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BTOR 19 Thompson- Lebanon
BTOR 74 Ammati- Lebanon
BACK-TO-OFFICE REPORT
Reporting Officers: Mohamed Ammati
Richard Thompson
Country: Lebanon
Dates of visit: 3 – 15 April 2011
Date of report: 18 May 2011
Purpose of visit: 1 Facilitate Pesticide Management Workshop
2 Agree scope of activities for GCP/INT/114/USA
3 Plan PSMS enhancement and roll-out
Brief recommendations and follow-up action:
• New pesticide legislation should be drafted encompassing all sectors including
Agriculture, Animal Health and Public Health
• National Consultants for review of Code of Conduct should finalize report of the
workshop including the national priorities and action plan for strengthening
pesticide management in Lebanon
• Finalize the plans and provide TORs and potential consultants to address the high
priority issues that were agreed with HE the Minister of Agriculture under
GCP/LEB/021/ITA and GCP/INT/114/USA
• With CIOK, finalize plan and develop TORs for the enhancement and roll-out of
PSMS in Lebanon
Distribution:
Pandey, AGP
Kenmore, AGP
Prante, AGP
Hodder, AGP
Davis, AGPMC
Lichaa, FAOLEB
Valat, TCID
Moumen, FAOLEB
Hachem, FAORNE
Ravelomanantsoa, LEGN
Wehling, LEGN
Viparthi, CIOK
Settle, AGPMC
Helps, AGPMC
Van der Wulp, AGPMC
Yang, AGPMC
AG Registry
TC-FPMIS-Data Quality
BTOR 19 Thompson- Lebanon
BTOR 74 Ammati- Lebanon
1 Code of Conduct Review under GCP/LEB/021/ITA
Background and objectives
Food Safety and security is a current priority of the Ministry of Agriculture particularly in
relation to use and misuse of pesticides. On 10 and 11 May 2010 under the patronage of
H.E the Minister of Agriculture the Arab Society for Plant Protection facilitated a
workshop “Crop Health Management and Food Safety”. The focus of the workshop was
improving the sustainability of agriculture in Lebanon while reducing reliance on
pesticides and reducing risks from pesticides. A key recommendation from the workshop
was that the country should review the effectiveness of its implementation of the
International Code of Conduct on the Distribution and Use of Pesticides and strengthen
areas of weakness and gaps.
As a result of this recommendation, AGPM and LEGN provided terms of reference for a
review by national consultants of pesticide legislation and pesticide management
practices under GCP/LEB/021/ITA.
The objectives of the workshop were:
1. Present the findings of the legislation review and Code of conduct review to a
wide range of stakeholders (ministries; research institutions; pesticide importers,
distributors and sellers; farmers; pesticide applicators; and NGOs).
2. To identify the gaps and issues, and agree actions and their priority for
strengthening legislation and pesticide management.
Highlights of the meeting:
The agenda, recommendations of the working groups and participants are shown in the
annexes. The workshop was facilitated by Mohamed Ammati and Richard Thompson
from AGPM; Lalaina Ravelomanantsoa and Philine Wehling from LEGN; Dany Lichaa
Khoury, Project Manager and his team from GCP/LEB/021/ITA ; and the national
consultants Imad Nahhal, Halima Itani and Abdallah Ahmad.
Methodology:
The workshop presented and discussed the findings of the review of pesticide
management and pesticide regulations in relation to the International Code of conduct on
the Distribution and Use of Pesticides.
The participants were organized into 3 work-groups to review different areas of the
pesticide life-cycle and to identify the priority issues and make recommendations for their
resolution. The three work groups were:
Group A: pesticide registration and related legislation;
Group B: pesticide management (import, inspection, storage and
distribution); and
Group C: Marketing, use and empty container and unwanted pesticide
management.
BTOR 19 Thompson- Lebanon
BTOR 74 Ammati- Lebanon
The outcomes and recommendations of the different working groups were discussed and
refined in plenary session.
Key findings
The key findings and high priority recommendations were:
1. Pesticide legislation
a. Elaboration of one legislation covering pesticide and bio-pesticides
used in agriculture, public health (including domestic) and animal
health, with the capability for regional harmonization.
b. Elaboration of separate regulations for:
i. Pesticide registration including field trials
ii. Import
iii. Control
c. Elaboration of a single list of registered pesticides and bio-
pesticides in the above three sectors
d. Upload pesticide registry in PSMS
2. Pesticide Management
a. Capacity building in inspection and quality control
i. Training for sampling and inspection
ii. Evaluation of laboratory capacity in Lebanon for pesticide
quality and residues
iii. Assess the stores (and if possible inventory the stocks) of
the licensed importers, distributors and resellers in PSMS
as is done in routine inspection currently.
3. Use
a. Management of Empty containers should be regulated and a
feasibility study undertaken to review options for a national
management scheme
b. Undertake field studies in relation to pesticides use to evaluate the
condition of use and to evaluate their performance according to the
current regulation.
These priority actions were agreed by the Minister of Agriculture and will be funded by
GCP/INT/114/USA and GCP/LEB/021/ITA .
National Strategy for strengthening pest and pesticide management
The national consultants are preparing their final report which will include a draft
national strategy for strengthening pest and pesticide management. This will include all
the issues and recommendations identified during the workshop. Once agreed by all the
Ministries involved in pesticides, this strategy will form the framework for any future
activities and projects in the sector..
