FTF INITIAL ENVIRONMENTAL EXAMINATION (IEE) AMENDMENT

Amendment Number 1

FOR THE APPROVAL OF THE FTF ATTPESTICIDE EVALUATION REPORT AND SAFER USE ACTION PLAN

(PERSUAP)

A. IEE PROGRAM/ACTIVITY DATA:

Program/Activity Number: USAID/Ghana_FTF_EE_2011_2015.docContract #: AID-641-A-13-00001

Country: Republic of Ghana Program/Activity Title: USAID/Ghana Feed the Future Program, Agriculture Technology Transfer (ATT)

SO 6: Economic GrowthSO 7: Health

USG Foreign Assistance Framework:Functional Objective 3: Investing in PeopleProgram Area 3.1: Health Program Element 3.1.9: NutritionProgram Area 3.3: Social and Economic Service and Protection

of Vulnerable Populations Program Element 3.3.3: Social AssistanceFunctional Objective 4: Economic GrowthProgram Area 4.2: Trade and Investment Program Element: 4.2.1: Trade and Investment Enabling Environment Program Element: 4.2.2: Trade and Investment CapacityProgram Area 4.4: Infrastructure Program Element: 4.4.3: Transport ServicesProgram Area 4.5: Agriculture Program Element: 4.5.1: Agricultural Enabling Environment Program Element: 4.5.2: Agriculture Sector CapacityProgram Area 4.6: Private Sector Competitiveness Program Element: 4.6.1 Business Enabling Environment Program Element: 4.6.2 Private Sector CapacityProgram Area 4.8: Environment Program Element: 4.8.2 Clean Productive Environment

Funding Begin: 2010 Funding End: 2015 LOP Estimated/Planning Amount: US$ 318,000,000

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IEE Original Prepared By: Justice Odoi; Environmental Specialist & Mission Environmental Officer, USAID/Ghana (jodoi@usaid.gov)

Original IEE Date: September 30, 2011. Original IEE : http://gemini.info.usaid.gov/egat/envcomp/repository/pdf/38018.pdf

IEE ENVIRONMENTAL ACTION RECOMMENDED: (Place X where applicable)Categorical Exclusion: ___ ___ Negative Determination: ____X___Positive Determination: __ ___ Deferral ______

IEE ADDITIONAL ELEMENTS: (Place X where applicable)CONDITIONS X SUAP:__X___

IEE Amendment (Y/N): Y

Current Date of IEE Amendment 1: December 20, 2013

Expiration of PERSUAP: December 30, 2018

PERSUAP [IEE Amendment 1] Prepared By: Mohammed Bukari, Northern Ghana Agriculture Extension Coordinator, IFDC and Alan Schroeder, PhD, MBA, and Environmental Assessment Professional.

Findings of Original IEE:

On pesticides, the original IEE, under Section 3.2.2, found the following:

Pursuant to 22 CFR216.3 (b) (1), a Negative Determination with conditions is recommended for activities involving use of pesticides.

The original IEE can be accessed at the link above:

Conditions for Pesticides in Original IEE:The FtF team shall ensure that any activity involving pesticides, or new pest management products or technologies will be preceded by the preparation and BEO approval of PERSUAPs in accordance with Agency guidance, and fulfilling all analytical elements required by 22CFR216.3 (b), USAID’s Pesticide Procedures. The AFR BEO and USAID/WA Regional environmental staff will assist the Ghana Mission Environmental Officer (MEO) and FtF Activity Managers in establishing the need. New PERSUAPs, if any, will be commissioned as necessary, by the respective implementing partners.

The existing ADVANCE PERSUAP will be adapted to encompass the scope of USAID/Ghana’s Commercial Agriculture and other FtF Programs in Northern Ghana. The Government of Ghana will be producing a Pest Management Plan (PMP) in accordance with the World Bank Operational Procedure 4.09. USAID’s PERSUAP will be controlling in terms of influencing the use of pesticides (USEPA-registered) and integrated pest and plant health management. The existing ADVANCE PERSUAP can be accessed at: http://gemini.info.usaid.gov/egat/envcomp/repository/pdf/38543.pdf.

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B. BACKGROUND OF ATT PROJECT AND SUB-GRANTEESThe Feed the Future USAID Agricultural Technology Transfer Project and Sub-grantees (FTF-USAID ATT) is a five-year activity funded by the U.S. Agency for International Development’s Ghana Mission (USAID/Ghana), to increase the competitiveness of rice, maize and soya value chains to foster broad-based and sustained economic growth through the increased availability of agricultural technologies to increase and sustain productivity in Northern Ghana. The program will focus on the Ghana Feed the Future (FTF) intervention zone, which covers the three regions of northern Ghana: Northern, Upper West and Upper East plus the Northern parts of Brong Ahafo and Volta regions, and will address technology constraints in Ghana’s FTF target crops of rice, maize and soy.

IFDC (International Fertilizer Development Center) is the lead implementer, with additional technical support provided through Iowa State University (ISU) and the Center for Development Innovation (CDI) of the Wageningen University & Research Centre, GAABIC, and other local organizations and public and private sector institutions in Ghana. Research institutions and various departments of the Ministry of Agriculture and other offices within the Government of Ghana will play an important role in providing support to ensure the implementation of regulatory reforms needed for a performing and private sector-driven seed and fertilizer sector in Ghana.

The program supports various actors along the targeted value chains in Ghana. Main stakeholders include producers, agro-input dealers, agricultural marketing enterprises, farm services providers, industrial food and feed processors, private sector actors involved in seed and fertilizer production and distribution, research institutions/laboratories, as well as government and regulatory bodies responsible for creating and maintaining an enabling environment for a dynamic agricultural sector.

C. BACKGROUND OF GHANA, AGRICULTURE & ENVIRONMENTIncluding inland water bodies, like the very large Volta Lake, Ghana covers 238,539 km2 and is located on the south central coast of West Africa. The country shares borders in the east with Togo; in the north with Burkina Faso; and in the west with Cote d’Ivoire. Most of Ghana lies below 600 m, less than 10 % of the land is above 300 m, and few places have elevations above 1000 m1. The lowest areas are the middle Volta Basin and along the coast.

Agriculture in Ghana accounts for about 25% of GDP and employs over 60% of the workforce. Primary value and food security crops include cocoa, rice, maize, cassava, groundnuts, Shea nuts, bananas, local yams and timber. Mango and soybean are of upcoming importance for processing into exportable as well as local products like juice and dried mango, and poultry/fowl feed, soy oil and soymilk.

There are six broad physiographic regions in Ghana: the coastal plains, the Buem-Togo ranges, the forest dissected plateau, the southern Voltaian plateau, the savanna high plains, and the Gambaga escarpment. Generally, rainfall decreases and temperature increases from the rain forest zone in the south to the savanna zone in the north. By far the most important climatic factor influencing vegetation in Ghana is rainfall. In the northern savanna, annual rainfall ranges between 800 and 1,000 mm, from May to November.

1 http://www.fao.org/ag/agL/swlwpnr/reports/rc_codes.htm

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Over the whole country the mean monthly temperature is about 25oC. Although temperatures are uniformly moderate, there are important variations over different parts of the country as a result of altitudinal variations in the landscape and distance from the sea. In the coastal areas, due to the modifying influence of the sea, the annual difference between the maximum and the minimum monthly temperature is about 5o-6oC. On the other hand, much farther inland, the difference is between 7o-9oC. Diurnal temperature ranges are more significant than the monthly ranges. In the forested zones of the south the mean diurnal range is still moderate, but in the northern savannas the difference may be as much as 14o-20oC, especially during the Harmattan season.

According to the 2011 USAID Biodiversity, Tropical Forests and Climate Change Environmental Opportunities and Threats Assessment (ETOA)2: “In northern Ghana, with existing dry conditions and foreseeable climate affects, agriculture stability is highly likely to be improved by irrigation and water retention projects, which capitalize on capture and use of seasonal rainfall as well as better use of existing water sources.” Those farmers living near a reservoir or other body of water can and do produce two seasons of crops a year, one during the rainy season (May to October) and one with irrigation during the dry season (November to April).

The ETOA study goes on to state: “In development of irrigation and water retention infrastructure there is the potential issue of adverse impacts to riparian areas from ill designed infrastructure development and clearing for agriculture. Conversely, there is the opportunity to accommodate riparian function and structure in design of these agricultural programs and to increase local knowledge of the water quality, water quantity, soil stabilization, biodiversity, and forest retention benefits of well managed riparian areas within agricultural settings.”

Although the ETOA study does focus a lot on agriculture, it makes no mention of pesticides as a primary issue of concern for the environment. And, it mentions agricultural chemicals (p. 21) only in the context of increasing cost of inputs in relation to climatic changes.

D. EVALUATION OF ACTIVITY WITH RESPECT TO POTENTIAL ENVIRONMENTAL IMPACTS & IDENTIFICATION OF MITIGATION MEASURESAll activities approved in the original IEE remain valid. This proposed IEE amendment does the following, using environmental and human health risks and mitigation procedures identified in “22CFR 216.3 (b) Pesticide Procedures” as a guide: PERSUAP/Allowed Pesticides: The 2014 ATT PERSUAP evaluates for Sub-grantees and

ATT pesticides that could be potentially supported (use on demo trials, promotion during training, procurement) with project and Sub-grantees resources, as well as those that cannot be supported, with reasons that they cannot be supported.

Safety Training/Equipment: Recommend that sub-grantees that use pesticides on demo trials, promote the use of pesticides to farmers, or procure pesticides for farmers perform pesticide safety training and use of Personal Protection Equipment (PPE).

Spray Services: Recommend that Sub-grantees and ATT promote and support the concept and use of pesticide spray services that have well trained and PPE protected spray personnel.

Good Agriculture Practices: Recommend that sub-grantees and ATT staff promote the use of state of the art Good Agriculture Practices (GAPs) for each of the three crops, including use of high yielding and quality seed, soil fertility testing and conservation, plant nutritional

2 http://www.encapafrica.org/documents/biofor/Environmental%20Annex_Ghana_FINAL.pdf

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needs to grow healthy crops, proper water use, crop rotation, clean storage and marketing. Pest Management Plans/Integrated Pest Management: Recommend that sub-grantees and

ATT promote the use of state of the art (used by many national and state extension services) pest management plans (PMPs) containing major pests/diseases/weeds of each target crop, with preventive non-chemical Integrated Pest Management (IPM) tools/tactics, registered synthetic pesticides, as well as any artisanal and registered natural pesticides available.

COMPILATION OF 12-FACTOR ANALYSIS PRIMARY CONCLUSIONS & ACTIONS 22CFR 216.3 (b) 12-Factor Analysis ATT Conclusions/Actions NeededFactor A: Choose and use pesticide Active Ingredients (AIs) registered by both Ghana and US Environmental Protection Agencies (GEPA and US EPA) and that are not in Restricted Use Pesticides (RUPs)

Pesticides might be used (on demo trials, promoted during training, or procured). Some northern Ghana farmers use banned pesticides or those too toxic for safe use. If pesticides are used by Sub-grantees or

ATT, they must contain only pesticide Active Ingredients (AIs) evaluated and approved (below) by this PERSUAP.

If there is a choice, use products with lower human toxicity.

Factor B: Pesticide Selection Basis Farmers in the north of Ghana use a limited number of available pesticides, and most often do so based upon the advice of agrodealers. Sometimes they rely on advice from neighbors and occasionally from extension agents. Most will select the lowest cost pesticides, which is not ideal as some of the low-cost generic products may not be sufficiently effective. Farmers require training on how to choose

the correct pesticide. If there is a choice, use products with lower

human and ecological toxicities.

Factor C: Pesticide use as combined with preventive IPM tools and tacticsFactor I: Pesticide and non-pesticide alternatives available

Farmers do use a few GAP and preventive IPM tools like crop rotation, raised-bed, scaring birds and rodents early in the morning from newly planted fields, use of artisanal pesticides from neem and strong-smelling herbs, and weeding by hoe. However, few use mechanization, hybrid seed, soil tests or fertilizers. Preventive IPM tools and tactics for each

crop-pest combination should be used before and combined with and the choice is made to purchase and use synthetic pesticides.

A national PMP has been produced with World Bank assistance and should be used.

Factor D: Pesticide application & Personal Protection Equipment (PPE)

Most farmers use leaky knapsack sprayers and no PPE to apply pesticides. Most farmers do not calibrate spraying properly, leading to

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over- and under-dosing. If pesticides are used, promote the concept

of spray service providers and train farmers on proper sprayer calibration, use, maintenance, use of PPE and empty container disposal by rinsing, puncturing and burial.

Pregnant or lactating females, immune compromised individuals (HIV), and children should not be permitted to apply pesticides.

Factor E: Pesticide acute & chronic toxicological hazards

Most farmers do not understand acute and chronic health issues associated with pesticide use. Train farmers on how to read safety

precautions and first aid on pesticide labels and encourage them to use PPE.

Factor F: Pesticide effectiveness Most pesticides available in the north contain generic copies of off-patent pesticide AIs, some of which may be of low quality and come without proper agrodealer technical support. Sub-grantees/ATT encourage farmers to

value and buy higher quality products that come with technical support.

Factor G: Pesticide hazards to target and non-target organismsFactor H: Pesticide use impact on natural resources: water, soil, flora & fauna

Most farmers do not understand ecotoxicity and pollution of natural resources associated with pesticide use. Train farmers about ecotoxicity and on

how to read ecotoxicity precautions on pesticide labels and encourage farmers to use PPE.

Train farmers on applying pesticides the proper distance from open bodies of fresh water.

Factor J: Pesticide management abilities of host countryFactor K: Pesticide safe use training

Ghana’s EPA tests and registers pesticides two times a year. Ghana’s Plant Protection Regulatory Services Directorate (PPRSD) does pesticide safety training, enforcement and disposal of obsolete pesticides, but has limited resources. A number of farmers around Tamale have received pesticide safety training and PPE from either MCC or ADVANCE. ATT/Sub-grantees encourage farmers to

purchase inputs from suppliers that provide quality technical backup support; and encourage farmers to use pesticide spray

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services. ATT/Sub-grantees provide pesticide safety

training and access to PPE especially to farmers not part of the previous MCC or ADVANCE projects.

Factor L: Pesticide use monitoring Many farmers do not understand how to choose pesticides, properly calibrate a knapsack sprayer or monitor use. This leads to the use of the wrong chemicals for the task and use of incorrect quantities of pesticides. Farmers require training on how to choose

the correct pesticide, knapsack sprayer calibration and record keeping.

E. RECOMMENDED ENVIRONMENTAL ACTIONS1. Recommended Environmental Threshold Determinations:A Negative Determination with Conditions is recommended for activities that are related to pest management/pesticide training/promotion, distribution and use, directly or through other financial instruments (credit, sub grants, vouchers) under this IEE amendment pursuant to 22CFR 216.3 (b) Pesticide Procedures.

2. ConditionsIf pesticide use is supported in any way by ATT or their sub-grantees, implement PERSUAP recommendations, as follows.

Condition 1: Allowed Pesticides (PER Factor A analysis)Upon approval of this PERSUAP, the pesticide active ingredients (AIs) listed as “allowed” in the following table may be supported by ATT and project and Sub-grantees covered by this PERSUAP. Such support is subject to the safer use conditions summarized below and set out in detail in the SUAP, section 4 of this PERSUAP.

Allowed pesticides are those that passed the 22CFR 216.3 (b) Pesticide Procedures 12-factor analyses, particularly Factor A: US Environmental Protection Agency (USEPA) and Ghana EPA Registration and USEPA Restricted Use Pesticide (RUP) Status & Factor E: Acute/Chronic Toxicological Hazards, as analyzed and summarized in Annex 7. Synthesizing across the PER analysis, ONLY the below-listed pesticides (active ingredients) are permitted for use/support on ATT/sub-grantee activities.

Table 1: Allowed Pesticides (some allowed only with conditions) found in northern Ghana

Allowed Insecticide AIs registered by Ghana found available in northern Ghana abamectin (Mektin 1.8EC) acetamiprid (Golan 20SL, but only when plants are in vegetative state, not when

flowering due to risk to pollinators and honeybee colony collapse disorder) deltamethrin (Deltapaz 12.5%)

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imidacloprid (Confidor 200SC, Akape, Momtaz, but only when plants are in vegetative state, not when flowering due to risk to pollinators and honeybee colony collapse disorder)

lambda-cyhalothrin (Lambda Super 2.5EC, Karate, Kombat 2.5EC, Sunhalothrin 2.5EC, Kilsect 2.5EC, Icon 10CS, Zap 2.5, K-Optimal) (in general formulations above 10% are RUP)

malathion (, Envigold 70 SL, for stored grain pests) mineral oil (EOS White Mineral Oil) neem seed artisanal extract (natural neem seed extract plus soap and water) pirimiphos-methyl (Ateco Super 25 EC, for stored grain pests)

Additional Allowed Insecticide AIs registered by Ghana if they become available in the north acephate Bacillus sphaericus Bacillus thuringiensis/BT (for crops and/or stored grain pests) bifenthrin (use only 10% EC and 2.5% ULV formulations) dimethoate Metarhizium anisopliae novaluron permethrin (Antuka EC with pirimiphos-methyl, for stored grain pests; M-Guard EC with

pirimiphos-methyl, for stored grain pests only) pyrethrum natural plant extract (pyrethrins; Agro Blaster EC or Super Agro Blaster, both

1%, for stored grain pests only) pyriproxyfen thiamethoxam (but only when plants are in vegetative state, not when flowering due to

risk to pollinators and honeybee colony collapse disorder)

Allowed Fungicide AIs registered by Ghana found available in northern Ghana captan (Merpan 50WP, seed treatment) copper (cupric) hydroxide (Kocide) (use only acute toxicity Class II or III products; not

Class I) copper sulfate (TopCop tribasic) (use only acute toxicity Class II or III products; not

Class I) mancozeb (Cotazeb 80%, Dithane-M 45, Kilazeb 80WP) mefenoxam (Ridomil Gold, Victory 72WP) sulfur (Sulfa 80WDG) thiophanate-methyl (Topsin-M 70WP) thiram (Momtaz seed treatment mix with insecticide imidacloprid)

Additional Allowed Fungicide AIs registered by Ghana if they become available in the north azoxystrobin copper (fixed or tribasic) (use only acute toxicity Class II or III products; not Class I) copper (cupric) oxide (CuO) (use only acute toxicity Class II or III products; not Class I) cuprous oxide (Cu2O) (use only acute toxicity Class II or III products; not Class I) difenoconazole folpet (likely carcinogen at higher doses used repeatedly over time, so use PPE) fosetyl aluminum

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metalaxyl propiconazole triadimenol (on pre-treated seed for maize only; not for sorghum seed) Trichoderma asperellum

Allowed Herbicide AIs registered by Ghana found available in northern Ghana 2 4 D amine salt (Select 722, Weedcot SL, Wiper 720SL, Balton 800, Ervextra, Dextra,

Herbacut) (use only acute toxicity Class II or III products; not Class I) bensulfuron methyl (Altidax) bentazon, sodium salt only (Basagran 480SL) glyphosate, isopropyl amine salt (Uproot 360, Wynna 360SL, Nwurawura 360SL,

Sunphosphate 360SL, Rival 360SL, Glyphogan 360, Roundup 360, Agasate 40, Tackle 480, Touchdown, Glyphader, Chemosate)

imazethapyr/imazethapir, ammonium salt (Vezir 240SL) nicosulfuron (Nicogan 40OD, Arrow 75WDG) oxyfluorfen (plus glyphosate mix equals Zoomer SC) pendimethalin (Alligator 400EC, Stomp 330E, Activus 500EC) propanil (Stam F-34, Orizo Plus)

Additional Allowed Herbicide AIs registered by Ghana if they become available in the north bispyribac-sodium fluazifop-P-butyl gibberellic acid mesotrione terbuthylazine triclopyr

The allowed AIs can only be used in compliance with the safer use measures and restrictions specified in the PER. These can be summarized as follows:

i. Only pesticides containing the above Active Ingredients approved by this PERSUAP may be supported with USAID funds in ATT activities. These pesticides are enumerated in the SUAP section 4.2 of this PERSUAP. Pesticide “support” means promotion, procurement, financing, use, recommending for use, or otherwise facilitating the use of a pesticide.

ii. In the case of the ATT project and Sub-grantees that assists with greenhouse and orchard production, pesticide support should be governed by a set of locally adapted crop- and pest-specific IPM-based pest management plans and observe enumerated use restrictions.

iii. Appropriate project and Sub-grantees staff & beneficiaries should be trained in safer pesticide use & pesticide first aid;

iv. To the greatest degree practicable, ATT project and Sub-grantees should require use & maintenance of appropriate PPE—as well as safe pesticide purchase, handling, storage and disposal practices;

v. ATT project and Sub-grantees should be systematic in their pesticide-related record keeping and monitoring.

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Condition 2: Rejected Pesticides (see PER, Factor A Analysis)Upon approval of this PERSUAP, the pesticide active ingredients (AIs) listed as “rejected” in the PER Factor A analysis—may NOT be supported by the ATT project and Sub-grantees as covered by this PERSUAP. See Section 3 of this PERSUAP for the 40 pesticides excluded.

Condition 3: The Safer Use Action Plan (SUAP, Section 4) provides a succinct, stand-alone statement of risks and risk reduction compliance requirements, synthesized from the 12-factor analysis. It also provides a template like an Environmental Mitigation and Monitoring Plan (EMMP) for assigning responsibilities and timelines for implementation and reporting of these requirements. The ATT project and Sub-grantees must complete this SUAP template and submit to its AOR/COR for approval and provide an annual update thereafter. With respect to pesticides, the Safer Use Action Plan can be used to satisfy the requirement for an environmental mitigation and monitoring plan (EMMP). The project and Sub-grantees EMMP may incorporate the SUAP by reference.

Condition 4: If pesticide use is supported, ATT project and Sub-grantees, during the pesticide safer use training required by this PERSUAP, will (1) promote and teach proper sprayer maintenance and repair; and (2) train participants on post-spray hygiene.

Condition 5: If pesticide use is supported, ATT project and Sub-grantees will assure and require well-maintained sprayers and proper post-spray hygiene for pesticide use on demo farms.

Condition 6: If agricultural production is done within 10km up-wind or up-stream from a protected area, the ATT project and Sub-grantees should investigate and strongly recommend the use of botanical and biological pesticides, as practical, or produce Organic crops near these valuable natural resources.

Condition 7: If a Ghanaian or regional pesticide container recycling facility is brought on-line during the life of the project and Sub-grantees, ATT should encourage its use.

Condition 8: If pesticide use is supported, ATT project and Sub-grantees conduct farmer training programs on safe handling, storage, use, monitoring and data record keeping techniques for pest control and pesticide needs and/or effectiveness.

Condition 9: ATT A/COR, at least one time during the agriculture cycle, make visits to several randomly selected farms receiving assistance through the ATT Project and Sub-grantees and check for implementation of the recommendations on pesticides and IPM found in this PERSUAP. As needed or desired, the COR could seek assistance/advice from the MEO (MEO could conduct site visits upon requests by A/COR).

Condition 10: Any agricultural products used in the anticipated activities should abide by local and export regulations and requirements.

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F. MANDATORY INCLUSION OF ENVIRONMENTAL COMPLIANCE REQUIREMENTS IN SOLICITATIONS, AWARDS, BUDGETS AND WORKPLANS

1. Appropriate environmental compliance language shall be included in solicitations and awards for this activity with an appropriate level of funding and staffing to satisfy the environmental compliance requirements set forth in this IEE Amendment.

