Initial Environmental Examination

INITIAL ENVIRONMENTAL EXAMINATION

2017USAID/Central Asia/Tajikistan
Programmatic Pesticide Evaluation Report and Safer Use Action Plan

(PERSUAP)

PROGRAM/ACTIVITY DATA

Activity Location:/Country CodeTajikistan/Central Asia

Activity Name:All USAID/CA/Tajikistan programs

Activity Number:Multiple

Life-of-Activity Funding:Est. 50 Million

Period Covered:Current date to expiration date as below

IEE Prepared by:MarkDoyle,Agricultural Development Officer, USAID/Central Asia

PERSUAP Prepared by:Alan Schroeder, PhD, MBA; Rahmatjohn Rozikov, BSc Azam Salimov, BSc and Davron Isaev, MSc

Funding Period:FY 2017-FY 2021

IEE Amendment (Y/N): YES – amends all current USAID/CA and USAID/CA/Tajikistan
IEEs covering Tajikistan activities with potential pesticide use

SUMMARY OF ENVIRONMENTAL THRESHOLD DECISION (Place X where applicable)

Categorical Exclusion / [ ] / Deferral / [ ]
Positive Determination / [ ] / Negative Determination / [ ]
Negative Determination with Conditions / [X] / Exemption / [ ]

SUMMARY

ThisInitial Environmental Examination (IEE) for USAID/CA/Tajikistan Programmatic Pesticide Evaluation Report Safer Use Action Plan (PERSUAP)addresses the requirements of 22 CFR 216.3(b) (“Pesticide Procedures”) regarding the assistance in procurement or use or both, of pesticides on all USAID/CA/Tajikistan programs. It amends all current USAID/CA and USAID/CA/Tajikistan IEEs covering activities that may involve the use of pesticides in Tajikistan. These include:Health IEE amendment #1 (DCN: Asia 14-101) Democracy and GovernanceIEE amendment #7 (DCN: Asia 14-68), Economic Growth IEE amendment #2 (DCN:Asia 14-125); Feed the Future IEE (DCN: Asia 15-010); Local Governance Program IEE(DCN: Asia 12-35), GDA Multi Input Area Developmental Financing Facility IEE (DCN: Asia 14-140), and Competitive Trade and Jobs DCA IEE (Asia 16-099).

Recommended Action: The activities under review are recommended for assistance in the procurement or use, or both, for same or similar uses by USEPA without restrictionof pesticides across the USAID/CA/Tajikistan portfolio, subject to compliance with the Safer Use Action Plan that comprises Section 4 of the document.

1.0BACKGROUND AND ACTIVITY DESCRIPTION

1.1 The Purpose of PERSUAP:

This PERSUAP (1) establishes the set of pesticides for which procurement, use or support for use is authorized across all USAID/CA/Tajikistan programs; and (2) establishes the conditions under which the authorized pesticides may be procured, used, or their use supported to best ensure user, consumer and environmental safety. It also supersedes and replaces the 2011 Tajikistan Umbrella PERSUAP and 2013 PERSUAP update that was prepared for USAID funded projects in Tajikistan.

1.2.PERSUAP brief description

Activities covered by the PERSUAP: In 2011, USAID declared Tajikistan a “Feed the Future” (FTF) country. FTF is a global hunger and food security initiative designed to address chronic struggles with food shortages. In addition to food security activities, several on-going economic gowth, democracy, and health activities in Tajikistan currently involve or may involve assistance for the procurement or use, or both of pesticides. Specifically, it is expected that PERSUAP will cover and will be applicable to the following programs in progress (but not limited to): Farmer-to-Farmer (9/2013 - 9/2018), FTF Tajikistan Health and Nutrition (9/2015 - 9/2020); Tajikistan FTF Land Market Development Activity (11/2016-9/2020); Maternal and Child Health (9/2008 - 3/2017); Micronutrient Supplementation (3/2013 - 3/2017); Tajikistan Nutrition-Sensitive Vegetable Technologies Project (TNSVT, 10/2014- 12/2017); Potato Production Support and Research to Improve Food Security in Khatlon (7/2013 – 6/2019); USAID TB Control Program, (9/2014 - 8/2019); HIV FLAGSHIP (12/2015 – 12/2020); Local Governance Project (10/2012 - 9/2017); Competitiveness, Trade and Jobs (10/2016- 9/2021); and Economic and Social Connections: A Multi-Input Area Development Financing Facility for Tajikistan (10/2014-9/2019).

