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TRACKING ID: # BFS-18-08-008 1 PARTNERSHIPS FOR AFRICA SEED TECHNOLOGY TRANSFER ACTIVITY PESTICIDE EVALUATION REPORT AND SAFER USE ACTION PLAN August 2018 This publication was produced for review by the United States Agency for international Development. Prepared by Maccheek Consultancy Services on Behalf of Syngenta Foundation for Sustainable Agriculture Schwarzwaldallee 215 CH-4058 Basel Switzerland Tel: +41 61 323 5634 Fax: +41 61 323 7200 www.syngentafoundation.org

PARTNERSHIPS FOR AFR ICA SEED TECHNOLOGY …tracking id: # bfs-18-08-008 1. partnerships for afr ica seed technology transfer activity pesticide evaluation report and safer use action

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Page 1: PARTNERSHIPS FOR AFR ICA SEED TECHNOLOGY …tracking id: # bfs-18-08-008 1. partnerships for afr ica seed technology transfer activity pesticide evaluation report and safer use action

TRACKING ID: # BFS-18-08-008

1

PARTNERSHIPS FOR AFRICA SEED TECHNOLOGY TRANSFER ACTIVITY

PESTICIDE EVALUATION REPORT AND SAFER USE ACTION PLAN

August 2018

This publication was produced for review by the United States Agency for international Development.

Prepared by Maccheek Consultancy Services on Behalf of

Syngenta Foundation for Sustainable Agriculture Schwarzwaldallee 215 CH-4058 Basel Switzerland Tel: +41 61 323 5634 Fax: +41 61 323 7200 www.syngentafoundation.org

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PESTICIDES EVALUATION REPORT AND SAFER USE ACTION PLAN FOR PASTTA GDA – AMENDMENT BFS-18-08-008 2

AMENDMENT TO PASTTA PERSUAP (BFS-17-12-002) PROJECT/ACTIVITY DATA

Project/Activity Name: “Building equitable partnerships for technology transfer of in-demand publicly bred in Sub-Saharan Africa” Activity ( or “Partnerships for Africa Seed Technology Transfer Activity - PASTTA)

Amendment (Y/N): Y Uganda amendment Geographic Location(s) (Country/Region): Africa (Senegal, Mali, Malawi, Kenya, Uganda) Implementation Start/End: 30 Sept 2017-29 Sept 2020 (3 years) Solicitation/Contract/Award Number: AID-OAA-A-17-00030 Implementing Partner(s): Syngenta Foundation for Sustainable Agriculture Tracking ID : BFS-18-08-008 Tracking ID of PERSUAP original IEE: BFS-17-12-002 / BFS-17-03-003

ORGANIZATIONAL/ADMINISTRATIVE DATA

Implementing Operating Unit: BFS/MPI Funding Operating Unit: BFS/MPI Funding Account(s): AID-OAA-A-17-00030 Funding Amount: $2,162,116.20 Other Affected Unit(s): USAID Mission Uganda Lead BEO Bureau: BFS Prepared by: Mark Huisenga (Oliver Macdonald) Date Prepared: 8/2/2018

ENVIRONMENTAL COMPLIANCE REVIEW DATA

Analysis Type: Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP), §216.3(b)

Environmental Determination(s): Negative Determination with Conditions / PERSUAP

EXECUTIVE SUMMARY - UGANDA SUPPLEMENT This is a supplement to the PERSUAP for the Partnership for Africa Seed Technology Transfer Activity (PASTTA) to add information for Uganda. The original PERSUAP for this project covered Kenya, Malawi, Mali and Senegal. A program of work in Uganda has since been added to the project. This document details the additional areas of the PERSUAP specific to Uganda.

PROHIBITED MATERIALS ANALYSIS (PMA) The following active substances and products that were proposed for use within the PASTTA GDA have been identified as not meeting USAID requirements and products containing them must therefore not be used within the PASTTA GDA. Additionally, farmers receiving seed but who are not part of the project should be discouraged from using them;

• Aclonifen (one of the AS in Lagon & Merlin Combi 575 SCS)

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• Carbendazim (AS in Rodazim, Pilarstin & Milstin)

• Dichlorvos (AS in Lava)

• Flubendiamide (one of the AS in Movento Total & Tihan 17500)

• Lufenuron (AS in Match 50EC and Proclaim Fit UV 45 WG) e Propineb (AS in Commander)

IMPLEMENTATION In accordance with 22CFR216 and Agency policy, the conditions and requirements of this document become mandatory upon approval in addition to all conditions of the original PERSUAP (BFS-17-12-002) and IEE (BFS-17-03-003).

App roval:

Clearance:

Concurrence: William Thomas BFS Bureau Environmental Officer

~/ 10/ 1q ' Date

8)tb//~ Date

·~ /"t6/ZotS Date / l

PESTICIDES EVALUATION REPORT AND SAFER USE ACTION PLAN FOR PASTT A GDA - AMENDMENT BFS-18-08-008 3

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PESTICIDES EVALUATION REPORT AND SAFER USE ACTION PLAN FOR PASTTA GDA – AMENDMENT BFS-18-08-008 4

Pesticide Evaluation Review And Safe Use Action Plan (PERSUAP)

BACKGROUND This is an update of the original PERSUAP produced for the PASTTA GDA to add information on pesticides and their use within the project in Uganda.

Table 1; Partners in the PASSTA GDA operating in Uganda

Organization Role Country AATF (African Agricultural Technology Foundation)

AATF as a sub-awardee is the Implementing partner in Malawi and Uganda | SFSA is providing an additional 3-year grant to AATF1 for

the purpose of funding Seeds2B activities in Malawi and Uganda, and is intended as leverage as part of SFSA’s contribution to this

GDA.

Malawi, Uganda

New Markets Lab

New Markets Lab is an experienced team of lawyers responsible for the “Marketing consent advice” project activity

Feedback to regional bodies at sub-regional project events (annual) Development of a manual for seed companies to navigate regional

registration processes.

