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TRACKING ID: LAC-IEE-17-51

IEE AMENDMENTPERSUAP AMENDMENT APPROVALPROJECT/ACTIVITY DATAProject/ Activity Name: Increasing Regional Economic Integration DO 1 PAD

for Regional EG: Activities- Regional Trade and Market Alliance (RTMA) & Regional Trade Facilitation and Border Management (RTFBM)

Amendment (Y/N): YImplementation Start/End: FY2010 to FY 2023Solicitation/Contract/Award Number: Project No. 596-0203.

RTMA USAID-596-C-13-0001:RTFBM in design

Implementing Partner(s): RTMA: Nathans Associates, RTFBM: TBD

Geographic Location(s): RTMA-Guatemala, Honduras, El Salvador and Nicaragua.RTFBM- Central America

Tracking ID/link: LAC-IEE-17-51Tracking ID/link of Related RCE/IEE (if any): LAC-IEE-16-20

http://gemini.info.usaid.gov/repository/pdf/46806.pdfTracking ID/link of Other, Related Analyses: NA

ORGANIZATIONAL/ADMINISTRATIVE DATA

Implementing Operating Unit(s): (e.g. Mission or Bureau or Office)

USAID/CAM Regional

Funding Operating Unit(s):(e.g. Mission or Bureau or Office)

CAM Regional, El Salvador Bilateral

Funding Account(s): DV, ESFFunding Amount: $75,000,000 CAM Regional

$25,000,000 El Salvador BilateralAmendment Funding Amount:

Amendment Funding Date:

Other Affected Unit(s): NALead BEO Bureau: Diana Shannon LACPrepared by: Lorena Aceto, EG (USAID/El Salvador)Date Prepared: August 30, 2017

ENVIRONMENTAL COMPLIANCE REVIEW DATA

Analysis Type: IEE DO level and PERSUAPEnvironmental Determination(s): CE and NDWCAdditional Analyses/Reporting Required: NAAnalysis Expiration Date: FY2023

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TRACKING ID: LAC-IEE-17-51

1.0 PURPOSE AND SCOPE

This IEE amendment is Amendment 1 of LAC-IEE-16-20. This IEE amendment focuses on two Activities that were covered in LAC-IEE-16-20: Regional Trade and Market Alliance (RTMA) and Regional Trade Facilitation and Border Management (RFTBM). All actions for these two Activities were analyzed for their environmental impact and covered under the existing IEE. This IEE amendment specifically includes an update to LAC-IEE-16-20 as follows:

1. Extend time of DO1 LAC-IEE-16-20 from 2020 to 2023 to cover the new Regional Trade Facilitation and Border Management Activity.

2. Approve the Regional Trade and Market Alliance Activity PERSUAP Amendment: The RTMA included actions to process agricultural produce but did not envision the use of pesticides under the prior IEE. The Implementing Partners were told by export firms that produce such as chia, passion fruit and plantain, needed to be fumigated using pesticides for exporting purposes. Therefore, an amendment to the PERSUAP (approved in February 2016) was prepared for this Activity to cover these products. This PERSUAP amendment is approved and becomes effective upon signature of this document. The PERSUAP amendment is attached as Attachment 1. The February 2016 PERSUAP remains in effect.

3. Update actions for Regional Trade Facilitation and Border Management: The RTFBM is a new Activity in design as of August 30, 2017. This Activity will build upon RTMA actions, but will not involve any agriculture production, processing, or marketing. The actions of RTFBM have been analyzed in LAC-IEE-16-20, but updates on actions are included in this amendment as per the chart below. In summary:

A. Positive Determination- REMOVE (Sub IR 1.1.2 f): the Activity was given a Positive Determination for large scale construction in LAC-IEE-16-20. Due to the lack of funds and changes in Activity goals, the Activity will not implement large scale construction.

B. Small Scale Construction -ADD (sub IR1.1.1e): The RTFBM will implement small scale construction at borders as the RTMA did. Thus RTFBM Activity is being added to sub IR1.1.1.e Small Scale Construction. NOTE: this action of small scale construction has been analyzed in LAC-IEE-16-20 for the RTMA, and the actions and impacts listed in the previous IEE are the same for the RTFBM Activity.

Following is the LAC-IEE-16-20 Table of Activities and Determination changes for the RTFBM. Note: All other actions and determinations on the Table in LAC-IEE-16-20 remain the same.

Environmental Determinations for CAM DO1 Increasing Regional Economic IntegrationIR/Sub IR/ Illustrative Activity Determination MechanismIR 1.1 – Regional Trade ExpandedSub IR1.1.1. Trade facilitation improvede. Improve border facilities for small Negative Regional Trade & Marketscale construction such as electrical, Determination with Alliancesbathroom repairs, building repairs, minor Conditionsreconstruction to retrofit new equipment, Regional Tradeantenna equipment placement. Facilitation and Border

ManagementACTIVITY ADDED BY

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TRACKING ID: LAC-IEE-17-51Environmental Determinations for CAM DO1 Increasing Regional Economic IntegrationIR/Sub IR/ Illustrative Activity Determination Mechanism

THIS AMENDMENT; ALREADY ASSESSED IN LAC-IEE-16-20

Sub-IR 1.1.2. Transportation modernized and logistics efficiency improvedf. Possible action: Improve multimode

transport infrastructure - large scale construction of roads and port, rail and airport facilities.

Positive Determination Regional Trade Facilitation and Border Management including El Salvador Trade Facilitation Component BEING REMOVED BY THIS AMENDMENT.

4. Add Climate Risk Management (CRM) Chart for Regional Trade Facilitation and Border Management activity: The CRM for the new RTFBM Activity was completed on June 27, 2017. The CRM was done by EG staff, including the CRM Point of Contact. The RTFBM activity received a low risk for the Categorical Exclusion actions (dealing with technical assistance, training, policy development) as the CRM identified that training and technical assistance actions would not be conducted during extreme weather events (such as storms or hurricanes) and that venues could be moved to areas not prone to floods. A medium risk was given for small scale construction as on-going or final construction facilities could deteriorate due to extreme heat or heavy rains. See Attachment 2 to this IEE amendment for the CRM chart.

2.0 CERTIFICATION OF COMPLIANCE All other aspects of the project design/activities and geographic scope remain unchanged from

previous environmental analyses in LAC-IEE-16-20 except as changes made above. No new actions will be implemented that haven’t already been analyzed in LAC-IEE-16-20. As required in LAC- IEE-16-20 for small scale infrastructure, the RTFBM shall prepare Environmental Mitigation and Monitoring Plan (EMMP) for small scale construction.

Annual Work Plan(s) have been verified to undertake only those activities proposed and all reporting requirements have been adhered to and remain unchanged. This project is in compliance now with the completion of the PERSUAP as described above.

There has been no change to the climate risk screening/management of the project in accordance with Mandatory Reference for ADS Chapter 201 on Climate Risk Management for USAID Projects and Activities. A CRM analysis was approved for the RTFBM Activity and is included as Annex 2 to this Amendment. See above in #4 for a summary of the CRM.

3.0 REVISIONSPer 22 CFR 216.3(a)(9), when ongoing programs are revised to incorporate a change in scope or nature, a determination will be made as to whether such change may have an environmental impact not previously assessed. If so, this environmental analysis will be amended to cover the changes. Per ADS 204, it is the responsibility of the USAID A/COR to keep the MEO/REA and BEO informed of any new information or changes in the activity that might require revision of this environmental analysis and threshold determination.

Attachment 1: Regional Trade and Market Alliance PERSUAP AmendmentAttachment 2: Climate Risk Management assessment completed for the Regional Trade Facilitation and Border Management Activity

Attachment 1

USAID REGIONAL TRADE AND MARKET ALLIANCES PROJECTAmendment to Pesticide Evaluation Report and Safer Use Action Plan – for the “Better Coffee Harvest” Project for Chia, Passion Fruit, and Plantain in El Salvador and Nicaragua

June 2017This document was prepared with support from the American people through the United States Agency for International Development (USAID). Its contents are the sole responsibility of the author(s) and do not necessarily reflect the views of USAID or of the Government of the United States of America.

PESTICIDE EVALUATION REPORT AND SAFER USE ACTION PLAN (PERSUAP)

Amendment to the Pesticide Evaluation Report and Safe User Action Plan (PERSUAP) “Better Coffee Harvest” Project for Chia, Passion Fruit, and Plantain in El Salvador and Nicaragua

USAID Regional Trade and Market Alliances Project, - Nathan Associates Inc.

El Salvador, June 2017

Report AuthorsMichelle Rodríguez, Sun Mountain International, SMTN Mike Seager, SMTN

Technical SupportClaudia Hasfura, USAID, Regional Trade and Market Alliances Project Zuleima Zhang USAID, Regional Trade and Market Alliances ProjectCarlos Morales, Consultant of the USAID, Regional Trade and Market Alliances Jaime Arnoldo Amaya, ACOPASCAJulian Oscar Escamilla, ACOPASCARafael Mata, Plataneros y Bananeros de El Salvador, PYBES Otho Ludwing Argueta, FUSADESEdwin de León, FUSADES Michelle Jaramillo, SMTN Francisco Silva, SMTN

Contents1. INTRODUCTION......................................................................................................1

1.1. USAID Procedures for Environmental Compliance.........................................1

1.2. Background......................................................................................................1

1.3. PERSUAP Methodology..................................................................................4

2. DESCRIPTION OF THE PROJECT.........................................................................5

3. PESTICIDE EVALUATION REPORT (PER)..........................................................10

3.1. (Factor A) USEPA Registration Status of the Proposed Pesticides............10

3.2. (Factor B) Basis for the Selection of Pesticides..........................................11

3.3. (Factor C) Extent to which the proposed pesticide use is, or could be part of an Integrated Pesticide Program (IMP) program....................................................15

3.4. (Factor D) Proposed method or methods of application, including the availability of application and safety equipment.....................................................17

3.5. (Factor E) Any acute and long-term toxicological hazard, either human or environmental, associated with the proposed use, and measures available to minimize such hazards...........................................................................................18

3.6. (Factor F) Effectiveness of the requested pesticide for the proposed use . 19

3.7. (Factor G) Comparability of the proposed pesticide use with target and non- target ecosystems..................................................................................................20

3.8. (Factor H) Conditions under which the pesticide is to be used, including climate, geography, hydrology, and soils...............................................................20

3.9. (Factor I) Availability of other pesticides or non-chemical control methods. 23

3.10. (Factor J) Host country’s ability to regulate or controle the distribution, storage, use, and disposal of the requested pesticide...........................................24

3.11. (Factor K) Provision of training for users and applicators........................25

3.12. (Factor L) Provision made for monitoring the use and effectiveness of each pesticide.................................................................................................................26

4. GENERAL PROBLEMS AND MITIGATION MEASURES.....................................28

5. SAFER USE ACTION PLAN (SUAP).....................................................................31

4. BIBLIOGRAHIC REFERENCES............................................................................40

Annex 1 SMTN Team.............................................................................................42

Annex 2 Stakeholders consulted............................................................................44

Annex 3 Nathan Associates Plantain Plant Field Trip Report 2/17........................45

Annex 4 Pesticides Factsheets..............................................................................48