BTOR 19 Thompson- Lebanon
BTOR 74 Ammati- Lebanon
2 Lebanon Component of GCP/INT/114/USA
Background
The US Department of State through its Chemical Treat Reduction Programme has
agreed to fund FAO’s work to reduce pesticides risks including reducing reliance on
pesticides, strengthening capacity for pesticide management and addressing obsolete
pesticides. The funding is mobilized through a framework agreement with the USDA
GCP/INT/114/USA . During the formulation mission to Lebanon in May 2010, the
project activities in Lebanon were agreed to focus primarily on strengthening pesticide
management capacity with the development and roll-out of PSMS in Lebanon. The
project document was approved and funding received from the USDA in October 2010
In the intervening period the Ministry of Agriculture and FAOLEB agreed to fund the
PSMS activities under GCP/LEB/021/ITA and GTFS/REM/070/ITA , and the project
document remained unsigned by the Ministry of Agriculture.
During Mr Thompson’s mission to Lebanon 22-25 February, it was agreed with the
Ministry of Agriculture that the activities to be undertaken under GCP/INT/114/USA
would be modified to address priority recommendations from the Code of Conduct
Workshop. The project document was signed by the Ministry on this basis.
Objective
The objective of the mission was to reformulate the project to address priority pesticide
management issues and obtain the agreement of the Ministry of Agriculture.
Highlights of the meeting:
The Minister of Agriculture confirmed that Mrs Lama Haydar, Head of Pesticide
Registration at the Plant Pharmacy Department as National project coordinator.
Following the Code of Conduct workshop meetings were held with Dr Samir el Chami,
Acting Director General of Agriculture-Director of Plant Resources; Mrs Lama, Dr Salah
Hajj Hassan, advisor to the Minister and Mr Mohammed Abou Zeid Head of the Plant
Pharmacy Department during which the scope and budget of the Lebanon Component
were agreed. The main elements are:
• Assessment and development of pesticide inspection capacity throughout the
life-cycle
• Training of trainers for inspection bodies
• Training on inspection and sampling of pesticide import
• Procurement of inventory equipment and personal protective clothing
• Feasibility study for a management scheme for empty containers and the
collection of unwanted pesticides from users
• Field studies on pesticide use
An Aide-Memoire was prepared detailing the activities and budget. During the meeting to
sign the Aide Memoire, on the insistence of the Minister with the support of FAOR, an
additional unbudgeted and unscoped activity, “Awareness campaign on pesticide
BTOR 19 Thompson- Lebanon
BTOR 74 Ammati- Lebanon
poisoning” was added. While agreeing that pesticide poisoning is an important issue, the
RO pointed out that, to be effective, communications campaigns require research into the
knowledge, attitudes and practices of the target audiences, careful design and adequate
funds. Unresearched, poorly designed and under-funded communications campaigns can
be counter-productive. The Minister agreed that if project funds did not become
available, the ministry would find its own resources for the awareness raising campaign.
The aide-memoire was signed by Dr Samir el Chami, Acting Director General of
Agriculture-Director of Plant Resources and FAOR on 14th
April and is included as an
Annex to this report.
3 Enhancement and Roll-out of PSMS
Background
The Ministry of Agriculture is keen to strengthen the management and control of
pesticides during their lifecycle in Lebanon. The Plant Pharmacy Department has a stand-
alone database that has been developed for them to manage their pesticides registrations.
The system however has not been put into operation.
FAO has developed the Pesticide Stock Management System (PSMS)as a tool for
countries to use to hold pesticide registration information, control and manage stocks of
pesticides throughout their lifecycle in the country including disposal of unwanted empty
containers and pesticides. There is a component that specifically addresses developing
safeguarding strategies for obsolete pesticides.
The Ministry of Agriculture is interested in utilizing PSMS to improve its lifecycle
control and management of pesticides. This document describes the wishes of the
ministry.
As PSMS is a tool for all FAO member states, it is important that any enhancements will
improve its usefulness and usability to all countries. Where Lebanon has requirements
that are specific solely to its national context, those requirements will have to be
addressed outside the core PSMS.
Objectives of the mission
The objective of the mission was to meet with the Ministry to clarify their requirements
and wishes for a system for managing and controlling pesticides and to canvass views of
other stakeholders that would be required to use the system. Following these meetings to
develop an outline scope for the system to facilitate discussions within AGPMC and
CIOK regarding the need for enhancements in PSMS and stand-alone systems for
Lebanon.
Highlights of Meetings
BTOR 19 Thompson- Lebanon
BTOR 74 Ammati- Lebanon
Meetings were held with the Ministry of Agriculture (Lama Haydar, Salah Hajj Hassan
and Mohammad Abou Zeid) and representatives of pesticide importers, formulators and
distributors (SLAC, Debbane, and Adonis).
The private sector were willing to cooperate with the initiative provided that their
commercially confidential information was protected. They accepted a system which
would manage the processes that are currently controlled by the Ministry, i.e. the import
procedures and the new selling procedures where users are required to produce a
prescription from an Agricultural engineer to procure pesticides. They were reluctant to
use a system which tracked pesticides throughout the distribution chain.
At the final meeting with the ministry a detailed specification document was prepared.
This is shown in the annex.
Recommendations
The RO should follow up with meeting with CIOK to identify the most effective means
of satisfying the requirements for the system in Lebanon.