2. The implementing partner will incorporate conditions set forth in this IEE into their work plans.

G. LIMITATIONS OF THE IEEGenerally this IEE Amendment does not cover major activities involving:

1. Classes of substantial actions normally having a significant effect on the environment pursuant to 22CFR 216.2(d)(1):

i. Programs of river basin development;ii. Irrigation and water management;iii. Agricultural land leveling;iv. Drainage projects;v. Large scale agricultural mechanization;vi. Resettlement projects;vii. New land development;viii. Penetration road building and road improvement;ix. Power plants;x. Industrial plants;xi. Potable water and sewerage projects;

2. Activities affecting endangered species or introducing exotic species.3. Support to extractive industries (e.g. mining and quarrying).4. Support for activities that promote timber harvesting.5. Construction, reconstruction, rehabilitation, or renovation work.6. Activities involving support to agro-processing, industrial enterprises, and regulatory

permitting.7. Activities involving support to industrial enterprises, and regulatory permitting.8. Potential activity components dealing with privatization of industrial facilities or

infrastructure with heavily polluted property.9. Project and Sub-grantees preparation, project and Sub-grantees feasibility studies, and

infrastructure investments for projects that may have a potentially significant impact on the environment.

10. Procurement or use of genetically modified organisms (GMOs).11. DCA or GDA programs.

Any of the above actions would require another amendment to the IEE approved by the BEO.

H. REVISIONSPursuant to 22 CFR 216.3(a) (9), if new information becomes available that indicates that activities covered by the IEE might be considered “major” and their effect “significant,” or if additional activities are proposed that might be considered “major” and their effect “significant,” this Initial Environmental Examination will be reviewed and, revised by the MEO with concurrence by the BEO. It is the responsibility of the USAID COR to keep the MEO, REA and BEO informed of any new information or changes in the activity that might require revision of the IEE.

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APPROVAL OF ENVIRONMENTAL ACTION RECOMMENDED:

AFR Bureau Environmental Officer Approval:/WIK for/ 4/17/2014

Brian Hirsch Date

Mission Director Approval: /s/ 4/16/2014James Bever Date

Mission Environmental Officer: /s/ 4/8/2014Justice Odoi Date

AFR BEO File Name: Ghana_Agricultural_Tech_Transfer_ATT_FTF_PERSUAP

CLEARANCES:

Program Office ____/s/___________ _4/10/2014__Tom Crubough Date

Contracting Officer’s Representative: /s/ 4/12/2014John Brighenti Date

Economic Growth Office Director: /s/ 4/12/2014Peter Trenchard Date

Deputy Mission Director: _________/s/___________ _4/8/2014___Andy Karas Date

Distribution:

1. Project and Sub-grantees files2. CORs/AORs and Activity Managers

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2013 Ghana IFDC Feed the Future Agriculture Technology Transfer (ATT) Project and Sub-grantees PERSUAP

(Pesticide Evaluation Report and Safer Use Action Plan)

DRAFT

By IFDC(International Fertilizer Development Center)

For USAID Ghana

November-December 2013

Authors:Mohammed Bukari, MSc

Agriculture Extensionmkanami09@gmail.com

Tamale, Ghana

Alan Schroeder, PhD, MBAEnvironmental Assessment Professional

alanschroeder99@gmail.comBusiness cell phone: 703-859-1676

Skype VOIP: happywildwarthog

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ACRONYMS

ABC Agro-Business CentreAI Active Ingredient (reference to chemical/s in pesticides)AOR Agreement Officer’s Representative (USAID)ATT Agriculture Technology Transfer Project and Sub-granteesBEO Bureau Environmental Officer (USAID)BMP Best Management PracticeBT Bacillus thuringiensis (a bacteria that produces a toxin used as a pesticide)CCD Colony Collapse DisorderCFR Code of Federal Regulations (USA)CLI Crop Life International (private sector pesticide companies trade association)COP Chief of Party (USAID)COR Contracting Officer’s Representative (USAID)E Emulsion (a pesticide formulation)EA Environmental AssessmentEC Emulsifiable Concentrate (pesticide formulation)EC50 Effective Concentration 50 (acute toxicity measure)EPA US Environmental Protection Agency (also known as USEPA)ETOA Environmental Threats and Opportunities Analysis (biodiversity/forestry study)EU European UnionFAO Food and Agriculture Organization (United Nations)FBO Farmer Based Organizations (MCC)FDA Food and Drug Administration (USA)FIFRA Federal Insecticide, Fungicide and Rodenticide Act (USA)FRAC Fungicide Resistance Action Committee FTF Feed the FutureG Granular (a pesticide formulation)GAP Good Agriculture PracticeGEPA Ghana Environmental Protection AgencyGlobalGAP Global Good Agriculture Practices, a certification systemGMO Genetically Modified OrganismGOG Government of GhanaGUP General Use PesticideHa HectaresHRAC Herbicide Resistance Action Committee HT Highly ToxicID IdentificationIEE Initial Environmental Examination (USAID)IFDC International Fertilizer Development CenterIGR Insect Growth RegulatorIPM Integrated Pest ManagementIRAC Insecticide Resistance Action Committee LC50 Lethal Concentration 50 (acute toxicity measure)LD50 Lethal Dose 50 (acute toxicity measure)MCC Millennium Challenge CorporationM&E Monitoring and Evaluation MEO Mission Environmental Officer (USAID)MIR Plus Marketing Inputs Regionally Plus Project (IFDC)MOFA Ministry of Food and Agriculture (GOG)MRL Maximum/Minimum Residue Level/Limit

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MSDS Material Safety Data SheetMSL Meters above Sea LevelMT Metric TonsMT Moderately ToxicNAT Not Acutely ToxicNCAT National Center for Appropriate Technology (USA)NEPA National Environmental Policy Act (USA)NGO Non-Governmental OrganizationNIFA National Institute of Food and Agriculture (USA)OD Oil Dispersion (a pesticide formulation)PAN Pesticide Action Network (pesticide NGO)PEA Programmatic Environmental Assessment (USAID)PER Pesticide Evaluation ReportPERSUAP Pesticide Evaluation Report and Safe Use Action PlanpH log of Hydrogen concentration, measure of acidityPHI Pre-Harvest IntervalPIC Prior Informed Consent (a treaty, relates to toxic pesticides)POPs Persistent Organic Pollutants (a treaty, relates to toxic persistent pesticides)PMP Pest Management PlanPNT Practically Non-ToxicPPE Personal Protection EquipmentPPRSD Plant Protection and Regulatory Services Directorate (GOG)R&D toxin Reproductive and Developmental toxinREA Regional Environmental AdvisorReg 216 Regulation 216 (USAID Environmental Procedures)REI Re-Entry Interval (safety period after pesticide spraying)RUP Restricted Use PesticideSC Suspension Concentrate (a pesticide formulation)SL Soluble Liquid (a pesticide formulation)S&C Standards and CertificationSOW Scope of WorkST Slightly ToxicSUAP Safe Use Action PlanUC University of CaliforniaUN United NationsUNEP United Nations Environment ProgramUSAID United States Agency for International DevelopmentUSDA United States Department of AgricultureUSEPA US Environmental Protection Agency (also known as EPA)VHT Very Highly ToxicWDG Water Dispersible Granule (a pesticide formulation)WHO World Health Organization (United Nations)WP Wettable Powder (a pesticide formulation, usually for fungicides)WPA Wildlife Protected Areas

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Table of Contents

FTF INITIAL ENVIRONMENTAL EXAMINATION (IEE) AMENDMENT....................1A. IEE PROGRAM/ACTIVITY DATA:...............................................................................................1B. BACKGROUND OF ATT PROJECT AND SUB-GRANTEES...................................................3C. BACKGROUND OF GHANA, AGRICULTURE & ENVIRONMENT......................................3D. EVALUATION OF ACTIVITY WITH RESPECT TO POTENTIAL ENVIRONMENTAL IMPACTS & IDENTIFICATION OF MITIGATION MEASURES...................................................4E. RECOMMENDED ENVIRONMENTAL ACTIONS.....................................................................7F. MANDATORY INCLUSION OF ENVIRONMENTAL COMPLIANCE REQUIREMENTS IN SOLICITATIONS, AWARDS, BUDGETS AND WORKPLANS...............................................11G. LIMITATIONS OF THE IEE..........................................................................................................11H. REVISIONS..........................................................................................................................................112013 Ghana IFDC Feed the Future Agriculture Technology Transfer (ATT) Project and Sub-grantees PERSUAP.................................................................................................................13ACRONYMS.............................................................................................................................................. 14ACKNOWLEDGEMENTS........................................................................................................................18SUMMARY OF FINDINGS AND RECOMMENDATIONS.............................................................19SECTION 1: INTRODUCTION...............................................................................................................241.1 Purpose, Scope & Orientation..................................................................................................241.2 USAID Environmental Regulations Development..............................................................241.3 Regulation 216............................................................................................................................... 251.4 The Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP)...........251.5 Integrated Pest Management—USAID Policy..................................................................261.6 Ghana FTF ATT/Sub-grantees PERSUAP Methodology...............................................261.7 Ghana FTF ATT/Sub-grantees PERSUAP General Findings.......................................27SECTION 2: BACKGROUND..................................................................................................................352.1 Ghana Country Background....................................................................................................352.2 IFDC FTF ATT Project Background......................................................................................382.3 Integrated Pest Management and PERSUAP Precedents............................................382.4 Ghana Pesticide System Risks and Areas for Improvement......................................39SECTION 3: PESTICIDE EVALUATION REPORT (PER)............................................................413.1 Factor A: USEPA Registration Status of the Proposed Pesticide..............................413.2 Factor B: Basis for Selection of Pesticides.........................................................................443.3 Factor C: Extent to Which the Proposed Pesticide Use Is, Or Could Be, Part of an IPM Program.............................................................................................................................................. 443.4 Factor D: Proposed Method or Methods of Application, Including the Availability of Application and Safety Equipment.....................................................................463.5 Factor E: Any Acute and Long-Term Toxicological Hazards, either Human or Environmental, Associated With the Proposed Use, And Measures Available To Minimize Such Hazards......................................................................................................................... 463.6 Factor F: Effectiveness of the Requested Pesticide for the Proposed Use...........473.7 Factor G: Compatibility of the Proposed Pesticide Use with Target and Non-Target Ecosystems...................................................................................................................................503.8 Factor H: Conditions under Which the Pesticide Is To Be Used, Including Climate, Geography, Hydrology, and Soils.....................................................................................52

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3.9 Factor I: Availability of Other Pesticides or Non-Chemical Control Methods....533.10 Factor J: Host Country’s Ability to Regulate or Control the Distribution, Storage, Use, and Disposal of the Requested Pesticide............................................................543.11 Factor K: Provision for Training of Users and Applicators......................................553.12 Factor L: Provision Made For Monitoring the Use and Effectiveness of Each Pesticide....................................................................................................................................................... 55SECTION 4: PESTICIDE SAFER USE ACTION PLAN (SUAP)...................................................574.1 Introduction........................................................................................................................................ 574.2 Allowed Pesticides........................................................................................................................... 574.3 USAID field monitoring requirement.......................................................................................594.4 Summary of Compliance Requirements (Safer Use Measures)....................................59Annex 1: Matrix of Ghana FTF ATT Crops with Primary Production Constraints, PERSUAP-Recommended Pest Prevention GAP/IPM Tactics & PERSUAP-Recommended Curative Tools and Tactics...................................................................................62Annex 2. Guidelines for Pest Management Plans (PMPs) for Ghana Crops and Beneficiaries............................................................................................................................................... 70Annex 3. Elements of Integrated Pest Management (IPM) Program................................73Annex 4. Botanical Active Ingredients in Pesticides, Repellents, and Baits Regulated by USEPA...................................................................................................................................................... 76Annex 5. Natural Pesticides That Have Been Commercialized............................................78Annex 6. Acute Toxicity of Pesticides: EPA and WHO Classifications...............................79Annex 7: PERSUAP Analyses of Active Ingredients in Pesticides Registered in Ghana.......................................................................................................................................................................... 81Annex 8. Training Topics and Safe Pesticide Use Web Resources.....................................86Annex 9. Field Monitoring Form for Farmer Best Practices including GAP and IPM options.......................................................................................................................................................... 88Annex 10: Farm and Project Record Keeping Associated with Pesticide Use...............90ANNEX 11: PERSUAP References......................................................................................................93Annex 12: List Of Institutions And Farmers Interviewed......................................................95Annex 13: 2014 Ghana IFDC FTF ATT Project EMMP (Environmental Risk Mitigation & Monitoring Plan) Management Matrix.......................................................................................97

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ACKNOWLEDGEMENTS

This PERSUAP team of Northern Ghana Agriculture Expert Coordinator Mohammed Bukari and Environmental Assessment Professional Alan Schroeder acknowledge the assistance of USAID Ghana AOR and MEO staff members for input, feedback and ideas, and logistical support.

The PERSUAP team would not have been able to accomplish its work without the assistance of IFDC headquarters and Ghana field staff members for contracting the study and for help with logistics, ideas, opinions and review. Other individuals and institutions—too numerous to list—contributed to the accuracy and completeness of this study.

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SUMMARY OF FINDINGS AND RECOMMENDATIONS

The Feed the Future USAID Agricultural Technology Transfer Project and Sub-grantees (FTF-USAID ATT) is a five-year activity funded by the U.S. Agency for International Development’s Ghana Mission (USAID/Ghana), to increase the competitiveness of rice, maize and soya value chains to foster broad-based and sustained economic growth through the increased availability of agricultural technologies to increase and sustain productivity in Northern Ghana.

The present 2014 PERSUAP addresses the Condition of the FTF ATT Initial Environmental Examination (IEE) Negative Determination regarding the potential use of pesticides, following 22CFR 216.3 (b) Pesticide Procedures. This PERSUAP will closely inform the technical assistance and capacity building for ATT/Sub-grantees and other partners. It addresses the following key findings and recommendations:

PERSUAP/Allowed Pesticides: The 2014 ATT PERSUAP evaluates for Sub-grantees and ATT pesticides that could be potentially supported (use on demo trials, promotion during training, procurement) with project and Sub-grantees resources, as well as those that cannot be supported, with reasons that they cannot be supported.

Safety Training/Equipment: Recommend that sub-grantees that use pesticides on demo trials, promote the use of pesticides to farmers, or procure pesticides for farmers perform pesticide safety training and use of Personal Protection Equipment (PPE).

Spray Services: Recommend that Sub-grantees and ATT promote and support the concept and use of pesticide spray services that have well trained and PPE protected spray personnel.

Good Agriculture Practices: Recommend that sub-grantees and ATT staff promote the use of state of the art Good Agriculture Practices (GAPs) for each of the three crops, including use of high yielding and quality seed, soil fertility testing and conservation, plant nutritional needs to grow healthy crops, proper water use, crop rotation, clean storage and marketing.

Pest Management Plans/Integrated Pest Management: Recommend that sub-grantees and ATT promote the use of state of the art (used by many national and state extension services) pest management plans (PMPs) containing major pests/diseases/weeds of each target crop, with preventive non-chemical Integrated Pest Management (IPM) tools/tactics, registered synthetic pesticides, as well as any artisanal and registered natural pesticides available.

COMPILATION OF 12-FACTOR ANALYSIS PRIMARY CONCLUSIONS & ACTIONS 22CFR 216.3 (b) 12-Factor Analysis ATT Conclusions/Actions NeededFactor A: Choose and use pesticide Active Ingredients (AIs) registered by both Ghana and US Environmental Protection Agencies (GEPA and US EPA) and that are not in Restricted Use Pesticides (RUPs)

Pesticides might be used (on demo trials, promoted during training, or procured). Some northern Ghana farmers use banned pesticides or those too toxic for safe use. If pesticides are used by Sub-grantees or

ATT, they must contain only pesticide Active Ingredients (AIs) evaluated and approved (below) by this PERSUAP.

If there is a choice, use products with lower human toxicity.

Factor B: Pesticide Selection Basis Farmers in the north of Ghana use a limited number of available pesticides, and most often

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do so based upon the advice of agrodealers. Sometimes they rely on advice from neighbors and occasionally from extension agents. Most will select the lowest cost pesticides, which is not ideal as some of the low-cost generic products may not be sufficiently effective. Farmers require training on how to choose

the correct pesticide. If there is a choice, use products with lower

human and ecological toxicities.

Factor C: Pesticide use as combined with preventive IPM tools and tacticsFactor I: Pesticide and non-pesticide alternatives available

Farmers do use a few GAP and preventive IPM tools like crop rotation, scaring birds and rodents early in the morning from newly planted fields, and weeding by hoe. However, few use mechanization, hybrid seed, soil tests or fertilizers. Preventive IPM tools and tactics for each

crop-pest combination should be used before and combined with and the choice is made to purchase and use synthetic pesticides.

A national PMP has been produced with World Bank assistance and should be used.

Factor D: Pesticide application & Personal Protection Equipment (PPE)

Most farmers use leaky knapsack sprayers and no PPE to apply pesticides. Most farmers do not calibrate spraying properly, leading to over- and under-dosing. If pesticides are used, promote the concept

of spray service providers and train farmers on proper sprayer calibration, use, maintenance, use of PPE and empty container disposal by rinsing, puncturing and burial.

Pregnant or lactating females, immune compromised individuals (HIV), and children should not be permitted to apply pesticides.

Factor E: Pesticide acute & chronic toxicological hazards

Most farmers do not understand acute and chronic health issues associated with pesticide use. Train farmers on how to read safety

precautions and first aid on pesticide labels and encourage them to use PPE.

Factor F: Pesticide effectiveness Most pesticides available in the north contain generic copies of off-patent pesticide AIs, some of which may be of low quality and come

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without proper agrodealer technical support. Sub-grantees/ATT encourage farmers to

value and buy higher quality products that come with technical support.

Factor G: Pesticide hazards to target and non-target organismsFactor H: Pesticide use impact on natural resources: water, soil, flora & fauna

Most farmers do not understand ecotoxicity and pollution of natural resources associated with pesticide use. Train farmers about ecotoxicity and on

how to read ecotoxicity precautions on pesticide labels and encourage farmers to use PPE.

Train farmers on applying pesticides the proper distance from open bodies of fresh water.

Factor J: Pesticide management abilities of host countryFactor K: Pesticide safe use training

Ghana’s EPA tests and registers pesticides two times a year. Ghana’s Plant Protection Regulatory Services Directorate (PPRSD) does pesticide safety training, enforcement and disposal of obsolete pesticides, but has limited resources. A number of farmers around Tamale have received pesticide safety training and PPE from either MCC or ADVANCE. ATT/Sub-grantees encourage farmers to

purchase inputs from suppliers that provide quality technical backup support; and encourage farmers to use pesticide spray services.

ATT/Sub-grantees provide pesticide safety training and access to PPE especially to farmers not part of the previous MCC or ADVANCE projects.

Factor L: Pesticide use monitoring Many farmers do not understand how to choose pesticides, properly calibrate a knapsack sprayer or monitor use. This leads to the use of the wrong chemicals for the task and use of incorrect quantities of pesticides. Farmers require training on how to choose

the correct pesticide, knapsack sprayer calibration and record keeping.

List 1: Allowed Pesticides (some allowed only with conditions) found in northern Ghana

Allowed Insecticide AIs registered by Ghana found available in northern Ghana abamectin (Mektin 1.8EC)

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acetamiprid (Golan 20SL, but only when plants are in vegetative state, not when flowering due to risk to pollinators and honeybee colony collapse disorder)

deltamethrin (Deltapaz 12.5%) imidacloprid (Confidor 200SC, Akape, Momtaz, but only when plants are in vegetative

state, not when flowering due to risk to pollinators and honeybee colony collapse disorder)

lambda-cyhalothrin (Lambda Super 2.5EC, Karate, Kombat 2.5EC, Sunhalothrin 2.5EC, Kilsect 2.5EC, Icon 10CS, Zap 2.5, K-Optimal) (in general formulations above 10% are RUP, while most of formulations below 10% are not RUP)

malathion (, Envigold 70 SL, for stored grain pests) mineral oil (EOS White Mineral Oil) neem seed artisanal extract (natural neem seed extract plus soap and water) pirimiphos-methyl (Ateco Super 25 EC, for stored grain pests)

Additional Allowed Insecticide AIs registered by Ghana if they become available in the north acephate Bacillus sphaericus Bacillus thuringiensis/BT (for crops and/or stored grain pests) bifenthrin (use only 10% EC and 2.5% ULV formulations) dimethoate Metarhizium anisopliae novaluron permethrin (Antuka EC with pirimiphos-methyl, for stored grain pests; M-Guard EC with

pirimiphos-methyl, for stored grain pests only) pyrethrum natural plant extract (pyrethrins; Agro Blaster EC or Super Agro Blaster, both

1%, for stored grain pests only)pyriproxyfen thiamethoxam (but only when plants are in vegetative state, not when flowering due to

risk to pollinators and honeybee colony collapse disorder)

Allowed Fungicide AIs registered by Ghana found available in northern Ghana captan (Merpan 50WP, seed treatment) copper (cupric) hydroxide (Kocide) (use only acute toxicity Class II or III products; not

Class I) copper sulfate (TopCop tribasic) (use only acute toxicity Class II or III products; not

Class I) mancozeb (Cotazeb 80%, Dithane-M 45, Kilazeb 80WP) mefenoxam (Ridomil Gold, Victory 72WP) sulfur (Sulfa 80WDG) thiophanate-methyl (Topsin-M 70WP) thiram (Momtaz seed treatment mix with insecticide imidacloprid)

Additional Allowed Fungicide AIs registered by Ghana if they become available in the north azoxystrobin copper (fixed or tribasic) (use only acute toxicity Class II or III products; not Class I) copper (cupric) oxide (CuO) (use only acute toxicity Class II or III products; not Class I) cuprous oxide (Cu2O) (use only acute toxicity Class II or III products; not Class I) difenoconazole

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folpet (likely carcinogen at higher doses used repeatedly over time, so use PPE) fosetyl aluminum metalaxyl propiconazole triadimenol (on pre-treated seed for maize only; not for sorghum seed) Trichoderma asperellum

Allowed Herbicide AIs registered by Ghana found available in northern Ghana 2 4 D amine salt (Select 722, Weedcot SL, Wiper 720SL, Balton 800, Ervextra, Dextra,

Herbacut) (use only acute toxicity Class II or III products; not Class I) bensulfuron methyl (Altidax) bentazon, sodium salt only (Basagran 480SL) glyphosate, isopropyl amine salt (Uproot 360, Wynna 360SL, Nwurawura 360SL,

Sunphosphate 360SL, Rival 360SL, Glyphogan 360, Roundup 360, Agasate 40, Tackle 480, Touchdown, Glyphader, Chemosate)

imazethapyr/imazethapir, ammonium salt (Vezir 240SL) nicosulfuron (Nicogan 40OD, Arrow 75WDG) oxyfluorfen (Zoomer SC) pendimethalin (Alligator 400EC, Stomp 330E, Activus 500EC) propanil (Stam F-34, Orizo Plus)

Additional Allowed Herbicide AIs registered by Ghana if they become available in the north bispyribac-sodium fluazifop-P-butyl gibberellic acid mesotrione terbuthylazine triclopyr

How to Use this PERSUAP Efficiently

The best way to use this document is to focus on the parts that apply to the crops produced, the pests of each and the preventive and curative tools and tactics, including pesticides. To do this efficiently, search this document for the crops or pests (common or scientific name) using the Word computer program’s “Find” feature, which allows one to enter the word or phrase desired, and then takes one to the exact parts of the report where the word or phrase is used. Specific pesticide active ingredients in Annexes 1 and 7 can be found using the same method.

Update the Report Annually and Amend the Report in Two Years

New pesticides and EPA registrations change weekly. In addition, new human health and environmental data is produced continuously. For these reasons and others, this PERSUAP should be updated at least annually, and amended after two years in order to remain current and accurate.