Annex 5 Exposure to Pesticieds, Toxicological Hazards and Mitigation Measures............................................................................................................................... 75

Annex 6 EPA Recommended Worker Protection Standard...................................79

Annex 7 Mitigation of Potential Pesticide Hazards and General Meassures to Ensure Safe Use....................................................................................................82

Annex 8 Pesticide Disposal Options.......................................................................85

Annex 9 Websites on Pesticides............................................................................89

Annex 10 Photos....................................................................................................91

LIST OF FIGURES

Figure 1. Location of ACOPASCA’s Production Plant.....................................................3Figura 2. Location of the Agroindustrial Complex “Ing. Héctor Lara Zamora”...............21

LIST DE TABLES

Table 1 Fungicides for Post-Harvest Mxture Preparation................................................7Table 2 EPA Registration of the Requested Pesticides................................................10Table 3 Classification of Toxicity According to EPA......................................................11Table 4 WHO Toxicity Classification..............................................................................12Table 5 Basis for Selection of Requested Pesticides....................................................13Table 6 Proposed Methods of Application.....................................................................17Table 7 Acute and Long Term Toxicological Hazard.....................................................18Table 8 Effectiveness of the Pesticide Requested for the Proposed Use.....................19Table 9 Potential Problems and Mitigation Measures...................................................28Table 10 Environmental Monitoring...............................................................................33Table 10 List of Stakeholders consulted........................................................................44Table 12 Action in case of poisoning emergency.........................................................76Table 12 Risk Assessment Aluminum Ammonium Sulfate (Alumbre)..........................78Table 13 Toxicity Category by Exposure Route and final use of the product...............79Table 14 Personal Protective Equipment (PPE) (body protection)...............................80Table 15 Personal Protective Equipment (PPE) (Hands Protection)............................80Table 16 Personal Protective Equipment (PPE) (eyes protection)...............................80Table 17 Personal Protective Equipment (PPE) (foot protection).................................81Table 18 Personal Protective Equipment (PPE) (airways protection)..........................81Table 19 Personal Protective Equipment (PPE) (Head protection)..............................81Table 21 Pesticides Regulated as Hazardous Toxic Wastes or Extremely Hazardous Toxic Wastes.................................................................................................................88

LIST DE PHOTOS

Photo 1 and Photo 2 Two “hands” of plantain (Musa sp) Affected by Crown Rot.........15Photo 3 and Photo 4 Plantains (Musa sp) Affected by por la Anthacnose....................16Photo 5 Water Discharge Pit Located in ACOPASCA..................................................91Photo 6 Fumigation Chamber........................................................................................91Photo 7 Pesticide Mixture Tank.....................................................................................92Photo 8 Water Discharge Pit.........................................................................................92Photo 9 Storage Tank of Water from the Well...............................................................93Photo 10 ACOPASCA workers without the full Personal Protective Equipment...........93

ACRONYMSACOPASCA Cooperative Association of San Carlos de R.L. ADESCO Association for community DevelopmentANDA National Administration of Aqueducts and Sewerage CFR Code of Federal RegulationsCRS Catholic Relief ServicesEPA United States Environmental Protection AgencyFUSADES Salvadoran Foundation for Economic and Social Development GAP Good Agriculture PracticesGMP Good Manufacturing PracticesGRAS Generally Recognized as SafeIEE Initial Environmental ExaminationIPM Integrated Pest ManagementMAG Ministry of Agriculture and Livestock, El SalvadorMARN Ministry of the Environment and Natural Resources, El Salvador PPE Personal Protective EquipmentPERSUAP Pesticide Evaluation Report and Safer Use Action Plan PYBES Plantain and Banana Producers Organization of El Salvador REA Regional Environmental AdviserRCRA Federal Law of Conservation and Recovery of Resources SMTN Sun Mountain InternationalUSAID United States Agency for International Development WHO World Health OrganizationWPS Worker Protection StandardsRTMA Regional Trade and Market Alliance Project

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1. INTRODUCTION1.1. USAID Procedures for Environmental Compliance

USAID Environmental Compliance Procedures (22 CFR 216) require that all the United States Agency for International Development (USAID) -funded activities that purchase or use pesticides conduct a Pesticide Evaluation and Safer Use Action Plan (PERSUAP), according to the 22 CFR 216.3(b) guidelines.

The purpose of a PERSUAP is to ensure that the risks to human health and the environment associated with the use of pesticides, their handling, storage and disposal are minimized.

The Pesticide Evaluation Report (PER) consists of 12 factors to assess the risk of the pesticide required in 22 CFR 216.3(b), and is used as the basis to establish requirements to ensure that the risks to human health, flora and fauna and the environment are minimized (See Chart A).

The set of pesticides authorized and the requirement for their safe use, form the base for the Safer Use Action Plan (SUAP).

1.2. Background

In February 2016, USAID approved The Better Coffee Harvest Project PERSUAP, which analyzed pesticides for safe use on coffee crops in El Salvador and Nicaragua. Besides coffee, the report analyzes chia crops (Nicaragua), plantain (El Salvador), and passion fruit (both countries). The report then analyzed the use of pesticides for these crops and recommended azoxystrobin for plantain cropping.

Nathan Associates, through the USAID Regional Trade and Market Alliances Project (RTMA), supports the Central American countries to achieve inclusive economic growth, enhancing intra-regional trade and exports. As part of the activities

CHART A – ANALYSIS OF 12 PESTICIDES FACTORS

Factor 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 of training for users and applicators.

Factor L. Provision made for monitoring the

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implemented, the project provided technical assistance to organizations selected in four countries (El Salvador, Guatemala, Honduras and Nicaragua) to strengthen their managerial and technical capacities, and to link them to regional or international value chains through a sustainable model. One of the beneficiary organizations was the Asociación Cooperativa San Carlos de R.L. (ACOPASCA)–El Paisnal located in the Agroindustrial Complex Ing. Héctor Lara Zamora in the Department of San Salvador, El Salvador (See Figure 1). In addition to providing training and technical assistance to this organization, Nathan Associates, funded a fumigation chamber for the plantain processing and packing plant to help the organization meet the basic requirements to export its product.

The fumigation center would be utilized to treat plantains with two pesticdes that are required by international buyers. The two pesticides in question are Azoxystrobin and Tiabendazole, which require USAID approval through the project’s PERSUAP. ACOPASCA also requires the use of Aluminum Sulfate, which is a salt formula Al2(SO4)3

Joe Torres, Regional Environmental Adviser (REA) for Central America, visited the facilities of the ACOPASCA Plant on February 17, 2017 to monitor its operations and identify potential impacts and improvements to USAID-funded interventions. Subsequently, REA requested the preparation of this document to amend the PERSUAP. (See Annex 3 Nathan Associates Plantain Plant Field Trip Report.)

This document serves to to amend The Better Coffee Harvest Project PESUAP by adding the analysis of Azoxystrobin, Thiabendazole and the salt formula Al2(SO4)3 Aluminum Sulphate in post-harvest processing. The use of these pesticides in the post-harvest processing stage are a requirement of the international plantain buyers interested in exporting plantains from the ACOPASCA plant.

Figure 1. Location of ACOPASCA’s Production Plant

Source: SMTN, 2017.

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1.3. PERSUAP Methodology

This amendment to the PERSUAP of The Better Coffee Harvest Project involved reviewing the information provided in the existing regional PERSUAP, and updating it according to the specific needs of the ACOPASCA Plant. This involves analysis of the pesticides requested by the buyer (Chiquita) through the Plantain and Banana Producers of El Salvador (PYBES, in Spanish), and recommending suitable practices for the post-harvest processing of plantains for export.

Fieldwork to develop this document was carried out from April 17 to 19, 2017 by the Sun Mountain International (SMTN) team (see Annex 1 SMTN Team 1 for Sun Mountain Team Resumè). Nathan Associates Inc.’s M&E Specialist accompanied the team to all field visits and interviews conducted for this study. In addition, the technical staff of Nathan Associates and the ACOPASCA Plant provided all the necessary information to develop this document.

Nathan staff and ACOPASCA employees were interviewed, as well as plantain buyers as detailed below (for more details, see Annex 2 Stakeholders Consulted):

• ACOPASCA employees• Clinton Foundation // ACCESO Oferta Local El Salvador• Walmart• PYBES• ACOPASCA’s staff• Laboratorios Falmar• Salvadoran Foundation for Economic and Social Development (FUSADES, in

Spanish), local technical partner of the RTMA project.

It is important to mention that the study only analyzes the products that will be used in the fumigation chamber; more specficially, the products requested by one of the buyers who requires this for export purposes. The local market does not require any type of fungicide to be applied. Therefore, the scope of this study is post-harvest treatment and not crop management.

DOCUMENT REVIEWIn addition to the fieldwork, the Team carried out an extensive document review to:

• Determine the status of the registration of pesticides (both in El Salvador and in the US), and the toxicological profiles of each one of the registered products;

• Gather information on the twelve (12) pesticide analysis factors, as set out in 22 CFR 216.3(b) and use this as a basis for establishing the requirements to minimize risks to human health and the environment;

• Prepare an Action Plan for Safer Use;• Review other relevant documentation, such as the Cacao Alliance PERSUAP

conducted by Catholic Relief Services (CRS) El Salvador in May 2016.

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2. DESCRIPTION OF THE PROJECTThe USAID Regional Trade and Market Alliance Project supports the Central American countries in achieving inclusive economic growth and improving intraregional trade and exports. The aim of the project is to establish consolidated regional value chains and improve market access for critical food products through stronger market alliances and greater trade facilitation, harmonization and institutional capacity.

The project began in April 2013 and extended through an option period through April 2018. The project is based in San Salvador, El Salvador; however, it has a regional scope and carries out activities in El Salvador, Costa Rica, Panama, Honduras, Guatemala, and Nicaragua. The project activities focus on two areas:

1. Develop critical agricultural value chains, linking small and medium-sized producers to regional and export markets, and the consolidation of intra-regional value chains to take full advantage of underutilized trade opportunities and open up new opportunities for new market niches.

2. Improve trade facilitation and regional trade capacity by strengthening the capacity of the private sector and the capacity of regional institutions to advance in the harmonization of customs procedures, trade administration, border management, transportation, logistics and other trade related mechanisms.

BACKGROUND TECHNICAL ASSISTANCE UNDER THE VALUE CHAIN COMPONENT:

In 2013, the project established an action plan to select relevant regional value chains and stakeholders, including local technical partners, producers, potential and / or actual buyers, and public entities. Once the organizations were selected, they were studied to identify improvement opportunities that could directly affect their productive capacity, competitiveness and competencies that would allow them to be part of a sustainable value chain.

In addition to the technical training provided to each organization, the project identified and donated equipment (specialized machinery) to strengthen the production capacity of organizations, industrial safety equipment (fire extinguishers, signage, personal protective equipment –PPE-), equipment for safe storage of products (pallets, wood planks, baskets) and other equipment to improve working conditions in the organizations (lockers, etc.). This equipment was procured through a committee comprising representatives of organizations, project experts, representatives of the local technical partner and independent experts. Once the equipment was installed, the project provided training and technical assistance to ensure adequate use of the equimpment and complementary training to strengthen the organizational capacity of the beneficiaries (administrative and financial competencies). The Project also developed materials such as the Industrial Safety Guide, which is now part of the

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standard procedure manuals, to ensure a work environment that mitigates occupational hazards.