Annex - Recommendations of Code of Conduct Workshop
Issues Recommendation Priority Classification
Evaluation of alternative
pest management options Not discussed
Identification and
Removal of highly
hazardous pesticides
Not discussed
Nee
ds
Ass
essm
ent
Incorporating needs
assessment in registration
process
Not discussed
Single Registration Body
for all Pesticides
• Need to establish a single registration body and the
details regarding its competencies in addition to
the stakeholders involved will be discussed later.
Reg
istr
atio
n
Definitions of Pesticides
• Adopt a law that will act as an umbrella for
chemical pesticides and bio-pesticides.
• The definition of the chemical pesticide will be
inspired by the code of conduct while the
definition of the biological pesticide will be agreed
upon pursuant to FAO recommendations.
• As for the details, regarding agricultural
pesticides, public health pesticides and veterinary
pesticides, they will be mentioned in special
decrees.
Annex - Recommendations of Code of Conduct Workshop
Issues Recommendation Priority Classification
Improvement of the
Registration System
• All pesticides, active ingredients and technical
ingredients should be registered.
• In order to import all kind of pesticides, licenses
for both registration and use should be given.
• While for technical and active ingredients, only a
license for registration is given.
• The registration process requires an importer
license.
• Agricultural professions licenses are subject to a
symbolic fee.
• Each pesticide to be registered shall also be
subject to a symbolic fee.
• After registering the pesticides in the relevant
tables, a time frame shall be determined for field
trials in order to ensure that the pesticide does not
have any harmful impact on the environment and
the public health. Following those trials, the
license of use will be issued.
Transparency and
Availability of
information on Registered
pesticides.
• A unified list of pesticides shall be developed on
national level.
Annex - Recommendations of Code of Conduct Workshop
Issues Recommendation Priority Classification
Regional Collaboration
and Harmonization
• The draft law shall stipulate the need to take all the
necessary procedures in order to ensure a proper use
and transportation of the pesticide and guarantee its
alignment with public health and environment safety.
• Information exchange and commercial exchange
between the countries of the region.
Issues Recommendation Priority Classification
Lack of data to base
decisions for needs
assessment
Prepare and publish detailed statistics of pesticide
registry, pesticide imports, stocks, use, types, package
sizes,
Cropping calendar for forthcoming season for use in
public and private sector decisions
H 1
Legislation,
regulations
and
institutional
structures
Nee
ds
Ass
essm
ent,
Imp
ort
/form
ula
tio
n
Effective needs
assessment
Undertake an agricultural census,( crops, pests, uses),
Field history and bookkeeping,
Needs of new areas to be developed
Training on needs assessment for import for public and
private sectors
H 2
Pesticide
Management
capacity
building
Annex - Recommendations of Code of Conduct Workshop
Issues Recommendation Priority Classification
Requirement for import
and export licences,
control and data
Further study and consultation required for reconciling the
requirements for the ministry to control imports and
ensure fair competition in the private sector
(Updating the legislations, reduce bureaucracy,
notification to replace license of export until procedures
are well defined, gathering correct data)
Important to have an import Licence, and work on speed
up procedures and transparency.
L 3
Legislation,
regulations
and
institutional
structures
Compliance with
Rotterdam
Review the mechanisms for compliance with Rotterdam
and determine the needs for export permits
M 2
Legislation,
regulations
and
institutional
structures
Sampling procedure at
entry point -
Staff do not have capacity
and equipment to sample
effectively at entry point
Large pack sizes should be customs sealed and the
samples taken at the facility of the importer or formulator.
Capacity building in safe sampling to avoid cross
contamination and correct sampling procedures
For consignments of small bottles should be sent directly
to Kfarsima
H 1
Pesticide
Management
capacity
building
Capacity and number of
Ministry staff
Review needs for staff numbers and capacity and
undertake Training for Ministry staff L 2
Pesticide
Management
capacity
building
Annex - Recommendations of Code of Conduct Workshop
Issues Recommendation Priority Classification
Emphasis of IPM IPM should be encouraged with the users to reduce
pesticides needs
Awareness Raising, Training of Farmers,
Alternatives to chemical pesticides H 1
Pest
management
capacity
building (e.g.
lower risk
alternatives)
Inspection can be seen as
over bureaucratic
Inspection regimes should not restrict private sector (not
too burdensome) yet fulfilling proper level of security and
quality H 1
Legislation,
regulations
and
institutional
structures
Quality control issues FAO pesticide specifications should apply as “good
quality pesticides”
Private sector would like to be able to use Kfarshima for
pesticide testing
Split samples and recourse to third party accredited lab in
event of dispute
Agreed methodologies should be used by Kfarshima
(accreditation)
Capacity building for laboratory staff in methodologies
and GLP
H 1
Legislation,
regulations
and
institutional
structures
insp
ecti
on
/qu
alit
y c
ontr
ol
Standard of inspection Assess inspection regimes in Lebanon with regard to the
code of conduct and identify gaps and plan for their
improvement H 1
Pesticide
Management
capacity
building
Annex - Recommendations of Code of Conduct Workshop
Issues Recommendation Priority Classification
Traceability Implement PSMS in Lebanon – step by step
H 1-3
Pesticide
Management
capacity
building
Low capacity of the staff
in the regional
inspectorates
Review the options for outsourcing the inspections to
private inspection companies or
Build capacity through the regional inspectorates with
Training and systems
H 2
Pesticide
Management
capacity
building
No standardised procedure
for inspection
Develop inspection procedures and checklists for stores
and pesticide quality
H 2
Legislation,
regulations
and
institutional
structures
MoA only accepts
analytical standards from
third party organisations –
for new AIs these are not
available
This problem should be addressed by the pesticides board
rather than just Kfarshima
H 1
Legislation,
regulations
and
institutional
structures
No transport rules for
hazardous materials
With the ministry of transport investigate options for
developing regulations for transport of hazardous
materials
Vehicle standards
Driver training
H 3
Legislation,
regulations
and
institutional
structures
Sto
rage
and
Dis
trib
uti
on
Low capacity of store
keepers
Training programme for storekeepers in private and public
sector stores - M 1
Pesticide
Management
capacity
building
Annex - Recommendations of Code of Conduct Workshop
Issues Recommendation Priority Classification
Stores are located in
residential areas
Review and update the regulations for pesticide stores to
meet international standards
Municipality grants approval for location of the store. The
Municipality staffs are not aware of the risks. The MoA
grants a licence on the basis of this approval. The
regulations should be amended to ensure adequate
assessment of the risks.