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SECTION 1: INTRODUCTION

1.1 Purpose, Scope & Orientation

PurposeIn compliance with USAID’s Pesticide Procedures (22 CFR 216.3(b)), this 2014 Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP) for the FTF ATT Project:

Establishes the subset of pesticides (of those registered by Ghana) found in the northern regions of Ghana for which support is authorized for ‘use’ on ATT project and activities.

Establishes requirements associated with support for these pesticides to assure that pesticide use/support (1) embodies the principles of safer pesticide use and, (2) per USAID policy, is within an Integrated Pest Management (IPM) framework.

These requirements come into effect upon approval of the PERSUAP.

ScopeThis PERSUAP document covers only the IFDC FTF ATT project, its sub-grantees and beneficiaries.

Orientation The set of authorized pesticides and requirements for safer use are established through Section 3 of the document, the Pesticide Evaluation Report (PER), which assesses the 12 pesticide risk evaluation factors (a through l) required by 22 CFR 216.3(b).

The Safer Use Action Plan in Section 4 provides a succinct, stand-alone statement of compliance requirements, synthesized from the 12-factor analysis. It also provides a template for assigning responsibilities and timelines for implementation of these requirements, very similar to the way an EMMP (Environmental Mitigation and Monitoring Plan) would. The FTF ATT/Sub-grantees Project subject to this PERSUAP has already completed such an EMMP template and submitted it to its AOR/COR.

1.2 USAID Environmental Regulations Development

From 1974 to 1976, over 2,800 Pakistan malaria spray personnel were poisoned (5 to death) by insecticide mishaps on a USAID/WHO anti-malaria program3. In response to this and other incidents arising from USAID programs, a lawsuit was brought by a coalition of environmental groups for USAID’s lack of environmental procedures for overseas projects. USAID, in response to the lawsuit, drafted 22 CFR 216 (Reg. 216). This regulation, which was updated in 1979 to include extraterritorial affairs in response to changes in the scope of the application of the National Environmental Policy Act (NEPA), now guides most USAID activities that could have potentially negative environmental impacts.

3 http://www.ncbi.nlm.nih.gov/pubmed/74508

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1.3 Regulation 216

According to Regulation 216, all USAID activities are subject to analysis and evaluation via – at minimum – an Initial Environmental Examination (IEE), and – at maximum – an Environmental Assessment (EA). One IEE was written in 2011 to cover FTF projects. It recommended that a PERSUAP be produced to deal with reducing risks with use of pesticides on the FTF projects. This 2013 FTF ATT PERSUAP responds to those IEE recommendations.

A large part of Regulation 216 – part 216.3 – is devoted to pesticide use and safety. Part 216.3 requires that if USAID is to provide support for the use of pesticides in a project, 12 pesticide factors must be analyzed and recommendations be written to mitigate risks to human health and environmental resources. This plan must be followed up with appropriate training, monitoring and reporting for continuous improvement on risk reduction and adoption of international best practices for crop production, protection and pesticide use safety is strongly encouraged.

Pesticide Definition

For the purposes of this PERSUAP, the word pesticide is used, following EPA’s guidelines4, for the following: fumigants, insecticides, miticides/acaricides, nematicides, molluscicides, fungicides, antimicrobials, bactericides/biocides, microbicides/antibiotics, herbicides, rodenticides, avicides, algicides, ovicides (kill eggs), disinfectants/sanitizers and anti-fouling agents. Even biological agents such as biopesticides, microbial pesticides, repellents, attractants/pheromones, defoliants, dessicants and insect growth regulators are included as pesticides.

FTF ATT/Sub-grantees Support for Pesticide Use

“Support for pesticide use” by the FTF ATT/Sub-grantees Project was defined and agreed upon at the outset of this PERSUAP study as potentially including:

Use or support by Sub-grantees or farmers on demonstration farms, Support for promotion or use during Sub-grantee project training of farmers.

Pesticides rejected by this PERSUAP analysis cannot be ‘supported or used’ for any of the above project activities, unless an Environmental Assessment (EA) is performed.

1.4 The Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP)

In the late 1990s, a USAID Bureau for Africa, East Africa Regional staff member developed the Pesticide Evaluation Report and Safe Use Action Plan (PERSUAP) concept as a tool to analyze the pesticide system or sector in any given country or territory. The PERSUAP tool focuses on the particular circumstances, crops, pests and IPM/pesticide choices of a project or program. This approach analyzes the pesticide sector or system from registration to import through use to disposal, and develops a location-specific pesticide risk profile based on the analysis. A PERSUAP is generally recommended by and submitted as an amendment to the project IEE or an EA.

4 http://www.epa.gov/pesticides/about/types.htm

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1.5 Integrated Pest Management—USAID Policy

In the early 1990s, USAID adopted the philosophy and practice of Integrated Pest Management (IPM) as official policy. IPM is also strongly promoted and required as part of Regulation 216.3. Since the early 2000s, IPM—which includes judicious use of ‘safe’ pesticides—has been an integral part of Good Agriculture Practices and is increasingly considered to constitute best management practices in agriculture.

A good definition of IPM from UC-Davis5 follows: “Integrated pest management (IPM) is an ecosystem-based strategy that focuses on long-term prevention of pests or their damage through a combination of techniques such as biological control, habitat manipulation, modification of cultural practices, and use of resistant varieties. Pesticides are used only after monitoring indicates they are needed according to established guidelines, and treatments are made with the goal of removing only the target organism. Pest control materials [pesticides] are selected and applied in a manner that minimizes risks to human health, beneficial and nontarget organisms, and the environment.”

1.6 Ghana FTF ATT/Sub-grantees PERSUAP Methodology

At Accra, in addition to interviewing IFDC staff, the team visited GEPA to discuss pesticide registration issues and to get a copy of the most recent (June 2013) list of registered pesticides. The team also visited the Plant Protection and Regulatory Services Directorate (PPRSD), Ministry of Food and Agriculture (MOFA) Extension Services and a local representative of Crop Life International (CLI) Ghana office.

In the north, where the project will be implemented, around Tamale, Savelugu, Walewale, Bolgatanga, Navrongo and Paga, the team visited irrigation schemes, villages, farmers, MCC farm service centers, two pesticide wholesalers, numerous agrodealers, agronomists, the regional MOFA director and regional GEPA director.

The study commenced during late November to early December 2013, which is just following the busy rainy season from May to November. The complexity of the tasks needed for this study required that the consultants provide wide-ranging and cutting-edge IPM, agronomic, business, entomological, phytopathological, rodentological, weed and chemical advice, in addition to environmental compliance interpretation. In order to make this PERSUAP study unbiased and as objective as possible, pesticide Active Ingredients (AIs) are chosen as the common denominator for analysis, and product brand names were used secondarily, so as not to bias the study.

The strategy used for writing this PERSUAP is for it to contain as many links to websites with best practices as possible, both to make it easier to use (reduce the report’s length and thickness) and more up-to-date or accurate (as websites are updated, but static information is not). So, instead of having numerous Annexes containing pesticide safety equipment recommendations or safe pesticide use practices; hot-linked websites now take their place. However, if project participants do not have access to the Internet, the ATT Project should reproduce and distribute key information.

5 http://www.ipm.ucdavis.edu/IPMPROJECT/about.html

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1.7 Ghana FTF ATT/Sub-grantees PERSUAP General Findings

Northern Ghana rainy season crops, primarily rice and maize, were being harvested at the time of the study. Other rainy season crops include vegetables okra, onion, tomato, chili peppers, spinaches, groundnut and some soybean. At irrigation sites, standing soybean crops were in the flower stage.

At the time of the PERSUAP study, irrigated dry season crops were already being planted in places where there are dams or reservoirs with irrigation canals. These crops include rotations of a second rice crop, chili peppers, spinaches, onions, green maize, and cowpea. Some relay crops of green maize (eaten fresh roasted) are grown during January to March, between other crops. Most farmers save their seed for use the following season, and thus it is not treated with seedling-protecting fungicides and systemic insecticides. Hybrid seeds are seen as too expensive, as are synthetic mineral fertilizers.

Almost all potential beneficiary farmers in the north use hand-pumped knapsack sprayers. Some farmers have two sprayers, one exclusively for herbicides, and the other for insecticides and occasionally for fungicides. Few farmers use fungicides. Farmers who had taken part in past MCC and Advance Project activities had and used project-donated PPE.

Since it was the end of the rainy season, the pesticide inventories of agrodealers were at their lowest point of the season, although what was left was reasonably representative of what is sold during the rainy season. During the rainy season, more open market tabletop sellers appear and more small agrodealer shops open.

Interviews with agronomists and farmers found that the following issues or production constraints are important for the three ATT crops: maize, rice and soybean.

The following crop constraints were found to be common in the north of Ghana:MaizeMaize: 2-3 leaf stage Weeds tillers,

hoeing,herbicides recommended by agrodealers

Birds (crows, partridge, quelea)

Scaring,Scarecrow

Rodents Scaring,Traps,Poison bait with zinc phosphide, carbofuran, or endomycin antibiotic

Maize: Vegetative stage Striga weed nothingTermites lambda-cyhalothrin or

deltamethrin on stalksFuradan (carbofuran) on soilMixtures of cypermethrin + dimethoate, or deltamethrin poured into a hole cut in termite mound

Stalk borers Plow stalks under

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Grasshoppers insecticides recommended by agrodealers

Spodoptera armyworms insecticides recommended by agrodealers

False smut occasional do nothingMaize blight occasional do nothingMaize streak virus occasional uproot and destroy plants,

do nothingMaize: Ear grain milk stage Earworm insecticides recommended by

agrodealersBirds scaring,

scarecrowMaize: Storage Weevils Actellic (pirimiphos-methyl)

Topstoxin (aluminum phosphide – not allowed per this PERSUAP)

RiceRice: Vegetative stage Pre-Emergence Weeds Alligator (pendimethalin

400EC)Stomp BASF (pendimethalin455)Activus (pendimethalin 500EC)glyphosate

Post-Emergence Weeds Orizo Plus propanil 360 + 24D acid 200 (but, farmers are unhappy when it drifts to veggies)

Gall midge sanitation,spray weeds,insecticides recommended by agrodealers

Stem borers insecticides recommended by agrodealers

Hispid larvae leaf miners insecticides recommended by agrodealers

Stalk-eyed borer insecticides recommended by agrodealers

Caseworm insecticides recommended by agrodealers

False smut fungicides recommended by agrodealers

Brown spot Topsin M (thiophannate-methyl),fungicides recommended by agrodealers

Virus possible nothingRice: Grain stage Birds scaring,

scarecrowsRice blast occasional nothing

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Rice: Storage Weevils Actellic (pirimiphos-methyl)Topstoxin (aluminum phosphide – not allowed per this PERSUAP)

SoybeanSoybean: Vegetative stage Pre-Emergence Weeds tillers,

hoeing,herbicides recommended by agrodealers

Spodoptera armyworms insecticides recommended by agrodealers

Soybean: Flowering stage Thrips—flower drop insecticides recommended by agrodealers

Heavy rain—flower drop nothingSoybean: Pod stage Green stinkbugs insecticides recommended by

agrodealersSoybean: Storage Weevils Topstoxin (aluminum

phosphide – not allowed per this PERSUAP)

Other than weeds and herbicides, little knowledge is available at the farm level on the different pesticides recommended for different pests. With the exception of rodents and bird pests, some farmers are not aware of the names of specific pests affecting their crop, particularly small or microscopic pests and diseases that cannot be easily seen. For example on soybean, most farmers were not able to link high flower drop with flower thrips, the cause of the flower drop.

As the PERSUAP team moved from Tamale to Northeast region, the amount of information available at the extension and farm levels did increase somewhat. The number of pests identified by farmers and agronomists for each ATT crop increased, as did information on what to do to manage each, and which pesticides to use. This may be due to the spillover effect of extension information coming from bordering Burkina Faso.

In most cases, interviewed farmers said that they purchase whatever pesticide an agrodealer or pesticide vendor recommends. This reflects the need for additional resources for extension information to reach the farm level. Likewise, some agrodealers did not have sufficient information on types of pests, and pesticides that should be used for each pest. Both farmers and agrodealers could use training on identification of pests and the best pesticides to be used to manage each key pest.

In addition to interviewing farmers and agronomists, the PERSUAP team interviewed two large pesticide wholesalers based in Tamale, many local town and village agrodealers and market tabletop sellers. The following are the active ingredients and products found and inventoried by the PERSUAP team in northern Ghana.

Inventory of active ingredients/products found in northern agrodealer shops, market tabletop sellers or that farmers say they use (Note – this is not a list of pesticides approved for use in this PERSUAP):Seed treatmentscaptan Merpan 50WP

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imidacloprid + thiram mix Momtaz (imidacloprid 25% + thiram 20%)

Insecticidesabamectin Mektin 1.8EC

acetamiprid (systemic) Golan 20SL Makhteshim Agan

acetamiprid + cypermethrin Clomaprid 88 (actamiprid 16 + cypermethrin 72)

acetamiprid + lambda-cyhalothrin Optimal 170 (acetamiprid 20 + lambda-cyhalothrin 150)

alphacypermethrin Cypadem

carbofuran (systemic) Carbodan 3G

chlorpyrifos-ethyl Armaphos 20%ECPyrinex 48ECDursban 4ESunpyrifosD-Ban Super 48EC

chlorpyrifos + deltamethrin Pyrinex Quick 250

cypermethrin Cymethrin

cypermethrin + dimethoate Cymetox Super 280 (cypermethrin 30 + dimethoate 250)Cydim 45EC (cypermethrin 15% + dimethoate 30%)Cymethoate Super

cypermethrin + profenofos Polytrin 336EC

deltamethrin Deltapaz 12.5%

diazinon Diazinon 50EWAkate Suro 50

emamectin benzoate AttackCaiman

endosulfan Thionex

fenitrothion Sumithion

fenvalerate Sumicidin

fenitrothion + fenvalerate Suncombi 30EC (fenitrothion 25% + fenvalerate 5%)Pawa 30EC (fenitrothion 25% + fenvalerate 5%)

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imidacloprid (systemic) Confidor 200SC BayerAkape

imidacloprid + beta-cyfluthrin Vector 210 + beta-cyfluthrin 90 WP

lambda-cyhalothrin: Lambda Super 2.5ECKombat 2.5ECSunhalothrin 2.5ECKilsect 2.5ECIcon 10CSZap 2.5K-Optimal

lambda-cyhalothrin + thiamethoxam Eforia 45EC

mineral oil EOS white mineral oil

neem seed artisanal extract natural neem seed extract plus soap and water

Herbicides24D amine salt (controls broadleaves)systemic pre- and post-emergence rice, maize

Select 722Weedcot SLWiper 720SLBalton 800ErvextraDextraHerbacut

alachlorpre-emergence maize

Lasso

atrazinepre, early post-emergence maize

Agrazine 500SCAgrazine 80WPAtraherb 80WPAtranex 80WP Makhteshim Agan—phasing outAtranex 50SC Makhteshim Agan—phasing outSun AtrazineAtraziller

bensulfuron-methylpre-and post-emergence broadleaf and sedge control in rice

Altidax

bentazonpost-emergence broadleaf maize, rice, soybean

Basagran 480SL BASF

butachlorpre-emergence broadleaf and grass in rice, soy

Butaplus 50EC

glyphosate, isopropylamine saltnon-selective pre-emergence maize,

Uproot 360Wynna 360SL

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rice, soybean Nwurawura 360SLSunphosphate 360SLRival 360SLGlyphogan 360 Makhteshim AganRoundup 360 MonsantoAgasate 40Tackle 480Touchdown SyngentaGlyphaderChemosate

glyphosate + oxyfluorfen Zoomer SC (glyphosate 360 + oxyfluorfen 30) Makhteshim Agan

imazethapyr, ammonium saltpre- and post-emergence soy

Vezir 240SL

nicosulfuronpost-emergence maize

Nicogan 40OD Makhteshim AganArrow 75WDG

paraquatnon-selective pre-emergence maize,rice, soybean

Paraquat dichlorideParazone 3SLPara-Q

pendimethalinpre-emergence rice, soy

Alligator 400ECStomp 330E BASFActivus 500EC Makhteshim Agan

pretiliachlor + pyribenzoxim early post-emergence rice

Solito 320EC (pretiliachlor 300 + pyribenzoxim 20) Syngenta

propanilpost-emergence in rice

Stam F-34

Propanil + 24Dpost-emergence in rice

Orizo Plus (propanil 360 + 24D acid 200)

propaquizafoppost-emergence grasses in soy

Agil 100EC Makhteshim Agan

terbutryne + metolachlorpre-to early post-emergence maize

Terbulor 500EC (terbutryne 167 + metolachlor 333)Makhteshim Agan

Fungicidescopper Kocide DuPont

copper sulfate TopCop tribasic

mancozeb Cotazeb 80%Dithane-M 45 DowKilazeb 80WP

mefenoxam Ridomil Gold Syngenta

mefenoxam + metalaxyl (systemic) Victory 72WP

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sulfur Sulfa 80WDG

thiphanate-methyl Topsin-M 70WP

Rodenticidescarbofuran Carbodan 3G, mixed by farmers with bait

zinc phosphide Zinc phosphide G, mixed by farmers with bait

Post-Harvest Stored Grain Treatmentsaluminum phosphide Topstoxin fumigant (not allowed per this PERSUAP)

herbs artisanal Natural strong smelling herbs

malathion Malathion 700Envigold 70 SL

neem seed artisanal Neem seed and extract

pirimiphos-methyl Actellic

E = EmulsionEC = Emulsifiable ConcentrateG = GranularOD = Oil DispersionSC = Suspension ConcentrateSL = Soluble LiquidWDG/WG = Water Dispersible GranulesWP = Wettable Powder

The most common pesticides used in northern Ghana are herbicides. Indeed many agrodealers’ inventories contained up to three-quarters herbicides, one-quarter insecticides, a rodenticide and occasionally a fungicide. Most of the pesticide products found and inventoried in agrodealer shops and market tabletops contained generic (off-patent) pesticide active ingredients. These are often the most affordable pesticides available for resource-limited smallholder farmers, and are produced by both well-known primary (making novel as well as generic molecules) and secondary (making only generic molecules) international/multinational companies, as well as repackaged by regional and local companies.

The most common generic pesticide AI molecules copied by numerous companies, and found in northern Ghana, include chlorpyrifos-ethyl, cypermethrin, dimethoate, lambda-cyhalothrin, 24D, atrazine, glyphosate, paraquat, pendimethalin and mancozeb. Several of these pesticide AIs do not pass this PERSUAP’s analysis, and cannot be supported or used on or by FTF ATT/Sub grantees activities. Even though most farmers save their seed and do not treat it with pesticides

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before planting it, two seed treatment pesticides were found available for sale: Merpan 50WP (with captan) and Momtaz (with imidacloprid + thiram).

Multinational company’s (Arysta, BASF, Bayer, Dow, Dupont, Monsanto, Syngenta) products are poorly represented in northern Ghana. These are identified above by red text, as are the products of Makhteshim Agan, a secondary international company known for producing high quality generic products. Many similar products with the same active ingredients are made by other companies (mostly from China and to a lesser degree from India) and marketed in Ghana, often with lower and more affordable prices. However the quality of these products may or may not be the same as similar products produced by the international and multinational companies, which have reputations to pay for and protect. Thus, if farmers buy cheaper products, they often get what they pay for. Makhteshim Agan is the only international company in northern Ghana (based in Tamale) with technical field support for their products. Their representative was the only wholesaler agrodealer interviewed by the PERSUAP team that fully understood each product and what it could and could not be used for. Furthermore, Makhteshim Agan understood the pesticides that are being scrutinized internationally for health or environmental issues. For example, they are discontinuing the production and sale of their own products (Atranex product names) containing atrazine, which is a known ground water pollutant, and Makhteshim has replacement herbicides available.

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SECTION 2: BACKGROUND

2.1 Ghana Country Background

Including inland water bodies, like the very large Volta Lake, Ghana covers 238,539 km2 and is located on the south central coast of West Africa. The country shares borders in the east with Togo; in the north with Burkina Faso; and in the west with Cote d’Ivoire. Most of Ghana lies below 600 m; less than 10 % of the land is above 300 m, few places have elevations above 1000 m (http://www.fao.org/ag/agL/swlwpnr/reports/rc_codes.htm). The lowest areas are the middle Volta Basin and along the coast.

Generally, rainfall decreases and temperature increases from the rain forest zone in the south to the savanna zone in the north. By far the most important climatic factor influencing vegetation in Ghana is rainfall. The wet evergreen forest lies within the wettest part of the country and receives a mean annual rainfall over 2,000 mm. The drier forest areas receive between 1,000 and 1,500 mm, whereas in the northern savanna annual rainfall ranges between 800 and 1,000 mm. The amount of rainfall however, varies within the vegetation zones owing to the local effect of relief. The driest area of the country is the coastal savanna, where the total annual rainfall ranges between 600 and 800 mm.

Figure 1: Ghana Map

Agriculture in Ghana accounts for about 25% of GDP and employs over 60% of the workforce. Primary crops include cocoa, rice, maize, cassava, peanuts, shea nuts, bananas and timber.

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Figure 2: Agricultural Land Use, UNFAO (United Nations Food & Agriculture Organization)

Topography of GhanaThere are six broad physiographic regions: the coastal plains, the Buem-Togo ranges, the forest dissected plateau, the southern Voltaian plateau, the savanna high plains, and the Gambaga escarpment. The Volta Basin takes up most of south-central Ghana and Ghana's highest point is Mount Afadjato, which is 885 m and is found in the Akwapim-Togo ranges. The climate is tropical and the eastern coastal belt is warm and comparatively dry, the southwest corner of Ghana is hot and humid, and the north savannah of Ghana is hot and dry.

Lake Volta, the world's largest artificial lake, extends through large portions of southeastern Ghana and many tributary rivers such as the Oti and Afram rivers flow into it. In the north where ATT is implemented, the Black and White Volta Rivers flow through, there are numerous water catchment schemes, some serving local villages with piped-in water (from the MCC project), while most other more remote villages rely upon a central or nearby well to get water.

Southern Ghana contains evergreen and semi-deciduous forests consisting of commercially valuable trees such as mahogany, odum, ebony and it also contains much of Ghana's oil palms and mangrove forests. In the northern savannah part of Ghana, where ATT is implemented, dominant trees include wild shea nut trees, baobabs, acacias, as well as stands of commercial teak and mango. Almost every town has artisanal shea nut oil and butter processing facilities. And, there is a mango processing facility near Tamale.

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Figure 3: Topography or Relief of Ghana, UNEP (United Nations Environment Program)

The FTF ATT project focuses on producers farming primarily at altitudes of 100-300 MSL (Meters above Sea Level). Most of the target sites are flat with little topographic variation until one approaches the Burkina Faso borders. Climate of GhanaOver the whole country the mean monthly temperature is about 25oC. Although temperatures are uniformly moderate, there are important variations over different parts of the country as a result of altitudinal variations in the landscape and distance from the sea. In the coastal areas, due to the modifying influence of the sea, the annual difference between the maximum and the minimum monthly temperature is about 5o-6oC. On the other hand, much farther inland, the difference is between 7o-9oC. Diurnal temperature ranges are more significant than the monthly ranges. In the forested zones of the south the mean diurnal range is still moderate, but in the northern savannas the difference may be as much as 14o-20oC, especially during the Harmattan season.

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Figure 4: Ghana rainfall, FAO

As can be seen from the above figure 4, the FTF ATT project focuses on the driest parts of the country, those with 948 to 1103 mm of rainfall a year. These are generally the most food insecure parts of the country due to risks from receiving slightly lower rainfall, and the resulting drought.

