SAFERUSEACTIONPLAN(SUAP)
Phosphine Gas Fumigation Management Plan (FMP)
Prepared by:
Md. Abdur Rashid
Advisor - Environment
Advisor - Environment
SHOUHARDO III, CARE Bangladesh
Revised date: 04/25/2017
SAFERUSEACTIONPLAN(SUAP)
Phosphine Gas Fumigation Plan (FMP)
1. BackgroundDescription of SHOUHARDOIII Program
The program has the provision of managing by direct delivery roughly 13190 metric tons of wheat,vegetable oil and Yellow Split Peas over the period of FY 2016 – FY 2019, planned to be stored and distributed respectively 4320 MT in FY 16, 3300 MT in FY 17, 3920 MT in FY 18 and 1650 MT in FY 19 as the assistance to address key behavioral and systematic constraintsrelated to food availability, access and utilization underlying socio political issues that bear upon theabilities of individuals and communities as well to exercise rights and make decisions impacting their livesand livelihood.
CARE Bangladesh in managing the program food commodity selected8 warehouses which will be used for regular dispatches, stacking, handling and delivery of food/nonfood commodities as per the field distribution plan and requirements. As per logistic plan, the food commodities will be unloaded through Chittagong port and Transport to each region for storing in district and Upazila level warehouses prior to the distribution at beneficiaries level. Local private transport agency has been assigned for transportation of commodity to the all Warehouses and Food Distribution Points (FDP). Again, storing at the district and Upazila level, fumigation, transportation and delivery including internal delivery up to the FDP will be doing by aforesaid regional offices of CARE Bangladesh with local level commodity management staff and community based organizations or groups.
2. USAID/Bangladesh PERSUAPFumigation PERSUAP from SHOUHARDO II (approved August 3, 2011):The SHOUHARDO III program has requested and received USAID approval to follow the Fumigation PERSUAP approved for the predecessor project. Below summarizes the program-specific requirements for safer use, including the template for the Fumigation Management Plan (FMP) that will be completed with each fumigation event.
Fumigation PERSUAP from SHOUHARDO II:
The PERSUAP basically consists of two parts, a Pesticide Evaluation Report (PER) and a Safer Use Action Plan (SUAP). The Pesticide Evaluation Report (PER) section addresses 12 informational elements, which is require for using pesticides on food storage and stock piling of emergency relief materials of CARE Bangladesh. This PER is the investigative half of the PERSUAP and it has furnished all the information needed to make appropriate decisions about pesticide management within the USAID program in question. The Safer Use Action Plan (SUAP) put the conclusions reached in the PER into a plan of action, including assignment /determination of responsibilities to appropriate parties to be concerned with the fumigation management program of all commodity storage warehouses.
3. Safer Use Action Plan (SUAP): Mandatory Conditions of Compliance Requirement:
This Safer Use Action Plan (SUAP) is the definitive statement of Implementing Partner (IP) pesticide compliance requirements and is synthesized from the Pesticides Evaluation Report (PER) analysis mandatorily applicable to SHOUHARDO III. USAID Bangladesh PERSUAP indicates, allowed pesticides (in section 6.2), summarizes the mandatory safer use conditions attendant to use/support of these pesticides (in section 6.3) and describes these conditions in the attached Mandatory Template, entitled the “Pesticide Safer Use Action Plan & Compliance Tracker,” (in section 6.4) for assigning responsibilities and timelines for implementation of these requirements and for tracking compliance.
Each project subject to USAID / Bangladesh PERSUAP must submit a completed SUAP template to its AOR/COR and MEO 30 days before the implementation of the activity and must provide an annual update of the SUAP. With respect to pesticides, the SUAP satisfies the requirement for an environmental mitigation and monitoring plan (EMMP). The project EMMP should simply incorporate the SUAP by reference.
3.1. Fumigation Compliance Guidance for USAID PartnersUSAID Fumigation PEA:With the approval of the “Commodity Protection in USAID Food Assistance Programs by PhosphineFumigation” Programmatic Environmental Assessment (“Fumigation PEA”), USAID for the first time willhave uniform, mandatory environmental, health and safety requirements regarding phosphine Fumigation of food commodities.
USAID Fumigation PEA:
The Fumigation PERSUAP from SHOUHARDO II complied with the USAID Fumigation PEA, and SHOUHARDO III will use this same Fumigation PERSUAP to meet Regulation 216.3(b), USAID’S Pesticide Procedures. In addition, the information provided herein and the Fumigation Management Plan (FMP) template provided below will be used by SHOUHARDO II.