All countries

Nestlé

Provide information on processing quality specifications to support the selection of varieties for further field testing. If promising

varieties are identified, Nestle may test small samples of grain to assess how well these varieties meet Nestlé’s processing quality

specifications. Part of Nestlé’s strategy is to source locally high-quality products.

All countries

Qualibasic Seed Company

Support the proposed GDA partner seed companies in accessing EGS for the target range of crops, including beyond the life of the

project on a commercial basis.

COUNTRY BACKGROUND

Uganda Most of Uganda forms part of the interior plateau of the African continent. It is characterized by flat-topped hills in the central, western and eastern parts of the country. The rise of the plateau in the eastern and western parts of the country is represented by mountainous topography found along the borders. These include the Block Mountains of the Rwenzori and the Mufumbira volcanoes in the West; and Mt. Elgon, Mt. Moroto, Mt. Morungole, Mt. Timu and Mt. Kadam in the East.

Uganda’s climate is heavily shaped by its own topography and that of surrounding regions. High mountains along some of its margins, an elevated plateau and lakes, including Victoria the biggest lake in Africa, exert a strong influence. The expanse of elevated terrain results in a more moderate climate than otherwise would be expected by the country's equatorial location.

A modified equatorial climate characterized by consistently high temperatures and humidity as well as substantial annual rainfall defines much of the Victoria shore and central Uganda as well as the southwestern highlands. Northern Uganda has drier, more seasonal climates culminating in the hot, semi-arid country of the northeast. In general, the high plateau trends from tropical-savanna to temperate climates with increasing elevation. Uganda experiences moderate

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PESTICIDES EVALUATION REPORT AND SAFER USE ACTION PLAN FOR PASTTA GDA – AMENDMENT BFS-18-08-008 5

temperatures throughout the year because of its location astride the equator and on a raised African plateau. Because of its equatorial position, high rainfall, and numerous lakes, the relative humidity is high in most parts of the country throughout the year especially in the southern and central parts of Uganda. In general, most parts of the country experience fairly well marked rainy and dry seasons.

Rainfall varies over the country’s regions. The districts located within the Lake Victoria Basin, the eastern and the north-western parts of the country receive the most rainfall. Karamoja rainfall averages less than 800 millimeters per year. The rainfall peaks in May and July while the driest months are December and January. The dry months are characterized by extensive burning of the dominantly shrub vegetation. In the western region the mean annual rainfall is between 875-1000 mm. However, on the higher plateaus of the region, the rainfall is over 1250 mm.

Although decreasing, agriculture is still the main stay of the Ugandan economy contributing about 23.9 % of the total GDP in 2013. Over 80% of the population in Uganda depends on subsistence agriculture for their livelihoods. The high rate of population growth puts pressure on the natural resources, including arable land, which in turn drives up the poverty rate and threatens future gains in agricultural production and food security. This is compounded by land fragmentation and shrinking per capita access to arable land. Demographic pressure affects the environment and compounds the impacts of climate change, especially in the northern, more arid and less developed regions, which have the highest fertility rates in the country.

Uganda's main food crops have been plantains, cassava, sweet potatoes, millet, sorghum, corn, beans, and groundnuts. The major cash crop is coffee. Sugar production has also been increasing in recent years. Historically, cotton, tea, and tobacco were also important but production collapsed in the 1970’s and 80’s.

CROP / PEST INFORMATION The PASTTA GDA intends to target seed production of the following crops. This list is not intended to be exclusive and is likely to be expanded with time.

Table 2; Target crops for PASTTA in Uganda

Beans (bush and climbing)

Soybean

Groundnut

Pigeon pea

Potato

Cassava

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PESTICIDES EVALUATION REPORT AND SAFER USE ACTION PLAN FOR PASTTA GDA – AMENDMENT BFS-18-08-008 6

PESTICIDE EVALUATION REPORT (PER) PESTICIDES REQUIRING SPECIAL CONSIDERATION The following active ingredients are used in pesticide products that are only authorized as Restricted Use Products in the USA. Such products “have the potential to cause unreasonable adverse effects to the environment and injury to applicators or bystanders without added restrictions”. The RUP classification restricts a product, or its uses, to use by a certified applicator or someone under the certified applicator's direct supervision. The use of such products within the project must therefore receive special consideration to ensure that, if used, suitable environmental and/or user protection is in place. The following table lists the active substances and example products for which special consideration is required and the nature of the hazard they present. Products containing these active substances should only be used following the completion of a suitable written risk assessment addressing the relevant concerns. It is advised that products that are classified as RUP’s due to concerns of human toxicity are only used within the project when no effective alternative products are available.

Table 3; Restricted Use Pesticides approved for use in the PASTTA GDA only after completion of further risk assessment

Active Ingredient

Example products in Uganda

Reason for restricted use classification

Comments

Abamectin Dynamec Toxicity to Fish,

Mammals and Aquatic organisms

Special consideration of protection of water bodies and avoidance of

drift is required

Cypermethrin Umethrin

Twiga Cyper Toxicity to Fish and

Aquatic invertebrates Special consideration of protection

of water bodies is required

Chlorpyrifos Dursban Human toxicity

The current US chlorpyrifos labels require workers using

chlorpyrifos to wear additional personal protective equipment

(chemical resistant gloves, coveralls, respirators), and restricting entry into treated fields for 24 hours up to five

days

Emamectin Benzoate

Proclaim Fit UV045 WG

Toxicity to Fish, Mammals and Aquatic

organisms

Special consideration of protection of water bodies and avoidance of

drift is required

Lambda-cyhalothrin

Lambdex 315 EC Twiga Lace 100EC

Toxicity to Fish and Aquatic invertebrates

Special consideration of protection of water bodies is required

Permethrin Actelic Super 1.9EC

Toxicity to Fish and Aquatic invertebrates

Special consideration of protection of water bodies is required

Profenofos Cypercal P720 Human toxicity

Mixing and loading should use closed systems. Applicators require a high level of PPE that should itself

be handled with care after use

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PESTICIDES EVALUATION REPORT AND SAFER USE ACTION PLAN FOR PASTTA GDA