In the case of ACOPASCA (one of the organizations selected through the grant program), the Project donated a plantain fumigation chamber to help package plantains for export.

FUSADES, RTMA’s local technical partner, also assisted ACOPASCA in best agricultural and manufacturing practices for harvesting and export activities. FUSADES also lent support in the design and construction of filtration wells to handle agrochemicals. In general, ACOPASCA has received various trainings from its buyers and FUSADES on the application and use of agrochemicals on crops, according to Good Agricultural Practices (GAP) and Good Manufacturing Practices (GMP), on Integrated Pest Management (IPM), fungicide management in cropping, etc. In addition, during 2016, a new training plan for the implementation of GAP and GMP in harvest and post-harvest was coordinated with Walmart and PYBES. Buyers are constantly monitoring the implementation of these type of practices, and if standards are not met, the organization may face commercial restrictions imposed by the buyer.

Collaborating with local technical entitites helps ensure the sustainability of the technical assistance that has been provided by the project beyond its term and scope. A partnership was formed with PYBES to evaluate the agrochemical control plan, in addition to establishing a phytosanitary control plan in accordance with the EPA. FUSADES intends to continue training and strengthening the organizations within the framework of other cooperation initiatives.

POST-HARVEST REQUIREMENTSOne of the international buyers (Chiquita) requires the application of the following pesticides on plantains for exports:

1. Azoxystrobin2. Tiabendazole

In addition, Chiquita requires the use of aluminum sulfate in combination with the other two (2) proposed active ingredients mixed with 150 liters of water in the plantain bath. This mixture will be applied, in the doses detailed in the table below, directly to the plantains through the fumigation chamber, which will start operating once this amendment to the PERSUAP is approved.

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Table 1 Fungicides for Post-Harvest Mxture Preparation

8

9

Source: PYBES, 2017.

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3. PESTICIDE EVALUATION REPORT (PER)

As detailed in 22 CFR 216 of the US Government, any USAID-funded project that includes support to purchase, promote, or use of pesticides should analyze its suggested use and develop a Pesticide Evaluation Report (PER) which addresses the twelve (12) factors of pesticide analysis proposed by USAID, and a Safer Use Action Plan (SUAP) that outlines measures to mitigate and/or control potential human health and environmental impacts.

The SMTN team evaluated two (2) pesticides and (1) salt (Aluminum Sulphate) required by the ACOPASCA cooperative to process and package exports plantains. The Ministry of Agriculture and Livestock (MAG) and the Environmental Protection Agency (EPA) have approved the use of these pesticides in El Salvador. Following is the detailed analysis of each one of the products.

3.1. (Factor A) USEPA Registration Status of the Proposed Pesticides

The international buyers of Plantains from the ACOPASCA Plant requested the use of two (2) pesticides.

1. Azoxystrobin2. Tiabendazole

From these pesticides, the use of azoxystrobin on plantains has been approved in El Salvador, by The Better Coffee Harvest Project PERSUAP. Nonetheless, the use was considered on the crop and not for post-harvest processes. Therefore, it will be added to the analysis in this document to ensure that the specific implications of its use in the post-harvest are considered.

The following table shows the registration status of each pesticide in the USEPA and by the Government of El Salvador. For more details about each active ingredient, see Annex 4 Factsheets Pesticides).

Table 2 EPA Registration of the Requested Pesticides

No. Type of pesticide

Commercial Name

Active Ingredient Dose

EPA RegistrationRUP/GUP

Registrati on in El

SalvadorUse Description

(Yes/No) PCCode

1. Fungicide Amistar 50WG Azoxystrobin 60 gr Yes 128810 GUP Yes

Azoxystrobin is a fungicide used to inhibit the contagion of pests.

1

2. Funguicide Mertect 50 SC Tiabendazole 90 cm3 Yes 060101 GUP Yes

Tiabendazole is used to control stans, rot, and other negative

1

No. Type of pesticide

Commercial Name

Active Ingredient Dose

EPA RegistrationRUP/GUP

Registrati on in El

SalvadorUse Description

(Yes/No) PCCode

effects caused by fungus.

Source: USEPA, 2017 and List of Agrochemical Products Approved in El Salvador, 2017

In addition, the international buyers have requested the use of Aluminum Sulphate (this is not a pesticide) as a healing element, to avoid plantain from staining with the natural latex that emanates from the product when it is cut.

The information collected shows that it is found that all the pesticides registered in the USEPA.

Issue: Not all ACOPASCA personnel are familiar with the information on EPA's

hazards classification.

Mitigation Measure:• All ACOPASCA personnel must be trained, on an ongoing basis, on the use of

EPA classification tables.1 It is important as EPA's active ingredient classifications are continually reviewed.

Issue:

• Phase I of the project has ended; at this stage, a PERSUAP should have been conducted.

Mitigation Measure:

• The project must train ACOPASCA on PERSUAP for this cooperative.

3.2. (Factor B) Basis for the Selection of Pesticides.

The two (2) pesticides requested by the Project have been approved by the Government of El Salvador, therefore their use is recommended given they are approved by both US-EPA and the Government of El Salvador.

The recommendation for approved pesticides is based on the toxicological classification of US-EPA and World Health Organization (WHO). The following tables show the EPA and WHO Toxicity classifications.

Table 3 Classification of Toxicity According to EPA

1 Ver https://iaspub.epa.gov/apex/pesticides/f?p=chemicalsearch:1

1

Class Descriptive terminology

Mammels LD50 Mammels Inhalation

LC50

Irritation Aquatic Invert/Fish

(LC50 o EC50)2

Honeybee

Oral Skin Eye1 Skin

I ExtremeToxicity ≤50 ≤200 ≤0.2 Corrosive Corrosive < 0.1

II High Toxicity 50-500 200-2000 0.2-2.0 Severe Severe 0.11-1.0 < 2 µg/bee

III Moderate Toxicity

500-5000

2000-20000 2.0-20 No Corneal

opacity Moderate 1.1-10.0 2.1-11µg/bee

IV Toxicidad ligera ≥5000 ≥20000 ≥20 None Moderate

or light 10.1-100

Relatively non- toxic 101-1000

Practically toxicity 1001-10,000 > 11

µg/abejaNon-Toxic > 10,000

Soude: Environmental Protection Agency, 2016.

Table 4 WHO Toxicity Classification

Class Descriptive TerminologyOral LD50 for Rats (mg/kg

body weight)Skin LD50 for Rats (mg/kg

corporal weight)Solid Liquid Solid Liquid

Ia Extremly hazardous ≤5 ≤20 ≤10 ≤40Ib Highly hazardous 5-50 20-200 10-100 40-400II Moderatly Hazardous 50-500 20-2000 100-1000 400-4000III Slightly Hazardous ≥501 ≥2001 ≥1001 ≥4001

U Sever danger in normal use- unlikely ≥2000 ≥3000 - -

Source: WHO, 2016.

Table 5 Basis for Selection of Requested Pesticides2

No. Type of Pesticide

Active Ingredient

Registration in El

Salvador (Yes/No)

EPA Toxicity Classification

Who Toxicity Classification Toxicological Description

Use Recommended in the Project

(Yes/No)Observation for Selections

1. Funguicide Azoxystrobin Yes IV UOb

Azoxystrobin is a fungicide of acute and chronic mild toxicity in humans, birds, mammals and bees; but with high toxicity in fish and aquatic invertebrates of fresh and salt water and highly toxic in estuarine and marine invertebrates.

It is a non-cancerous product.In permeable soils where the water is shallow, it can contaminate it.3

Yes

It is recommended to approve for use in the ACOPASCA Plant since it is registered in both El Salvador and USEPA. In addition, it is classified with slight toxicity in USEPA. (For more information. see Annex 4 Factsheet).

2. Funguicide Tiabendazole Yes III U

Thiabendazole is a product of mild acute toxicity. The USEPA considers it is carcinogenic product if used in very high doses that could affect the thyroid and the liver. The recommended dosages for use of this product are far from causing cancer. Thiabendazole is practically non-toxic in birds and mammals, but it is highly toxic in estuarine and freshwater fish andinvertebrates. 4

Yes

It is recommended to approve for use in the ACOPASCA Plant since it is registered in both El Salvador and USEPA. In addition, it is classified with slight toxicity in USEPA. (See Annex 4 Factsheet for more information).

Source: The Better Coffee Harvest Project, EPA, PesticideInfo y SMTN, 2017.

2 The information to prepare this table was taken from both of The Better Coffee Harvest Project, https://iaspub.epa.gov/apex/pesticides/f?p=chemicalsearch:1 and http://www.pesticideinfo.org/.3 Taken literally from The Better Coffee Harvest Project PERSUAP. Table 2. Status of Pesticide registration according to USEPA and the reasons for the selection of the pesticide. La traducción es propia.4 From EPA R.E.D Facts: Thiabendazole. Available at https://www3.epa.gov/pesticides/chem_search/reg_actions/reregistration/fs_PC-060101_1-May-02.pdf. Own Translation.

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Aluminum sulphate, which is considered a salt formula Al2 (SO4),3 currently has two presentations, solid and liquid, and is used in the following forms:

Pharmaceutical industry: as astringent; Paper Industry: as waste waters treatment; Drinking water treatment: to clarify and purify water; Chemical industry: for the production of other aluminum salts; Banana industry: as regenerator that stops the secretion of latex in bananas,

since it slows down the metabolic process of oxidation and maturation.

Currently, in El Salvador, aluminum and ammonium sulfate is marketed under the name of Alumbre Generally Recognized as Safe (GRAS); and there is no evidence in the information available on aluminum sulphate that suggests any danger for its users5.

Aluminum sulfate is not a pesticide and is not of concern from a toxicological point of view. When considered a double salt, aluminum sulfate is totally neutralized since it has neither acidity nor basicity. It has neutral pH and is widely used in the food industry given it is a flocculating agent due to the presence of aluminum sulfate and healing effect due to the presence of ammonium ion (NH4+). Its use is purely as a solution dosed in sprinklers, which maximizes its effect in vacuum chambers.

It is also worth mentioning that the EPA has issued a notification, "Exemption from the requirement of a tolerance", for aluminum sulphate. This shows that there is very little likelihood that its use causes any affect to consumer health. In addition, aluminum sulfate is on the US Food and Drug Administration (FDA) list of the United States6. It is found in small amounts even in foodstuffs of daily consumption like "baking soda".

Since it is already a product marketed by chemical laboratories in El Salvador and therefore regulated by the Ministry of National Health, and that it does not present toxicological risks according to the US FDA, where the product will be exported, it is recommended to approve its use in the ACOPASCA Plant.

For the selection of the pesticides requested, the project should consider the following considerations, in addition to the information recorded in table 5.

Registration: If (for involuntary reasons) there are no natural or biological options and/or alternatives, the Project should consider only pesticides registered by the EPA and the Government of El Salvador.