2.2 IFDC FTF ATT Project Background

The Feed the Future USAID Agricultural Technology Transfer Project and Sub-grantees (FTF-USAID ATT) is a five-year activity funded by the U.S. Agency for International Development’s Ghana Mission (USAID/Ghana), to increase the competitiveness of rice, maize and soya value chains to foster broad-based and sustained economic growth through the increased availability of agricultural technologies to increase and sustain productivity in Northern Ghana. The program will focus on the Ghana Feed the Future (FTF) intervention zone, which covers the three regions of northern Ghana: Northern, Upper West and Upper East plus the Northern parts of Brong Ahafo and Volta regions, and will address technology constraints in Ghana’s FTF target crops of rice, maize and soy.

IFDC is the lead implementer, with additional technical support provided through Iowa State University (ISU) and the Center for Development Innovation (CDI) of the Wageningen University & Research Centre, GAABIC, and other local organizations and public and private sector institutions in Ghana. Research institutions and various departments of the Ministry of Agriculture and other offices within the Government of Ghana will play an important role in providing support to ensure the implementation of regulatory reforms needed for a performing and private sector-driven seed and fertilizer sector in Ghana.

The program supports various actors along the targeted value chains in Ghana. Main stakeholders include producers, agro-input dealers, agricultural marketing enterprises, farm services providers, industrial food and feed processors, private sector actors involved in seed and fertilizer production and distribution, research institutions/laboratories, as well as government and regulatory bodies responsible for creating and maintaining an enabling environment for a dynamic agricultural sector.

2.3 Integrated Pest Management and PERSUAP Precedents

In the mid-1990s, the United Nations Food and Agriculture Organization (UN FAO) organized Integrated Pest Management (IPM) Farmer Field School (FFS) study tours and irrigated rice field trials and training for farmers by Ghanaian university and Ministry of Food and Agriculture (MOFA). Eighty percent of trained farmers adopted IPM tools and tactics, and doubled their yields.

A five-year compact with Millennium Challenge Corporation (MCC) was begun in 2006 in Ghana6, in part to assist the rural agribusiness sector with irrigation and crop storage infrastructure and advice. In numerous places around Tamale, Farmer Based Organizations (FBOs) and Agro-Business Centres (ABCs) were started and grain/equipment storage warehouses/FBO/ABC headquarters were built. 6 https://www.mcc.gov/documents/agreements/080106_ghana_compact_summary.pdf

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Then in 2011, the World Bank worked with MOFA and others and produced a state of the art Ghana-specific Pest Management Plan. This PMP covers the three ATT crops, among others, and their major pests. Also, in 2011, IFDC’s Marketing Inputs Regionally (MIR) Plus Project, which aimed at facilitating the development of a regional agri-inputs market in West Africa, produced a Pesticide Handling Manual for target farmers.

ACDI-VOCA, in 2012, produced a PERSUAP for their Ghana Agriculture Development and Value Chain Enhancement (ADVANCE) Project. ADVANCE worked in northern Ghana on the same three crops as ATT, and was in the process of project closeout while the ATT PERSUAP team was present.

2.4 Ghana Pesticide System Risks and Areas for Improvement

Problems, constraints or risks in the Ghana pesticide cycle of use

Recommendations for government, donors, NGOs, private sector & projects

Priority

Pesticide shops with limited safety equipment (PPE) available

Source and subsidize (cost share) the purchase of quality PPE for beneficiaries, and make it a condition for receipt of assistance.

High

Pesticide shops with limited sprayer replacement parts available

Training for pesticide shops Med

Limited resources for extension Do demonstration farms and field days.

High

Most farmers are unaware of acute and chronic health risks from use of pesticides

Do repeated training on pesticide risks and safety

High

Some farmers use fumigants containing aluminum phosphide for grain stores in their homes (note: not allowed in this PERSUAP)

Do repeated training on pesticide risks and safety

High

Very little use of PPE by farmers mixing and applying pesticides

Do training on proper PPE to use; subsidize quality PPE and encourage the development of professional pesticide spray services.

High

Over- and under-applications of pesticides and no record-keeping

Do repeated training on calibration & application. Promote the development and use of spray and record-keeping services organized or channeled through cooperatives or associations.

Med

Pesticides applied at wrong time of day and/or with winds too high

Do repeated training on application timing risks and encourage the development of professional pesticide spray services.

Med

Back-pack sprayers leak onto spray applicators’ backs; leaks soak into

Do repeated training on sprayer maintenance and encourage the

High

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clothing, run down into their boots, run down their arms and into gloves/onto hands

development of pesticide spray services.

Some empty pesticide containers are thrown into the field or along the road

Do repeated training on proper disposal (rinse, puncture, bury). Encourage the development of professional pesticide spray services trained to collect and dispose of containers.

Med

Most farmers will not pay for hybrid seed or fertilizers

ATT has as its goal to encourage and provide access to these inputs

High

Positive Pesticide System Opportunities in Ghana GEPA has produced and biannually updates a list of pesticides registered for import and use in

Ghana Ghana’s list of registered pesticides contains information on specific crops and uses MOFA, with World Bank support, has produced a national Pest Management Plan with IPM

tools/tactics for many crops PPRSD has been involved in teaching GAPs and IPM tactics to row crops farmers, reducing

overall need for pesticides Crop Life International (CLI) is leading an effort to promote spray services and collect, rinse,

puncture and recycle empty pesticide containers One company, Makhteshim Agan, has regional representatives (including one in Tamale) to

provide backup support to the products they sell Most pesticide labels are written in English and have charts of crops, pests & dosages for

recommended use No pesticides were found being imported and sold in (breakable) glass bottles Most urban and rural pesticides stores visited were well-organized, well-ventilated and with a

cement or tile floor for easy cleanup

Conclusion: There still remain some issues with pesticides that can increase the risk for errors to occur, and thus the risks that farmers, farm family members, and even consumers may be acutely or slowly poisoned and/or their environment may become polluted and damaged. Thus the pesticide risk profile for northern Ghana is higher than might be encountered in some more developed countries. Extra care will be needed with emphasizing and implementing risk mitigation measures that work.

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SECTION 3: PESTICIDE EVALUATION REPORT (PER)

This part of the PERSUAP, the PER (Pesticide Evaluation Report), addresses pesticide choices based upon environmental and human health issues, uses, alternate options, IPM, biodiversity, conservation, training, PPE options, monitoring and mitigation recommendations according to the twelve Regulation 216.3(b)(1) Pesticide Procedures Factors, outlined and analyzed below.

Reg. 216.3(b)(1)(i) stipulates: “When a project includes assistance for procurement or use, or both, of pesticides registered for the same or similar uses by USEPA without restriction, the Initial Environmental Examination for the project shall include a separate section evaluating the economic, social and environmental risks and benefits of the planned pesticide use to determine whether the use may result in significant environmental impact. Factors to be considered in such an evaluation shall include, but not be limited to the following:” (see box, right)

The PERSUAP can recommend or propose specific pesticides to replace those highly used or desired pesticides that are rejected, but the job of recommending pesticides for specific uses against specific pests is usually the mainstay of a ministry of agriculture’s extension service, if they have such a capability. In Annex 1, this PERSUAP proposes preventive IPM choices available to integrated with pesticides recommended by extension services. Usually, a PERSUAP should not replace an extension service and the expert advice that they can provide.

It would be ideal to find pesticides for every need that are Class IV acute toxicity, have no chronic human health issues, no water pollution issues and no aquatic ecotoxicity issues. Such pesticides do not exist. Most pesticides, including “natural” pesticides, have toxicity to at least one aquatic organism, or bees, or birds.

3.1 Factor A: USEPA Registration Status of the Proposed Pesticide

THE 12 PESTICIDE FACTORSFactor A. USEPA Registration Status of the Proposed Pesticides

Factor B. Basis for Selection of Pesticides

Factor C. Extent to which the proposed pesticide use is, or could be, part of an IPM program

Factor D. Proposed method or methods of application, including the availability of application and safety equipment

Factor E. Any acute and long-term toxicological hazards, either human or environmental, associated with the proposed use, and measures available to minimize such hazards

Factor F. Effectiveness of the requested pesticide for the proposed use

Factor G. Compatibility of the proposed pesticide use with target and non-target ecosystems

Factor H. Conditions under which the pesticide is to be used, including climate, geography, hydrology, and soils

Factor I. Availability of other pesticides or non-chemical control methods

Factor J. Host country’s ability to regulate or control the distribution, storage, use, and disposal of the requested pesticide

Factor K. Provision for training of users and applicators.

Factor L. Provision made for monitoring the use and effectiveness of each pesticide

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USAID project activities are effectively limited to promoting during training, recommending, buying, subsidizing, financing or permitting on demonstration farms, pesticides containing active ingredients (AIs) in products registered in Ghana by GEPA and in the US by the EPA for the same or similar uses, without restriction. Emphasis is placed on “similar use” because often the crops and their pest species found overseas are not present in the US, and therefore pesticides may not be registered for the exact same use, but often are registered for similar crops, pests, methods of application, and pest situations.

The USEPA classifies pesticides according to actual toxicity of the formulated products, taking formulation types and concentrations into account, thus generally making the formulated product less toxic than the active ingredients alone would be. This method of classifying acute toxicity is accurate and representative of actual risks encountered in the field. By contrast, the WHO acute toxicity classification system is based on the active ingredient only. For a comparison of USEPA and WHO acute toxicity classification systems, see Annex 6.

In the USA, only, some specific commercial pesticide products are labeled as Restricted Use Pesticides (RUPs) due to inordinate risks, usually under specific circumstances of use, such as formulation or crop. However, for each AI, which may be present in a number of RUP products, there are generally additional or other products, formulations and uses—with the exact same AI—that do not possess the same risks and are thus labeled or determined to be General Use Pesticides—that is—not RUP. Ergo, for each AI, there may be RUP and non-RUP products depending upon risks they do or do not pose.

Analysis: Annex 7 provides EPA registration status analysis for each AI found in selected pesticides currently registered (and proposed for imminent registration) for import, imported and used in the Ghana. Annex 7, column number three, labeled “EPA Registered” has a “yes” if the AI is registered by EPA in pesticides for same or similar uses. If column three has a “no” it is not registered by EPA and is thus one reason for shading the AI line with red—signifying that it is not approved by the PERSUAP Annex 7 analysis. Pesticide AIs that pass this registration factor, and all following pertinent factor analyses, are shaded with green.

Issue: Pesticide products analyzed and found containing active ingredients not EPA-registered or in same or similar RUP pesticide products

The following is the result of the Factor A analysis, showing pesticide AIs in GEPA-registered products, imported and used by farmers, that are NOT in EPA registered products, are in RUP products or are too toxic for ATT/Sub-grantee beneficiaries.

2013 Ghana ATT PERSUAP-Rejected Pesticide AIs/products

Rejected Fumigant aluminum phosphide (Topstoxin, RUP)

Rejected Insecticides alphacypermethrin (Cypadem, RUP) cadusafos (not EPA registered) carbofuran (Carbodan 3G, RUP) carbosulfan (not EPA registered) chlorpyrifos-ethyl (Armaphos 20%EC, Pyrinex 48EC, Dursban 4E, Sunpyrifos, D-Ban

Super 48EC, Pyrinex Quick 250, Polytrin 336EC, chlorpyrifos-ethyl not registered by EPA for spraying on crops)

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cypermethrin (Clomaprid 88, Cymethrin, Cymetox Super 280, Cydim 45EC, Cymethoate Super, cypermethrin not registered by EPA for agricultural use)

diazinon (Diazinon 50EW, Akate Suro 50, RUP for all horticultural products) emamectin benzoate (Attack, Caiman, RUP for all horticultural products and uses) endosulfan (Thionex, Thiodan, Endocoton, RUP, POPs list chemical) fenitrothion (Sumithion, Suncombi 30EC, Pawa 30EC, not registered by EPA for

agricultural use) fipronil (not registered by EPA for agricultural use) fenvalerate (Sumicidin, not EPA registered) lambda-cyhalothrin + acetamiprid (Optimal 170 with lambda-cyhalothrin at 150g/L is too

high a concentration for safety) oxamyl (all uses RUP) thiocyclam hydrogen oxalate (not EPA registered)

Rejected Fungicides carbendazim (EPA registrations are not for agricultural uses) dichlofluanid (not EPA registered) fenpropimorph (not EPA registered) maneb (EPA registrations cancelled)

Rejected Herbicides 2 4 D isobutylate (not EPA registered) alachlor (Lasso, all products RUP) atrazine (Agrazine 500SC, Agrazine 80WP, Atraherb 80WP, Atranex 80WP, Atranex

50SC, Sun Atrazine, Atraziller, known water pollutant) bromacil (known water pollutant) butachlor (Butaplus 50EC, not EPA registered) cycloxydim (not EPA registered) diuron (known water pollutant) ethephon (Class I, too toxic for smallholder farmers) haloxyfop (not EPA registered) metolachlor (known water pollutant) paraquat dichloride (Paraquat Dichloride, Parazone 3SL, Para-Q, all uses RUP) pretiliachlor + pyribenzoxim (Solito 320EC, neither pretilachlor or pyribenzoxim EPA

registered) profenofos (RUP) propaquizafop (Agil 100EC; not EPA registered) terbutryne + metolachlor (Terbulor 500EC, terbutryne not EPA registered, metolachlor

known water pollutant)

Rejected Rodenticides carbofuran (Carbodan 3G, RUP) zinc phosphide (Rat Killah 50G, concentration too high for safety)

Compliance Requirements ATT project/Sub-grantees will not promote, finance and use on demonstration farms,

pesticides not registered by EPA for same or similar use, those classified by EPA as RUP products, or those deemed too toxic for smallholder farmers to use.

If ATT wishes to authorize the support of any non-EPA registered or RUP product in the, including use on any demonstration farm, then a full Environmental Assessment (EA)

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must be done and approved by the AFR BEO. ATT project/Sub-grantees get and retain copies of the MSDS for each pesticide that their

beneficiary farmers use frequently.

3.2 Factor B: Basis for Selection of Pesticides

This procedure generally refers to the practical, economic and/or environmental rationales for choosing a particular pesticide. In general, best practices and USAID – which promote IPM as policy – dictate that the least toxic pesticide that is effective is selected. Fortunately, as a general but important trend, the more toxic pesticides (Class I) are decreasing in number worldwide and the number of least toxic pesticides (Class IV) is increasing. Thus, farmers may be able to choose products of lower toxicity (Class III and IV/U pesticides), especially if PPE is not available or used.

Farmers in the north of Ghana use a limited number of available pesticides, and most often do so based upon the advice of agrodealers. Sometimes they rely on advice from neighbors and occasionally from extension agents. Most will select the lowest cost pesticides, which is not ideal as some of the low-cost products may not be sufficiently effective.

Recommendations:

Farmers require training on how to choose the correct pesticide. If there is a choice, use products with lower human and ecological toxicities (see Annex 7).

3.3 Factor C: Extent to Which the Proposed Pesticide Use Is, Or Could Be, Part of an IPM Program

USAID promotes training in and the development and use of integrated approaches to pest management tools and tactics whenever possible. This section emphasizes how any of the approved pesticides can be incorporated into an overall IPM strategy, as the ultimate pest control tools, following exhaustion of all preventive tools and tactics.

Certainly, some of the approved pesticides are more useful and gentler on the environment than others; Annex 7 shows relative toxicities of each pesticide AI. In general, most of the natural products and extracts are less disruptive to the ecosystem. However, agricultural production cannot rely solely on the use of natural pesticides, unless they are certified as Organic.

Good crop management practices can strongly affect the success of IPM, and good agronomic or cultural practices are the most basic and often the most important prerequisites for an effective IPM program. A healthy and vigorous crop optimizes both capacity to prevent or tolerate pest damage while maintaining or increasing yield potential.

As state of the art, the USA, through the USDA supports several programs aimed at investigating and developing IPM tools and tactics. These include NIFA7 (the National Institute of Food and Agriculture) and the National Sustainable Agriculture Information Service of the National Center

7 http://www.csrees.usda.gov/pesticides.cfm

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for Appropriate Technology8 (NCAT). Ghana has a cadre of experts in MOFA who recognize the importance of these tools and techniques, and are ready to implement them in crop-specific PMPs. And, in 2011, Ghana produced a national PMP.

Approved pesticides can be fitted into GAP and IPM programs, and their use can be reduced when in combination with other preventive tools, as follows:

Soil testing Resistant varieties Certified clean seed Seed treatments Soil solarization Raised-bed production Mulches Proper seeding/thinning rate Soil moisture testing Organic fertilizers/compost Synthetic fertilizers Crop rotation Green manures Manipulate plant/harvest time Trap crops Pruning Pest ID correct Weekly scouting/monitoring Sticky traps for monitoring Pheromone traps for monitoring Weeding by hoe Weeding by tiller Soil conservation practices Crop residue destruction Artisanal (homemade) pesticides Spot pesticide treatments instead of blanket treatment Farmscaping9

To further put IPM tools and tactics into practice, Annex 1 contains a detailed Crop-Pest-preventive IPM matrix for each crop to be grown by ATT-assisted beneficiary farmers, noting most major pests of each crop, a list of preventive tools and tactics recommended for the same pests in countries with significant commercial production recommended by leading state extension services in the USA.

Northern Ghana farmers do use a few GAP and preventive IPM tools like crop rotation, raised-bed, use of scarecrows and physically scaring birds and rodents early in the morning from newly-planted fields, use of artisanal pesticides made from neem seed and strong-smelling herbs, crop residue destruction, and weeding by hoe. However, few farmers interviewed use mechanization, hybrid seed, soil tests or fertilizers.

Recommendations:

8 http://www.attra.ncat.org/ 9 https://attra.ncat.org/attra-pub/farmscape.html

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Preventive IPM tools and tactics for each crop-pest combination (Annex 1) should be used before and combined with and the choice is made to purchase and use synthetic pesticides.

A national PMP has been produced with World Bank assistance, and should be used.

3.4 Factor D: Proposed Method or Methods of Application, Including the Availability of Application and Safety Equipment

This section examines how the pesticides are to be applied, to understand specific risks with different application equipment available and application methodologies, and the measures to be taken to ensure safe use for each application type. Pesticides can and do enter the body on the hands, skin or eyes when mixing and from splashes, on back, arms and hands from leaky backpack sprayers when spraying, through the nose and mouth as vapors while spraying and from spray drift, and by mouth from ingestion on food or cigarettes.

Findings from ATT PERSUAP team field visits show that farmers predominantly use leaky hand-pumped piston knapsack sprayers. Some farmers have two sprayers, one exclusively for herbicides and the other primarily for insecticides. The PERSUAP team found no tractor-drawn sprayers anywhere in the north. Farmers who worked with the ADVANCE or MCC projects had PPE and used it; others did not. Most farmers do not calibrate spraying properly, leading to over- and under-dosing.

Recommendations

If pesticides are used, promote the concept of spray service providers and train farmers on proper sprayer calibration, use, maintenance, use of PPE and empty container disposal by rinsing, puncturing and burial.

Pregnant or lactating females, immune compromised individuals (HIV), and children should not be permitted to apply pesticides.

3.5 Factor E: Any Acute and Long-Term Toxicological Hazards, either Human or Environmental, Associated With the Proposed Use, And Measures Available To Minimize Such Hazards

This section of the PERSUAP examines the acute and chronic toxicological risks associated with the proposed pesticides. Information on specific risks to environmental resources and how to mitigate or minimize such risks are detailed below under Factor G.

Pesticides are poisons, and nearly all of them—including natural ones—present acute and/or long-term acute and ecotoxicological hazards, especially if they are used incorrectly. The pesticide AI analysis matrix in Annex 7 contains information on acute and chronic human and environmental toxicological risks for each AI in products registered for use in Ghana.

The PERSUAP team found no documented instances of pesticide poisoning of people or environmental resources, and there were no recorded fish or wildlife kills.

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The Stockholm Convention on Persistent Organic Pollutants (POPs) and Rotterdam Convention’s Prior Informed Consent (PIC) procedure which list banned and highly regulated toxic chemicals, respectively, were not known when Regulation 216 was written, so there is no language directly governing their use on USAID projects. Nevertheless, they present high risks to users and the environment, due to persistence and toxicity. It is thus prudent that they be discussed, and avoided on USAID projects. The following websites contain current lists of all POPs and PIC chemicals: http://www.pops.int; http://www.pic.int. Popular cotton insecticide active ingredient endosulfan (contained in Thionex, Thiodan, Endocoton, Endocel, Phaser) is now on the POPs list; however numerous West African cotton-producing countries have stockpiled it and still use it. It should not be used on ATT’s food crops.

Most northern Ghana farmers do not understand acute and chronic health issues associated with pesticide use.

Recommendation

If pesticide use is supported through training or on demonstration farms, ATT/Sub-grantees train farmers on how to read safety precautions and first aid on pesticide labels and encourage them to use PPE.

The pesticide safer use training required by this PERSUAP should include basic first aid for pesticide overexposure, availability and use of antidotes, and following recommendations found on pesticide Labels and MSDSs for commonly used pesticides.

3.6 Factor F: Effectiveness of the Requested Pesticide for the Proposed Use

This section of the PERSUAP requires information similar to that provided previously, but more specific to the actual conditions of application and product quality. This section considers the possible use of low-cost and potentially low-quality generic products as well as the development of pest resistance to proposed pesticides, both of which will decrease effectiveness (efficacy).

Pesticides are important pest management tools. Many pesticides gradually lose their effectiveness—especially if overused, not calibrated properly, and not rotated with other classes of pesticides—due to the development of resistance by pests. Pest resistance is a heritable and significant decrease in the sensitivity of a pest population to a pesticide that is shown to reduce the field performance of those specific pesticides.

The management of the development of pesticide resistance is an important part of sustainable pest management and this, in conjunction with alternative pest management strategies and Integrated Pest Management (IPM) programs, can make significant contributions to reducing risks to humans and the environment. Annex 7 serves as one tool for managing resistance by providing the class of each pesticide AI, so that project field managers and farmers can rotate pesticides among classes.

Pests known to have developed significant pesticide resistance (especially to older-generation organophosphate, carbamate and synthetic pyrethroid insecticides, strobin fungicides and azine herbicides—see Annex 7 for classes in which each pesticide is categorized) globally:

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Whiteflies Aphids Spider mites Thrips Mealybugs Scales Psyllids Colorado Potato Beetle Corn Earworm Powdery mildew Downy mildew Pigweed Striga

Pesticides with known global resistance by certain pests or diseases (use with care—do careful calculations of dose—and rotate with other classes or families of pesticides)

Most of the synthetic pyrethroid insecticides and miticides Strobin fungicides Glyphosate herbicide Azine herbicides

Issue: Lack of knowledge and information on reduced pesticide effectiveness and resistance. At some point, project field staff and farmers may begin to note that some products no longer work well to control pests in their field, and will likely begin to blame pesticide manufacturers for a weaker product. This could be due to the use of cheap generic products, improper dosing, or the development of resistance. Farmers should be trained to understand the development of resistance, and project implementers should be on the lookout for it during their field visits.

A resistance management strategy should also consider cross-resistance between pesticides with different modes/target sites of action. Pests may develop cross-resistance to pesticides based on mode/target site of action.

The website http://www.pesticideresistance.com/ can be used to search for specific known resistance issues in countries with certain pest or disease resistance to specific pesticide AIs with the resources to buy and use large quantities of pesticides. Fungicide resistance and rotation recommendations are found on the Fungicide Resistance Action Committee (FRAC) website http://www.frac.info/frac/index.htm.

If pesticide use is warranted and a risk of pesticide resistance development is identified, a Resistance Risk Management approach should be followed. The following section details points of concern for both application equipment and pesticide applications.

