Treaty Element)

OD Oil Dispersion (a pesticide formulation)

OECD Organization for Economic Cooperation and Development

OPV Open Pollinated Variety (crop seed)

PAN Pesticide Action Network (pesticide NGO)

PEA Programmatic Environmental Assessment

PER Pesticide Evaluation Report

PERSUAP Pesticide Evaluation Report and Safer Use Action Plan

PPERSUAP Programmatic PERSUAP

PGR Plant Growth Regulator

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)

PMI Presidential Malaria Initiative (USAID and CDC collaboration)

PMP Pest Management Plan

PNT Practically Non-Toxic

PPE Personal Protection Equipment

R&D toxin Reproductive and Developmental toxin

Reg 216 Regulation 216 (USAID Environmental Procedures under 22 CFR 216.3 (b))

REI Re-Entry Interval (safety period after pesticide spraying)

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RRCA Agrochemicals Registration and Control Department (Mozambique)

RUP Restricted Use Pesticide

S&C Standards and Certification

SC Suspension Concentrate (a pesticide formulation)

SEA Strategic Environmental Assessment (European Development Fund)

SL Soluble Liquid (a pesticide formulation)

SO Strategic Objective

SOW Scope of Work

SPU Safe Pesticide Use

ST Slightly Toxic

SUAP Safe Use Action Plan

TDS total dissolved solids (hydrology)

UC University of California

UN United Nations

UNEP UN Environment Program

UNFAO UN Food and Agriculture Organization (also known as FAO)

US United States

USAID US Agency for International Development

USDA US Department of Agriculture

USEPA US Environmental Protection Agency (also known as EPA)

VHT Very Highly Toxic

WB World Bank

WG Water Dispersible Granule (a pesticide formulation, prior name WDG)

WHO World Health Organization (United Nations)

WP Wettable Powder (a pesticide formulation, usually for fungicides)

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TABLE OF CONTENTS EXECUTIVE SUMMARY .................................................................................................................................................................. 4

ACRONYMS ..................................................................................................................................................................................... 12

TABLE OF CONTENTS ................................................................................................................................................................ 16

1. INTRODUCTION .................................................................................................................................................................. 17

2. USAID PESTICIDE PROCEDURES ..................................................................................................................................... 18

3. BCI BACKGROUND INFORMATION ............................................................................................................................. 20

4. ENVIRONMENTAL BACKGROUND FOR INDIA, MOZAMBIQUE, PAKISTAN, SENEGAL ............................ 24

5. COTTON PESTICIDE USE RISK ANALYSIS ................................................................................................................... 42

6. SECTION 6: THE PESTICIDE EVALUATION REPORT 12 FACTOR ANALYSIS .................................................. 47

7. BCI’S PESTICIDE SAFER USE ACTION PLAN (SUAP) ................................................................................................. 61

ANNEX 1: TARGET COUNTRY COTTON PESTS, DISEASES, PREVENTIVE & CURATIVE IPM TOOLS ............. 73

ANNEX 2: GUIDELINES FOR PMPS FOR COTTON BENEFICIARIES ............................................................................. 79

ANNEX 3: ELEMENTS OF IPM PROGRAM ............................................................................................................................. 83

ANNEX 4: PESTICIDE AIS PROPOSED FOR PERSUAP ANALYSIS: PESTICIDE ACTIVE INGREDIENTS USED BY BCI FARMERS IN 2014 COTTON PRODUCTION, AS ANALYZED BY BCI ................................................................. 87

ANNEX 5: PERSUAP ANALYSES OF PESTICIDE ACTIVE INGREDIENTS ...................................................................... 91

ANNEX 6: PESTICIDES ANALYZED AND REJECTED FOR BCI ACTIVITIES ................................................................ 96

ANNEX 7: TRAINING TOPICS AND SAFE PESTICIDE USE WEB RESOURCES .......................................................... 99

ANNEX 8: BCI STRATEGY FOR COMPLYING WITH PERSUAP MITIGATION CONDITIONS ........................... 101

REFERENCES .................................................................................................................................................................................. 113

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1. INTRODUCTION

The US Global Development Lab (USAID/GDL) brings together a diverse set of partners to discover, test, and scale breakthrough solutions to achieve human progress. Launched on April 3, 2014, USAID/GDL seeks to increase the application of science, technology, innovation, and partnerships to accelerate the Agency’s development impact in helping to end extreme poverty. The Lab does this by working closely with colleagues across the Agency and by bringing together a diverse set of partners to find innovations, tools, and approaches to solve development challenges more effectively and sustainably. The Lab serves as a central hub for shared learning on science, technology, innovation and partnerships and works across USAID and with international partners to mainstream proven solutions to reach global impact.

The USAID/GDL is providing support to the Better Cotton Initiative (BCI) for establishment and management of country-level programs to produce 'Better Cotton'. BCI works with strategic and implementation partners in a number of cotton producing countries. Currently, USAID supports BCI in India, Mozambique, Pakistan, and Senegal.

The Better Cotton Initiative (BCI) is a private, non-governmental, not-for-profit membership association whose long-term objective is to promote best farming practices, high quality products and managerial responsibility, while minimizing the use of agrochemical products and protecting workers’ rights through a participatory stakeholder approach. BCI exists in order to respond to the current impacts of cotton production worldwide. BCI aims to promote measurable improvements in key environmental and social impacts of cotton cultivation worldwide to make it more economically, environmentally, and socially sustainable.

Use of pesticides in cotton production. Cotton represents nearly half the fiber used to make clothes and other textiles worldwide. Pesticides and similar chemicals are heavily used in cotton production; this poses risks to human health and the environment, including severe health impacts on agricultural field workers and significant impacts on ecosystems that receive run-off from farms.

BCI production principles include a focus on Integrated Pest Management (IPM). BCI promotes non-chemical preventive tools and tactics for management of serious pests and diseases of cotton. BCI also promotes rational pesticide choice and use decisions by its cotton farmer clients, and BCI analyses pesticides used by their farmer clients in specific target countries. To promote and establish its approach to better cotton production, BCI does much of its work through local national counterpart implementing partner (IP) sub-grantee experts in its target countries.

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12 FACTOR PESTICIDE ANALYSIS Factor A. USEPA registration and restriction 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 Integrated Pest Management (IPM) program

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

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

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

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

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

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

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

Factor K. Provision for training of users and applicator

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

2. USAID PESTICIDE PROCEDURES

2.1 HISTORY OF USAID PESTICIDE REGULATIONS

Vigilant attention to safe pesticide use is extremely important as USAID projects have learned in the past. From 1974 to 1976, over 2,800 Pakistan malaria spray personnel were poisoned (5 to death) by insecticide mismanagement on a USAID/World Health Organization (WHO) anti-malaria program. USAID was sued by a coalition of environmental groups and, in response to the lawsuit, drafted 22 CFR 216 (Reg. 216). According to Reg. 216, all USAID activities are subject to Environmental Compliance (EC) analysis and evaluation via – at a minimum – an Initial Environmental Examination (IEE), and – at a maximum – an Environmental Assessment (EA).

A large part of Reg. 216 – Part 216.3 – is devoted to pesticide use and safety. Part 216.3 requires that if USAID is to provide support (see definition below) for pesticides in a project, 12 factors must be analyzed, and recommendations must be written to mitigate or reduce risks to human health and environmental resources. This plan must be followed up with appropriate training, monitoring and reporting for continuous improvement on risk reduction. The adoption of international best practices for Integrated Pest Management (IPM) and Safer Pesticide Use (SPU) with Personal Protective Equipment (PPE) is required.

2.2 REGULATORY REQUIREMENTS FOR USAID-FUNDED SUPPORT OF PESTICIDES

The PER (Pesticide Evaluation Report), addresses pesticide choices based upon environmental and human health issues, uses, alternate options, IPM, biodiversity, conservation, training, PPE options, and monitoring and mitigation recommendations according to the twelve Regulation 216.3(b)(1) Pesticide Procedures Factors, outlined in the blue box above.

Reg. 216.3(b)(1)(i) stipulates: “When a project includes assistance for procurement or use, or both, of pesticides registered for the same or similar uses by USEPA without restriction, the Initial Environmental Examination for the project shall include a separate section evaluating the economic, social and environmental risks and benefits of the planned pesticide use to determine whether the use may result in significant environmental impact.”

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This PERSUAP serves as that “separate section” to the IEE referred to above, usually as an attachment to the IEE. Factors to be considered in such an evaluation shall include, but not be limited to the twelve factors in the blue text box.

When pesticides are necessary, it would be ideal to find pesticides for every need that are US Environmental Protection Agency (EPA) Class IV acute toxicity (the lowest toxicity) and have no chronic human health issues, no water pollution issues, and no ecotoxicity issues. Unfortunately, such pesticides do not exist. Most pesticides, including “natural” or “bio” pesticides, are toxic to at least one aquatic organism, or bees, or birds—and USAID requires that they also go through this PERSUAP analyses. Further, dosage alone determines the poison, meaning that most substances—even innocuous ones like table salt—in sufficiently high doses, can kill organisms, including people, and exceptionally low doses of a very toxic substance may not.

2.3 DEFINING USAID SUPPORT FOR PESTICIDES

“Support for pesticide use” was defined at the outset of this PERSUAP study as potentially including:

• Support for beneficiary training on decision-making about pesticide choice and use. • Support through direct or indirect (e.g., finance schemes or by sub grantees/partners) purchase of

pesticides using USAID resources. • Support for pesticide promotion or use, application equipment, or PPE during training of partners,

host country organizations, farm laborers, and farmer beneficiaries. • Any technical assistance (such as use or promotion on demonstration farms) that includes the use of

pesticides, no matter who purchases the pesticide.

This “support” includes any by USAID-funded programs, projects, and activities executed by IPs, as well as by the IP’s sub-grantees, partners, financiers, and beneficiaries. Pesticides rejected by this PERSUAP analysis cannot be “supported or used” for any of the USAID-supported project activities, unless an EA is performed and determines their use to be appropriate.

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3. BCI BACKGROUND INFORMATION

3.1 BCI PRODUCTION PRINCIPLES

The Better Cotton Initiative is a global public-private partnership working as the catalyst for a sustainable transformation to Better Cotton. The Better Cotton Initiative exists to make global cotton production better for the people who produce it, better for the environment it grows in, and better for the sector’s future. BCI aims to transform cotton production worldwide by developing “Better Cotton” as a sustainable mainstream commodity.

A Swiss-registered Membership Association, governed by a multi-stakeholder Council representing producers, traders, suppliers, manufacturers, retailers, brands, and civil society actors, BCI has a business model based on dual-track delivery. On one track, BCI, the organization, owns the Better Cotton Standard System and is responsible for ensuring it is credible and accessible, delivers significant impact, and reaches mainstream scale. The other track, characterized by shared ownership with local and national partners, is focused on field-level investment and management.

BCI delivers lasting improvements to farmer livelihoods through involving the entire value chain from producer to supplier to retailer using sustainable added-value basic principles, enabling significant volumes of Better Cotton to be produced and procured.

To achieve this mission, BCI works with a diverse range of stakeholders across the cotton supply chain to promote measurable and continuing improvements for the environment, farming communities, and the economies of cotton-producing areas.

BCI has four specific aims:

• Reduce the environmental impact of cotton production • Improve livelihoods and economic development in cotton producing areas • Improve commitment to and flow of Better Cotton throughout supply chain • Ensure the credibility and sustainability of the Better Cotton Initiative

Developed by BCI, the Better Cotton Standard System is a holistic approach to sustainable cotton production focused equally on environmental, social and economic impact, based on a voluntary standard for improvement which can be implemented in a mainstream way on a global scale. Currently, it is the only such system existing for cotton in the world. At farm level, it applies six principles:

1. Minimize the harmful impact of crop protection practices 2. Use water efficiently and care for the availability of water 3. Care for the health of the soil 4. Conserve natural habitats 5. Care for and preserve the quality of the fiber 6. Promote Decent Work

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3.2 BCI STRATEGIC PLAN

BCI confirms that in the next 3 years operations will focus, among others, on the following strategic areas:

1. Adapt, optimize and make BCI global operations fit for purpose to secure supply from different geographies, to connect supply with demand and to implement BCI vision of embedding the BCI Standard System into national and sub-national agricultural practices, sharing the responsibility for Better Cotton worldwide with local originations well-placed to oversee implementation in the field, and preventing excessive or inefficient growth of the BCI Secretariat.

2. Engage, acquire and retain members and boost demand of better cotton from retailers and brands: A new department was created in January 2015 to recruit and retain members throughout the whole supply chain and to boost demand from Retailers and Brands.

3. System building and enhancements to enable scale up: The current traceability system, the training platform and other IT infrastructures will have to be upgraded and sometimes completely re-engineered.

4. Efficient and effective governance: BCI’s governance will have to evolve and adapt to help the organization achieve its objectives. BCI will constantly put in place appropriate governance committee structures, clear accountability mechanisms, comprehensive risk management as well as compliance and assurance systems.

5. Raising the profile of BCI: Increasing demand for Better Cotton means securing the commitment of more supply chain actors and helping them to engage their customers. To do that, BCI will need to provide clear and exciting messages and materials to present a persuasive case.

6. Increasing financing capacity and capability: To achieve 30% of global cotton production, BCI will have to expand its global programs and develop innovative funding mechanisms for mainstreaming Better Cotton. For that purpose BCI requires to expand its funding base and to kick off the Growth and Innovation Fund.

Although none of these specifically use the word pesticide, agricultural operations under number 1 and increasing production under number 6 will include the use of inputs and pesticides, which are a main input for cotton production worldwide. Further, BCI maintains lists of pesticides used by their beneficiary farmers.

3.3 BCI ENVIRONMENTAL COMPLIANCE, BEST COTTON IPM/PESTICIDE PRACTICES

The first four of BCI’s six Better Cotton Standard System principles—listed in Section 3.1 above—can be and are impacted by pesticides. For this reason and others, BCI uses state of the art Crop Production and Pest Management Plans (PMPs) in its training materials and training delivery. These include many good preventive IPM tools.

As noted above, for USAID, BCI has already written an Environmental Review Checklist (ERC) that addresses environmental consequences of its activities (see BCI ERC for details). Prior to launching this PERSUAP study, BCI provided analytical information for each of the 12 factors required in the PER analysis. This information from BCI has been dovetailed into this document’s PER, along with additional specific information on the pesticides known to be used by BCI beneficiaries in the four target countries where USAID funds will support BCI operations (India, Mozambique, Pakistan, and Senegal).

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BCI has also analyzed locally (nationally) registered pesticides used on cotton in each of the four USAID target countries. For pesticides known to be used by beneficiaries on cotton in the four countries, BCI created a Toxic Load Indicator Scoring System to rank pesticides by several risk factors.

As part of its Better Cotton Assurance Program, BCI has produced Results Indicators. These include kilograms per hectare of inputs, pesticides (AIs), fertilizers, and water used by smallholders for medium and large cotton farms. Importantly, the program and its Results Indicators also include data on yield, profitability, elimination of child labor, and women’s empowerment. Farmers are trained to keep records on inputs including pesticides and yield, among other data, in Farmer Field Books (FFBs). Finally, pesticides used by farmers often include homemade or artisanal pesticides.

BCI has produced Better Cotton Production Principles and Criteria, which include IPM and pesticide best practices. Further, BCI produced a Better Cotton Performance Scale for Smallholders. This performance scale includes best crop production principles and SPU for pesticide use, and improvement requirements including PPE use. BCI promotes only pesticides that are registered nationally for the crop being treated and correctly labeled in the national language.

BCI-analyzed pesticides (AIs) used by their beneficiaries in the four target countries are listed in Annex 4. These pesticides are further analyzed in this PERSUAP by twelve factors required in Regulation 216’s Pesticide Procedures, part 216.3(b)(1)(i) a-l (Factors a-l). The BCI-analyzed pesticides approved by this PERSUAP analysis for same or similar use are listed in the Executive Summary and in the SUAP.

3.4 BCI PERSUAP METHODOLOGY / ANALYTICAL APPROACH

This Programmatic PERSUAP was developed by the author in cooperation with USAID/GDL, BCI, and Cadmus staff, with consultation and guidance from GDL’s BEO. The work was done without travel to any of the four target countries; the author had worked in all of them but Pakistan in the past and had experience working on cotton for USAID’ Regional Mission to West Africa.

BCI staff, with guidance from this report’s author and Cadmus, sent lists of pesticides currently registered in the four target countries, drafted a “total toxic load” analysis of key pesticide AIs known to be used by BCI cotton farmers in these countries, and adopted cotton pest management plans (PMPs) developed by different groups in these countries to guide their farmers with field technical and IPM decisions. Cadmus staff provided task guidance, produced background sections for each of the four target countries, and along with GDL provided feedback on the drafts of this PERSUAP.

Pesticide AIs proposed by BCI for further analysis were alphabetized by type (insecticides and miticides, fungicides, herbicides and plant growth regulators (PGRs), and one molluscicide), and characterized by chemical class (so that IPs can teach beneficiaries which class to rotate within to avoid the development of pest resistance). Each AI was screened for EPA registration in pesticide products for “same or similar use” and restriction by way of its restricted use (RUP) status in certain registered products, as required by Factor A.

Pesticide AIs not contained in any EPA registered products, or registered for uses other than agriculture, were rejected and eliminated from further consideration. AIs with most or all products or uses classified by EPA as RUP were also rejected and eliminated. AIs that are in few or about half but not all RUP products were subject to further screening to determine the reason for restriction. Where restrictions are generally

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based on AI concentration, non-RUP products with lower concentrations or special safer formulations could be accepted for potential support by USAID IPs, should they choose to do so.

The remaining AIs, found to be currently registered and accepted for use in non-RUP products, were subjected to analysis by the remaining 11 Factors (B-L) required under USAID’s pesticide procedures. The SUAP compiles mandates and recommendations from each of the 12 Factor analyses and puts them into an action plan for BCI implementation. The Programmatic SUAP includes known risks and risk reduction standards of best practice for safer use of the pesticides. These are generally recognized and globally-applicable standards that must be understood and applied if pesticide use is to be supported.

Significantly, Annex 1 contains primary pests and diseases of cotton in the four target countries. For each, it proposes preventive IPM tools and tactics available to be integrated with select pesticides evaluated by this PER, as recommended by various country extension services for the same or similar (same genus) pests and diseases of cotton in those countries. Further, Annex 2 provides guidelines for making PMPs, and Annex 3 provides a system for putting an IPM system in place using Farmer Field Schools (FFS).

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4. ENVIRONMENTAL BACKGROUND FOR INDIA, MOZAMBIQUE, PAKISTAN, SENEGAL

The following information on geography, geology, topography, climate, protected sites, soils, hydrology, marine resources, agriculture, and pesticide-related environmental policy is provided for each of the four target countries where USAID funding will support BCI operations. This information is used and referred to later in this document in the 12-factor analyses, particularly factors G and H.

4.1 INDIA

Geography. India is the 7th largest country in the world with a total area of 3,287,263 kilometers2. India is located in Southern Asia between the Arabian Sea and the Bay of Bengal. Its bordering countries include Bangladesh, Bhutan, Burma, China, Nepal, and Pakistan.1

Geology. India’s geological makeup is varied, containing rocks from different geologic periods as old as the Eoarchean Era. The country carries a significant fossil record, including stromatolites, invertebrates, vertebrates, and plant fossils. The geographical land area can be divided into Deccan trap, Gondwana, and Vindhyan classifications. India is susceptible to various types of natural hazards, including droughts, flash floods, severe thunderstorms, and earthquakes.

FIGURE 1. MAP OF INDIA

Source: www.mapsofindia.com

1 CIA World Factbook, India; accessed via the internet on 4/6/2016 at https://www.cia.gov/library/publications/resources/the-world-factbook/geos/in.html

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Topography. India’s landscape is characterized by three main features: The mountain belt of the Himalayas, which separates it climactically from its bordering Asian countries; the Peninsula, which consists of severely weathered and eroded crystalline rock; and the Ganges-Brahmaputra Lowland, which acts as a channel between two rivers. Two other major topographic features are the narrow coastal plain along the Arabian Sea and a wider coastal plain along the Bay of Bengal. India is home to some of the world’s highest peaks, which are found in the northern mountain region.

The trench between the Peninsula and the Himalayas creates the largest alluvial plane on earth, measuring 1,088,000 km2. Six of India’s rivers also flow through the Peninsula, which holds the majority of the country’s mineral wealth.2

Climate . India’s climate varies from tropical monsoon in the south to temperate in the north. The southern, east, and west coasts of the Peninsula and the Ganges Delta are humid and tropical, while the remainder of this region is moist subtropical to temperate. The western desert area is also subtropical to temperate.

Weather extremes are prevalent in the country, as western desert areas may receive less than 13 cm of annual rainfall, while the Khasi Hills of Assam (2,400 km east), may receive 1,143 cm. Snowfall is common in the northern mountains, although the majority of the country experiences severe dust and hail storms in the spring. Frost occurs in the northern half from November to February, but temperatures may reach as high as 49 degrees C in May.

The most significant aspect of India’s climate is the monsoon, as it divides the year into four seasons: rainy (southwest monsoon) from June-September, moist (retreating monsoon) from October-November, dry and cool (northeast monsoon) from December-March, and hot in April-May.3

Protected Sites. There is a protected area network in India that has been used to manage natural resources and conserve biodiversity. Currently, India has established a network of 679 Protected Areas (PAs), extending over 1,62,365.49 km2 (4.9 percent of the total geographic area) and comprising 102 National Parks, 517 Wildlife Sanctuaries, four Community Reserves, and 56 Conservation Reserves. The National Wetland Conservation Program has identified 115 wetlands, 25 of which are already classified as Ramsar sites.4 India emphasizes forest protection and reforestation and, importantly, has a National Forest Policy, which aims to maintain a minimum of 33 percent of the country’s geographical area under forest and tree cover. Additionally, 106 coastal and marine sites have been identified and prioritized as Important Coastal and Marine Areas.

India has six natural World Heritage Sites with “Outstanding Universal Values,” including Kaziranga National Park, Manas National Park, Keoladeo National Park, Nandadevi National Park, Sundarbans National Park, and Western Ghats serial site. More natural sites are being evaluated to be added as World Heritage Sites.5

2 Nations Encyclopedia, India-Topography; accessed via the internet on 4/7/2016 at: http://www.nationsencyclopedia.com/Asia-and-Oceania/India-TOPOGRAPHY.html 3 Nations Encyclopedia, India-Climate; accessed via the internet on 4/7/2016 at: http://www.nationsencyclopedia.com/geography/Congo-Democratic-Republic-of-the-to-India/India.html 4 India, Ramsar; accessed via the internet on 4/18/2016 at: http://www.ramsar.org/wetland/india 5 Convention on Biological Diversity, India-Overview; accessed via the internet on 4/7/2016 at: https://www.cbd.int/countries/?country=in

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Soil. Among the major soil types in India, Alluvial Soil is the most prevalent and has a chemical composition that makes it one of the most fertile soils in the world. Black soil is found in the Deccan Plateau and is ideal for cotton cultivation. Red soil is useful for rice, millets, tobacco, and vegetables. Laterite soil is found mostly in the Western region and is used for tea, coffee, and coconut.

To tackle the food crisis, genetic diversity must be maintained in crop varieties, livestock, forest species, aquaculture, and most of all, in the soil, as soil biodiversity is essential for sustained good yields. Forest and mountain soils as well as desert soils are also significant in India’s soil composition. Issues such as soil erosion occur in dry and hilly areas as a result of forest depletion and incorrect land use.6

The long-term exploitation of soil in tea gardens has brought about changes in the physical, chemical and biological attributes of soil, decreasing organic matter content, cation exchange, water-holding capacity, soil biota (reduced up to 70 percent), and pH, while simultaneously increasing concentrations of toxic aluminum.7

Indian national biodiversity strategies and action plans to concentrate on wildlife, crops, livestock diversity, and microorganisms, which will likely include those in soil, as soil microorganisms are crucial for both wild and agricultural ecosystems.

Hydrology. Despite having approximately four percent of the world’s freshwater resources, India is still designated as a water stressed region with utilizable freshwater at 1,122 m3 per year per capita. This is partly due to rapid urbanization, industrialization, and agricultural demand, but it is also due to topographic constraints, distribution patterns, technical limitations, and poor management.

India is drained by 12 major river systems and many smaller rivers and streams. The major river systems are the Himalayan Rivers (Ganga, Yamuna, Indus and Brahmaputra), the southern rain-fed rivers (Krishna, Godavari, and Cauvery), and central India’s Narmada, Mahanadi, and Tapti.

Over 70 percent of India’s rivers drain into the Bay of Bengal, with the remaining draining into the Arabian Sea and interior basins and natural lakes. The Ganges-Brahmaputra and Indus systems drain almost half of the country and carry more than 40 percent of the utilizable surface water from the Himalayas to the ocean. Rivers are used for drinking water, irrigation for agriculture, and industry, and have some of the highest rates of siltation in the world. Flooding is the most common natural disaster in India. Seventy-five percent of total annual rainfall is received from June to September as a result of the southwest monsoon. The rivers in North and Central India are vulnerable to flooding during this period. Because rainfall is not evenly distributed in terms of time and location in the country, floods and droughts often occur in different areas, sometimes simultaneously.

India’s lakes are used for the same purposes as the rivers: drinking water, agriculture, and industry. They also act as sewage absorbers, flood cushions, recharge zones for aquifers, and they support tourism. Lakes face many threats including uncontrolled tourism disturbing biodiversity, over-draining, effluent dumping, agricultural runoff, encroachments, and poor management. Water shortages have seriously affected bird sanctuaries and fisheries as well.

Groundwater availability in India is mostly limited to valleys and low-lying areas. More than 60 percent of irrigation water and 85 percent of drinking water comes from groundwater sources. The rate of extraction is 6 WinEntrance, India Major Soils; accessed via the internet on 4/8/16 at: http://winentrance.com/general_knowledge/geography/soils-india.html 7 Excerpt from Managing Agricultural Resources for Biodiversity Conservation; prepared under the Environmental Liaison Centre International; accessed via the internet on 4/7/2016 at: https://www.cbd.int/doc/nbsap/agriculture/IndVeitPhil.pdf

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unsustainable; the worst-affected areas of Rajasthan, Gujarat, Andrah Pradesh, and western Madhya Pradesh have water tables below 300 m. The amount of shallow tubewells was 3,000 in 1960, compared to 6 million in 1990. Poorly managed extraction has also led co contaminated aquifers from high levels of arsenic and fluoride, and seawater in coastal areas. 8

Marine Resources. With 8,000 km of coastline, India has a wide range of important marine ecosystems, including estuaries, lagoons, mangroves, backwaters, salt marshes, rocky coasts, sandy stretches, and coral reefs. Mangroves occur in deltas, estuaries, backwaters, and sheltered bays. Total mangrove cover is about 700,000 hectares, consisting of 59 different mangrove species.

