RC Sub-Regional Meeting Proceedings BZ-DOM Sub... · The meeting was opened with a blessing from...

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PROCEEDINGS

SUB-REGIONAL MEETING ON THE IMPLEMENTATION OF THE ROTTERDAM CONVENTION

IDENTIFYING THE ELEMENTS OF A NATIONAL ACTION PLAN OR

STRATEGY

BELIZE – DOMINICA

12-16 NOVEMBER 2007

BELIZE BILTMORE PLAZA, BELIZE CITY, BELIZE

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Sub-regional meeting on the implementation of the Rotterdam Convention Identifying the elements of a national action plan or strategy

Belize – Dominica

12-16 November 2007 Belize Biltmore Plaza, Belize City, Belize

Contents

1. Brief Introduction a. brief description of status quo

2. Objective of the meeting 3. Meeting flow: description of the individual sessions

4. Agenda

5. List of participants

6. National Reports

a. BELIZE b. DOMINICA

7. Elements of a national action plan for implementation of the Rotterdam Convention

a. BELIZE b. DOMINICA

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1. Introduction: At its third meeting in October 2006 the Conference of the Parties (COP3) in Decision RC.3/6 adopted a programme on the national and regional delivery of technical assistance for 2007-2008. The programme is composed of activities that are tailored to the specific needs of individual countries or small groups of countries with a focus on those actions that are deemed necessary for Parties to implement fully the Convention. An important component of this programme is national or sub-regional consultations aimed at helping countries to systematically review the status of implementation of the Convention at the national level. A sub-regional consultation was convened involving Belize and Dominica to review in detail the status of implementation of the Convention within each country and, for the key obligations under the Convention, consider what is to be done, by whom and whether and how things might be improved. Dominica has ratified the Basel and Stockholm Conventions while Belize has ratified the Basel Convention. Both have identified focal points under the Strategic Approach to International Chemicals Management (SAICM). The meeting also provided an opportunity to consider how the work on the Rotterdam Convention might be integrated with ongoing chemicals management activities as well as with relevant regional and global activities such as the Basel and Stockholm Conventions or the Strategic Approach to International Chemicals Management (SAICM). In order to help ensure the effectiveness of the meeting, Belize and Dominica were requested to prepare a brief report on how chemicals were managed in the country, the status of implementation of the Rotterdam Convention and the key challenges faced. Copies of these national reports may be found in Section 3 of this report. 2. Overall Objective: To facilitate a national dialogue among relevant stakeholders on the implementation of the Rotterdam Convention as the basis for identifying the key elements in a national action plan or a strategy for the implementation of the Convention. The discussions took place over a period of 5 days and were structured around a series of plenary sessions and work in breakout groups organized along national lines. A copy of the agenda for the meeting may be found in Section 4 of this report. Participants: There were a total of 20 participants (13 from Belize and 7 from Dominica). They represented a range of stakeholders involved in the chemicals management including Ministries of Environment, Agriculture and Health, Industry and Commerce, Customs as well as representatives of the Pesticide Control Boards and pesticide importers. The participation of a broad range of stakeholders allowed an in depth discussion on the challenges faced and possible solutions in the implementation of the Convention. A list of the meeting participants may be found in Section 5 of this report.

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3. Meeting Flow Opening The meeting was opened with a blessing from Canon Leroy Flowers, followed by welcoming remarks from Mr. Bill Murray on behalf of the Rotterdam Convention Secretariat. Honorable Servulo Baeza, Minister of State in the Ministry of Natural Resources in Belize formally opened the meeting and highlighted the activities aimed at promoting coordinated implementation of related chemicals management activities in the country. Mr. Gene Pollard, of the FAO subregional office in Barbados welcomed participants and offered words of thanks to the government of Belize for hosting and organizing the meeting. Session 2 and Session 3 – Introduction –Status of implementation After a brief presentation on the structure and objectives of the meeting the Secretariat provided a general overview of the Rotterdam Convention which introduced the key provisions of the Convention and the role of the key players in order to ensure a common understanding of a country’s responsibilities under the Convention, what the Convention is and what it is not. Both Belize and Dominica presented their national reports which provided an overview of their national chemicals management infrastructure in their countries including a description of the approval or registration process for pesticides and industrial chemicals and a description of the status of implementation of the Rotterdam Convention in each country. These national reports may be found in Section 6 of the proceedings report. Further presentations on the experience of Jamaica in the implementation of the Convention and an overview of activities on pesticides in the sub region were also provided. Session 4 Review of Key obligations The four sessions reviewed in detail the key obligations under the Convention concerning import responses, notifications of final regulatory actions, severely hazardous pesticide formulations and export notifications. . In each case the Secretariat made a brief introduction highlighting how the obligation fits within the key provisions of the Convention, the role of the DNA and some of the challenges in implementing these obligations. These presentations were followed by presentations on national experience by either Belize or Dominica. Following the introduction in plenary two breakout Groups were formed to provide an opportunity for more in-depth discussion. To facilitate these discussions a series of tables were used to help to capture the key elements of what is to be done, by whom and when. Each of the groups was also requested to identify priorities for action. The results of the Breakout Group discussions were presented in Plenary as a means to share experience between the two countries. The tables and the executive summaries of the break-out group discussions may be found in Section 7 of this report. Session 5 and 6 – Information Exchange under the Rotterdam Convention – Integration with other regional or international activities on chemicals In plenary the Secretariat reviewed the broad range of information relevant to chemicals management available under the Convention and highlighted how it might be used to strengthen chemicals

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management at the national level, in particular decision making on potentially hazardous chemicals. A subsequent presentation on the linkages between the Rotterdam, Basel and Stockholm Conventions highlighted possible opportunities for an integrated approach to implementation with the Rotterdam Convention. A brief presentation on the key elements of SAICM was also provided. Following the presentations in plenary the breakout groups reconvened to revisit the tables completed in session 4 for a more in-depth discussion on how the information available under the Convention might be used to strengthen chemicals management decision making at the national level. The breakout groups also reviewed the tables to identify opportunities to integrate the work of the Rotterdam Convention with ongoing national or sub regional activities on the implementation of other relevant international agreements on chemicals, e.g. the Stockholm and Basel Conventions and SAICM. Session 7 and 8 Confirm next steps and priorities for action – review and adopt elements of a national action plan or strategy for the implementation of the Rotterdam Convention These sessions provided an opportunity for the break out groups to have a final review of the completed tables in order to confirm what is to be done, by whom and as far as possible when. The over all priorities for action were also discussed. In order to draw together the results of the discussions in the breakout groups and in Plenary, small drafting groups were tasked with preparing a summary/introduction to the work of the breakout groups as reflected in the completed tables. The summary/introduction puts results of the discussions in context, highlight the status of implementation of the Convention in each country, the key challenges, how they are to be addressed, key conclusions, priorities for action and next steps. The summary/introduction and the completed tables set out the elements of a national action plan or strategy on the implementation of the Rotterdam Convention. These reports were presented in plenary for final review and adoption. The reports for Belize and Dominica may be found in Annexes A and B respectively.

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4. AGENDA

Sub regional meeting on the implementation of the Rotterdam Convention – Identifying the elements ad a national action plan or strategy

12 – 16 November 2007

Monday, 12 November

Session 1: Opening and introduction 10.00 – 10.30 Opening

Ceremony Master of Ceremonies: Godswell Flores Welcome Remarks: Bill Murray, RC Secretariat

Address : Hon. Servulo Baeza, Government of Belize

Vote of Thanks: Gene Pollard, FAO

Introduction and structure of the meeting B. Murray 10.30 – 11.00 (includes coffee break)

Logistical arrangements M. Serrut

Session 2: Introduction à la Convention de Rotterdam

11.00-12.00 Plenary Overview of the Rotterdam Convention

• What it is and what it is not • Key elements and key players Status of the implementation

B. Murray

Questions and answers

12.00-13.30 Lunch

Session 3: Status of implementation of the Convention 13.30-14.30 Plenary National presentations : status of implementation of the

Rotterdam Convention at national level Belize Dominica

Questions and answers 14.30-15.00 Experience in the implementation of the Rotterdam

Convention and the legal case study: Jamaica

H. Chin Sue

15:00-15:30 coffee break

15.30 –16:00 Rotterdam Convention and relevant regional activities in pest and pesticides management in the Caribbean sub region

G. Pollard

16.00-16.30 Brief introduction to the work of the Breakout group (BG) and that of the drafting group

B. Murray

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Tuesday, 13 November

Session 4: Review of the key obligations under the Rotterdam Convention 09.00-9 :15 Plenary Presentation on the PIC procedure B. Murray

9 :15-10 :00 4a) Import responses/decisions

1. Import responses and the PIC procedure: role and obligations for both importing and exporting countries 2. A participant is invited to share experience in taking and reporting import decisions.

