Sustainable Agriculture and Production Linked to Improved ... · USAID DCHA ENVIRONMENT AL THRESHOLD DECISION FOR THE PROJECT SPECIFIC SAFER USE ACTION PLAN (SUAP) Awardee Helen Keller

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Helen Keller INTEl{NATIONAL

Sustainable Agriculture and Production Linked to Improved

Nutrition Status, Resilience and Gender Equity (SAPLING)

SAFER USE ACTION PLAN (SUAP)

Chief of Party Contact Information: Treena Bishop

Chief of Party, SAPLING

Helen Keller International

House 1 OE, Road 82

Gulshan 2, Dhaka 1212 Tel : (088) 02-882-3055 E-mail: tbishop@hki .org

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Country Office Contact Information: Meredith Jackson-deGraffenried

Country Director, Bangladesh

Helen Keller International

House 1 OE, Road 82

Gulshan 2, Dhaka 1212 Tel: (088) 02-882-3055 E-mail: mdegraffenried(a)hki .org

USAID DCHA ENVIRONMENT AL THRESHOLD DECISION FOR THE PROJECT SPECIFIC SAFER USE ACTION PLAN (SUAP)

Awardee Helen Keller International (HKI) OCHA Office Food for Peace Program Title Sustainable Agriculture and Production Linked to Improved

Nutrition Status, Resilience, and Gender Equity (SAPLING) Award Number AID-FFP-A-15-000 I 0 Country/Region Bangladesh/ South Asia Life of Grant September,2015- September 2020 LOP Funding $28,777,000 SUAP prepared by Md. Kamrul Hasan Bhuiyan, Environment Specialist;

SAPLING Project IEE amendment No submission date October 27, 2016

ENVIRONMENTAL ACTION RECOMMENDED:

Categorical Exclusion: X I Negative Determination w/Conditions: X Positive Determination: I Deferral: Bureau Environmental Threshold Decision (ETD): Approval w/ Conditions

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APPROVAL of Pesticides Safer Use Action Plan and Compliance Tracker:

Pesticides Safer Use Action Plan (SUAP) and Compliance Tracker for Sustainable Agriculture and Production Linked to Improved Nutrition, Resilience and Gender Equity (SAPLING) Project

A. Mission Clearances:

Mission Environment Officer (MEO) ~ Date:

B. Concurrence:

OCHA Bureau Environnent Officer (BEO) : __________ Date : ___ _

Approved: ______________ _

Disapproved: _____________ _

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2/13/2017

X

Erika J. Clesceri

Pesticides Safer Use Action Plan & Compliance Tracker1

Implementing Partner: Helen Keller International

Project: Sustainable Agriculture and Production Linked to Improved Nutrition, Resilience

and Gender (SAPLING)

Initial Submission and will annually be updated thereafter

SI Required compliance Initial compliance Actions planned to Status of (mitigation) measure status (if not known, achieve & maintain compliance

indicate) compliance (with actions deadlines & responsible party)

SUPPORT ONLY THE PESTICIDES AUTHORIZED BY THE 2015 USAID/Bangladesh Programmatic PERSUAP

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Immediately Inventory pesticides No Class I chemicals Develop pesticides Underway supported and ensure NO will be used under inventory and review for SUPPORT for Class I SAPLING. Class I chemicals; chemicals. Deadline: January 31,

2017 Res12onsible: Environmental Specialist Review inventory annually (in October). Res12onsible: Environmental Specialist

Ensure that Class I No Class I fumigants Verify annually (in fumigants, as approved will be used under October); in this PERSUAP, can SAPLING. Res12onsible: only be used by, or under Environmental Specialist supervision of, a certified pesticide applicator. Ensure that Restricted No RUPs will be used Review of RUPs Use Pesticides (RUPs), under SAPLING annually (in October); as c lassified by United Res12onsible: States Environmental Environmental Specialist Protection Agency (USEPA), can only be used by, or under supervision of, a certified pesticide applicator. Ensure that veterinary No veterinary Verify annually (in use of pesticides can only pesticides used under October); be provided by trained SAPLING Res12onsible:

1 Completion of the Pesticides Safer Use Action Plan & Compliance Tracker is required under the 2015 USAID

Bangladesh mission-wide Programmatic PERSUAP for all implementing partners who use or recommend pesticides as part of project activities

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veterinary workers Environmental Specialist 5 Distribute copies of the List will be prepared List of PERSUAP- Underway

list of allowed Active and distributed to the allowed pesticides and Ingredients (Als) with project field staff Als used/recommended matching commercial by project will be product names and list of distributed to project cancelled products to all field staff as part of project field extension compliance training; staff. Deadline: January 2017;

Responsible: Environmental Specialist Distribute updated list annually (in January) Responsible: Environmental Specialist

As soon as possible: 6 Assure that USAID- Training materials and Cross-check all Underway

funded pesticide support content currently informational training is limited to ONLY recommend only materials with the PESTICIDES approved pesticides. approved list; APPROVED BY Deadline: January 2017; PERSUAP. Continue Responsible: verification throughout Environment Specialist the life of the project. Verify annually (in

January) Responsible: Environmental Specialist

Pesticide technical assistance and use must be governed by a set of locally adapted IPM-based pest management plans and observe enumerated use restrictions. For agricultural activities these will be crop-and-pest specific.

By 2017

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7 Using information in Currently under Complete !PM-based Underway PERSUAP Annexes A development PMPs; and B, adopt/develop Deadline: March 2017; crop and pest-specific Responsible: Integrated Pest Environment Specialist Management (IPM)- and Manager, Food based pest management Security and Livelihood plans (PMPs). For (FS&L) chemical controls, PMPs must include use restrictions specified in Annex B pesticide profiles. (E.g. no use near surface waters.)

8 Translate PMPs into Will begin after After finalization of IPM-crop-specific field completion of PMPs based PMPs, develop reference guides or initial set of field posters for farmers to reference guides or anticipate and manage posters for farmers; pests. Deadline: June 2017;

Responsible: Environment Specialist and Manager (FS&L)/ Social and Behavior Change Communication (SBCC) specialist

B v 2017 9 Provide first-time PMP under preparation First-time training to be

training to appropriate conducted for project project staff, partners and staff; participants in PMPs; Deadline: during Quarter Provide refresher training 4 of FY 2016 (June to annually. September)

Responsible: Environmental Specialist and Manager (FS&L) Annual refresher Underway training; Deadline: February 2017; Responsible: Environmental Specialist

By 2017

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indicate) compliance (with actions deadlines & responsible oartv)

10 Require and enforce NI A - there are no NIA NIA PMP implementation in situations currently situations where the where the project has project has direct control direct control over over pesticide use. pesticide use

11 Require and enforce that No action taken to date Integrate PMP approach field extension under - awaiting completion into current training direct project control be of PMPs modules and extension PMP based. materials; Deadline:

September 2017; Responsible: Environmental Specialist and Manager (FS&L) Incorporate use of PMPs into Farmer Leader trainings and Farmer Producer Group courtyard sessions as part of training on improved agricultural practices; Deadline: September 2017; Responsible: Environmental Specialist and Manager (FS&L) Implement PMPs for all project demo plots; Deadline: Begin in third quarter of FY 2017 following training and roll-out conducted in second quarter; Responsible: Environmental Specialist assisted by Technical Officer (Horticulture & Marketing)

12 Where project control No action taken to date Promote PMPs as part of over extension or - awaiting completion skill development agricultural practice on of PMPs training provided to the ground is less than project staff and Lead complete, promote and Farmers; support PMPs to the Deadline: Begin in greatest possible extent. Quarter 3 of FY 2017;