7

Table 4; Summary of Pesticides Approved for PASTTA GDA

Example Trade name

(Active Ingredient)

US Equivalent product (AI)

EPA Registration Number

Toxicity Class (EPA/WHO signal word) GUP/RUP

Crops on US label † Pre-Harvest Interval

Environmental Toxicity Issues

Seed treatments

Gaucho Imaxi

(Imidacloprid)

Gaucho 600 Flowable (Imidacloprid)

100-941

Caution WHO II

GUP

Canola, Rapeseed, Mustard seed (Not for human consumption), Flax, Crambe, Borage,

Safflower, Sunflower N/A Highly toxic to birds and

aquatic invertebrates.

Apron Star (Thiamethoxam +

Mefenoxam + Difenoconazole)

Cruiser 5 FS (Thiamethoxam)

100-941

Caution WHO III

GUP

Cereals grains, Cotton, Cucurbits, Legumes, Soybeans, Peanuts, Potatoes,

Sugarbeet, Sunflower N/A

Toxic to wildlife, highly toxic to aquatic

invertebrates, highly toxic to bees

Apron XL (Mefenoxam) 100-799

Warning, Eye irritant GUP

Leafy Brassica vegetables, Bulb vegetables, Carrots, Cereals Grains,

Cotton, Cucurbits, Forage grass, Forage legumes, Fruiting veg, Globe artichoke, Leafy veg, Legume veg, Millet, Peanut,

Rapeseed crop (subgroup 20A), Root and tuber veg (except potato), Sorghum,

Soybean, Sunflower, Turfgrass

N/A

Do not apply to water or areas where surface

water is present Groundwater advisory Surface water advisory

Difenoconazole technical (see note 1)

100-739

Caution WHO II

GUP Cereals, Cotton, Sweetcorn, Canola N/A

Toxic to fish, mammals, and aquatic invertebrates Do not apply to water

Calthio I 350 FS Fox 45 WS

Movento Plus (Imidacloprid +

Thiram)

Sativa IMT MAX (Imidacloprid, Thiram,

Metalaxyl, Tebuconazole)

Caution WHO II

GUP Barley, Wheat N/A Highly toxic to birds and

aquatic invertebrates

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PESTICIDES EVALUATION REPORT AND SAFER USE ACTION PLAN FOR PASTTA GDA – AMENDMENT BFS-18-08-008 8

Example Trade name

(Active Ingredient)

US Equivalent product (AI)

EPA Registration Number

Toxicity Class (EPA/WHO signal word) GUP/RUP

Crops on US label † Pre-Harvest Interval

Environmental Toxicity Issues

Foliar treatments (Insecticides)

Nimbecidine (Azadirachtin) Artisinal neem

extracts

Azatil-XL (Azadirachtin) 70051-27

Debug Optimo (Neem oil) 70310-7

Caution GUP

All crops None Hazardous to fish and aquatic invertebrates

Pyneem 20EC (Azadirachtin +

Pyrethrins)

Azera / MGK-2905 (Azardiachtin +

Pyrethrins) 1021-1872

Warning GUP

All Outdoor and Glasshouse Crops, including residential gardens None

Toxic to aquatic organisms.

Highly toxic to bees.

Voliam Targo 063 SC (Chlorantraniliprole +

Abamectin)

Voliam Express (Lambda-cyhalothrin +

Chlorantrailiprole) 100-1320

(Voliam

Targo = W

HO

II)

Warning RUP

Alfalfa, Brassica veg, Corn, Cotton, Cucurbit veg, Fruiting veg, Grass

(forage, fodder & hay), Legume veg, Lettuce, Pome fruit, Stone fruit, Sugarcane, Tobacco, Tree nuts, Tuberous and Corm

veg

1-40 days depending on crop

Extremely toxic to fish and aquatic organisms and toxic to wildlife

DuPont Coragen (Chlorantraniliprole)

352-729

None GUP

Brassica leafy veg (inc. broccoli), Cotton, Cucurbit veg, Fruiting veg, Leafy veg,

Potato

1-21 days depending on crop

Toxic to aquatic invertebrates, oysters

and shrimp. Surface water advisory

Agri-Mek 0.15EC (Abamectin)

100-898

Warning RUP

Apples, Avocados, Celeriac, Cotton, Cucurbit veg, Dry beans, Fruiting veg,

Grapes, Herbs, Leafy veg, Mint, Bulb Onion, Pears, Stone fruit, Strawberries, Tree nuts, Tuberous and Corm veg

7-30 days depending on crop

Toxic to fish and wildlife

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PESTICIDES EVALUATION REPORT AND SAFER USE ACTION PLAN FOR PASTTA GDA – AMENDMENT BFS-18-08-008 9

Example Trade name

(Active Ingredient)

US Equivalent product (AI)

EPA Registration Number

Toxicity Class (EPA/WHO signal word) GUP/RUP

Crops on US label † Pre-Harvest Interval

Environmental Toxicity Issues

Dynamec 1.8 EC Abamectin 1.8 EC

Vertimec 18EC Bomec 18EC

Acarius (Abamectin)

-----”----- -----”----- -----”----- ----”---- -----”-----

Attakan C344 SE (Cypermethrin +

Imidacloprid)

Up-Cyde 2.5 (Cypermethrin)

70506-20

Warning WHO II

RUP

Cotton, Broccoli, Cauliflower, Cabbage, Mustard greens, Broccoli raab, Head lettuce,