Toxicity / Safety: In the EPA classification, products are assigned a category of toxicity (I-IV), where I is the most toxic and IV is slightly toxic. The project will purchase pesticides classified III and IV and shall not buy or use classified pesticides I or II in the EPA classification system (for active ingredients with several classifications only Class III or IV can be used).

Effects on human health: only pesticides with the least negative effects on human health will be allowed.

Effects on ecosystems, flora and fauna: only pesticides with the least negative effects on local flora and fauna will be allowed.

5(https://www.federalregister.gov/documents/2015/06/05/2015-13821/aluminum-sulfate-exemption-from-the-requirement-of-a-tolerance).6(https://www.fda.gov/Food/IngredientsPackagingLabeling/GRAS/SCOGS/ucm260848.htm)

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Issue ACOPASCA officials and staff are unaware of the implications of pesticide

selection bases. ACOPASCA officials and staff are unaware of MAG's pesticide records.

Mitigation measure ACOPASCA officials and staff must be trained on PERSUAP, this training

should be channeled through the Project with the local partner. ACOPASCA and project officials must purchase the pesticide registration table

from MAG.

3.3. (Factor C) Extent to which the proposed pesticide use is, or could be part of an Integrated Pesticide Program (IMP) program

This amendment to PERSUAP focuses on controlling pests affecting plantain in the post-harvest phase. This section will focus on how the use of the two (2) active ingredients can be incorporated into an IMP system, applied only to the post-harvest phase, processing and packaging of the plantain.

During the post-harvest phase, the two most damaging affectations on plantain are crown rot and Anthracnose (Delgado et al., 2011; Barkai-Golan, 2001). Crown rot is caused by a series of fungi that produce a degradation of the crown of the plantain hand, but that if untreated can affect the whole fruit. For this disease to begin, a "pathway" such as wounds and damage to the banana peel and crown of the hands is required, as well as environmental conditions that enable its development. The symptoms of this disease are not visible when the bananas are in the processing and packing center, but during shipment, maturity and storage in consuming countries.

Photo 1 and Photo 2 Two “hands” of plantain (Musa sp) Affected by Crown Rot.

Source: Flickr ©

Anthracnose can attack plantain during all its development stages and cause 30-40% loss of plantain crop (Musa ssp.) (Ranasinghe, 2003). Anthracnose is caused by the fungus Colletrichum musae, and causes an extremely rapid maturation process especially in the wounds and cracks of the skin. Plantains affected by this fungus are typically covered with orange-salmon spots around the wounds, and there are other black spots that appear and cover the entire surface of the fruit skin. However, normally the pulp is not affected, unless the plantains are too ripe or exposed to high temperatures for a long time.

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Photo 3 and Photo 4 Plantains (Musa sp) Affected by la Anthacnose.

Source: Flickr ©

USAID promotes training and design of IMP tools and systems, and only promotes the use of chemical pesticides as a last resort if other forms of controls fail to prevent, eliminate or mitigate the pest within acceptable levels. Prior to the use of the chemicals and products approved by this PERSUAP, the Project will make every effort possible to control pests affecting plantains during the post-harvest phase using cultural, biological or physical methods. The recommendations for IMP measures come from a review of technical and academic literature (Plantwise, 2017; Ludivine L., Marc, C, Luc de L.D.B and Haissam J.M., 2010; Satyagopal et al., 2014).

Reducing the risk of contamination during and after the harvest

Handle plantains hands carefully during and after harvest to avoid bruising, wounds and scars both in the field and at the processing and storage center.

As soon as possible after harvest, plantains should be placed in a room with a temperature of 13-14 ° Celsius.

Keep processing and storage centers clean and remove all discarded leaves, flowers and fruit.

Cut the crown with a sharp knife so that the surface of the crown is smooth. Use clean, disinfected water to wash plantain hands, and ensure that water is

changed from the wash area on a regular basis to avoid spores contamination

After the implementation of all these controls, the need for chemical treatment may be reduced. However, since the buyer (Chiquita) requires the treatment with the chemicals identified above, fumigation should be implemented in a safe and controlled manner.

Fumigation of plantains in the post-harvest phase goes hand in hand with the implementation of the cultural measures described in this section, to reduce the frequency of crown rot and / or anthracnose.

Issue Without the implementation of cultural controls intended to prevent pest

infestation in the post-harvest phase, there will be a greater prevalence of crown rot and anthracnose affectation, and a greater reliance on the use of chemical controls.

Mitigation measure• The preventive methods detailed in this section (3.3) for the control of pests affecting plantain in the post-harvest phase should be implemented with

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the use of the fungicides recommended in this PERSUAP according to the requirements of the buyer (Chiquita).

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

The following table sets out the application methods, the Personal Protective Equipment (PPE) and safety equipment required, and the guarantee of their availability.

For more information, see Annex 5 Exposure to Pesticides, Toxicological Hazards and Mitigation Measures, Annex 6 EPA Recommended Worker Protection Standard, and Annex 7 Mitigation of Potential Pesticide Hazards and General Measures to Ensure Safe Use.

Table 6 Proposed Methods of Application

No. Type of Pesticide

Active Ingredient

Proposed Method of Application

Required Personal Protective Equipment

(PPE) and SecurityPPE y Seguridad

Availability

1. Funguicide Azoxystrobin

It is mixed together with the other products analyzed in this PERSUAP in a container of 150 liters of water.

The mixture enters the fumigation chamber system through tubes.

The mixture is applied through a spray system to the plantain trays entering by a conveyor belt.This mixture is sufficient to apply to a container with plantains.

Goggles Gloves Mask Denim cloth that

protects limbs Plastic apron

It must be used by all persons handling these products from the mixing, processing in the fumigation chamber, to obtaining the plantain outside the conveyor belt

The project will insist that ACOPASCA comply with the use of this equipment (through a monitoring plan) for the personnel manipulating these products from the mixing, processing in the fumigation chamber, to obtaining the plantain outside the conveyor belt.It is suggested, at the end of the useful life of the protective equipment, that ACOPASCA acquires PPE made of materials adapted to the climate of El Salvador; this equipment is available in El Salvador

2. Funguicide Tiabendazol

3. Salt Aluminum Sulfate

Source: SMTN, 2017.

Issue: The tank of the mixture located in an open space is accessable to anybody. The

workers and partners of the ACOPASCA Plant are exposed to a potential contamination of the product since this is a busy area adjacent to the plant manager’s office.

Mitigation Measure:• Change the place where the mixing tank is located to a safe place with a

surrounding fence and locked door. The only person who should have access is the person responsible for preparing the mixture. Additionally, there should

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always be sand available if there are spillages. The sand should be in a place accessible to all ACOPASCA staff.

Issue:• Acopasca workers and partners do not comply with the use of PPE.

Mitigation Measure:• Make producers aware of the medium and long term risks for human health if

not using PPE• Establish a protocol on the use of the Cooperative PPE, in addition to including

it as a labor standard in ACOPASCA.• ACOPASCA should establish a monitoring plan to follow up on the use of PPE.• Look for other alternatives with regard to the PPE material, mainly the

apron/white coat, so the material is lighter and adapted to the climate conditions in El Salvador.

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

Table 7 Acute and Long Term Toxicological Hazard

No. Type of Pesticide

Active Ingredient Toxicological Hazard

1. Funguicide AzoxystrobinAzoxystrobin has low acute toxicity in humans, birds, mammals and bees, but is highly toxic to freshwater fish and invertebrates, and very highly toxic to estuarine and marine invertebrates.

2. Fungicide Tiabendazole

Thiabendazole is a product of mild acute toxicity. The USEPA considers it a carcinogenic product if it is used in very high doses that could affect the thyroid and the liver. The recommended dosages for use of this product are far from causing cancer.

Thiabendazole is practically non-toxic in birds and mammals, but is highly toxic in estuarine and freshwater fish and invertebrates.7

Source: EPA, 2017.

All pesticides will be used at their lowest effective concentrations.

Issue:• There is a problem with the design or maintenance of the pits, since the level of

the water at the time of the visit coincided with the summer (dry) season, and was only a few centimeters from its overflow level. There is a potential risk of water spillage in the winter (rainy) season. It is important to mention that the pit will receive water from the wash tank and the fumigation chambers where pesticides will be applied.

7 Tomado de EPA R.E.D Facts: Thiabendazole. Disponible en https://www3.epa.gov/pesticides/chem_search/reg_actions/reregistration/fs_PC-060101_1-May- 02.pdf. La traducción es propia.

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Mitigation Measure:

• Check with a civil engineer that the capacity to collect wastewater from the pit coincides with the capacity of the plantain-washing tank. It should include the amount of water use at the highest production peaks with an estimated 10% more. (The pipe of the fumigation chamber is connected in the pit of the plantain washing water.)

• Check with a civil engineer on whether the pit requires maintenance or a redesign for the uses of the plantain processing plant. It’s important to note that the waters that will fall into the pit come from the fumigation chamber and the plantain-washing tank.

• To ensure farmers are aware of the hazards of pesticides, the project will include training on hazards and routes of pesticides exposure, and how to reduce and mitigate potential hazards, basic knowledge of first aid for overexposure to pesticides; and pesticide disposal procedures. (For more information, see Annex 5 Exposure to Pesticides, Toxicological Hazards and Mitigation Measures, and Annex 9 Pesticide Disposal Options).

3.6. (Factor F) Effectiveness of the requested pesticide for the proposed use

Table 8 Effectiveness of the Pesticide Requested for the Proposed Use

Pesticide Proposed Use Effect EffectivenessAzoxistrobin Colletotrichum musae

Fusaium moliformeF. roseumF. pusillumF semitectumF. theobromae Verticilium theobromae Gloesporium musarum Thieloviopsis paradoxa Caratocystis Botrydipodia theobromaeThese fungi are responsible for crown rot and dry on any part of the plantain (Black spot).

It eliminates the spores and the mycelium of the fungus, it avoids rotting in the plantain (crown rot and dry in the plantain).

Efficient against crown rot and anthracnose

Tiabendazole Gloesporium musarium Colletotricum musae Thiploviopsis paradoxa Ceratocystis paradoxa Fusarium roseum Verticiliun theobromaeThese fungi generate several rotting in the plantain, in addition to crown rot and dry rot

It eliminates fungal spores and mycelial rot, prevents crown rot and dry in the plantain; prevents the development of fungi. Its effect is systemic at protecting new tissues.

Efficient against crown rot and anthracnose

Aluminum Sulfate (Ammonium)

Black spot on plantains due to the latex secretion caused by the cut

Heals scars in the cuts of the plantain avoiding black spots on plantains

Effective to control the development of fungi.

Source: SMTN, 2017; Siriwardana et al., 2017; Lassois and Luc de Lapeyre de Bellaire, 2014

Pesticide products produced in China and India should not be purchased as they could be adulterated and at the same time significantly affect their effectiveness.

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It is important for ACOPASCA to review the expiration date of pesticides, as some suppliers may repackage expired pesticides. Old and expired pesticides can degrade into even more dangerous and toxic chemical compounds than the original pesticide product, and agro-service beneficiaries and owners should be aware of the risks of using and marketing expired products.