Responsible:


indicate) compliance (with actions deadlines & responsible party) Environmental Specialist, Manager (FS&L)

Ongoing over Life of Pro· ect (LOP) 13 Modify PMPs over LOP Action to be taken after Collect feedback from

based on ground- introduction of PMPs field extension agents truthing/Field and modify PMPs experience. accordingly;

Deadline: October 2017; Responsible: Environmental Specialist, M&E manager

For all target activities, appropriate project staff and participants must be trained in safer pesticide use and pesticide first aid. 14 Ensure availability of Training and courtyard Compile product labels Underway

product label and sessions will include and MSDS for all Material Safety Data content and guidance pesticides in project Sheets (MSDS). For all on the review of pesticide inventory; products in use, project product labels Deadline: February 2017; personnel must obtain Responsible: and review the product Environmental Specialist label and MSDS to Introduce use of MSDS ensure that pesticide in trainings and courtyard users are aware of sessions; continue potential hazards and are training on how to read undertaking all measures and interpret product to minimize risks to labels; human health and safety Deadline: Ongoing for and to the environment. the LOP

Responsible: Environmental Specialist and Manager (FS&L)

15 Ensure that, for all Training and courtyard Ensure content on Underway projects that provide sessions will include handling of dressed seed support for procurement content and guidance is updated and included or use, or both of seed on handling of dressed in training materials; treated with pesticides, seeds Deadline: February 2017 training in handling Responsible: dressed seeds is Environmental Specialist

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indicate) compliance (with actions deadlines & responsible partv)

provided. Continue providing training on handling of dressed seeds as part of training and courtyard sessions; Deadline: Ongoing for the LOP Responsible: Environmental Specialist and Manager (FS&L)

16 Ensure that training is NIA- SAPLING is not NIA NIA provided to relevant staff involved with stored of all projects that commodities provide support for treatment of stored commodities.

17 Ensure that training of SAPLING will provide Ensure content on post- Underway trainers (TOT) is TOT for FFs and harvest use of pesticides provided to relevant staff Technical Officers to is updated and included to support participants of create master trainers in training materials; all projects that provide for supporting project Deadline: February 2017 support to farmers in participants (farmers) Responsible: post-harvest use of in post-harvest Environmental Specialist pesticides. management and

courtyard sessions will Provide training on post-include content and harvest use of pesticides guidance on post- as part of training and harvest use of courtyard sessions; pesticides - Deadline: Ongoing for emphasizing the use of the LOP biological pesticides Responsible: like neem leaves and Environmental Specialist nishinda leaves for and Manager (FS&L) grain storage.

18 Ensure that TOT training SAPLING will provide Provide training on using is provided to relevant TOT to FFs and pesticides in fish farming staff to support Technical Officers to as part of training and participants of all create master trainers courtyard sessions projects that provide for supporting fish likewise; ensuring the support to fish farmers farmers (project safe use of rotenone, e.g., using pesticides. participants) on using using personnel

pesticides especially protective equipment use of Rotenone for (PPE) during application, removing predators would be added to the

training manual on Good

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SI Required compliance Initial compliance Actions. planned to Status of (mitigation) measure status (if not known, achieve & maintain compliance

indicate) compliance (with actions deadlines & responsible partv) Aquaculture Practices (GAP). Deadline: Ongoing for the LOP Responsibility: Environment Specialist and Manager (FS&L)

19 Ensure that TOT training SAPLING will provide Provide training on using is provided to relevant TOT training to of disinfectants and staff to support Maternal Child Health pesticides in health participants of all and Nutrition (MCHN) services as part of projects that provide specialists for health training and courtyard support to health service service activities that sessions; activities that use use disinfectants and Deadline: Ongoing for disinfectants and pesticides the LOP pesticides. Responsibility: Manager

(MCHN); Environment Specialist and Technical Advisor of Eye and Tropical Diseases

20 Ensure that if livestock No veterinary Deadline: Verify NIA- no projects introduce pesticides will be used annually; veterinary veterinary pesticide use, under SAPLING Responsible: Technical pesticides they must inform the Officer (animal currently Environmental Officer husbandry) and used for approval Environmental Specialist

21 Develop a Training Plan Training Plan to be Deadline: Update plan on for Pesticide Safe developed as part of a quarterly basis; Practices and IPM for SAPLING Detailed Responsible: project staff and Implementation Plan Environmental Specialist participants, including an (DIP) and Manager (FS&L) annual refresher training at least.