Garlic, Onions, Pecans

Gaucho 550SC / Admire Pro

(Imidacloprid) 264-827

Caution WHO II

GUP

Cotton, Peanut, Potato, Soybean, Tobacco, Cucurbit veg, Bulb veg, Fruiting veg, Globe artichoke, Herbs, Leafy Brassica

veg, Leafy green veg, Leafy petiole veg, Legume veg, Root tuberous and corm

veg, Strawberry, Banana, Bushberry, Caneberry, Citrus, Coffee, Cranberry, Grape, Hops, Pome Fruit, Pomegranate, Stone fruit, Tree nuts, Tropical fruit

Highly toxic to Bees

(application restrictions apply)

Dursban (Chlorpyrifos)

Lorsban (Chlorpyrifos)

62719-591

Warning Who II RUP 5

Alfalfa, Apple (trunk only), Asparagus, Leafy Brassica veg, Turnip Rutabaga, Citrus fruit,

Corn, Cotton, Cranberry, Fig, Grape, Legume veg, Onion, Peanut, Pear,

Peppermint & Spearmint, Sorghum, Soybean, Strawberry, Sugarbeet, Sunflower, Sweet

potato, Tobacco, Tree nuts, Turf, Wheat

Toxic to fish, aquatic invertebrates, small mammals and birds

Lambdex Super (Chlorpyrifos +

Lambda-cyhalothrin)

Cobalt Advanced (Chlorpyrifos + Lambda-

cyhalothrin) 62719-615

Warning Who II RUP

Alfalfa, Apple (trunk only), Brussels sprout, Ornamental trees, Corn, Cotton, Sorghum,

Soybean, Sunflower, Tree fruits (dormant), Tree nuts, Wheat

Toxic to fish, aquatic invertebrates, small mammals and birds

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PESTICIDES EVALUATION REPORT AND SAFER USE ACTION PLAN FOR PASTTA GDA – AMENDMENT BFS-18-08-008 10

Example Trade name

(Active Ingredient)

US Equivalent product (AI)

EPA Registration Number

Toxicity Class (EPA/WHO signal word) GUP/RUP

Crops on US label † Pre-Harvest Interval

Environmental Toxicity Issues

Decis 25 EC (Deltamethrin)

Decis 1.5 EC (Deltamethrin)

264-1011

Danger Poison WHO II

RUP

Bulb veg, Cucurbit veg, Fruiting veg, Root veg, Tuberous & corm veg, Pome fruit, Tree nuts,

Canola, Cotton, Corn (field, sweet, pop) Soybeans, sorghum, sunflowers

1-21 days depending on crop

Dimethoate 400 EC Agrithoate 40 EC

Tafgor 40EC (Dimethoate)

Dimethoate 4E (Dimethoate)

279-3541

Warning WHO II

GUP

Pears, Cherries, Citrus, Pecans, Asparagus, Beans, Brussels sprouts, Celery, leaf lettuce, kale, turnip greens, mustard greens, Swiss

chard, Endive, Lentils, Melons, Peas, Peppers, Potatoes, Tomatoes, Alfalfa, Field corn,

cotton, Safflower, Sorghum, Soybeans, Wheat

0-28 days depending on crop

Toxic to wildlife and aquatic invertebrates. Highly toxic to bees.

Mamectin 5%WG (Emamectin benzoate)

Proclaim (Emamectin benzoate)

100-904

Danger WHO II

RUP Brassica veg, Leafy veg, Pome fruit

7-14 days depending on crop

Acutely toxic to fish and wildlife

Pygar (Garlic oil + Pyrethrum)

Aphid-Pruf (Garlic Extract)

44688-1 Caution

Cotton, Sorghum, Wheat, Alfalfa, Soybeans, Peas, Sunflowers, Watermelon, Cantaloupe, Pecan trees, Honey locust trees, Oak trees,

Ornamental plants

None

Biogard Concentrate (Pyrethrins) 82074-12

Caution GUP

All crops

Thunder OD 145 (Imidacloprid + Beta-

cyfluthrin)

Leverage 360 (Imidacloprid + Beta-

cyfluthrin) 264-1104

Caution WHO II

RUP

Bulb veg, Leafy petiole veg, Legume veg, Cucurbit veg, Bushberries &

Caneberries. Herbs, Root veg, Tropical fruit

0-14 days depending on crop

Extremely toxic to fish and aquatic invertebrates

Highly toxic to Bees (application restrictions

apply)

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PESTICIDES EVALUATION REPORT AND SAFER USE ACTION PLAN FOR PASTTA GDA – AMENDMENT BFS-18-08-008 11

Example Trade name

(Active Ingredient)

US Equivalent product (AI)

EPA Registration Number

Toxicity Class (EPA/WHO signal word) GUP/RUP

Crops on US label † Pre-Harvest Interval

Environmental Toxicity Issues

Jackpot 50EC Mambda 50EC

(Lambda-cyhalothrin)

Karate EC-W (Lambda-cyhalothrin) 100-1086

Warning WHO II

RUP

Alfalfa, Canola, Cereal Grains, Cole Crops, Cotton, Cucurbit veg, Fruiting veg, Grass

(forage, fodder & hay), Legume veg, Lettuce, Onion, Peanuts, Pome fruit, Stone fruit, Sugarcane, Sunflower, Tobacco, Tree

nuts, Tuberous and corm veg, Coniferous and deciduous trees, Non

crop land (excel. Public land)

1-45 days depending on crop

Restricted Use due to Toxicity to fish

Twiga Lace 100EC (Lambda-cyhalothrin +

acetamiprid)

Assail 70 WP (Acetamiprid)