The Indian Ocean is home to some of the most diverse reefs in the world, and India contains all three major reef types (atoll, fringing, and barrier). The total area of coral reefs is about 2,374.9 km2. Reefs are mainly located in the Gulf of Kutch, Palk Bay, and the Gulf of Mannar, but not in the Bay of Bengal due to the large amount of freshwater and silt that is brought down by major rivers.

Marine and coastal mammals include whales, dolphins, porpoises, manatees, and dugongs. Marine reptiles include sea turtles, crocodiles, and sea snakes, and sea and water birds both feed and breed near the sea. About 177 bird species are found in India’s mangrove forests.9

India has rich fishery resources, including various species of fish and crustaceans. The country is ranked third in fishery production and second in aquaculture production. There are approximately 21,585 fish in India, with 41 percent freshwater and 59 percent marine. The fishing industry contributes about 1 percent to India’s GDP. Marine resources come from the Exclusive Economic Zone (2.02 million sq km), the coastline (8129 km), rivers and canals (197,024 km), and the Continental Shelf (.506 million sq km). Oil Sardines are the most significant species, as they constitute 13.1 percent of total marine fish landings. Because land areas are limited, capacity will likely not be able to meet rapidly increasing food demand.10

Agriculture. India uses 60.5 percent of its land for agricultural practices. The land is 52.8 percent arable, 4.2 percent permanent crops, and 3.5 percent permanent pasture. Agriculture employs about 60 percent of India's population and contributes about 25 percent to GDP. Slightly more than half of India’s geographical area is cultivated, and only 30-35 percent of India’s agriculture land is irrigated. In response to a rapidly growing population and as an attempt to allay poverty, India has developed its agricultural production in the past four to five decades. The country has converted much of its wild land to agriculture and diverse small-scale farms to homogeneous large-scale commercial farms, exploited biodiversity resources, and increased its use of modified species that require significant pesticides and fertilizer inputs.11

In addition to the increasing population, climate change will likely pose a great threat to agriculture in India. Varied precipitation, heat waves, droughts, and floods will significantly alter agricultural production and pose

8 India’s Water Resources, Availability, usage and problems; accessed via the internet on 4/18/2016 at: http://base.d-p-h.info/fr/fiches/dph/fiche-dph-7825.html

9 Challenges of marine management, infochange India; accessed via the internet on 4/18/2016 at: http://infochangeindia.org/agenda/coastal-communities/challenges-of-marine-management.html

10 Excerpt from Marine Fisheries Resource of India; prepared under Karnatak Science College; accessed via the internet on 4/7/2016 at: http://www.slideshare.net/SameerChebbi1/marine-resource-of-india

11 Excerpt from Managing Agricultural Resources for Biodiversity Conservation; prepared under the Environmental Liaison Centre International; accessed via the internet on 4/7/2016 at: https://www.cbd.int/doc/nbsap/agriculture/IndVeitPhil.pdf

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shocks to the economy. Temperature changes could negatively impact land and water ecosystems as well as production potential.12

India’s cotton industry contributes about 14 percent to industrial production, 4 percent to GDP and 14.42 percent to export earnings. India produces approximately 27 million bales of cotton annually, which makes it the world’s second top cotton producer. India is projected to yield 28.5 million 480-pound bales of cotton in 2016-2017 on a considerably low acreage of 11.8 million hectares. Production is forecast to increase in the near term as a result of ameliorated crop, pest, and weed management and an expected normal monsoon after two years of little rainfall.13

Pesticide-related Environmental Policy. India’s Insecticides Act of 1968 is a key piece of legislation that governs the use, manufacture, distribution, sale, and transport of insecticides in efforts to decrease risks to human and animal health. However, pesticides in India are widely used in the agriculture industry with little regard for the consequences of unregulated and indiscriminate use. This has been the case for the past 50 years. Although the government is supposed to regulate pesticide use under law, this is rarely the case.

When pesticide use in India is regulated, it is primarily by the Central Insecticides Board and Registration Committee (CIBRC) and the Food Safety and Standards Authority of India (FSSAI). The CIBRC registers pesticides for crops, while the FSSAI sets the maximum residue limits (MLRs) of pesticides for the crops for which they have been registered. However, of the 234 pesticides registered in India, the FSSAI has not set MRLs for 59 pesticides. CIBRC has registered 63 pesticides for cotton. There is currently no system in place to track the sale of banned pesticides, and the authors preparing this PERSUAP were unable to find any government ministry data on this topic. Both the Ministry of Agriculture and the Ministry of Health and Family Welfare should take action to make certain that pesticide restrictions are being followed.14

According to the Plant Quarantine (Regulation of Imports into India) Order of 2003, imports of plants and plant products must receive an import permit issued by the MOA’s Department of Agriculture and Cooperation in order to prevent the introduction of exotic pests and diseases.15

12 Excerpt from India Can Beat the Food Crisis; prepared by Dr. Suman Sahai; accessed via the internet on 4/7/2016 at:

https://www.cbd.int/doc/external/mop-04/gc-en.pdf 13 India Brand Equity Foundation, Cotton Industry India; accessed via the internet on 4/7/2016 at: http://www.ibef.org/exports/cotton-industry-india.aspx

14 Excerpt from State of Pesticide Regulations in India; prepared by Centre for Science and Environment; accessed via the internet on 4/7/2016 at: http://www.cseindia.org/userfiles/paper_pesticide.pdf 15 USDA Foreign Agricultural Service Global Agricultural Information Network, India-Food and Agricultural Import Regulations and Standards; accessed via the internet on 4/8/2016 at:

http://gain.fas.usda.gov/Recentpercent20GAINpercent20Publications/Foodpercent20andpercent20Agriculturalpercent20Importpercent20Regulationspercent20andpercent20Standardspercent20-percent20Certification_Newpercent20Delhi_India_1-11-2016.pdf

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4.2 MOZAMBIQUE

FIGURE 2. MAPS OF MOZAMBIQUE

Source: http://www.lib.utexas.edu/maps/mozambique.html

Geography. Mozambique is located in Southeastern Africa along the Indian Ocean, between South Africa and Swaziland to the south, and Tanzania to the North. It is bordered to the west by Malawi, Zambia, and Zimbabwe. Mozambique has a total surface area of almost 800,000 km2, 13,000 km2 being water, and almost 5,000 km of coastline along the Mozambique Channel. The Zambezi River flows from west to east across the middle of the country, originating in Zambia and emptying into the Indian Ocean. Lake Nyasa (also known as Lake Malawi) is the largest lake in Mozambique, located between Malawi, Mozambique, and Tanzania.16

Geology. The geology of Mozambique is quite varied. The southwestern, central, and northeastern provinces consist of mostly Precambrian terrains, from Archean to Upper Proterozoic rocks, covered mainly by Phanerozoic (ranging from Jurassic through Tertiary) sedimentary rocks in the south and east. Precambrian terrains (ranging from Archaean to Upper Proterozoic rocks) are the predominant underlying rocks in the southwestern, central, and northeastern provinces.

16 CIA World Factbook, Mozambique; accessed via the internet on 4/8/2016 at: https://www.cia.gov/library/publications/the-world-factbook/geos/mz.html

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Along the western border with Zimbabwe, the terrain is an extension of the Zimbabwe Craton, which consists mostly of Archaean granitic gneiss complexes, with greenstone belts and shallow Palaeo-Proterozoic sedimentary basins. The Great East African Rift (now partly occupied by Lake Nyasa) has extensions in Mozambique, which are typically filled by the Karoo System terrigenous sediments and volcanism from the end of the Karoo sedimentation. The majority of coastal plains in the central and southern parts of the country were laid down during the Cretaceous. 17

Topography. The Zambezi River divides Mozambique into distinctive northern and southern halves. The northern half contains many mountains and plateaus, including the Livingstone-Nyasa Highlands, the Shire (or Namuli) Highlands and the Angonia Highlands in the northeast. The west is particularly mountainous, transitioning to plateaus and uplands heading eastward. Below the Zambezi River are fertile plains, especially bordering the river. The central part of the country consists of uplands, marshes, and coastal lowlands. The dry inland areas do not support much vegetation. Due to its location on the African Tectonic Plate, Mozambique experiences little to no tectonic activity.18

Climate. Mozambique’s climate is semi-arid and subtropical in the south and tropical in the north. There is a warm, wet season from November to March and a dry, cooler season from April to October. Climate is influenced by altitude, latitude, and proximity to the sea. Mozambique receives anywhere from 300 to 2,000 millimeters (mm) of rain per year, depending on location. The lowlands in the southern interior typically receive less rain than the Zambezi Delta and the mountainous areas in the north and west. Droughts and floods are common as precipitation varies significantly from year to year.19

Protected Areas. Mozambique has extended its protected areas from 11 to 25 percent of its national area, and it has recently added Quirimbas National Park for marine and coastal ecosystems and Limpopo Transfrontier National Park, which straddles the borders of Mozambique, South Africa, and Zimbabwe. Several areas are also under special protection, including Marromeu Complex, Maputoland Centre of Endemism, and the Chimanimani and Namuli Mountains. Overall, protected areas include 6 national parks, 8 national reserves, 13 forest reserves, 2 integral reserves, and 14 hunting concessions designated for sport hunting and protecting species. In addition, the Marromeu Natural Reserve and Lake Nyasa Partial Reserve are Ramsar sites due to the extensive biodiversity of their wetlands. Mozambique has one UNESCO Cultural World Heritage Site, the Island of Mozambique.20

Soils. Granite rock underlies most of northern and west-central Mozambique, while the soils of southern and east-central Mozambique are derived from sedimentary rock. The northern and central regions have more fertile, water-retentive soils with a higher content of red clay. In the south, soils are mostly sandy and infertile; fertile soils are limited to alluvials in the valleys of the Save, Limpopo, Incomáti, Umbelúzi, and Maputo Rivers.21

17 Regional Geology, Baobab Resources; accessed via the internet on 4/8/2016 at: http://www.baobabresources.com/mozambique/regional-geology

18 Topographic Regions, Mozambique, Nations Encyclopedia; accessed via the internet on 4/8/2016 at: http://www.nationsencyclopedia.com/geography/Morocco-to-Slovakia/Mozambique.html 19 Excerpt from Southern Africa Amendment to the PEA for the Manufacture and use of aflasafe in Sub-Saharan Africa; prepared under GEMS project; accessed via the internet on 4/11/2016 at: http://gemini.info.usaid.gov/egat/envcomp/repository/pdf/46761.pdf 20 Ibid

21 Ibid

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Hydrology. Mozambique has abundant water resources due to its major river systems, which also offer hydroelectric and irrigation potential. The Rovuma River lines Mozambique’s northern border with Tanzania, while the Zambezi River and its tributaries are found in the central region. The Zambezi has 819 km in Mozambique and drains more than 225,000 km2 of the central region. The southern border with Swaziland and South Africa is formed partly by the Maputo River. Other drainage areas include the Messalo, Púngoè, Revuè, Buzi, and Limpopo Rivers. Mozambique shares several lake borders with Malawi (Nyasa, Chiuta and Chilwa) but has no other important lakes besides human-made lakes created by the hydroelectric dam network.

Mozambique has considerable groundwater potential with well yields in the Zambezi and Incomáti basins at 70,000 m3 per day. Seventeen km3 of groundwater is produced annually, along with 97.3 km3 of surface water. Including some overlap between ground and surface water, total renewable water sources equal around 100.3 km3 per year. The Cahora Bassa dam on the Zambezi River is the largest hydroelectric plant in southern Africa, with an installed capacity of 2,060 megawatts. Surface water is the main water source in Mozambique, although groundwater is used for drinking water supply in certain urban areas. In rural areas, shallow wells and handpump-mounted boreholes are the main sources of drinking water.

The greatest use of water is agriculture; irrigation accounted for 86.6 percent of total water used in 2000, mainly from surface water. In 2003, 1,181 km2 was irrigated. Total irrigation potential is around 3,300,000 ha, where the main areas suitable for irrigation are the center and the north of the country. The Zambezia province is home to 60 percent of the irrigation potential. Most irrigated lands are occupied by smallholder farmers and agricultural enterprises. Small-scale irrigation schemes exist all over the country but are mostly abandoned or in bad condition due to the civil war, lack of inputs and technical assistance, and floods in 2000 and 2001.22

Marine Resources. Coastal and marine ecosystems occupy approximately 42percent of the country. The main marine ecosystems are seagrass beds, coral reefs, mangroves, and open-ocean pelagic ecosystems. Thirteen different species of seagrass cover about 439 km2 in Mozambique and play an important role as both nurseries and feeding areas for commercially valuable species as well as endangered species, such as sea turtles and dugongs. Seagrass beds are also home to several invertebrate species that are collected by coastal communities, and seagrass beds support artisanal fisheries in northern Mozambique.

Coral reefs cover 1,890 km2 in Mozambique and are distributed from the northern coast just north of Sofala Bank. These are mainly fringing reefs, containing mostly hard corals, although soft corals are abundant from the Bazaruto archipelago to Ponta do Ouro. Mozambique’s coral reefs contain significant biodiversity, including more than 900 species of fish, 300 species of hard coral, more than 50 species of soft coral, and other species such as ascidians, sponges, and other invertebrates. Coral reefs also support about 6.6 million people in 48 coastal districts for small-scale fisheries.

Mangrove forests make up 4,000 km2 in Mozambique, of which nine species of mangrove trees have been identified. Mangroves are important for livelihood activities for local communities, who use mangrove forests for construction, firewood, fish traps, and medicine. They also provide ecosystem services such as coastal protection and nursery/refuge habitats for a variety of species.

22 Excerpt from Southern Africa Amendment to the PEA for the Manufacture and use of aflasafe in Sub-Saharan Africa; prepared under GEMS project; accessed via the internet on 4/11/2016 at: http://gemini.info.usaid.gov/egat/envcomp/repository/pdf/46761.pdf

32

The majority of Mozambique’s exclusive economic zone is over deep water, meaning little is known about these ecosystems. However, the pelagic zone is considered productive, and foreign vessels harvest several tuna and other commercial fish species. 23

Agriculture. Agricultural production is an important livelihood for 80 percent of Mozambicans, contributing 30.9 percent to the GDP in 2011. There are an estimated 3.2 million smallholder farmers with plot sizes averaging only about 0.25 ha, yet smallholder farmers are responsible for nearly 95 percent of the agricultural GDP production. Maize and cassava make up 80 percent of the crops grown by smallholder farmers. They typically sell produce to secondary buyers, sell it themselves at roadside stalls, or retain it for household use. Mozambique’s major exports are tobacco, sugar, cashew, cotton, and sesame; groundnut, cassava, maize, poultry, and cashew are important in the domestic market. 24

Cotton production. Mozambique is not a major cotton producer, but there are approximately 200,000 small farm producers in rural areas who grow cotton as their only cash crop. The area under cotton production is estimated at 157,000/ha. Professional companies that consider cotton to be their core business often supply farmers with inputs including seeds, herbicides, and insecticides. The Government of Mozambique has given high priority to cotton production.25

Pesticide-related Environmental Policy. The regulation by which pesticides are registered for use in Mozambique was first promulgated in 1998 with updates in 2003 and 2009. The current procedure adheres to the 2009 regulation (Decree 6/2009 of 31st of March), but guidelines are still being developed to provide guidance on transport, storage, handling, and use of pesticide products to accompany the legislation. The regulation covers matters of registration, production, donation, trading, importation, exportation, packing, storage, transport, handling, use, and elimination of pesticides and adjuvants.

The main institutions responsible for managing pesticides in Mozambique are the Ministry of Agriculture and Food Security (previously Ministry of Agriculture), the Ministry of Health (MISAU), and the Ministry of Land, Environment, and Rural Development (MITADER). Representatives of these ministries form part of the Technical Assessment Committee for Pesticides Registration (CATERP, or Comité de Avaliação Técnica do Registo de Pesticidas), which was created to assess, approve, or disapprove the registration of pesticides in Mozambique; determine the technical conditions to be observed during importation, exportation, production, donation, trading, handling, and application of each pesticide; and impose restrictions on the use of certain pesticides.

During registration, a pesticide’s active ingredient and formulation are registered at the same time. Although the Agricultural Investigation Institute (IIAM) is responsible for conducting and validating efficacy field trials, pesticide registration relies on CATERP. The National Directorate of Environmental Management is responsible for reviewing environmental impacts of the product following review by IIAM. Several of the institutions profiled above have roles in the registration of pesticides as part of CATERP. CATERP is chaired by the Registrar of the Agrochemicals Registration and Control Department (RRCA). In addition, it includes

23 USAID/Mozambique Environmental Threats and Opportunities Assessment (ETOA), January 2013; accessed via the internet on 4/11/2016 at: http://www.usaidgems.org/Documents/FAA&Regs/FAA118119/Mozambique2013.pdf

24 Excerpt from Southern Africa Amendment to the PEA for the Manufacture and use of aflasafe in Sub-Saharan Africa; prepared under GEMS project; accessed via the internet on 4/11/2016 at: http://gemini.info.usaid.gov/egat/envcomp/repository/pdf/46761.pdf

25 https://www.icac.org/getattachment/mtgs/Workshop/Research-Associate-Program-2015/Details/Cotton-in-Mozambique-VF-washington-2015.pdf

33

the National Directorate of Veterinary Services, IIAM, MISAU, and MITADER. After approval of the pesticide, the National Directorate of Agricultural Services then issues the permits and licenses.26

4.3 PAKISTAN

Geography. Pakistan is located in Southern Asia, with approximately 1,000 km of coastline along the Arabian Sea. It is bordered by India to the East, Afghanistan and Iran to the west, and China to the north. Pakistan has a total surface area of almost 800,000 km2, 25,000 of which is water. Pakistan’s largest river, the River Indus, flows from Tibet China through Pakistan into the Arabian Sea and has four main tributaries, the Jhelum, Chenab, Ravi, and Sutlej. 27

FIGURE 3. MAP OF PAKISTAN

Source: www.angelfire.com

Geology. Pakistan’s Sindh and Punjab provinces overlap with the Indian tectonic plate, while Balochistan and most of Khyber-Pakhtunkhwa lie on the Eurasian plate, comprising the Iranian plateau. Gilgit-Baltisan and Azad Kashmire lie mostly on the edge of the Indian plate and are prone to violent earthquakes.

Topography. The majority of Pakistan is arid or semiarid. The Baluchistan Plateau dominates the western part of the country with arid plains and ridges. This area has mostly seasonal rivers, streams, and lakes. The south is also arid and rises to the rocky Kirthar Mountain in the east and the Sulaiman Mountains in the North, which extend towards the Indus plains. Rawalpindi is surrounded by a semi-watered plateau that is bounded by a salt range to the south. In the south, the Punjab plains support about 60 percent of Pakistan’s population. In Northern Pakistan, the lofty mountain ranges are home to 60 peaks over 6,700 m, including

26 Southern Africa Amendment to the PEA for the Manufacture and use of aflasafe in Sub-Saharan Africa; prepared under GEMS project; accessed via the internet on 4/11/2016 at: http://gemini.info.usaid.gov/egat/envcomp/repository/pdf/46761.pdf

27 CIA World Factbook, Pakistan; accessed via the internet on 4/13/2016 at: https://www.cia.gov/library/publications/the-world-factbook/geos/pk.html

34

K-2, which at 8,611 m is the second-highest mountain in the world. The main ranges include several Himalayan ranges (including Pir Panjal and Zaskar) and the Karakoram Mountains.28

FIGURE 4. TOPOGRAPHIC MAP OF PAKISTAN

Climate. Pakistan’s climate is dry and hot near the coast and becomes progressively colder heading northeast. Winter is cold and dry; the hot season is March through June, when temperatures can reach up to 49º C. The monsoon occurs between June and September, providing about 38 cm of rainfall on average and up to 150 cm in the northern areas. Rainfalls vary drastically by year, and flooding and drought are not uncommon.29

Protected Areas. The Government of Pakistan and World Wildlife Fund have documented about 305 Protected Areas in Pakistan, which cover about 12 percent of total land area. While this seems extensive, most are considered “paper parks”, i.e., only protected on paper, while no actual management or protection occurs on the ground. National Parks have the best protected area enforcement, while game reserves and wildlife sanctuaries are lacking in protection. Pakistan also has 19 wetlands recognized by the Ramsar convention as having global importance.30

Soils. Approximately 75 percent of the country’s soil is composed of six broad soil types: Mountain/valley (30.6 percent), rolling/hilly/sandy (14.7 percent), loamy-clayey (11.4 percent), rock out-crop and loamy (6.6

28 Pakistan-Topography, Nations Encyclopedia; accessed via the internet on 4/13/2016 at: http://www.nationsencyclopedia.com/Asia-and-Oceania/Pakistan-TOPOGRAPHY.html

29 Pakistan-Climate, Nations Encyclopedia; accessed via the internet on 4/13/2016 at: http://www.nationsencyclopedia.com/Asia-and-Oceania/Pakistan-CLIMATE.html

30 USAID/Pakistan Tropical Forest & Biodiversity Assessment (FAA 118/119), 2012; accessed via the internet on 4/14/2016 at: http://pdf.usaid.gov/pdf_docs/PA00KH5K.pdf

Source: https://www.worldofmaps.net/en/asia/map-pakistan/topographic -map-pakistan.htm

35

percent) loamy and partly gravelly (5.8 percent) and loamy soils at 5.3 percent. Soils are mostly dry and are high in calcium carbonate and low in organic matter. The Bongar Soils located in the Indus plain are considered the best in the country for agriculture.31

Hydrology. Pakistan is one of the most water-stressed countries in the world, with fewer than 1,000 m3 per person available. Surface water comes from rainfall, glaciers, and rivers and dams. The two main sources of rainfall are the Monsoons and the Western Disturbances. As mentioned above, annual precipitation ranges greatly from south to north. Pakistan has many glaciers, covering 13,680 km2 of land. Water from snow and ice in the glaciers of the Upper Indus catchment provide around 80 percent of the Indus River’s total flow in the summer and 50 percent of the flow in the Jhelum River. The Indus River system is the main source of surface water in Pakistan, averaging 154 mean annual flow (MAF) (including its tributaries) annually. The majority, 104.73 MAF, is diverted for irrigation, while 39.4 MAF flows into the sea and 9.9 MAF is lost during evaporation, seepage, and spills during floods. Water intended for irrigation is diverted through reservoirs and barrages into main canals and then branch canals into its command area. The aggregate length of canals and related systems is 56,073 km. 32

Between 1967 and 1976 Pakistan built two large dams: the Tarbela Dam on the Indus River and the Mangla Dam on the Jhelum River. Together, they form the Indus Basin Project, which resulted from an agreement between India and Pakistan, and were built to control seasonal fluctuations on the Indus River. The Tarbela Dam has a reservoir capacity of 13.7 billion m3, making it the second largest dam in the world by reservoir capacity, and the largest fill-type dam in the world. The Mangala dam has a reservoir storage capacity of 9.13 billion m3. 33,34

Total groundwater potential in Pakistan is estimated at 55 MAF. The quality ranges from fresh (salinity less than 1,000mg/L total dissolved solids, TDS) near major rivers to highly salinized (more than 3,000 mg/L TDS). In addition to surface water used for agriculture, an additional 41.6 MAF of groundwater is also used via tube wells. Originally following widespread irrigation via surface water, the groundwater table began to rise due to poor management, lack of drainage facilities, and resulting additional recharge from canals, distributaries, water courses, etc. Now, more than 500,000 tube wells supply supplemental irrigation water annually, mainly during periods of low surface water availability. The Indus Basin is underlain by an aquifer covering about 15 million acres, about 70 percent of Punjab and 28percent of Sindh.35

Marine Resources. Pakistan’s coastline consists of sandy beaches and rocky protruding points. Dams upstream of the Indus Delta have reduced river-borne sediments, drying up estuaries and inducing sea encroachment further inland. Detailed flora and fauna information is not well-known, but about 800 species of fish have been recorded along the coast. The Indus dolphin lives in the Indus River and estuary and is one of the world’s rarest animals as well as the second most endangered freshwater river dolphin. It is threatened by water pollution, poaching, habitat fragmentation, and strandings in irrigation canals. Two species of endangered turtles, the green turtle and the olive Ridley turtle, are found on Pakistan’s beaches. 31 Ibid

32 Water Resources of Pakistan, WaterInfo; accessed via the internet on 4/14/2016 at: http://waterinfo.net.pk/sites/default/files/knowledge/Waterpercent20Resourcespercent20ofpercent20Pakistan.pdf

33 http://www.britannica.com/topic/Mangla-Dam

34 http://www.britannica.com/topic/Tarbela-Dam

35 Water Resources of Pakistan, WaterInfo; accessed via the internet on 4/14/2016 at: http://waterinfo.net.pk/sites/default/files/knowledge/Waterpercent20Resourcespercent20ofpercent20Pakistan.pdf

36

Pakistan also has mangrove ecosystems, consisting of eight species of mangroves that are rich in biodiversity. Over 48 macro-fauna species have been identified in these mangrove forests, as well as 56 species of birds. Coral reefs have recently been discovered along the coast of Jewani and Astola Island. Coral also appears in patches at Astola Island, Gwadar, and south of Astola Island.

Pakistan has 780,000 hectares of wetlands, covering 9.7 percent of total surface area. More than 225 are recorded in a Pakistan Wetlands GIS database, and 19 are Ramsar sites, most of which are located in the Indus River Delta.36

Agriculture. Of the 59.3 million hectares that have been surveyed in Pakistan, 24.6 million are classified as not available for cultivation, 3.6 million are forests, and 9.2 million are unused but are potentially cultivatable. About 22 million hectares are under cultivation, 16 million of which are under agricultural production, with the remaining considered fallow. About 13.5 million hectares are irrigated, and 6.5 million are sown more than once per year. The majority of irrigated, cultivatable land is in the eastern provinces of Punjab and Sindh, proximate to the Indus River and its tributaries. Most cropland is irrigated by rainwater only, despite variable rainfall, due to Pakistan’s extensive but inefficient canal irrigation system. Agriculture employs more than 40 percent of the working population, but per capita agricultural land is declining.