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22 Develop or source Project will be Review existing Underway curricula conforming to sourced* and materials and ensure that required training developed a set of they conform to required elements specified in training materials on training elements Annex C of the 2015 safer pesticide use specified in Annex C; Mission-wide Deadline: February 2017; PERS UAP. *includes materials Responsible:

developed by Croplife Environmental Specialist Asia and adapted by the USAID Ag Extension and USAID Ag Inputs Projects

23 Implement training plan, Initial training on safer Training on safer use of providing first time pesticide use will be pesticides to be provided training to all relevant provided by fourth to selected local service staff and beneficiaries quarter of FY 16 to providers or extension within 6 months. relevant project staff agents;

Deadline: Quarters 3 and 4 of FY16; Responsible: Environmental Specialist and Manager (FS&L) Refresher Training for all relevant project staff; Deadline: To be conducted in January 2017 and January 2018; Responsible: Environmental Specialist Provide training I share information on safer use of pesticides at Farmer Field Days, farmer courtyard sessions, and Lead Farmer trainings; Deadline: on going for the LOP Responsible: Environment Specialist

To the greatest degree possible, all projects must require use & maintenance of appropriate PPE - as well as safe pesticide purchase, handling, storage and disposal practices.

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indicate) compliance (with actions deadlines & responsible oartv)

24 If carbamate or NI A - There is no NIA organophosphate-class extensive use of pesticides are used carbamate or extensively, follow organophosphate-class procedures for baseline pesticides under testing for cholinesterase SAPLING. inhibition, and establish a periodic cholinesterase monitoring schedule when necessary.

25 Implement/observe core Beneficiaries are given Continue to provide risk mitigation measures information on PPE as information on PPE as (PPE and other part of training/ part of training and precautions) identified in courtyard sessions on courtyard sessions as per the summary section of safe use of pesticides training calendar; each extended pesticide Environmental Specialist profile. Where control is and Manager (FS&L) less complete, take all practicable measures to support and promote implementation of these measures. Whenever providing, SAPLING, in Continue to promote

26 supporting or coordination with the farmer use of PPE, and recommending pesticides Nobojatra and share information on for use, assure that SHOUHARDO III local availability, as part appropriate PPE is Projects, will confirm of beneficiary training available and, to the that appropriate PPE is and information sessions greatest degree possible, available in the FFP Environmental Specialist require its use. zone; & Manager (FS&L)

SAPLING cannot require use of PPE as actions by participant farmers are outside its control

27 Whenever directly using, NIA- project does not NIA procuring or supplying directly use, procure or pesticides, ensure that supply pesticides quality application equipment is available and local capacity for its available and maintained.

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28 To the greatest degree NIA - project does not NIA possible, enforce good have direct control over disposal and clean-up pesticide use by practices. participants and thus

cannot enforce good disposal and clean-up practices

29 For directly supported NIA- currently no NIA pesticide stores, assure involvement for that Food and directly supported Agriculture Organization pesticides stores or (F AO) Best Management transport to the Practices are met. (See participant level Annex C). For directly supported pesticide transport, ensure that minimum practices specified in Annex C are met.