8033-23

Caution GUP

Asparagus, Bush & cane berries, Citrus, Clover, Cotton, Cucurbits, Legume veg, Fruiting veg, Grapes & other vine small fruit, Head & stem brassicas veg, Leafy brassica veg, Leafy veg, Bulb veg, Pome

fruit, Strawberries and other low growing berries, Sweetcorn, Tobacco, Tree

nuts, Tuberous and corm veg

0-30 days depending on crop

Toxic to birds and aquatic invertebrates

Rimon 100 EC (Novaluron)

Rimon 0.83EC (Novaluron)

6222-35

Warning WHO U

GUP

Avocado, Beans, Berries, Carrot, Cotton, Cucurbit veg, Fruiting veg, Head 7 Stem

brassica veg, Leafy brassica greens, Ornamentals, Peanuts, Pome Fruit,

Potatoes, Sweet potatoes, Sorghum, Soybeans, Stone fruits, Strawberry, Sweet corn,

Sugarcane,

1-30 days depending on crop

Toxic to freshwater and marine/estuarine

invertebrates

Agrillic Super (Pirimiphos-methyl +

Permethrin)

Actellic 5E (Pirimiphos-methyl)

1381-170

Danger WHO II

GUP Storage us on Corn and Sorghum N/A

Permethrin has numerous registrations

Warning WHO II

GUP/RUP depending on use

Many uses on crops, structures and as topical applications to animals

depending on product N/A

Extremely toxic to aquatic organisms, including fish and

invertebrates

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Example Trade name

(Active Ingredient)

US Equivalent product (AI)

EPA Registration Number

Toxicity Class (EPA/WHO signal word) GUP/RUP

Crops on US label † Pre-Harvest Interval

Environmental Toxicity Issues

Actara 25 WG Cruiser 350 FL

(Thiamethoxam)

Actara (Thiamethoxam) 100-938

None WHO III

GUP

Barley, Berry and small fruit, Brassicas, Citrus, Cucurbits, Fruiting veg, Globe artichoke, Leafy veg, Pome Fruit, Root

veg (Except sugar beet), Stone fruit, Tropical Fruit, Tuberous and Corm veg

0-14 days depending on crop

Toxic to wildlife, highly toxic to aquatic

invertebrates, highly toxic to bees

Engeo 247 SC (Thiamethoxam +

lambda-cyhalothrin)

Endigo ZC (Thiamethoxam +

Lambda-cyhalothrin) 100-1276

Warning WHO II

RUP

Barley, Head & Stem brassica, Cotton, Cucurbit veg, Fruiting veg, Lettuce, Pome fruit, Soybean, Stone fruit, Tobacco, Tree

nuts, Tuberous and corm veg

1-40 days depending on crop

Extremely toxic to fish and aquatic organisms and toxic to wildlife.

Calfos 500 EC (Profenofos)

Curacon 8E (Profenofos)

100-669

Caution WHO II RUP 5

Cotton

Biological agents

Batik WG (Bacillus thuringiensis

subsp kurstaki)

Thuricide 3 (Bacillus thuringiensis subsp kurstaki strain

SA12) 4-226

Caution GUP

Tree fruit, Stone fruit, Pome fruit, Headed and leafy brassicas, Beans, Beets,

Carrots, Celery, Chard, Chinese cabbage, Endive, Escarole, Garlic, Lentils, Lettuce, Onions, Parsley, Radish, Spinach, Squash,

Cucumbers, Melons, Watermelon, Potato, Caneberries, Blueberries, Strawberries,

Mint, Oranges, Fruiting veg,

None

Kinymet (Metarhizium

anisopliae)

Tick-Ex EC Bioinsecticide

(Metarhizium anisopliae strain 52) 70127-10

Caution GUP

Cucurbits, Onions, Celery, Lettuce, Spinach, Peppers, Tomatoes, Grape, Strawberry,

Cranberry, Raspberry, Blackberry, Potatoes, Ornamental plants, Turf

None

Kinybeau (Beauveria bassiana Bb

5a)

Naturalis L (Beauveria bassiana

ATCC 74040) 53871-9

Caution WHO: Not acute

hazard GUP

Alfalfa, Cereals, Berry and small fruit,, Canola, Citrus fruit, Corn, Cotton, Hops, Pasture land, Peanuts, Pineapple, Safflower,

Sunflower, Tobacco, Bulb veg, Cucurbits,

None

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Example Trade name

(Active Ingredient)

US Equivalent product (AI)

EPA Registration Number

Toxicity Class (EPA/WHO signal word) GUP/RUP

Crops on US label † Pre-Harvest Interval

Environmental Toxicity Issues

Mycotrol ES (Beauveria bassiana

GHA) 82074-1 Bioceres

Fruiting Veg, Leafy and Cole crops. Legume veg, Root and Tuber veg,

Herbs, spices and mint, Pome fruit, Stone fruit, Tree nuts, Avocado, Tropical

fruits, Ornamentals, Lawns and turfgrasses, Greenhouse, shadehouse

and hydroponic cultivation, (Beauveria bassiana strain

ANT-03) 89600-1

Kinyderma (Trichoderma viridi)

No current products (Trichoderma viride)

Pesticide Docket EPA-HQ-OPP-2006-0245

None specified but product is applied to soil or seedlings where Trichoderma sp. are

naturally present. There assumed safe for all crops.