Municipality staff should be trained.
M 2
Legislation,
regulations
and
institutional
structures
Environmental risks posed
by storage locations and
conditions
Use PSMS to evaluate the risks of stores
The Ministries of Environment and Health should be
involved in the assessments M 2
Legislation,
regulations
and
institutional
structures
Issues Recommendation Priority Classification
Misleading publicities Prior technical control by MOH, MOA in collaboration
with MOI when needed
M-2 Legislation-
regulations
Unavailability of
information
MOA to continuously publish the list of registered and
banned products and their crop use (Label + MSDS)
H-1 Communicatio
n
Solvents of toxicological
concern
MOA to enforce naming of these solvents in the label
under “notes to physicians”
M-3 Legislation
Difficulty in custom
clearance of biological
pesticides alternatives
MOA in collaboration with customs to facilitate faster
clearance in the ports of entry
H-2 Regulations
Ma
rket
ing
Unsuitability of some
pesticides containers
MOA to enforce the fabricators/Importers to provide
suitable quality containers and to repack the pesticides of
inadequate containers
H-3 Legislation
Annex - Recommendations of Code of Conduct Workshop
Issues Recommendation Priority Classification
Transfer of pesticides to
smaller packs
Promote the use of soluble small packs when applicable M-3 Pesticide
Management
capacity
building
Scarcity of measuring
cups
MOA to enforce the inclusion /distribution of measuring
cups in adequate numbers
M-2 Pesticide
Management +
Legislation
Lack of proper application
equipment
New technology transfer program on equipment and their
proper use
H-1 Pesticide
Management
Capacity
building-
Communicatio
ns &
Awareness
raising
No use & Lack of PPE
(Personal Protective
Equipment)
Awareness program on the importance of using PPE to
users
H-1 Communicatio
ns &
Awareness
raising
Use
Misuse of pesticides and
spraying equipment
Training of MOA staff on proper pesticides and equipment
use
Extension program and demonstrations
H-1 Communicatio
n and
awareness
raising/
Pesticide
Management
Capacity
building
Annex - Recommendations of Code of Conduct Workshop
Issues Recommendation Priority Classification
Weak advisory system for
pest management
Support IPM research
Continuous training of MOA extension staff
Initiate IPM programs on greenhouses, citrus, grapes and
other major crops (Public -Private- Research centres and
universities and NGOs partnership)
H-1 Pest
management
capacity
building
Farmers don’t read labels Awareness campaign by extension services H-1 Communicatio
n and
awareness
raising
No follow up of pesticide
efficacy and mixture
compatibility at end user
level
Extension services in cooperation with private sector to
monitor and report efficacy and compatibility of mixtures
M-1 Pesticide
management
capacity
building
Health monitoring Activate existing legislations
MOH to request from hospitals and medical centres to
report cases of pesticide poisoning
MOA to enforce the inclusion of poisoning centre phone
(toll free)
H-1 Legislation
and
communicatio
n
Ma
nag
emen
t o
f em
pty
con
tain
ers
an
d
un
wa
nte
d p
esti
cid
es Weak mechanism of
disposal of empty
containers
Awareness on triple-rinse, puncturing of containers and
proper disposal
Waste collecting services to include specific bins for
empty pesticides containers in agricultural areas
Farmers to return empty containers to resellers, resellers to
collecting services
Collection and recycling (non food grade)/ disposal by the
plastic recycling industries
MOI to control the recycling into non food grade
Cost of services to be charged as a levy on quantity of
imports
M-2 Pesticide
management
building
capacity +
Legislation +
Communicatio
n and
awareness
raising
Annex - Recommendations of Code of Conduct Workshop
Issues Recommendation Priority Classification
No mechanism for
disposal of unwanted
pesticides (obsolete,
expired or unused)
MOA to enforce importers to assess the quantity of
pesticides needed
Expired pesticides are considered obsolete unless proved
to be properly stored in the importers stores and
complemented by chemical and physical validation tests in
locally and internationally accredited labs
MOA-MOH-MOE to make yearly circular requesting all
whole sale and retail pesticides stores to declare the
amount of obsolete pesticides available with a clear note
that the disposal will be at the expense of the Lebanese
government and it doesn’t involve any penalty for small
quantities
H-2 Legislation
1
Participants
Strengthening Production and Marketing of the Lebanese Agricultural Products (GCP/LEB/021/ITA)
Name Position Institution Email Phone Signature
Samir el-Chami
Acting Director General of
Agriculture-Director of Plant
Resources
Ministry of
Agriculture
Salah Hajj Hassan Advisor to The Minister Ministry of
Agriculture
Mohamad Abu
Zeid Head of Plant Protection Service
Ministry of