Projects must follow safety restrictions and precautions for all target activities 30 People who are not NIA - project staff do NIA NIA

wearing PPE should not not directly use or enter pesticide treated apply pesticides under areas during Restricted this scenario; project Entry Intervals (REI) to does not have direct perform tasks that control over pesticide involve contact with use by project pesticide treated surfaces. participants Each pesticide label specifies a REI usually ranging from 12 to 72 hours.

31 Warning signs should be NIA- project staff do NIA NIA posted to warn people in not directly use or advance about pesticide apply pesticides as part application and REI. of project activities

32 Products that are NI A - project staff do NIA NIA suspected to have not directly use or potential to cause harm apply pesticides as part to unborn child, such as of project activities; Dimethoate and project does not have Mancozeb, will not be direct control over handled and applied by pesticide use by project pregnant women. participants Pregnant women should

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not enter treated areas during application and REI.

33 Pre-harvest interval Information on PHI is Update and expand Underway (PHI) is the time required currently provided to content on PHI in project between the last farmers as part of training materials; application of pesticides project-sponsored Deadline: March 2017 and the safe harvesting of training and Responsible: edible crops for information sessions Environment specialist immediate consumption. and manager (FS&L) Farmers will be trained Continue providing on the importance of training to beneficiary adhering to the PHI farmers; stated on the label to Deadline: Ongoing for ensure no chemical LOP residues are found on Responsible: harvested crops. Environment specialist

and manager (FS&L) Projects must be systematic in their pesticide related record-keeping and monitoring 34 Pesticide efficacy in SAPLING will develop Deadline: As per crop

demonstration plots must pesticide information season; be evaluated data sheet for pesticides Responsible:

efficacy and evaluation Environment Specialist; Upazila coordinator, union supervisors & Field facilitators

35 Any evidence of Information tracked by Deadline: As per crop pesticide resistance pesticides data sheet/ season for demonstration development must be monitoring form plots; tracked and reported Responsible:

Environment Specialist Flow-down requirements 36 Prime contractors must Pending Update sub-award

write pesticide agreements with CRS compliance requirements and Caritas to include as set out above into each pesticide compliance grant or sub-contract that requirements; will involve support for Deadline: March 2017; pesticide use . Responsible:

Environmental Specialist and Chief of Party (COP)

Pesticide registration status in Bangladesh and USEPA must be updated annually.

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OFFICE OF FOOD, DISASTER & HUMANITARIAN ASSISTANCE (OFDHA) USAID/ Bangladesh

ROUTING AND TRANSMITTAL SLIP Date: February 13, 2017

Sustainable Agriculture and Production Linked to Improved

Nutrition Status, Resilience and Gender Equity (SAPLING) Subject:

SAFER USE ACTION PLAN (SUAP)

TO: (Name, office symbol, room number, building, Agency/Post) Initials Date Comments

1. Farah Naz - OFDHA ,... 2.

, O:l./ j 3/ :(Oj.T fl!> .:s~11cLfU... f.u;t)1t'd-Sultana Rebeka - PRO -~J---- - wrtt-. ee M l\A~ A~.

3. OFDHA

4.

5.

6.

Ac tion File Note and Return

x Approval For Clearanc e Per Conversation

As Requested For Correction Prepare Reply

Circ ulate For Your Information See Me

Comment Investigation Signature

Coordination Justify

REMARKS

DO NOT use this form as a RECORD of a r ovals concurrences dis osals clearances and similar actions

FROM: (Name, org, symbol, Agency/ Post)

Samira Habib I OFDHA

Note: Please Call Samira (Ext. 2196) to bring the fi le from your des k 504 1- 103 U.S. Government Printing Office: 1995 - 387-722/20018

Room No. - Bldg.

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2196 OPTIONAL FORM 41 (Rev. 1-94 ) Prescribed by GSA

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Sustainable Agriculture and Production Linked to Improved ... · USAID DCHA ENVIRONMENT AL THRESHOLD DECISION FOR THE PROJECT SPECIFIC SAFER USE ACTION PLAN (SUAP) Awardee Helen Keller