B. Murray Belize


Guidance to the BG work and introduction to the working tables B. Murray

10.00-12.30 (includes coffee break)

Groups will review the national legislative and administrative basis for import decisions. They will discuss on what remains to do and identify key players, timeline and priority for action.

BG

SHOW 12.30-14.00

Lunch

14.00-14.30 Plenary Report of BG: the completed tables, including the proposed priorities for action, will be presented in plenary

14:30 – 15:15 4b) Notifications of final regulatory actions to ban or severely restrict a chemical 1. Requirements of the Convention regarding the preparation and submission of notification of FRA 2. Review key elements of a notification of final regulatory action form and how it might be completed

H. Chin Sue


Guidance to the BG work and introduction to the working tables H. Chin Sue


BG The groups will review the national legislative and administrative basis for national decision making on chemicals, they will discuss what still needs to be done and identify key players, timelines and priority for action Te groups will also have an opportunity to work through a notification of final regulatory action form.

BG

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Wednesday, 14 November 09.00-09.30

Plenary

(Session 4 cont’d) Report of BG: the completed tables, including the proposed priorities for action, will be presented in plenary

BG

09.30-10.30 Plenary Session 4c) Severely Hazardous Pesticide Formulations (SHPFs) 1. General overview of the provisions regarding SHPFs 2. A participant will share his experience in collecting information on pesticide poisoning incidents as a basis for a proposal for SHPF

G. Pollard Belize


Guidance to the BG work and introduction to the working tables

10.30-12.30 (coffee break)

BG The groups will review existing mechanisms available at the national level to collect information on pesticide poisoning incidents and the means by which such information might be made available to the DNAs as a basis for a proposal

BG

12.30-14.00 Lunch 14.00-14.30 Plenary Report of BG: the completed tables, including the proposed

priorities for action, will be presented in plenary

BG

14.30-15.15 Plenary Session 4d) Export notification 1. A general overview of the provisions regarding export notifications 2. A participant will share his experience in issuing and/or acknowledging export notifications in the country, highlighting the processes followed

B. Murray Dominica


Guidance to the BG work and introduction to the working tables


BG BG will focus on the responsibility of an importing country to acknowledge receipt of export notifications as well as possible follow-up actions that might be taken upon receipt of an export notification.

BG

Thursday, 15 November

09.00-09.30

Plenary

(Session 4 cont’d) Report of BG: the completed tables, including the proposed priorities for action, will be presented in plenary

BG

Session 5: Information Exchange under the Rotterdam Convention

09.30-10.30 Plenary 1. Presentation on the information exchange provisions B. Murray

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under the Convention, the type of information available and how it might be used to strengthen chemicals management at the national level 2. A participant will share his experience in using the information available under the Convention in their national chemicals management activities.

Belize/Dominica


Introduction to the BG work 10.30-12.30 (includes coffee break)

GT Opportunity for a more in-depth discussion on how the information available under the Convention might be used at the national level To revisit the tables completed in session 4.

B. Murray BG (no plenary report)

12.30-14.00 Lunch Session 6 : Integration with other regional or international activities on chemicals 14.00-15.00 Plenary Linkages between the Rotterdam, Basel and Stockholm

Conventions and highlight possible opportunities for an integrated approach to implementation at the national level.

B. Murray

Key elements of SAICM B. Murray

A focal point for SAICM or of the Basel or Stockholm Convention may present other chemicals management activities and possible collaboration

• both have focal points for SAICM, and are Parties to Basel

• Dominica is a Party to SC – but no NIP or focal point identified.

TBD

Presentation on possible regional collaboration on framework for international conventions – e.g. Coordinating Group of Pesticides Control Boards in the Caribbean; CARICOM; IICA, UWI

G. Pollard

Discussion

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Session 7: Review work of Sessions 4 through 6 and confirm next steps and priorities for action 15.00-17.00 (includes coffee break)

Plenary Guidance to the BG/drafting group B. Murray

BG In the light of the discussion on MEAs and SAICM, BG will review the completed tables for each of the operational elements presented in Sessions 4 to 6, confirm the priorities identified under each area and draw up a “short list” of overall priorities.

BG

Friday, 16 November

Session 8 : Review and adopt elements of a national plan or strategy for the implementation of the Rotterdam Convention

09.00-12.30 Plenary/BG Review the introduction/summary prepared by drafting

groups including the priorities for action and accompanying tables prepared previously

BG

Discussion

Session 9: Closure

Plenary Outline the steps for finalization and distribution of the

proceedings of the meeting B. Murray

Provide feedback on the effectiveness of the consultation Participants

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5. MEETING PARTICIPANTS

DOMINICA ABEO TROTTER 19th Street Canefield, Roseau, Commonwealth of Dominica TEL.: 1-767-266-3741 FAX: EMAIL ADDRESS: [email protected]/[email protected] BARNABAS ABRAHAM Tete Morne, Grand Bay, Dominica TEL.: 1-767-448-2401 EXT. 3468 FAX: - EMAIL ADDRESS: [email protected]/[email protected] BERNADETTE COMMODORE P. O. Box 422 G.P.O. Roseau TEL: 1-767-448-2602 EXT. 3700/ MOBILE 1-767-276-7384 FAX: 1-767-448-7950 EMAIL ADDRESS:[email protected] JEFF JNO BAPTISTE Roseau Fisheries Complex Dame Mary Eugenia Charles Blvd., Roseau, Commonwealth of Dominica TEL: 1-767-448-4577 FAX: - EMAIL ADDRESS: [email protected] KENT COIPEL P. O. Box 1015 Roseau, Commonwealth of Dominica TEL: 1-767-448-1685 FAX: 1-767-449-9217 EMAIL ADDRESS: [email protected] RONNIE GUISTE 16 B Virgin Lane, Roseau, Dominica TEL: 1-767-285-0030 FAX: 1-767-448-5200 EMAIL ADDRESS: [email protected]

THEODORA ANTHONY Dexia, P.O. Box 173 Bay Front, Roseau, Dominica TEL: 1-767-448-2780/ Mobile: 1-767-277-4328 FAX: 1-767-448-6308 EMAIL ADDRESS: [email protected]

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BELIZE ANGEL COCOM Customs & Excise Department Said Musa Street, Benque Viejo Town, Cayo District TEL: 501-227-7092/93 /MOBILE 501-604-8002 FAX: 501-227-7091 EMAIL ADDRESS: [email protected] DR. ERASMO FRANKLIN James Brodie & Co. Ltd. P. O. Box 365, Belize City TEL: 501-610-1184 FAX: 501-227-5593 EMAIL ADDRESS: [email protected] GODSWELL FLORES Ministry of Health East Block Independence Plaza, Belmopan City, Cayo District TEL: 501-822-2325 FAX: 501-822-2942 EMAIL ADDRESS: [email protected]/[email protected] HERBERT MASSON/WILMOT SIMMONS Prosser Fertilizer & Agrotec Co. Ltd. P. O. Box 566, Belize City, Belize TEL: 501-223-5410 FAX: 501-222-5548 EMAIL ADDRESS: [email protected]/bertm,[email protected] ISABEL ENFINGER Belize Agricultural Health Authority Central Investigations Laboratory Belize City TEL: 501-669-3473 FAX: 501-224-5230 EMAIL ADDRESS: [email protected]/[email protected] ISMAEL FABRO Department of the Environment Ambergris Drive Belmopan City, Cayo District TEL: 501-822-2816/501-607-1947 FAX: 501-822-2868 EMAIL ADDRESS: [email protected]