Agriculture
[email protected] 03 315 180
Lama Haidar Head of Plant Pharmacy
Department
Ministry of
Agriculture
[email protected] 71 297 410
Imad NAHHAL Head of Plant Protection
Department
Ministry of
Agriculture
b
03 894 679
Salem Hayar Head of Kfarshima Lab for
Pesticides Analysis
Ministry of
Agriculture
[email protected] 03 416 364
Najwa Khansa Plant Pharmacy Department Ministry of
Agriculture
Najwa-
03 216 972
Rima El Shihne Plant Pharmacy Department Ministry of
Agriculture
Rima-el-
70 476 177
1
List of Participants of the Workshop Pesticide Management in Lebanon
Strengthening Production and Marketing of the Lebanese Agricultural Products (GCP/LEB/021/ITA)
Desire El Dayyeh Plant Pharmacy Department Ministry of
Agriculture
Desiree-
03 730 268
Carole Najjar Plant Pharmacy Department Ministry of
Agriculture
[email protected] 70 858 852
Abdallah Ahmad Legal dept Ministry of
Agriculture
[email protected] 03 297 086
Name Position Institution Email Phone Signature
Abir Abou El-
Khoudoud
Head of extension and
education department
Ministry of
Agriculture
v.lb
Did not come
Dr. Elias Chaaban Veterinary Drugs Office Ministry of
Agriculture [email protected]
70 068 797
Charles Zazour Head of plant Quarantine
Service
Ministry of
Agriculture [email protected]
009615952510
Dr. Obeida
Mdawar
Head of Animal quarantine
Department
Ministry of
Agriculture [email protected]
03 469 019
Youssef Abou
Jawde
Member of Pesticides
Committee
American University
of Beirut- [email protected]
03 01 03 44
1
List of Participants of the Workshop Pesticide Management in Lebanon
Strengthening Production and Marketing of the Lebanese Agricultural Products (GCP/LEB/021/ITA)
List of Participants of the Workshop Pesticide Management in Lebanon
Aziz El Ammar Member of Pesticides
Committee Debbane Freres [email protected]
03 300 598
Fabienne Jbara Member of Pesticides
Committee SLAC [email protected]
03 699522
Nadine Antar Member of Pesticides
Committee ANTAGRO
Did not come
Samir ASSI Member of Pesticides
Committee ADONIS [email protected]
03 300 345
Kozhaya El
ZOUKI
Member of Pesticides
Committee INSECTA
Did not come
Fatima EL Ali Member of Pesticides
Committee
Lebanese
Agricultural Research
Institute
Did not come
Name Position Institution Email Phone Signature
Mhamad Kabbara Observer- Pesticides Committee Order of Engineers Did not come
1
Strengthening Production and Marketing of the Lebanese Agricultural Products (GCP/LEB/021/ITA)
List of Participants of the Workshop Pesticide Management in Lebanon
Dr. Fakher
Dakroub Observer- Pesticides Committee Order of Engineers
03 652 363
Adel Yacoub Head of Protection of Natural
Resources Service
Ministry of
Environment [email protected]
01 976 555
Ext:456
Did not come
Olfat Hamdan Head of Chemical Safety
Department
Ministry of
Environment [email protected]
01 976 555
Ext:408
Did not come
Farid Karam Head of Service of Sanitary
Engineering Ministry of Health
m
03 643 155
Ms Hayat Azouri
Health issue person -
Toxicologist
03-332246
St Joseph University
Anti poisoning centre
– toxicology
department
03 332 246
Eng Mohammad
Naja
Registration Officer in the
company Agricultural Materials
m.naja@agrimatco-
me.com
03 386 127
Eng Ziad Zughaib Registration Officer in the
company
Akiki
Did not come
Fouad Diab Large farmer of Citrus in South
of Lebanon Commercial farmer
Did not come
Name Position Institution Email Phone Signature
1
Eng. Ibrahim Al
Hariri
Large farmer and act as a leader
to farmers in his region (Saida)
Al Hariri Foundation -
Agricultural Section &
Commercial farmer
Did not come
Eng Ali Fiad Al
Tarshishi
Large farmer and sprayer to
farmers in his region (Bekaa –
Baalbeck)
Worker &
Commercial farmer [email protected]
Did not come
Eng. Mohammad
Al-Hajj
General Manager- Agriculture
Section
Jihad-al- Binaa
Development
Association
Did not come
Eng. Patricia R.
Sfeir
Agriculture & Environment
Department Manager
Young Men's
Christian Association
(YMCA)
Did not come
Ms Maya Dao Legal dept Ministry of
Environment [email protected]
01 976555
ext:463
Did not come
Mr. Bashir Eid Customs Service Ministry of Finance [email protected]
b
03 675089
Louai Hajj
Chehadeh Directeur des douanes Ministry of Finance
01 429 003 Did not come
Eng. Ramzi
Shasha Chemical Engineer Ministry of Industry
m
71 79 45 22
Dr. Fadi Salhani
Head of Department for
Applying of public health
pesticides
Municipality of Beirut
01 580 122
03 87 55 53
1
Strengthening Production and Marketing of the Lebanese Agricultural Products (GCP/LEB/021/ITA)
List of Participants of the Workshop Pesticide Management in Lebanon
Name Position Institution Email Phone Signature
Eng Adnan Katerji Responsible for applying public
health pesticides Municipality of Beirut
Ammar El kaak Small farmer of vegetables in the
Bekaa - Baalbeck Commercial farmer
03 038540 Did not come
Nihal El Homsi WHO Did not come
Solange
MattaSaade Field programme Officer FAO Lebanon
Solange.mattasaade@fao.