Types of Sectors/Services considered in PERSUAP include: Pesticide use in Agriculture (seed, field and greenhouse, and locust control, food processing and post harvest pest control for more than 30 crops); Food Security (food treatment and warehouse fumigation); Veterinary (livestock and feed additives); Water and Sanitation; Avian Influenza; and Health and Malaria (microbial disinfection); Construction (termite and ant control); and Rights of Way Treatment (weed control).

Tajikistan and US EPA Registered Pesticides:The 2017 document addresses only chemicals currently (since 2004) registered for import and use in Tajikistan, and excludes any pesticides from the region that are not legally approved by the Government of Tajikistan (GOT) for import and use. The document updates the EPA registration status of all the registered pesticides that were reviewed in the 2011 document, and, in theAnnex11, identifies and proactively analyzes pesticides that have been proposed (in 2012) by GOT for registration, in case they become approved during the life of this document. To the 2011 and 2013 documents, this 2017 PERSUAP adds the sectors of locust control with insecticides and rights of way (roads, runways, power lines, irrigation canals, and so on) treatments with herbicides.Unrestricted, Tajikistan-Registered and EPA-approved list of registered for the same or similar uses by USEPA without restriction)pesticides is available in PERSUAP Executive Summary and Section 4 (Table 4.1). Pesticides that are not EPA registered, have restricted use, are known carcinogens, or are classified as extremely toxic (Class I) are not included in the list. All pesticides, which are not on the approved list, shall not be procured or used on FTF or other USAID/Tajikistan programs, projects or activities. Tajikistan does not consider microbial disinfectants/microbiocides and pheromone formulations to be pesticides, and therefore don’t legally register them in the same way it registers pesticides. The US EPA, on the other hand, does consider disinfectants/microbiocides and pheromones contained in solid matrix containers to be pesticides, thus, this 2017 PERSUAP evaluates these for compliance with EPA regulations (

PERSUAP Recommendations (conditions):

In summary, Implementing Partners (IP) conditions require that:

• Only pesticides with approved active ingredients can be procured, used or recommended for use with USAID funds.
• Pesticide products procured, used or recommended for use must be labelled in a national language (Tajik or Russian) and include specified essential information.
• Basic training in safer use must be provided broadly to those using, selling, financing or providing extension services involving pesticides with USAID funding. Training must be reported to the AOR/COR.
• Pesticides for plant protection must be part of an IPM scheme governed by crop- and pest-specific IPM-based pest management plans.
• Projects must assure use per label, including the correct use of appropriate PPE (per label) for all pesticide use under their direct control. Otherwise, projects must assure access to, proper use and maintenance of appropriate PPE and use per label to the greatest degree practicable.
• In addition to any other procurement requirements, projects seeking approval to purchase pesticides must certify that such procurement is compliant with this PERSUAP and provide other specified information for AOR/COR review and clearance via a provided forms(Annex 18)
• Record-keeping, reporting on compliance with the above conditions as part of regular project implementation reporting,and pass-down of all above requirements to subcontractors, grantees and sub-grantees is required.