Issue:

• Effectiveness will be determined by the joint monitoring with the buyer and the local technical partner. Pesticides may have less effectiveness over time, so it is important to comply with the recommendations on the product (label) and apply the recommended dose. The products registered in the MAG of El Salvador have a label that contains very complete information on use, doses, precautions, toxicity, among others.

Mitigation measures:

• The project, together with the local technical partner, will be responsible for training ACOPASCA officials, plant workers and partners on the importance of following all instructions on the use and dosage on pesticide labels and pamphlets that come in every product.

• Create a strategic alliance with the buyer (Chiquita) so they advise on recommended pesticides, and monitor the effectiveness of treatment during the transportation phase

• The Project and ACOPASCA must ensure that the pesticides used in the fumigation chamber are registered in the MAG.

3.7.(Factor G) Comparability of the proposed pesticide use with target and non-target ecosystems

The ACOPASCA Plant is located in the Agroindustrial Complex Ing. Héctor Lara Zamora, as shown in Figure 2. This environment is, as its name says, already intervened by man and has characteristics of industrial development in the Municipality of El Paisal. In this ecosystem, there is no evidence of a direct threat to the environment from uses of the pesticides requested for the practices of the ACOPASCA Plant, since the territorial organization already designates this area for this type of activities. However, the Agroindustrial Complex Héctor Lara Zamora is located near the Lempa River. For more details about the potential impacts to this ecosystem, see section 3.8. (Factor H) Conditions under which the pesticide is to be used, including climate, geography, hydrology and soils.

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

The “ACOPASCA” processing plant is located in the surrounding area of Rio Lempa (See figure 2).

Figure 2. Location of the Agroindustrial Complex “Ing. Héctor Lara Zamora”

Source: USAID, SMTN, 2017.

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Below, general aspects related to the conditions of El Salvador are detailed, which being a very small area, has similar environmental conditions in all its territory.

Geography

El Salvador is the smallest country in Central America with an extension of 20,742 km2. It limits the south with the Pacific Ocean, the Northwest with Guatemala, and the North with Honduras.

El Salvador is heavily deforested and has only 6% of its original vegetation. More than 60% of the soils are deteriorated.

Weather

El Salvador is located in the northern part of the Earth’s tropical belt, as a result, in November and October there is great influence of north-easterly winds and occasionally North Wind gushes that bring in fresh air that originates in the polar regions of North America, but which is heated largely when it crosses the Gulf of Mexico on its way to Central America (MARN, 2015).

Soil

El Salvador has an intermediate soil cover between the two previously mentioned countries. The presence of Andosols, as well as the abundance of Cambisols, shows a country with a relatively pronounced relief and non-negligible volcanic activity. This fact can be supported by its richness in Nitosols, edafotaxe that often come from the natural evolution of the Andosols (Ibáñez, 2007).

Hydrology

There are two hydrographic systems and their associated tributaries that drain most of the country. The largest and most important is the Lempa, which enters El Salvador from Guatemala in the northwestern corner of the country and runs east 130 km, crossing the interior plain forming part of the border with Honduras, before turning south to run 105 km crossing the central heights and crossing the coastal plain, to empty in the Pacific. This river provides water to irrigate crops in the southeast coastal plains.

Flora

The indigenous native trees of El Salvador generally include mangrove, rubber, cornus, mahogany, cedar and walnut. Pine and oak are found in the mountainous region of the north of the country. A large variety of tropical fruits, numerous medicinal plants and balm, a medicinal gum, grow in the country (Nations encyclopedia, 2017).

Fauna

The native fauna of El Salvador (very reduced in the last decades) includes varieties of monkeys, jaguar, coyote, tapir and armadillo, along with several types of parrots and several migratory birds. There is a variety of fish, both fresh and salt water, turtles, iguanas, crocodiles and alligators. Serpent and non-venomous snakes are common in El Salvador, including the boa constrictor (Nations encyclopedia, 2017).

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Issue: Regarding the water resource, there is a potential conflict on the use of water.

Currently, the water used by ACOPASCA comes from a well that also supplies the San Rafael farm. The well had an initial depth of 65 meters, and now is at37 meters. Domestic and agro-commercial use can cause problems in the future. It is important to mention that ACOPASCA has a permit from ANDA (National Administration of Aqueducts and Sewerage). And the well has been part of the Association for Community Development (ADESCO) lending since 2017. This has resulted in ACOPASCA paying a much lower rate for water use.

Mitigation Measure:

Define a design to harvest rainwater in winter through the roof of the plantain processing plant.

Construct a proper well for ACOPASCA with the objective of using this water for agro-commercial purposes or construction of a water reservoir with relevant studies.

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

Researchers have conducted several controlled studies proving at an experimental level the effectiveness of biological / alternative treatments to crown rot and Anthracnose. For example:

Plant extracts to control plant diseases are emerging as alternatives to conventional fungicides as they are generally safe for humans and are environmentally friendly. Extracts of 50 plants were examined in vitro against the pathogenic fungus of banana Colletotrichum musae. Immersion of fruits in aqueous extract of Solanum torvum sp. to 50% concentration effectively reduces plantain anthracnose disease (over 90%) and increases shelf life to 26 days (Thangavelu, 2004).

Fusarium semitectum was isolated at high frequency from a plantain cropping showing the symptoms of plantain crown rot in commercial markets. The invitro inhibitory effect of essential oils tested on mycelial growth was higher than on the germination of the conidium of F. semitectum. Complete inhibition of fungal growth and spore germination were recorded. For this, essential oils of cinnamon, thyme and almond were applied in concentrations of 1.0, 2.0 and 4.0% to the cut surface of the crown of the hand of plantains to examine the effects on the incidence of banana crown rot. With the application of a 4.0% concentration of thyme and cinnamon oils, a control effectiveness of 100% was reported (Abd-Alla, 2014).

Colletotrichum musae is a causal organism of banana anthracnose. The antifungal effects of gum arabic (GA) (10%), lemon oil (LG) (0.05%), cinnamon oil (CM) (0.4%) were analyzed in vitro and in vivo. Their combinations for the control of post-harvest anthracnose of plantain and papaya. LG at 0.05% and 0.4% CM showed fungicidal effects against Colletotrichum, GA alone did not show any fungicidal effect whereas the combination of 0.05% LG and 0.4% CM with 10% GA by itself showed more fungicidal effects. The use of a combination

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of gum arabic and cinnamon essential oil was the most effective in controllingColletotrichum spp. (Maqbool et al., 2011).

The antagonistic activity of two yeast strains (Pichia anomala and Candida oleophila) was evaluated against the parasite complex responsible for the banana crown rot. Strains of these yeasts were applied at three different concentrations (106, 107, 108 cfu / ml) and tested in vivo on three separate fungi (Colletotrichum musae, Fusarium moniliforme and Cephalosporium sp.), and on a parasitic complex formed by association of these three fungi. At concentrations used C. musae appeared to be the most pathogenic. The complex showed an intermediate aggressiveness between C. musae and the other two fungi. Statistically significant antagonistic effects were observed in C. musae, F. moniliforme and in the fungal complex (Lassois, 2008).

Acetic Acid (AC) is a metabolic intermediate that occurs naturally in many fruits. Its inhibitory effect on microorganisms is greater than pH alone and non- dissociated CA can penetrate the microbial cell to exert its toxic effect (Tripathi and Dubey, 2004).

The use of propolis as a fungicide. Propolis is commonly used inside the hive to control the growth of bacteria, fungi microorganisms, generating an aseptic environment (Barrera et al., 2012).

It is not feasible for the program to use these treatments yet, because they are mostly in experimental and research phases and the effects for post-harvest phase and transportation to their final destination is not yet known. For ACOPASCA it is a risk to test with these treatments that still do not reflect final results.

In addition, some of these are high cost treatments, which could significantly increase the final value of the consumer product.

Through PYBES, it is known that Chiquita Brands has not requested the use of biological pesticides in the post-harvest phase.

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

El Salvador is a signatory of the following international conventions that pertain to the use, handling, transport and disposal of pesticides:

1. The Stockholm Convention on Persistent Organic Pollutants2. Prior Informed Consent (PIC) -the Rotterdam Convention3. Basel Convention on the Control of Transboundary Movements of Hazardous

Wastes and Their Disposal4. Central America Regional Agreement on the Transboundary Movement of

Hazardous Wastes and their Disposal5. Montreal Protocol

According to Legislative Decree 534 of November 30, the Ministry of Agriculture and Livestock (MAG) is responsible for keeping the Pesticides Registry. In addition, it is

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responsible for monitoring the quality of pesticides and companies that import, export and market pesticides.

As a rule, in El Salvador every pesticide marketed in the country must be sold with its respective manual in Spanish that describes its use, application and has information on its toxicity.

It is known that the General Directorate of Plant and Animal Health of the MAG, has a complete database of all the pesticides registered in El Salvador which is updated frequently, and which is available at USD 16.85. The most recent update was completed in January 2016. It is one of the most complete pesticide databases and technicians working in the agricultural development of the country should consider it as a tool.

Currently ACOPASCA is not using the Fumigation Chamber because they do not have the PERSUAP; of two pesticides requested by the plantain buyer (Chiquita), both have been approved for use in El Salvador.

In 2000, and then in 2013, MAG prepared a list of pesticides banned in El Salvador. However, the Legislative Assembly did not ratify the list by incidence of pesticide importers and suppliers.

The Ministry of Environment and Natural Resources (MARN) is responsible for ensuring that pesticides do not pollute the environment, including water sources, streams, rivers, soil and aquatic and terrestrial organisms.

Unfortunately, there are no state standards governing the final disposal of pesticide containers, and obsolete or outdated pesticides, which are potential soil, water, and wildlife contaminants; However, the final disposal that ACOPASCA carries out with pesticide waste from banana cultivation is to deliver the containers (triple washing and perforated) to the La Cabaña sugar mill for later delivery to the Metapan cement plant. For more information, see Annex 8 Pesticide Disposal Options.

Issue:• ACOPASCA is not familiar with the database of pesticides registered in the

MAG.

Mitigation Measure:• ACOPASCA must purchase the MAG pesticide database and updates when

they expand, and must assure the ACOPASCA workers and Board of Directors are familiarized with this information.

3.11. (Factor K) Provision of training for users and applicators

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

Issue:

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Some of the workers at the ACOPASCA plant are unaware of the risks to which they are exposed without the use of PPE.

Mitigation measures:

• ACOPASCA should develop a capacity-building plan on issues related to the safe use of pesticide.

• Develop a Training Program on Safe Use of Pesticides to train trainers in procedures that comply with Global GAP.

• Develop a monitoring plan to keep a record and control the safe use of PPE in the ACOPASCA Plant.

• Training for farmers on the safe use of pesticides will be implemented through the methodology learning-by-doing in order to have a visual memory on the subject. The project and FUSADES will accompany the officials in charge at the plant on the use and manipulation of the pesticides during the first exportations.

For more information, see Annex 5 Exposure to Pesticides, Toxicological Hazards and Mitigation Measures, Annex 6 EPA Recommended Worker Protection Standard, and Annex 7 Mitigation of Potential Pesticide Hazards and General Measures to Ensure Safe Use.