Additional guidance may also be sought by SHOUHARDO II directly from the USAID Fumigation PEA as necessary. This Annex guides USAID implementing partners in complying with these requirements. Partners that follow the instructions in this annex use the templates provided in other “T” Annexes, and follow through on implementation and reporting as specified herein will satisfy the requirements established by the PEA. [CARE Prepared this SUAP – FMP, carefully following the T – Annexes of Commodity Protection by Phosphine Fumigation in USAID Food Aid Programs, Programmatic Environmental Assessment Tools Annex, updated December 2015 USAID/ Bangladesh PERSUAP, includes the relevant issues of Safer Uses Action Plan (SUAP) of SHOUHARDOII as was approved by USAID]
3.2. FMPRequirements forUSAIDPartners.As described in Annex T-1, Ffumigationcompliance requiresUSAIDpartnerstocompleteaFumigation Management Plan(FMP) foreach fumigationeventand to keep these FMPsonfile for2 years. SHOUHARDOIII recognized such compliance and will prepare well ahead of each fumigation in all of the warehouses of the program. FMP compliancefurtherrequiresthattheplan andthefumigation eventitselfsubstantively confirmwiththe FMPtemplatethatfollows.
3.3. Comply Key “safer fumigation” requirements per PEA: Fumigation Services RFQs andcontracts require conformity withacceptable fumigation practices per annex T-6 of the USAID Fumigation PEA, including:• Required use of full faced canisterrespirators or self-containedbreathing apparatus (SCBA), • Required hazard & efficacymonitoring, • Required maintenance of an exclusion zone for duration offumigation event (7-10 days)each fumigation event must have a fumigation management plan (FMP)conforming to these practices. USAID partners shall enforce theserequirements and take correctiveactions as required.• Report on compliance with these requirements.• Have formal authorization under USAID’s environmentalprocedures to contract for (generally, “support”) suchfumigation. These includes other necessary and relevant elements for safer fumigation work described in this document will carefully be followed and comply in the fumigation process of the SHOUHARDOIII program.
4. USEPA Registered and Approved Pesticides planned to be used on Warehouse Storage Commodities in SHOUHARDO III.
4.1. Legal and Policy Issues: The SHOUHARDO III Program has the concern of ensuring the uses of pesticides in case of storingfood, wheat, vegetable oil and yellow peas (likely food and perishable and or non-perishable items) andalso ensuring no or minimum effect of pesticides uses as well. In such case, because of risk concernspresented by pesticides, the USAID environmental regulations require that at least the 12 factorsoutlined in the pesticide procedures described in 22 CFR 216.3 (B) (1) (I) be addressed in the program that includes assistance for the procurement or use of pesticides. The Fumigation PERSUAP for SHOUHARDO II met this 12 factors requirement and is being adapted for use again with SHOUHARDO III. The pesticides listed herein are in compliance with the USAID approved Fumigation PERSUAP for SHOUHARDO II.
4.2.Analysis of Available Relevant Pesticides: In SHOUHARDO III Program, it is necessary to store commodities/food for direct distribution to targetbeneficiaries' includes food for work activities and for stockpiling of emergency relief materials forfuture disaster response. Commodities like wheat, yellow split peas and vegetable oil need to store in suitable / standard conditions during unloading of commodities from ships/vessel until the time of its distribution to beneficiaries' level. It is often necessary to store these commodities for up to twelve or few months in regional warehouses.
To protect thesecommodities from the action of pests, it is necessary to use some of the recommended pesticideslike Actellic, Agriphos, Dursban, Quick-Fume, Sanphos and Ustad are registered in the host country Bangladesh as well as in US EPA.[Status of these pesticides usually uses for storage of commodities are shown in Table 1and 2 respectively].SHOUHARDO III,warehousepestcontrolactivitiesfor protectionofstored agriculturalcommoditieswill be performedbytrainedandcertifiedpestcontrolexperts.Productsof those are approvedinBangladeshforcontrolofpestsinwarehousesanditssurroundingswill beusedbyapproved fumigators.
Actellic (generic name Pirimphos-methyl) is a USEPA (United States Environmental Protection Agency) - registered pesticide that is classified for “general use”. It is an organophosphate with a USEPA Toxicity Class of III (Caution). It controls a wide range of pests affecting grains and other stored products. It is a rapid acting chemical with a 7-day toxicity cycle and is effective in warm and humid climates. Actellic acts through fumigation and ingestion and has a low mammalian toxicity. Actellic is highly recommended for use on stored grains and is approved for this purpose in the Supplementary Environmental Assessment completed for USAID. It is registered by the Department of Agricultural Extension (DAE), Ministry of Agriculture, for use on stored grains and is the least toxic of other available products. Previous experience by users has confirmed that it is the most effective product for this purpose.