Ways to address and manage or mitigate pest resistance:

Use IPM to minimize pesticide use: Minimizing pesticide use is fundamental to pesticide resistance management. IPM programs incorporating pest monitoring in USA states of California, New York, Maryland and Canada have demonstrated 25 to 50% reduction in pesticide use with an increase in crop quality. IPM programs will help determine the best application timing for pesticides (when they will do the most good), thus helping to reduce the number of applications.

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The use of nonchemical strategies, such as pest exclusion (e.g., screening, microtunnels, greenhouses), host-free periods, crop rotation, biological control, and weed control may reduce the need to use chemicals and consequently slow the development of pesticide resistance.

Avoid Knapsack Mixes: Never combine two pesticides with the same mode of action in a tank mix (e.g., two organophophate insecticides or two azine herbicides). Such a 'super dose' often increases the chances of selection for resistant individuals. In some cases, mixing pesticides from two different classes provides superior control. However, long-term use of these two-class pesticide mixes can also give rise to pesticide resistance, if resistance mechanisms to both pesticides arise together in some individuals. Continued use of the mixture will select for these multiple-pesticide-resistant pests.

Avoid Persistent Chemicals: Insects with resistant genes will be selected over susceptible ones whenever insecticide concentrations kill only the susceptible pests. An ideal pesticide quickly disappears from the environment so that persistence of a 'selecting dose' does not occur. When persistent chemicals must be used, consider where they can be used in a rotation scheme to provide the control needed and with a minimum length of exposure.

Use Long-term Rotations: Resistance management strategies for insects, weeds, and fungal pathogens all include rotating classes of pesticides. Pesticides with the same modes of action have been assigned the same group number by their respective pesticide resistance action committees, Insecticide Resistance Action Committee (IRAC), Fungicide Resistance Action Committee (FRAC), and Herbicide Resistance Action Committee (HRAC). These group numbers have been included in the treatment tables of this guideline to help clarify when rotating pesticides, which ones can be rotated.

However, the strategies used in rotations differ. For example, with fungicides, it is suggested that classes be rotated every application. With insecticides, a single chemical class should be used for a single generation of the target pest followed by a rotation to a new class of insecticide that will affect the next generation and any survivors from the first generation. Longer use of a single chemical class will enhance the chance of resistance since the survivors of the first generation and the next will most likely be tolerant to that class. Rotating through many chemical classes in successive generations will help maintain efficacy.

Most pesticides available in the north of Ghana contain generic copies of off-patent pesticide AIs, some of which may be of low quality and come without proper agrodealer technical support.

Recommendations

If pesticide use is supported or discussed, Sub-grantees/ATT should encourage farmers to value and buy higher quality products that come with technical support.

The pesticide safer use training required by this PERSUAP and extension activities will include the fundamentals of “safer pesticide purchase,” including to encourage farmers to use quality name-brand products and discourage farmers from using cheap generic products.

If pesticide use is supported or discussed, the pesticide safer use training required by this PERSUAP should teach and emphasize proper sprayer calibration and spray nozzle choice.

If pesticide use is supported or discussed, Sub-grantees/ATT should encourage farmers to use the above resistance risk management plan and websites.

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3.7 Factor G: Compatibility of the Proposed Pesticide Use with Target and Non-Target Ecosystems.

This section examines the potential effect of the pesticides on organisms other than the target pest. Non-target ecosystems include protected areas, species and water resources. Non-target species of concern include fish, honeybees, birds, earthworms, aquatic organisms and beneficial insects.

Biodiversity, protected areas and pesticides in Ghana

Annex 7 compiles the known risks to the different types of terrestrial and aquatic organisms referred to above for each pesticide active ingredient found in pesticide products registered for use in Ghana, found in northern Ghana, and covered by this PERSUAP, so that informed product choices can be made if a pesticide is to be used in or near sensitive areas or resources.

In the 2011 USAID Ghana Biodiversity, Tropical Forests and Climate Change Environmental Opportunities and Threats Assessment (ETOA)10 the word pesticide is used once, as follows: “The modernization of the Agriculture sector is expected to be an important driver of growth in the medium-term on the basis of improved productivity (e.g., adoption of high yield crops, improved seedlings, use of pesticides and spraying technologies, and mass spraying in the cocoa sector) and increased acreage due to factors such as improved irrigation, subsidized inputs, improved mechanization services along the value chain, improved marketing, improved extension services, and improved institutional coordination for agricultural development.”

An Annex to the ETOA report states: “In development of irrigation and water retention infrastructure there is the potential issue of adverse impacts to riparian areas from ill designed infrastructure development and clearing for agriculture. Conversely, there is the opportunity to accommodate riparian function and structure in design of these agricultural programs and to increase local knowledge of the water quality, water quantity, soil stabilization, biodiversity, and forest retention benefits of well managed riparian areas within agricultural settings.”

Although the ETOA study does focus a lot on agriculture, it makes no mention of pesticides as a primary issue of concern for the environment. And, the ETOA Annex mentions agricultural chemicals (p. 21) only in the context of increasing cost of inputs in relation to climatic changes.

Ghana’s Protected Areas and Natural Resources

There is one large national park in northern Ghana, Mole National Park, and one resource reserve, Gbele, shown in Figure 5 below. None of ATT Project’s activities will be implemented in these natural resource areas. The 2011 Ghana ETOA lists numerous additional protected areas in Annex 5. Please refer to this report for complete lists.

10 http://www.encapafrica.org/documents/biofor/ETOA_Ghana_FINAL.pdf

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Figure 5: Ghana Wildlife Protected Areas, http://www.wildlifeghana.com

Most farmers do not understand ecotoxicity and pollution of natural resources associated with pesticide use.

Recommendations

If pesticide use is supported or discussed: Train farmers about ecotoxicity and on how to read ecotoxicity precautions on pesticide

labels and encourage farmers to use PPE. Train farmers on applying pesticides the proper distance (30 meters) from open bodies of

fresh water, and not to wash their sprayers out in ponds, lakes, rivers or streams. Minimize chemical spray drift by using low-pressure sprays and nozzles that produce large

droplets, properly calibrating and maintaining spray equipment, and use of a drift-control agent.

Warn beekeepers of upcoming spray events so that they may move or protect their hives;

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3.8 Factor H: Conditions under Which the Pesticide Is To Be Used, Including Climate, Geography, Hydrology, and Soils

In general, in addition to covering biodiversity and protected areas under Factor G above, this requirement attempts to protect natural resources from the dangers of pesticide misuse and contamination, especially of groundwater resources.

Ghana Climate and Geography

Ghana’s climate and geography are described in the background section to this report, with maps on rainfall and country relief; refer to them for background on this factor.

Ghana Hydrology

The map of Ghana in the background section to this PERSUAP shows the waterways in northern Ghana. In addition to occasional small streams, some irrigation canals from man-made reservoirs not shown, the larger Black and White Volta Rivers clearly bisect northern Ghana. Project sites will include those on irrigation canals near reservoirs as well as some fields along the Volta Rivers.

Ghana Soils

Northern Ghana soils in the area of ATT project sites are primarily red iron-containing acidic Ferric soils. These soils are typically deficient in organic matter and nitrogen, but with high available phosphorous. Grass is the dominant vegetation. Figure 6, below, depicts the major soils present throughout Ghana, and in the north where ATT will be implemented.

Figure 6: Ghana Soils, http://www.fao.org/docrep/008/a0013e/a0013e05.htm

The soils of Ghana are highly weathered with predominantly light textured surface horizons in which sandy loams and loams are the common textural classes. The lower soil horizons have relatively heavier textures varying from coarse sandy clay loams/sandy loams to clays. Heavier textured soils are normally abundant in the valley bottoms, which are ideal for rice cultivation. The B-horizons - subsurface horizons showing features of accumulation or significant alterations - may contain abundant coarse material either as gravel or stone/concretionary materials. The

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coarse nature of the soils has an adverse impact on their physical properties, particularly their water holding capacity. Thus crop water stress is not uncommon during the growing season.

Safer Use Actions/Mitigation

If pesticide use is supported or discussed, assure the following:

Hydrology. Do not spray or rinse pesticide equipment in or within 30 meters of ponds, irrigation and drainage ditches, and other surface waters.

Do not spray pesticides with high toxicities to aquatic organisms before an impending rainstorm, as they can be washed into waterways before breaking down.

Soils: Do not use or recommend for use herbicides or other pesticides with high leaching and groundwater pollution potential (see Annex 7) near drinking water sources, on highly sandy soils or soils with water tables close (2-3 meters) to the surface.

Soils: Since transport of soil particles with pesticides adsorbed to them is a likely transportation route to waterways, employ techniques to reduce farm soil erosion whenever erosion is likely. Such techniques include vegetated buffer strips, green manure, mulching, terracing, employing wind breaks, employing ground covers between rows, planting rows perpendicular to the slope, using drip irrigation, and so on).

3.9 Factor I: Availability of Other Pesticides or Non-Chemical Control Methods

This section identifies less toxic synthetic, as well as non-synthetic or ‘natural’ (extracts of naturally-occurring plants, spices, oils, fatty acids, induced resistance elicitors, minerals, microbes or microbial extracts) pesticide options for control of pests, and their relative advantages and disadvantages. Many of these ‘natural’ pesticides can be toxic to humans, and several are even classified as RUPs due to environmental risks; thus safe pesticide use practices extend to these natural as well as synthetic (produced in laboratories or factories) pesticides.

Annex 1—the heart of this PERSUAP—contains numerous preventive non-chemical control methods for every major pest of every USAID-supported crop in Ghana. It is the intent of this PERSUAP that the ATT Project uses this valuable resource, as well as the national PMP, both of which compile preventive IPM tools and tactics for each pest of each crop. Annex 1 can be considered as a pullout, stand-alone section that can be reproduced as necessary, and should be considered for translation into local languages, lamination, and distribution to farm input supply companies to help advise farmers at point-of-purchase.

Issue: Natural pest controls availability

Natural chemicals: Many non-synthetic chemical IPM tools and technologies are listed in Annexes 4 and 5. The list of natural pesticides likely entering Ghana is not very extensive compared with other countries.

As noted above, under Factor C, farmers do use a few GAP and preventive IPM tools like crop rotation, raised-bed, scaring birds and rodents early in the morning from newly planted fields, artisanal pesticides from local trees and weeds, and weeding by hoe. However, few use mechanization, hybrid seed, soil tests or fertilizers.

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Recommendations

Preventive IPM tools and tactics for each crop-pest combination should be used before and combined with and the choice is made to purchase and use synthetic pesticides.

A national PMP has been produced with World Bank assistance and should be used.

3.10 Factor J: Host Country’s Ability to Regulate or Control the Distribution, Storage, Use, and Disposal of the Requested Pesticide

This section examines the host country’s existing infrastructure and human resources for managing the use of the proposed pesticides. If the host country’s ability to regulate pesticides is inadequate, the proposed action – use of pesticides – could result in greater risk to human health and the environment.

Ghana’s EPA tests and registers pesticides two times a year. Ghana’s Plant Protection Regulatory Services Directorate (PPRSD) does pesticide safety training, enforcement and disposal of obsolete pesticides, but has limited resources. A number of farmers around Tamale have received pesticide safety training and PPE from either MCC or ADVANCE.

Disposal of obsolete pesticides

In 2008, MOFA found old stockpiles of approximately 71 tons of obsolete pesticides (primarily aldrin and monocrotophos from cocoa and oil palm plantations) in Ghana and proposed to properly inventory, repackage, store, transport and dispose of them11. As of 2013, MOFA has inventoried another 100 tons of additional obsolete pesticides to add to this stock, for a total of 170 metric tons12, and these are stored properly awaiting disposal.

Disposal of pesticide containers

Information from the Ghana pesticide system indicates that the issue of the final disposition of empty pesticide containers is well understood. The present solution is to triple-rinse the containers, puncture them to discourage re-use, and bury them. Burning plastic bottles and single-use sachets can lead to the formation of toxic furans and dioxins, and is not recommended. Crop Life Ghana promotes the collection, rinsing and disposal of pesticide containers.

Recommendations

If pesticide use is supported or discussed, assure the following:

ATT/Sub-grantees encourage farmers to purchase inputs from suppliers that provide quality technical backup support; and encourage farmers to use pesticide spray services.

ATT/Sub-grantees provide pesticide safety training and access to PPE especially to farmers not part of the previous MCC or ADVANCE projects.

11 http://www.modernghana.com/news/162193/1/agric-ministry-to-dispose-of-obsolete-pesticides.html 12 http://vibeghana.com/2013/05/05/croplife-ghana-calls-for-education-on-obsolete-pesticides-disposal

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3.11 Factor K: Provision for Training of Users and Applicators

USAID recognizes that, in addition to the use of PPE, safety training is an essential component in programs involving the use of pesticides. The need for thorough training is particularly acute in developing countries, where the level of education of applicators may typically be lower than in developed countries.

If pesticide use is supported or discussed by ATT/Sub-grantees, training in Safe Pesticide Use and target crops GAP/IPM tools and tactics are of important for project beneficiary farmers using pesticides. Additional and refresher trainings are superb means for effecting beneficiary farmer behavioral change, now especially, as they expand their agricultural opportunities.

Many farmers interviewed do not understand how to choose pesticides, properly calibrate a knapsack sprayer or monitor use. This leads to the use of the wrong chemicals for the task and use of incorrect quantities of pesticides.

Recommendation

Farmers require training on how to choose the correct pesticide, knapsack sprayer calibration and record keeping.

3.12 Factor L: Provision Made For Monitoring the Use and Effectiveness of Each Pesticide

Evaluating the risks, impacts and benefits of pesticide use should be an ongoing, dynamic process. Proper pesticide use and pest resistance are two of the risks for which this element is intended, as well as human health and safety and environmental effects.

Record keeping should track quantities and types of pesticides used, where they were used and what they were used for with notes on efficacy. Notes on effectiveness of individual pesticides and pest numbers will help develop a more sustainable pesticide use plan for ATT beneficiary farmers. Records of farmers will need to make note of any reductions in pesticide efficacy experienced, which is the first indication that resistance may be developing, and then a strategy needs to be in place to determine a shift to a different pesticide class, and rotation among classes, to overcome resistance development.

The following aspects should be included in the record keeping system: Local regulatory compliance: A list of country laws related to the use of agrochemicals

for plant protection, short notes on the relevance of the law, dates the laws come into or exit force and MRLs for each crop-pesticide combination.

A pesticide checklist: This list allows agronomists to ensure that the pesticides they are using are registered. It should also provide notes on special safety requirements.

GAPs/IPM measures tried/used (see Annex 1): USAID agronomists should try to incorporate a minimum of at least ten new IPM measures per annum and document their success or failure.

PPE: Lists of the types of equipment made available to applicators, number of pieces, prices and contact details of suppliers, dates when equipment needs to be washed, maintained or replaced. PPE should be numbered or personally assigned to applicators to

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ensure that it is not taken into the home where (as a contaminated material) it could pose a risk to family members.

Monitoring/recording pests: Agronomists should incorporate into their records regular field pest monitoring and identification. This could be done by the agronomists themselves, or if properly trained, by farmers.

Environmental conditions: Field conditions should be incorporated into the record keeping system (for example; precipitation, soil analyses and moisture, soil pH, temperatures and so on).

Information should be transmitted at least annually and ATT should report to USAID on this progress in pesticide safety and GAP/IPM use in annual reports.

Issue: Monitoring by USAID field staff and beneficiary farmers should detect:

Human poisonings and any incidences of chronic health issues. Farm animal and livestock deaths. Any incidences of water pollution. Fish, bird, wildlife or honeybee kills.

Any of the above items should be reported immediately to USAID. Other information should be transmitted at least annually to USAID, and USAID should report on this progress in pesticide environmental and human health safety in annual reports.

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SECTION 4: PESTICIDE SAFER USE ACTION PLAN (SUAP)

4.1 IntroductionThis Safer Use Action Plan, is the definitive statement of IP pesticide compliance requirements and is synthesized from the PER analysis:

Section 4.2, immediately below, enumerates allowed pesticides.

Section 4.3 establishes USAID field monitoring requirements for compliance with safer use conditions

Section 4.4 summarizes the safer use conditions attendant to use/support of these pesticides.

These conditions are then detailed in the EMMP in Annex 13 for assigning responsibilities and timelines for implementation of these requirements, and for tracking compliance.

With respect to pesticides, the Safer Use Action Plan satisfies the requirement for an environmental mitigation and monitoring plan (EMMP). The project EMMP should simply incorporate the SUAP by reference.

4.2 Allowed PesticidesSynthesizing across the PER analysis, ONLY the below-listed pesticides (active ingredients) are permitted for use/support on the FTF ATT project/Sub-grantees.

Upon approval of this PERSUAP, the pesticide active ingredients (AIs) listed as “allowed” in the following table that follows—and ONLY those AIs—may be supported by the Ghana FTF ATT project/Sub-grantees covered by this PERSUAP. Such support is subject to the safer use conditions summarized below and set out in detail in the SUAP, section 4 of this PERSUAP.

Allowed pesticides are those that passed the 12-factor analyses, particularly Factor A (EPA & Ghana Registration and Restricted Use Pesticide—RUP Status) & Factor E (Acute/Chronic Toxicological Hazards), as analyzed and summarized in Annex 7. Synthesizing across the PER analysis, ONLY the below-listed pesticides (active ingredients) are permitted for use/support in Ghana FTF ATT project/Sub-grantees.

List 1: Allowed Pesticides (some allowed only with conditions) found in northern Ghana

Allowed Insecticide AIs registered by Ghana found available in northern Ghana abamectin (Mektin 1.8EC) acetamiprid (Golan 20SL, but only when plants are in vegetative state, not when

flowering due to risk to pollinators and honeybee colony collapse disorder) deltamethrin (Deltapaz 12.5%) imidacloprid (Confidor 200SC, Akape, Momtaz, but only when plants are in vegetative

state, not when flowering due to risk to pollinators and honeybee colony collapse

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disorder) lambda-cyhalothrin (Lambda Super 2.5EC, Karate, Kombat 2.5EC, Sunhalothrin 2.5EC,

Kilsect 2.5EC, Icon 10CS, Zap 2.5, K-Optimal) (in general formulations above 10% are RUP, while most of formulations below 10% are not RUP)

malathion (Envigold 70 SL, for stored grain pests) mineral oil (EOS White Mineral Oil) neem seed artisanal extract (natural neem seed extract plus soap and water) pirimiphos-methyl (Ateco Super 25 EC, for stored grain pests)

Additional Allowed Insecticide AIs registered by Ghana if they become available in the north acephate Bacillus sphaericus Bacillus thuringiensis/BT (for crops and/or stored grain pests) bifenthrin (use only 10% EC and 2.5% ULV formulations) dimethoate Metarhizium anisopliae novaluron permethrin (Antuka EC with pirimiphos-methyl, for stored grain pests; M-Guard EC with

pirimiphos-methyl, for stored grain pests only) pyrethrum natural plant extract (pyrethrins; Agro Blaster EC or Super Agro Blaster, both

1%, for stored grain pests only) pyriproxyfen thiamethoxam (but only when plants are in vegetative state, not when flowering due to

risk to pollinators and honeybee colony collapse disorder)

Allowed Fungicide AIs registered by Ghana found available in northern Ghana captan (Merpan 50WP, seed treatment) copper (cupric) hydroxide (Kocide) (use only acute toxicity Class II or III products; not

Class I) copper sulfate (TopCop tribasic) (use only acute toxicity Class II or III products; not

Class I) mancozeb (Cotazeb 80%, Dithane-M 45, Kilazeb 80WP) mefenoxam (Ridomil Gold, Victory 72WP) sulfur (Sulfa 80WDG) thiophanate-methyl (Topsin-M 70WP) thiram (Momtaz seed treatment mix with insecticide imidacloprid)

Additional Allowed Fungicide AIs registered by Ghana if they become available in the north azoxystrobin copper (fixed or tribasic) (use only acute toxicity Class II or III products; not Class I) copper (cupric) oxide (CuO) (use only acute toxicity Class II or III products; not Class I) cuprous oxide (Cu2O) (use only acute toxicity Class II or III products; not Class I) difenoconazole folpet (likely carcinogen at higher doses used repeatedly over time, so use PPE) fosetyl aluminum metalaxyl propiconazole

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triadimenol (on pre-treated seed for maize only; not for sorghum seed) Trichoderma asperellum

Allowed Herbicide AIs registered by Ghana found available in northern Ghana 2 4 D amine salt (Select 722, Weedcot SL, Wiper 720SL, Balton 800, Ervextra, Dextra,

Herbacut) (use only acute toxicity Class II or III products; not Class I) bensulfuron methyl (Altidax) bentazon, sodium salt only (Basagran 480SL) glyphosate, isopropyl amine salt (Uproot 360, Wynna 360SL, Nwurawura 360SL,

Sunphosphate 360SL, Rival 360SL, Glyphogan 360, Roundup 360, Agasate 40, Tackle 480, Touchdown, Glyphader, Chemosate)

imazethapyr/imazethapir, ammonium salt (Vezir 240SL) nicosulfuron (Nicogan 40OD, Arrow 75WDG) oxyfluorfen (Zoomer SC) pendimethalin (Alligator 400EC, Stomp 330E, Activus 500EC) propanil (Stam F-34, Orizo Plus)

Additional Allowed Herbicide AIs registered by Ghana if they become available in the north bispyribac-sodium fluazifop-P-butyl gibberellic acid mesotrione terbuthylazine triclopyr

4.3 USAID field monitoring requirementIn addition to continuous monitoring by the FTF ATT project/Sub-grantees environmental compliance staff and others delegated, USAID’s AOR, MEO and/or REA must at least two times annually, make inspection visits to several randomly selected farms receiving project assistance to check for compliance with the IPM and safer use measures summarized in section 4.4 below, and detailed data collection form found in Annex 9 and in the EMMP compliance tracking and reporting template that follows in Annex 13.

4.4 Summary of Compliance Requirements (Safer Use Measures)The above-listed allowed AIs can only be used in compliance with the safer use measures and restrictions specified in the PER. These can be summarized as follows:

A. Only pesticides approved by this PERSUAP may be supported with USAID funds in FTF ATT/Sub-grantee activities. These pesticides are enumerated in section 4.2, above.

Pesticide “support” = any of the following: use of USAID funds to: purchase pesticides; directly fund the application of pesticides; recommend pesticides for use; facilitate or enable the application or purchase of pesticides via provision of application equipment, credit support, or other means.

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B. If pesticide use is supported, appropriate project staff, sub-grantees & beneficiaries must be trained in IPM (Annex 1) safer pesticide use and pesticide first aid;

C. To the greatest degree practicable, if pesticide use is supported, the FTF ATT Project/Sub-grantees and its activities must require use and assure maintenance of appropriate PPE and application equipment—as well as safe pesticide purchase, handling, storage and disposal practices.

The PER and the annexes provide substantial resources to support compliance with these requirements, as detailed in the table below. In addition,

IPM/Safer Use Requirement

Key Resources Provided

Pesticide recommendations and use must be governed by a set of crop- and pest-specific IPM-based pest management plans.

(FTF ATT, sub-grantees, demo farmers, partners and retailers are responsible for developing these plans.)

Annex 1, Matrix of Ghana FTF ATT Crops, sets out in tabular format crop-by-crop, pest-by-pest chemical and non-chemical management methods recommended by this PERSUAP. This is intended to serve as the basis for a crop-specific pest management plan. See also the pest management plan for the associated Ghana Commercial Agriculture Program (GCAP).13

Annex 7, Analyses of Active Ingredients in Pesticides Registered in Ghana, provides toxicology information for each approved active ingredient, including human acute toxicities and chronic health issues, water pollution potential, as well as potential ecotoxicities to important non-target organisms like fish, honeybee pollinators, birds and several aquatic organisms.