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

Monitoring and follow-up is a tool to determine action measures, i.e. action thresholds. It is estimated that inappropriate use of pesticides could potentially generate pest resistance in export bananas, which in many cases could be linked to poor application of pesticides. It is essential that ACOPASCA develop a monitoring and follow-up tool based on the activities that are developed in the plant. Monitoring and follow-up on the amount of pesticdes used will help ACOPASCA comply with the standards requested by the buyer.

As a part of the monitoring, it is important to establish indicators, which must be associated with quality control and account for the control and use of pesticides, such as percentage of Colletotrichum musae, Fusaium moliforme, F. roseum, F. pusillum, F, Theobromae, Verticilium theobromae, Gloesporium musarum, Thieloviopsis paradoxa, Caratocystis sp., Botrydipodia theobromae among others. Should ACOPASCA find it difficult to measure these indicators due to the equipment required to determine this affectation, the percentage of discarded or waste product in the post-harvest phase should be estimated.

Additionally, it is important that Chiquita Brands provide this information when unpacking the product in the country of destination. The monitoring will also enable ACOPASCA to keep a financial record on costs, which will contributes to net profit calculations.

It is suggested that ACOPASCA develop a record that will provide the necessary information for the monitoring and follow-up of the application of pesticides in the post- harvest phase.

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Issue

• ACOPASCA does not have a tool for monitoring and evaluating pesticide application that allows determining action thresholds.

Mitigation Measure

• Establish indicators and a monitoring card/tool that should be associated with quality control and the use of pesticides.

• Coordinate with Chiquita Brands to provide information on the indicators established by ACOPASCA at the place of destination.

• Provide training to the Board of Directors on the importance, use and maintenance of the monitoring tool established by ACOPASCA.

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4. GENERAL PROBLEMS AND MITIGATION MEASURES

This section presents general problems identified during the second document review, field visits and interviews with key stakeholders. Problems are placed in a "general" category as they are not related to any of the 12 factors, but are crosscutting nature. These problems and mitigation measures have been included in Table 12 Environmental Monitoring Plan.

Table 9 Potential Problems and Mitigation Measures

No. Factor Potential Problems Mitigation Measures1. FACTOR A ACOPASCA is not aware of the

information on the EPA risk classification.

ACOPASCA personnel must be trained in the use of EPA classification tables. It is important as EPA's active ingredient classifications are continously reviewed.

2. FACTOR A Phase I of the project has finalized. At this stage, training should have been conducted and a PERSUAP developed.

The project must train ACOPASCA on the PERSUAP for this cooperative.

3. FACTOR D The location of the mixing tank is in a place where people are circulating, therefore, the workers and partners of the ACOPASCA Plant are exposed to potential contamination of the product.

Place the mixing tank in a safe place; install a fence around it and a door with a lock so that only those in charge of making the mixture will have access. Always have sand available in the case of a spillage. The sand must be in a place accessible to all ACOPASCA staff.

4. FACTOR C Without the implementation of controls that aim to prevent pest infestation in the post-harvest phase, there will be a higher incidence of crown rot and anthracnose affectation, and a greater dependence on the use of chemical controls.

The preventive methods detailed in section 3.3 for the control of pests affecting bananas in the post-harvest phase should be implemented with the use of the fungicides recommended in this PERSUAP according to the requirements of the buyer (Chiquita Brands).

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5. FACTOR D ACOPASCA workers and partners do not comply with the daily use of PPE.

Raise the awareness among the operators about the risks of not using PPE in human health in the medium and long term.

ACOPASCA should establish a monitoring plan to follow up on the use of PPE.

Establish a protocol on the use of the Cooperative's PPE, in addition to including it as a labor standard in ACOPASCA.

Seek other alternatives regarding the PPE material, so that the the equipment is lighter and adapted to the weather conditions in El Salvador.

6. FACTOR E There is a problem with the design or Check with a civil engineer to confirm

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No. Factor Potential Problems Mitigation Measuresmaintenance of the pits. Because the level of the water at the time of the visit coincided with the summer season and the water was only a few centimeters from its overflow level, there is a potential risk of water spillage in the winter season. It is important to mention that the pit will receive water from the washing tank and the fumigation chambers where the pesticides will be applied.

the catchment capacity of wastewaters pit matches the capacity of the plantain washing tank. The amount of water used during the highest peaks of production must be included, estimating 10% more of water use.

Check with a civil engineer to confirm if the pit requires maintenance or a redesign for the uses of the plantain processing plant, which in this case, the waters come from the fumigation chamber (in the future) and the plantain washing tank.

In the short term, the organization must assure a daily control to avoid water puddles from forming.

To ensure that farmers are aware of the hazards of pesticides, the project will include training on hazards and routes of exposure to pesticides and how to reduce and mitigate potential hazards, basic knowledge on first aid for overexposure to pesticides, and procedures for disposal of pesticides.

7. FACTOR F The effectiveness will be determined by the monitoring conducted jointly with the buyer and the local technical partner.Pesticides may have less effectiveness over time so it is important to comply with the recommendations in the product (label) and apply the recommended dose.

The project will train ACOPASCA officials, plant workers, and partners on the importance of following all the dosage instructions on the labels, and pamphlets of the pesticides that come with each product.

Create a strategic alliance with the buyer (Chiquita Brands) so they can advice on the pesticides recommended for purchase and export.

The Project and ACOPASCA must ensure that the pesticides used in the fumigation chamber are registered in the MAG.

8. FACTOR H Regarding the water resource, there is a potential conflict on the use of water.Currently, the water used by ACOPASCA comes from a well that also supplies the San Rafael farm. The well had an initial depth of 65 meters, and now is at 37 meters. Domestic and agro-commercial use can cause problems in the future. It is important to mention that ACOPASCA has a permit from ANDA (National Administration of Aqueducts and Sewerage). And the well has been part of the Association for Community Development (ADESCO) lending since 2017. This has resulted in ACOPASCA paying a much lower rate

Define a design to harvest rainwater in winter through the roof of the plantain processing plant.

Construct a proper well for ACOPASCA with the objective of using this water for agro-commercial purposes or construction of a water reservoir with relevant studies.

3

No. Factor Potential Problems Mitigation Measuresfor water use.

9. FACTOR J ACOPASCA is not familiar with the database of pesticides registered in the MAG.

ACOPASCA must purchase the MAG's pesticide database and updates when they are issued.

10. FACTOR K Workers at the ACOPASCA plant are unaware of the risks to which they are exposed without the use of PPE.

ACOPASCA should develop a capacity building plan on issues related to safe pesticide use.

Develop a Safe Use Pesticide Training Program to train trainers on procedures that comply with Global GAP.

Develop a monitoring plan to keep a record and control on the safe use of PPE in the ACOPASCA Plant.

The training for plant personnel on the safe use of pesticides will be implemented through the learning-by- doing methodology in order to have a visual memory of the subject.

11. FACTOR L ACOPASCA does not have a monitoring and evaluation tool for the application of pesticides to determine action thresholds

Establish indicators and a card/tool for monitoring, which must be associated with quality control and use of pesticides.

Coordinate with Chiquita Brands to provide information from the destination on the indicators established by ACOPASCA.

Provide training to the Board of Directors on the importance, use and follow-up the monitoring tool established by ACOPASCA

Source: SMTN, 2017.

3

5. SAFER USE ACTION PLAN (SUAP)

Nathan Associates will implement a training campaign on handling and safe use of pesticides. This campaign will include visual guides, operational practices, awareness talks, installing signage, and other tools to assertively communicate the effects of pestiside use and manipulation, and safe use methods to prevent effects on human health and the environment.

The training campaign will be based on Annex 5: Exposure to Pesticides, Toxicological Risks and Mitigation Measures, Annex 7: EPA Standard Worker Protection Recommendations, Annex 8: Mitigation of Potential Pesticide Hazards and General Measures to Ensure Safe, and Annex 9: Pesticide Disposal Options. Additionally, Nathan Associates will consult the Pest Management Sector Guidelines: Safe Use of Pesticides from USAID's Global Environmental Management System (SGGA), in designing the contents of the pesticide use training campaign.

Following is a summary of the topics that should be included in the pesticide safe use training campaign for project beneficiaries. More details of each topic are included in the aforementioned annexes.

• Chemical Knowledge: information about the status of the pesticide product registration, correct application procedures, and product label specifications. This training includes a thorough review of label information (resources must be provided in Spanish and/or with photos); a discussion of dosage, application, calibration and maintenance of equipment, intervals between applications, re-entry intervals and pre-harvest, and demonstrations of proper use of equipment. For more information, see Annex 9 Pesticide Websites.

• Storage: emphasis will be placed on the need for a separate facility, marked and locked only to store agricultural chemicals. Pesticides shall not be located near or in the same space with foodstuffs for human or animal consumption, or sources of potable water. The storage facilities will not have openings that allow the entry of insects/rodents. Pesticides will always be stored in their original containers. Pesticides will not be placed on floors and will be stored on shelves out of the reach of children.

• Transportation: the subject of safe transportation of pesticides (eg, not using public transport if possible, keeping chemicals in a closed environment, avoiding punctures and rips in bags, etc.).

• Protection of workers: types of personal protective equipment (PPE) when to use, and why, and how to care for it. The basic PPE recommendations for all pesticide applications includes long sleeve shirts, long pants, glasses, shoes and socks. Depending on the toxicity and labeling instructions, Nathan Associates may provide chemical resistant gloves, aprons, and masks to the ACOPASCA Plant workers for demonstration activities.

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• General safety practices: appropriate mixing techniques and the importance of not contaminating water sources. Types of containers used in the preparation of chemical substances. Applicants are taught not to eat or drink or smoke while mixing or applying pesticides. Areas where pesticides are mixed must be fenced and away from the home, but near a source of water. The mixing area should have a soil filter with sand and charcoal to absorb the chemicals so that the pesticide residues do not contaminate the soil. This area will be used to clean pesticide bottles and fumigation machinery.

• First aid and medical facilities: First aid materials (soap, clean water, and a towel) must be available in the demonstration plots. Participants will be taught to identify the main symptoms of exposure to chemicals, and what to do in an emergency.

• Waste management: how to safely clean and dispose of unused chemicals. In the case of liquids, the empty containers should be rinsed 3 times and the residues introduced into a sprinkler tank as part of the application mix. When the product is completely finished, the chemical containers are should be rinsed three times and drilled before being buried. Containers should never be reused.

• Environmental safety: the importance of protecting natural resources and the appropriate use of pesticides to avoid environmental contamination and impacts on non-target organisms will be addressed.

The following table is the recommended monitoring chart for the ACOPASCA Plant. This is a practical technical tool recommended to use, however, it can be modified to adapt more effectively for the use and need of the ACOPASCA Plant.

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Table 10 Environmental Monitoring

No. Problem Mitigation Measure Responsible Indicators Methods Frequency

Estimated Cost US $

Mon

itorin

g D

ates

Prob

lem

s id

entif

ied

Miti

gatio

n Ef

fect

iven

ess

Rec

omm

ende

d A

djus

tmen

ts

1.

ACOPASCA andproject personnel are not familiar with the EPA risk classification information.

ACOPASCApersonnel must be trained in the use of EPA classification tables. It is important as the EPA's active ingredient classifications are continually reviewed.