org
03 950206
Did not come
Halima Itani National pesticides management
consultant [email protected]
03 620 952
Eng. Georges
Kaddisi Marketing coordinator
Comptoir Agricole du
levant [email protected]
01 890 811
Moussa Kfoury Agriculture business master 70 836 157
Sarah Ezzedine Agriculture Engineer YMCA [email protected]
m
03 260 388
1
Strengthening Production and Marketing of the Lebanese Agricultural Products (GCP/LEB/021/ITA)
List of Participants of the Workshop Pesticide Management in Lebanon
Dr. Hanna Bou
Habib MoE [email protected]
03 175 022
Name Position Institution Email Phone Signature
Mustafa Antar Marketing Coordinator Antagro [email protected] 01 311 603
Nayla Maalouf Agriculture engineer Robinson Agri [email protected] 09 796 144
Talar Babikian Agriculture engineer Robison Agri [email protected] 70 862 465
Dr. Abed Rahman
Saghir Consultant Ex AUB [email protected]
03 728 819
Marwan Akkary Technical and Development
manager Debbane [email protected]
03 370 310
Nabil Kaissi Engineer ESIB [email protected] 01 864 876
Mohammad
Darwish Saab Foundation
Hsaab-
03 80 94 97
Hanadi Jaafar MoA [email protected]
m
Dr. Faten Raad Researcher LARI [email protected] 03 73 84 32
1
Annex
25
Aide-Memoire
FAO Lead Technical Unit
Pesticide Risk Reduction in Middle East and Asia (GCP/INT/114/USA)
Reformulation of the Project Component for Lebanon
April 4 - 15, 2011
1 Introduction
The component for Lebanon in Pesticide Risk Reduction in Middle East and Asia
(GCP/INT/114/USA) was originally formulated during a mission in May 2010 by the Lead
Technical Officer, Richard Thompson. It was agreed that the focus of the component should
be implementation of the Pesticide Stock Management System (PSMS) in the country while
the project “Lebanese Observatory for Agricultural Development” (GCP/LEB/020/ITA)
would include an initial survey of obsolete pesticides from agricultural input suppliers. The
project framework agreement was signed between the United States Department of
Agriculture and FAO in October 2010.
During the intervening period, the priority for the implementation of PSMS was raised and it
was agreed between the Ministry of Agriculture and FAO Lebanon that it should be included
in the project “Strengthening Production and Marketing of Lebanese Agricultural Products”
(GCP/LEB/021/ITA) with additional support from the Regional IPM Project
(GTFS/REM/070/ITA).
GCP/LEB/021/ITA has also funded a review of the “pesticide life cycle” and an evaluation of
the country’s implementation of the Code of Conduct on the Distribution and Use of
Pesticides (the Code). A stakeholder workshop was held between 5th
and 7th
April 2011, at
which the gaps in the implementation of the Code were reviewed and activities to address
them identified.
The Ministry of Agriculture (MoA) has requested that FAO reformulate the Lebanon
component of GCP/INT/114/USA to address the highest priority activities. This aide
memoire describes the activities, the revised budget and new work plan that have been agreed
by the Ministry.
2 Reformulated Activities
The priority activities that will be addressed under the Lebanon component of
GCP/INT/114/USA are described below:
2.1 Legislation and pesticide management workshops
The development of the national pesticide legislation and the national pesticide management
strategy will require two further stakeholder workshops in October 2011 and January 2012.
The workshops and the participation of other FAO experts will be funded by
GCP/LEB/021/ITA. The LTO of GCP/INT/114/USA will participate in both workshops to
assist in the formulation of the legislation and the development of the national pesticide
management strategy. His participation will be funded by GCP/INT/114/USA.
26
2.2 Assessment and development of pesticide inspection capacity throughout the
life-cycle
The capacity and inspection roles of the regional MoA services responsible for inspection of
pesticides, customs inspectors, quarantine officers and other inspection staff will be assessed
in a review undertaken by a national consultant under the support of an international expert.
If there is a potential need for the use of private sector inspection agencies, their capacity will
also be assessed. The international consultant will develop a report detailing
recommendations in the improvement of the inspection strategy for Lebanon. The report will
include recommendations for the roles of each of the groups involved in inspection; their
training requirements; the development of standard inspection methodologies and checklists;
and the equipment required for sampling, sample storage and personal protection. All
methodologies and checklists will be prepared with Arabic versions.
2.3 Training of trainers for inspection bodies
The national and international consultants employed under section � will be engaged to
undertake a five-day training of trainers for up to 20 staff selected from each of the central
and regional bodies designated for undertaking pesticide inspections. The training will be
based on the methodologies and checklists developed in section �.
2.4 Training on inspection and sampling of pesticide import
The national and international consultant employed under section � will be engaged to
undertake a five-day training for up to 25 staff selected from the inspectors of imports and for
identification of pesticide products and inspection and sampling methodologies. The staff will
undertake a full medical check (including cholinesterase inhibition to check for previous
pesticide poisoning) prior to the training. The project will procure sampling equipment
(samplers and sample storage equipment) and personal protective clothing that will be
demonstrated during the training. The specification and quantity for the sampling equipment
will be determined by the consultants during the assessment outlined in section �.