The main crops in Pakistan are wheat, rice, maize, barley, oil seeds, pulses, cotton, sugarcane, vegetables, tobacco, and fruits. About 3,000 taxa of cultivated plants are indigenous, and there are 500 wild relatives of cultivated crops, mainly found in Northern Pakistan. There are many threats to agro-ecosystems in Pakistan, including loss of topsoil, increased pesticide use, introduction of high yield crops, and loss of local varieties, loss of local and indigenous knowledge, and climate change. Further, intensive agriculture reduces crop diversity due to the introduction of genetically uniform varieties and hybridization between exotic and local varieties. Genetically modified varieties spread, reducing the adaptability of crops to changing environmental conditions and reducing performance in marginal lands. High yield crops also can create stress for poor farmers, who are required to buy more fertilizer to support these varieties.37

Cotton production. Cotton is an important cash crop in Pakistan. Pakistan is the world's fourth-ranked cotton producer after China, India, and the United States. Cotton is not only an export-earning crop but also provides raw material to local textile industry. A profound investment in the form of over 1,000 ginning factories and over 400 textile mills heavily depend upon cotton. Millions of farmers are directly associated with cultivation and harvesting of cotton crop and sale of lint. Many others are indirectly linked with the cotton value chain. The government of Pakistan is giving high priority to plant biotechnology research in the hope of addressing the pressing challenges related to improving productivity, farmers’ livelihoods, driving rural development, and meeting food security demands.38

Pesticide-related Environmental Policy. The Agricultural Pesticide Ordinance (APO) was developed in 1971 to regulate the import, manufacture, formulation, sale, distribution, use, and promotion of pesticides. In 1973, the Agricultural Pesticides Rules were created to standardize registration of pesticides with the help of the provincial agricultural departments. The Department of Plant Protection under the Ministry of Food, Agriculture and Livestock is responsible for the registration and management of pesticides. The National

36 USAID/Pakistan Tropical Forest & Biodiversity Assessment (FAA 118/119), 2012; accessed via the internet on 4/14/2016 at: http://pdf.usaid.gov/pdf_docs/PA00KH5K.pdf

37 Ibid

38

37

Agricultural policy of Pakistan stressed the importance of IPM in 1980, and excessive use of pesticides is monitored by the provincial agricultural departments.39

Pesticides are common in Pakistan, and although environmentally hazardous pesticides are banned by law, unauthorized pesticides are still available for purchase. There are various problems associated with pesticide use in Pakistan, including poor knowledge about pesticide suitability, application, safety measures, and the identification of the correct pest stage to use pesticides. Increased use also leads to spray drift and effects on non-target species, and unsafe use results in soil and water contamination.40

4.4 SENEGAL

Geography. Senegal is the western-most country in Africa, with 2,684 km of coastline along the Atlantic Ocean. Senegal is bordered by Mauritania to the North, Mali to the East, and Guinea-Bissau and Guinea to the south and southeast. The Gambia is completely surrounded by Senegal, with the exception of a small coastline on the Atlantic Ocean. Senegal’s total area is 196,722 km2. Senegal mainly consists of low, rolling plains but rises to foothills in the southeast (Kedougou). 41

Geology. Senegal lies on the African Tectonic Plate. It is made up of two major geological domains, the Sedimentary Basin, which covers more than 75 percent of the country, and the Precambrian basement, which covers the remainder in the southeast. The sedimentary basin is a Mesozoic basin, in which most of the outcrops are sandy covers. The Precambrian basement formations contain the Mauritanides range bordering the eastern part of the sedimentary basement, and the Palaeoproterozoic volcano-sedimentary sequences are located in the far east. Volcanic activity created the Cap Vert promontory and the nearby islets, which are the most western point of Africa.42

Topography. Senegal is the most western part of the broad savannah stretching across the Sahel region. The majority of the country consists of flat, undulating plains with sparse vegetation. There are no major elevation changes or natural landmarks. Steep slopes and broken terrain are only found in the southeastern corner of

39 Pakistan, FAO; accessed via the internet on 4/18/2016 at: http://www.fao.org/docrep/008/af340e/af340e0g.htm

40 USAID/Pakistan Tropical Forest & Biodiversity Assessment (FAA 118/119), 2012; accessed via the internet on 4/18/2016 at: http://pdf.usaid.gov/pdf_docs/PA00KH5K.pdf

41 Excerpt from Senegal WASH IEE, 2016

42 Senegal’s Geology, SimSenegal; accessed via the internet on 4/15/2016 at: http://simsenegal.com/industry-info/senegals-geology/

Source: CIA World Factbook

FIGURE 5. MAP OF SENEGAL

38

the country. The lowlands between Thies and Kaolack produce significant peanut and food crops, but the majority of remaining land is pasturage. 43

Climate. Senegal’s climate can generally be considered tropical, but weather varies in different parts of the countries. The Atlantic coastal region is cooler than inland. Winter temperatures range from 18-26 °C and summer temperatures average 31°C. The rainy season along the coast is from July to October, bringing around 550 mm of rain annually. The northern Sahel region is semi-arid and temperatures can drop at night to around 14 °C. During the day, temperatures can reach 40 °C, and rainfall is below 400 mm annually. The southern half of the country is generally hot and humid. The average high temperature is above 30 °C and rainfall can reach over 1,500 mm annually.44

Protected Areas. Senegal has a large protected area network. In addition, rural populations retain many sites as places of worship. In total, 10 percent of the country’s territory is currently under protection. Some plant and animal species are found only in the protected areas, and Senegal does have endangered plants, mammals, reptiles, fish, and birds.

The Forest Code (regulations) defines forests, reforestation or restoration areas, national parks, strict nature reserves and special reserves; it provides for the classification and declassification of forests; and it governs the administration of protected areas. Senegal is a signatory to the Bern Convention, which is of particular importance to migratory birds. The Bern Convention is a binding international legal instrument in the field of nature conservation, covering most of the natural heritage of the European continent and extending to some States of Africa.

The National Parks Service, incorporated within the National Parks Directorate, is primarily responsible for the protection of wildlife within national parks. It functions as a paramilitary organization and has trained armed guards to prevent poaching. National Parks (Parc National) are areas where hunting, capturing animals, or exploiting flora, soil or subsoil is prohibited. In some locations public access for educational or recreational purposes is permitted.

Special reserves (Réserve spéciale) are areas in which partial or total, temporary or permanent restrictions may be necessary in certain circumstances (including scientific explorations, tourism, etc). Classified forests (Forêt classée) are areas of bamboo, forage trees, palms, and other vegetation exploited for various products, e.g., wood and fruit. These areas are not utilized for agricultural production. 45

Soils. The soils of Senegal range from dry sandy soils in the north, to tropical ferruginous soils in the central region, to ferralitic soils in the South. Overall, soil fertility is low, and soils are mostly fragile, making them highly susceptible to water and wind erosion. The soil in most fresh water river valleys tends to be high in clay and silt content. Soils in these valleys are classified as "generally good soils", i.e., they do not have serious limitations and are able to produce good yields of suitable, climatically adapted crops.

Senegal has experienced some extreme forms of soil degradation. Barren, arid lands have increased, and some areas do not support vegetation due to the rise in salinity or even alkalinity. Because of soil fertility losses, forest rehabilitation and recovery of degraded forest resources have become extremely difficult. Indeed, over

43 Senegal, Nations Encyclopedia; accessed via the internet on 4/15/2016 at: http://www.nationsencyclopedia.com/geography/Morocco-to-Slovakia/Senegal.html

44 Excerpt from Senegal WASH IEE, 2016

45 Excerpt from Senegal 4A IEE, 2016

39

the last two decades, the country has lost nearly one-tenth of its forest area, which has also led to a decline in biodiversity.46

Hydrology. Senegal has four major surface water systems, most of which are transnational: the Senegal River, the Gambia River, the Saloum River, and the Casamance River. Part of the Kayanga River is also in Senegal before it enters Guinea Bissau. The two main dams on the Senegal River (Senegal’s Northern border with Mauritania) have altered the hydrology of the Senegal River and its basin. The Manantali dam (located in Mali) supplies hydropower to Senegal; hydropower contributes to more than 10 percent of electricity generated in the country.

The Diama Dam serves as a regulator of water level in the Senegal River delta and protection against sea water intrusion. Freshwater resources and the endemic plants and animals located therein have been seriously degraded due to drought and human activities and therefore are home to some of the rarer and/or endangered species. Along the Senegal River, the Acacia nilotica, which used to form a large riparian forest, has faced severe deforestation.

The major groundwater resources come from the Senegalese-Mauritanian sedimentary basin and the Precambrian basement. The Senegalese-Mauritanian basin covers 80 percent of the country and includes shallow aquifers, an intermediate aquifer system and a deep system of Maestrichtian limestone and sand. The Precambrian basement in the southeast contains granite and greenstone belts and meta-sedimentary rocks. The rate of freshwater withdrawal in Senegal, over 2 billion m3 annually, is extremely high in comparison with total available renewable freshwater resources, 25.8 billion m3 per year.47

Marine Resources. Coastal, estuarine, and marine resources are under threat from human activities, drought, and overexploitation. The Saloum estuary in Senegal already experiences land losses due to coastal zone inundation. Due to the low altitude of the estuary, a one-meter rise in sea level can result in 27 percent of the land area flooding, of which 50 percent is covered by mangroves. 34 Mangrove ecosystems are important in Senegal for fresh water, soil erosion protection, and habitat for fish. Major threats to mangroves in Senegal include drought (especially the long drought in the 1970s and 1980s), domestic use (unsustainable extraction for fuel wood, fishing, and construction), human infrastructure (roads and dykes), and upland clearing (lower vegetation density increases water flow and erosion). Mangroves are especially important in the Sine-Saloum Delta, where 60 percent of the 300,000 ha are covered with mangroves, which also serve as a breeding ground for migratory birds. The degradation of the mangroves has in turn led to salinization of the Saloum Delta and the coastal ecosystems of the Casamance region.

Fishery resources can be divided into two groups: deep coastal demersal resources (fish, crustaceans, and cephalopods) and coastal pelagic and deepwater (offshore) resources that contain sardines and mackerel. The major pelagic fishing zones along the coast include Saint Louis, Kayar, Dakar, Mbour, the Saloum Delta, and Ziguinchor. Some of the priority species in Senegal are Sardinella, which is the main species landed by artisanal fishermen, and Bonga, which is common in the Saloum and Casamance estuaries. One of the most iconic fish in Senegal, the white grouper, or “thiof” in Wolof, is now nearly extinct as a result of increased large-scale artisanal and industrial fishing over the last few decades, along with exports to Europe of this high-value commercial species.

46 Ibid

47 Excerpt from Senegal WASH IEE, 2016

40

Senegal has four designated Ramsar sites, covering almost 100,000 hectares, and a fifth site that is on the tentative list. The sites are Gueumbeul, a saline lagoon that supports breeding grounds for mammals and reptiles; Djoudj, an internationally important bird area; Bassin du Nidael, supporting migrant birds; Delta du Saloum, consisting of mangrove forests, saline channels, lagoons, islands and islets; and the Reserve Naturelle Communautaire de Toc Toc (tentative); a permanent coastal lake that supports over 98 fish species.48

Agriculture. Agriculture, including terrestrial crops and wild fisheries, is the driving force of the economy in Senegal; almost 80 percent of the population relies on these sectors as their main source of employment and income. Rain-fed cereal crops occupy most of the cultivated land during the growing season. They are mainly intended for self-consumption and are very sensitive to climate shocks. The main terrestrial cash crops are peanuts and cotton. Agronomic potential has been seriously altered by population dynamics, the expansion and practice of extensive farming with slash burning, drought, bush fires, and the disappearance of plant cover. Terrestrial agriculture – its use of fertilizers and diversion of environmental water flows – poses serious threats to marine biodiversity and the health of coastal habitats such as the productive deltas and estuaries. 49

Cotton production. Conventional cotton production has been practiced in Senegal since the 1960s in the regions of Kaolack, Kolda, and Tambocounda. Cotton is Senegal’s second most important crop after groundnuts. Since 1974, cotton production has been overseen by Société de Développement des Fibres Textiles (SODEFITEX), which provides support to market services including credit, inputs, ginning, marketing, and some rural infrastructure and support programs. Significant value is added to the seed through in-country processing and resale. Senegal cotton production zones are primarily in the southeast of the country, an area that has historically had good rainfall but experienced variability recently.50

Pesticide-related Environmental Policy. The primary groups that oversee food safety regulations, phytosanitary measures, and the control of crop and animal pests and diseases are: the Directorate of Domestic Trade; the Senegalese Standards Association through its Division of Phytosanitary and Quality Control; and the Directorate of Plant Protection, which enforces the application of measures and standards related to plant protection, pest control, and the prevention of plant quarantine diseases.

There is also the Permanent Interstates Committee for Drought Control in the Sahel (CILSS), which has established a common pesticide registration regulation that covers Senegal, Burkina Faso, Cape Verde, Chad, Guinea Bissau, The Gambia, Mauritania, and Niger. This regulation covers all pesticides entering the Sahel through a committee of experts, the Sahelian Pesticide Committee.

Senegal is party to the Codex Alimentarius pesticide residue standards, and Senegal has several specific national standards on food safety that specifically ban the sale or distribution of certain agrochemicals.

Senegal’s Directorate for the Protection of Vegetation maintains the list of approved and banned pesticides and also manages registration and acceptance. Any new livestock breeds, pesticides, and veterinary 48 USAID/Senegal ETOA, 2015

49 Excerpt from Senegal 4A IEE, 2016 50

41

pharmaceuticals must be officially approved by the Ministry of Livestock or Agriculture, and the Senegalese Institute for Agricultural Research tests each new seed and pesticide released to markets. 51

51 Private-Sector Agricultural Research and Innovation in Senegal, July 2011; accessed via the internet on 4/18/2016 at: http://www.asti.cgiar.org/pdf/private-sector/Senegal-PS-Report.pdf

42

5. COTTON PESTICIDE USE RISK ANALYSIS

5.1 KNOWN PESTICIDE RISKS IN THE COTTON SECTOR

There are many websites that detail well-documented pesticide risks in the cotton sector. According to Organic Cotton52 and World Wildlife Fund53 (WWF), for example, cotton is usually grown in monoculture, which is conducive to the spread of pests and diseases; it is a very pesticide-intensive crop; and 73% of cotton around the world is irrigated. Worldwide, cotton farmers use 16% of all pesticides combined, with 24% of all the insecticides and 6.8% of all herbicides used. This is despite the fact that cotton is grown on only ~2.5% of the world’s arable land. Defoliants, desiccants, and growth regulators are used in agricultural production to accelerate the preparation of crops for harvest. Applied pesticides can easily contaminate catchment bodies of water that irrigation and runoff waters enter. Pesticide risks on cotton are well known in most countries that grow cotton, including India54, Mozambique55, Senegal56, and Pakistan57. The following are risks from excessive pesticide use on cotton.

In the environment, cotton pesticides can:

• pollute rivers and groundwater • cause pests to quickly develop resistance if pesticides are used often • kill beneficial insects as well as predators and parasites that can control pests • lead to the outbreak of secondary pests usually controlled by predators and parasites • reduce biodiversity • cause soil degradation and loss of fertility

On the farm, cotton pesticides are used by or with:

• Focus on top-down extension efforts that promote calendar-based intensive applications of often hazardous insecticides

• Credit from state-supported cotton companies at the beginning of the growing season, to be deducted from the value of the sold cotton at the end of the season, on prices set by these companies.

• Poor or nonexistent pesticide import and safety enforcement as well as lack of sufficient funding from government ministries of agriculture, environment, or health;

• Smallholder farmers, workers on medium and large scale farms, and other pesticide applicators who do not always wear PPE (assuming they wear basic long-sleeved shirts and pants to protect their skin);

52 http://organiccotton.org/oc/Cotton-general/Impact-of-cotton/Risk-of-cotton-farming.php; http://documents.worldbank.org/curated/en/2015/09/25022147/senegal-agricultural-sector-risk-assessment

53 http://wwf.panda.org/about_our_earth/about_freshwater/freshwater_problems/thirsty_crops/cotton/

54 http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2984095/

55 http://www.jstor.org/stable/40376220?seq=1#page_scan_tab_contents

56 http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3928884/

57 http://www.slideshare.net/sanaullahnoonari/economic-evaluation-and-risk-analysis-ofintegrated-pest-management-ipm-in-cotton-pakistan

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• Cheap counterfeit or fake pesticides wasting farmers’ money; • Farmers applying pesticides at the hottest time of day when PPE and long-sleeved shirts and pants

are extremely uncomfortable; • Limited technical assistance to implement IPM theory or principles; • In some cases, the limited ability of smallholder farmers or other users to read or comprehend

pesticide labels and safety warning pictograms due to illiteracy, lack of training, and labels being in a language other than what the farmers speak/read;

• Inability to correctly identify pests, especially small pests (thrips, whiteflies, aphids, leaf miners, spider mites) and microscopic pests (most fungal, bacterial, viral and rickettsial diseases), pest population levels, and economic thresholds;

• Inadequate knowledge of pesticides and their dangers, particularly long-term hazards and risks to environmental resources;

• Potential for misuse of pesticides by not following the label instructions or dosages; • Lack of understanding how to properly calibrate a backpack sprayer; • Use of pesticides by children and pregnant women; • Unsafe modes of storage (for instance, in the home with exposure to children), transportation,

handling, and disposal of pesticides; • Lack of reliable pesticide analytical facilities can limit the scope for testing foods in the marketplaces

for safety.

5.2 RISK MITIGATION BY INTERNATIONAL ORGANIZATIONS

FAO Farmer Field Schools (FFS). The FAO FFS training program concept (Annex 3) has been used in southern Mali to promote IPM. It has reduced (by 93%)58 use of hazardous pesticides and reduced many of the above risks and negative impacts. The FFS program has also been implemented in India59, Mozambique60, and Senegal61. In Pakistan62, in less than 10 years the FFS program for cotton increased the use of IPM tools and decreased the use of and reliance on pesticides. Dr. Ahmad, director of the National IPM Program says “Our national data shows a dramatic decline in pesticide use in Pakistan. Farmers are making more profit, and a government study shows a 10% increase in cotton production thanks to IPM.”

USAID West Africa Cotton Improvement Program (WACIP). From 2006 to 2013, USAID West Africa Mission supported the WACIP program. According to USAID, https://www.usaid.gov/west-africa-regional/press-releases/usaid-improve-cotton-farmers-incomes-and-food-security, WACIP has, after seven years “...successfully completed its activities to reduce poverty and hunger by helping increase both cotton farmers' incomes and the added value of cotton processed by artisans and ginners. The program, implemented by the International Fertilizer Development Center, supported the cotton sectors in Benin, Burkina Faso, Chad and commonly known as the C-4 countries, plus Senegal.”

58 http://rstb.royalsocietypublishing.org/content/369/1639/20120277 ; http://www.fao.org/news/story/en/item/214049/icode/

59 http://base.d-p-h.info/en/fiches/dph/fiche-dph-8085.html

60 https://blogs.state.gov/stories/2015/01/16/farmer-field-school-enhances-food-security-mozambique

61 http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3928884/

62 http://infochangeindia.org/agriculture/stories-of-change/farmer-field-schools-rid-pakistans-cotton-fields-of-pesticides.html

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The program focused on the dissemination of good agricultural practices (GAP), integrated pest management, and integrated soil fertility management in the C-4 countries. By applying sustainable techniques, producers are able to substantially increase the productivity of cotton in combination with rotational crops (such as maize and cowpeas). WACIP demonstrated that, if the appropriate agricultural techniques are applied, a farmer's income can rise between 30% and 50%.

Among its key accomplishments, WACIP achieved the following:

• Increased yields for seed cotton (17%), maize (18%), and cowpeas (31%) for almost 76,000 WACIP supported farms.

• Increased gross margins (returns) per hectare for seed cotton (43%), maize (7%), and cowpeas (153%) for WACIP supported farms.

• Trained over 1,100 extension agents and more than 900,000 farmers.”

In October of 2013, USAID WACIP held a regional forum titled Final Project Results and Perspectives on Cotton and Food Security in West Africa. The forum brought together U.S. experts and representatives of West Africa regional organizations to review the impact of the diffusion of GAP (including IPM tools and training), share experiences, and exchange information on agricultural policies related to climate change and food security of member states.

Clearly, the goal of encouraging cotton farmers to use IPM tools and tactics, with less and more careful use of pesticides and improved safety, has been aided by FAO and USAID, among other donors and actors.

5.3 ORGANIC COTTON INITIATIVES

Only 0.8 per cent of world cotton production is organic. Initiatives for growing organic cotton are active in Senegal. 63 Organic cotton is beginning to play a dynamic role in the larger scheme of Indian agriculture, despite the negligible percentage of land under organic cotton (~3%) compared to conventional cotton and the steady increase in Genetically Modified (GM) cotton. In Pakistan, organic cotton is produced in the Baluchistan province, neighboring to the West of the Sindh region. 64 Projects have been underway in Mozambique that produced marketable amounts of organic cotton.65

Risk mitigation by Better Cotton Initiative (BCI)

To reduce use of pesticides and their risks, BCI’s Production Principles and Criteria incorporate IPM practices. Rather than employing a specific set of rules, BCI considers IPM as the fundamental guiding approach to how a cotton farmer should protect their cotton crop from the many and varied pests that attack it. BCI adheres to the following principles in its IPM programs:

63 http://www.pan-germany.org/download/cotton/YNW_leaflet_gbr.pdf

64 http://farmhub.textileexchange.org/learning-zone/growing-regions/south-asia

65 http://www.pan-uk.org/pestnews/Issue/pn38/pn38p12.htm

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• The interests of, and impacts on, producers, society and the environment are taken into account in the choice of crop protection techniques, such as the potential health and environmental impacts of pesticide use, and the need to manage genetically modified varieties to prevent resistant insect and/or weed populations, and the risk of cross-fertilization of any neighboring cotton that is not genetically modified;

• A range of pest control strategies should be used in an integrated manner, with no single strategy (particularly pesticide application) relied on to excess, and both preventative and curative measures are used;

• The presence of pests should not automatically lead farmers to apply control measures; • When control of pests becomes necessary, non-chemical pest control methods should be considered

first; the use of pesticides (especially those with broad spectrum activity) should be seen as a last resort.

The objectives/benefits of implementing IPM include:

• Reduced use of pesticides and subsequent reduced risk to human health and the environment; • Use of a wider range of control techniques and reduced reliance on a single method of pest control,

leading to a more resilient approach to crop protection.

The specific techniques that can be implemented in any one farmer’s field will depend upon a range of agro-climatic, seasonal, socio-economic and political factors, and BCI will not endeavor to prescribe what these should be. The identification and promotion of the specific and most appropriate pest management techniques suitable in a given location is best left to local experts. Nevertheless, there is a range of broad strategies available, examples of which are provided here to help characterize what field-level practices might be included within a BCI IPM program:

• Preserving and enhancing populations of beneficial organisms; tactics include planting refuge crops and intercrops that provide habitat for beneficial animal species;

• use of attractants to attract natural pest predators; • release of beneficial insects; • choosing the least disruptive insecticide (e.g., a narrow-spectrum pesticide) if this type of control is

deemed necessary; • maintaining on-farm habitat biodiversity; • Preventing pest population build-up; tactics include rotating crpos to break pest and disease cycles; • keeping the farm weed-free; avoiding planting crops that host pests; • Ensuring a healthy crop that can withstand some degree of damage; tactics include good soil and bed

preparation; choice of appropriate plant varieties and planting dates; appropriate water and nutrition management; and harvest management and timing;

• Regular monitoring of the crop for pests, beneficial insects, and crop damage, in conjunction with the use of appropriate pest thresholds so that some crop damage can be tolerated;

• Management of resistance; tactics include rotation of insecticide groups; adopting pest and damage thresholds; limiting the total number of applications of any one class of insecticide; using trap crops; using mechanical means to control pests (e.g., destroying overwintering pupae through cultivation); selecting insecticides that are least disruptive to beneficial insects;

• Managing the crop to early maturity to reduce the length of time the crop is exposed to pests,

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especially late-season pests; • Using non-chemical means of control; tactics include encouraging bird and bat species that act as

predators to cotton pest populations; using pheromones; • Using border crops (e.g. maize and sorghum) around cotton fields to provide a physical barrier to

pests and to mask the odors given off by cotton plants.

Finally, when pesticides are promoted or used, they must be: (i) registered nationally for the crop being treated; and (ii) correctly labeled in the national language.

In addition to BCI’s extensive efforts to promote IPM, this PERSUAP analysis has collected and listed the primary pests and diseases of cotton in Annex 1 and has researched preventive IPM tools and tactics as well as pesticides recommended in the United States.

5.4 BCI PROPOSED PESTICIDES FOR ANALYSIS

In 2014, BCI surveyed beneficiary cotton farmers in its target countries for pesticides used. This list of pesticides that are actually used by BCI beneficiaries is a reflection of demand, availability, and affordability (otherwise the pesticides would not be used). The analyses in this PERSUAP were restricted to the list of pesticides that BCI beneficiary cotton farmers actually use. The authors of this PERSUAP adopted this approach because it is more practical to consider BCI’s list than any complete list of pesticides currently registered in each country, many of which would never be used on cotton, and some of which would not be available or affordable. The list of pesticides proposed for analysis is attached as Annex 4.

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6. SECTION 6: THE PESTICIDE EVALUATION REPORT 12 FACTOR ANALYSIS REQUIRED BY 22 CFR 216.3(B)

FACTOR A: US EPA REGISTRATION STATUS OF THE PROPOSED PESTICIDES

Each of the four target countries has a complete regulatory framework for safe use, evaluation, and registration of pesticides; and each registers new pesticides at least once per year. Unfortunately, none of the target countries has sufficient resources for adequate enforcement of the regulations and registrations. Furthermore, counterfeit and fake pesticides with the exact same or similar product names and (supposed) concentrations and formulations are common in all emerging market countries. For this analysis, BCI provided the latest (2015 or 2016) lists of pesticides registered in each target country.