Regional Tradeand Market Alliances Program (M & E specialist) and LocalTechnical Partner (FUSADES, food specialists - Innova)

All the ACOPASCAPlant personnel has been trained on EPA pesticide information and classification

Training Campaign Once 750.00

2.

Phase I of the Project is finalized. Training should have been provided and a PERSUAP carried out during this phase.

The Project should train ACOPASCA onthe PERSUAP for this cooperative.

Regional Tradeand Market Alliances Program (M & E specialist) and LocalTechnical Partner (FUSADES, food specialists - Innova)

3.

The location of the tank with the mixture is located where people circulate, therefore, ACOPASCA workers and members are exposed to a potential contamination of the product.

Change the place where the mixture tank is located to a safe place with a fence and a door with a lock, so the only person who will have access will be the person responsible for preparing the mixture. Always have available sand, for spills,

Regional Tradeand Market Alliances Program (M & E specialist) and LocalTechnical Partner (FUSADES, food specialists - Innova)

Mixture tank located in a safe place

Relocation Once 250.00

3

No. Problem Mitigation Measure Responsible Indicators Methods Frequency

Estimated Cost US $

Mon

itorin

g D

ates

Prob

lem

s id

entif

ied

Miti

gatio

n Ef

fect

iven

ess

Rec

omm

ende

d A

djus

tmen

ts

which should be kept in a place where all ACOPASCApersonnel have access.

4.

ACOPASCA workers and members do not comply with the use of PPE.

Create awareness among producers on the risk of not using PPE on human health in the medium and long term.

Regional Tradeand Market Alliances Program (M & E specialist) and LocalTechnical Partner (FUSADES, food specialists - Innova)

All the ACOPASCAPlant personnel has been trained on the use of PPE and health impacts

Training Campaign Once 750.00

Create awareness among producers on the risk of not using PPE on human health in the medium and long term.

Regional Tradeand Market Alliances Program (M & E specialist) and LocalTechnical Partner (FUSADES, food specialists - Innova)

All ACOPSCApersonnel directly exposed to the use, and manipulation of pesticides and the fumigation chamber using the appropriate PPE

PPEPurchase and distribution

Once 750

Develop a protocol on the use of PPE of the Cooperative, and establish it as a labor standard.

Regional Tradeand Market Alliances Program (M & E specialist) and LocalTechnical Partner (FUSADES, food specialists - Innova)

Protocol on the use of PPEestablished PPE used according to the protocol

Protocol document on Use of PPE

Once 100.00

Seek other Regional Trade Other PPE Document Once 300.00

3

3

No. Problem Mitigation Measure Responsible Indicators Methods Frequency

Estimated Cost US $

Mon

itorin

g D

ates

Prob

lem

s id

entif

ied

Miti

gatio

n Ef

fect

iven

ess

Rec

omm

ende

d A

djus

tmen

ts

alternatives for PPE, in terms of the PPE material, once the useful life of the PPE has expired.Seeking lighter material and adapted to weather conditions of El Salvador.

and Market Alliances Program (M & E specialist) and LocalTechnical Partner (FUSADES, food specialists - Innova)

alternatives found and socialized with the workers of the ACOPASCAPlant.

PPEAlternatives

5.

There is a problem with the design or maintenance of the pits, since the level of the water at the time of the visit coincides with the summer season, only a few centimeters from its overflow level. There is a potential risk of water spillage in the winter season. It is important to mention

Verify with a civil engineer that the sewage capacity of the pit coincides with the capacity of the plantain washing tank. The amount of water used should be included in the highest production peaks, estimating 10%

Regional Tradeand Market Alliances Program (M & E specialist) and LocalTechnical Partner (FUSADES, food specialists - Innova)

Pits adjusted for required capacity

Water not puddled up in plantain washing zones and pits

Professional Advisory of a Civil Engineer

Field Visits

Once

Monthly

2,000

3

No. Problem Mitigation Measure Responsible Indicators Methods Frequency

Estimated Cost US $

Mon

itorin

g D

ates

Prob

lem

s id

entif

ied

Miti

gatio

n Ef

fect

iven

ess

Rec

omm

ende

d A

djus

tmen

ts

that the pit will receive water from the washing tank and the fumigation chambers where pesticides will be applied.

more use of water.

Appropriate pit design Once

6.

The effectiveness will be determined by the monitoring that will be conducted jointly with the buyer. The pesticides may have less effectiveness over time so it is important to comply with the recommendations in the product (label) and apply the recommended dose.

The project will train ACOPASCA officials, plant workers and partners on the importance of following all instructions on the use and dosage on the labels and pamphlets of the pesticides that come in each product requested and used.

Create a strategic alliance with the buyer (Chiquita),

Regional Tradeand Market Alliances Program (M & E specialist) and LocalTechnical Partner (FUSADES, food specialists - Innova)

All ACOPASCAPlant personnel have been trained on the importance of following all instructions on the use and dosage of pesticide labels and pamphlets

Training Campaign Once 750

3

3

No. Problem Mitigation Measure Responsible Indicators Methods Frequency

Estimated Cost US $

Mon

itorin

g D

ates

Prob

lem

s id

entif

ied

Miti

gatio

n Ef

fect

iven

ess

Rec

omm

ende

d A

djus

tmen

ts

the local technical partner in order for them to provide advice on the pesticides recommended for purchase and export.

The Project and ACOPASCA must ensure that the pesticides used in the fumigation chamber are registered in the MAG.

Regional Tradeand Market Alliances Program (M & E specialist) and LocalTechnical Partner (FUSADES, food specialists - Innova)

Strategic Alliance Established

Meeting Once 50.00

7.

Potential conflict due to the use of water - currently the water used by ACOPASCA comes from a well that also supplies the San Rafael community. Domestic and agro-commercial use can cause problems in the future. The well already has a depth of 37 meters when the initial depth was 65 meters. It is important to mention that ACOPASCA has a permit from ANDA (National Administration of

Harvest rainwater in winter (rainy season) through the roof of the plantain processing plant.

ACOPASCAPlant manager or delegated person

Water harvesting system designed

Demonstratio n Practice

Design for subsequent adjustment in the plant.

Once 1,000 USD

Construction of a water reservoir with relevant studies.

ACOPASCAPlant manager or delegated person

Construction study for a reservoir

Studies and Construction Once

Construction of a well owned by ACOPASCA inorder to use this water for agro- commercial purposes.

ACOPASCAPlant manager or delegated person

Design and feasibility study for construction of own well

Study and construction plan

Once 1,000

4

4

No. Problem Mitigation Measure Responsible Indicators Methods Frequency

Estimated Cost US $

Mon

itorin

g D

ates

Prob

lem

s id

entif

ied

Miti

gatio

n Ef

fect

iven

ess

Rec

omm

ende

d A

djus

tmen

ts

Aqueducts and Sewerage). And the well has been part of the Association for Community Development

8.

ACOPASCA is not familiar with the database of pesticides registered in the MAG.

ACOPASCA must purchase the MAG's pesticide database and updates when they are expanded.

ACOPASCAPlant manager or delegated person.

Regional Tradeand Market Alliances Program (M & E specialist) and LocalTechnical Partner (FUSADES, food specialists - Innova)

Database purchased

Database Purchase

Every six months or annually, as required

20.00

9.

Workers at the ACOPASCA plant are unaware of the risks to which they are exposed if they do not use PPE.

ACOPASCAshould develop a capacity building plan on pesticide safe use related issues.

ACOPASCA

Regional Tradeand Market Alliances Program (M & E specialist) and LocalTechnical Partner (FUSADES, food specialists - Innova)

Capacity Building Plan on issues related to pesticide safe use developed.

Plan Once 100.00

Develop a Safe Use of Pesticides TrainingProgram to train trainers in procedures that comply with

ACOPASCA

Regional Tradeand Market Alliances Program (M & E specialist) and Local

Training Program on Safer Use developed

Program Once 100.00

4

4

No. Problem Mitigation Measure Responsible Indicators Methods Frequency

Estimated Cost US $

Mon

itorin

g D

ates

Prob

lem

s id

entif

ied

Miti

gatio

n Ef

fect

iven

ess

Rec

omm

ende

d A

djus

tmen

ts

Global GAP Technical Partner (FUSADES, food specialists - Innova)ACOPASCA

Develop a Monitoring Plan to keep a record and control on the safe use of PPE in the ACOPASCAPlant

Regional Tradeand Market Alliances Program (M & E specialist) and LocalTechnical Partner (FUSADES, food specialists -

Monitoring Plan to keep a record and control on the safe use of PPE in the ACOPASCAPlant

Monitoring Plan

Every Six Months 100.00

Innova)The training forplant personnel Regional Tradeon safe use of and Marketpesticides will be Alliances Programimplemented (M & E specialist)through the and Locallearning-by-doing Technical Partnermethodology in (FUSADES, foodorder to have a specialists -visual memory on Innova)the subject.

Source: SMTN, 2017.

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4. BIBLIOGRAHIC REFERENCES− Abd-Alla, M. A., El-Gamal, N. G., El-Mougy, N. S., & Abdel-Kader, M. M. (2014).

Post-harvest treatments for controlling crown rot disease of Williams banana fruits (Musa acuminata L.) in Egypt. Journal of Fungal Biology-ISSN, 2229, 2217.

− Barkai-Golan, R. (2001). Postharvest diseases of fruits and vegetables: development and control. Elsevier.

− EPA R.E.D Facts: Thiabendazole. Disponible en https://www3.epa.gov/pesticides/chem_search/reg_actions/reregistration/fs_PC- 060101_1-May-02.pdf.

− Ibañez, J. (2007). Suelos de El Salvador, Belize y Las Bahamas. Disponible en: http://www.madrimasd.org/blogs/universo/2007/09/06/73484

− Lassois, L., de Bellaire, L. D. L., & Jijakli, M. H. (2008). Biological control of crown rot of bananas with Pichia anomala strain K and Candida oleophila strainO. Biological Control, 45(3), 410-418.

− Lassois, L., & De Lapeyre de Bellaire, L. (2014). Crown rot disease of bananas. Postharvest Decay, control strategies, 103-130.

− Ludivine L., Marc, C, Luc de L.D.B and Haissam J.M. 2010. Crown rot of bananas: Preharvest factors involved in postharvest diseases development and integrated control methods. Plant Disease, 94(6), pp.648-658.

− Maqbool, M., Ali, A., Ramachandran, S., Smith, D. R., & Alderson, P. G. (2010). Control of postharvest anthracnose of banana using a new edible composite coating. Crop Protection, 29(10), 1136-1141.

− Maqbool, M., Ali, A., Alderson, P. G., Mohamed, M. T. M., Siddiqui, Y., & Zahid, N. (2011). Postharvest application of gum arabic and essential oils for controlling anthracnose and quality of banana and papaya during cold storage. Postharvest biology and technology, 62(1), 71-76.