JEAVON HULSE Department of the Environment 10/12 Ambergris Ave., Belmopan City, Cayo District TEL: 501-822-2816 FAX: 501-822-2868 EMAIL ADDRESS: [email protected] JOHN BODDEN Ministry of Health East Block Independence Plaza, Belmopan City, Cayo District TEL: 501-822-2325 FAX: 501-822-2055 EMAIL ADDRESS: jonbodden @btl.net JORGE FRANCO Department of the Environment 10/12 Ambergris Ave., Belmopan City, Cayo District TEL: 501-822-2816 FAX: 501-822-2867 EMAIL ADDRESS: [email protected] LUIS CHO Bureau of Standards TEL: 501-222-4030 FAX: 501-222-4074 EMAIL ADDRESS: [email protected] OSCAR ALONZO Department of the Environment 10/12 Ambergris Ave., Belmopan Cayo TEL: 501-822-2542/ Mobile: 501-602-7202 FAX: 501-822-2862 EMAIL ADDRESS: [email protected] UDENSI UDENSI-KALU Belize Agriculture and Health Authority (BAHA), Belize City TEL: 501-668-2345 FAX: - EMAIL ADDRESS: [email protected] MIRIAM SERRUT Pesticides Control Board Central Farm, Cayo District TEL: 501-824-2640 FAX: 501-824-3486 Mobile: 501-610-4149 EMAIL ADDRESS: [email protected]; [email protected]

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FACILITATORS BILL MURRAY Secretariat of Rotterdam Convention, Viale delle Terme di Caracalla, 00100 Rome, Italy TEL: 1-390-657-056-289 FAX: 1-390-657-053-224 EMAIL ADDRESS: [email protected]

HYACINTH CHIN-SUE WALTERS Pesticides Control Authority Kingston, Jamaica TEL: 1-876-967-1281 FAX: 1-876-967-1285 EMAIL ADDRESS: [email protected]

GENE POLLARD P. O. Box 631-C, Bridgetown, Barbados TEL: 1-246-426-4110 FAX:1-246-427-6075 EMAIL ADDRESS: [email protected]

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6. NATIONAL REPORTS a. BELIZE

NATIONAL REPORT

Sub-regional meeting on the implementation of the Rotterdam Convention

Identifying the elements of a national action plan or strategy

Belize, 12 – 16 November 2007

Status of Ratification Belize became a party to the Rotterdam Convention by accession on 20 April 2005. The Convention entered into force in Belize on 19 July 2005. Belize currently owes US$198 in unpaid pledges which corresponds to pledges for 2007. Designated National Authorities Industrial Chemicals Sanitation Engineer Public Health Bureau Ministry of Health Belize City Belize Pesticides Registrar Department of Agriculture Pesticides Control Board Central Farm Cayo Belize Industrial Chemicals and Pesticides Chief Environmental Officer Department of the Environment 10/12 Ambergris Ave. Belmopan City Belize

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Official Contact Points Deputy Prime Minister Ministry of Natural Resources Market Square Belmopan Belize Attn: Mr. John Briceño Minister of Foreign Affairs Ministry of Foreign Affairs Belmopan Belize Attn: Mr. Godfrey Smith Official contact points need to be updated to reflect recent changes; that is, Minister of Natural Resources (who is no longer the Deputy Prime Minister). Both Ministers are no longer in the above Ministries. Chemicals Management in Belize Overview of chemicals management infrastructure The regulation of pesticides in Belize is carried out by the Pesticides Control Board (PCB); a statutory regulatory body; mandated to carry out the provisions of the Pesticides Control Act (PCA). The Pesticides Control Act came into effect on 31 December 1988; there has been one amendment to the Act passed by the National Assembly in 2002. The PCA and the PCB fall under the responsibility of the Minister of Agriculture; the Minister of Agriculture appoints 14 Board members to serve a term of two years. Board members represent the Ministries of Agriculture, Health, Environment, the Belize Agricultural Health Authority, agricultural and pesticides industries and other departments and stakeholders. The Board meets quarterly, while its working Committees meet on a more regular basis. Board members serve on a voluntary basis, although a small honorarium is paid to members attending Board meetings. The Registration Committee of the Pesticides Control Board is charged with the review of technical data submitted for the registration of pesticides. The Committee meets monthly or as necessary and makes recommendations to the Pesticides Control Board pertaining to the registration and classification of pesticides. Members are bound by the Committee’s Code of Ethics pertaining to the protection of confidentiality of data submitted to support applications for registration. Only duly registered pesticides may be imported, distributed and used in the country. The Executive Committee meets monthly, or at least twice in any given quarter, and is responsible for providing administrative support to the Secretariat. A principal activity of the PCB is the training and certification of users of Restricted Use Pesticides. The Training Committee is responsible for the review and approval of training materials and training methodology, and also provides support to the training

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team by way of recommendations and monitoring/quality control of the training program. The Legislation Committee is responsible for providing guidance with respect to the review of current legislation, and drafting of new legislation as per Board directives. Draft legislation is submitted to the Board for approval prior to submission to the Ministry of Agriculture and the Office of the Solicitor General. Committee members are selected from among the Board members, or co-opted based on their area of expertise. The PCB’s Secretariat is headed by the Registrar, with four Technical Assistants in charge of four zones in the country (Northern, Central, South-Central and Southern) and one Accountant/Secretary. The Secretariat is basically responsible for carrying out the mandates of the Board, namely, the enforcement of the provisions of the Pesticides Control Act and secondary legislation. Current regulations or Statutory Instruments cover pesticide registration, importation, distribution and use of restricted-use pesticides. Regulations are phased in based on the Board’s capability to enforce them in line with available human and other resources. The Board currently operates on an annual budget of US$150,000, largely from the collection of pesticides import fees (2%), pesticide registration fees and annual licences. The training of pesticide users is highly subsidized by the Board, with trainees paying a token fee of $2.50 for certification. No administrative or regulatory mechanisms have been put in place specifically to fulfill national obligations under the Convention. While the Department of the Environment is responsible for the management of industrial chemicals, it still needs to become familiar and execute its share of obligations as the industrial pesticides DNA under the Rotterdam Convention. Role of the DNA in chemicals management activities The Ministries of Agriculture, Environment and Health are represented on the Pesticides Control Board, and as such take an active role in the pesticide management policies of the country, especially with respect to the work of the Registration Committee. Similarly, the Registrar and/or Chairman of the PCB also sit on various other inter-sectoral committees such as the Stockholm Convention Project’s National Task Force and Steering Committee (administrated under the Department of the Environment). The pesticides industry is also represented on the PCB by two pesticide importers who together account for 75% of pesticide imports. Status of implementation of the Rotterdam Convention Import responses Import responses for the 24 pesticides and 4 severely hazardous pesticides formulations listed in Annex III of the Convention were submitted by the pesticides DNA in 2005. Feedback was received from the Secretariat indicated that all responses were found valid in accordance with Article 10 of the Convention. Import decisions are made based on the classification of the pesticide – approved, prohibited, or restricted status or on the basis of never having been registered for use in the country. So far, import responses have been straightforward with little need to utilize the Decision Guidance Documents.

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While there is no formal procedure in place to ensure timely decision making and submission of import responses, the good coordination between the Registrar of Pesticides and the Registration Committee provides for timely consultation and submission. However, the meetings of the Committee are loaded with revision and consideration of registration applications, which leaves little time for other matters. Officials at point of entry (Quarantine and Customs officers) assist in the certification of all pesticide imports to ensure that only approved or registered pesticides enter the country. No responses have been transmitted with respect to the 11 industrial chemicals; Belize is currently listed among those countries who have failed to submit a response for the industrial chemicals. Notifications of final regulatory action In 1992, notifications of final regulatory action were submitted by Belize for all prohibited and restricted pesticides. These did not meet the information requirements, and are still pending resubmission. A list of prohibited pesticides was arrived at prior to the passing of the Pesticides Control Act in 1988, and still serves as the official listing of banned pesticides. Upon registration, pesticides are classified as either general-use pesticides or restricted pesticides. The decision-making process for classification of a restricted pesticide is mostly based on a hazard evaluation. Restricted-use pesticides require that their purchasers and users be certified pesticide applicators or be supervised by one. The challenge faced in the taking of regulatory action to ban or severely restrict a pesticide lies mostly in the limited technical and scientific expertise in the country, especially in the area of pesticide toxicology. The challenges of the DNA in submission of notifications are related to the lack of experience in submitting a proper notification, as well as having various responsibilities and few staff. Severely hazardous pesticide formulations A fledgling pesticide intoxication surveillance system established under the Plagsalud project (PAHO) still does not provide sufficient data in order to make decisions or recommendations with respect to health problems related to conditions of use. Moreover, most cases reported are of intentional causes of intoxication. A system needs to be established for the regular reporting of pesticide intoxication incidents to the Pesticides Control Board. Furthermore, the API surveillance system needs to be improved and strengthened for uniform application across the country. Export notifications It is understood that export notifications would be received by the pesticide DNA and action taken at that level. A process needs to be developed and implemented to ensure that this is done in a timely manner.