In summary, conditions for USAID/CA/Tajikistan require that:

• USAID/CA/Tajikistan put in place effective internal procedures to review pesticide use plans and pesticide procurement requests submitted by IPs. The MEO must review and approve all procurement requests.
• Per ADS 204.3.4, AORs/CORs must assure that the requirements established by section (IP Conditions, summarized above)are funded, implemented, and monitored.
• Technical Offices, working with OAA, must ensure that contract and award language requires compliance with the conditions established by this PERSUAP for each relevant project.
• USAID/CA/Tajikistan must assure that all relevant mission staff receive an internal short-format (~1–2 hour) training on the requirements established by this PERSUAP.
• At such time that pesticides are registered under the 2003 Tajikistan’s National Pesticide and AgrochemicalsLaw, USAID/CA/Tajikistan must update this PERSUAP.
• Annual review of the approved pesticides list in this 2017PERSUAP: The lists of pesticides approved by Tajikistan and analysed for approval by US EPA was dated January, 2016. To ensure that this PERSUAP stays current & compliant with US EPA registration status, the list of chemicals should be reviewed annually, in January. Thus the next review will be due in January of 2017.
• Substantial update every 3-5 years of the PERSUAP. In order to distill lessons learned and ensure that all requirements are up-to-date, this document should be substantially updated at least every 3-5 years. Thus, the next major update should occur not later than January 2020, by which time Tajikistan may produce a new list of registered pesticides, and EPA registrations will have changed significantly.
• Regular training for USAID/CAR and USAID/CA/Tajikistan, IPs, GOT officials.Do regular annual training on use of this PERSUAP for all stakeholders so that they understand how to interpret and use it. The next training will be due in March of 2017.

NOTE: Table 4.1, IP and USAID Conditions are reproduced in full in the Executive Summary.

Approval of Recommended Environmental Actions:

Clearances:

Regional Mission Director,

USAID/CA:______Date: ______

Jatinder Cheema

Regional Environmental Advisor

for Central and South Asia & OAPA:Concurred by e-mailDate: 12/2/2016

Andrei Barannik

USAID/CA Tajikistan Country

Office Director:Cleared by e-mailDate: 1/4/2017

Kate Crawford

USAID/CA Tajikistan TAWA

COR: Cleared by e-mailDate: 1/4/2017

Mark Doyle

USAID/CA Mission

Environmental Officer: ______Date: ______

Nina Kavetskaya

Approval:

Asia Bureau Environmental Officer: ______Date: ______

William Gibson

CCed:

USAID/CA EDO, HEO and DGO Project File

MEO/CAR Tracking System (P:\PSPUB\ENVIRONMENTAL COMPLIANCE\Initial Environmental Examinations)

OAA

Bureau for Food Security

2016Tajikistan Programmatic PERSUAP

(Pesticide Evaluation Report and Safe Use Action Plan)

Covering Sectors of Pesticide use in/on:

Agriculture (Seed, Field and Greenhouse)

Food Security (Food Treatment and Warehouse Fumigation)

Veterinary/Feed Additives

Water and Sanitation

Avian Influenza/Disinfectants

Health/Malaria

Locust Control

Construction

Rights of Way Treatments

Using Resources of Chemonics International TAWA Project

January to June 2016

Alan Schroeder, PhD, MBA

Social and Agricultural Entrepreneur

Environmental Assessment Professional

Business cell phone: 703-859-1676

Skype VOIP: happywildwarthog

Rahmatjohn Rozikov, BSc

TAWA Agriculture and Environmental Compliance Specialist

Azam Salimov, BSc

TAWA Agriculture and Dairy Specialist

Davron Isaev, MSc

TAWA Agriculture and Environmental Compliance Specialist

Acronyms and a Glossary of Terms used in this Tajikistan Programmatic PERSUAP

ACDIAgriculture Cooperative Development International (now ACDI/VOCA)

ADB Asian Development Bank

AFRAfrica Bureau, USAID

AglinksAgricultural Linkage Project

AIActive Ingredient (when pesticide reference)

ANammonium nitrate

ANEAsia and Near East Bureau, USAID

APOAgricultural Pesticides Ordinance, Pakistan

AVRDCAsian Vegetable Research and Development Center (operated 2016 Tajik project)

BCI Better Cotton Initiative

BMPBest Management Practice

BPPBest Processing Practices

BTBacillus thuringiensis (a bacteria that produces a toxin used as a pesticide)

BRC British Retail Consortium

CAC Central Asia and Caucasus

CARCentral Asian Republics

CACRPCentral Asia and the Caucasus Regional Program

CANcalcium ammonium nitrate

CARCentral Asian Republics

CAWMP Community Agriculture and Watersheds Management Project (World Bank)