2.5 Procurement of inventory equipment and personal protective clothing
The project will procure equipment to be used for the evaluation of pesticide stores and the
inventory of their stocks. The equipment will be available for use by the regional inspectors
when they inspect pesticide stores and complete inventories of stores of the importers,
distributors and resellers as part of the roll-out of PSMS.
2.6 Feasibility study for a management scheme for empty containers and the
collection of unwanted pesticides from users
A national consultant will be engaged to undertake an assessment of the pesticides entering
the market/used in Lebanon and their pattern of distribution and use in order to:
• estimate the quantities, sizes, types and materials of construction of containers that are
required to be recycled annually;
• estimate the patterns of arising of empty containers including seasonality and
geographical concentrations;
• estimate the current level of practice of “triple rinsing”;
• identify the options for collecting the empty containers and small quantities of
unwanted pesticides from users including the local waste management services,
dedicated collection points, reverse distribution through the resellers; and
• assess the national and regional recycling industry to identify recycling/disposal
options for each of the container materials.
27
Together with the national consultant, the international consultant will undertake a two day
stakeholder workshop to present the findings of the review and develop recommendations for
the national container management scheme. The international consultant will prepare a costed
proposal for establishing and running the scheme including awareness raising and
infrastructure. The proposal will also include options for funding the scheme.
2.7 Field studies on pesticide use
The current data available to the Ministry of Agriculture on the patterns and practices of use
of pesticides is very limited. A national consultant will be engaged to undertake field studies
to gather information on the storage, use and disposal practices of pesticide users. The study
will primarily focus on farmers involved in agriculture, horticulture, livestock husbandry but
will also include public health pesticides by municipal authorities and the public. The study
will assess the knowledge, attitudes and practices of farmers with respect to: sources of
advice on pest management; needs assessment; pesticide use; alternative pest management
practices; pesticide risks; personal protection; and awareness poisoning symptoms and signs.
The report of the study will include an assessment of the gaps and recommendations for
priority actions.
2.8 Awareness campaign on pesticide poisoning
The Ministry of Agriculture will develop an awareness campaign on pesticide poisoning to be
designed after the beginning of the project.
3 Terms of Reference
Outline terms of reference are included in the main project document. Detailed terms of
reference will be developed from these for each of the consultancies.
4 Duration
The duration of the project is 12 months from the date of signature of this Aide Memoire.
5 Budget
The total budget for this component is USD 180 000. The budget breakdown by activity and
oracle code is shown in Annex 1.
6 Work plan
The work plan is shown in Annex 2.
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7 Signature
This Aide-Memoire has been signed on 14th
April 2011 by the Government of Lebanon,
represented by the Director General of the Ministry of Agriculture, Eng Samir El Chami
and the Food and Agriculture Organization of the United Nations, represented by the FAO
Representative in Lebanon, Dr Ali Moumen.
For the Food and Agriculture
Organization of the United Nations
Ali Moumen
FAO Representative
For the Government of Lebanon
Eng Samir El Chami
Director General of the Ministry of Agriculture
Annex 1 Budget
Budget
line Component Description Sub Comps Main Comp.
5013 Consultants USD 39,755
5542 Consultants - International USD 18,800
5543 Consultants – National USD 20,955
5014 Contracts USD 0
5650 Contracts Budget USD 0
5020 Locally Contracted Labour USD 4,800
5652
Casual Labour - Temporary
Assistance USD 4,800
5021 Travel USD 30,015
5661 Duty travel others (FAO staff only) USD 4,492
5684 Consultants - International USD 12,753
5685 Consultants – National USD 12,770
5023 Training USD 18,800
5920 Training Budget USD 18,800
5024 Expendable Equipment USD 30,000
6000 Expendable Equipment USD 30,000
5025 Non Expendable Equipment USD 0
6100 Non Expendable Equipment Budget
5027 Technical Support Services USD 28,080
6120 Honorarium TSS USD 28,080
5028 General Operating Expenses USD 7,842
6300 General Operating Expenses Budget USD 7,842
5029 Support Cost USD 20,708
6118 Project Support Costs (13%) USD 20,708
Grand Total USD 180,000
Pesticide Management US Dollar
Evaluation of stores of importers and resellers 15,000
Training of inspection protocols throughout life-cycle 10,716
Training in sampling and inspection at borders 39,488 Assessment of inspection capacity throughout life-cycle and development of inspection protocols 13,490
Use
Field Studies 27,240
Feasibility study for container management and collection of small quantities 15,986
Legislation
Facilitation of stakeholder workshops on national pesticide legislation and pesticide management strategy 18,892
Management
Management of Lebanon Component 13,680
PSC 20,708
National Project coordinator 4,800
Grand Total 180,000
2011 2012
Activity J F M A M J J A S O N D J F M A M J J A S O N D
1 workshops
2 Assess and develop inspection capacity
3 Training of Trainers for inspection
4 Training of trainers for sampling
5 Procurement for inventory
6 Feasibility study for Container Management
7 Field studies on pesticide use
Pesticide Stock Management System Implementation in Lebanon
1 Introduction
The Ministry of Agriculture is keen to strengthen the management and control of pesticides
during their lifecycle in Lebanon. The Plant Pharmacy Department has a stand-alone database
that has been developed for them to manage their pesticides registrations. The system
however has not been put into operation.
FAO has developed the Pesticide Stock Management System (PSMS)as a tool for countries
to use to hold pesticide registration information, control and manage stocks of pesticides
throughout their lifecycle in the country including disposal of unwanted empty containers and
pesticides. There is a component that specifically addresses developing safeguarding
strategies for obsolete pesticides.
