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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
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)
• 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
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
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
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
TRACKING ID: # BFS-18-08-008
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
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
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
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)
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
PESTICIDES EVALUATION REPORT AND SAFER USE ACTION PLAN FOR PASTTA GDA – AMENDMENT BFS-18-08-008 12
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
PESTICIDES EVALUATION REPORT AND SAFER USE ACTION PLAN FOR PASTTA GDA – AMENDMENT BFS-18-08-008 13
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
PESTICIDES EVALUATION REPORT AND SAFER USE ACTION PLAN FOR PASTTA GDA – AMENDMENT BFS-18-08-008 14
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
PESTICIDES EVALUATION REPORT AND SAFER USE ACTION PLAN FOR PASTTA GDA – AMENDMENT BFS-18-08-008 15
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
PESTICIDES EVALUATION REPORT AND SAFER USE ACTION PLAN FOR PASTTA GDA – AMENDMENT BFS-18-08-008 16
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
TRACKING ID: # BFS-18-08-008
PESTICIDES EVALUATION REPORT AND SAFER USE ACTION PLAN FOR PASTTA GDA
17
† 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
TRACKING ID: # BFS-18-08-008
PESTICIDES EVALUATION REPORT AND SAFER USE ACTION PLAN FOR PASTTA GDA
18
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.
PESTICIDES EVALUATION REPORT AND SAFER USE ACTION PLAN FOR PASTTA GDA – AMENDMENT BFS-18-08-008 19
• 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
PESTICIDES EVALUATION REPORT AND SAFER USE ACTION PLAN FOR PASTTA GDA – AMENDMENT BFS-18-08-008 20
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
PESTICIDES EVALUATION REPORT AND SAFER USE ACTION PLAN FOR PASTTA GDA – AMENDMENT BFS-18-08-008 21
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
PESTICIDES EVALUATION REPORT AND SAFER USE ACTION PLAN FOR PASTTA GDA – AMENDMENT BFS-18-08-008 22
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