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Conclusion While it can be said that in general Belize has made positive steps with respect to the Rotterdam Convention, i.e., ratification and submission of import responses, work is still needed in the following priority areas:

1. Improvement of the linkages between the key players in the Convention to ensure greater participation and communication.

2. Improvement of the processes which are essential to the active participation of Belize as a party to the Convention, i.e., pesticide intoxication surveillance, pesticide classification.

3. Establishment of procedures needed by DNA offices to comply with their responsibilities under the Convention.

Elaboration of a national action plan or strategy which would include the above components among others is essential in order to successfully implement the Rotterdam Convention in Belize.

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b. DOMINICA NATIONAL REPORT

Sub-regional meeting on the implementation of the

Rotterdam Convention Identifying the elements of a national action plan or strategy

Belize, 12 – 16 November 2007

Introduction As a party to the Rotterdam Convention, the Commonwealth of Dominica has made a commitment to its citizens and the international community to establish the appropriate policies, protocols, legislations and regulations to protect human health and the environment through environmentally sound management practices as it relates to the use of pesticides, chemicals and hazardous waste.

How chemicals are managed in the country a) Overview of chemical management infrastructure in the country including both pesticides and industrial chemicals. The Commonwealth of Dominica has ratified the Rotterdam Convention in its ordinance on the Prior Informed Consent Procedures for certain chemicals in international trade. The key players in ensuring the implementation of the Convention in Dominica are the Designated National Authority-Pesticide Control Board (PCB) Ministry of Agriculture, Fisheries and Forestry, Ministry of Health and Environment, and Ministry of Trade Industry and Consumer Affairs)

1. Brief description of the key legal and administration arrangements that forms the basis for the chemicals management infrastructure and the Ministries responsible for the implementation:

Ministry of Agriculture, Fisheries and Forestry

• The Pesticide Control Board of the Commonwealth of Dominica is the major institution responsible for the management of pesticides and chemicals. This is so mandated by the Pesticide Act No 15 of 1974 of the Ministry of Agriculture provides for the control of importation, sale, storage, and use of pesticides. Imports of pesticides require a license from the Pesticide Control Board.

• Environmental Coordinating Unit (ECU), focal point for the Convention on Persistent Organic Pollutants.

The Ministry of Health and Environment

• The Environmental Health Department is also mandated under the Environmental Health Service Act No 8 of 1997 of the Ministry of Health to manage chemicals used for domestic purposes.

• The Solid Waste Management Cooperation has the responsibility under the Solid Waste Management Act No 1 of 2002 of the Ministry of Health to manage both Pesticides waste and Industrial waste.

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There are also other key agencies, including other government departments and non-governmental agencies that assist in the management and the implementation process of chemicals and pesticides. The Ministry of Trade, Industry and Consumer Affairs (Dominica Bureau of Standard) for example, is responsible for the development of standards on the labeling and packaging of pesticides. Customs and Excise Department, Environmental Health, Environmental Coordinating Unit (ECU), Plant Quarantine Unit of the Ministry of Agriculture and the Port Authority also play an important role in securing and monitoring chemicals at the ports of entry. 2. Brief description of the process for decision making on chemicals and pesticides in Dominica. The Designated National Authority (Pesticide Control Board) is responsible for the approval, admission of bans and restrictions on severe and hazardous chemicals and pesticides. There are existing national institutional structures, which comprise of both public and private sector stakeholders. For instance, a National Implementation Plan (4 May 2006) for Persistent Organic Pollutants, other pesticides and Hazardous materials and waste, outlines twenty two (22) policy statement for the management of pesticides and chemicals in Dominica. The Pesticide Control Board in collaboration with other Government Departments play an important role in the bans of import, manufacturing, sale, use, distribution or export for sale of the Thirty one (31) Chemicals (Pesticide and Industrial Chemicals) listed as annex III of the Rotterdam Convention. The Technical Committee of the Pesticide Control Board is the basis for decision-making on chemicals and pesticides (ban, approval and restrictions).These decisions are fundamentally based on scientific research which entails a Risk Assessment, information on the use, labeling, safety requirements as well as bans instituted by other countries. The secretary to the DNA holds the responsibility for recording decisions made as it relates to pesticides; however there is no structured mechanism in place to record all the information on chemicals and pesticides use in Dominica. The human and institutional resources required to optimize chemical and pesticide management are currently not in place. 3. Brief description of the process for the implementation and enforcement of these decisions on chemicals. The exportation, importation and manufacturing of chemicals and pesticides require a license (permit) and approval by the DNA-Pesticide Control Board. A registered file is then made available on the different pesticides in question. The ECU is the focal point for Persistent Organic Pollutants, other pesticides and Hazardous materials and waste, Customs, Port Authority and Plant Quarantine Unit also play an important role in the enforcement of the regulations at the Ports of Entry. There is also a Pesticide Inspector, who regularly monitors the type, sale, storage, packaging and use of these chemicals and pesticide to the general public. 4. Administration and regulatory mechanism in order to fulfill National Obligation under the convention

• Administrative Framework - Establishment of the DNA (Pesticide Control Board-Inspectors, Secretary, Technical Committee etc)

• Legislative Framework- harmonization of legislations and regulations (e.g. Pesticide Act) in compliance with the Rotterdam convention

• Notification of some of the chemicals listed in Annex III

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• Formation of various Technical Committees to strengthen inter-agency coordination mechanisms to address duplication and inconsistency in the current administrative framework for pesticide management.

• Formation a National Implementation Plan (4 May 2006) for Persistent Organic Pollutants, other pesticides and Hazardous materials and waste, outlines twenty two (22) policy statement for the management of pesticides and chemicals in Dominica

• In accordance with the objective of the convention, the Commonwealth of Dominica has instituted programs to facilitate exchange of scientific, technical, economical, and legal information concerning the scope of this convention, toxicological, ecotoxicological and safety information.

• Conduct training and ensures information exchange and dissemination on the safe use of chemicals and pesticides.

b) Role of the DNA in chemical management activities in Dominica

• The DNA provides the legal framework and administrative support for the use, export, import, manufacture, use and sale of pesticides and chemicals.

• Ensures that programs are in place for the safe use of chemicals. • Ensures that the general public is well informed on the safe use of chemicals and pesticides. • The establishment of registers and databases on information on pesticides and chemicals. • Training in the safe use of pesticides and chemicals, and also the promotion of safer chemicals

and pesticides as alternatives to the more toxic pesticides. • The development and coordination programmes for the management of pesticides and chemicals. • The inspection and monitoring of pesticide and chemicals in international trade. The human and institutional resources required to optimize chemicals and pesticide management are seriously limited. To compound this problem, at present there is no holistic institutional system, with adequate structures and mechanisms, in place for management of all the pesticides and chemicals. Currently there is little real and meaningful consultation between the various bodies involved in chemicals and pesticides management. Therefore, the effective establishment of a functional chemicals and pesticides management framework that will, amongst other national priorities, provide for the implementation of the Rotterdam Convention will require:

a) The establishment and strengthening of linkages and networking between private and public sector institutions involved in chemicals and pesticide management.

b) The strengthening of institutions and organizations that have key mandates and

responsibilities for chemical and pesticide management, notable the PCB, ECU and Environmental health.

c) The establishment of public awareness and education programmes. d) The engagement of stakeholders for meaningful collaboration and consultation on pesticides

and chemicals management

23

b) Status of implementation of the Rotterdam Convention The Commonwealth of Dominica has ratified the Rotterdam Convention in its ordinance on the prior informed consent procedures for certain chemicals. The majority of the legislative and administrative framework has been instituted; however there are principal problems or challenges identified as impeding the implementation and ratification of the Convention are as follows:

a) Inadequate legal or regulatory infrastructure on chemicals for implementing the provisions of the prior informed consent procedure;

b) Inadequate legal or regulatory infrastructure for the control of industrial chemicals;

c) Inadequate human and financial resources for implementing the interim prior informed consent

procedure;

d) Need for improved political support in Ministries responsible for implementing the interim prior informed consent procedure;

e) Need for improved coordination and communication within and between relevant Ministries and

designated national authorities in implementing the interim prior informed consent procedure;

f) Need to improve or establish cooperation and communication between relevant Ministries, designated national authorities and stakeholders in implementing the interim prior informed consent procedure;

g) Need for improved coordination at both the national and regional levels in implementing the

Rotterdam Convention and other relevant conventions;

h) Lack of capacity/capability to undertake hazard and risk assessments on the effects of chemicals, including effects of pesticides on human health and the environment;

i) Poor reporting or collection of information on pesticide poisonings and need for the

establishment of poison control centres;

j) Improved access to international literature, databases, risk/hazard evaluations and socio-economic assessments of chemicals.