Agriphos, Quick-Fume and Sanphos (generic name Aluminum Phosphide) are USEPA-registered pesticide that is classified for “restricted use”. It is an inorganic Phosphide with a USEPA Toxicity Class of I (Most Toxic, Danger-Poison) and used as tablets, pellets and partially spent dust. It releases hydrogen Phosphide / Phosphine gas if it is exposed to moisture from the air or it comes into contact with water. It controls a wide range of pests affecting grains and other stored products. It is a rapid acting chemical with a 48-72 hrs.Toxicity cycle and is effective in warm and humid climates. This group of product acts through fumigation and ingestion and has high mammalian and nesting bird toxicity. Aluminum Phosphide is highly recommended for use on indoor agricultural food commodities,animal feeds, processed food commodities and non-food commodities (tobacco) as well as foroutdoor fumigation for burrowing rodent and mole control. It is registered by the Department of Agricultural Extension (DAE), Ministry ofAgriculture, Bangladesh, for use on stored grains and is the least toxicamong other available products.
Dursban (generic name Chloropyriphos) is a USEPA-registered pesticide that is classified for “restricted use”. It is an organophosphate with a USEPA Toxicity Class of II (Moderate Toxic-Warning). It is used as liquid form and effective for the control of a wide range of insect pests of commercial importance. It controls a wide range of pests and crawling insects affecting grains and other stored products. It is a rapid acting chemical with a dependence on the soil type; microbial metabolism of Chloropyriphos may have a half-life of up to 279 days and is effective in warm and humid climates. Dursban is used through high or low volume spraying and ingestion and has a low mammalian, birds and other organisms’ toxicity. Dursbanis highly recommended for use on wide range of insect pests of commercial importance such as crops, soil, livestock and pest control operation in and around buildings. It can be used to successfully control crawling insects. It is also termed as public health pesticide. It is registered by the Department of Agricultural Extension (DAE), Ministry of Agriculture for the said use.
Ustad (generic name Cypermethrin) is a USEPA-registered pesticide that is classified for “restricted use”. It is an organophosphate with a USEPA Toxicity Class of II (Moderate Toxic-Warning). It is used as liquid form and effective for the control of a wide range of insect pests of commercial importance. It controls a wide range of pests and crawling insects affecting grains and other stored products. It is a rapid acting chemical with no detectable decomposition at normal ambient temperatures and for at least 3 months at 50 degrees Celsius to date and is effective in warm and humid climates. Ustad is used through high or low volume spraying and ingestion and has a low mammalian, birds and other organisms’ toxicity. Cypermethrin, a parathyroid, is extremely toxic to fish. It is highly toxic to bees exposed to direct treatment on blooming crops or weeds. Ustad is used as liquid form and effective for the control of a wide range of insect pests of commercial importance. It controls a wide range of pests and crawling insects affecting grains andother stored products. It is a rapid acting chemical with no detectable decomposition at normal ambient temperatures and for at least 3 months at 500 C and is effective in warm and humidclimates. However, these productsare registered by the Department of Agricultural Extension (DAE).
Table 1: Status of Recommended Pesticides Used in Bangladesh
Sl.# / Trade Name / Chemical Name / Origin / Action / Toxicity ClassEPA / EPA Reg. Status
1 / Actellic / Pirimphos Methyl / UK / Store Grain Insecticide / III
Slightly Toxic
(Caution) / Yes
GUP
2 / Agriphos / Aluminum Phosphide / CHINA / Store Grain Insecticide / I
Most Toxic
(Danger-Poison) / Yes
RUP
3 / Dursban / Chloropyriphos / USA / Public Health Pesticide / II
Moderate Toxic
(Warning) / Yes
RUP
4 / Quick-Fume / Aluminum Phosphide / INDIA / Store Grain Insecticide / I
Most Toxic
(Danger-Poison) / Yes
RUP
5 / Sanphos / Aluminum Phosphide / INDIA / Store Grain Insecticide / I
Most Toxic
(Danger-Poison) / Yes
RUP
6 / Ustad / Cypermethrin / INDIA / Wide Spectrum Insecticide / II
Moderate Toxic
(Warning) / Yes
RUP
GUP: General use pesticide; RUP: Restricted use pesticide; a: Oral toxicity (I = Most Toxic, II = Moderate Toxic, III = Slightly Toxic)
Table 2: Status of Recommended Pesticides Used in Bangladesh
Sl# / Trade Name / Reg. Status in Host Country / Reg.No / Recommended
Pest / Recommended
Dose
1 / Actellic / Yes / PHP-10 / Wheat &Rice Weevil / 10mL/1000kg or 2g/m2
2 / Agriphos / Yes / AP-174 / Commodity insecticide, Rodenticides / 6 tablets/1000 kg
3 / Dursban / Yes / PHP-05
PHP-85
AP-93 / Termite
Mosquitoes, Larvae / 0.125L/a i/ha or 62.5mL/ha
4 / QuickFume / Yes / AP-254 / Commodity Insecticide,
Red Grain Beetle / 6 tablets/1000 kg