The Ministry of Agriculture is interested in utilizing PSMS to improve its lifecycle control
and management of pesticides. This document describes the wishes of the ministry.
As PSMS is a tool for all FAO member states, it is important that any enhancements will
improve its usefulness and usability to all countries. Where Lebanon has requirements that
are specific solely to its national context, those requirements will have to be addressed
outside the core PSMS.
2 Objectives for use of PSMS in Lebanon
The Ministry of Agriculture wishes to monitor and control the import, distribution and use of
pesticides in Lebanon with the following objectives:
• Manage Pesticide Registrations
• Investigated sources of pesticides where crops are found with excessive residue
levels.
• Monitoring lifecycle of pesticides
• Limit smuggling
• Limit inappropriate use of pesticides
• Monitoring expiry of pesticide stocks
3 Vision for PSMS implementation mechanism
3.1 Registration
PSMS has been developed to HOLD pesticide registration information that would be
common to all countries using the system. It was not intended to replace pesticide registration
systems that been designed to meet the specific requirements of a country for evaluating
dossiers etc.
As part of the enhancement process, the FAO CIOK team will investigate the options that
will allow MoA to manage all the datasets that have been built into the Ministry’s standalone
registration database. These options will include:
• Adapting PSMS to hold all the information
• Linking PSMS automatically with the Lebanese standalone registration database
system
• Exporting from Lebanese standalone registration database system and importing to
PSMS
• Splitting the functions between the two systems such that registrations are handled in
PSMS and other data (e.g. list of engineers) is held in the Lebanese standalone
registration database
3.2 Import
Importers do not want to divulge their imports until immediately before they arrive.
• Issue a series of barcode numbers for each importer
• Importer gives to his supplier sufficient of these the bar code numbers for the
containers in the consignment. The supplier puts barcodes onto each container prior
to shipment.
• Prior to the arrival of the load, the importer should enter the details of the pesticides in
the consignment into PSMS together with the barcode numbers.
• When the product arrives in Lebanon, the following steps are taken
Ministry of Agriculture Plant Quarantine at Entry
Point
Customs
Importer submits to MOA PP:
request for taking samples of
shipment along with copy
shipping documents
Importer puts the information
of the consignment into psms
Examine the shipping
documents to determine
whether the shipment contains
pesticides
MOA checks to see product is
registered and PSMS record is
complete issue a Laissez
Passer for taking samples plus
a paper copy of PSMS record
to the plant Quarantine
Issue a provisional declaration
which is sent to plant
quarantine
When both documents are
received, plant quarantine
take a sample and check
that the psms information
is correct and send sample
to Kfarshima
Kfarshima checks analysis
certificate and other info
and import statement and
if OK undertakes analysis
If analysis is fine,
Kfarshima send a copy of
the analysis to MOAPP,
this should be done
electronically
If analysis is not ok,
MOAPP check the analysis
and informs the Importer to
collect analysis from MOA.
Importer signs the analysis for
receipt.
If the analysis is not ok the
importer has a right to do the
analysis again in an
independent laboratory
this should be done
electronically – to importer
and plant quarantine
Importer takes analysis to
plant quarantine who then
release the pesticides and
sign the Customs
Provisional declaration
authorizing customs to
release the goods
PSMS record is updated to
show it has entered the
Ministry of Agriculture Plant Quarantine at Entry
Point
Customs
country and arrived at the
importer
3.3 Sale process at retailer
• Retailers must all be licenced and Stores should be recorded in PSMS
• Farmers must be registered. (registered farmers could be input in PSMS)
• Farmer obtains a prescription (5 copy) from an Agricultural Engineer
• Farmer goes to reseller with the prescription and buys the prescribed pesticides
• The reseller puts the barcode numbers of the pesticides onto the prescription
there are two options for this:
• A double barcode label that has a peelable sticky top label (in one colour) that can
be stuck to the prescription and a permanent under label (in another colour) with
the same number
• Write the bar code number on the prescription. (issue with mistakes in writing the
number)
• The reseller transfers the details of the prescription, sale and barcodes to MoA. There
are two options:
• The reseller enters the information into PSMS directly
• The reseller delivers monthly the prescription with the receipt and barcodes to the
local inspector. The local inspector transmits the documents to the MoA for data
entry.
4 Enhancements and integration with local systems
The ministry of Agriculture wishes to use PSMS
• All reports should be generated in Arabic
• The system should include an automatic registration numbering (start with the last
registered number) (could be just a test to check for uniqueness – currently the number
sequential number concatenated with the date dd
• Usage details page: add more fields including dosage, Pre-Harvest Interval (PHI), Maximum
Residue Limit (MRL)
• Include a database of engineers or technical responsible per business
• Scanning of all related documents (should be further investigated specially in relation to
confidentiality issues)
• The system should popup warning alerts in relation to the expiry of registration
• The system should be able to generate a Certificate of Registration(template specific to
Lebanon e.g. with logos and in Arabic)
• Review the design of Excel export form in registration
• Expand the search to single page covering all the fields, including the newly requested ones
• The system should not allow the registration of banned active ingredients
• Reproduce all the forms in Arabic
• The system should distinguish between importers, retailers and formulators
• Add the prescription records for every movement from retailer to user
• The system should include a sample tracking component of imported pesticide
• Automatic and printable confirmation to the importing companies module
• Movement tracking: add quantity and barcode series fields in order to cater with the small
bottles
Add a repacking component