If pesticide use is supported, appropriate FTF ATT project staff/Sub-grantees & beneficiaries must be trained in safer pesticide use & pesticide first aid

Annex 8, Training Topics and Safe Pesticide Use Web Resources, provides significant discussion of safer use training elements.

If pesticide use is supported, farm compliance monitoring forms could be used

Annex 9, Field Monitoring Form for Farmer Best Practices including GAP and IPM options, provides ideas for farm monitoring information to collect, and a format to collect it

If pesticide use is supported, FTF ATT/Sub-grantees must be systematic in their pesticide-related record-keeping and monitoring

Annex 10, Farm and Project Record Keeping Associated with Pesticide Use, provides record-keeping templates/aids

13 This GCAP pest management plan can be accessed at: http://www-wds.worldbank.org/external/default/WDSContentServer/WDSP/IB/2011/11/23/000406484_20111123114819/Rendered/PDF/E28900EA0P11420gement0Plan0P1142640.pdf

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If pesticide use is supported, FTF ATT/Sub-grantees must track the impact of risk mitigation measures

Annex 13, the EMMP, provides a template for monitoring risk mitigation actions

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Annex 1: Matrix of Ghana FTF ATT Crops with Primary Production Constraints, PERSUAP-Recommended Pest Prevention GAP/IPM Tactics & PERSUAP-Recommended Curative Tools and Tactics

RicePest Prevention GAP/IPM Tactics Curative Tools and Tactics

Rice gall midges (Orseolia oryzivora, Cricotopus sylvestris,Paralauterborniella subcincta,Paratanytarsus spp.)

Farmers use early planting/sowing Use resistant varieties Plow under ratoon from previous crop Remove off-season alternate host plants like wild rice Draining fields for 3-4 days controls the midge Seeding synchronously as soon as possible after flooding Seed parts of the field in sequence as they fill with water Avoid over-doses of fertilizer

In general, insecticide treatment for rice gall midge is ineffective.

Rice stem borers (Chilo zacconius, Coniesta ingnefusalis, Orseola oryzicola, Maliarpha separatella); Pink borer (Sesamia calamistis)

Use resistant and early-maturing varieties. Improved semi-dwarf varieties are generally more resistant to stem borers than the tall traditional ones.

Transplant & grow healthy rice seedlings and plants. Harvest at the very base of the plants, or plow stubble under and flood. Early/synchronized planting & water management

Use natural extracts of neem and chili peppers.

Rice leaf miners (Hydrellia griseola) (Trichispa species)

Several parasitic wasps attack the rice leafminer. Normally a combination of parasites, predators, and high temperatures cause leafminer populations to drop rapidly.

Level the field as accurately as possible. Manage water levels in the field to encourage the rice to emerge quickly and

grow erect. Use resistant varieties. Use crop rotation. Keep bunds and surroundings free from grass weeds Destroy stubble and avoid ratooning. Ensure balanced nutrition (avoid excessive nitrogen application). Removing weedy vegetation on the levees in spring near the time of seeding.

The synthetic insecticides containing deltamethrin or lambda-cyhalothrin may be used.

Diopsid (stalk-eyed) fly (Diopsis longicornis, Diopsis

Use resistant varieties. Remove and dispose of dead-heart plants.

Farmers spray with insecticides containing pyrethroids like lambda-cyhalothrin or deltamethrin and neem-

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thoracica, Diopsis spp.)

based materials.

Rice Caseworm (Nymphula depunctalis)

Use resistant varieties. Ensure balanced nutrition (avoid excessive nitrogen application). Removing weedy vegetation on the levees in spring near the time of seeding. Many predators control caseworm naturally. Use wider spacing and earlier planting.

Insecticides are not commonly used in northern Ghana against caseworm.

False smut on rice (Ustilaginoidea virens, Entyloma oryzae)

Some hybrids and varieties are more resistant than others. Avoid mechanical injuries to plants and maintain well-balanced soil fertility. Rotate to another crop, the longer the better. Use of disease-free seeds that are selected from healthy mother plants. Split nitrogen applications. Removal and proper disposal of infected plant debris. Avoid field activities when the plants are wet.

Fungicides are generally not used for most smuts.

Brown leaf spot (Bipolaris oryzae)

Use resistant varieties. Careful use of fertilizer can do much to prevent the disease Burn or feed stubbles after harvest Hot water treatment of seeds

Seed treatment with captan, thiram, or mancozeb.

Rice blast (Pyricularia oryzae)

Use of resistant cultivars. Destruction of infested residue. Use of certified clean or non-infested seed. Water seeding (not drill seeding). Continuous flooding. Avoid using excess nitrogen. Do not plant too early or too late. Avoid close planting in nurseries.

Use application of synthetic fungicides containing mefenoxam (metalaxyl-M).

Rice weeds Use an integrated weed management scheme: Perform thorough land preparation (soil tillage, fertilizer, and water

management). Narrow row spacing makes the crop more competitive than the weeds, use

intercropping. Place the fertilizer in such a way that the crop has access to it but the weeds

do not. This allows the crop to be more competitive with weeds. Keep the surroundings of farm free of weeds, unless they are maintained and

intended as habitats for natural enemies of crop pests. Regularly clean farm tools. Use green manure, which chokes out weeds.

Pre-emergence: use an herbicide containing pendimethalin plus hand weeding/hoeing.

Post-emergence: use an herbicide containing trichlopyr selectively control broadleaves and sedges.

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Use intercropping. Hand weeding, hoeing and composting (do not compost weeds that have

flowered and set). Minimizing weed competition during the early stages of the crop, before it

has formed a closed leaf canopy, is particularly important. In upland rice this critical period is approximately 15-40 days after seeding, while in transplanted rice, the crop can form a canopy more rapidly. Where a crop is exposed to prolonged weed competition during this critical period it is not usually able to recover sufficiently to give a good yield.

Rice Storage Weevils: Rice weevil (Sitophilus oryzae)

Do routine monitoring. Ensure good pest identification; understand pest biology, ecology, and behavior.

Use good sanitation and good grain storage practices, as follows: All grain stored off the floor on palates, with space between palates, well

ventilated/aerated and lighted, dispose of old containers. In empty shipping containers, thoroughly sweep or brush down walls,

ceilings, ledges, braces, and handling equipment, and remove all spilled debris.

Brush, sweep out and/or vacuum the truck beds, augers, and loading buckets to remove insect-infested grain and debris.

Remove all debris from fans, exhausts, and aeration ducts (also from beneath slotted floors, when possible).

Remove all debris and vegetation growing within ten feet of the warehouses (preferably the whole storage area).

Examine area to determine if rodent bait stations are required, and use if needed. Be sure to follow all label directions.

Spray cleaned area around bins with a residual herbicide to remove all undesirable weedy plants.

Remove all debris from the storage site and dispose of it properly. Frequent rotation of the stocks, "FIFO" (First In - First Out) rule applies. Use sticky traps to monitor for presence and quantity.

If needed, can use synthetic pyrethroid insecticides containing permethrin, lambda-cyhalothrin for surface, crack and crevice spraying.

MaizePest Prevention GAP/IPM Tactics Curative Tools and Tactics

Maize stalk borers (Busseola fusca)

Natural enemies of larvae include parasitoids Braconid family of parasitic wasps, wasps of the genus Cotesia, and Tachinid fly larvae. Trichogramma parasitoids attack eggs of stalk borers. Predators include ground beetles, lacewing larvae and adults, praying mantis and weaver ants.

Use borer-resistant varieties. Use crop rotation and intercrop maize with cowpea or groundnut. Plant early at the beginning of rains or within 2 weeks.

Apply imidacloprid or thiamethoxam to seed or growing plant, or apply acetamiprid to the plant (but only when plants are in vegetative state, not when flowering due to risk to pollinators and honeybee colony collapse disorder).

If they become registered, use natural

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Sanitation: Remove and destroy stalks by burning, feeding to cattle or composting.

pesticides containing BT toxin (extract from soil microbes) between the egg stage and leaf-feeding stage (before they bore into the stem).

Can use synthetic insecticides containing lambda-cyhalothrin.

Corn earworm (Helicoverpa zea)

Use resistant varieties. Many predators and parasites attack corn earworm eggs, including several

species of Trichogramma. General predators include lacewings, minute pirate bugs, and damsel bugs eat corn earworm eggs and small larvae.

Monitor fields regularly. Two weeks before planting, remove weeds and grasses to destroy earworm

larvae and adults harboring in those weeds and grasses. Practice crop rotation. Avoid planting crops successively that are hosts to

cotton bollworm like corn, sorghum, tobacco, soybean, and tomato. Sanitation: After harvest, remove cotton stubble and destroy by burning,

feeding to cows or composting.

Use of organic botanical insecticides like neem seed extract.

Use of organic biopesticides or microbial controls consisting of Bacillus thuringiensis/BT.

Armyworms (Spodoptera exempta)

Natural enemies include parasitoid Braconid and Cotesia wasps and Tachinid flies as well as damsel bugs, ground beetles, lacewings and weaver ants.

Remove weeds from bordering fields and on field borders. Sanitation: Remove all plant debris after harvesting. Pheromone traps placed along the edges of fields may be used to monitor

adult moths. This is a particularly good technique for detecting large emergences or migrations occurring on weather fronts.

Start monitoring before seedlings emerge by checking for egg masses and young larvae in surrounding weeds.

Botanical and homemade water extracts include chili, garlic, and neem seed.

Use sprays of BT, if and when they become registered and available.

To reduce development of resistance, regularly rotate chemicals to different chemical families.

Can use synthetic insecticides containing lambda-cyhalothrin.

Termites Baits: wood stakes treated with borates Insecticide seed treatment. Use composted instead of fresh mulch. Hand dig out nest to kill queen, synthetic pyrethroid insecticides poured into

nest.

Can spray imidacloprid (but only when plants are in vegetative state, not when flowering due to risk to pollinators and honeybee colony collapse disorder).

Maize Leafhoppers (Cicadulina spp. Especially Cicadulina mbila (transmits MSV)

Plant early and maintain a maize-free period over the winter months. Practice proper field sanitation. Many cereal crops and wild grasses serve as

reservoirs of the virus and the vectors. Free area of weeds and remove all plant debris after harvest to remove the possible breeding sites of adults.

Prepare a healthy soil to grow healthy plants. Healthy plants can withstand leafhoppers' feeding damage.

Practice crop rotation: do not plant maize after maize. Remove all volunteer

Try botanical and homemade water extracts of garlic and neem.

No synthetic insecticides are recommended or cost-effective, however synthetic insecticides containing imidacloprid could be used (but only when plants are in vegetative state, not

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Maize Streak Virus (MSV)

maize plants that grow in new plantings of rotation crops. Properly rotate crops that are not susceptible to leafhoppers. Use reflective mulches

when flowering due to risk to pollinators and honeybee colony collapse disorder).

Grasshoppers Send kids to handpick. Natural predators control most grasshoppers. Control weeds around and in field.

Can use insecticides containing lambda-cyhalothrin or deltamethrin.

Leaf Blight (Helminthosporium turcicum)

Use resistant or tolerant varieties or hybrids. Maintain soil and plant health (test these with lab tests). Sanitation: destroy infected crop residues. Rotate maize with other crops.

No fungicides are recommended.

Smuts (Ustilago maydis and Sphacelotheca reiliana)

Although no maize variety is immune, some hybrids and varieties are more resistant than others.

Avoid mechanical injuries to plants. Maintain well-balanced soil fertility. Rotate to another crop, the longer the better. Use of disease-free seeds that are selected from healthy mother plants Split nitrogen applications Removal and proper disposal of infected plant debris. Avoid field activities when the plants are wet. Control insect pests that may transmit smut.

Fungicides are generally not used for most smuts.

Annual & Perennial Grass Weeds, Broad Leaf Weeds

Use an integrated weed management scheme: Perform thorough land preparation (soil tillage, fertilizer, and water

management). Narrow row spacing makes the crop more competitive than the weeds, use

intercropping. Place the fertilizer in such a way that the crop has access to it but the weeds

do not. This allows the crop to be more competitive with weeds. Keep the surroundings of farm free of weeds, unless they are maintained and

intended as habitats for natural enemies of crop pests. Regularly clean farm tools. Use green manure, which chokes out weeds. Use intercropping. Hand weeding, hoeing, rototiller and composting (do not compost weeds that

have flowered and set).

Before planting, use non-selective herbicides containing glyphosate.

At planting or after planting, use synthetic herbicides containing glyphosate or pendimethalin.

Maize Storage weevils and grain

Do routine monitoring. Ensure good pest identification; understand pest biology, ecology, and behavior.

If needed, can use synthetic insecticide powders or dusts containing pirimiphos-

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borers Use good sanitation and good grain storage practices, as follows: All grain stored off the floor on palates, with space between palates, well

ventilated/aerated and lighted, dispose of old containers. In empty shipping containers, thoroughly sweep or brush down walls,

ceilings, ledges, braces, and handling equipment, and remove all spilled debris.

Brush, sweep out and/or vacuum the truck beds, augers, and loading buckets to remove insect-infested grain and debris.

Remove all debris from fans, exhausts, and aeration ducts (also from beneath slotted floors, when possible).

Remove all debris and vegetation growing within ten feet of the warehouses (preferably the whole storage area).

Examine area to determine if rodent bait stations are required, and use if needed. Be sure to follow all label directions.

Spray cleaned area around bins with a residual herbicide to remove all undesirable weedy plants.

Remove all debris from the storage site and dispose of it properly. Frequent rotation of the stocks, "FIFO" (First In - First Out) rule applies. Use sticky traps to monitor for presence and quantity.

methyl. Pyrethrum/pyrethrins or pirimiphos-methyl+ permethrin may be used, if these products become available in north Ghana.

SoybeanPest Prevention GAP/IPM Tactics Curative Tools and Tactics

Armyworms (Spodoptera exempta)

Natural enemies include parasitoid Braconid and Cotesia wasps and Tachinid flies as well as damsel bugs, ground beetles, lacewings and weaver ants.

Remove weeds from bordering fields and on field borders. Sanitation: Remove all plant debris after harvesting. Pheromone traps placed along the edges of fields may be used to monitor

adult moths. This is a particularly good technique for detecting large emergences or migrations occurring on weather fronts.

Start monitoring before seedlings emerge by checking for egg masses and young larvae in surrounding weeds.

Botanical and homemade water extracts include chili, garlic, and neem seed.

Use sprays of BT, if and when they become registered and available.

To reduce development of resistance, regularly rotate chemicals to different chemical families.

Can use synthetic insecticides containing lambda-cyhalothrin.

Thrips—flower drop Use of soil mulches. Control weeds around fields. Sampling for thrips by examining early flower clusters. Remove weed and crop residues at end of season. Use yellow and blue traps to monitor or for mass trapping.

Use of neem seed extract. Can use insecticides containing

dimethoate, lambda-cyhalothrin and pyriproxyfen provide great reduction in thrips emergence.

Green stinkbugs (Nezara viridula)

Use resistant varieties Many parasitoids control GSB eggs and larvae, so do not use broad-spectrum

Can use homemade neem seed extract plus soap water.

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insecticides; monitor for parasitism levels and make treatment decision accordingly

Destroy weeds (legumes, thistles, mustards, and mallows) that are good overwintering hosts for adult stinkbugs around fields.

Can use insecticides containing deltamethrin, imidacloprid or thiamethoxam (for imidacloprid and thiamethoxam, only when plants are in vegetative state, not when flowering due to risk to pollinators and honeybee colony collapse disorder).

Pre-Emergence Weeds

Use an integrated weed management scheme: Perform thorough land preparation (soil tillage, fertilizer, and water

management). Narrow row spacing makes the crop more competitive than the weeds. Place the fertilizer in such a way that the crop has access to it but the weeds

do not. This allows the crop to be more competitive with weeds. Keep the surroundings of farm free of weeds, unless they are maintained and

intended as habitats for natural enemies of crop pests. Regularly clean farm tools. Use green manure, which chokes out weeds. Use intercropping. Hand weeding, hoeing, rototiller and composting (do not compost weeds that

have flowered and set).

Use herbicides containing glyphosate, 24D-amine, bentazon sodium salt, imazethapyr.

Soybean Storage weevils

Do routine monitoring. Ensure good pest identification; understand pest biology, ecology, and behavior.

Use good sanitation and good grain storage practices, as follows: All grain stored off the floor on palates, with space between palates, well

ventilated/aerated and lighted, dispose of old containers. In empty shipping containers, thoroughly sweep or brush down walls,

ceilings, ledges, braces, and handling equipment, and remove all spilled debris.

Brush, sweep out and/or vacuum the truck beds, augers, and loading buckets to remove insect-infested grain and debris.

Remove all debris from fans, exhausts, and aeration ducts (also from beneath slotted floors, when possible).

Remove all debris and vegetation growing within ten feet of the warehouses (preferably the whole storage area).

Examine area to determine if rodent bait stations are required, and use if needed. Be sure to follow all label directions.

Spray cleaned area around bins with a residual herbicide to remove all undesirable weedy plants.

Remove all debris from the storage site and dispose of it properly.

If needed, can use natural insecticide powders or dusts containing BTor pyrethrins (pyrethrum extract) if these products become available in north Ghana.

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Frequent rotation of the stocks, "FIFO" (First In - First Out) rule applies. Use sticky traps to monitor for presence and quantity.

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Annex 2. Guidelines for Pest Management Plans (PMPs) for Ghana Crops and Beneficiaries

What is a PMP14?

Pest Management Plans or Guides provide field crop, livestock production or project decision-makers – farmers and farm managers – with best production practices recommendations, usually adapted by region, crop phenology and seasons. The aims of PMPs are to reduce the risks to production from pests by using a combination of best practices, including IPM, Integrated Vector Management (IVM) and Integrated Weed Management (IWM), that maximize crop or livestock health, and thus resilience to or tolerance of pests, and without an over-reliance on pesticides needed when best practices are not followed. Thus, prevention of pests plays a strongly pivotal role in the PMP, followed closely by management of pests when prevention alone is not adequate for the level of control needed or desired.

Who are the PMP’s intended audiences and users?

Farm land preparation and crop production decision-makers Farmers Farm managers

Why is a PMP being done?

PMP Objectives:

Prevent or reduce pest damage risk to agricultural production or health Protect the health of farmers, farm family members, laborers and community members from

pesticide risks Maintain economically sound practices Reduce environmental pollution and degradation risks Enhance the overall quality and quantity of biodiversity on the sustainable farm work

environment Respond to foreign market demand for the use of agriculture sector best management practice

standards, also called Good Agriculture Practices (GAPs) which include IPM measures, to achieve farm and produce certification

Comply with local, regional, donor and international laws, conventions, and regulations

Organization of the PMP

The following pieces of crop- or livestock-specific background information are used to build a PMP base

General information on the crop/livestock/sector Crop/livestock common/species names:

14 PMPs or Year-Round (seasonal) IPM Programs are state of the art in many developed countries, and they help institutionalize IPM in planning and practice. PMPs provide agriculture managers and farmers with a tool to predict and prevent many crop pests of each crop throughout a season. See examples of PMPs at http://www.ipm.ucdavis.edu/PMG/crops-agriculture.html, upper left corner under “Year-Round IPM Programs”.

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Crop/livestock developmental stages: Production regions and how they differ by soil type, pH, fertility, etc Overall concerns and priorities for crop/livestock production Crop/livestock cultural best practices Crop/livestock Good Agriculture Practices (GAPs) including some IPM (see PERSUAP section

on GAPS and IPM) recommendations

Individual Pest Prevention and Management Sections for each of the following pest types:

Invertebrate (Insects, Mites, Slugs/Snails, Nematodes) Diseases (Fungi, Bacteria, Viruses, Other) Weeds (annual grasses, broadleaves, perennial grasses, broadleaves, sedges, others) Vertebrates (birds, rodents, other)

For each pest type, first, identify overall priorities for pest prevention and management in the target crop or livestock.

Next, identify individual pest species noting the type of damage incurred; part of plant damaged: roots/rhizomes/tubers, stems/stalks, leaves, florescence, or seeds (field or stored); or if livestock, part of animal affected.

To best understand how to manage a pest, one needs to understand how, where, when and on what parts of the plant or animal the pest feeds. For field pests and stored grain/food pests, many PMPs are designed and outlined as follows, for each major species of pest (insects, mites, slugs/snails, nematodes):

Photographs of each pest, life stages Photographs of plant or livestock damage Description of the pest, life cycle and survival strategies15: Description of damage symptoms Best Prevention Practices

o Use any and all of the above GAPs including IPM o Country or region-specific information

Best Management Practiceso Focus on prevention (above) o Country or region-specific information

Information on PMP-recommended pesticides:

Information needed for each pesticide referenced in the above PMP, by pest (so the farmer/farm manager has the information at their fingertips and do not need to refer to other documents and tables to find it):

Pesticide essential information needed

Active Ingredient (AI) name Product Trade names (with EPA and WHO Acute Toxicity Classifications in parenthesis)

15 Survival strategies: All pests have survival strategies that allow them to live and breed in each crop’s farming systems. Knowing the survival strategies, including overwintering habit and alternate host plants, that are employed by the pest can help with decision making at the farming systems-level (e.g. choice of rotation crops) and also can help to anticipate pest outbreaks.

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Amounts to use per hectare Price Pre-Harvest Interval (PHI) Special comments on best application methods and frequency Any resistance management strategies needed Pesticide application record sheet Guidelines for reducing spray drift Re-entry interval (REI): field safe re-entry period after spraying Maximum residue levels (MRL) permitted by markets Pesticide precautions with use including Reading the label Legal responsibilities and permitted registration uses Permit requirements for possession and use Recommended and obligated use of PPE and best practices First aid and antidotes Transportation best practices Storage best practices Safe use best practices Container disposal best practices Leftover pesticide disposal best practices Protection of non-pest animals, plants, endangered species and water body quality Protect natural enemies & honeybees: http://www.ipm.ucdavis.edu/PMG/r584310111.html Posting signage in treated fields Some chemicals not permitted on processed crops Potential for phytotoxicity (crop injury) on some crops Documentation and record-keeping on farms

Information needed on Natural Enemies of Pests:

Common Names of Predators and Parasitoids effective against above pests: For a list of common natural enemies of crop pests, see http://www.ipm.ucdavis.edu/PMG/NE/index.html. Genera will likely be the same around the world, with different species in different continents, filling similar niches.

Additional Information Needed:

Will there be an IPM Coordinator, an IPM Advisory Committee, Education and Licensing for Applicators, Currency and Approval of the PMP?

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Annex 3. Elements of Integrated Pest Management (IPM) Program

IPM16

Although farmers are likely using numerous IPM tactics, without really calling them that, IPM philosophy or planning is not generally an active part of crop production in West Africa CORAF/WECARD plots; thus, a basic understanding of the steps or elements needed in an IPM program are addressed below.

Step 1: Learn and value farmers’ indigenous IPM tactics.Most farmers are already using their own forms of GAPs and IPM, many of which are novel, self-created, adapted for local conditions, and many of which work well. These local tools and tactics need to be well understood and taken into account when making PMPs. Accurate assessments of these farmers’ GAP and IPM technologies, as well as an understanding of actual losses due to different constraints in farmers’ fields are required before designing a crop production and pest management program. Standards and Certification (S&C) farmers will have records of historical pesticide use and trends, as well as information on current use of artisanal or local IPM tactics.

Step 2: Identify key pests for each target crop. Although perhaps up to ten species of pests may impact a crop and yields at different plant growth stages, generally only two or three are considered serious enough to spend money controlling. Farmers should be encouraged to monitor their population size, their life cycle, the kind of damage they cause and actual losses. Note that crop loss figures based on farmers’ perceptions of damage and loss are often overestimated.

Step 3: Evaluate all management options. Use of best management practices, preventive measures, and “organic” options to control pest impacts may eliminate the need for synthetic pesticides.