24

LISTING OF ALL IMPORTING RESPONSES RECEIVED FROM DOMINICA AND CASES OF FAILURE ON ITS PART TO SUBMIT RESPONSE.

NAMES OF CHEMICALS CATEGORY OF CHEMICALS

PUBLISHED DATES OF

FINAL DECISION ON

IMPORT

FAILURE TO

SUBMIT RESPONSE

2,4,5 T and its salts and esters Pesticide 06/2006 Aldrin Pesticide 01/1996 – no

consent

Binapacryl Pesticide 06/2006 Captafol Pesticide 06/2006 Chlordane Pesticide and

Industrial chemical 01/1996 – no

consent

Chlordimeform Pesticide 01/1996 – no consent

Chlorobenzilate Pesticide 06/2006 DDT Pesticide 01/1996 – no

consent

Dieldrin Pesticide and Industrial chemical

01/1996 – no consent

Dinitro – ortho – cresol (DNOC) & its salts (such as ammonium salt, potassium salt & sodium salt)

Pesticide 06/2006

Dinoseb & Dinoseb salts Pesticide 01/1996 – no consent

EDB (1,2 – dibromoethane) Pesticide 01/1996 – no consent

Ethylene dichloride Pesticide 06/2006 Ethylene oxide Pesticide 06/2006 Fluoroacetamide Pesticide 01/1996 – no

consent

HCH (mixed isomers) Pesticide Heptachlor Pesticide and

Industrial chemical 01/1996 – no

consent

Hexachlorobenzene Pesticide and Industrial chemical

06/2006

Lindane (gamma – HCH) Pesticide 06/2006 Mercury compounds, including inorganics mercury compounds, alkyl mercury compounds and alkyoxyalkyl and aryl mercury compounds.

Pesticide Interim decision on import. 01/1996 –

consent under conditions

Monocrotophos Pesticide 06/2006 Parathion Pesticide and

Industrial chemical 06/2006

Pentachlorophenol & its salt & esters Pesticide 06/2006 Toxaphene (Camphenchlor) Pesticide and

Industrial chemical 06/2006

Adjustable powder formulations containing a combination of benomyl at or above 7%, carbofuran at or above 10% & thiram at or above 15%

06/2006

25

NAMES OF CHEMICALS CATEGORY

OF CHEMICALS PUBLISHED DATES OF

FINAL DECISION ON

IMPORT

FAILURE TO

SUBMIT RESPONSE

Methamidophos (soluble liquid formulations of the substance that exceed 600g active ingredient / l)

Pesticide 06/2006

Methyl- parathion ( emulsifiable concentrates (EC) at or above 19.5% active ingredient & dusts at or above 1.5%

Pesticide 06/2006

Phosphamidon (soluble liquid formulations of the substance the exceed 1000g active ingredient / l)

Pesticide 06/2006

Actinolite asbestos Industrial chemical 06/2006 Amosite, asbestos Industrial chemical 06/2006 Anthophyllite Industrial chemical 06/2006 Crocidolite Industrial chemical 06/2006 Polybrominated Biphenyls (PBBs ) Industrial chemical 06/2006 Polychlorinated Biphenyls (PCBs) Industrial chemical 06/2006 Polychlorinated Terphenyls (PCTs) Industrial chemical 06/2006 Tetraethyl lead Industrial chemical 06/2006 Tetra methyl lead Industrial chemical 06/2006 Tremolite Industrial chemical 06/2006 Tris (2,3 dibromopropyl) phosphate Industrial chemical 06/2006

26

7. ELEMENTS OF A NATIONAL ACTION PLAN FOR IMPLEMENTATION OF THE ROTTERDAM CONVENTION

a. BELIZE

ELEMENTS OF A NATIONAL ACTION PLAN FOR IMPLEMENTATION OF THE ROTTERDAM CONVENTION

Introduction Belize ratified the Rotterdam Convention in April 2005. Presently, the Designated National Authorities (DNAs) of the Rotterdam Convention are the Registrar of the Pesticides Control Board (PCB), the Chief Environmental Officer of the Department of the Environment (DOE) and the Director of Health Services of the Ministry of Health. The Registrar of the PCB is charged with the responsibility for the various pesticides under the convention while the Chief Environmental Officer and the Director of Health Services are responsible for the Industrial Chemicals. In response to an official request to the Secretariat of the Rotterdam Convention by the Registrar of the Pesticides Control Board, a national workshop was proposed for the relevant national stakeholders with regards to the Convention. The purpose of this national workshop was to facilitate a national dialogue among the relevant stakeholders on the implementation of the Rotterdam Convention as the basis for identifying the key elements in a national action plan or strategy for the implementation of the Convention. As result of a similar request by Dominica, a sub-regional meeting was held in Belize from the 12th to the 16th of November, 2007. The National stakeholders that participated in the Workshop included representatives from the Pesticides Control Board, Department of the Environment, Ministry of Health, Belize Agricultural Health Authority (BAHA), Customs Department, Bureau of Standards, and representatives of the Belize pesticide industry. With the meeting being structured around a series of plenary presentations and breakout group discussions, the national stakeholders discussed key aspects of the Convention and national obligations under the convention including Import Responses, Notification of Final Regulatory Actions, Proposals for Severely Hazardous Pesticide Formulations (SHPF), and Export Notifications. This report summarizes the discussions and recommendations for future action as detailed in the attached tables. Table 1: Import Responses The objective of the first breakout group session was to ensure that participants understand the scope and purpose of an import decision in the context of the PIC procedure, and the importance of a clearly defined process for taking national import decisions and submitting them to the secretariat. In working to achieve the objective the group did an exercise that gave an overview of the current legal infrastructure/administrative procedure that are in place to facilitate import responses. In addition, the working group identified the actions that have been effected, what activities/tasks need to be done, by what time the identified actions will be completed and by whom. In review the legal infrastructure/administrative procedures, it was noted that Belize already has legislations, some more relevant to ensure compliance with the Convention than others. For instance, the Pesticides Control Act already makes provision for a schedule of prohibited pesticides and this