In the United States, the EPA regulates pesticides through the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), as amended. USAID-funded programs are limited to procuring, using, and/or supporting the use of pesticides containing active ingredients and/or products registered by the US EPA for the same or similar uses. Emphasis is placed on “similar use” because some crops and their pest species found overseas are not present in the United States. Therefore, pesticides might not be registered for the “exact” use anticipated by the USAID project.

The US EPA also designates some products as Restricted Use Pesticides (RUPs), i.e., pesticides that might be hazardous to human health or to the environment even when used according to the label. In the United States, the pesticides and active ingredients that are labeled RUP may only be sold to and used by certified applicators or persons under their direct supervision and only for the purposes covered by the applicator's certification (e.g., for row crops, tree crops, or structural pests).

22 CFR 216 requires a full scoping statement and environmental assessment (EA) before use of a RUP can be supported with USAID funds, except in cases when RUPs are so designated solely for reason of user hazard. RUPs designated solely for reason of user hazard can be authorized for procurement or use with USAID funding on the basis of a user hazard analysis in the EA. In such a case, the recipient government must be made aware of the hazard, and a mitigation action will be made and implemented with additional technical assistance.

Because of the low level of beneficiary pesticide knowledge and awareness in the four target countries, it would not be appropriate to authorize USAID funds to support RUPs as part of the Better Cotton Initiative. Risks are too high. Under this Factor A analysis, pesticides are rejected not only when they are not EPA registered but also when they are RUP for the same or similar uses on cotton.

The matrix in Annex 5 shows the US EPA registration and restriction status (RUP) of all pesticides approved by this Factor A analysis for use on cotton. Pesticide AIs rejected by this analysis are listed in Annex 6, with the reason(s) for rejection.

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FACTOR B: BASIS FOR SELECTION OF PESTICIDES

In general, best practice and USAID policy recommend that the least toxic pesticide that is effective is approved for use by the beneficiary, if they understand and can afford the least toxic option. USAID projects strive to support pesticides with the lowest human and environmental risk profiles. As discussed above, USAID requires, at a minimum, that proposed pesticides must be registered by the US EPA. For this PER analysis, the following additional criteria were applied to develop the final list of approved pesticides:

US EPA Registration and Restriction Status (discussed under Factor A above). Pesticides must have active registration in the United States for the same or similar crops, pests, diseases and weeds, without restriction (RUP).

Pesticide registration in the host country. Pesticides must also be registered in the host country and host-country regulations for use must be followed.

USEPA Acute Toxicity Category I or WHO Acute Toxicity Classification Ia or Ib. Pesticides with these ratings are rejected because they have known toxicity of sufficient concern to eliminate them from further consideration. No USEPA/WHO Category/Class I AIs are advanced for approval in this PERSUAP.

Toxicity and Safety. Pesticide selection must be appropriate not only to the cotton context in the four target countries but also to the targeted cotton beneficiaries, pests and diseases, and local conditions. In general, as noted above, the context is characterized by the on-farm and environmental risks compiled above, under Section 3.

WHO Versus US EPA Acute Toxicity. The World Health Organization (WHO) classifies pesticide toxicity according to pure concentrated AI, whereas EPA classifies toxicity based upon the product, which usually contains a diluted concentration of AI and a specific formulation that can decrease or increase toxicity. Although most developing countries without resources to analyze toxicity themselves use WHO toxicity classifications as selection criteria – and this PERSUAP also considers WHO toxicity classifications – this PERSUAP also considers and presents US EPA acute toxicity because it is more precise and is based upon EPA’s decisions, which Regulation 216 must follow.

International Conventions Banning or Severely Restricting Pesticides. This PER analysis rejects AIs that are internationally classified as Persistent Organic Pollutants (POPs) or as Prior Informed Consent (PIC) chemicals by the Stockholm and Rotterdam Conventions, respectively.

Other known toxicity of sufficient concern. No known carcinogens are advanced for approval in this PERSUAP.

Need. Pesticides must serve a known pest management need for target BCI activities. Both current and potential future needs are considered by this PERSUAP.

Efficacy in local circumstances. Pesticides must be shown to be efficacious for controlling targeted pests and diseases under climates/conditions similar to those found in the four target countries. Efficacy information, as available, is collected by this PERSUAP study for the four target countries.

Local Registration and Availability. As noted above, pesticides supported with USAID funds must be registered legally in the host country, if such registration exists. In addition, it is worth noting that pesticide companies often register more pesticide products than there are current markets or demand for, on the chance that demand or markets will open in the future, having already completed the often lengthy (up to 2-3

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years) registration process. Then, when a market does appear, the product is already (pre-)registered, reducing potential delays to be able to import and sell the product.

Thus, in order for USAID to approve a pesticide product for potential beneficiary use, it has to be available to farmers on local markets or known to be imminently available.

Affordability. There is no sense recommending certain pesticides to smallholder farmers if they cannot afford them. Many of the newer, safer, better-targeted (narrow-spectrum) pesticides are relatively expensive. Unless subsidized somehow, resource-challenged smallholders will be left with the options of buying the cheaper generic products that have been on markets for years, that have lost their patents and thus are cheaper, and that are generally broad-spectrum, causing more harm to non-target organisms and the environment.

FACTOR C: EXTENT TO WHICH THE PROPOSED PESTICIDE USE IS PART OF AN IPM PROGRAM

BCI already promotes IPM practices as part of its primary mandate. BCI has adopted FAO’s definition of IPM as given in the International Code of Conduct on the Distribution and Use of Pesticides (Revised Version, 2002):

Integrated Pest Management means the careful consideration of all available pest control techniques and subsequent integration of appropriate measures that discourage the development of pest populations and keep pesticides and other interventions to levels that are economically justified and reduce or minimize risks to human health and the environment. IPM emphasizes the growth of a healthy crop with the least possible disruption to agro-ecosystems and encourages natural pest control mechanisms.

IPM also requires an integrated approach to its implementation – integration of the technical knowledge appropriate in any given field situation on how to manage a pest with appropriate social processes for developing, sharing, and imparting that knowledge so that farmers can make informed pest management decisions.

As noted above in Section 3, BCI has a large list of IPM principles and criteria that it follows in target countries, placing them largely in control of and compliant with this issue. Additionally, Annex 1 shows a complete range of IPM tools and tactics (including pesticide AIs approved by this PERSUAP) that cotton extension systems and farmers in other countries currently use, which can be shared with, tried, and adopted by BCI beneficiary farmers.

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FACTOR D: PROPOSED METHOD OR METHODS OF APPLICATION, INCLUDING THE AVAILABILITY OF APPLICATION AND SAFETY EQUIPMENT

To get good results without using excessive pesticides, varied application methods are appropriate. The methods selected will depend on the various types of the crops/pests, activities, and pesticide formulations. However, methods of applying any given pesticide must be always consistent with the pesticide label.66 Most smallholder farmers will apply pesticides using plastic hand-pumped backpack sprayers. Most of these sprayers will eventually develop leaks at joints where various pieces are fitted together.

Personal protective equipment such as masks, boots, gloves, and goggles are more commonly available than items such as waterproof aprons, full face shields, and coveralls. However, available masks are usually paper dust masks that protect only against larger particles. Proper carbon-filter respirators used against pesticide vapors or volatile components are not as commonly available on the market or are not affordable. Most smallholder farmers and other users rarely use full safety equipment, and they rarely comply with product labels regarding safety gear.

Frequently, the reasons that farmers and pesticide applicators in developing countries give for not wearing safety equipment are that it is uncomfortable for use in high heat and humidity, and it is too costly. Also, many farmers do not understand the risks associated with exposure to pesticides, particularly environmental hazards and potential impacts of chronic exposure. When farmers and pesticide applicators in developing countries do use safety equipment, they most commonly use only gloves and boots.

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

Annex 5 summarizes the toxicological profile of the full list of pesticides approved for use. For situations in which the IP has direct control over pesticide use, they are required to implement or observe core risk mitigation measures identified by the product label and the extended information pesticide profiles available on the Materials Safety Data Sheet (MSDS). If MSDSs are not available in-country from dealers, they can be readily found online or requested from the manufacturer.

In some cases, the MSDS for a similar product with the same AI, concentration and formulation can be substituted for the product used (although exact formulation is likely to vary). In situations in which IP oversight is limited, they will be required to take all practicable measures to support and promote implementation of these safety measures. The toxicological information in Annex 5 and supplemented by additional information on pesticide labels and profiles in MSDSs allows screening of the candidate pesticides against additional criteria enumerated under Factor B—Basis for selection of the pesticide.

66 http://www.extension.umn.edu/agriculture/pesticide-safety/ppat_manual/Chapter%209.pdf

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Before registering a pesticide product and allowing a manufacturer to bring their product to the market, an assigned government agency (the EPA in the United States) evaluates product toxicity. Potential registrants must generate scientific data necessary to address concerns pertaining to the identity, composition, potential adverse effects, and environmental fate, as well as human acute, sub-chronic, and chronic effects of each pesticide.

Acute effects are harmful effects in an organism through a single or short-term exposure and include oral (ingestion), dermal (skin) toxicity and irritation, skin sensitization (an allergic response following skin contact), inhalation, and eye irritation. The usual expression of acute toxicity is LD50, which is the average lethal dose relative to body weight (mg/kg) required to kill 50 percent of a test population. Toxicity tests are conducted on experimental animals such as rats, mice, and rabbits. Because toxicity depends upon body weight, the amount of chemical lethal to a child is less than the amount lethal to an adult. Similarly, it takes more to kill a large animal than a small one.

The ‘signal’ word (e.g. Danger, Warning, and Caution) on the pesticide label applies to the most toxic method or route of exposure. Generally, if ingested, class I substances can be lethal to an average-sized adult person at a dose of less than 5 g (0.18 oz.), Class II at 5 - 30 g (0.18 - 1.058 oz.), and Class III at more than 30 g (1.058 oz.).67 The table below provides details on US EPA acute toxicity categories I to IV for pesticide products.

Important differences between EPA and WHO acute toxicity classifications

It is important to note that WHO uses a similar acute toxicity categorization system, except that it provides acute toxicity for concentrated pesticide AIs, not products. In addition, WHO has divided EPA’s Class I into Classes Ia and Ib for extremely and highly hazardous chemicals, respectively; and EPA’s Class 4 is replaced by WHO’s Class U, for ‘Unlikely to pose an acute hazard in normal use’. Further, WHO does not provide acute toxicity for fumigants, whereas EPA does.

TABLE 1. US EPA TOXICITY CATEGORIES

STUDY CATEGORY I CATEGORY II CATEGORY III CATEGORY IV

Acute oral Up to and including 50 mg/kg >50 through 500 mg/kg

>500 through 5,000 mg/kg

>5,000 mg/kg

Acute dermal Up to and including 200 mg/kg >200 through 2,000 mg/kg

>2,000 through 5,000 mg/kg

>5,000 mg/kg

Acute inhalation (based on 4 hour exposure)

Up to and including 0.05 mg/L >0.05 through 0.5 mg/L

>0.5 through 2 mg/L >2 mg/L

Primary eye irritation

Corrosive (irreversible destruction of ocular tissue) or corneal involvement or irritation persisting for more than 21 days

Corneal involvement or other eye irritation clearing in 8-21 days

Corneal involvement or other eye irritation clearing in 7 days or less

Minimal effects clearing in less than 24 hours

67 http://sitem.herts.ac.uk/aeru/ppdb/en/docs/Background_and_Support.pdf

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TABLE 1. US EPA TOXICITY CATEGORIES

STUDY CATEGORY I CATEGORY II CATEGORY III CATEGORY IV

Primary skin irritation

Corrosive (tissue destruction into the dermis and/or scarring)

Severe irritation at 72 hours (severe erythema or edema)

Moderate irritation at 72 hours (moderate erythema)

Mild or slight irritation at 72 hours (no irritation or slight erythema)

A toxic substance has sub-chronic effects when it causes effects for more than one year but less than the lifetime of the exposed organism. A toxic substance or mixture has chronic effects when it causes harmful effects over an extended period, usually upon repeated or continuous exposure, sometimes lasting for the entire life of the exposed organism. Chronic toxicity tests include tests for carcinogenicity, mutagenicity, reproductive and developmental toxicity, neurotoxicity, and general metabolism studies.

Ecological toxicity includes the potential for air, water and soil pollution, and effect on non-target organisms including mammals, birds, aquatic organisms, sometimes amphibians and reptiles, non-target insects, and non-target plants. All products with acute toxicity class I (Red Label, Words Danger-Poison, skull and crossbones on the pictogram) are rejected by this PERSUAP.68 In countries where trained professionals are available for proper pesticide application of products with acute toxicity class I, these products could be approved, but for smallholder farmers usually they are not approved.

FACTOR F: EFFECTIVENESS OF THE REQUESTED PESTICIDES FOR THE PROPOSED USE

Pest management needs are documented on a crop-by-crop and pest-by-pest basis in Annex 1. For each crop, the tables in Annex 1 identify pest-specific suggested controls. Together, these strategies offer a high degree of assurance that the pesticides will be effective for their proposed use:

1. The proposed pesticide uses are consistent with their US EPA registrations; in each case, US EPA has registered these pesticides for use on the same or similar crops and against the same or similar pests. Such registration requires that the effectiveness of the pesticides be demonstrated. This demonstration of effectiveness is within the U.S. agro-environmental context.

2. Resistance action committees have been established by the pesticide industry to track the development of resistance of key pests. Those websites are discussed and footnoted below and were used to cross-check information for this PERSUAP.

3. Each of the recommended uses has been cross-checked against information provided by pesticide label, and registration and label information was supplemented from published literature or recommendations available from other countries, as well as from online searches.

At some point, project field staff and farmers may begin to note that some products no longer work well to control pests in the field and will likely begin to blame pesticide manufacturers for a weak product. This could be due to the use of cheap generic products, improper dosing, or the development of pest resistance.

68"Hazard Communication Standard Pictogram." Hazard Communication Standard Pictogram. United States Department of Labor, https://www.osha.gov/Publications/HazComm_QuickCard_Pictogram.html

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Farmers should be trained to understand the development of pest resistance, and project implementers should be on the lookout for pest resistance during field visits.

A resistance management strategy should also consider cross-resistance between pesticides with different modes/target sites of action. Pests may develop cross-resistance to pesticides based on mode/target site of action. The website http://www.pesticideresistance.com/ can be used to search for known resistance issues in countries with certain pest or disease resistance to specific pesticide AIs.

If pesticide use is warranted and a risk of pesticide resistance development is identified, a Resistance Risk Management approach should be followed. The following section details points of concern for both application equipment and pesticide applications.

Ways to address and manage or mitigate pest resistance:

• Use IPM to minimize pesticide use: Minimizing pesticide use is fundamental to pesticide resistance management. IPM programs incorporating pest monitoring in USA states of California, New York, and Maryland, and in Canada have demonstrated 25% to 50% reduction in pesticide use with an increase in crop quality. IPM programs will help determine the best application timing for pesticides (when they will do the most good), thus helping to reduce the number of applications. The use of nonchemical strategies, such as pest exclusion (e.g., screening, micro tunnels, greenhouses), host-free periods, crop rotation, biological control, and weed control may reduce the need to use chemicals and consequently slow the development of pesticide resistance.

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

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

• Use Long-term Pesticide Rotations: Resistance management strategies for insects, weeds, and fungal pathogens all include rotating classes of pesticides. Pesticides with the same modes of action have been assigned group numbers by their respective pesticide resistance action committees, Insecticide Resistance Action Committee (IRAC)69, Fungicide Resistance Action Committee (FRAC)70, and Herbicide Resistance Action Committee (HRAC)71. These group numbers have been included in the treatment tables of these committee’s guidelines (see foot-noted websites, below) to help clarify which pesticides can be rotated.

• The strategies used for rotations differ by type of pesticide: For example, with fungicides,

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

70 http://www.frac.info/

71 http://www.hracglobal.com/

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

In general, development of resistance is a key threat to pesticide effectiveness. The introduction of pesticides and continuous use over time enhances the probability that resistance will develop. The use of pesticides within an IPM framework, as required by this PERSUAP, is a key measure to prevent or slow the development of pest resistance.

Monitoring by IPs and beneficiaries is required to confirm that the pesticides being recommended will perform as expected. Evaluation of pesticide efficacy (and of pest management plans more generally) is an essential part of demonstration plot management. Monitoring for and reporting of resistance development is a recommended element of SUAP compliance reporting. Counterfeit or obsolete products and product adulteration by pesticide sellers should be addressed by current programs through building awareness among farmers and the introduction of programs promoting quality control (including proper management of expired products).

The following cotton pests are known to have developed resistance to some types of pesticides:

• Stinkbugs (Euschistus Heros) have developed resistance to carbamates and organophosphates • Cotton Bollworms (Helicoverpa armigera) have developed resistance to some carbamates,

organophosphates, and pyrethroids/pyrethrins. • Tobacco budworm (Heliothis virescens) has developed resistance to BT toxin • There is some resistance of cotton whitefly (Bemisia tabaci) to buprofezin • Some mites are somewhat resistant to abamectin

FACTOR G: COMPATIBILITY OF THE PROPOSED PESTICIDE USE WITH TARGET AND NON-TARGET ECOSYSTEMS

Over 98 percent of sprayed insecticides and 95 percent of herbicides reach a destination other than their target species because they are sprayed or spread across entire agricultural fields. Runoff can carry pesticides into aquatic environments while wind can carry them to other fields, grazing areas, human settlements, and undeveloped areas, potentially affecting other species.

Each pesticide, or pesticide class, comes with a specific set of environmental concerns.72 Some pesticides result in detrimental impacts to birds, beneficial insects, fish, and / or animals. Before applying a pesticide, it is important to become familiar with the area to be treated and its surroundings. Some pesticides are less "environmentally friendly" than others and may not be selected for sites with special concerns.

72 Originally published in 1987 as Pesticide Use and the Environment, Nevada Pesticide Applicator’s Certification Workbook, SP‐87‐07, by W. Johnson, J. Knight, C. Moses, J. Carpenter, and R. Wilson. Updated in 2012 by M. Hefner and S. Donaldson, University of Nevada Cooperative Extension, and J. Carpenter, Nevada Department of Agriculture. http://www.unce.unr.edu/programs/sites/pesticide/files/pdf/PesticideUseAndEnvironment.pdf

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Pesticides in soil. When pesticides are applied in the field, the effect of soil-applied pesticides can sometimes be short-lived. In fact, in some instances they may enhance the population of certain soil organisms. Soil organisms are responsible for contributing to the decomposition of dead animal and plant material into organic matter, which is an important component of soil. Other soil organisms can be involved in the natural control of soil pests. Aside from their direct effects on pest organisms, soil microbes are a major agent in degrading pesticides. The breakdown of pesticides is beneficial from a crop rotation standpoint and for food residue concerns. It also provides herbicide selectivity in some instances. The value of certain soil bacteria that have a symbiotic relationship with leguminous plants in fixing nitrogen translates into reduced synthetic nitrogen fertilizer inputs and increased crop yields.

Chemical degradation of pesticides in soils is governed by a variety of factors, such as pH, presence of water, and the presence of various catalysts and reagents capable of attacking reactive compounds. Many insecticides have been shown to undergo photoreactions to form products that are either more toxic or less toxic than the parent compounds.73

Pesticide drift. Pesticide dust or droplets can drift through the air at the time of application or soon after to sites other than the area intended. Pesticide droplets are produced by spray nozzles used in application equipment for spraying pesticides on crops and home gardens. Pesticide drift can pose health risks when sprays and dusts are carried by the wind and deposited on other areas such as nearby homes and schools, adjacent fields, water bodies, wildlife, and plants.74

Effect on non-target terrestrial organisms. Animals and humans can be poisoned by pesticide residues that remain on food. Poisoning can occur when wild animals or people enter sprayed fields or nearby areas shortly after spraying. Reductions in bird populations have been found to be associated with periods and areas in which pesticides are used. Granular formulations have been found most toxic to birds when they mistake the granules for food. Pesticides also affect birds indirectly by reducing food sources. Wild bees, certain wasps, honeybees, and other insects are important pollinating agents of crops. Some pesticides are harmful to these pollinators, causing direct losses of the insect populations and indirect losses of crop yield because of the lack of adequate pollination. Pesticides can be harmful to other beneficial organisms that include various insects, mites, nematodes, fungi, bacteria, and other microorganisms that feed on or parasitize pest species. There are several different classes of pesticides that have a wide range of toxicity to honey bees. Neonicotinoids are the group of pesticides most commonly implicated as a contributing cause of widespread honey bee losses, both through direct toxic action and chronic effects on the immune system. Organophosphate compounds have a wide range of toxicity levels on bees. Pyrethroids are toxic to bees, but Insect Growth Regulators have been found to have low toxicity levels on bees.75

Surface water pollution. Pesticides can pollute surface water and have adverse effects on people and animals drinking this water as well as adverse effects on fish, aquatic invertebrates, and aquatic plants. Fish and other aquatic biota may be harmed by pesticide-contaminated water. Amphibians have permeable skin that is highly absorbent, making them extremely susceptible to pesticides. Pesticides can also harm beneficial aquatic insects that prey on pests.

73 Perry, A.S., and R.Y. Perry. "Effects in Arid Regions." John Wiley & Sons Ltd, 1989. Web. 18 Aug. 2015. http://dge.stanford.edu/SCOPE/SCOPE_38/SCOPE_38_4.2_Perry_155-194.pdf .

74 http://www2.epa.gov/reducing-pesticide-drift/introduction-pesticide-drift

75 "Types of Pesticides." Types of Pesticides. Web. 18 Aug. 2015. http://www.pollinator.ca/canpolin/typesofpesticides.html .

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Marine pollution. Pollution to the marine environment can come from land and air sources. Pesticide pollution can impact marine life, mangrove forests, and people.

Groundwater pollution. Pesticides that are mobile in soil may pollute groundwater. Leaching occurrences into the groundwater will depend on type of pesticide used, soil texture, pattern of pesticide use, amount of organic matter in the soil, and depth of the water table.

Humid and arid ecosystems. Pest management in humid areas is more complex than in arid ecosystems because of the greater number of pests that need to be controlled. Most agricultural practices are similar in humid and arid areas, except water and pest management frequency of application and pest control complexity.

Fungicides. Some fungicides can irritate skin and eyes, while others may cause throat irritation and coughing when inhaled. Prolonged inhalation of certain fungicides can cause neural and visual disturbances. The long-term effects of fungicides on humans are still unknown, but some may be mutagenic - permanently silencing or reprogramming normal genes, with the effect possibly lasting several generations.76 Pesticides can cause harm to a fetus or embryo during pregnancy, causing birth defects, while the mother shows no signs of toxicity. Pregnant and lactating women must be informed not to handle pesticides determined or suspected to cause reproductive and developmental harm, e.g., birth defects and impairment of normal growth and development.

Regular use of fungicides can potentially pose a risk to the environment, particularly if residues persist in the soil or migrate off-site and enter waterways. Reading the MSDS and the label is of utmost importance for minimizing adverse impacts of pesticides on human health and the environment.

Herbicides. Some surfactants in herbicide formulations can be toxic to mammals (including humans). Some herbicide products have the signal words “Danger-Corrosive” or “Danger-Poison” on the label. Herbicides with these signal words are not approved for use of this PERSUAP. “Warning” also appears as a signal word for herbicides with label statements indicating that they can cause eye or skin irritation or burns or may be harmful if swallowed, inhaled, or absorbed through the skin. Herbicides with the word “Caution” mean that the product has low oral, dermal, and inhalation toxicity and has little or no irritability to either the eyes or the skin.

Herbicides are believed to present a bigger concern because of their concentration in the water supply due to runoff from agricultural use. Herbicides can be slightly, moderately or highly toxic to aquatic organisms. They may cause reduction of sensitive species and abundance of tolerant species.98 Long term effects of concern include endocrine disruption and carcinogenicity. Resistance of weeds to herbicides is becoming a worldwide problem. All herbicide labels warn the user to keep the product out of lakes and streams. Many herbicides, including glyphosate, are carrying label statements about groundwater contamination. Care must be taken to ensure that such products are not used where groundwater contamination is likely.77

In 2015, glyphosate was identified as a potential carcinogen by US EPA, and the State of California became the first State to require labeling of glyphosate products such as Roundup as potential carcinogens. World Health Organization's research arm also recently found that the chemical is probably carcinogenic to humans and research has also linked glyphosate to the steep decline of monarch butterflies. Scientists have

76 http://www2.epa.gov/sites/production/files/documents/rmpp_6thed_ch16_fungicides.pdf

77 https://ipm.illinois.edu/pubs/iapmh/11chapter.pdf

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increasingly raised new alarms about potential negative health impacts tied to glyphosate, including a recent study suggesting that long-term exposure to tiny amounts of the chemical (thousands of times lower than what is allowed in drinking water in the US) could lead to liver and kidney problems.

Pesticides that are labeled as natural or organic are not necessarily harmless to humans or the environment. Many are quite safe, but some have hazards associated with them. Other problems can emerge from poor pesticide management practices. Over time, repeated application increases pest resistance, and effects on other species can facilitate resurgence of pest species.78

Toxicology Information. Annex 5 provides toxicology information for a range of non-target organisms: mammals, birds, fish, aquatic invertebrates, beneficial arthropods, honeybees, earthworms. The US EPA registration process requires that toxicity of a pesticide against each of these classes of organisms must be assessed by a standardized test.

Four basic chemical characteristics control pesticide movement in the environment: solubility, adsorption, volatility, and persistence. Solubility is the ability of a pesticide to dissolve in a solvent, usually water. Adsorption is the ability of a pesticide to bind with soil particles. Volatility is the ability of a pesticide to turn into a gas or vapor. Persistence is the ability of a pesticide to remain in its original active form and not break down into an inactive form.79

In addition to a pesticide’s toxicity level to non-target organisms, the solubility, adsorption, persistence, and volatility of a pesticide in the environment and its ultimate mobility (e.g., potential to enter groundwater, move and remain in soil and sediment, or stay in the air) strongly affect the significance of adverse effects on non-target organisms. Annex 5 provides additional information on this topic.

Issue: Most smallholder farmers do not understand pesticide ecotoxicity and pollution of the environment. Most pesticide container labels and MSDSs contain information on sensitive natural resources and how to reduce risks and protect them. Many farmers do not read or understand this information or know how to use it. Extension services can assist BCI with training farmers on how to read pesticide labels, particularly the pictograms that show pesticide risks, and how to mitigate risks with PPE and proper behaviors.