Step 4: Choose IPM methods; identify Needs, and Establish Priorities.Continue dialog with project field staff, ministry extension staff and farmers when choosing methods to be used. Consider the feasibility of attractive methods, including the availability of resources needed, farmers’ perceptions of pest problems, their abilities to identify pests, their predators, diseases and parasitoids, and to act upon their observations.

Step 5: Do effective activities and training to promote IPM.Next, identify strategies and mechanisms for fostering the transfer of the needed IPM technology under various project and institutional arrangements, mechanisms, and funding levels. Define what is available for immediate transfer and what may require more adaptation and validation research. Set up an initial planning workshop (with a COP-supported and signed Action Plan) to help define and orient implementation activities, and begin to assign individual responsibilities.

Learning-by-doing/discovery training programs

The adoption of new techniques by small-, medium- and large-holder farmers occurs most readily when program participants acquire knowledge and skills through personal experience, observation, analysis,

16http://www.fao.org/docrep/006/ad487e/ad487e00.htm ; http://www.fao.org/docrep/006/ad487e/ad487e02.htm; http://en.wikipedia.org/wiki/Farmer_Field_School; http://www.ipm.ucdavis.edu/PMG/crops-agriculture.html

2013 Ghana ATT PERSUAP 73

experimentation, decision-making and practice. At first, frequent (usually weekly) sessions are conducted for 10–20 farmers during the cropping season in farmers’ fields by trained instructors or extension agents.

Smallholder support and discussion groups

Weekly meetings of smallholders, held during the cropping season, to discuss pest and related problems can be useful for sharing the success of various control methods. However, maintaining attendance is difficult except when there is a clear financial incentive (e.g., credit, advance knowledge of nearby infestations for early action leading to yield improvement).

Educational material

In many countries, basic written and photographic guides to pest identification and crop-specific management techniques are unavailable or out of date. Videos featuring graphic pictures of the effects of acute and chronic pesticide exposure, and interviews with poisoning victims can be particularly effective.

Youth education

Promoting and improving the quality of programs on IPM and the risks of synthetic pesticides has been effective at technical schools for rural youth. In addition to becoming future farmers, these students can bring informed views back to their communities.

Food market incentives (especially important in the last decade)

Promoting Organic, GlobalGAP, BRC, Fair Trade or other certification for access to the lucrative and rapidly growing S&C systems-driven international and regional food markets can be, and is, a strong incentive to adopt IPM.

Step 6: Partner successfully with other IPM implementers.The following design steps are considered essential.

Articulate the partnership’s vision of IPM

Organizations may forge partnerships based on a common commitment to “IPM” – only to discover too late that that their visions of IPM differ considerably. It is therefore highly important that partners articulate a common, detailed vision of IPM, centered on the crops and conditions the project will encounter.

Confirm partner institutions’ commitment

The extent of commitment to IPM integration into project, design, and thus implementation depends strongly upon the following key variables:

IPM program integration into larger project. The IPM program is likely to be part of a larger “sustainable agriculture” project. The IPM program must fit into a partner’s overall goals. The extent of this integration should be clearly expressed in the proposed annual work plan.

Cost sharing. The extent of funds (or in-kind resources) is a good measure of a genuine partner commitment.

Participation of key IPM personnel. Organizations should have staff with expertise in IPM. In strong partnerships, these staff members are actively involved in the partnership.

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Step 7: Monitor the fields regularly.At minimum twice a week, farmers should monitor their fields for pests, as some pest populations increase rapidly and unexpectedly; this increase is usually related closely to the stage of crop growth and weather conditions, but it is difficult to predict the severity of pest problems in advance.

Step 8: Select an appropriate blend of IPM tools.A good IPM program draws from and integrates a variety of pest management techniques, like those presented in the above list. Flexibility to fit local needs is a key variable. Pesticides should be used only if no practical, effective, and economic non-chemical control methods are available. Once the pesticide has been carefully chosen for the pest, crop, and environment, it should be applied only to keep the pest population low, not necessarily eliminate it.

Step 9: Develop education, training, and demonstration programs for extension workers.Implementation of IPM depends heavily on education, training, and demonstration to help farmers and extension workers develop and evaluate the IPM methods. Hands-on training conducted in farmers’ fields (as opposed to a classroom) is a must. Special training for extension workers and educational programs for government officials and the public are also important.

Step 10: Monitoring, Record-Keeping and Evaluation (M&E).Develop data collection forms and checklists, collect baseline GAP/IPM data at the beginning of the project, and set targets.

For the use and maintenance of Good Agriculture Practices (that include safe pesticide storage, use and disposal), maintain farm or project files of: farmer and farm employee training records certification; farm soil, water, biodiversity, cropping and pesticide use maps; pesticide purchase and stock records; price increases or decreases, chemical application instructions including target pest, type of chemical applied, dosage, time of spray, rates at which pesticides were applied, harvest interval days, application machinery, PPE required and used, and any special instructions on mixing, exposure to children or dangers.

Further, for project staff, beneficiaries, produce processing facilities, food warehouses, seed multipliers, or farmers that store seed or food and deal with stored seed and food pests, there are warehouse BMPs and monitoring reports that incorporate some IPM tactics. These monitoring forms track, by location or warehouse, use of pallets, stacking, general hygiene and sanitation, damaged packages, actual infestations or signs of rodents, molds, insects, drainage, locks and security measures, use of IPM tactics including least toxic chemicals and strict BMPs, including restricted access, for use of the pesticides approved in this PERSUAP.

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Annex 4. Botanical Active Ingredients in Pesticides, Repellents, and Baits Regulated by USEPA

Name Other Names Use Toxicity EPA Tracking NumberAllium sativum Garlic Repels insects Low 128827Allyl isothiocyanate Oil of Mustard Kills & repels insects Questionable 004901Anise Oil Repels vertebrates Low 0043014-allyl anisole Estragole Kills beetles Low 062150Azadirachtin Azadirachta indica Neem tree

extractKills & repels insects Low, IV 121701

Bergamot Repels vertebrates 129029Canola Oil Brassica Napus B. Campestris Kills many insects Low 011332Capsaicin Capsicum frutescans Repels vertebrates Low, III 070701Castor Oil Repels vertebrates Low 031608Cedarwood Oil Repels moth larvae Low 040505Cinnamaldehyde Ceylon and Chinese cinnamon oils Kills insects, fungi & repels vertebrates* Low 040506Citronella Oil Repels insects & vertebrates Low 021901Cloves, Crushed Low 128895Dihydroazadirachtin Neem tree extract Azadirachta

indicaKills & repels insects III-IV 121702

Eucalyptus Oil Repels insects, mites fleas & mosquitoes Low 040503Eugenol Oil of cloves Kills insects** Low 102701Geraniol Oil of rose isomeric w/ linalool Repels vertebrates** Low 597501Geranium Oil Low 597500Indole from all plants Trap bait: corn rootworm beetles Low 25000-Jasmine Oil Low 040501Jojoba Oil Kills & repels whitefly kills powdery mildew Low 067200Lavandin Oil Repels clothes moth Low 040500Lemongrass Repels vertebrates Low 040502Linalool Oil of Ceylon isomeric w/geraniol Repels insects, ticks, mites & spiders Low 128838Maple lactone Roach trap bait Low 004049Methyl salicylate Oil of wintergreen Repels moths, beetle & vertebrates May be Toxic in

large quantity76601-

Mint Herb Kills aphids Low 128892Mint Oil Kills aphids Low 128800

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Name Other Names Use Toxicity EPA Tracking NumberMustard Oil Repels insects, spiders & vertebrates Low 004901Neem Oil Kills whitefly, aphids Low 0250061-Octen-3-ol From clover, alfalfa Trap bait: mosquitoes Low 69037-Orange Repels vertebrates Low 040517p-Methane-3,8 diol Eucalyptus sp. Repels biting flies, mosquitoes Low2-Phenylethyl-propionate

From peanuts Kills insects, ticks, mites & spiders Low 102601

Pyrethrum Chrysanthemum sp. Stored products use IIIRed pepper Chilli Repels insects Low 070703Rosemary Herb Low 128893Rotenone Derris sp., Tephrosia Controls ticks IIIRyania Ryania speciosa Kills thrips, codling moth, corn borersSabadilla Schoenocaulon sp. IIISesame Oil Sesamum indicum Pyrethroid synergist LowSoybean Oil Soja Kills insects, mites Low 031605Thyme Herb Controls aphids Low 1288941,2,4 Trimethoxy-benzene

From squash Trap bait: corn rootworm, cucumber beetles Low 40515-

Verbenone From pine trees Repels bark beetles Low 128986

* attracts corn rootworm beetles, ** attracts Japanese beetles. Not all plant extracts are listed. More detailed information available for most oils: http://www.epa.gov/pesticides/reregistration/status.htm. Natural Source: Only one or a few sources are listed. Most of these chemicals are found in many different plants.

Since the time in the late 1990s when EPA did register biological ingredients listed above, it has since developed a list of botanical extracts (mostly essential oils) under “Minimum Risk Pesticides Exempted under FIFRA Section 25(b)17”. Some of the very same ingredients are in both lists. However, most US states and USAID consider botanical extracts and essential oils used to kill, destroy, mitigate, or repel pests to be analyzed and treated as pesticides.

17 http://www.epa.gov/oppbppd1/biopesticides/regtools/25b_list.htm 2013 Ghana ATT PERSUAP 77

Annex 5. Natural Pesticides That Have Been Commercialized

Insecticidesazadirachtin—component in neem oil botanical extractBacillus thuringiensis-BT microbialBeauveria basiana microbialcartap hydrochloride marine worm (Lumbriconereis heterodopa) extractchili pepper extract botanical (spice)emamectin benzoate botanical extractgarlic extract/allicin botanical extract (spice)harpin protein plant induced resistance elicitorkaolin clay inorganic minerald-limonene citrus extract (spice)Metarhizium anisopliae microbialnarrow range dormant oil paraffin oilneem oil botanical extractnuclear polyhedrosis virus (NPV) microbialPaecilomyces lilacinus microbialPaecilomyces fumosoroseus microbialpyrethrin botanical extract pyriproxyfen IGR (Juvenile Hormone mimic)ryania botanical extractsoap (insecticidal) fatty acidsspinosad microbial extractbuprofezin IGR (Chitin Synthesis inhibitor)

FungicidesBacillus subtilis microbialBordeaux mix inorganic (Bordeaux ingredients EPA registered)copper inorganiccopper hydroxide inorganiccopper oxychloride inorganiccopper sulfate inorganicharpin protein plant induced resistance elicitorsulfur inorganicTrichoderma species microbial

Nematocides Myrothecium verrucaria microbial tomatillo oil + thyme oil extracts (Promax18) botanical + spice extracts—soil biopesticide Molluscicideiron phosphate inorganic

18 http://www.bhn.name/humagro/biopesticides.html

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Annex 6. Acute Toxicity of Pesticides: EPA and WHO Classifications

General Toxicity

Pesticides, by necessity, are poisons, but the toxicity and hazards of different compounds vary greatly. Toxicity refers to the inherent intoxicating ability of a compound whereas hazard refers to the risk or danger of poisoning when the pesticide is used or applied. Pesticide hazard depends not only on toxicity but also on the chance of exposure to toxic amounts of the pesticide. Pesticides can enter the body through oral ingestion, through the skin or through inhalation. Once inside the body, they may produce poisoning symptoms, which are either acute (from a single exposure) or chronic (from repeated exposures or absorption of smaller amounts of toxicant).

EPA and WHO Toxicity Classifications

Basically, there are two systems of pesticide toxicity classification. These are the USEPA and the WHO systems of classification. It is important to note that the WHO classification is based on the active ingredient only, whereas USEPA uses product formulations to determine the toxicity class of pesticides. So, WHO classification shows relative toxicities of all pesticide active (or technical) ingredients, whereas EPA classification shows actual toxicity of the formulated products, which can be more or less toxic than the active ingredient alone and are more representative of actual dangers encountered in the field. The tables below show classification of pesticides according to the two systems.

a) USEPA classification (based on formulated product = active ingredient plus inert and other ingredients)

Class

Descriptive term

Mammalian LD50

Mammalian

Inhalation

LC50

Irritation Aquatic invert/fish (LC50 or EC50)2

Honey bee acute oral (LD50)

Oral Dermal

Eye1 Skin

I Extremely toxic

50 200 0.2 Corrosive

Corrosive

< 0.1

II Highly toxic

50-500

200-2000

0.2-2.0 Severe Severe 0.11-1.0 < 2 µg/bee

III Moderately toxic

500-5000

2000-20000

2.0-20 No corneal opacity

Moderate

1.1-10.0 2.1-11 µg/bee

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IV Slightly toxic

5000

20000

20 None Moderate or slight

10.1-100

Relatively non-toxic

101-1000

Practically non-toxic

1001-10,000

> 11 µg/bee

Non-toxic > 10,000

1 Corneal opacity not reversible within 7 days for Class I pesticides; corneal opacity reversible within 7 days but irritation persists during that period for Class II pesticides; no corneal opacity and irritation is reversible within 7 days for Class III pesticides; and Class IV pesticides cause no irritation2 Expressed in ppm or mg/l of water

b) WHO classification (based only on active or ‘technical’ ingredient)

Class Descriptive term

Oral LD50 for the rat (mg/kg body wt)

Dermal LD50 for the rat (mg/kg body wt)

Solids Liquids Solids Liquids

Ia Extremely hazardous 5 20 10 40

Ib Highly hazardous 5-50 20-200 10-100 40-400

II Moderately hazardous 50-500 20-2000 100-1000 400-4000

III Slightly hazardous 501 2001 1001 4001

U Unlikely to present acute hazard in normal use 2000 3000 - -

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Annex 7: PERSUAP Analyses of Active Ingredients in Pesticides Registered in Ghana

Introduction to Annex 7

Annex 7 below compiles all of the AIs in pesticides (natural and synthetic) registered for use in Ghana, and proposed for imminent registration. Project decision-makers—especially those who interface at the field level with beneficiary farmers—are encouraged to look at the label of potential pesticide choices to determine the AIs contained in them and then use this Annex as a quick reference guide to attributes and issues with each chemical.

The pesticide attributes include pesticide class (to manage resistance by rotating chemicals from different classes), EPA registration and Restricted Use Pesticide (RUP) status (to comply with Regulation 216) and acute toxicity (judged by this document to be safe, or not, for smallholder farmers—most Class I chemicals are not considered safe for smallholder farmers to use). Annex 7 also presents chronic health issues, water pollution potential, and potential toxicities to important non-target organisms like fish, honeybee pollinators, birds and several aquatic organisms.

Further, Annex 7 contains basic pieces of human safety and environmental data needed for the various analyses required throughout the PER; ergo it is referred to throughout this document. Thus, this PERSUAP provides useful tools for evaluating and choosing among IPM options, including natural and synthetic pesticides, while adhering to 22 CFR 216.

See Annex 7 Matrix, below.

Key to matrix:

Red shading: Do not promote products containing AIs shaded in red on USAID-supported farms or wood processing

Green shading: Can be promoted on USAID-supported farms

Yellow shading color: Some products accepted; some products rejected

RUP: Few = one or two products; Some = a third of products; Most/All = most or all products

WHO Acute Toxicity Classes: O = Obsolete; Ia = Extremely Hazardous; Ib = Highly Hazardous; II = Moderately Hazardous; III = Slightly Hazardous; U = Unlikely to present acute hazard in normal use

EPA Acute Toxicity Classes: I = Extremely Toxic; II = Highly Toxic; III = Moderately Toxic; IV = Slightly Toxic

Chronic Human Toxicity: KC = Known Carcinogen; PC = Possible Carcinogen; LC = Likely Carcinogen; ED = Potential Endocrine Disruptor; RD = Potential Reproductive & Development Toxin; P = Risk of Parkinson’s

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Ecotoxicity: NAT = Not Acutely Toxic; PNT = Practically Not Toxic; ST = Slightly Toxic; MT = Moderately Toxic; HT = Highly Toxic; VHT = Very Highly Toxic

References used to find pieces of data contained in Annex 7: See references at the end of the report.

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2013 Ghana Registered InsecticidesEcotoxicity

Active Ingredients Class

EPA R

egistered

Restricted U

se Pesticide

WH

O A

cute Toxicity Class

EPA A

cute Toxicity Classes

Chronic Toxicity

Groundw

ater contaminant

fish

bees

birds

amphibians

worm

s

Mollusks

Crustaceans

Aquatic Insects

Plankton

abamectin/avermectin microbial extract yes some NL II, III ED, RD no data ST HT PNT MT HT VHT VHT

acephate organophosphate yes no III II, III PC, ED potential MT HT MT ST ST ST

acetamiprid neonicotinoid yes no NL III NL potential NAT MT HT NAT

allethrin/bio-allethrin synthetic pyrethroid no no III III ED no data VHT MT ST HT VHT HT

alpha cypermethrin synthetic pyrethroid no no II II, III PC no data HT HT PNT MT VHT VHT VHT

aluminum phosphide inorganic yes all NL I NL no data HT HT HT MT

Bacillus sphaericus microbial yes no U III NL no data

Bacillus thuringiensis/BT microbial yes no III III NL no data MT PNT NAT NAT ST ST

bifenthrin synthetic pyrethroid yes some II II, III PC, ED, RD no data VHT HT MT HT

cadusafos organophosphate no no Ib NL NL no data HT HT HT HT HT HTcarbofuran carbamate yes most Ib I, II ED potential MT HT HT ST MT MT HT HT VHT

carbosulfan carbamate no no II II NL no data HT HT HT HT HTchlorpyrifos (ethyl) organophosphate yes some II II, III ED no data HT HT HT MT PNT MT VHT HT MT

cypermethrin synthetic pyrethroid yes some NL II, III PC, ED, RD no data HT HT PNT MT VHT VHT VHTdiazinon organophosphate yes some II II, III ED, RD potential MT HT VHT MT MT MT HT HT HTdimethoate organophosphate yes no II II PC, ED, RD potential ST VHT VHT HT MT VHT HT VHT MT

emamectin benzoate botanical yes some NL I, II, III NL potential HT MT HT HT HTfenitrothion organophosphate yes no II II, III ED no data MT HT MT MT MT MT VHT HT MTfenvalerate synthetic pyrethroid no no II III ED no data VHT HT ST HT VHT HT HT HT VHT

fipronil pyrazole yes some II II, III PC, ED potential HT HT HT HT HT

imidacloprid neonicotinoid yes no II II, III NL potential NAT MT VHT

lambda cyhalothrin synthetic pyrethroid yes some II II, III ED no data VHT HT PNT VHT VHT VHT VHTmalathion organophosphate yes no III II PC, ED potential MT HT MT HT ST VHT MT VHT HT

Metarhizium anisopliae microbial yes no NL III NL no data NAT NAT NAT

novaluron insect growth regulator yes no NL II, III NL no data MT MT MT MT HT

oxamyl carbamate yes some Ib I NL no data ST HT VHT HT ST MTpermethrin synthetic pyrethroid yes All agr II III PC, ED no data VHT VHT PNT ST ST ST VHT MT MT

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pirimiphos methyl organophosphate yes no II, III I, II, III NL no data MT HT MT MT VHT VHT

profenofos organophosphate yes all II III NL potential HT VHT VHT VHT

Pyrethrum/pyrethrins botanical yes some II III PC no data HT HT ST MT HT

sulfur/sulphur Inorganic yes no U III NL no data NAT NAT NAT NAT NAT

temephos organophosphate yes no U II, III NL no data ST MT MT NAT HT VHT HT

tetramethrin pyrethroid yes no U III PC, ED no data VHT HT NAT HT MT

thiamethoxam neonicotinoid yes few NL III PC no data PNT HT PNT PNT PNT PNT PNT

thiocyclam hydrogen oxalate nereistoxin no no II NL NL no data HT MT HT HT HT

2013 Ghana Registered FungicidesEcotoxicity

Active Ingredients Class

EPA R

egistered

Restricted U

se Pesticide

WH

O A

cute Toxicity Class

EPA A

cute Toxicity Classes

Chronic Toxicity

Groundw

ater contaminant

fish

bees

birds

amphibians

worm

s

Mollusks

Crustaceans

Aquatic Insects

Plankton

azoxystrobin strobin yes no U III NL potential MT MT MT MT MT VHT

captan thiopthalamide yes no NL I, II, III KC (hi dose) no data HTNAT

PNT MT MT

NAT MT MT

carbendazim benzimidazole yes no U III PC, ED no data MTNAT ST ST ST HT

copper-fixed or tribasic inorganic yes no NL I, II, III NL no data MT HTPNT HT HT VHT ST ST

copper (cupric) oxide (CuO) inorganic yes no NL I, II, III NL no dataNAT ST ST

copper (cupric) hydroxide inorganic yes no II I, II, III NL no data HT MT MT MT HTNAT HT HT

cuprous oxide (Cu2O) inorganic yes no II II, III NL no data HT HT HT VHT

dichlofluanid sulphamide no no U NL NL no data HT MTNAT MT MT MT VHT

difenoconazole azole yes no III III PC, ED no data MT MT ST MT MT HT

fenpropimorph morpholine no III I NL no data MT MT MT MT MT

folpet thiophthalimide yes no U II, III LC no data HTPNT ST HT MT ST HT MT

fosetyl aluminum unclassified yes no NL II, III NL potentialNAT ST ST MT

NAT MT

mancozeb dithiocarbamate yes no U III PC, ED, RD no data MT MT ST HT NAT

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maneb carbamate No no U III PC, ED, RD no data MTNAT

PNT ST ST HT

metalaxyl benzanoid yes no III II, III NLpotential ST

PNT

PNT ST

propiconazole azole yes no II II, III PC, RD potential MT MT ST MT MT

sulfur (sulphur, hydrogen sulfide) inorganic yes no U III NL no dataNAT

NAT

NAT NAT NAT

thiophanate methyl benzamidazole yes no U III PC, RD potential MTPNT NAT ST

triadimenol triazole yes no III II, III PC, ED no data MT ST MT MT

Trichoderma asperellum microbial yes no NL III NL no data

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Ghana Registered Herbicides & PGRsEcotoxicity

Active Ingredients Class

EPA R

egistered

Restricted U

se Pesticide

WH

O A

cute Toxicity Class

EPA A

cute Toxicity Classes

Chronic Toxicity

Groundw

ater contaminant

fish

bees

birds

amphibians

worm

s

Mollusks

Crustaceans

Aquatic Insects

Plankton

2 4 D amine chlorophenoxy acid yes no NL NL PC no data

2 4 D amine salt chlorophenoxy acid yes no NL NL PC no data

2 4 D isobutylate chlorophenoxy acid no no NL IV NLpotential MT VHT HT ST ST

bensulfuron methyl sulfonyl urea yes no U II, III NLpotential

NAT MT ST MT ST NAT

Bentazon, sodium salt benzothiazinone yes no III III NL no dataNAT MT MT MT ST MT

bispyribac-sodium unclassified yes no U III NLpotential MT ST

NAT MT MT

bromacil uracil yes no UII, III, IV PC, ED known

NAT MT

NAT ST ST

butachlor chloroacetanalid no no U III PC no data HT MTNAT MT MT MT HT MT

cycloxydim cyclohexanone no no U NL NL no dataNAT MT MT MT MT

diuron urea yes no U IIILC, ED, RD known ST ST ST ST MT ST

ethephon organophosphate PGR yes no U I, III NL no dataNAT ST MT

NAT NAT NAT

fluazifop-P-butyl propionic acid yes no III III NL no data MT STPNT ST

gibberellic acid botanical PGR yes no U II, III NL no dataNAT

glyphosate phosphonoglycine yes no U I, II, III NLpotential ST ST

NAT PNT MT ST

haloxyfop a propionic acid no no II NL NL no data ST ST MT

imazapyr/imazapir imidazolinone yes no U III NL no data ST MT ST MTNAT

mesotrione unclassified yes no NL II, IIII NL no dataNAT MT MT MT

NAT

metolachlor chloroacetamide yes no III III PC, ED known MT ST MT MT MT

nicosulfuron sulfonylurea yes no U II, III NLpotential MT MT MT MT MT

oxyfluorfen diphenyl ether yes no U II, III PC no data HTPNT

PNT HT HT HT

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paraquat (dichloride) bipyridylium yesmost II I P

potential ST

NAT MT ST ST ST NAT ST

pendimethalin dinitroanaline yes no III III PC, ED no data MTNAT ST MT MT

propanil analide yes no III II, III PCpotential MT

NAT MT ST NAT ST ST ST

propaquizafop a propionic acid no no U NL NL no data MT MT MT MT MT

terbuthylazine triazine yes no U III NL no data MT MT MT MT MT HT

triclopyr chloropyridinyl yes no III I, II, III NL no data MT NAT ST

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Annex 8. Training Topics and Safe Pesticide Use Web Resources

GAP/IPM

Pest identification: How to recognize common important pests and diseases Monitoring: The importance of frequent crop monitoring for pests, diseases and weeds GAP and IPM concepts, tactics and tools found in Annex 1 that can reduce pesticide use and

associated risks on specific pests of Ghana FTF ATT target crops PMPs—Pest Management Plans: Creating and using these farm crop-management tools

Pesticides

Understanding pesticides: Quality, types, classes and acute toxicities of common pesticides Regulations: US, EU and Ghana laws that guide pesticide registration and use Natural pesticides: Raise awareness of and promote the use of natural pesticides found in

Annexes 1, 4, 5 and 7 as well as green-label synthetic pesticides with relatively low risks Spot Treatments: The importance of spot treatments if needed (instead of crop-wide treatments) MSDS: How to use MSDSs for pesticide-specific information on risks and risk reduction

measures REI—Re-Entry Intervals: Pesticide-specific risks associated with entering a sprayed field too

soon after the spray operation PHI—Pre-Harvest Interval: Pesticide-specific risks associated with harvesting a crop before

pesticides have had a chance to break down MRL—Maximum Residue Level: Risks associated with pesticide residues on human food Vulnerable individuals: The importance of keeping children, pregnant women, elderly and infirm

away from the field while spraying and kept out after spraying Human and environmental risks: Risks associated with more commonly-used pesticides (use

information from MSDSs and Annex 7) When to spray: Early in the morning, late in the afternoon, or night without wind or rain Use of recommended PPE: Why it is used (see product MSDSs, product labels and web reference

below) Proper use and maintenance of sprayers, including proper sprayer calibration and spray nozzle

choice Proper clean-up & post spray hygiene Safe Use: How to purchase, transport, store and use pesticides safely (“safe purchase” requires

quality, brand-name products) Maintenance: of PPE and sprayers Monitoring for the development of pesticide resistance Proper collection and disposal of pesticide rinseate and packaging (see disposal web reference

below and MSDSs) The use of pesticide spray buffer zones near schools, water resources, organic crop production,

apiaries, bird sanctuaries, biodiversity enclaves, national parks or other sensitive areas.