27

schedule already includes all the Pesticides listed in Annex III of the Convention. Whilst the Environmental Protection Act does not have a clearly defined Schedule to address the Annex III Industrial Chemicals, it does allow for a licensing process for scheduled substances. Notwithstanding, the DOE, within twelve (12) months anticipates the development of a negative list of chemicals and have such included in its regulatory framework. Furthermore, to address the issue of imports, the Government of Belize also has the Pesticides Registration System to which all new active ingredients and pesticides formulation must be subject prior to importation. For industrial chemicals, there is need for the establishment of an industrial chemical review and approval procedure, an activity to be spearheaded by the DOE. The Customs and Excise Department also has regulations that control the imports of pesticides and chemicals and are currently using the Globally Harmonized System Codes. The Government of Belize has made import responses for all Annex III Pesticides. These import responses have been submitted to the Secretariat, which has acknowledged receipt; import responses have been published in the PIC Circular. However, still pending are the import responses for the eleven (11) Industrial Chemicals. The Government of Belize has phased out the use of Polychlorinated biphenyls (PCBs), which was predominantly used as a coolant in transformers. The National POPs inventory indicates that there is less than 1% of all transformers in country contain PCBs. Considering that other alternatives are already being widely used, importation of this substance is not expected to occur. Also, Belize has banned the import of fuels that contain lead; i.e. only unleaded fuels are allowed for importation and sale within its territory. Considering that both PCBs and lead-containing compounds are no longer in any significant demand, Belize looks forward to making an import response of “No Consent” for these two Annex III industrial chemicals within the next three (3) months. To ensure that the import responses are completed in a manner that would not negatively impact possible users of any of these chemicals, the first action to be undertaken is research of these industrial chemicals, for which the primary source of information will be the Decision Guidance Documents. The Department of the Environment shall also cross check with the Customs Department regarding any importation of industrial chemical with emphasis on those included in Annex III. In addition, the Department of the Environment will verify whether the HS Codes assigned for the Annex III Industrial Chemicals are included in the Customs Tariff and if not, work along with the Customs Department to include these specific codes. This research will facilitate in identifying any potential users in the country. Once users have been identified, the next activity would be to consult with them and inform them of the commitment that the Government has under the Convention and of its intention to submit import responses of “No Consent.” The entire process is expected to take approximately nine (9) months, by which time Belize should be in a position to make the necessary import responses and have regulatory infrastructure in place. In respect to the import response submitted for DDT, i.e, Interim response – No consent, the Pesticides Control Board intends to change its decision form interim to final. However, in order to make such a response, the Ministry of Health must be consulted with; an activity that is anticipated to be completed within one month. The Pesticides Control Board shall also review monocrotophos in view of submitting an import response of “No Consent” within the next 8 months. It was noted that much positive experience in the control of chemical imports has been garnered by way of the activities between the Department of the Environment’s Ozone Unit and the Customs Department aimed at addressing the country’s obligations with respect to ozone depleting substances under the Montreal Protocol.

28

Table 2: Notification of Final Regulatory Action The Pesticides Control Board will revisit its Schedule of Prohibited Pesticides and prioritize ten (10) of these that are not included in Annex III, for submission of notifications of Final Regulatory Action. The Pesticides Control Board will review and submit subsequent sets of ten (10) prohibited pesticides until the Schedule of Prohibited Pesticides has been fully covered. To address the issue of Industrial Chemicals under this thematic area, the Department of the Environment shall work towards development of enabling legislation to allow for the classification (Prohibited, Severely Restricted, etc.) of industrial chemicals. Once the list has been established, and the review mechanism for industrial chemicals has been instituted, the next step will be to submit Notifications of Final Regulatory Action for those chemicals not within Annex III of the Convention. Table 3: Proposals for Severely Hazardous Pesticide Formulations In reference to Belize’s compliance with the proposal for SHPFs, there are two mechanisms identified that can facilitate reporting of pesticide poisoning. One of the most important instruments for the collection of pesticide poisoning incidents is the Pesticide Intoxication Reporting form, which is used by health facilities. This is also supported by a national data base system at the Ministry of Health through the Belize Health Information Unit System (BHIUS), which contains a module for pesticide poisoning data recording. In addition, over the years, various stakeholders have conducted a number of studies to determine levels of pesticide residues in food and the environment. This information is yet to be reviewed by the relevant regulatory authorities and utilized in the decision making process. While Belize’s position in regard to SHPFs could be classified as progressive with respect to effects on human health, there is still work to be done in the area of capturing their possible adverse effects on the environment. Table 4: Export Notifications

To date Belize has received very few export notifications for either pesticides or industrial chemicals. The DNA’s are firmly in place for the reception and acknowledgement of notifications should any be received. However, the procedure for acknowledgement of notifications needs to be formalized.

There is a concern that Belize may not be receiving export notifications because we currently

engage in trade with some countries that are not signatories to the Rotterdam Convention. In light of this, it may be advisable for the Secretariat to find a way to encourage non-signatories to become parties to the Convention.

Another recommendation for future action is for the DNAs (PCB, DOE, MOH) to take a

proactive approach and conduct research into the status of Annex III chemicals and pesticides in the countries that export to Belize, in order to determine if they are acting in compliance with their obligations as exporting countries under the Rotterdam Convention.

We expect to formalize the acknowledgement procedure and have all research completed in time

for the upcoming COP 4.

29

Conclusion This exercise has successfully assisted in identifying the key elements to be addressed in a national action plan for the implementation of the Rotterdam Convention. Much progress has been made, however we recognize many more advances are still needed. Achieving this will require technical support from relevant parties such as the RC Secretariat and the FAO. Specific requests for support will be made in due course.

30

TABLE 1 : IMPORT RESPONSES

Current legal infrastructure/ administrative procedure

What has been done?

What needs to be been done?

Who is responsible/involved and how to proceed?

Timelines

• Consultation with Ministry of Health with respect to updating DDT import decision from interim to final (no consent)

PCB/MOH • PCB/MoH DDT consultation – 30 December 2007

Pesticides • Pesticides

Control Act and secondary legislation

• Pesticide Registration System

• Import responses have been submitted and acknowledged for 28 pesticides.

• Review monocrotophos and consider a No Consent import decision.

PCB • Monocrotophos review – June 2008

• Consultation with potential affected stakeholders and development of negative list for industrial chemicals (Pollution Regulations) (DOE)

Department of the Environment and Industry

• Development of negative list - November 2008

Industrial Chemicals • List of

substances in Schedule to EPA

• Licensing process for scheduled substances

• No import responses have been submitted for industrial chemicals.

• PCBs have been phased out

• Leaded gasoline has been phased out

• National inventory of POPs

• Further research on use of Annex III chemicals. (DOE)


Research of Annex III industrial chemicals using DGDs – March 2008

31

• Preparation and submission of import responses for PCB and Lead in the short term (DOE)


• Preparation and submission of import responses for PCB and lead – March 2008

• Submission of import responses for 9 other industrial chemicals (DOE)


• Preparation and submission of other 9 industrial chemicals 1 month each

• Amendment of pollution regulations to address classification of industrial chemicals


• Amendment of regulations – June 2008

• Establish an industrial chemical review and approval procedure


• June 2008

32

• Cross check with Customs regarding importation of Annex III industrial chemicals (DOE/Customs)

DOE and Customs and Excise Department

• Consultation with Customs 30 November 2007

Auxiliary Infrastructure • Customs

Regulations

• Adoption of HS codes specifically for Annex III chemicals by Customs

DOE, PCB/Customs

• 30 November 2007

33

TABLE 2: NOTIFICATION OF FINAL REGULATORY ACTION


What has been done?

What needs to be done? Who is responsible/involved and how to proceed?

Timelines

• Prioritize set of 10 pesticides for notification (from Schedule of Prohibited pesticides, excluding those already in Annex III)

• PCB • December 2007

• Submit first set of 10 notifications in line with Convention requirements.

• PCB • May 2008

• Subsequent sets of notifications sent until all prohibited and severely restricted pesticides have been notified.

• PCB • December 2008 and June 2009

• Provide Customs with list of prohibited pesticides with their respective HS Codes


Pesticides • Pesticides Control Act and subsidiary legislation for pesticide registration. • Registration process for pesticides.

• Schedule of prohibited pesticides. • Restricted-use pesticide classification. • Some experience gained by way of notifications sent in 1992 but which did not comply with submission requirements.

• Review of pesticide regulations to include a severely restricted pesticide classification


34


What has been done?

What needs to be done? Who is responsible/involved and how to proceed?

Timelines

• Develop enabling legislation to allow for classification (Prohibited, Severely Restricted, etc.) of industrial chemicals.

• DOE

• Develop draft legislation by May 2008.

• Once list of prohibited industrial chemicals is developed, provide to Customs with respective HS Codes.

• DOE

• May 2008

Industrial Chemicals • Section 17 of EPA makes provision for regulation of certain hazardous substances. Import permits for these chemicals may be granted at the discretion of the Minister.

• Existing schedule of hazardous substances • Procedure in place for issuing permits for importation of industrial chemicals.

• Establish regulatory mechanism for industrial chemicals (which would include process for evaluation and approval)

• DOE • Develop mechanism by May, 2008

35

TABLE 3: PROPOSALS FOR SEVERELY HAZARDOUS PESTICIDE FORMULATIONS

Available infrastructure for pesticides poisoning report

What has been done?