78 "Pesticides: Environmental Effects." EPA. Environmental Protection Agency. Web. 18 Aug. 2015. http://www.epa.gov/pesticides/ecosystem/ .

79 Originally published in 1987 as Pesticide Use and the Environment, Nevada Pesticide Applicator’s Certification Workbook, SP‐87‐07, by W. Johnson, J. Knight, C. Moses, J. Carpenter, and R. Wilson. Updated in 2012 by M. Hefner and S. Donaldson, University of Nevada Cooperative Extension, and J. Carpenter, Nevada Department of Agriculture. http://www.unce.unr.edu/programs/sites/pesticide/files/pdf/PesticideUseAndEnvironment.pdf

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FACTOR H: THE CONDITIONS UNDER WHICH THE PESTICIDE IS TO BE USED, INCLUDING CLIMATE, FLORA, FAUNA, GEOGRAPHY, HYDROLOGY, AND SOILS

In addition to covering biodiversity and protected areas under Factor G above, this requirement is meant to protect natural resources from the dangers of pesticide misuse and contamination, especially of surface and groundwater resources.

Protected areas, biodiversity and pesticides in the four target countries

Information on the geography, geology, topography, protected sites, soils, hydrology, marine resources, and pesticide issues are all well-covered above under Sections 2.3 and 3, above.

The key for BCI implementers is to overlay maps or the above natural resources with a map of their project locations to see the water resources and major types of soils that their beneficiaries are working with. Some soils are better than others at holding and detoxifying pesticides (see issue, below), while others lead to rapid leaching of pesticides to scarce and valuable groundwater resources.

Issue: Pesticides can adsorb (stick) to soil, later leaching and contaminating groundwater resources. Each pesticide has physical and chemical characteristics, such as solubility in water. Also each has an inherent ability to bind to soil particles and be held there (adsorbed). And each has a natural breakdown rate in nature. If they are strongly held by soil they do not enter the soil water interface and the ground water table as easily. A listing of these properties for at least some of the pesticides in use in the four target countries can be found by checking at this website: http://sitem.herts.ac.uk/aeru/ppdb/en/atoz.htm.

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

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

A pesticide’s ability to enter groundwater resources also depends on how quickly and by what means it is broken down and the distance (and thus time) needed to travel to reach groundwater. If the groundwater table is high, the risk that a pesticide will reach it before being broken down is increased. Thus, a sandy soil with a high water table is the most risky situation for groundwater contamination by pesticides. Groundwater pollution (contamination) potential for each pesticide active ingredient is provided in Annex 5, column 9.

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Since the risks for contamination of scarce water resources is high in much of BCI-supported projects, sub-grantees should investigate these factors of soil adsorption and solubility before choosing pesticides to promote or support for their beneficiaries.

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

Annex 1 contains numerous non-chemical control methods for major pests and diseases of cotton. It is recommended that BCI, their partners, sub-grantees, field extension staff and beneficiaries use this valuable resource, which compiles all known preventive IPM tools and tactics for each pest of cotton. It can be considered as a pullout, stand-alone section that can be reproduced as necessary, and should be considered for translation into local languages, lamination, and distribution to farm input supply companies to help advise farmers at point-of-purchase.

Natural pest controls availability

Some farmers produce their own artisanal or homemade pesticides, including extracts of neem tree seed, chili pepper, and garlic, in addition to mixtures of fire ash, cow manure, and urine as repellents.

FACTOR J: HOST COUNTRY’S ABILITY TO REGULATE OR CONTROL THE DISTRIBUTION, STORAGE, USE, AND DISPOSAL OF THE REQUESTED PESTICIDE

Each of the four target countries has an MOA with extension services present. However, risks to agriculture and from pesticides still exist in most cotton-producing countries, as noted under Section 2.3 for each country and Section 3, above. A complete set of IPM tools are not widely marketed, known, or used. Fake, counterfeit, and low quality pesticides are of particular concern.

Most emerging market countries like India, Pakistan, Mozambique and Senegal do not have sufficient resources to control import, sale and use of quality pesticides. These governments often lack the ability or the funds to monitor the quality of pesticides that require certified laboratories capable of testing registered pesticides for quantity and quality of AIs as well as their byproducts. Often, donors are left filling or assisting with these information and safety gaps in one way or the other.

FACTOR K: PROVISION FOR TRAINING OF USERS AND APPLICATORS

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

BCI’s national partners that support pesticide use will need to provide training in SPU and cotton GAP/IPM tools and tactics. These are important for project beneficiary farmers using pesticides (see Annex 7 for recommended training topics). Refresher trainings are one potential way for changing beneficiary farmer behaviors, especially as they expand their agricultural opportunities.

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FACTOR L: PROVISION MADE FOR MONITORING THE USE AND EFFECTIVENESS OF EACH PESTICIDE

Evaluating the risks, impacts and benefits of pesticide use should be an ongoing, dynamic process. Proper pesticide use and pest resistance are two of the risks that this factor is intended to address, as well as human health and safety and environmental effects.

On the farm, record keeping should track quantities and types of pesticides used, where they were used and what they were used for with notes on efficacy. Notes on effectiveness of individual pesticides and pest numbers will help develop a more sustainable pesticide use plan for USAID/GDL BCI agriculture sector, national partners and beneficiary farmers. Farmers should keep records of any reductions in pesticide efficacy experienced, which is the first indication that resistance may be developing, and then a strategy needs to be in place to determine a shift to a different pesticide class, and rotation among classes, to overcome resistance development.

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7. BCI’S PESTICIDE SAFER USE ACTION PLAN (SUAP)

7.1 INTRODUCTION TO SUAP

This Safer Use Action Plan (SUAP) is the definitive statement of the USAID/GDL BCI project’s pesticide compliance requirements for the four supported countries and is synthesized from the PER analysis:

• Immediately below it lists the allowed pesticides and required conditions that are summarized in the Executive Summary.

• The SUAP establishes field-monitoring requirements for compliance with safer use conditions for BCI staff and supported IPs or groups.

• Section 5.4 summarizes the recommended best practices and safer use conditions to be used/supported by BCI and supported IPs with these pesticides.

7.2 SUAP CONDITIONS

Approved pesticide AIs. Upon approval of this PERSUAP, the below-listed pesticide active ingredients (AIs) are permitted for use/support/promotion with USAID/GDL funds on BCI activities in the four target countries. This approval is subject to compliance with general conditions including no acute toxicity Class I products, no RUP products, following the pesticide container label and MSDS precautions, using appropriate Personal Protection Equipment (PPE), and any additional conditions listed for each AI in the Table below. BCI beneficiary cotton farmers in the four target countries are known to use the approved AIs listed below. The list is organized by type of pesticide (insecticides/miticides; herbicides/plant growth regulators (PGRs)/defoliants/desiccants; and fungicides).

INSECTICIDE AND MITICIDE AIS APPROVED

CONDITIONS/CAUTIONS (IN ADDITION TO FOLLOWING LABEL AND MSDS PRECAUTIONS, AND USING PPE)

• Abamectin • Only products with < 2% Active Ingredient are allowed

• acephate •

• Acetamiprid • Recommended for use as a seed treatment only; not during vegetative growth and not during flowering

• Bacillus thuringiensis/BT •

• beta-cyfluthrin • Only products with < 10% Active Ingredient are allowed

• beta-cypermethrin • Use all but 2.5 Emulsifiable Concentrate formulations

• Bifenthrin • Use only 10% Emulsifiable Concentrate and 2.5% Ultra-low-volume formulations

• Buprofezin •

• Carbaryl •

• chlorantraniliprole •

• Cyfluthrin • Only products with < 10% Active Ingredient are allowed

• Diflubenzuron • Only products with < 25% Active Ingredient are allowed

• Dimethoate •

• Dinotefuran • Recommended for use as a seed treatment only; not during vegetative growth and not during flowering

• Esfenvalerate •

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• etoxazole miticide/insecitide •

• Fenpyroximate •

• Flubendiamide •

• hexythiazox miticide •

• Imidacloprid • Recommended for use as a seed treatment only; not during vegetative growth and not during flowering

• indoxacarb, S isomer •

• lambda-cyhalothrin • Only products with < 10% Active Ingredient are allowed

• Malathion •

• methoxyfenozide •

• neem oil •

• Novaluron •

• Pyriproxyfen •

• Spinosad •

• Spiromesifen •

• sulfur miticide •

• Thiamethoxam • Recommended for use as a seed treatment only; not during vegetative growth and not during flowering

HERBICIDE, PLANT GROWTH REGULATOR (PGR), DEFOLIANTS AND DESICCANT AIS APPROVED

CONDITIONS/CAUTIONS

• 1-naphthylacetic acid (NAA) •

• chlormequat chloride •

• Cyclanilide •

• Ethephon •

• Fluometuron •

• Glyphosate •

• mepiquat chloride •

• Metolachlor • Keep away from water and groundwater sources

• Pendimethalin •

• Prometryn •

• pyrithiobac/pyrothiobac-sodium •

• quizalofop/quizalfop-p-ethyl •

• quizalofop-p-tefuryl •

• s-metolachlor • Keep away from water and groundwater sources

• Thidiazuron •

• trifloxysulfuron (sodium) •

• Trifluralin •

FUNGICIDE AIS APPROVED

CONDITIONS/CAUTIONS

• Azoxystrobin •

• Difenoconazole •

• Mancozeb •

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• Pyraclostrobin •

• Sulfur •

• Tebuconazole •

• Thiram •

Rejected pesticides. AIs rejected by this PERSUAP are listed in Annex 6 of this document. Reasons for each rejection are also listed in Annex 6. Low-risk AIs not requiring approval under this PERSUAP. Note that some particularly low-risk AIs (primarily essential oils and other plant extracts) are exempt from regulation under the US Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and therefore may 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 pesticide Inert Ingredients that are exempt from FIFRA is available at: http://www.epa.gov/sites/production/files/2015-01/documents/section25b_inerts.pdf

General conditions. This PERSUAP articulates the mitigating conditions of the BCI Initial Environmental Examination (IEE) Negative Determination regarding the potential use of pesticides, following 22 CFR 216.3 (b) Pesticide Procedures. This PERSUAP will closely inform the technical assistance and capacity building for BCI USAID/GDL supported activities, as well as any partners/sub-grantees, and beneficiaries.

This PERSUAP establishes requirements for safer pesticide use (SPU), particularly the support and use of personal protection equipment (PPE) by any and all pesticide trainers, promoters, and users. Additionally, the PERSUAP identifies country-level requirements within the framework of a Safer Use Action Plan (SUAP). These and other conditions recommended in the body of this PERSUAP are highlighted and summarized below. They are conditions of the award from USAID to BCI:

1. Only pesticides approved by this PERSUAP (listed above) can be supported by USAID-funded BCI activities

2. BCI USAID-funded activities must not support AIs rejected by this PERSUAP (Annex 6)

3. BCI should continue to promote Good Agricultural Practices (GAPs) and develop PMPs (see Annex 2) using recommended preventive IPM tools and tactics provided in Annex 1

4. BCI should take necessary steps to prevent the development of pest resistance by using and/or promoting tools recommended by this PERSUAP (in PER, Section 5, Factor F)

5. BCI Implementing Partner (IP) staff and beneficiaries who address pesticides through use of training materials, during training, and on demo trials, should promote Safe Pesticide Use (SPU) through explaining pesticide risks, promotion of pesticide best practices, and safety use training. Annex 7 provides training resources

6. To the greatest degree practicable, pesticide-related activities that BCI supports and USAID funds must require use & maintenance of appropriate Personal Protection Equipment (PPE) – as well as safe pesticide purchase, transportation, handling, storage, and disposal practices

7. Flow-down requirements apply to sub-contracts and sub-awards

Additional recommendations for BCI activities include:

Promoting professional and certified pest control services. Promoting Empty Pesticide Container (EPC) Recycling.

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1. Only pesticides approved by this PERSUAP (listed above) can be supported by USAID-funded BCI activities. USAID defines Pesticide “support” broadly as use of USAID funds to: purchase pesticides; train farmers on pesticide decision-making, directly fund the application of pesticides; recommend pesticides for use; facilitate or enable the application or purchase of pesticides via provision of application equipment (sprayers), PPE, credit support, or other means by the IPs, sub-grantees, partners or providers of finance.

BCI will promote only pesticides with AIs approved by this PERSUAP. If BCI wishes to request the support with USAID funds of any non-EPA registered or RUP product, including use on any demonstration farm, then a full EA must be done and approved by the GDL BEO. BCI project national partners and sub-grantees shall obtain and retain copies of the Material Safety Data Sheets (MSDS) for each pesticide that their beneficiary farmers use frequently.

Where alternatives (Classes III and IV/U) exist, do not recommend or use EPA and WHO Acute Toxicity Class II pesticide products on BCI activities, unless the project can verify that producers and pesticide applicators properly use PPE as recommended by the pesticide label and MSDS.

2. BCI USAID-funded activities must not support AIs rejected by this PERSUAP (Annex 6). BCI must not, with USAID funds, and in any of the four target countries, purchase, use or permit to be used during training or on demonstration trials, pesticides with any of the AIs listed in Annex 6. BCI will, within 6 months of receiving this PERSUAP, train local national partners and sub grantees in each target country to understand the pesticide AIs contained in Annex 6 and emphasize that they must not be used with USAID funds. Absolutely no POP or PIC chemicals will be used or supported on BCI activities.

3. BCI should continue to promote Good Agricultural Practices (GAPs) and develop PMPs (see Annex 2) using recommended preventive IPM tools and tactics provided in Annex 1. BCI, as part of its mandate, will continue to promote the use of crop production plans and adapt (from Annex 1) IPM plans containing descriptions of major pests/diseases/weeds of cotton and preventive non-chemical IPM tools/tactics. BCI and its IPs will employ these tools/tactics before using PERSUAP-approved pesticides, which are the measure of last resort. Such tools/tactics will include the use of high yielding and certified quality clean seed, resistant varieties, natural predators and parasites, soil fertility testing and conservation, plant nutritional needs to grow healthy crops, proper water management, crop rotation, intercropping, crop residue destruction, clean storage, and rotation of pesticide types to reduce resistance, among others.

Preventive IPM tools and tactics for each crop-pest combination (Annex 1) should be used before the choice is made to purchase and use synthetic pesticides.

Annexes 2 and 3 provide guidelines for making PMPs and using IPM. For most pests, diseases and weeds, Annex 1 provides several choices of natural and synthetic pesticides to choose from.

Smallholder farmers require additional training on IPM philosophy and practice and how it fits into certified markets for high quality, low input cotton. BCI already provides such training for its partners and beneficiary farmers.

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4. BCI should take necessary steps to prevent the development of pest resistance by using and/or promoting tools recommended by this PERSUAP (in PER, Section 5, Factor F) Pest resistance to pesticides can largely be prevented by adopting tactics noted above under PER Section 5, Factor F, including rotating among different classes of each type of pesticide. BCI and its IPs will train and encourage farmers to rotate among pesticides from different chemical classes. Preventive IPM tools and tactics for each cotton-pest/disease combination (see Annex 1) should be recommended and used before, as well as combined with, the use of natural and synthetic pesticides. Monitoring and record keeping are a requirement for detecting development of resistance. BCI should train farmers on ways to reduce the development of resistance through monitoring and record keeping.

The following are recommended for all USAID/GDL-funded BCI project partner record keeping systems:

• GlobalGAP-like record keeping on crops grown, pests/diseases encountered and pesticides sprayed. • Grantees/partners to do monitoring of beneficiary compliance and GAPs. • A pesticide checklist: This list allows project agronomists to ensure that the pesticides they are using

are registered. It should also provide notes on special safety requirements. • PPE: Lists of the types of equipment made available to applicators, number of pieces, prices and

contact details of suppliers, dates when equipment needs to be washed, maintained or replaced. PPE should be numbered or personally assigned to applicators while ensuring that it is not taken into the home where (as a contaminated material) it could pose a risk to family members.

• Local regulatory compliance: A list of country laws related to the use of agrochemicals for plant protection.

• Monitoring/recording pests: Agronomists should incorporate into their records regular field pest monitoring and identification.

• Environmental conditions: Field conditions should be incorporated into the record keeping system (for example; precipitation, soil analyses and moisture, soil pH, temperatures and so on).

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

• Farmers require training and refresher trainings on how to choose the correct quality pesticide, do knapsack sprayer calibration and record keeping, as well as proper pest identification and IPM.

• Annex 7 on Training Topics provides significant discussion of SPU and IPM.

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5. BCI Implementing Partner (IP) staff and beneficiaries who address pesticides through use of training materials, during training, and on demo trials, should promote Safe Pesticide Use (SPU) through explaining pesticide risks, promotion of pesticide best practices, and safety use training. Annex 7 provides training resources. BCI Implementing Partner (IP) staff and beneficiaries who address pesticides through use of training materials, during training and on demo trials, should promote Safe Pesticide Use (SPU) through explaining pesticide risks, promotion of pesticide best practices and safety use training. Training must include topics listed in Annex 7.

Training should emphasize the need for understanding product labels and requirements for use of PPE. BCI must promote the use of safety equipment and its proper maintenance.

Training provided by BCI should encourage farmers to use products of known high quality as well as lower human and ecological toxicities (see Annex 5) if there is a choice among pesticide products and AIs. As part of the SUAP (Section 5), pesticide users should be trained in effective, efficient and safe mixing, handling and application of pesticides and proper maintenance of application equipment. Beneficiaries should be aware of pesticide risks and that human poisoning and pollution can be caused by drift, runoff/leaching and leaking sprayer nozzles as well as by accidental spills and during filling, rinsing and disposal of solution.

Training should also include information about recognizing symptoms of pesticide poisoning and first aid. The pesticide safer use training in basic first aid for pesticide overexposure will require availability and use of antidotes, and training on recommendations found on pesticide labels and MSDSs for commonly used pesticides.

BCI will train farmers in adoption of IPM approach that (1) emphasizes prevention, (2) sanitation and exclusion of pests, (3) use of traditional practices, and (4) utilizing pesticides only as a last resort when other options have failed. Note that the toxicity table in Annex 5 also provides a key reference for development of crop- and pest-specific pest management plans.

The following is additional detail about recommended training topics:

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• Train farmers about health risks and ecotoxicity and on how to read pesticide labels. • Train farmers about ecotoxicity precautions including applying pesticides the proper distance (30 meters)

from open bodies of fresh water and not to wash their sprayers out in ponds, lakes, rivers, streams, or wetlands, or where rinse water may run off into these aquatic resources.

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

• Warn beekeepers of upcoming spray events so that they can move or otherwise protect their hives. • Train farmers not to spray when honeybees are active and foraging. • Do not spray or rinse pesticide equipment in or within 30 meters of rivers, ponds, irrigation and drainage

ditches, and other surface waters, including wetlands. • Do not spray pesticides with high toxicities to aquatic organisms before an impending rainstorm, as

pesticides can be washed into waterways before breaking down. • Do not use or recommend for use herbicides or other pesticides with high leaching and groundwater

pollution potential (see Annex 5) near drinking water sources, on highly sandy soils, or on soils with water tables close (2-3 meters) to the surface.

• Since transport of soil particles with pesticides adsorbed to them is a likely transportation route to waterways, employ techniques to reduce farm soil erosion whenever erosion is likely. Such techniques include vegetated buffer strips, green manure, mulching, terracing, employing wind breaks, employing ground covers between rows, planting rows perpendicular to the slope, and using drip irrigation.

• Train farmers to purchase quality inputs from suppliers that provide quality technical backup support, and to purchase and use PPE, or contract private pesticide spray services.

• Train farmers about proper storage and handling of unused pesticides.

Additional important training topics are listed in Annex 7.

6. To the greatest degree practicable, pesticide-related activities that BCI supports and USAID funds must require use & maintenance of appropriate Personal Protection Equipment (PPE) – as well as safe pesticide purchase, transportation, handling, storage, and disposal practices

7. Flow-down requirements apply to sub-contracts and sub-awards

Prime contractors must write pesticide compliance requirements as set out above into each grant or sub-contract that will involve support for pesticide use.

The following are additional recommendations of this PERSUAP:

Promoting professional and certified pest control services: Recommend that BCI promote and support the concept and use of farmer-cooperative or private-sector fee-based pesticide spray services that have well trained spray personnel protected with appropriate PPE.

Promoting Empty Pesticide Container (EPC) Recycling: Recommend that BCI promote and support the concept and use of EPC best practices, including triple rinsing after last use, puncturing to prevent re-use, return to collection sites, and recycling into agriculture plastics approved by the Government of the four target countries.

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7.3 USAID MONITORING AND REPORTING REQUIREMENT

In addition to regular monitoring by BCI and its sub-grantees/partners, environmental compliance staff, and others delegated, USAID’s responsible field staff in each country (A/COR, MEO) should be encouraged and empowered to make inspection visits to several randomly selected farms receiving project assistance/finance to check for compliance with the IPM and safer use measures summarized by Safer Use Action Plan (SUAP) Compliance Tracker form given in section 7.4.

BCI’s designated Pesticide Compliance Lead in each of the four target countries where USAID will support BCI operations will be required to submit completed SUAP Compliance Tracker forms to GDL’s BEO and GDL’s A/COR according to the schedule given in Section 7.4.

7.4 SAFER PESTICIDE USE ACTION PLAN (SUAP) COMPLIANCE TRACKER FORM

For each country where USAID will support BCI operations:

• BCI must submit the SUAP Compliance Tracker form (below) to the GDL BEO and GDL A/COR by March 2017 • BCI should update and re-submit the form with BCI’s first Environmental Mitigation and Monitoring Report (EMMR) due in September 2017 • BCI should update and re-submit the form annually thereafter with each subsequent EMMR

BASIC INFORMATION SUBMISSION DATES:

COUNTRY INITIAL

SUBMISSION

NATIONAL IMPLEMENTING PARTNERS

UPDATE #1

BCI PESTICIDE COMPLIANCE LEAD

UPDATE #2

CONTACT INFORMATION

UPDATE #3

SUMMARY OF PEST MANAGEMENT CONCERNS/NEEDS ON PROJECT

UPDATE #4

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REQUIRED COMPLIANCE (MITIGATION) MEASURE

COMPLIANCE TIMEFRAME

INITIAL COMPLIANCE STATUS (IF NOT KNOWN, SO INDICATE)

ACTIONS PLANNED TO ACHIEVE & MAINTAIN COMPLIANCE

(WITH DEADLINES & RESPONSIBLE PARTY)

STATUS OF COMPLIANCE ACTIONS

Required Condition 1: Support provided only for pesticides approved by this PERSUAP (AIs listed in Annex 5 and also in the Executive Summary) and only with specified use restrictions

(Insert extra rows if needed for all sections)

Distribute copies of the list of allowed AIs with matching commercial product names to all BCI consortium members and project field staff; advise regarding March 2017 deadline for compliance with Condition 2 (below)

Immediately after receiving USAID funding

Ensure USAID-funded pesticide “support” is limited to pesticides approved by this PERSUAP and only with specified use restrictions

Continue verification throughout life-of-project

Ongoing over Life of Project (LOP); at least monthly during production season

Required Condition 2: BCI USAID-funded activities must not support AIs rejected by this PERSUAP (AIs listed in Annex 6)

Inventory pesticides used by BCI beneficiaries to ensure no USAID “support” (see above) is provided for rejected AIs

No later than March 2017

Ensure that USAID-funded pesticide “support” is not provided to products containing rejected AIs

No later than March 2017; ongoing over Life of Project (LOP); at least monthly during production season

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Recommended Condition 3: BCI should continue to promote Good Agricultural Practices (GAPs) and develop PMPs using recommended preventive IPM tools and tactics (resources are provided in Annex 1, Annex 2, Annex 3, and Annex 7).

Adapt/refine/develop pest/disease-specific IPM-based pest management plans (PMPs)

By March 2017

Modify PMPs over LOP based on ground-truthing/field experience.

LOP, at least annually

Develop crop-specific PMP field reference guides, flyers, or posters for farmers to anticipate and manage pests.

By March 2017

Recommended Condition 4: BCI should take the necessary steps to prevent the development of pest resistance by using and/or promoting tools recommended by this PERSUAP (in PER, Section 5, Factor F).

Pesticide applications are recorded and efficacy against pests is evaluated

LOP, during production season

Farmers maintain records and any evidence of pesticide resistance is tracked and reported

LOP, during production season

Recommended Condition 5: BCI should provide Safe Pesticide Use (SPU) Training (Resources and training topics are provided in Annex 7)

Develop a Training Plan for SPU and IPM training elements specified in Annex 7 for project staff and beneficiaries

By March 2017

Develop or source curricula conforming to training elements specified in Annex 7

By March 2017

Implement training plan, providing first-time training to all relevant BCI staff and beneficiaries within 6 months and provide refresher trainings

Starting March 2017 and over LOP at least annually

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Required Condition 6: To the greatest degree practicable, pesticide-related activities that BCI supports and USAID funds must require use & maintenance of appropriate Personal Protection Equipment (PPE) – as well as safe pesticide purchase, transportation, handling, storage, and disposal practices

Implement/observe core risk mitigation measures (PPE and other precautions) identified in the summary section of each extended pesticide profile

Where control is less complete, take all practicable measures to support and promote implementation of these measures

Over LOP, at least monthly during production

Whenever providing, supporting or recommending pesticides for use, to the greatest degree practicable, ensure that appropriate PPE and quality application equipment is available and, to the degree possible, require its use

Over LOP, at least monthly during production

To the greatest degree practicable, enforce triple-rinsing of empty pesticide containers and good disposal practices

Over LOP, at least monthly during production

For directly supported pesticide stores or transport, and to the greatest degree practicable, ensure that FAO Best Management Practices are met. (See PERSUAP References)

Over LOP, at least monthly during production

Required Condition 7: Flow-down requirements

Prime contractors must write pesticide compliance requirements as set out above into each grant or sub-contract that will involve support for pesticide use

Over LOP, upon every sub-award

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ANNEX 1: 2015 FOUR TARGET COUNTRY COTTON PESTS, DISEASES, PREVENTIVE & CURATIVE IPM TOOLS

PRIMARY PESTS, DISEASES, WEEDS

RECOMMENDED PREVENTIVE GAP/IPM TOOLS/TACTICS TO INTEGRATE RECOMMENDED CHEMICAL CONTROLS, WHEN NEEDED

Bollworms/Budworms Cotton/American Bollworm/Corn earworm (Helicoverpa armigera) MZ, IN Red Bollworm (Diparopsis castanea) MZ Pink Bollowrm (Pectinophora = gossypiella) MZ Cotton Bollworm/Spiny Caterpillar (Earias vitella, Earias biplaga, Earias insulana) MZ, IN Tobacco budworm (Heliothis virescens)

• Natural enemies include parasitoids in the Braconid wasp and Tachinid fly families and Trichogramma egg parasitoids and Telemonus species.