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How to reduce and mitigate risks to critical environmental resources and biodiversity (found in PER Factors E and G)

Honeybees: Ensuring pesticide applicators notify beekeepers about spray activities, and spray early morning or late afternoon when no heavy winds or rain are present

Water Pollution: Raise awareness of pesticides (especially some herbicides) with high ground water contamination potential where water tables are high or easy to reach (use Annex 7 and MSDSs)

Exposure routes: Ways pesticides enter the body and ways to mitigate entry Basic first aid: Understanding how to treat pesticide poisonings (see first aid web reference and

MSDSs) Record-keeping: Pesticide used, when used, which crop, how applied, who applied

Web Safe Pesticide Use Training Resources

General Mitigation of Potential Pesticide Dangers General Measures to Ensure Safe Use: http://pdf.usaid.gov/pdf_docs/PNADK154.pdf, Chapter 13

EPA Recommended Worker Protection Standards: http://www.epa.gov/oppfead1/safety/workers/equip.htm (all types of PPE)http://www.cdc.gov/nasd/docs/d001701-d001800/d001797/d001797.html (respiratory PPE)

Routes of Pesticide Exposure and Mitigation of Risks:http://pdf.usaid.gov/pdf_docs/PNADK154.pdf, Chapter 13

Basic First Aid for Pesticide Overexposure: http://pdf.usaid.gov/pdf_docs/PNADK154.pdf, Chapter 13

International PIC & POPs Lists:PIC Pesticides and Industrial Chemicals (http://www.pic.int)POPs Pesticides and Chemicals (http://www.pops.int)

Pesticide Disposal Options:http://www.epa.gov/oppfead1/labeling/lrm/chap-13.htm

2013 Ghana ATT PERSUAP 89

Annex 9. Field Monitoring Form for Farmer Best Practices including GAP and IPM optionsName of USAID Staff Responsible for Monitoring Demonstration Farms:

Name of Demonstration Farmer: Crop: Date:

What are the major pests encountered by the farmer?:

Which of the attached Preventive and Curative GAP and IPM tools and tactics are used by farmer?

Are pesticides used by demo farmer? Yes__ No__

How are pesticides applied? backpack sprayer__ other__

What are the names of the pesticides used?:

Which PPE does farmer have and use? gloves___ overalls___ boots___

respirator___ goggles___

Has the farmer had IPM and Safe Pesticide Use training? Yes__ No__

Are there any empty pesticide containers scattered in the field? Yes__ No__

Are there signs that the backpack sprayer has leaks? Yes__ No__

Does the farmer understand the pesticide label information? Yes__ No__

Is the pesticide stored safely out of the house or away from kids? Yes__ No__

Does the farmer use gloves for mixing the pesticide with water? Yes__ No__

What times of the day are the pesticides applied? ________

Are pesticides applied during rain or windy conditions? Yes__ No__

Are women or children permitted to apply pesticides? Yes__ No__

Are empty pesticide containers are used to store water? Yes__ No__

Does the farmer rinse equipment away from streams and open water? Yes__ No__

Does the farmer wash clothes after applying pesticides? Yes__ No__

How does the farmer dispose of empty pesticide containers? puncture/bury__ burn__

Is there any evidence that pesticides are becoming less effective? Yes__ No__

2013 Ghana ATT PERSUAP 90

Preventive and Curative GAP and IPM options:

Preventive Preventive CurativeSoil nutrient, texture and pH

testingFarmer ability to correctly identify

pest predators, parasitoids and diseases

Mechanical insect control by hand picking

Pest resistant/tolerant seed/plant variety

Weekly field scouting to assess pest levels/damage

Farmers make & apply local artisanal plant extracts (neem, pyrethroid, garlic, chili, other)

Early/late plantings or harvestings to avoid pests

Use of trap crops to trap and destroy pests

Weed control by machine cultivation, hoe or hand

Seed treatment with pesticides Removal/pruning of diseased or heavily infested plants/tree branches

Purchase and release of predators or parasitoids to control major pests

Soil moisture testing Planting parasite-attracting plants on field margins

Use of pheromone traps to reduce overall pest levels

Raised-bed production or mounding

Put baits and use other practices to encourage predator/parasite build-up

Use of pheromone inundation to confuse pest mating

Irrigation and drip irrigation Use of pheromone traps to monitor pest levels

Spot treatment of pest hotspots with insecticides, miticides or fungicides

Use of natural fertilizers (manure, compost)

Inter-planting crops with aromatic herbs (celery, cilantro, parsley, dill or local plants) that repel pests

Area spraying (complete field coverage) using synthetic and natural insecticides, miticides or nematocides

Use of purchased mineral fertilizers

Mulching with organic materials or plastic to control weeds

Use of synthetic and natural fungicides or bactericides

Combinations of organic and mineral fertilizers

Plant living barriers or bamboo/tree barriers on windward edge of field

Use of herbicides for weed control

Crop rotation Exclude insect pests by using vegetable tunnels and micro-tunnels

Farm use of a locked storage building for pesticides

Use of green manure crops Use of biodiversity or energy conservation practices

Farmer use of pesticide in-ground compost trap for depositing and capturing spilled or leftover pesticides

Farmer ability to correctly identify pests and their damage

Crop stalks, residue and dropped fruit destruction/composting season end

Farmer use of receptacle for empty pesticide bottle disposal

2013 Ghana ATT PERSUAP 91

Annex 10: Farm and Project Record Keeping Associated with Pesticide Use

2013 Ghana ATT PERSUAP 92

2013 Ghana ATT PERSUAP 93

1.- Control Card for Pesticides Use.- This card will stay with farmer, to keep a record on the use of pesticide by crop.

GENERAL DATA

FARMERS NAME

Community: Municipality: Province: Altitude:

USE OF PESTICIDES - 1st TREATMENT

CROP: SURFACE:

Pest to be treated Name of material Date and time of application Quantity used

Environmental conditions:

Justification for use

Other recommended control measures

Result of application

NAME AND SIGNATURE OF IG AND NRM SUPERVISOR:

USE OF PESTICIDES - 2nd TREATMENT

CROP: SURFACE:

Pest to be treated Name of material Date and time of application Quantity used

Environmental conditions:

Justification for use

Other recommended control measures

Result of application

NAME AND SIGNATURE OF IG AND NRM SUPERVISOR:

CONTROL FORM FOR THE USE OF PERTICIDES

2013 Ghana ATT PERSUAP 94

ANNEX 11: PERSUAP ReferencesBaker EL, Zack M, Miles JW, Alderman L, Warren M, Dobbins RD, Miller S, Teeters WR (1978) Epidemic malathion poisoning in Pakistan malaria workers. The Lancet, January: 31–33.

Websites: Website references used to develop the PERSUAP International Treaties and Conventions:POPs website: http://www.pops.int

PIC Website: http://www.pic.intBasel Convention: http://www.basel.int/

Montreal Protocol: http://www.unep.org/OZONE/pdfs/Montreal-Protocol2000.pdf

Pakistan malaria poisonings: http://pdf.usaid.gov/pdf_docs/PNACQ047.pdf.

Pesticide poisonings: http://www.panna.org/resources/panups/panup_20080403

http://magazine.panna.org/spring2006/inDepthGlobalPoisoning.html

IPM and PMP websites:http://www.ipm.ucdavis.edu/

http://edis.ifas.ufl.edu/pg058 http://www.ipmcenters.org/pmsp/index.cfm

http://www.dpi.nsw.gov.au/__data/assets/pdf_file/0005/154769/Cotton-pest-management-guide-1.pdf

Pesticide Research Websites:http://extoxnet.orst.edu/pips/ghindex.html (Extoxnet Oregon State database with ecotox)

http://www.agf.gov.bc.ca/pesticides/f_2.htm (all types of application equipment)http://www.greenbook.net/Search/AdvancedSearch (pesticide Material Safety Data Sheets)

http://www.epa.gov/pesticides/reregistration/status.htm (EPA Registration Eligibility Decisions)

Ecotoxicity : http://www.ohioline.osu.edu/hyg-fact/2000/2161.html (pesticide toxicity to honeybees)

http://wihort.uwex.edu/turf/Earthworms.htm (pesticide toxicity to earthworms)

Safety : http://www.epa.gov/oppbppd1/biopesticides/ingredients/index.htm (EPA regulated biopesticides)

http://www.ipm.ucdavis.edu/index.html (IPM, PMPs and pesticide recommendations)

2013 Ghana ATT PERSUAP 95

http://edis.ifas.ufl.edu/pdffiles/PI/PI07300.pdf (Restricted Use Pesticides)http://www.epa.gov/pesticides/health/ (EPA Health & Safety)

http://www.epa.gov/opppmsd1/PPISdata/index.html (EPA pesticide product information)

Personal Protection Equipment (PPE):http://www.epa.gov/oppfead1/safety/workers/equip.htm (all types of PPE)

http://www.cdc.gov/nasd/docs/d001701-d001800/d001797/d001797.html (respiratory PPE)

2013 Ghana ATT PERSUAP 96

Annex 12: List of Institutions and Farmers Interviewed1. AGRO-DEALEARS

Firm/organisation Location Date of Visit Contact Person Contact No,1.1. GANYE AGRO-

CHEMICALSSAVELUGU 28/11/13 SUALE

ABUKARI0247436571

1.2. WUNPINI AGRO-CHEMICALS

TAMALE 04/12/13 Iddi 0244290265

1.3. GANORMA AGRO-CHEMICALS

TAMALE 04/12/13 HAJIA 0244845995

1.4. MAKHTESHIM AGRO-CHEMICALS

TAMALE 09/12/13 OSMAN 0544348817

1.5. VA NS ADDO AGRO-CHEMICALS

TAMALE 09/12/13 EVANS 0244780151

IRRIGATION SCHEMESFirm/organisation Location Date of Visit Contact Person Contact No,

1.6. BONTAGA IRRIGATION SCHEME

BONTAGA 29/11/13 ALI &FARMERS 0246211870

1.7. LIBGA IRRIGATION SCHEME

LIBGA 02/12/13

1.8. TONO IRRIGATION SCHEME

TONO 03/12/13 ISA &HANS-AKUFO

0244577663

1.9. GOLINGA IRRIGATION SCHEME

GOLINGA 2/12/13 YEMALE 0548495406

2. AGRI-BUSINESS CENTRESFirm/organisation Location Date of Visit Contact Person Contact No,

2.1. BUSAKA ABC SAVELUGU 28/11/13 Emanuel 02648905562.2. PRESBY AGRIC

STATION ABCWALEWALE 03/12/13 SANDOW 0248974004

3. GOVERNMENT OFFICESFirm/organisation Location Date of Visit Contact Person Contact No,

3.1. REGIONAL AGRICULTURAL DEV’T UNIT (RADU)

TAMALE 29/11/13 BOAKYE-ACHEMPONG

0244216918

3.2. ENVIRONMENTAL PROTECTION UNIT (EPA)

TAMALE 29/11/13 ABU IDRRIS &TEAM

0203247375

3.3. SAVANA AGRIC RESEARCH INSTITUTE (SARI)

NYANKPALA 02/12/13 Dr. DOGBE &

Dr MUMUNI

0264603414

3.4.

4. FARMERS

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Firm/organisation Location Date of Visit Contact Person Contact No,4.1. KHAMA FARMERS

GROUPTIBALI 05/12/13 KHARMA

MUHIIB0205891529

4.2. PEASANT FARMERS ASSOCIATION

TAMALE 09/12/13 NAASHIRU 0243540629

4.3.4.4.

2013 Ghana ATT PERSUAP 98

Annex 13: 2014 Ghana IFDC FTF ATT Project EMMP (Environmental Risk Mitigation & Monitoring Plan) Management MatrixATT Activity Potential

Environmental Risks & Impacts

Mitigation Measures & BMPs (Best Management Practices)

Monitoring Indicators M & E Responsibility

Planned Monitoring (M) & Reporting (R) Frequency

From ATT 2014 Annual Workplan & Project IEE Requirements

Risks Associated with IFDC FTF-ATT Activities

Mitigation of Risks from Sector Activities

Indicators of Sector Best Management Practices

Responsible Staff Member: Name(s) to Train on Sector BMPs & Monitor & Evaluate Risk Reduction Success

M = ? (continuous, weekly, monthly)R = ? (quarterly, biannually, annually)

Crop & Seed Production, Processing, Testing Input (potentially pesticide) Risks: Negative Determination with Conditions

IEE, page 5: “the preparation and BEO approval of PERSUAPs”

No analysis done of new integrated pest management technologies including pesticide risks

Complete the 2013 ATT PERSUAP

PERSUAP done. PERSUAP

recommendations followed, as practicable.

Baseline: No PERSUAP

M&E Specialist M=ContinuousR=Annually

Safer pesticide management practices not implemented.

Implementation of the SUAP and compliance with recommended Safer Use Measures.

Results of inspection visits at randomly selected farms.

AOR, MEO and/or REA

M&R (biannual)

Use of pesticides with high toxicity or potential to adversely impact the environment.

Conduct training on safer pesticide use and pesticide first aid.

Conduct training on maintenance of appropriate PPE and application equipment.

Conduct training on safe pesticide selection, purchase, handling, storage and disposal practices.

Pesticide safety and PPE usage understood and used by target farmers

Training records maintained.

Pesticide usage records maintained (per templates and forms in Annexes 9 and 10)

Baseline: ..% of target farmers using PPE. TBD

Sub-grantees report to ATT Grants Manager

2013 Ghana ATT PERSUAP 99

ATT Activity Potential Environmental Risks & Impacts

Mitigation Measures & BMPs (Best Management Practices)

Monitoring Indicators M & E Responsibility

Planned Monitoring (M) & Reporting (R) Frequency

From ATT 2014 Annual Workplan & Project IEE Requirements

Risks Associated with IFDC FTF-ATT Activities

Mitigation of Risks from Sector Activities

Indicators of Sector Best Management Practices

Responsible Staff Member: Name(s) to Train on Sector BMPs & Monitor & Evaluate Risk Reduction Success

M = ? (continuous, weekly, monthly)R = ? (quarterly, biannually, annually)

after baseline survey.

Workplan, page 3: “..developing public institutions’ and private businesses’ capacities to introduce new technologies and supply agricultural inputs in collaboration with other stakeholders”

The word “inputs” can include pesticides; it can also include preventive (non-chemical) Integrated Pest Management (IPM) tools/tactics

Promotion or Use of non-EPA registered pesticides, certain RUP pesticides

Promotion or Use of banned pesticides

Preventive (non-chemical) Integrated Pest Management (IPM) inputs (tools/tactics) not known, or understood, or used

If pesticide inputs might be promoted, it would likely be done through sub-grantees working with agrodealers. Thus sub-grantee grant language would contain wording on which pesticides might be supported, as part of IPM, and which cannot be supported in any way.

Sub-grantees to perform training on IPM tools and tactics recommended in the PERSUAP, including pesticides, as well as pesticide use safety.

Grants contain IPM and safe pesticide use language as recommended by PERSUAP

No PERSUAP rejected pesticides promoted or used with AID resources

Preventive IPM tools and tactics understood and used for maize, rice and soybean target farmers

Training records maintained.

Baseline: ..% of target farmers using unregistered, rejected, or banned pesticide. TBD after baseline survey.

Sub-grantees report to ATT Grants Manager

M=ContinuousR=Annually

Activities involving land and water management improvement, watershed management, soil erosion control: Negative Determination with 2013 Ghana ATT PERSUAP 100

ATT Activity Potential Environmental Risks & Impacts

Mitigation Measures & BMPs (Best Management Practices)

Monitoring Indicators M & E Responsibility

Planned Monitoring (M) & Reporting (R) Frequency

From ATT 2014 Annual Workplan & Project IEE Requirements

Risks Associated with IFDC FTF-ATT Activities

Mitigation of Risks from Sector Activities

Indicators of Sector Best Management Practices

Responsible Staff Member: Name(s) to Train on Sector BMPs & Monitor & Evaluate Risk Reduction Success

M = ? (continuous, weekly, monthly)R = ? (quarterly, biannually, annually)

Conditions Workplan, page 6: “In

the project context, ISFM technologies are not only limited to integrated soil fertility management but encompass a wide range of technologies, including land preparation, planting, harvesting and post harvest handling.”

Risk of slash and burn with forest degradation, loss of biodiversity, loss of topsoil and loss of soil fertility.

Train on and use soil tests, crop rotation, composting, fallow periods, fertilizers, ISFM, and no burning.

Low risk of topsoil loss due to small size of parcels and low slope of land

Low risk to forestry and biodiversity, due to uniformity and relatively small parcels tilled (of total available)

Presence of soil test results

Soil test recommendations followed and amendment use

Crop rotation practiced Baseline: .. of target

farmers using ISFM practices. TBD after baseline survey.

ISFM AdvisorM&E Specialist

M=ContinuousR=Annually

New Seed Varieties, and GMO Introduction Risks: Negative Determination with Conditions, and Deferral for GMOs

Workplan page 6 “…developing and disseminating improved seed”

Agroclimatic zone not appropriate

Introduction of exotic invasive species, displacing local biodiversity

Ensure that imported genetic material and seeds are adapted to Tamale Savannah environment

Ensure that imported genetic material and seeds are certified to be not contaminated with seed from other species

Only adapted certified seeds used

Baseline: ..% of target farmers using improved seed. TBD after baseline survey.

Seed AdvisorM&E Specialist

M=ContinuousR=Annually

Workplan page 22 Lack of USAID biosafety Commission a USAID Work closely with PBS Seed Advisor M=Continuous

2013 Ghana ATT PERSUAP 101

ATT Activity Potential Environmental Risks & Impacts

Mitigation Measures & BMPs (Best Management Practices)

Monitoring Indicators M & E Responsibility

Planned Monitoring (M) & Reporting (R) Frequency

From ATT 2014 Annual Workplan & Project IEE Requirements

Risks Associated with IFDC FTF-ATT Activities

Mitigation of Risks from Sector Activities

Indicators of Sector Best Management Practices

Responsible Staff Member: Name(s) to Train on Sector BMPs & Monitor & Evaluate Risk Reduction Success

M = ? (continuous, weekly, monthly)R = ? (quarterly, biannually, annually)

“Build research capacity for genetically engineered seed”

analysis Local knowledge on

GMOs is insufficient

biosafety analysis and check with national biosafety authorities for any new GMOs that are introduced for research

Science based publications and information materials

on biosafety issues Publications and

information materials disseminated

Baseline: No Biosafety Study

M&E Specialist R=Annually

Small Grant Facility Risks: Negative Determination with Conditions Workplan page 28

“Grants mechanism…to expand the availability and use of new technologies”

New technologies could include provision of pesticides

New technologies could include manufacture of soy processors and agric machinery spare parts

New technology could include processing soybean to soy milk

Grants contain language and grantees follow PERSUAP recommendations on allowed and rejected pesticides

Grants contain language and grantees follow good manufacturing and processing practices (see Annex 1)

Percent of grantees following PERSUAP recommendations

Percent of grantees following good manufacturing and processing recommendations

Baseline : % each of target manufacturers and processors understand and use good manufacturing and processing practices. TBD after baseline survey.

Sub-grantees report to ATT Grants ManagerM&E Specialist

M=ContinuousR=Biannually

Fertilizer System and Deep Placement Risks: Negative Determination with Conditions

2013 Ghana ATT PERSUAP 102

ATT Activity Potential Environmental Risks & Impacts

Mitigation Measures & BMPs (Best Management Practices)

Monitoring Indicators M & E Responsibility

Planned Monitoring (M) & Reporting (R) Frequency

From ATT 2014 Annual Workplan & Project IEE Requirements

Risks Associated with IFDC FTF-ATT Activities

Mitigation of Risks from Sector Activities

Indicators of Sector Best Management Practices

Responsible Staff Member: Name(s) to Train on Sector BMPs & Monitor & Evaluate Risk Reduction Success

M = ? (continuous, weekly, monthly)R = ? (quarterly, biannually, annually)

Workplan pages 17 & 20, “..promoting the judicious use of mineral fertilizers in combination with locally available soil amendments..” & “Strengthen ISFM and Fertilizer Supply Chain”

Potential users not trained in integrated soil fertility management (ISFM)

Little use of local soil amendments

Perform training in proper fertilizer handling, storage, use and application techniques and fertilizers are employed according to the best practices, promoting ISFM

Percent of beneficiary farmers using ISFM

Baseline: % of target farmers understand and use ISFM practices. TBD after baseline survey

ISFM AdvisorM&E Advisor

M=ContinuousR=Annually

2013 Ghana ATT PERSUAP 103

2013 Ghana ATT PERSUAP 104