Foliar treatments (Fungicides)

Quadris 50WG (Azoxystrobin)

Abound Flowable Fungicide /

Ortiva 250 SC (Azoxystrobin)

100-1098

Caution WHO III

GUP

Almonds, Artichoke globe, Asparagus, Bananas, Berries, Brassica head & stem, Brassica leafy greens, Bulb veg, Canola,

Carrots, Celery, Cereals, Citrus fruit, Clover, Corn, Cotton, Cucurbits, Fruiting veg, Grapes & other vine fruit, Grasses, Herbs and Spices, Leafy veg, Legume

veg, Mint, Non grass animal feeds, Oilseed crops, Peanuts, Pistachios, Potatoes, Quinoa, Rice, Sorghum, Soybeans, Sugarcane, Tobacco, Vegetables, Leaves of Root and

Tuber Group and Root Subgroup, Stone fruit, Ti Palm, Tree nuts, Tropical fruit, Tuberous and Corm veg, Watercress

0-45 days depending on crop

(Asparagus 100 days)

Toxic to freshwater and estuarine/marine fish and

aquatic invertebrates Ground water and

Surface water advisories

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Example Trade name

(Active Ingredient)

US Equivalent product (AI)

EPA Registration Number

Toxicity Class (EPA/WHO signal word) GUP/RUP

Crops on US label † Pre-Harvest Interval

Environmental Toxicity Issues

Copper oxychloride, Copper hydroxide or

Cuprous oxide (multiple formulations)

Badge SC (Copper oxychloride)

Kocide 80289-3

(Copper hydroxide) 91411-3

(multiple other products)

Caution WHO II

GUP

Citrus Fruit, Alfalfa, Barley, Clover, Corn, Oats, Peanut, Potato, Soybean, Sugar Beet,

Sugarcane, Wheat, Small fruits, Tree crops, Vegetables, Grape, Hops and Kiwi.

0 days

Toxic to fish and aquatic invertebrates and may

contaminate water through runoff

Score 250EC (Difenoconazole)

Inspire (Difenoconazole)

100-1262

Warning WHO III

GUP

Globe artichoke, Bean and Pea (dried shelled), Berry (bush, low growing ), Leafy brassica veg, Bulb veg, Carrots,

Chickpea, Citrus fruit, Cotton, Cucurbit veg, Fruiting veg, Ginseng Grapes, Pome

fruit, Potatoes, Rapeseed, Rice, Soybean, Stone fruit, Sugar beets, Treenuts

0-45 days depending on crop

Toxic to fish, mammals, and aquatic invertebrates

Velum Prime (Fluopyram)

Velum Prime / Lune Privilege

(Fluopyram) 264-10787

Caution GUP

Artichoke (Globe), Brassica leafy veg, Bulb veg, Carrot; Cereals (except rice), Citrus, Corn, (field, grain, pop), Cotton, Cucurbits, Dill seed, Fruiting veg, Ginseng; Grapes and small vines, Herbs, Hops, Leafy veg, Legume veg, Peanut; Pome fruit, Potato and other

root, tuberous and corm veg, Rapeseed, Small Berries (caneberries and bushberries),

Soybean, Stone Fruits, Strawberry and other low-growing berries, Sugarbeet, Sunflower,

Sweet Corn; Tobacco, Tree Nuts

0-30 days depending on crop

-

Folpan 50WP (Folpet)

Folpan 80WG (Folpet)

66222-48

Warning WHO U

GUP Avocado, Hops 7 / 14 days Highly toxic to fish and

aquatic invertebrates

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Example Trade name

(Active Ingredient)

US Equivalent product (AI)

EPA Registration Number

Toxicity Class (EPA/WHO signal word) GUP/RUP

Crops on US label † Pre-Harvest Interval

Environmental Toxicity Issues

Revus 250SC (Mandipropamid)

Revus (Mandipropamid)

100-1254

WHO III GUP

Basil, Bean (snap), Brassicas, Bulb veg, Citrus (non bearing), Cucurbits, Ginseng,

Grapes, Hops, Leafy veg, Fruiting veg, Tobacco

1-14 days depending on crop

None

Unizeb 80WP Sancozeb 80WP

(Mancozeb)

Dithane M45 (Mancozeb)

892-286

WHO U GUP

Corn, Cucumber, Melon, Tomatoes, Watermelons

(Many other crops approved for other formulations)

5-7 days depending on crop

Toxic to aquatic organisms

Ridomil Gold 68 WG (Metalaxyl-M +

Mancozeb)

Ridomil Gold MZ WG (Mefenoxam2 +

Mancozeb) 100-1269

Caution WHO III

GUP

Cucumber, Cantaloupe, Casaba, Crenshaw, Honeydew, Melon, Watermelon, Summer Squash, Grapes, Onion, Shallots, Garlic,

Potatoes, Sugar beets, Tomatoes

3-14 days (Grapes 66

days)

Toxic to aquatic organisms

Unilax 72WP Mancolax 72WP

Ridomil 4 (Metalaxyl + Mancozeb)

UPL Metalaxyl Technical1

(Metalaxyl) 91813-8

Warning WHO III

GUP

Alfalfa, Birdfoot Trefoil, Apples, Asparagus, Avocados, Berries (Blueberries, Cranberries, Grapes, Raspberries, Strawberries), Citrus Fruit, Brassica (Cole) Leafy Veg, Cotton,

Cucurbit vegetables, Hops, Leafy Veg except Brassica, Legume Veg (Succulent or dried) ,

Onions, Nut trees (Almond and Walnut only), Papaya, Peanuts, Fruiting Veg, Pineapple, Root

and Tuber Veg, Stone Fruit, Tobacco.

None specified

Orius 25EC (Tebuconazole)

Orius 3.6F (Tebuconazole)

66222-117

Caution WHO II

GUP

Asparagus, Beans, Cucurbit Veg, Onion, Leek, Spring Onion, Garden Beet, Leafy Brassica Greens, Okra, Turnip, Barley, Corn, Cotton, Grasses Grown for Seed,

Peanuts, Soybeans, Sunflower, Wheat Lychee, Pecan.

