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

2. Overview of Pesticide Compliance
IEE to FMP
Overview of Pesticide Compliance

3. 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?

4. 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?

5. 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 (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

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

7. 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

8. 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
pea/fumigationpeafeb24_2014.pdf

9. 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
pea/fumigationpeafeb24_2014.pdf

10. 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

11. 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.

12. 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

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

14. 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

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

16. 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

17. 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

18. TOP TEN