CCDColony Collapse Disorder

CCFCCommonly Consumed Food Commodities

CCPCommittee on Chemical Protection (Tajikistan)

CEQCouncil on Environmental Quality (US Government)

CFRCode of Federal Regulations

CIMMYT The International Maize and Wheat Improvement Center

CISCommonwealth of Independent States

COP Chief of Party

COTRContracting Officer’s Technical Representative

DAIDevelopment Alternatives International

DCNDocument Number

DDTDichloro-Diphenyl-Trichloroethane

DPP Department of Plant Protection, Pakistan

DSPowders for dry seed treatment(pesticide formulation)

EAEnvironmental Assessment

EASC EuroAsian Interstate Council for Standardization, Meteorology and Certification

EBRD European Bank for Reconstruction and Development

ECEmulsifiable Concentrate (pesticide formulation)

EC50Effective Concentration (acute toxicity measure)

EDDEnvironmental Due Diligence

EGEconomic Growth

EMMPEnvironmental Mitigation & Monitoring Plan

EPAUS Environmental Protection Agency (also known as USEPA)

EUEuropean Union

FAOFood and Agriculture Organization (United Nations agency)

FAVZLocal Tajik Pesticide Importer and Distributor

FDAFood and Drug Administration (US)

FFPFood for Peace

FIFRA Federal Insecticide, Fungicide and Rodenticide Act

FOMFarmers Ownership Model

FSFlowable concentrate for seed treatment (pesticide formulation)

FTFFeed the Future

GAPGood Agriculture Practice

GDPGross Domestic Product

GFATM Global Fund to Fight AIDs, Tuberculosis and Malaria (WHO)

GHG Green House Gas

GIZGesellschaft für Internationale Zusammenarbeit (German International Cooperation)

GLAAS Global Acquisition and Assistance System

GlobalGAPGlobal Good Agriculture Practices, a certification system

GMP Global Malaria Programme (WHO)

GOSTGosudarstvennyy (Russian) standard

GOTGovernment of Tajikistan

GUPGeneral Use Pesticide

HaHectares

HACCPHazard Analysis and Critical Control Points

HFHydrogen Fluoride

HPAIHighly Pathogenic Avian Influenza

HTHighly Toxic

ICAMAInstitute for the Control of Agrochemicals of the Ministry of Agriculture, China

ICARDAInternational Center for Agricultural Research in Dry Areas

IDIdentification

IFRP International Food Relief Partnership

IEEInitial Environmental Examination

IGRInsect Growth Regulator

IPImplementing Partner

IPMIntegrated Pest Management

IRSIndoor Residual Spraying

ITNInsecticide-Treated Nets

IVMIntegrated Vector Management

IWMIntegrated Weed Management

LC50Lethal Concentration (acute toxicity measure)

LD50Lethal Dose (acute toxicity measure)

LGCP Local Governance and Citizen Participation

LLITNsLong-Lasting Insecticide-Treated Nets

LMDLocal Market Development, Swiss Helvetus

LRCSP Land Registration and Cadastre System for Sustainable Agriculture Program

MAILMinistry of Agriculture, Irrigation and Livestock, Afghanistan

M&E Monitoring and Evaluation

MCMercy Corps

MDMicro Dispersion (pesticide formulation)

MEOMission Environmental Officer

MOAMinistry of Agriculture

MOUMemorandum of Understanding

MRLMaximum/Minimum Residue Level/Limit

MRPMinimum Risk Pesticides

MSDSMaterial Safety Data Sheet

MTModerately Toxic

NATNot Acutely Toxic

NCATNational Center for Appropriate Technology

NEPANational Environmental Policy Act (US)

NGOsNon-Governmental Organizations

NIFANational Institute of Food and Agriculture

NIPNational Implementation Plan (for Stockholm Convention/POPs)