3-30 days depending on crop

Toxic to mammals, fish and aquatic invertebrates

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Example Trade name

(Active Ingredient)

US Equivalent product (AI)

EPA Registration Number

Toxicity Class (EPA/WHO signal word) GUP/RUP

Crops on US label † Pre-Harvest Interval

Environmental Toxicity Issues

Herbicides

2,4-D Amine Herbix Plus 720 SL

Amanora 720SL (2,4-D amine)

Nufarm 2,4-D Acid (2,4-D) 61272-3

Danger (Corrosive)

WHO II GUP

Corn, Cereals, Soybeans (preplanting), Sugarcane, Grassland, Asparagus,

Blueberries, Cranberries, Grapes, Hops, Orchards, Potatoes, Strawberreis

7-45 days depending on crop

Toxic to fish and aquatic invertebrates

Round up 360 SL Round Up Turbo 450

SL (Glyphosate)

Touchdown (Glyphosate)

100-1212

Caution WHO III

GUP

Alfalfa, Clover, and Other Legumes, Berries, Fruits, Nuts, and Vines, Canola, Corn, Cotton, Fallowland and Postharvest, Grasses and Grass

Seed Production, Herbs, Pastures, Small Grains, Sorghum, Soybeans, Sunflower,

Vegetables

1-30 days depending on crop

Sencor 480 EC Metribuzin 70 WDG /

Metrixx

Caution WHO II

GUP

Alfalfa, Sainfoin, Asparagus, Carrots, Cereals, Corn, Chickpeas, Lentils, Peas, Soybeans,

Sugarcane, Potatoes, Tomatoes

7-75 days depending on crop

Groundwater advisory

Stomp CS Fist 33EC

(Pendimethalin)

Prowl (Pendimethalin)

241-337

Caution WHO III

GUP

Alfalfa (forage, hay or seed Production), Bearing Citrus Fruit Trees, Bearing Nut

Trees, Bearing Pome Fruit Trees, Bearing Stone Fruit Trees, Carrots, Corn (field, pop, seed, sweet), Cotton, Edible Beans,

Forage Legumes, Fruiting Vegetables (Pepper, Tomato), Garlic, Grain Sorghum,

Leek, Lentils & Peas, Mint, Nonbearing Fruit Tree & Nut Tree Crops, Nonbearing

Vineyards, Onions & Shallots (dry bulb, green), Peanuts, Potatoes, Rice, Soybeans, Strawberry,

Sugarcane, Sunflowers, Tobacco, Wheat.

1-120 days depending

on crop and use

Toxic to fish

Authority 48%SC (Sulfentrazone)

Authority (Sulfentrazone)

279-3146 (& 3148/3149/ 3175/3179)

Caution GUP

Soybeans

Toxic to marine/estaurine

invertebrates Groundwater advisory Surface water advisory

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† Crops in bold refer to crop groups, see label for details of specific crops. Not including ornamental crops. 1 product is intended for the formulation of crop protection products 2 Metalaxyl-M is a synonym of Mefenoxam 3 Example product, there are several different strains of Bacillus thuringiensis registered in the US. The specific strain in Batik WG is not identified. 4 Ridomil is no longer available but a range of similar generic products are. Ridomil differs from Ridomil Gold in containing Metalaxyl instead of the optically

pure stereo-isomer, Metalaxyl-m. 5 These are RUPs due to Human Toxicity concerns. They should therefore only be used when no effective alternatives are available and if suitable PPE is

available

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SAFE USE ACTION PLAN (SUAP)

Project Title: PARTNERSHIPS FOR AFRICA SEED TECHNOLOGY TRANSFER ACTIVITY Pesticide(s): See Table 4 Crops: See Table 2

Required Compliance Mitigation Measures

Compliance Dates Actions to achieve compliance Responsible

Party Status

Capa

city

Bui

ldin

g Identify National PERSUAP Coordinators

28th Feb 2018 For each country appoint a coordinator responsible for ensuring the PERSUAP is implemented nationally

National coordinators

Training of Pesticide Handlers

Before undertaking any pesticide related work

Ensure all staff, including new recruits, have received appropriate training.

National coordinators

Loca

l Iss

ues

Establish Pesticide Quality Standards

30th March 2018

Review existing procedures and update if required

National coordinators

Require Good Packaging and Clear, Adequate

Labeling

30th March 2018

Review existing procedures and update if required

National coordinators

Development and Distribution of Educational

Material

Before trials begin

Ensure all partners and growers are supplied with and understand guidance documents. Translate into French for use in west Africa.

Field staff

Safe

r Pes

ticid

e U

se

Ensure Accessibility of Personal Protective

Equipment

30th March 2018

Review PPE to ensure that all necessary equipment is available and fully functional

National coordinators

Define Appropriate Procedures for Safe Pesticide Transport

30th March 2018

Review existing procedures and update if required

National coordinators

Define Appropriate Methods for Safe Pesticide

Storage

30th March 2018

Review existing procedures and update if required

National coordinators

Define Disposal Provisions for Used

Pesticide Containers

30th March 2018

Review existing procedures and update if required

National coordinators

Long

-Ter

m

Prog

ram

Coordination, Collaboration, Awareness

Raising, Surveillance, Control Management,

Research

Annually in December

Review PERSUAP requirements and implementation

Head of Program

Within the context of the PASTTA GDA pesticides will be used in three areas;

• Field trials managed and run by PASTTA GDA staff with the input of trained agronomists employed by NARS and partners in the PASSTA GDA. All staff are trained in the safe use of pesticides.

• Seed treatments applied by PASTTA GDA staff or contractors and supplied to a range of users, including local farmers.

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• Foliar applications made by elite farmers trialing seeds.

For the first two areas pesticide use will therefore be within the direct control of either PASSTA GDA staff or of qualified contractors all of whom have received adequate training in the safe use and handling of pesticides. Within each trial pesticides will be selected by trained agronomists in response to known pest risks or identified pest presence and within an IPM system.

Elite farmers trialing seed will be monitored by PASSTA GDA staff. They will all be required to successfully complete a pesticide induction course before taking part in the program. PASTTA GDA staff supervising trials will ensure that appropriate application equipment and PPE is available and properly maintained, that only pesticides approved for use within the project are applied and that all pesticide use is recorded. Where necessary, additional training and equipment will be provided to ensure that these requirements are adhered to.