• Predators include damselflies, hoverflies, lacewings, ladybird beetles and larvae, minute pirate bugs, praying mantis and spiders.

• Use resistant varieties. • Plow and harrow fields at least 2 times before sowing seeds. This will expose pupae

of corn earworm to chicken, birds, ants and other predators. Corn earworm pupates in the soil.

• Monitor regularly, use pegboard tool to count pest numbers. • Do strip intercropping in this sequence: cotton, leguminous crops, cereals, cotton. • Use pheromone and baited traps. • Practice crop rotation. Avoid planting crops successively that are hosts to bollworms

like hibiscus, okra, corn, sorghum, tobacco, soybean, and tomato. • Remove weeds from field and field margins: Two weeks before planting, remove

weeds and grasses to destroy earworm larvae and adults harboring in those weeds and grasses.

• Plant Marigold, Cosmos, sunflowers, alfalfa, pigeon pea as trap crops around and in the field to lure caterpillars away from cotton; once heavily infested, harvest the sunflower seeds, plow these under or spray them.

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

• Once bollworms are inside the boll, there is little chance of hitting them with a contact insecticide. Any spraying of contact insecticides must be done in concert with careful monitoring to see when small larvae are present and have not yet bored into the boll; otherwise pesticide will be wasted.

• Rotate among different classes of insecticides, Cotton Bollworms have developed resistance to some carbamates, organophosphates and pyrethroids/pyrethrins.

• There is known tobacco budworm resistance to BT toxin.

• Use seed treated with systemic insecticide imidacloprid or thiamethoxam.

• Use organic natural insecticides containing BT, local neem/azadirachtin extract, spinosad and pyrethrum extract.

• Can rotate among rapid knock-down insecticides containing synthetic pyrethroids beta-cypermethrin, esfenvalerate, beta-cyfluthrin, bifentrhin, cyfluthrin or lambda-cyhalothrin.

• For longer-term control, use spot treatments and rotate among indoxicarb, carbaryl, chlorantraniliprole or buprofezin mixed with spinosad.

Defoliators / Leaf Eaters Cutworms (Agrotis segetum) MZ Tobacco Caterpillar, Oriental Leafworm (Spodoptera litura) IN

• Natural enemies include Braconid wasps (Cotesia species and others) and Tachinid fly larvae. Predators include ground beetles, lacewings, praying manits and ants.

• Plow and harrow fields properly before planting to kill pupae and larvae. • Control weeds around edges of field. • Interplant field edges or main crops with onion, garlic, peppermint, coriander, or

garlic every 10-20 rows to repel caterpillars. • Plant Marigold, Cosmos, sunflowers, alfalfa as trap crops in or around fields to lure

caterpillars away from cotton; once heavily infested, plow these under or spray them.

• Walk around field edge to find heavily infested spots (areas), do spot treatments with insecticides of only these areas, not the entire field.

• Use organic natural insecticides containing BT, local neem/azadirachtin extract, and pyrethrum extract.

• Use rapid knock-down insecticides containing synthetic pyrethroids beta-

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PRIMARY PESTS, DISEASES, WEEDS

RECOMMENDED PREVENTIVE GAP/IPM TOOLS/TACTICS TO INTEGRATE RECOMMENDED CHEMICAL CONTROLS, WHEN NEEDED

Cotton leafworm (Spodoptera littoralis) Cotton Leaf-Roller (Sylepta derogata) IN Green Semi-Looper (Anomis flava) IN Cotton Semi-Looper (Tarache notabilis) IN Bihar Hairy Caterpillar (Spilosoma obliqua) IN Grasshoppers (various species) MZ Leaf Perforator (Bucculatrix loxoptera) IN

• Use pheromone and baited traps. • Monitor regularly, use pegboard tool to count pest numbers. • Mixed or strip cultivation with onions, garlic, chilies, chrysanthemums or hot

peppers can have a repellent effect against leaf eaters. • Post-harvest sanitation; remove and destroy crop residue and weeds.

cypermethrin, esfenvalerate, beta-cyfluthrin, bifentrhin, cyfluthrin or lambda-cyhalothrin.

• For longer-term control, use spot treatments and rotate among diflubenzuron, indoxicarb, carbaryl, chlorantraniliprole or buprofezin mixed with spinosad.

Leaf Miner (Liriomyza trifolii) IN

• Natural enemies include Braconid wasps (Cotesia species and others) and Tachinid fly larvae. Predators include ground beetles, lacewings, praying manits and ants.

• Plow and harrow fields properly before planting to kill pupae and larvae. • Control weeds around edges of field. • Interplant field edges or main crops with onion, garlic, peppermint, coriander, or

garlic every 10-20 rows to repel caterpillars. • Plant Marigold, Cosmos, sunflowers, alfalfa as trap crops in or around fields to lure

caterpillars away from cotton; once heavily infested, plow these under or spray them.

• Use pheromone and baited traps. • Monitor regularly, use pegboard tool to count pest numbers. • Mixed or strip cultivation with onions, garlic, chilies, chrysanthemums or hot

peppers can have a repellent effect against leaf eaters. • Post-harvest sanitation; remove and destroy crop residue and weeds.

• For leaf miners, use synthetic insecticides with spinosad or IGR pyriproxyfen.

Weevils Cotton Stem Weevil

• Use weevil resistant varieties or cultivars. • Use early planting. • Stimulate rapid growth by thorough preparation of the seed bed, by adequate

• Use organic natural insecticides containing local neem extract, spinosad and pyrethrum extract.

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PRIMARY PESTS, DISEASES, WEEDS

RECOMMENDED PREVENTIVE GAP/IPM TOOLS/TACTICS TO INTEGRATE RECOMMENDED CHEMICAL CONTROLS, WHEN NEEDED

(Pempherulus affinis) IN Internode Borer (Alcidodes affaber) IN Boll Weevils (Anthonomus grandis)

fertilization and by recommended weed control practices. • Selection of early maturing varieties specifically adapted to local areas. • Post-harvest sanitation; remove and destroy crop residue and weeds.

• Use seed treated with systemic insecticide imidacloprid or thiamethoxam.

Cotton Lint Stainer Bugs Cotton Stainer Bug, Red Cotton Bug (Dysdercus koenigii, Dysdercus superstitiosus) MZ, IN Dusky Cotton bug (Oxycarenus laetus) Lygus Bugs (Lygus hesperus and other Lygus species) Stinkbug (Euschistus Heros)

• Other crops are more attractive to these bugs than cotton. Many weeds like Russian thistle, mustards and radishes are also attractive to bugs. These include alfalfa (seed and hay), safflower, sugarbeet, tomato, beans, and potato. As these crops are prepared for harvest, winged adults migrate out of the field in search of new hosts. As these alternate host plants begin to dry, check for bug stage; if adults, spray the field; if larvae, disc or plow under.

• Use plantings of any of the above as trap crops to lure and trap bugs. • Mixed or strip cultivation with onions, garlic, chilies, chrysanthemums or hot

peppers can have a repellent effect against bugs. • Post-harvest sanitation; remove and destroy crop residue and weeds.

• Use of synthetic insecticide treatments may result in secondary outbreaks of spider mites, aphids, or other pests.

• For quick knock-down, can use insecticides containing synthetic pyrethroids beta-cypermethrin, beta-cyfluthrin, esfenvalerate, bifentrhin, cyfluthrin or lambda-cyhalothrin.

• There is some resistance of some of these pests to carbaryl, use with care or rotate with other chemicals like etoxazole, indoxacarb, dimethoate, malathion, novaluron.

Green Leafhopper/Jassids (Empoasca facialis) MZ, IN Okra Leafhopper (Amarasca biguttula)

• Natural enemies include general predators such as lady beetles, lacewings, ants spiders and Nabid bugs, but they will not provide adequate control of leafhoppers.

• Use resistant varieties. • Provide adequate moisture through timely irrigation. • Monitor regularly, use pegboard tool to count pest numbers. • Remove weeds from field and field margins. • Post-harvest sanitation; remove and destroy crop residue and weeds.

• For quick knock-down, can use insecticides containing synthetic pyrethroids beta-cypermethrin, beta-cyfluthrin, esfenvalerate, bifentrhin, cyfluthrin or lambda-cyhalothrin.

• Can use and rotate among synthetic insecticides containing flubendiamide, novaluron, malathion.

Cotton aphids (Aphis gossypii) MZ, IN

• Many natural enemies include damsel bugs, big-eyed bugs, green lacewings, minute pirate bugs and numerous parasitic wasps.

• Use resistant varieties. • Early planting avoids many severe aphid problems. • The aphido-pathogenic fungus Neozygites fresenii, if present in the field may help

control cotton aphids and reduce populations.

• Can use natural artisanal insecticides containing insecticidal soap, narrow range oils and azadirachtin/neem extract.

• Use seed treatments with synthetic systemic insecticides containing imidacloprid or thiamethoxam.

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PRIMARY PESTS, DISEASES, WEEDS

RECOMMENDED PREVENTIVE GAP/IPM TOOLS/TACTICS TO INTEGRATE RECOMMENDED CHEMICAL CONTROLS, WHEN NEEDED

• Plant Marigold, Cosmos, sunflowers, alfalfa as trap crops in or around fields to lure aphids away from cotton; once heavily infested, plow these under or spray them.

• Post-harvest sanitation; remove and destroy crop residue and weeds.

• For quick knock-down, can use insecticides containing synthetic pyrethroids beta-cypermethrin, beta-cyfluthrin, bifentrhin, esfenvalerate, cyfluthrin or lambda-cyhalothrin.

• Use and rotate among synthetic insecticides containing etoxazole, or pyriproxyfen.

Cotton Whitefly (Bemisia tabaci) vector of the cotton leaf-curl virus (LCV) IN, PK

• Natural enemies include general predators such as parasitic wasps, lady beetles, and lacewings provide 5-10% control.

• Weed and eradicate the following alternate hosts of LCV and whitefly: okra, sun kukra, china rose, dhatura thorn apple, mint, karund, cucurbits (especially water melon), beans, tomatoes, tobacco, chilies, soybean, sunflower, cowpea, egg plant, holly hock, zinnia, sesame, and some citrus species.

• Mixed or strip cultivation with onions, garlic, chilies, chrysanthemums or hot peppers can have a repellent effect against white fly.

• Post-harvest sanitation; remove and destroy crop residue and weeds.

• Use of insecticides is ineffective to control whiteflies sufficiently and thus reduce LCV.

• Can use natural artisanal insecticides containing insecticidal soap, oils and azadirachtin/neem extract.

• For quick knock-down, can use insecticides containing synthetic pyrethroids beta-cypermethrin, beta-cyfluthrin, bifentrhin, cyfluthrin or lambda-cyhalothrin.

• There is some resistance of cotton whitefly to buprofezin; use with care and rotate with insecticides like pyriproxyfen, spiromesifen.

Cotton Thrips (Thrips tabaci and Scirtothrips dorsalis) IN

• Choose resistant and hairy leaf varieties. • Predaceous thrips can often, if not killed with insecticides spraying, control cotton

thrips. • Post-harvest sanitation; remove and destroy crop residue and weeds. • Avoid early planting during cool conditions. • Avoid planting cotton near small grains and onions, as thrips will often migrate from

these to other crops like cotton.

• Can spray post-emergence acephate or dimethoate.

Mealybugs (Phenacoccus solenopsis) are secondary pests that outbreak when other pests and their natural enemies are over-sprayed or GMO BT cotton is used MZ, IN, PK

• Many parasites, parasitoids and predators feed on and control mealybugs. • Intercropping (with pigeon pea, sorghum, maize, soybean, cluster bean, some of

which can be used as green manure) slows the movement of mealybugs through the cotton field.

• Use sticky traps placed in the field to survey for the presence and population density of the mealybug

• Prune and cut heavily off infested plant parts and destroy them.

• Can use homemade insecticidal soap treatments on small populations.

• Use seed treatments with synthetic systemic insecticides containing acetamiprid, imidacloprid or thiamethoxam.

Spider mites (Tetranychus urticae)

• Use resistant varieties: Pima cotton is less susceptible to spider mites than upland cotton varieties.

• Preserve natural enemies of mites by avoiding early season, broad-spectrum insecticide applications. The most important predator early in the season is the western flower thrips. Later, bigeyed bugs, minute pirate bugs, predaceous mites, and other predators are also important.

• Avoid large area treatments with broad-spectrum pesticides, which kill natural enemies and may result in mite outbreaks. Do spot treatments instead.

• Use sprays of artisanal preparations containing insecticidal soap, some oils

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PRIMARY PESTS, DISEASES, WEEDS

RECOMMENDED PREVENTIVE GAP/IPM TOOLS/TACTICS TO INTEGRATE RECOMMENDED CHEMICAL CONTROLS, WHEN NEEDED

• Use continuous scouting and monitoring to locate “hot spots” where mite infestations are heavy; treat hot spots.

• Provide good plant growing conditions, in particular enough water; water stressed plants are prone to mite damage.

• Avoid planting next to infested fields.

(narrow range oil), azadirachtin/neem seed extract, and sulfur dust are acceptable on organic cotton.

• Some mite resistance exists to abamectin. Rotate abamectin with diflubenzuron, etxazole, fenpyroximate, flubendiamide, hexythiazox, spiromesifen.

Root knot nematodes (Meloïdogyne species; Heterodera rudicicola)

• Use certified nematode-free planting stock. • Use more resistant varieties. • Use fallowing, crop rotation, and soil solarization (these methods reduce nematodes

in the top foot of soil, so they are effective only for about a year). • Ensure sufficient water management and nutrition to keep plants strong. • French marigolds, Tagetes species, (varieties include Nemagold, Petite Blanc, Queen

Sophia, and Tangerine) suppress root knot and lesion nematodes. • Sanitation: Remove and destroy any plants that exhibit symptoms of nematodes, and

remove plant debris at end of season.

• Nematicides are not recommended for smallholder farmer use, as most are Class I and thus too toxic.

Verticillium wilt (Verticillium dahliae)

• Use tolerant varieties (these include most Acala varieties and Pima varieties). • Rotate out of cotton with corn, wheat, barley, sorghum, safflower, or rice. • Delay first irrigation if disease pressure is high (more than 10 microsclerotia per

gram of soil) and air temperatures are cool. • Take soil samples and have them analyzed. Where a single susceptible cotton

variety is planted without rotation, a level of 10 or more microsclerotia per gram of soil usually results in significant yield loss.

• Soil solarization in sunny climates can be useful. • Sanitation: Remove and destroy any plants that exhibit symptoms of Verticillium wilt.

• Fungicides are generally not economical for control of Verticillium wilt.

Bacterial blight of cotton (Xanthomonas malvacearum)

• Use certified disease-free seed. • Use hot water (56 degrees C, 10 min) seed treatment. • Maintain proper plant density. • Plant only in properly drained soil. • Use crop rotation and control weeds. • Sanitation—post-harvest removal of stalks and debris for fire fuel or compost.

• Treatment of seed with other bacteria like Pseudomonas fluorescens may elicit an induced resistance response in cotton against blight.

• Use of bactericide is not economical.

Rots and Wilts Stem Canker, Stem Burn, Collar Rot (Phytophthora nicotianae var. parasitica) Boll and Root Rots (Ascochyta gossypii, Fusarium

• Cultivation of disease resistant varieties: Resistance has been found in fiber-type Roselle cultivars.

• Use of healthy disease-free seed, acid delinting and chemical seed treatment to minimize the disease incidence of seedling, root and boll rots as well as bacterial blight.

• Early sowing of crop is preventive measure for control of boll rot. • Keep soils well drained: Ensure sufficient water management and nutrition to keep

plants strong.

• Treat seed with a fungicide containing thiram, pyraclostrobin or difenoconazole and metalaxyl.

• Can use natural fungicides containing sulfur. • Can use synthetic fungicides containing

azoxystrobin, pyraclostrobin, tebuconazole or mancozeb.

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PRIMARY PESTS, DISEASES, WEEDS

RECOMMENDED PREVENTIVE GAP/IPM TOOLS/TACTICS TO INTEGRATE RECOMMENDED CHEMICAL CONTROLS, WHEN NEEDED

species, Phytophthora species, Rhizoctonia solani) and others Anthracnosis (Colletotrichum gossypii)

• Deep plowing with short duration, at least two months before sowing, helps to control seedling and root rot.

• Crop rotation with non-host, that is, sowing of sorghum for 3 to 4 years is useful for control of seedling and root rot.

• Mixed cropping with kidney bean or fodder and leguminous crops can help reduce root rot.

• Sanitation: Remove and destroy plant debris and seeds at the end of harvest.

Hibiscus stem canker and leaf spot (Coniella musaiaensis var. hibisci)

• Ensure sufficient water management and nutrition to keep plants strong. • Take care not to injure tissues when planting, transplanting, or during work or

harvest. • Sanitation: Remove dead or dying plants from plantation, and burn.

• There are no fungicides recommended for treating cankers.

Leaf Spots (Cercospora hibisci) and others

• Keep the leaves dry. • To reduce humidity, plant with proper spacing between plants. • Sanitation: remove and dispose of fallen plant debris.

• Fungicide treatments are not warranted. • If needed, use sulfur.

Mildews: Powdery mildew (Oïdium abelmoschi) Arolate Mildew (Ramularia = Cercosporella gossypii)

• A disease at the end of the growing season. • To reduce humidity, plant with proper spacing between plants. • Sanitation: As rains are beginning, prune dead and heavily diseased branches, and

sterilize tools between cuts and bushes. Remove heavily diseased plants.

• An artisanal sodium bicarbonate (baking soda) solution can be used as a preventative.

• Can use mancozeb or sulfur-based fungicides.

ANNEX 2: GUIDELINES FOR PMPS FOR COTTON BENEFICIARIES

WHAT IS A PMP?

PMPs or Year-Round (seasonal) IPM Programs are state of the art in many developed countries, and they help institutionalize IPM in planning and practice. PMPs provide agriculture managers and farmers with a tool to predict and prevent many crop pests of each crop throughout a season.

See examples of PMPs at http://www.ipm.ucdavis.edu/PMG/crops-agriculture.html, with the green arrow next to each crop with a “Year-Round IPM Program”.

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

Who are the PMP’s intended audiences and users?

• Farmland preparation and crop production decision-makers • Farmers • Farm managers

Why do a PMP?

PMP Objectives:

• Prevent or reduce pest damage risk to agricultural production or health • Protect the health of farmers, farm family members, laborers and community members from

pesticide risks • Maintain economically sound practices • Reduce environmental pollution and degradation risks • Enhance the overall quality and quantity of biodiversity in the farm work environment • Respond to foreign market demand for the use of agriculture sector best management practice

standards, also called Good Agriculture Practices (GAPs), which include IPM measures, to achieve farm and produce certification

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

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Organization of the PMP

Use the following pieces of crop- or livestock-specific background information to build a PMP:

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

GAPS and IPM) recommendations

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

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

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

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

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

• Photographs of each pest, life stages • Photographs of plant or livestock damage • Description of the pest, life cycle and survival strategies80 • Description of damage symptoms • Best Prevention Practices

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

• Best Management Practices Focus on prevention (above)

• Country or region-specific information

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

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Information on PMP-recommended pesticides:

Here is information needed for each pesticide referenced in the PMP; this information should be organized by pest type (so the farmer/farm manager has the information at their fingertips and does not need to refer to other documents and tables to find it):

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

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

Information needed on Natural Enemies of Pests:

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

82

Additional Information Needed:

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

83

ANNEX 3: ELEMENTS OF IPM PROGRAM Although farmers are likely using numerous IPM tactics, IPM philosophy or planning is not generally an active part of crop production in most emerging market countries; thus, a basic understanding of the elements needed in an IPM program are addressed below, as formulated by FAO81.

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

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

Step 2: Identify key pests for each target crop.

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

Step 3: Evaluate all management options.

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

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

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

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

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

Learning-by-doing/discovery training programs The adoption of new techniques by small-, medium- and large-holder farmers occurs most readily when program participants acquire knowledge and skills through personal experience, observation, analysis,

81http://www.fao.org/docrep/006/ad487e/ad487e00.htm; http://www.fao.org/docrep/006/ad487e/ad487e02.htm; http://en.wikipedia.org/wiki/Farmer_Field_School; http://www.ipm.ucdavis.edu/PMG/crops-agriculture.html

84

experimentation, decision-making, and practice. At first, frequent (usually weekly) sessions are conducted for 10–20 farmers during the cropping season in farmers’ fields by trained instructors or extension agents.

Smallholder support and discussion groups

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

Educational material

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

Youth education

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

Food market incentives (especially important in the last decade)

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

Step 6: Partner successfully with other IPM implementers.

The following design steps are considered essential.

Articulate the partnership’s vision of IPM

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

Confirm partner institutions’ commitment

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

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

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

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

85

Step 7: Monitor the fields regularly.

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

Step 8: Select an appropriate blend of IPM tools.

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

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

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

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

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

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

Further, for project staff, beneficiaries, produce processing facilities, food warehouses, seed multipliers, or farmers that store seed or food and deal with stored seed and food pests, there are warehouse BMPs and monitoring reports that incorporate some IPM tactics. These monitoring forms track, by location or warehouse, use of pallets, stacking, general hygiene and sanitation, damaged packages, actual infestations or signs of rodents, molds, insects, drainage, locks and security measures, use of IPM tactics including least toxic chemicals and strict BMPs, including restricted access, for use of common but hazardous fumigants like aluminum phosphide.

86

Preventive and Curative GAP and IPM options:

PREVENTIVE PREVENTIVE CURATIVE Soil nutrient, texture and pH testing Farmer ability to correctly identify

pest predators, parasitoids and diseases

Mechanical insect control by hand picking

Pest resistant/tolerant seed/plant variety

Weekly field scouting to assess pest levels/damage

Farmers make & apply local artisanal plant extracts (neem, pyrethroid, garlic, chili, other)

Early/late plantings or harvestings to avoid pests

Use of trap crops to trap and destroy pests

Weed control by machine cultivation, hoe or hand

Seed treatment with pesticides Removal/pruning of diseased or heavily infested plants/tree branches

Purchase and release of predators or parasitoids to control major pests

Soil moisture testing Planting parasite-attracting plants on field margins

Use of pheromone traps to reduce overall pest levels

Raised-bed production or mounding Put baits and use other practices to encourage predator/parasite build-up

Use of pheromone inundation to confuse pest mating

Irrigation and drip irrigation Use of pheromone traps to monitor pest levels

Spot treatment of pest hotspots with insecticides, miticides or fungicides

Use of natural fertilizers (manure, compost)

Inter-planting crops with aromatic herbs (celery, cilantro, parsley, dill or local plants) that repel pests

Area spraying (complete field coverage) using synthetic and natural insecticides, miticides or nematocides

Use of purchased mineral fertilizers Mulching with organic materials or plastic to control weeds

Use of synthetic and natural fungicides or bactericides

Combinations of organic and mineral fertilizers

Plant living barriers or bamboo/tree barriers on windward edge of field

Use of herbicides for weed control

Crop rotation Exclude insect pests by using vegetable tunnels and micro-tunnels

Farm use of a locked storage building for pesticides

Use of green manure crops Use of biodiversity or energy conservation practices

Farmer use of pesticide in-ground compost trap for depositing and capturing spilled or leftover pesticides

Farmer ability to correctly identify pests and their damage

Crop stalks, residue and dropped fruit destruction/composting season end

Farmer use of receptacle for empty pesticide bottle disposal

ANNEX 4: PESTICIDE AIS PROPOSED FOR PERSUAP ANALYSIS: PESTICIDE ACTIVE INGREDIENTS USED BY BCI FARMERS IN 2014 COTTON PRODUCTION, AS ANALYZED BY BCI