What could be done in the future?


Timelines

• Develop a reporting system for environmental incidents.

• DOE • June 2008

• Revise API reporting form to be in line with information required by RC

• MoH • December 2008

• Pesticide Intoxication Reporting Form (hospital level, some of the larger farms)

• API Reporting Form developed and procedure for reporting of APIs • Module for logging of data for API in the Belize Health Information Unit System (BHIUS)

• Training of MoH statistical unit on the use of the API model of the BHIUS

• MoH

• June 2008

• Strengthen reporting of intoxication cases among small farmers through the use of CNAs and other support persons through training.

• MoH, PCB • June 2008 • MoH Epidemiological Surveillance Unit

• Information collected from hospitals, farms, community nursing aides(CNAs), private clinics • Establishment of Belize baseline cholinesterase levels for population (organophosphates and carbamates)

• Enactment of draft worker protection legislation.

• PCB • February 2008

36

• Seek assistance for development of protocols for monitoring of blood cholinesterase levels and other intoxication-related medical tests.

• MoH/PCB • June 2008 • Draft legislation has been developed for worker health protection. • Training of health personnel in API surveillance and recognition and management of API.

• Continue training of health personnel in API surveillance and recognition and management of API.

• PCB, MoH • April 2008

• Review of existing studies to determine which pesticides may be causing detrimental environmental effects for possible further regulatory action.

• PCB, DOE • April 2008

Research opportunities • Limited studies conducted for pesticides levels in air, water, sediments, fish, breast milk, fruits and vegetables • Monitoring of aquaculture farms for water quality (organophosphates, carbamates) – Belize Agricultural Health Authority (BAHA)

• Develop procedure for wider distribution of BAHA laboratory results

• BAHA • January 2008 (start)

Department of Environment

• Well developed environmental monitoring, compliance and enforcement structure within the DOE.

• Develop an initial system for recording environmental incidents and sharing of information with relevant parties.


37

• Finalize system for recording environmental incidents.


38

TABLE 4: EXPORT NOTIFICATIONS

Current practice What has been done?

What needs to be done?


Timeline

• Formalize the procedure at DNA’s offices to ensure timely acknowledgement of notifications

• PCB, DOE (DNAs)

• March 2008

Belize does not export pesticides therefore does not issue export notifications. Minimal notifications are received and acknowledged (U.S.A. only). Some countries exporting to Belize are not parties to the Convention therefore not obligated to notify Belize. Not known whether exporting parties (relevant to Belize imports) are exporting (to Belize) any pesticide(s) banned or severely restricted in their countries and not issuing export notifications. Also not known whether notifications are being sent but through the wrong channels, therefore not reaching the DNAs.

• Convention DNAs already in place. • Acknowledgements sent for the few notifications received.

• Research status of pesticides and industrial chemicals in countries exporting to Belize to determine whether or not exporting countries have been in compliance with obligations under the RC.

• PCB, DOE • COP 4

39

b. DOMINICA

ELEMENTS OF A NATIONAL ACTION PLAN FOR IMPLEMENTATION OF THE ROTTERDAM CONVENTION

INTRODUCTION Dominica has been a Party to the Rotterdam Convention since 30th December 2005. The country has made a commitment to its citizens and the international community to establish the appropriate policies, protocols, legislation and regulations to protect human health and the environment through environmentally sound management practices as it relates to the use of pesticides and other hazardous chemicals. The Rotterdam Convention convened a Sub-regional Consultation in Belize City, Belize, November 12-16th 2007. The objective of the consultation was to facilitate a national dialogue among relevant stakeholders on the implementation of the Rotterdam Convention as the basis for identifying the key elements in the National Action Plan or a strategy for the implementation of the Convention. The Sub- Regional Consultation in Belize comprised of a delegation of seven (7) technical officers from Dominica representing the following ministries: (i) Ministry of Agriculture, Forestry and Fisheries; (ii) Ministry of Foreign Affairs, Trade, Industry and Diaspora Affairs; (iii) Ministry of Finance and Planning; (iv) Ministry of Housing, Land, Telecommunication, Energy, and Port; and (v) Ministry of Health and Environment In Dominica, the Pesticide Control Board has been established as the Designated National Authority (DNA) for pesticides and industrial chemicals. The Chairman of the Board recently moved to another office and it is expected that the new contact person will be regularised by December 2007 and the Secretariat of Rotterdam notified. The attendance at this consultation is committed to work towards strengthening the implementation alongside the DNA towards improved chemical management at the national level. Table 1 refers to import responses for chemicals listed in Annex III The Tables provide further details on the import response, notifications of final regulatory actions, proposals for severely hazardous pesticide formulation and export notifications with timelines for the necessary actions to be taken to comply with the obligations of the Convention. The DNA has submitted eleven (11) import responses for pesticides listed in Annex III, however, the import responses of seventeen (17) other pesticides remain outstanding. Given that Dominica has an approved list, the DNA will submit the remaining 17 responses by January 2008 on the basis of the pesticides listing of the approved list. For those that are approved, the country will provide a import consent decision and for those on the prohibited list, a no consent to import. The Customs Department will be advised to utilise the Harmonised Systems Codes (HS) designated to chemicals on Annex III of the Rotterdam Convention. To date, no import responses have been submitted for 11 industrial chemicals listed on Annex III. Ninety-Eight percent (98%) of the PCBs has been phased out and leaded fuel has been completely phased out. The import responses will be submitted for nine (9) chemicals by December, 2008. Legislation for industrial chemicals should be passed by December 2010.

40

Table 2 outlines the requirements to enable notifications of final regulatory Actions for banned or severely restricted chemicals The notification for final regulatory action pertaining to pesticides is governed by three (3) Acts namely the Pesticide Control Act, Noxious and Dangerous Substance Act and the Environmental Health Services Act. With regards to submission of notification of final regulatory action, no submission was made, despite the existence of a Schedule of prohibitive pesticides under the Pesticide Control Act which includes two pesticides, Cyhexatin and Aldicarb, which are not on the list in Annex III. A draft National Implementation Plan for the management of hazardous chemicals was submitted to Government for consideration for passing and enactment by January 2010. There are other pieces of legislations to control the importation, sale, handling and disposal of industrial chemicals. Other ways to improve the management of industrial chemicals include the preparation of an approved list of industrial chemicals and formally requesting assistance from Conference of the Parties (COPs) of the three conventions to manage industrial chemicals. Table 3 outlines the purpose of the proposal for SHPF In Dominica there is an existing infrastructure for reporting pesticide poisoning. Cases are reported at the District Health Clinics/Hospital thereafter, the more severe cases are reported to the Epidemiology Department at the Hospital to be investigated by the Primary Health Care System. There are several initiatives in place to reduce and manage pesticide exposure / poisoning e.g. Farmer Field School, Fair Trade and TESCO. Other initiatives in progress include the plans to declare Dominica an Organic Island, conducting a National Survey on Chemicals and a Chemical Tracking System developed for retailers. Extension Officers of the Ministry of Agriculture are identified as the Pesticides Control Board to monitor records on farmers’ use and handling of pesticides and distribution by retailers whereas the Ministry of Health will coordinate reporting, managing and treating incidences of pesticide poisoning. The full implementation of this programme is envisaged by the end of June 2008. Table 4 outlines the requirements for export notifications Currently, the DNA has received export notifications for two (2) chemicals and has responded but no follow up action has been taken at the national level. In light of the change in DNA, the Pesticides Control Board will designate another person to specifically deal with acknowledgment and responses and ensure that users of these chemicals are contacted and investigation done on possible alternative where necessary by the end of 2007. Dominica, in fulfilling its obligations under the Rotterdam Convention, has given priority to address in the short term the following actions:

• Prepare import responses for the outstanding 17 pesticides and 11 industrial chemicals that form part of Annex III

• Notification of final regulatory action for all pesticides on the prohibited list will be prepared on a phased basis. Notification of final regulatory action for two (2) pesticides- Cyhexatin and Aldicarb will be given priority since they are not already on the list in Annex III.

