FACM Training: Fumigation 3 Sessions: IEE to FMP What’s in YOUR toolkit? Integrated Pest Management Phosphine Fumigation

Overview of Pesticide Compliance IEE to FMP Overview of Pesticide Compliance

environmental impact assessment process IEE to FMP: Reg 216 22 CFR Part 216 Defines USAID’s pre-implementation environmental impact assessment process What? Why? To protect environment & human health Process evaluates proposed projects for environmental impact. The output of this process is Reg. 216 documentation, including the Initial Environmental Examinations (IEEs). Most IEEs establish mandatory environmental “conditions” [mitigation actions] that must be fulfilled during project implementation to protect the environment and human health and welfare. IEE is submitted as part of the proposal package, approved by USAID, and revisited as planning begins IEE (Initial Environmental Examination) Output? http://www.usaidgems.org/reg216.htm

Environmental Mitigation and Monitoring Plan (EMMP) IEE to FMP: Reg 216 Environmental Mitigation and Monitoring Plan (EMMP) What? Translates IEE into specific mitigation measures Why? Needed to ensure implementation of IEE Mitigation is the implementation of measures designed to eliminate, reduce or offset the undesirable effects of a proposed action on the environment. Most USAID Initial Environmental Examinations (IEEs) and all Environmental Assessments (EAs) establish conditions (mitigation requirements) that must be complied with during activity design and implementation. Monitoring is the essential complement of mitigation. It is BOTH (1) determining whether mitigation is being implemented as required; and (2) determining whether mitigation is sufficient and effective. Experience shows that systematic implementation of mitigation measures – and thus compliance with IEE and EA requirements – requires an Environmental Mitigation and Monitoring Plan (EMMP). For this reason, EMMPs are required by most newer IEEs and EAs across most USAID bureaus. EMMPs provide a basis for systematic implementation of IEE. (IEE may be general but EMMP is specific.) Implementing partners must report on environmental compliance as one portion of routine project performance reporting. EMMPs provide a framework for this reporting. For USAID activities failure to implement IEE conditions puts the activity in a non-compliance category [ends the activity] EMMPs are also called Environmental Management Plans (EMPs), Mitigation and Monitoring Plans (M&M Plans), and by other, similar names. Indicators/criteria for monitoring implementation Timing and responsible parties Framework for reporting Output? http://www.usaidgems.org/mitMonRep.htm

IEE to FMP: Reg 216 22 CFR 216.3(b) What? Additional analysis & review - if using pesticides How? PERSUAP Pesticide Evaluation Report and Safer Use Action Plan Formal amendment to project IEE Authorizes use of specific pesticides 22 CFR 216.3 (b) establishes specific, additional pre-implementation analysis and review requirements that apply to procurement and/or use of pesticides in USAID-funded activities. Most Bureaus satisfy these requirements with a “Pesticide Evaluation Report and Safer Use Action Plan” (PERSUAP) which is formally an amendment to the project’s IEE. Must be in place before 1st fumigation When? Before 1st fumigation http://www.usaidgems.org/Documents/complianceTopics/ST_Pesticides_Safer_UseCompliance_Cairo_10Oct2012.pdf

& IEE to FMP: Reg 216, PERSUAP Safer Pesticide Evaluation Report Use Action Plan & Analysis of hazards Mitigation actions

IEE to FMP: Reg 216, PERSUAP Pesticide Evaluation Report Analysis of hazards Addresses the 12 informational elements in your agencies pesticides procedures. Provides opportunities to consider practical actions to reduce risks of using pesticide products. When to use pesticides; What pesticides to use; How to use them safely Risk to human health Risk to environment

IEE to FMP: PEA PEA Programmatic Environmental Assessment Mandatory safety requirement for phosphine fumigation Fumigation with the pesticide phosphine gas is a critical tool to assure protection of stored food commodities. It is also an intrinsically dangerous process: phosphine is deadly, flammable and corrosive. Failure to conduct fumigation properly poses serious risks to human health and of ineffective fumigation, posing both an immediate problem for commodity losses and contributing to phosphine pesticide resistance. In recognition of these risks and to develop clear guidance and tools, the USAID Office of Food for Peace (FFP) conducted a study in order to design a safer and more effective approach to phosphine fumigation. Looked at potential risks (to human health and the environment) of fumigation with aluminum and magnesium phosphide. Found that yes, phosphine poses risks to fumigators, others in the warehouse, and to nearby residents. Concluded that phosphine fumigation can be done if certain mandatory safety requirements are met. A fumigation management plan is required for each fumigation event. Fumigators must use respiratory protection, monitor the gas levels (for both safety & efficacy) Report on compliance http://www.usaidgems.org/documents/fumigation pea/fumigationpeafeb24_2014.pdf

IEE to FMP: PEA Mandatory Requirement for PH3 fumigation Fumigators must wear masks and monitor gas levels Fumigation Management Plan for each event Implement IPM http://www.usaidgems.org/documents/fumigation pea/fumigationpeafeb24_2014.pdf

IEE to FMP: Reg 216, PEA TOOLS Safer Use Action Plan Mitigation actions USAID also developed tools and guidance for safer fumigation procedures. This Safer Use is based on including IPM measures . You have a copy of PEA Tools Annex TOC in binder; and will get a soft copy of the entire document on USB stick at end of training. Puts PER into actions Annual update satisfies EMMP

IEE to FMP: PEA TOOLS Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP) Solicitation and Contract Language Fumigation Management Plan (FMP) Fumigation Service Quotation Request Model Contract Partners select better-qualified service providers Remember, a PERSUAP is needed if treated or pesticide exposed commodity is used for consumption.

Pesticide Evaluation Report & Safer Use Action Plan IEE to FMP: Reg 216, PERSUAP SUMMARY Pesticide Evaluation Report & Safer Use Action Plan Formal amendment to the project’s IEE Authorizes phosphine fumigation Authorizes use of specific residual pesticides Establishes IPM practices Monitoring of the PERSUAP should be done through the EMMP. Serves as compliance tracking & reporting tool

IEE to FMP: FMP WHY? Assures fumigant is applied safely & effectively WHAT? Summarizes steps taken before, during and after fumigation

IEE to FMP: FMP Small Group Activity: Form 6 groups Read your section of the FMP template Determine if you will have any difficulties completing the section In plenary: Briefly explain your section Tells us about any difficulties you expect Purpose: Familiarize participants with FMP

IEE to FMP: FMP Small Group / Section to Review: : A - E F - J K - N O - Q R - U V - W

PEA to FMP: Warehouse Staff Safety Guide Chapter 1: Introduction And Purpose Chapter 2: Safe Practices, Compliance And Enforcement Chapter 3: Fumigation Planning And Safety Chapter 4: Fire Prevention And Emergency Action Plan Chapter 5: First Aid And Medical Emergency Planning Chapter 6: Facilitators Training Tool Appendices Warehouse safety Posters Chapter 3: Fumigation Planning And Safety Fumigants Signs of Illness Preparation for Fumigation (FMP, Official Notice of Fumigation, Marking Poster, Emergency Contact Info sheet.) Recommendations to avoid Injury during Fumigation Safe Disposal of Fumigation Containers www.fsnnetwork.org/warehouse-staff-safety-guide

Key Tools Included in Appendices Warehouse Safety Inspection Checklist Warehouse Tools & Equipment Checklist First-Aid Kit Inspection Log USAID Fumigation Management Plan (FMP) Fumigation Marking Poster & Notice of Fumigation Accident Investigation Report Form Emergency Contact Information Form Safety Posters

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