PESTICIDE ACTIVE INGREDIENT CAS_NUMBER USE TYPE BCI COUNTRY TOTAL TOXIC LOAD

1-Naphthylacetic acid 86-87-3 PGR IN, PK 54

Abamectin 71751-41-2 I PK 87

Acephate 30560-19-1 I IN, PK, 60

Acetamiprid 135410-20-7 I IN, ML, MZ, PK, SN, 50

Acetochlor 34256-82-1 H IN, PK, ML, 76

Azocyclotin 41083-11-8 I IN 64

Azoxystrobin 131860-33-8 F IN 55

Beta-cyfluthrin 68359-37-5b I IN 66

Bifenthrin 82657-04-3 I IN, PK 99

Bromopropylate 18181-80-1 I IN 72

Buprofezin 69327-76-0 I IN, PK 73

Carbaryl 63-25-2 I IN 76

Carbendazim 10605-21-7 F IN, PK 80

Carbofuran 1563-66-2 I IN 87

Carbosulfan 55285-14-8 I IN 92

Cartap hydrochloride 15263-52-2 I IN 48

Chlorantraniliprole 500008-45-7 I IN 63

Chlorfenapyr 122453-73-0 I IN, PK 75

Chlormequat chloride 999-81-5 PGR IN 31

Chlorpyrifos 2921-88-2 I IN, ML, PK 80

Clethodim 99129-21-2 H IN, PK 49

Clofentezine 74115-24-5 I IN 80

Copper oxychloride 1332-40-7 F IN 77

Cyclanilide 113136-77-9 PGR IN 51

Cyfluthrin 68359-37-5 I IN 71

88

Cypermethrin 52315-07-8 I IN, ML, PK 81

Cypermethrin, alpha 67375-30-8 I IN, ML 82

Cypermethrin, beta 52315-07-8b I IN, ML 66

Deltamethrin 52918-63-5 I IN, PK 80

Diafenthiuron 80060-09-9 I IN, PK 66

Dichlorvos 62-73-7 I IN, PK 79

Difenoconazole 119446-68-3 F IN 71

Diflubenzuron 35367-38-5 I IN, PK 61

Dimethoate 60-51-5 I IN, PK 81

Dinotefuran 165252-70-0 I IN 68

Diuron 330-54-1 H IN 56

Emamectin 119791-41-2 I ML, PK 90

Emamectin benzoate 155569-91-8 I IN, ML, MZ, PK, SN 90

Endosulfan 115-29-7 I PK 72

Esfenvalerate 66230-04-4 I IN 80

Ethephon 16672-87-0 PGR IN 46

Ethion 563-12-2 I IN 82

Etoxazole 153233-91-1 I PK 57

Fenpyroximate 134098-61-6 I IN 62

Fipronil 120068-37-3 I IN 98

Flonicamid 158062-67-0 I IN, PK, 48

Flubendiamide 272451-65-7 I IN, ML, PK, SN 49

Fluometuron 2164-17-2 H ML, SN 76

Glyphosate 1071-83-6 H IN, MZ, SN 51

Haloxyfop-R-methyl 72619-32-0 H ML 60

Hexaconazole 79983-71-4 F IN 67

Hexythiazox 78587-05-0 I IN 55

Imidacloprid 138261-41-3 I IN, ML, PK, SN 71

Indoxacarb 173584-44-6 I IN, PK, ML 74

Lambda-cyhalothrin 91465-08-6 I IN, ML, MZ, PK, SN 84

Lufenuron 103055-07-8 I IN, PK 78

89

Malathion 121-75-5 I ML, PK 73

Mancozeb 8018-01-7 F IN 67

Mepiquat chloride 24307-26-4 PGR IN 27

Methamidophos 10265-92-6 I IN 80

Methomyl 16752-77-5 I IN 76

Methoxyfenozide 161050-58-4 I IN 62

Metiram 9006-42-2 F IN 61

Metolachlor 51218-45-2 H PK 70

Monocrotophos 6923-22-4 I IN 84

Nitenpyram 150824-47-8 I IN, PK 57

Novaluron 116714-46-6 I IN 67

Omethoate 1113-02-6 I IN 69

Oxadiargyl 39807-15-3 H IN 61

Oxydemeton-methyl 301-12-2 I IN 75

Paraquat dichloride 1910-42-5 H IN 62

Parathion 56-38-2 I IN 89

Pendimethalin 40487-42-1 H IN, ML, PK 78

Phorate 298-02-2 I IN 94

Phosphamidon 13171-21-6 I IN 100

Phoxim 14816-18-3 I IN, PK 71

Profenofos 41198-08-7 I IN, ML, MZ, PK, SN 72

Prometryn 7287-19-6 H ML, SN 64

Propargite 2312-35-8 I IN, PK 75

Propiconazole 60207-90-1 F IN 72

Pyraclostrobin 175013-18-0 F IN 55

Pyridaben 96489-71-3 I IN 62

Pyriproxyfen 95737-68-1 I IN, PK 58

Pyrithiobac-sodium 123343-16-8 H IN 54

Quinalphos 13593-03-8 I IN 65

Quizalofop-ethyl 76578-14-8 H IN 77

Quizalofop-p-tefuryl 119738-06-6 H IN 61

90

S-Metolachlor 87392-12-9 H IN, PK 52

Spinosad 168316-95-8 I IN, PK 75

Spiromesifen 283594-90-1 I IN, ML, PK 60

Spirotetramat 203313-25-1 I IN, PK, SN 53

Sulfoxaflor 946578-00-3 I PK 40

Sulphur 7704-34-9 F IN 30

Tau-fluvalinate 102851-06-9 I IN 54

Tebuconazole 107534-96-3 F IN 68

Teflubenzuron 83121-18-0 I IN, ML 83

Thiamethoxam 153719-23-4 I IN, PK 65

Thidiazuron 51707-55-2 PGR IN 57

Thiodicarb 59669-26-0 Mo IN 74

Thiram 137-26-8 F IN, ML 63

Triazophos 24017-47-8 I IN, PK 86

Trifloxysulfuron sodium 199119-58-9 H ML, PK, SN 48

Trifluralin 1582-09-8 H PK 84

Bacillus thuringiensis 68038-71-1 I IN 12

Neem oil 8002-65-1 I IN, PK 12

ANNEX 5: PERSUAP ANALYSES OF PESTICIDE ACTIVE INGREDIENTS Introduction to Annex 5

Annex 5 below compiles all of the AIs in pesticides (natural and synthetic) for which BEO approval is being requested (also compiled in the Executive Summary). Project decision-makers—especially those who interface at the field level with beneficiary farmers—are encouraged to look at the label of potential pesticide choices to determine the AIs contained in them and then use this Annex as a quick reference guide to human and environmental acute and chronic attributes and issues with each chemical.

The pesticide attributes include pesticide class (to manage resistance by rotating chemicals from different classes), EPA registration and Restricted Use Pesticide (RUP) status (to comply with Regulation 216) and acute toxicity (judged by this document to be safe, or not, for smallholder farmers—most Class I chemicals are not considered safe for smallholder farmers). Annex 5 also presents chronic health issues, water pollution potential, and potential toxicities to important non-target organisms like fish, honeybee pollinators, birds and several aquatic organisms.

Further, Annex 5 contains basic pieces of human safety and environmental data needed for the various analyses required throughout the PER 12-factor analysis; it is referred to throughout this document. Accordingly, this PERSUAP provides useful tools for evaluating and choosing among IPM options, including natural and synthetic pesticides, while adhering to 22 CFR 216.

Key to Annex 5 matrix, below:

RUP: Few = one or two products; Some = a third of products; Most/All = most or all products containing the AI are labeled RUP by EPA

WHO Acute Toxicity Classes: O = Obsolete; Ia = Extremely Hazardous; Ib = Highly Hazardous;

II = Moderately Hazardous; III = Slightly Hazardous; U = Unlikely to present acute hazard in normal use

EPA Acute Toxicity Classes: I = Extremely Toxic; II = Highly Toxic; III = Moderately Toxic;

IV = Slightly Toxic

Chronic Human Toxicity: KC = Known Carcinogen; PC = Possible Carcinogen; LC = Likely Carcinogen; ED = Potential Endocrine Disruptor; RD = Potential Reproductive & Development Toxin; P = Parkinson’s Disease Risk

Ecotoxicity: NAT = Not Acutely Toxic; PNT = Practically Not Toxic; ST = Slightly Toxic; MT = Moderately Toxic; HT = Highly Toxic; VHT = Very Highly Toxic

Reference websites used to find pieces of data contained in Annex 5: See references at the end of the report.

Approved Cotton Insecticides and Miticides

Reg 216 Factors E & G: Ecotoxicity, Non-target Impacts

Insecticide and Miticide Active Ingredients approved for control of insects and mites on cotton

Reg 216, Factor I Availability of Other Pesticide Options: AI chemical classes for rotation to avoid development of resistance, and reduction of effectiveness (Factor F)

Reg 216, Factor A

: Is AI E

PA

R

egistered?

Reg 216, Factor A

: Any R

estricted U

se Pesticides w

ith this AI?

Reg 216 Factor E

: WH

O A

cute T

oxicity Class

Reg 216 Factor E

: EP

A A

cute T

oxicity Classes

Reg 216 Factor E

: Chronic T

oxicity

Reg 216 Factors G

& H

(Non-target

ecosystem, H

ydrology): G

roundwater contam

inant

fish

bees

birds

amphibians

worm

s

Mollusks

Crustaceans

Aquatic Insects

Plankton

abamectin miticide microbial extract yes some NL II, III ED, RD no data ST HT PNT

MT

HT VHT VHT

acephate organophosphate yes no III II, III PC, ED potential MT HT MT ST ST

ST

Acetamiprid neonicotinoid yes no NL III NL potential NAT MT HT

NAT

Bacillus thuringiensis/BT microbial yes no III III NL no data MT PNT NAT NAT

ST ST

beta-cyfluthrin synthetic pyrethroid yes few II II, III ED no data VHT HT PNT

ST

VHT VHT

beta-cypermethrin synthetic pyrethroid yes some NL II, III PC, ED no data HT HT ST

HT

Bifenthrin synthetic pyrethroid yes some II II, III PC, ED, RD no data VHT HT MT

HT

Buprofezin insect growth regulator yes no U II, III PC no data MT ST MT NAT MT

Carbaryl carbamate yes no II II, III KC, PC, ED potential MT HT PNT MT VHT ST HT HT MT

Chlorantraniliprole anthranilic diamide yes no NL III NL no data NAT MT MT

MT

HT

Cyfluthrin synthetic pyrethroid yes some II II, III ED no data VHT HT PNT

ST

VHT VHT

Diflubenzuron insect growth regulator yes some U III ED no data ST NAT PNT NAT

NAT NAT ST MT

Dimethoate organophosphate yes no II II PC, ED, RD potential ST VHT VHT HT MT VHT HT VHT MT

Dinotefuran neonicotinoid yes no NL III NL no data MT HT MT

Esfenvalerate synthetic pyrethroid yes few II II, III ED no data VHT HT ST VHT

ST HT

etoxazole miticide/insecticide diphenyl oxazoline IGR yes no NL III NL no data MT NAT MT

MT

HT MT

fenpyroximate miticide/insecticide pyrazole miticide yes no NL II NL no data HT MT MT

MT

HT

Flubendiamide benzene dicarboxamide yes no NL III NL no data HT NAT MT

MT

HT

93

Approved Cotton Insecticides and Miticides

Reg 216 Factors E & G: Ecotoxicity, Non-target Impacts

Insecticide and Miticide Active Ingredients approved for control of insects and mites on cotton

Reg 216, Factor I Availability of Other Pesticide Options: AI chemical classes for rotation to avoid development of resistance, and reduction of effectiveness (Factor F)

Reg 216, Factor A

: Is AI E

PA

R

egistered?

Reg 216, Factor A

: Any R

estricted U

se Pesticides w

ith this AI?

Reg 216 Factor E

: WH

O A

cute T

oxicity Class

Reg 216 Factor E

: EP

A A

cute T

oxicity Classes

Reg 216 Factor E

: Chronic T

oxicity

Reg 216 Factors G

& H

(Non-target

ecosystem, H

ydrology): G

roundwater contam

inant

fish

bees

birds

amphibians

worm

s

Mollusks

Crustaceans

Aquatic Insects

Plankton

hexythiazox miticide insect growth regulator yes no U III PC no data HT NAT MT

MT

MT

Imidacloprid neonicotinoid yes no II II, III NL potential NAT

MT

VHT

indoxacarb (S isomer) oxadiazine yes no O III NL no data MT HT HT

NAT

MT

lambda cyhalothrin synthetic pyrethroid yes some II II, III ED no data VHT HT PNT

VHT VHT VHT VHT

Malathion organophosphate yes no III II PC, ED potential MT HT MT HT ST VHT MT VHT HT

Methoxyfenozide diacylhydrazine yes no U III NL potential MT MT ST

ST

HT MT

neem oil botanical yes no NL III NL no data ST NAT NAT MT

MT

Novaluron insect growth regulator yes no NL II, III NL no data MT MT MT

MT

HT

Pyriproxyfen insect growth regulator yes no U III NL no data MT MT MT

MT

MT

VHT

Spinosad microbial yes no U III NL no data MT HT PNT

ST

HT MT

Spiromesifen keto-enol yes no NL III NL no data HT ST MT

MT

sulfur/sulphur miticide inorganic yes no U III NL no data NAT NAT NAT NAT

NAT

Thiamethoxam neonicotinoid yes few NL III PC no data PNT HT PNT

PNT PNT PNT PNT

94

Approved Cotton Herbicides, PGRs, Defoliants and Desiccants

Reg 216 Factors E & G: Ecotoxicity, Non-target Impacts

Herbicide Active Ingredients proposed for control of crop diseases and thus proposed for Reg 216 analysis

Reg 216, Factor I Availability of Other Pesticide Options: AI chemical classes for rotation to avoid development of resistance, and reduction of effectiveness (Factor F)

Reg 216, Factor A

: Is AI E

PA

R

egistered?

Reg 216, Factor A

: Any R

estricted U

se Pesticides w

ith this AI?

Reg 216 Factor E

: WH

O A

cute T

oxicity Class

Reg 216 Factor E

: EP

A A

cute T

oxicity Classes

Reg 216 Factor E

: Chronic T

oxicity

Reg 216 Factors G

& H

(Non-target

ecosystem, H

ydrology): G

roundwater contam

inant

fish

bees

birds

amphibians

worm

s

Mollusks

Crustaceans

Aquatic Insects

Plankton

1-naphthylacetic acid (NAA) PGR yes no U II, III NL no data ST NAT NAT

NAT

NAT

chlormequat chloride quaternary ammonium PGR yes no III II, III NL no data NAT MT MT

MT

NAT

ST

cyclanilide malonanilate yes no NL I, II, III none no data ST MT MT

MT

MT

MT

ethephon organophosphate PGR yes no U I NL no data NAT

ST

MT

NAT NAT NAT

fluometuron urea yes no U II, III PC potential ST

ST

MT

glyphosate phosphonoglycine yes no U II, III NL potential ST ST NAT

PNT

MT

ST

mepiquat chloride quaternary ammon. PGR yes no III II, III NL potential ST MT MT

MT

HT

VHT

metolachlor chloroacetamide yes some III III PC, ED known MT ST MT

MT

MT

pendimethalin dinitroanaline yes no III III PC, ED no data MT NAT ST

MT MT

prometryn triazine yes no U III RD potential MT NAT PNT ST NAT

NAT ST ST

pyrithiobac/pyrothiobac-sodium pyrimidinyloxybenzene yes no U II PC potential NAT MT NAT

NAT

quizalofop/quizalfop-p-ethyl a propionic acid yes no NL I, III NL no data MT MT MT

MT

MT

quizalofop-p-tefuryl aryloxyphenoxypropionate yes no II III PC potential MT MT NAT

MT

MT

s-metolachlor chloroacetanilide yes no NL III PC, ED known MT ST MT

MT

MT

thidiazuron urea PGR defoliant yes no U III NL no data ST NAT

MT

trifloxysulfuron (sodium) sulfonylurea yes no NL III NL potential NAT MT MT

MT

NAT

trifluralin dinitroanaline yes no U II, III PC, ED no data HT PNT PNT MT HT ST ST ST MT

95

Approved Cotton Fungicides

Reg 216 Factors E & G: Ecotoxicity, Non-target Impacts

Fungicide Active Ingredients proposed for control of crop diseases and thus proposed for Reg 216 analysis

Reg 216, Factor I Availability of Other Pesticide Options: AI chemical classes for rotation to avoid development of resistance, and reduction of effectiveness (Factor F)

Reg 216, Factor A

: Is AI EPA

R

egistered?

Reg 216, Factor A

: Any R

estricted U

se Pesticides with this A

I?

Reg 216 Factor E: W

HO

Acute

Toxicity Class

Reg 216 Factor E: EPA

Acute

Toxicity Classes

Reg 216 Factor E: C

hronic Toxicity

Reg 216 Factors G

& H

(Non-target

ecosystem, H

ydrology): G

roundwater contam

inant

fish

bees

birds

amphibians

worm

s

Mollusks

Crustaceans

Aquatic Insects

Plankton

azoxystrobin strobin yes no U III NL potential MT MT MT

MT

MT

VHT

difenoconazole azole yes no III III PC no data MT MT ST

MT

MT

HT

mancozeb dithiocarbamate yes no U III PC, ED, RD no data MT MT ST HT

NAT

Pyraclostrobin strobin yes no NL II, III NL no data ST MT MT

MT

HT

sulfur/sulphur inorganic yes no U III NL no data NAT NAT NAT NAT

NAT

Tebuconazole azole yes no III II, III PC potential MT MT MT

MT

MT MT HT

Thiram (diothio) carbamate yes no III III ED, RD no data HT NAT PNT VHT HT

NAT HT HT

ANNEX 6: PESTICIDE AIS ANALYZED AND REJECTED FOR BCI ACTIVITIES Insecticide and Miticide AIs not registered by EPA for same or similar use on field agriculture cotton

• azocyclotin miticide • bromopropylate • carbosulfan • cartap hydrochloride • chlorfenapyr miticide (not registered for use on cotton, due to risks to birds, registered for use in

greenhouses, resistance has developed to spider mites) • clofentezine miticide (not registered for use on cotton, due to risks to birds, registered for use in greenhouses,

resistance has developed to spider mites) • cypermethrin (registered for spraying in cracks/crevices in food warehouses, not for use on cotton) • diafenthiuron • dichlorvos/DDVP (only one non-RUP product is registered for use in cattle ear tags, not cotton) • emamectin, emamectin benzoate (the only non-RUP product is registered for use in cockroach bait, not

cotton) • endosulfan (also on POPs list) • ethion • fipronil • lufenuron (not registered for use on cotton, only registered for use in termite baits) • methamidophos (also on PIC list) • methomyl (only non-RUP products are registered for use in fly baits, not cotton) • monocrotophos (also on PIC list) • nitenpyram • omethoate • parathion (also on PIC list) • phosphamidon (also on PIC list) • phoxim • pyridaben miticide (not registered for use on cotton) • quinalphos • spirotetramat (not registered for use on cotton) • sufoxaflor • tau-fluvalinate (EPA has rescinded registration for use on cotton) • teflubenzuron • triazophos

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Insecticide and Miticide (and one molluscicide) AIs in EPA-classified restricted use products (RUPs)

• alpha cypermethrin, cpyermethrin alpha • carbofuran • chlorpyrifos-ethyl • deltamethrin (RUP specifically for use on cotton) • emamectin, emamectin benzoate (Proclaim, Denim, the only two products registered for agriculture use are

RUP) • flonicamid • methomyl • oxydemeton methyl • phorate • profenofos • propargite miticide • thiodicarb (also molluscide)

Insecticide and Miticide AIs Banned or Severely Restricted Internationally

Stockholm Convention on Persistent Organic Pollutants (POPs)

• endosulfan

Rotterdam Convention on Prior Informed Consent (PIC) highly toxic pesticide ingredients

• methamidophos • monocrotophos • parathion • phosphamidon

Herbicide and PGR AIs not registered by EPA for same or similar use

• haloxyfop R methyl • oxadiargyl

Herbicide AI in EPA-classified restricted use products (RUPs)

• acetochlor • paraquat (dichloride)

Herbicide AI Known to be a Carcinogen

• diuron (also known water pollutant)

Fungides and PGRs not registered by EPA for same or similar use

• carbendazim (only registered for use in tree injection, paint, sealing and coating products) • copper oxychloride (not registered for use on cotton) • hexaconazole (not registered)

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• metiram (not registered for use on cotton) • propiconazole (not registered for use on cotton)

Molluscicide AI in EPA-classified restricted use product (RUP)

• thiodicarb (also insecticide)

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ANNEX 7: TRAINING TOPICS AND SAFE PESTICIDE USE WEB RESOURCES

GAP/IPM

• Pest identification: How to recognize common important pests and diseases • Monitoring: The importance of frequent crop monitoring for pests, diseases and weeds • GAP and IPM concepts, tactics and tools found in Annex 1 that can reduce pesticide use and associated risks

on specific pests of project target crops • PMPs—Pest Management Plans: Creating and using these farm crop-management tools

PESTICIDES

• Understanding pesticides: Quality, types, classes and acute toxicities of common pesticides • Regulations: US, EU and Ukraine laws that guide pesticide registration and use • Natural pesticides: Raise awareness of and promote the use of natural pesticides found in Annexes 1, 4, 5 and

7 as well as green-label synthetic pesticides with relatively low risks • Spot Treatments: The importance of spot treatments if needed (instead of crop-wide treatments) • MSDS: How to use MSDSs for pesticide-specific information on risks and risk reduction measures • REI—Re-Entry Intervals: Pesticide-specific risks associated with entering a sprayed field too soon after the

spray operation • PHI—Pre-Harvest Interval: Pesticide-specific risks associated with harvesting a crop before pesticides have

had a chance to break down • MRL—Maximum Residue Level: Risks associated with pesticide residues on human food • Vulnerable individuals: The importance of keeping children, pregnant women, elderly and infirm away from

the field while spraying and kept out after spraying • Human and environmental risks: Risks associated with more commonly-used pesticides (use information

from MSDSs and Annex 7) • When to spray: Early in the morning, late in the afternoon, or night without wind or rain • Use of recommended PPE: Why it is used (see product MSDSs, product labels and web reference below) • Proper use and maintenance of sprayers, including proper sprayer calibration and spray nozzle choice • Proper cleanup & post spray hygiene • Safe Use: How to purchase, transport, store and use pesticides safely (“safe purchase” requires quality, brand-

name products) • Maintenance: of PPE and sprayers • Monitoring for the development of pesticide resistance • Proper collection and disposal of pesticide rinseate and packaging (see disposal web reference below and

MSDSs) • The use of pesticide spray buffer zones near schools, water resources, organic crop production, apiaries, bird

sanctuaries, biodiversity enclaves, national parks or other sensitive areas. • How to reduce and mitigate risks to critical environmental resources and biodiversity (found in PER Factors

E and G)

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• Honeybees: Ensuring pesticide applicators notify beekeepers about spray activities, and spray early morning or late afternoon when no heavy winds or rain are present

• Water Pollution: Raise awareness of pesticides (especially some herbicides) with high ground water contamination potential where water tables are high or easy to reach (use Annex 7 and MSDSs)

• Exposure routes: Ways pesticides enter the body and ways to mitigate entry • Basic first aid: Understanding how to treat pesticide poisonings (see first aid web reference and MSDSs) • Record-keeping: Pesticide used, when used, which crop, how applied, who applied

WEB RESOURCES FOR SAFE PESTICIDE USE TRAINING

General Mitigation of Potential Pesticide Dangers General Measures to Ensure Safe Use: http://pdf.usaid.gov/pdf_docs/PNADK154.pdf, Chapter 13

EPA Recommended Worker Protection Standards: http://www.epa.gov/oppfead1/safety/workers/equip.htm (all types of PPE)

http://www.cdc.gov/nasd/docs/d001701-d001800/d001797/d001797.html (respiratory PPE)

Routes of Pesticide Exposure and Mitigation of Risks:

http://pdf.usaid.gov/pdf_docs/PNADK154.pdf, Chapter 13

Basic First Aid for Pesticide Overexposure:

http://pdf.usaid.gov/pdf_docs/PNADK154.pdf, Chapter 13

International PIC & POPs Lists:

PIC Pesticides and Industrial Chemicals (http://www.pic.int)

POPs Pesticides and Chemicals (http://www.pops.int)

Pesticide Disposal Options:

http://www.epa.gov/oppfead1/labeling/lrm/chap-13.htm

ANNEX 8: BCI STRATEGY FOR COMPLYING WITH PERSUAP MITIGATION CONDITIONS Note: Technical specialists at the BCI secretariat drafted this Annex in response to the PERSUAP that the Cadmus Group delivered in August 2016. The Global Development Lab BEO negotiated and approved the final content of this Annex.

INTRODUCTION

On August 18th 2016, USAID provided the BCI secretariat with a PESTICIDE EVALUATION REPORT AND SAFER USE ACTION PLAN (PERSUAP). The PERSUAP indicates the conditions under which BCI is able to benefit from a USAID grant and follows federal regulation 22 CFR 216 (Regulation 216), which is intended ensure that any introduction of pesticides through USAID-funded programs does not have unintended negative impacts on people and the environment.

The BCI context is atypical mainly because the BCI program does not introduce or fund pesticides or promote their use. BCI acknowledges that farmers are starting from a baseline in which they often use pesticides indiscriminately in their cotton production practices. BCI fosters, through its voluntary standard system, a progressive reduction in pesticide volume, toxicity, and risk.

Although the procurement, distribution, and use of pesticides are not part of any activities under the USAID-funded project, BCI through its network of Implementing Partners does provide guidance to farmers on safer use of pesticides, and BCI enables farmers to make informed decisions about the selection and use of pesticides. Regulation 216 therefore applies, and the PERSUAP includes seven mitigation conditions (both requirements and recommendations) for BCI’s implementation of the USAID grant.

The BCI secretariat is the sole recipient of the grant from USAID. Therefore, any conditions of the grant described in the associated PERSUAP apply to the BCI secretariat.

This PERSUAP Annex identifies a set of measures that the BCI secretariat will put in place in response to the PERSUAP. All measures can be justified within the constraints of the Better Cotton Standards System (BCSS). The BCSS itself is constrained by the ISEAL82 Codes of Good Practices, notably the Code of Good Practice for Setting Social and Environmental Standards and the Code of Good Practice for Assuring Compliance with Social and Environmental Standards. These codes also refer to international normative documents such as the WTO Technical Barriers to Trade (TBT) Agreement Annex 3 Code of good practice for the preparation, adoption and application of standards and ISO/IEC Guide 59 Code of good practice for standardization.

The BCI PERSUAP includes seven mitigation conditions (numbered 1-7 below) that BCI must address. BCI will put in place the following measures with respect to the seven conditions.

82 ISEAL represents the movement of credible sustainability standards. Its mission is to strengthen sustainability standards for the benefit of people and the environment and aims to define credibility for sustainability standards. As a full ISEAL member, BCI needs to demonstrate ability to meet all ISEAL Codes of Good Practice and accompanying requirements.

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CONDITION 1 - ONLY PESTICIDES APPROVED BY THE PERSUAP CAN BE SUPPORTED BY USAID-FUNDED BCI ACTIVITIES

BCI does not and is not able to support or encourage the use of any particular pesticide Active Ingredients (AIs), but BCI does support good decisionmaking in relation to the selection of pesticides and decisions to spray, as part of a well-developed farmer’s Integrated Pest Management Plan. Each year, as new pesticides become available for use or are recommended for use by relevant local authorities across the 4 target countries where BCI will operate with USAID funds (India, Pakistan, Mozambique, and Senegal), farmers will be required to report their use of new AIs. BCI commits to:

i. Continue enforcing the requirement that only AIs registered nationally for use on cotton are used. Non-conforming producers will be disqualified.

ii. Monitor any new AI used—through the Better Cotton Standard System (BCSS) Result Indicator collection process—and report to USAID on a seasonal (annual) basis for each of the 4 target countries (India, Pakistan, Mozambique, and Senegal). Reports will include the names of each new AI, frequency of use (number of farmers), and volume used.

iii. Analyze the hazard/toxicity level of each new AI reported against the Toxic Load Indicator (TLI) methodology and its 15 hazard/toxicity parameters, as well as classification with respect to 3 relevant international conventions (Rotterdam, Stockholm, and Montreal Protocol of the Vienna Convention). BCI will report this to USAID.

iv. Progressively put in place, throughout the project duration, all reasonable measures within its remit, to educate, train, encourage, reward, and otherwise create incentives for BCI Implementing Partners and producers to progress towards the PERSUAP’s recommendation/requirements, within the limit of BCI’s resources and as supported by the grant from USAID. This includes promoting the cautions associated with the PERSUAP’s list of approved pesticides given in Section 7.2 of the PERSUAP and repeated in the Executive Summary.