• Ensure that the new DNA is functional

41

• Collaborate with DNAs from the region and other regional partners while asking Secretariat to assist to strengthen implementation

• Training of Customs Officers on the Rotterdam, Basel and Stockholm Conventions to improve control of ports

• Facilitate national consultation with stake holders to make decisions, disseminate information and discuss legislation

• Establish management programme for industrial chemicals. Dominica has proposed in the medium-long term to undertake the following actions:

• To establish the required legislative frame work and coordinate existing legislation to fulfil the obligations of Rotterdam

• To strengthen linkages between the DNAs, Customs and national focal points from Basel and Stockholm regarding the control of imports of pesticides and industrial chemicals

• To strengthen data collection on incidence of exposure to pesticides and develop reporting for exposure to industrial chemicals

• To identify the industrial chemicals in use in Dominica and the countries that supply them.

While Dominica has proposed its plan of action it will need the continued support of the Rotterdam Secretariat to provide assistance in the following areas:

• To provide training of the new DNA on fulfilling obligations of the Rotterdam Convention • To assist with training of medical personnel in data collection and treatment of persons exposed • To provide expertise towards assisting in risk evaluation/assessment on pesticides and chemical • To provide support to strengthen the life cycle management of pesticides and establish a basic

programme for managing industrial chemicals • Legal consultancy for stakeholder consultation to ensure that the draft legislation meets the

obligations of the Rotterdam Convention as well as Stockholm and Basel Conventions • Strengthen the incidence reporting system for pesticides and broaden the programme to include

reporting incidence on industrial chemicals exposure • Strengthen Customs to improve border control for industrial chemicals and pesticides

42

TABLE 1 : IMPORT RESPONSES Current legal infrastructure/ administrative procedure • Pesticide Control Act No.

15 of 1974 (Licensing and Registration process for products listed on Schedule)

What has been done? • Import responses

made for 11 pesticides

• HS code used by

Customs

• List of approved and prohibited pesticides exist

• National Inventory of

Persistent Organic Pollutants (POPs) drafted

What needs to be done? • Prepare and submit

import responses for the outstanding 17 pesticides;

• Import decisions

published in local newspapers to communicate decisions to stakeholders.

• Establish new contact

person and notify secretariat of new DNA

Who is responsible /involved and how to proceed?

• PCB/ DNA need to submit import response for the 17 pesticides. Pesticides on the approved list consent will be given; whereas pesticides on the prohibited list or not yet registered will be no consent

Timelines

• Import response for the 17 pesticides submitted by January, 2008

• Inform

Secretariat of new DNA (contact person) by December, 2007

INDUSTRIAL CHEMICALS

• Noxious and Dangerous Substance Act of 1982

• Draft legislation has

been proposed and pending finalization – Pesticides and Toxic Chemicals

• 98% of PCBs phased out

• Leaded fuel

(gasoline) has been completely phased out.

• Prepare and submit import responses for the 11 chemical

• Establish list of

prohibited industrial chemicals

• Need a process for

the evaluation of industrial chemicals and establish a procedure to ensure

• Consult with Customs and Users of the 11 industrial chemicals

• PCB/ DNA

needs to make decisions and submit Import response on the 11 chemicals

• Import response for the 9 chemical submitted by December, 2008

• Import

Response for PCBs and Lead submitted by

43

timely submission of import responses in the future

• Examine draft

legislation to ensure it meets the obligations of Rotterdam, Basel and Stockholm Conventions

• Establish

procedures to communicate import decisions to those concerned within your country e.g use of local newspaper

• Follow-up on draft

legislation with Secretariat and Cabinet

• DNA to request assistance from Secretariat to review legislation and assist to put management system to support implementation of legislation

• DNA

March, 2008

• Consultation to establish legislation and management framework for industrial chemicals (April, 2008)

• Legislation

passed by January, 2010

44

TABLE 2: NOTIFICATION OF FINAL REGULATORY ACTION

INDUSTRIAL CHEMICALS

• Draft legislation has been proposed and pending finalization

• Pesticide Control

Board makes decisions on importation of chemicals

• Government

policies taken on phasing out leaded fuel and the 12 POPs under the Stockholm Convention

• Draft National

Implementation Plan for Management of POPs and other hazardous chemicals presented for Government consideration

• Pass and Enact

Legislations • Prepare a

prohibited/ restricted list of industrial chemicals

• Need a process for

the evaluation and prohibition of industrial chemicals

• Expand incident

reporting and monitoring of pesticide use to include industrial chemicals

• Prepare a approved

list of industrial chemicals

In the interim, the PCB/DNA would initiate consultations on drafted legislation and present its proposal through the Ministry of Agriculture in order that Cabinet can instruct Legal Affairs

DNA to establish prohibited list for inclusion in legislation August 2008 Ministry of Agriculture, Ministry of Industry and retailers to consider reporting of industrial chemicals use and exposure in order to prohibit chemicals of high risk for exposure

• Pass and Enact Legislations

January, 2010 ●

• December 2008

45

TABLE 3: PROPOSALS FOR SEVERELY HAZARDOUS PESTICIDE FORMULATIONS Available infrastructure for pesticides poisoning report • Programs in place to

reduce and manage pesticide exposure: Farmer Field School (IPM) approach, EUREPGAP, Fair Trade Banana Production, TESCO

• National Policy to declare

country as Organic Island • Cases are reported at the

District Health Center, If cases are severe referrals are made at The Epidemiological Department located at the Princess Margaret Hospital. Further investigation is conducted by the Primary Health Care Systems (Environmental Health Department, Public Health Nurses.

What has been done? • Annual medical test for

Banana Farmers subsidized by Dominica Banana Producers Limited (DBPL).

• National Surveys and

Inventories developed on Chemical Use.

• Pesticide Tracking

System developed for Retailers.

What could be done in the future? Improve pesticides record keeping and tracking system to monitor distribution, sales and use. • Review Ministry of

Health reporting system to verify if data is available

• Improve system of documenting cases of incidents of pesticide poisoning among farmers and the format for submitting reports to DNA.

• Modify reports to incorporate the incidence reporting form developed by the Rotterdam Convention

• Provide training for

medical practitioners, nurses, student nurses, users and suppliers on symptoms associated

Who is responsible/involved and how to proceed? • DNA and

Extension Officers to monitor farm records , review and modify reporting forms

• Ministry of Health

and the Environment, Medical Association and Ministry of Agriculture

• DNA could request

assistance from the Convention for trainers for medical

Timelines

• Ongoing

• End of

February, 2008, Ongoing

• End of

February, 2008, Ongoing

• June 2008

46

with pesticide poisoning and treatment.

• Formalize arrangement

for reporting incidence of (pesticide use, poisoning incidents) through MOU between Ministry of Health and Ministry of Agriculture and to include NGOs, DNA, Medical Authority and Agricultural Division.

• Make use of the

Rotterdam Convention incident report form for Health and Environment

personnel and data collection in the field

• Chief Medical

Officer and Medical Association to identify doctors for training

• Ministry of Health

and the Environment(Health Promotion Unit), Ministry of Agriculture (Extension Officers)

• DNA/Epidemiology

Section

• End of May 2008

47

TABLE 4: EXPORT NOTIFICATIONS Current practice

• PCB/ DNA receive and acknowledge receipt of notification

• No export of

pesticide or industrial chemical from Dominica

• PCB/ DNA serves as notification point for both pesticides and chemicals

What has been done?

• DNA has received at least two (2) export notifications in the past and has acknowledged receipt of them however, no follow up to contact local users

What needs to be done? • PCB to designate

person to deal specifically with acknowledgement

• Follow up of users of

the product and dialogue with DNA/ exporter at the point of origin of the product for additional information on product as needed

• Use HS code to help

identify users through Customs

• Better use of

information available from export notifications to inform national decisions on future imports and prepare negative list

• Proper management of information pertaining to notifications and circulation of

Who is responsible/involved and how to proceed? • DNA DNA PCB/Customs DNA DNA

Timeline End of 2007 Ongoing Ongoing Ongoing

48

information among relevant authorities

• Networking of DNAs in the region to identify chemicals used in the region that are subject to notification

• Prepare a list of countries supplying pesticides and industrial chemicals

DNA, Ministry of Agriculture, Ministry of Foreign Affairs, Trade, Industry and Diaspora Affairs.

January 2009

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