NPVNuclear Polyhedrosis Virus

OVCDOrganic Value Chain Development, Swiss Helvetus

PANPesticide Action Network

PEAProgrammatic Environmental Assessment

PERPesticide Evaluation Report

PERSUAPPesticide Evaluation Report and Safe Use Action Plan

PGRPlant Growth Regulator

pHlog of Hydrogen concentration, measure of acidity

PHI Pre-Harvest Interval

PICPrior Informed Consent (a treaty, relates to toxic pesticides)

POPsPersistent Organic Pollutants (a treaty, relates to toxic persistent pesticides)

PMPPest Management Plan

PNTPractically Non-Toxic

PPEPersonal Protection Equipment

ProAptTajikistan Productive Agriculture Project

PVOs private voluntary organizations

RBM Roll Back Malaria (WHO)

R&D toxin Reproductive and Developmental toxin

REARegional Environmental Advisor

Reg 216 Regulation 216 (USAID Environmental Procedures)

REIRe-Entry Interval (safety period after pesticide spraying)

ROWRights of Way

RUPRestricted Use Pesticide

S&CStandards and Certification

SCSave the Children

SCSuspension Concentrate (pesticide formulation)

SECOSecretariat for Economic Affairs, Swiss

STSlightly Toxic

SUAPSafe Use Action Plan

TAFF Tajik Agricultural Finance Framework

TAWATajikistan Agriculture and Water Activity

TDRSpecial Program for Research and Training in Tropical Diseases (WHO)

TSDWPTajikistan Safe Drinking Water Project

TERPTajikistan Emergency Response Program (Food for Peace, operated by SC/MC)

THM Trihalomethane

TFFPTajikistan Family Farming Program

TSEPTajikistan Stability Enhancement Program (operated by Mercy Corps)

UCUniversity of California

UFUniversity of Florida

ULVUltra-Low Volume (a type of sprayer/spraying that uses little water)

UNUnited Nations

UNDPUnited Nations Development Program

USAIDUnited States Agency for International Development

USDAUnited States Department of Agriculture

USEPA US Environmental Protection Agency (also known as EPA)

VATValue Added Tax

VOCA Volunteers in Overseas Cooperative Assistance (now ACDI/VOCA)

VHTVery Highly Toxic

WEEPWomen’s Entrepreneurship for Empowerment Project

WFPWorld Food Program (UN)

WHOWorld Health Organization

WPWettable Powder (pesticide formulation)

WSWater dispersible powder for slurry treatment (pesticide formulation)

WUAWater User Association

WUASPWater User Associations Support Program (operated by Winrock International)

Glossary of Terms

MSDS, Material Safety Data Sheet, a 2-5 page flyer produced by the pesticide manufacturer containing safety information(MSDSs can be found at www.msdsonline.com/; and and by doing Google searches using the acronym ‘MSDS’).

PMP, or Pest Management Plan, which can include an Integrated Pest Management (IPM) plan, includes pest anticipation and prevention planning and decision points, following USAID, USDA, academia and university extension services advice. Detailed IPM data contained in this PERSUAP is in Annex 1.

HACCP, Hazard Analysis and Critical Control Points, an analysis that identifies and mitigates point sources of risk in food handling and processing.

Table of Contents

INITIAL ENVIRONMENTAL EXAMINATION

Acronyms and a Glossary of Terms used in this Tajikistan Programmatic PERSUAP

Table of Contents

ACKNOWLEDGEMENTS

EXECUTIVE SUMMARY

Allowed Unrestrticted Pesticide Active Ingredients And Products For Same And Similar Use

PERSUAP Requirements and Recommendations for Mitigating Risks

SECTION 1: INTRODUCTION

1.1USAID Environmental Regulations

1.2Differences Between USEPA, WHO and Russian Acute Toxicity Classification Systems, and why this is Important

1.3Integrated Pest Management—USAID Policy

1.42016 Tajikistan PERSUAP Methodology

SECTION 2: BACKGROUND

2.1Country Background

2.2Pesticide Use Sectors in Tajikistan

2.2.1 Seed Treatment with Pesticides

2.2.2 Field Agriculture Pesticide Use