Actions listed in the Safer Use Action Plan (SUAP) for Condition 1 (See PERSUAP Section 7.4)

Distribute copies of the list of allowed AIs with matching commercial product names to all BCI consortium members and project field staff

BCI will distribute to, and train all BCI Country team staff in the 4 target countries on the PERSUAP (including annex 5 and 6) as well as this PERSUAP Annex and related activity plan. BCI will refer to the lists of nationally registered active ingredients for use in cotton production as the base list of pesticides eligible for use in any given specific country. None of the BCI country teams in charge of implementing this USAID project’s activities is involved in pesticide procurement, distribution, use, or selection. BCI’s Better Cotton Standards System (BCSS) requires, however, that all the stakeholders who voluntarily participate in the BCS have the list of eligible AIs on file and consult it in case of doubts. There are no consortium members, since BCI will not have any sub-grantees. BCI can restrict the use of problematic AIs (with interventions ranging from discouraging to banning) based on universally recognized hazard parameters (see discussion associated with condition 2 below).

Ensure USAID-funded pesticide “support” is limited to pesticides approved by this PERSUAP and only with specified use restrictions

See above and discussion associated with condition 2 below

Continue verification throughout life-of-project

See above

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CONDITION 2 - BCI USAID-FUNDED ACTIVITIES MUST NOT SUPPORT AIS REJECTED BY THIS PERSUAP (ANNEX 6)

Among all of the AIs analyzed and rejected by the PERSUAP in Annex 6, there are 49 AIs that were reported to be used by farmers participating in the BCI program in the 4 target countries in 2014. (2014 is considered BCI’s baseline year for the purposes of establishing compliance with and implementing this mitigation condition). Abiding the requirement to totally reject these AIs will be challenging for the BCI secretariat, considering that the selection and use of pesticides is done by producers themselves and lies largely beyond the role and remit of the BCI secretariat, the sole recipient of this grant. The BCI secretariat commits, however, to take the concrete steps elaborated in this section to endeavor to comply with Condition 2, monitor and report on progress, and learn and report on challenges and limitations.

When proposing interventions aimed at restricting the use of pesticides, BCI can and customarily does refer to risk and hazard parameters that are science-based and universally recognized. Therefore, BCI has conducted an in-depth analysis of the AIs analyzed and rejected in the PERSUAP (Annex 6), including all hazard classifications and frequency of use across the 4 target countries.

BCI’s analysis of the PERSUAP’s Annex 6 resulted in subdividing the 49 AIs into 6 groups ranked on decreased hazard levels. BCI will apply to these 6 groups a set of 6 distinct interventions of decreased levels of prescription and stringency. The analysis also identified those AIs within Annex 6 that are most frequently used – indicating which AIs are expected to require more time and targeted support interventions to facilitate their phasing out.

When assessing the 6 hazard groups, the following parameters were considered:

• Relevant international conventions (Stockholm, Rotterdam, Montreal Protocol of the Vienna Convention) • Hazard classifications already included in BCI’s Production Principles and Criteria (PPC), namely WHO class

1a and 1b • Specific US EPA classifications for acute mammalian toxicity • The 15 existing hazards/toxicity parameters included in BCI’s Toxic Load Indicator (TLI) methodology,

which builds on GHS83 classifications but also refers to a few relevant EPA classifications: i. Acute Toxicity (Oral, dermal, inhalation) ii. Carcinogenicity iii. Mutagenicity iv. Reproductive & developmental toxicity v. Acceptable Daily Intake (ADI) & Acceptable Operator Exposure Level (AOEL) vi. Algae (Acute EC50 up to 96 h (growth)) vii. Waterflea (Daphnia) & Fish (Acute LC50 up to 96h) viii. Birds (Acute LD50 up to 96h) ix. Beneficial organisms (Lethal rate 50%) x. Honey bees (acute LD50 per bee) xi. Bioconcentration factor (BCF); log KOW P xii. Persistence in soils, sediments and water xiii. Leaching potential xiv. Volatility xv. Half-life on plant

When developing Annex 6, the PERSUAP authors also considered many of the same parameters above. Listed below (in decreasing order of identifiable hazard) are the 6 groups into which BCI’s analysis divided the 49 AIs that are listed in Annex 6 and are frequently used in the four target countries.

83 Globally Harmonized System of Classification and Labelling of Chemicals of the United Nations

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• Annex 6 – Group 1: AIs already banned in the current version of the BCI Production Principles and Criteria (PPC): Stockholm Convention and those not nationally registered for use in cotton (= 6 AIs)

• Annex 6 – Group 2: AIs listed under the Rotterdam Convention, currently required to be phased out according to the BCI PPC (= 5 AIs)

• Annex 6 – Group 3: AIs classified as extremely or highly acutely toxic to mammals, currently required to be phased out according to the BCI PPC (= 8 AIs)

• Annex 6 – Group 4: AIs classified in the highest hazard categories for carcinogenicity (known or likely), mutagenicity, or reproductive toxicity (= 4 AIs)

• Annex 6 – Group 5: AIs with an overall TLI score significantly higher than average (= Approx. 12 AIs; To Be Refined after refinement of the TLI scores)

• Annex 6 – Group 6: AIs with an overall TLI score not significantly higher than average (= Approx. 14 AIs; To Be Refined after refinement of the TLI scores)

BCI will put in place the following interventions, customized for each category.

Annex 6 – Group 1: BCI will not introduce any new intervention because these AIs are already banned and are not used by Better Cotton farmers. Any farmer who uses these will be disqualified. The 6 AIs that had originally been submitted for the PERSUAP analysis had been reported by farmers that were either comparison farmers (non-BCI farmers), or from disqualified farmers.

Annex 6 – Group 1 AIs already banned by BCI Standards System

Active Ingredient Classification Use Frequency (2014 baseline)

Carbosulfan Not in use Not in use

Cartap hydrochloride Not in use Not in use

Endosulfan Not in use Not in use

Haloxyfop R methyl Not in use Not in use

Hexaconazole Not in use Not in use

Oxadiargyl Not in use Not in use

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Annex 6 – Group 2: BCI proposes to submit to the Standards review public consultation84 a proposal to require AIs in the Rotterdam Convention to be banned as minimum conformity criteria. This proposal has already been discussed and agreed with the standards revision committee, but its approval and the timing of its enforcement are dependent on the outcome of the public consultation.

Annex 6 – Group 2 AIs listed under the Rotterdam Convention

Active Ingredient Classification Use Frequency (2014 baseline)

Carbofuran Rotterdam PIC 0.003% (IN)

Methamidophos Rotterdam PIC 0.007% (IN)

Monocrotophos Rotterdam PIC 47.48% (IN)

Parathion Rotterdam PIC 0.26% (IN)

Phosphamidon Rotterdam PIC 0.71% (IN)

BCI will conduct the following additional targeted interventions to facilitate the phasing out of Monoctrotophos in India:

o Global and local research on available alternatives to Monocrotophos o Publication of a guidance document or an IP training module on available alternatives to

Monocrotophos o Targeted training of Implementing Partners in India

Annex 6 – Group 3: BCI will submit to Standards review public consultation a proposal to require AIs in this category to be phased out with a strict timeline (3 years for Extremely Hazardous and 6 years for Highly Hazardous). This proposal has already been discussed and agreed with the standards revision committee. BCI furthermore will propose to extend the definition of this criterion, currently solely based on WHO classification, to also include the most stringent rating from either GHS or US EPA. Further expert research is required to identify how US EPA rating can be included, considering this typically applies to formulated products as opposed to pure AIs. The approval of this proposal and the timing of its enforcement are dependent on the outcome of the expert research and public consultation. It must be noted that some stakeholders may object to the introduction of a parameter (US EPA acute toxicity rating) that is not internationally recognized; BCI will do its best to argue the case.

84 BCI follows a rigorous multi-stakeholder procedure each time its Standard (i.e. Production Principles and Criteria) needs to be reviewed and revised: BCI Standard setting and revision procedure. This process meets the requirements of ISEAL’s Code of Good Practice for Setting Social and Environmental Standards. The process necessarily includes several rounds of public consultation. One round of public consultation in planned in November 2016.

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Annex 6 – Group 3 AIs classified as extremely or highly acutely toxic to mammals

Active Ingredient Classification Use Frequency (2014 baseline)

Dichlorvos/DDVP WHO 1b 1.65% (IN); 0.85% (PK)

Emamectin, Emamectin Benzoate EPA AcuTox = 1 1.92% (IN); 24.52% (PK); 73.48% (SN)

Methomyl WHO 1b 0.94% (IN)

Omethoate WHO 1b 0.02% (IN)

Oxydemeton Methyl WHO 1b 0.01% (IN)

Phorate WHO 1a 0.06% (IN)

Propargite EPA AcuTox = 1 0.01% (IN); 1.39% (PK)

Triazophos WHO 1b 20.39% (PK); 17.63% (IN)

BCI will conduct the following additional targeted interventions to facilitate the phasing out of Emamactin in Senegal and Pakistan, as well as Triazophos in India and Pakistan

o Global and local research on available alternatives to Triazophos and Emamectin o Publication of guidance document or an IP training module on available alternatives to Triazophos and

Emamectin o Targeted training of Implementing Partners in India and Pakistan on phasing out Triazophos and

Emamectin o Advocacy activities with local partners and pesticide regulatory agencies of West and Central Africa

regarding the phasing out of Emamectin. NOTE: Use of Emamectin in Senegal is directly prescribed by regional authorities. Training activities will therefore be insufficient, and long-term advocacy work will be required.

Annex 6 – Group 4: BCI will submit to Standards review public consultation a proposal to require AIs in this category to be phased out, with timing dependent on available alternatives. This will effectively mean that all participating farmers who use these AIs will be expected and required to address the phasing out through their annual Continuous Improvement Plans.

Annex 6 – Group 4 AIs classified in the highest hazard categories for carcinogenicity, mutagenicity, or reproductive toxicity

Active Ingredient Classification Use Frequency (2014 baseline)

Carbendazim TLI ReproTox, Mutagen = 10 1.11% (IN)

Diuron Known Carcinogen 0.27% (IN)

Metiram TLI Cancer = 10 0.02% (IN)

Thiodicarb TLI Cancer = 10 1.33% (IN)

Annex 6 – Group 5: For these AIs, BCI was not able to identify any science-based parameters that could justify the creation of a restriction criterion within BCI’s standard. However, these AIs do present a higher than average general level of hazard based on BCI’s TLI methodology, compared to other active ingredients in use. BCI

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therefore proposes to progressively roll out the TLI methodology as a learning and decisionmaking tool for producers, supporting them to make more informed decisions about pesticide selection and identification of alternatives. The hypothesis here is that famers will choose to reduce their overall “toxic load” levels once they get access to information about hazard levels and available alternatives. BCI will furthermore work with like-minded standards systems, through the IPM Coalition, to support the development of a pesticide alternative database. In order to foster best results against Annex 6 elimination, BCI will build the TLI learning tool in such a way that it can encourage users to apply relevant weighting coefficients to key parameters. Applying a weighting coefficient to acute toxicity may be justifiable in the context of smallholder farming in the tropics, and our analysis reveals that it may help single out more of the AIs rejected in Annex 6. The expert committee in charge of overseeing the credible development of the TLI methodology had already ruled out the possibility of adding weighting coefficients to the methodology, as it would have damaged the objectivity and impartiality of the tool, but BCI will propose for users themselves to apply recommended weighing coefficients. Rolling out the TLI learning tool constitutes a major undertaking; its development is dependent on the development of the BCI central data management system and its accessibility by farmers and partners. It is expected to be trialed in one country and then rolled out over a 3-year period.

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Annex 6 – Group 5 AIs with an overall TLI scores significantly higher than average (subject to evolve through weighting

coefficients)

Active Ingredient Classification Use Frequency (2014 baseline)

Fipronil None (TLI > 75) 8.08% (IN)

Teflubenzuron None (TLI > 75) 0.04% (IN)

Alpha Cypermethrin, None (TLI > 75) 0.33% (IN)

Ethion None (TLI > 75) 7.73% (IN)

Cypermethrin None (TLI > 75) 1.88% (IN), 5.35% (PK)

Chlorpyrifos-ethyl None (TLI > 75) 3.40% (IN), 0.50% (PK)

Clofentezine None (TLI > 75) 0.003% (IN)

Deltamethrin None (TLI > 75) 0.93% (IN), 9.32% (PK)

Lufenuron None (TLI > 75) 0.003% (IN), 18.72% (PK)

Copper Oxychloride None (TLI > 75) 4.11% (IN)

Acetochlor None (TLI > 75) 0.11% (IN), 10.76% (PK)

Chlorfenapyr None (TLI > 75) 0.003% (IN), 29.28% (PK)

BCI will conduct in 2018 the following additional targeted interventions to facilitate the phasing out of Lufenuron and Chlorfenapyr in Pakistan, and any other new AIs with high TLI scores that may become used with high frequency in the future.

o Global and local research on available alternatives to Lufenuron, Chlorfenapyr and any other relevant problematic AIs

o Publication of guidance document or an IP training module on available alternatives to the above mentioned AIs

o Targeted training of Implementing Partners in Pakistan and any other relevant country on phasing out of the above mentioned AIs

Annex 6 – Group 6: For these AIs (approximately 14), as for Group 5, BCI was not able to identify any science-based parameters that could justify the creation of a restriction criteria within BCI’s standards. Furthermore, BCI was unable to identify any hazard assessment methodology that would indicate that these AIs are particularly hazardous (compared to the average). As with all other categories, however, BCI will monitor and report on their use. Should any of them see their hazard classification increase (e.g., inclusion as a Rotterdam PIC, new studies demonstrating a high carcinogenicity risk, etc.) or their registration terminated, BCI will be able to measure its reduction of use or elimination.

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Annex 6 – Group 6 AIs with an overall TLI score not significantly higher than average (subject to evolve through weighting

coefficients)

Active Ingredient Classification Use Frequency (2014 baseline)

Bromopropylate None (TLI < 75) To Be Determined

Profenofos None (TLI < 75) 19.36% (IN), 71.41% (IN), 12.46% (PK), 73.71% (SN)

Propiconazole None (TLI < 75) 0.42% (IN)

Phoxim None (TLI < 75) 0.01% (IN), 1.23% (PK)

Diafenthiuron None (TLI < 75) 17.75% (IN), 32.06% (PK)

Quinalphos None (TLI < 75) 0.32% (IN)

Azocyclotin None (TLI < 75) 0.23% (IN)

Paraquat (Dichloride) None (TLI < 75) 0.89% (IN)

Pyridaben None (TLI < 75) 0.01% (IN)

Nitenpyram None (TLI < 75) 0.13% (IN)

Tau-fluvalinate None (TLI < 75) 0.003% (IN)

Spirotetramat None (TLI < 75) 0.003% (IN), 0.58% (PK), 0.67% (SN)

Flonicamid None (TLI < 75) 5.41% (IN), 0.12% (PK)

Sulfoxaflor None (TLI < 75) 0.06% (PK)

Actions listed in the Safer Use Action Plan (SUAP) for Condition 2 (See PERSUAP Section 7.4) Inventory pesticides used by BCI beneficiaries to ensure no USAID “support” (see above) is provided for rejected AIs

The inventory will be done, in the form of systematic monitoring and reporting, for all AIs used (frequency, volume), on an annual basis. This will serve as a tool to evaluate progress towards elimination and reduction of use of pesticide AIs rejected in Annex 6, as proposed above.

Ensure that USAID-funded pesticide “support” is not provided to products containing rejected AIs

See proposal above, aimed at progressive measurable reduction of the use of AIs rejected in Annex 6. Some will be completely eliminated; some are expected to see their use reduced overtime.

In addition to the interventions listed above, BCI will systematically monitor progress and challenges for each intervention and report to USAID on an annual basis. BCI will monitor the use of annex 6 AIs, through BCI’s BCSS Result Indicator collection process and report to USAID on a seasonal (annual) basis, from the 2015 season until the end of the project, for each of the 4 target countries (India, Pakistan, Mozambique, & Senegal). Reports will include the names of each new AI, frequency of use (number of farmers), and volume used. It is also important to note that through the implementation of Integrated Pest Management Plans, and irrespective of AI restriction requirements, BCI has a proven record of helping farmers reduce their dependence on chemical pest controls as well as the overall volume of chemical pesticides significantly.

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RECOMMENDED CONDITION 3 - BCI SHOULD CONTINUE TO PROMOTE GOOD AGRICULTURAL PRACTICES (GAPS) AND DEVELOP PMPS (SEE ANNEX 2) USING RECOMMENDED PREVENTIVE IPM TOOLS & TACTICS

BCI will continue to promote Good Agricultural Practices through the promoting and implementation of its BCSS. BCI will provide guidance on Good Agricultural Practices through the next version of BCI’s PPC, expected to be launched in 2017, which will incorporate extended and improved guidance from the current “PPC explained85” document.

BCI also proposes to develop training modules on the following topics:

• Building quality IPM plans that address all components prescribed in BCI’s PPC. BCI will take into account all relevant guidance from this PERSUAP, notably from annex 3.

• Building, implementing, monitoring, and periodically review Continuous Improvement Plans. • BCI will build a “qualification management system” to ensure all relevant IP staff are trained and

qualified. Actions listed in the Safer Use Action Plan (SUAP) for Condition 3 (See PERSUAP Section 7.4) Adapt/refine/develop pest/disease-specific IPM-based pest management plans (PMPs)

BCI does not develop or implement IPM plans or IPM-based pest management plans. But BCI will continue to promote and require such plans from all participating farmers and will develop a specific IPM training module for IPs before the end of 2017.

Modify PMPs over life of project based on ground-truthing/field experience.

PMPs are an advanced forms of pest management that BCI expects participating farmers to progress towards as part of their IPM plans, but as described in the PERSUAP cannot be expected to be fully implemented by largely illiterates smallholder farmers. All relevant PMP components described in the PERSUAP will be integrated in BCI’s IPM training module. BCI will continue to assess farmers’ conformity against the level of IPM planning as prescribed in BCI’s PPC and will foster and measure continuous improvement.

Develop crop-specific PMP field reference guides, flyers, or posters for farmers to anticipate and manage pests.

BCCI does not interact directly with farmers and therefore does not develop any locally specific farmer training material. BCI will however collect IPM training materials that IPs develop, on an annual basis and at the end of the season, and will facilitate knowledge and learning exchange between IPs.

85 BETTER COTTON PRODUCTION PRINCIPLES & CRITERIA EXPLAINED OCTOBER 2013 http://bettercotton.org/wp-content/uploads/2014/01/Better-Cotton-Production-Principles-and-Criteria-Explained_Final-2013_eng_ext.pdf

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RECOMMENDED CONDITION 4 - BCI SHOULD TAKE NECESSARY STEPS TO PREVENT THE DEVELOPMENT OF PEST RESISTANCE BY USING AND/OR PROMOTING TOOLS RECOMMENDED BY THIS PERSUAP (SEE SECTION 5, FACTOR F)

The need to manage resistance is one of the 5 mandatory components of the IPM plan as required in BCI’s PPC. Resistance management will constitute a key section of the IPM IP training Module that BCI will develop and request all relevant IP staff to take and demonstrate sufficient understanding. BCI will consider all relevant guidance from the PERSUAP to be integrated in the training module as long as it does not conflict with BCI’s standards or local legislation.

Actions listed in the Safer Use Action Plan (SUAP) for Condition 4 (See PERSUAP Section 7.4) Pesticide applications are recorded and efficacy against pests is evaluated

All Pesticide applications will be recorded by participating farmers in their farmer Field Book. BCI will collect, analyze, and report to USAID on a representative sample of farmers (Learning groups), in line with BCI’s Result Indicator Collection program. BCI will train IPs, through the IPM training module, on the need to put in place systems to evaluate the efficacy of selected AIs against pests. Farmers maintain

records and any evidence of pesticide resistance is tracked and reported

RECOMMENDED CONDITION 5 - BCI SHOULD PROVIDE SAFE PESTICIDE USE TRAINING

BCI Implementing Partner (IP) staff and beneficiaries who address pesticides through use of training materials, during training, and on demo trials, should promote Safe Pesticide Use (SPU) through explaining pesticide risks, promotion of pesticide best practices, and safety use training. (Resources and training topics are provided in Annex 7)

BCI will develop in 2017 a SPU training module for IPs. All relevant IP staff will be required to follow the training and demonstrate sufficient understanding. BCI will build a “qualification management system” to ensure all relevant IP staff are trained and qualified. The training module will take into account all relevant guidance from the PERSUAP, notably annex 7 Actions listed in the Safer Use Action Plan (SUAP) for Condition 5 (See PERSUAP Section 7.4) Develop a Training Plan for SPU and IPM training elements specified in Annex 7 for project staff and beneficiaries

BCI will develop in 2017 a SPU training module for IPs. All relevant IP staff will be required to follow the training and demonstrate sufficient understanding. As part of the BCSS, BCI will continue to ensure that all farmers are trained by IPs on Safe Pesticide Use. Relevant resources from Annex 7 will be included. Systemic failure to train farmers will lead to disqualifying Producer Units. BCI will monitor cases of con-conformities and report to USAID on an annual basis.

Develop or source curricula conforming to training elements specified in Annex 7 Implement training plan, providing first-time training to all relevant BCI staff and beneficiaries within 6 months and provide refresher trainings

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CONDITION 6 - TO THE GREATEST DEGREE PRACTICABLE, PESTICIDE-RELATED ACTIVITIES THAT BCI SUPPORTS AND USAID FUNDS MUST REQUIRE USE & MAINTENANCE OF APPROPRIATE PERSONAL PROTECTION EQUIPMENT (PPE) – AS WELL AS SAFE PESTICIDE PURCHASE, TRANSPORTATION, HANDLING, STORAGE, AND DISPOSAL PRACTICES

The use of appropriate PPE and application equipment, as well as appropriate handling, storage and disposal practices for pesticides are all included in BCI’s PPC (Criteria 1.6, 1.7, 1.8, 1.9). As a result, BCI will continue to promote these practices and monitor their level of adoption through its Assurance Program. Producers will be disqualified when they fail to meet minimum requirements, and their performance level will be determined based on their level of adoption of improvement requirements. BCI will monitor level of adoptions thought the annual review of its assurance program, and report to USAID on a seasonal (annual) basis.

Actions listed in the Safer Use Action Plan (SUAP) for Condition 6 (See PERSUAP Section 7.4)

CONDITION 7 - FLOW-DOWN REQUIREMENTS APPLY TO SUB-CONTRACTS AND SUB-AWARDS

Not applicable since grant will not have any sub-grantees.

Implement/observe core risk mitigation measures (PPE and other precautions) identified in the summary section of each extended pesticide profile

Where control is less complete, take all practicable measures to support and promote implementation of these measures

Appropriate PPE and quality application equipment will be addressed through the promotion, enforcement, and monitoring of BCI PPC criteria 1.6 and 1.7

Safest and most appropriate forms of empty pesticide containers disposal will be addressed though the promotion, enforcement and monitoring of BCI PPC Criteria 1.9. Triple-rinsing of pesticide containers will be promoted whenever better disposal practices are not practiced or available.

FAO Best Management Practices form the basis of the BCI’s PPC. FAO recommended best practices for the handling and disposal of pesticides will be revisited and considered during the design of BCI’s SPU training module for IPs (see condition 5)

Whenever providing, supporting or recommending pesticides for use, to the greatest degree practicable, ensure that appropriate PPE and quality application equipment is available and, to the degree possible, require its use

To the greatest degree practicable, enforce triple-rinsing of empty pesticide containers and good disposal practices

For directly supported pesticide stores or transport, and to the greatest degree practicable, ensure that FAO Best Management Practices are met. (See PERSUAP References)

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REFERENCES Baker EL, Zack M, Miles JW, Alderman L, Warren M, Dobbins RD, Miller S, Teeters WR (1978) Epidemic malathion poisoning in Pakistan malaria workers. The Lancet, January: 31–33.

WEBSITES: WEBSITE REFERENCES USED TO DEVELOP THE PERSUAP

International Treaties and Conventions:

POPs website: http://www.pops.int

PIC Website: http://www.pic.int

Basel Convention: http://www.basel.int/

Montreal Protocol: http://ozone.unep.org/new_site/en/montreal_protocol.php

Pakistan malaria poisonings: http://pdf.usaid.gov/pdf_docs/PNACQ047.pdf.

Pesticide poisonings:

http://www.panna.org/resources/panups/panup_20080403

http://www.panna.org/legacy/panups/panup_20060131.dv.html

IPM and PMP websites:

http://www.ipm.ucdavis.edu/

http://edis.ifas.ufl.edu/topic_pest_management http://www.ipmcenters.org/pmsp/index.cfm

http://www.dpi.nsw.gov.au/__data/assets/pdf_file/0005/154769/cotton-pest-management-guide-part1.pdf

Pesticide Research Websites:

http://extoxnet.orst.edu/pips/ghindex.html (Extoxnet Oregon State database with ecotox)

http://www.agf.gov.bc.ca/pesticides/f_2.htm (all types of application equipment)

http://www.greenbook.net/ (pesticide Material Safety Data Sheets)

http://www.epa.gov/pesticides/reregistration/status.htm (EPA Registration Eligibility Decisions)

Ecotoxicity:

http://alamancebeekeepers.org/wp-content/uploads/2012/01/Hazardous-Pesticides.pdf (pesticide toxicity to honeybees)

http://wihort.uwex.edu/turf/Earthworms.htm (pesticide toxicity to earthworms)

Safety:

http://www.epa.gov/oppbppd1/biopesticides/ingredients/index.htm (EPA regulated biopesticides)

http://www.ipm.ucdavis.edu/index.html (IPM, PMPs and pesticide recommendations)

http://edis.ifas.ufl.edu/pdffiles/PI/PI07300.pdf (Restricted Use Pesticides)

http://www.epa.gov/pesticides/health/ (EPA Health & Safety)

http://www.epa.gov/pesticides/PPISdata/ (EPA pesticide product information)

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Personal Protection Equipment (PPE):

http://www.epa.gov/oppfead1/safety/workers/equip.htm (all types of PPE)

FAO guidelines on roles of national and local authorities for safe pesticide management http://www.fao.org/docrep/x1531e/x1531e04.htm