5 / Sanphos / Yes / AP-663 / Commodity Insecticide,
Red Grain Beetle / 6 tablets/1000 kg
6 / Ustad / Yes / PHP-82 / Wide Spectrum Insecticide / 2mL with 24 cc water/100m3 area
4.3.Extent to which the proposed pesticide is the part of integrated pest management (IPM):
The use of Aluminum Phosphide in a series of CARE Bangladesh controlled storage trials /demonstrations designed to evaluate effectiveness and the cost/benefit of its appropriate usage forits commodity warehouse. The use of “Actellic” by other users to control disease carries and nuisance pests including mosquitoes, ant, wasps, flies, cockroaches, fleas and other crawling insects.As it is most toxic class of compound, it cannot be used as a part of Integrated Pest Management (IPM).However, the program will undertake IPM practices during the commodity storage period as appropriate referred in next clauses of this document. The use of Dursban in CARE Bangladesh for commodity warehouse maintenance. It has a strongaction on wide range of insect pests of commercial importance such as crops, soil, livestock and pestcontrol operations in and around buildings. It can be used to successfully control crawling insectstermed as public health pesticide.The use of Ustad in CARE Bangladesh for commodity warehouse maintenance. It has a strongaction on wide range of insect pests and miticide. It can also be used to successfully controlcrawling insectstermed as public health pesticide. Due to long half-life and intense effect it may not be used as a part of IPM.
4.4 Proposed methods of application, including availability of appropriate application and safetyequipment:The precautionary recommendations included on the packaging of this products will be strictly followed, including the i) use of a mask over mouth and nose, ii) wearing protective clothing, iii)immediate removal of clothing used during application iv) hand / rubber gloves and boots and v) burning of used containers v) prior toapplication and as per recommendations on the pesticide container, the product may be stored in itsoriginal container in CARE Bangladesh warehouses (if convenient), which will not be used again for the storage of fooditems vi) Warehouses will be locked and well ventilated vii) Any person entering the warehouseswill be informed of its existence and be aware of the toxicity of the product.
4.5. Provisions made for training of users and applicators: Proposed pesticide will be applied by registered and experienced fumigation company staffs and technicians under the close supervision of CARE Bangladesh warehouse managers/ environmental compliance specialist and other concerns who have previous experienceof working in the correct handling, use and management of warehouse fumigation work. The whole commodity warehouseinspection and commodity storage program will be under the control of experienced persons, who have worked with proposed pesticides. Provisions will be made for detail training of users and applicators for occupational health and safety measures. Under SHOUHARDO III program, commodity warehouse management staff and fumigation workers will be provided with orientation and refreshers in each year during the program period.
4.6. Provisions made for monitoring the use and effectiveness of the pesticide: During application, preparations to apply proposed pesticides to the commodities will follow the instructions on the label, in the proper sequence. No one will handle the product without the proper protective mask, clothing and soap and water will be available for immediate cleaning of hands and eyes. Partially used containers will be securely sealed during the application process and returned to storage.After completing the application, the empty containers will be punctured and burnt (as per the “The Pesticides Ordinance, 1971 Bangladesh”). The clothing and other equipment used during the application will be thoroughly cleaned (the clothes will be ashes separately from other clothes).
As the application will take place within a controlled area using sacks and drums, there should not be drifting problems (movement of pesticide dust away from the commodities to be treated).Application will take place in the early morning (prior to 10:00 AM), avoiding the hottest part of theday. No food or drink will be consumed within the warehouse during application. Should anyoneshow signs of pesticide poisoning, the application will be stopped and first aid will be immediately sought. First aid kits are to be stored on site and individuals will be trained in basic first aidprocedures. The treated commodities will be used after complete aeration of the warehouses. There will be subsequent applications during the storage period as prescribed by the manufacturer of pesticides. The storage trials may be set up following prescribed protocols and closely monitored bySHOUHARDO III staff of the organization. Experts will collect and analyze the data and present the findings in CARE Bangladesh annual / other reports.