National PASTTA GDA coordinators will ensure the following;

• All staff involved in the use of pesticides have received appropriate training and are competent to follow pesticide labels, and use pesticides safely with relevant awareness of potential adverse effects on human and animal health and the environment.

• Staff are supplied with and use all necessary safety equipment and personal protective equipment.

• That all application equipment and safety equipment is properly maintained and calibrated and records of such maintenance kept.

• That all pesticides use is properly recorded.

• That all pesticide waste is properly disposed of.

All staff will be supplied with a copy of this PERSUAP and their attention drawn to the following annexes.

Annex A; Gives an example of a pesticide data sheet. Filling these out may be useful as a training aid to ensure that staff are fully aware of the requirements of the PERSUAP

Annex B; Monitoring Pests and Pesticide Effects

Annex C; Pesticide use records

Annex D; Elements of an IPM program

Annex G; Guidance documents

Further follow-up trials work with seed companies after the handover of varieties may also be required. However, this will either be provided through SFSA committed follow-on funds (public-bred material) or through chargeable services provided through Seeds2B Africa LLC and is therefore not considered to be within the scope of this SUAP.

FIELD STAFF

Permanent staff employed on the PASTTA GDA in Uganda;

Plans are underway to recruit an agronomist to support the PASTTA Project in Uganda. If all goes according to plan, the successful candidate will assume office by early September 2018.

PROHIBITED MATERIALS ANALYSIS (PMA)

Information and analysis on pesticides which should NOT to be used in project implementation, or other related environmental information.

The following products that were proposed for use in the program have failed the Pesticide Evaluation Report as they contain active substances that are not approved for use in the US by the USEPA. Any other products incorporating the identified active substances are also

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prohibited from use. Note that two of these products contain more than one active substance. These restrictions do not apply to the active substances spirotetramat or isoxaflutole and products containing these actives substances may be permissible.

Table 5; Products that MUST NOT be used in PASTTA GDA program

Product Active substances Countries registered / proposed for use

Comments

Lagon 575 SC / Merlin Combi 575

SC Aclonifen + Isoxaflutole Mali + Senegal

Aclonifen is not US approved. However this

is a very new A.S. therefore recommend keeping under review

Pilarstin 500SC Milstin 50% WP

Rodazim Carbendazim Uganda No approval for foliar

use in the US

Dede/Doom & other dichlorvos

containing products Dichlorvos Uganda No US approval, High

toxicity (WHO 1b)

Proclaim Fit Enamectin Benzoate + Lufenuron Malawi, Uganda

No Agricultural approval of Lufenuron in

US

Movento Total Tihan 175OD

Flubendiamide + Spirotetramat Mali, Senegal + Uganda Flubendiamide is not

EPA approved

Match 50EC Lufenuron Kenya

No Agricultural approval in US (Only

approval is for termite control)

Antracol Commander 70

WP Propineb Mali + Senegal

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ANNEX E; PESTICIDES PROPOSED FOR USE IN THE PASTTA GDA

List of pesticide products proposed for use in field trials in Uganda

Active Ingredient(s)

Example Products Comments

Seed Treatments

Thiamethoxam +, Mefenoxam + Difenoconazole

Apron Star

Imidacloprid Gaucho

Insecticides

Abamectin Dynamec 1.8 EC RUP - Special consideration of protection of water bodies and avoidance of drift is required.

Azadirachtin + Pyrethrins Pyneem

Beauveria bassiana Kinybeau

Chlorpyrifos Dursban RUP - High quality PPE required. Use should be avoided if possible.

Chlorpyrifos + Lambda-cyhalothrin Lambdex Super 315EC RUP - High quality PPE required. Use should be

avoided if possible.

Deltamethrin Decis Toxic to fish, aquatic invertebrates, small mammals and birds.

Dimethoate Agrithoate 40 EC

Tafgor 40EC

Emamectin benzoate Mamectin 5%WG RUP - Special consideration of protection of water bodies and avoidance of drift is required.

Garlic Oil + Pyrethin Pygar 35EC

Imidacloprid + Beta-cyfluthrin Thunder OD 145

Extremely toxic to fish and aquatic invertebrates Highly toxic to Bees (application restrictions apply).

Lambda-cyhalothrin Jackpot 50EC Mambda 50EC

RUP - Special consideration of protection of water bodies is required.

Toxic to fish.

Lambda-cyhalothrin + Acetamiprid Twiga Lace 100EC Toxic to fish.

Metarhizium anisopliae Kinymet

Pirimiphos-methyl + permethrin

Agrillic Super 1.9DP Agro-Dellic Grain

Dust

RUP - Special consideration of protection of water bodies is required.

Only approved for stored products. Extremely toxic to aquatic organisms, including fish and invertebrates.

Thiamethoxam Actara 25WG

Thiamethoxam + Lambda-cyhalothrin Engo 247SC Extremely toxic to fish and aquatic organisms and

toxic to wildlife.

Fungicides

Azoxystrobin Quadris 50 WG

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Active Ingredient(s)

Example Products Comments

Copper oxychloride Cupravit 50WP

Folpet Folpan 50WP

Mancozeb Unizeb 80WP

Sancozeb 80WP

Mancozeb + Metalaxyl Unilax 72WP

Mancolax 72WP Where possible products containing metalaxyl-M

should be used in preference.

Mancozeb + Metalaxyl-M Ridomil Gold 68 WG

Mandipropamid Revus 250 SC

Tebuconazole Orius 25EC

Trichoderma viridae Kinyderma

Nematicide/Fungicide

Fluopyram Velum 500SC

Herbicides

2,4-D 2,4-D Amine

Herbix Plus 720 SL Amanora 720SL

Glyphosate Round up 360 SL

Round Up Turbo 450 SL

Metribuzin Sencor 480SC

Pendimethalin Stomp CS Fist 33EC