− Ministerio de Medio Ambiente y Recursos Naturales. (2015). Clima en El Salvador. Disponible en: http://www.snet.gob.sv/ver/meteorologia/clima+en+el+salvador/

− Nationsecyclopedia. (2017). El Salvador - Flora and Fauna. Disponible en: http://www.nationsencyclopedia.com/Americas/El-Salvador-FLORA-AND- FAUNA.html#ixzz4gVTTY7Ke

− Nesheim O.N. y Fishel F.M. (2005) disponible en inglés en: https://www.google.com.ec/?gfe_rd=cr&ei=dK4AVt7VKNaK- gWUio7oDQ&gws_rd=ssl - q=%22O. +Norman+Nesheim+and+Frederick+M.+Fishel2%22

− Rovesti, Luciano. Comunicación personal. 26 de abril de 2017.

− Rovesti, Luciano, V. Gómez y R. Delgado, 2011. Evaluación y Plan de Acción para uso seguro de plaguicidas (PERSUAP) Proyecto FECOPROD Paraguay.

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− Satyagopal, K., S.N. Sushil, P. Jeyakumar, G. Shankar, O.P. Sharma, S.K. Sain,D.R. Boina, B.S. Sunanda, Ram Asre, K.S. Kapoor, Sanjay Arya, Subhash Kumar,C.S. Patni, C. Chattopadhyay, N.M. Patil, P.K. Ray, C.M. Rafee, B.C. Hanumanthaswamy, K.R. Srinivas, A.Y. Thakare, A.S. Halepyati, M.B. Patil, A.G. Sreenivas, N. Sathyanarayana, S. Latha. 2014. AESA based IPM package for banana. pp 46. http://farmer.gov.in/imagedefault/ipm/Banana.pdf

− Siriwardana, H., Abeywickrama, K., Kannangara, S., & Jayawardena, B. (2017). Efficacy of alum treatment and vacuum packaging in controlling crown rot disease of Cavendish banana. Journal of Faculty of Graduate Studies, 5.

− Plantwise. Plantwise Knowledge Bank Technical Factsheet: Tip rot of banana (Colletotrichum musae). Accessed May 8, 2017. http://www.plantwise.org/KnowledgeBank/Datasheet.aspx?dsid=14923

− Ranasinghe, L., Jayawardena, B., & Abeywickrama, K. (2003). Use of waste generated from cinnamon bark oil (Cinnamomum zeylanicum Blume) extraction as a post harvest treatment for Embul banana. Food, Agriculture andEnvironment, 1(2), 340-44.

− Thangavelu, R., Sundararaju, P., & Sathiamoorthy, S. (2004). Management of anthracnose disease of banana caused by Colletotrichum musae using plant extracts. The Journal of Horticultural Science and Biotechnology, 79(4), 664-668.

− USAID. The Better Coffee Harvest Project PERSUAP

− https://iaspub.epa.gov/apex/pesticides/f?p=chemicalsearch:1

− http://www.pesticideinfo.org/.

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Annex 1 SMTN Team

Michelle Rodríguez

Michelle Rodriguez is a specialist in Climate Change and Agroforestry at Sun Mountain. Ms. Rodríguez is a forest engineer with a master's degree in Tropical Agroforestry from the Tropical Agronomic Research and Teaching Center (CATIE) in Costa Rica. She has more than seven years of experience in the implementation of adaptation projects and mitigation of climate change, and is very familiar with ecosystem services and water catchment projects in Central America and Ecuador. Michelle has worked with IUCN, ACICAFOC, CATIE and many other respectable organizations. During the last two years, Michelle has worked in the Ecuadorian Amazon coordinating a project on measures to adapt to climate change, including carbon sequestration and rehabilitation of forest cover in Sucumbíos. In addition, she has extensive experience in environmental diagnosis, technology transfer, forest management, and development and delivery of programs to strengthen capacities to adapt to climate change with local authorities and other key actors. In addition, in her work experience, Michelle has cultivated influential contacts and developed the ability to coordinate with local government and state entities to generate strategic alliances that increase the impact of the project on the territory.

Michael Seager (Climate Change Specialist)

Mike Seager

Mike Seager is Sun Mountain International specialist in Natural Resource Management and Regulation 2016, where he started working in 2009. He holds a Master's degree in Natural Resource Management from James Cook University, Australia, where he studied the impacts of climate change on the dynamics of tropical forests and the carbon cycle. He is a specialist in Sun Mountain USAID Regulation 216 and is the author and co-author of more than 20 environmental assessments, tropical forest and biodiversity assessments, pesticide assessment reports, and safer use action plans (PERSUAP), Initial environmental reviews, environmental mitigation, and monitoring plans. Mike has conducted program evaluations for USAID projects in more than 15 countries in Africa, Latin America and the Caribbean. He also coordinated a team of five (5) professionals that provided urgent technical assistance to the Environmental Officer of the USAID DCHA Office in reviewing and approving all environmental compliance documentation submitted under the $ 2 billion DCHA portfolio. He is originally from the United States and currently lives in Ecuador. He speaks fluent Spanish and English and is an excellent researcher and writer.

Michelle Jaramillo

Michelle Jaramillo holds a diploma in Sociology with a major in Political Science from the Pontifical Catholic University of Ecuador. Michelle has worked with nongovernmental organizations, public and private sector organizations in development projects, and specializes in internationally funded projects, including USAID, Inter- American Development Bank and International Finance Corporation. Michelle has extensive experience in evaluating social and environmental impacts (including pesticide use assessments) in Ecuador, Ghana, Haiti, Mali and Central America, with a

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gender and local territory focus to have a positive impact on communities. Michelle has developed risk assessments for vulnerable populations and implemented resettlement plans; strategies for stakeholder participation, including the dissemination of information programs and community consultations; legal and institutional comparisons of the requirements of local laws and international financing standards; and livelihood assessments. Since 2015 with Sun Mountain, Michelle was a member of the team that developed the initial environmental assessment for the Harande project implemented by CARE in Mali. Michelle is fluent in Spanish and English and has basic knowledge of French and Italian.

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Annex 2 Stakeholders consulted

Table 11 List of Stakeholders consulted

Date Name Institution/Organization Position

17/04/17 Julio Arnoldo Amaya ACOPASCA Marketing manager

17/04/17 Julián Oscar Escamilla ACOPASCA Good Environmental

Practices Manager

18/04/17 Jaime TorrezClinton Foundation, Acceso Oferta Local Productos de El Salvador

Agriculture Manager

18/04/17 Rafael MataPlantain and Banana Producers of El Salvador/ ACOPASCA

ACOPASCA Project Implementer /Member of the Board

18/04/17 Ezequiel Aguiler Walmart ACOPASCA fruit and vegetables buyer

08/05/17Lic. Rómulo L. Henríquez,

Laboratorios FalmarChemical Reagents Sales Representative

08/05/17Otho Ludwing Argueta Recinos ProInnova, FUSADES Food Specialist

08/05/17 Edwin de León ProInnova, FUSADES Food Specialist

08/05/17 Sergio Méndez AGRITEC Operations Manager

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Annex 3 Nathan Associates Plantain Plant Field Trip Report 2/17

Field Trip Report-Joe Torres REA CAMACOPASCA –El Paisnal Plantain Processing and Packing Plant with Dehydration Plant February 17, 2017Nathan Associates –Implementing PartnerPurpose: Monitor operation of ACOPASCA plant to identify potential impacts and improvements from USAID funded interventions.

Background: The ACOPASCA plant was implemented without any environmental compliance documentation (i.e. EMMP or PERSUAP). USAID funded the equipment, including a fumigation station that will be used for exporting plantains. The municipality completed the construction of the building.

The Activity is meeting its objective of improving marketing and income of the Cooperative as they are now selling uncooked plantains and dried fruits to Walmart and Super Selectos markets.The construction and equipment seem to be adequate for the operation. Workers were wearing protective/sanitation PPE and signs were visible about operational Best Management Practices. Waste from the processing operations (especially from the dehydration plant) is collected and used for organic fertilizer at the farms. They have a separate closed/locked room for chemical, soaps, and other dangerous products. Propane is used for the drying ovens in the dehydration plant.

Findings on Construction and Water:1. Construction of the building was well done and equipment is in place and operational. Plantains are offloaded at a dock and go into a washing station. Presently water for the washing station is obtained from the community “pozo” and the cooperation has municipal permission to use 50 gallons/minute over a 20-hour period. The use is within the 25m3 of water per day that is used for the washing station. The wastewater is being pumped out of the washing tank into an open-air tank in the field 25 meters from the washing station. The tank has soil filters and wastewater goes back into the cane field through the filters.The dehydration plant also has a washing station that uses much less water but still puts a strain on the community pozo, especially during the dry season and droughts.

2. There is no drainage around the base of the plant and water from the washing area was spilling out on the cement floor and out the entrance area to the dirt outside of the plant.

Recommendations regarding water and construction:1. Recycle the wastewater by filtering it and pumping it up to a holding tank for gravity flow back into the washing tank. This could be done for a week or so until the filtered wastewater is too dirty to use. At least this would save water from the pozo, especially during the dry season.2. Place gutters on roofs of the two large buildings to capture rainwater in holding tanks that can be used for washing.3. The Coop is planning to construct a new pozo so they would not affect the community water supply.4. Drainage channels should be constructed around the washing area of the processing plant and spilled water channeled out into the cane field.

Findings on Fumigation Station:

4

1. USAID funded a fumigation station that has not been used yet as it is only for use on plantains that will be exported. Chiquita Company has plans to purchase the plantains for export and the machine is planned to start up in early March.

As fungicides will be used in this equipment, the contractors based on the fungicides that Chiquita is planning on using should have prepared a PERSUAP. The plant manager said that the purchasing company would test the following fungicides:Amistad (Amistar-Active Ingredient azoxystrobin) GUP Class 4 (depending on the specific product) Metric 340 (Mertect – Active Ingredient Thiabendazole GUP Class 3 (depending on the specific product)Alumbre (Product Unknown-Alum) GUP or RUP Class 1 depending on product. This fungicide has not been approved in past USAID PERSUAPs in various countries.

Recommendation/Action needed regarding fungicides:1. Amistar 50- Azoxystrobin has been approved in the Regional Coffee PERSUAP and it is for use on plantains. The Regional PERSUAP did not envision using this product for post harvesting. Thus, the PERSUAP will need to be amended.2. Mertect-Thiabendazole was not included in either the El Salvador Cacao PERSUAP or the Regional PERSUAP for coffee. Thus, if this fungicide were planned for use, it would need to be covered in the Regional coffee PERSUAP amendment.3. Alumbre/Alum is not recommended for use given its extreme toxicity as a Class 1 product.4. The contractor (Nathan Associates) will need to prepare a PERSUAP amendment of the Regional Coffee PERSUAP before the use of the fumigation machine occurs. I would consider that Amistar could be used while the PERSUAP is being amended, as it is included in the PERSUAP already, even though it included for a different use. USAID’s regulations as per REG 216 regarding the use of pesticides is that a PERSUAP must be completed and approved for each pesticide proposed for use for a specific crop and use within the crop process (in this case the use is for post-harvest fumigation).5. For the preparation of the PERSUAP amendment, Nathan Associates needs to discuss with the company/companies that will be receiving the export of plantains regarding the specific fungicide products and formulas that they will be using.6. Nathan Associated needs to analyze all the other product plants that were constructed or equipment donated by USAID to determine if any other crops within the Activity are being treated with pesticides during the post-harvest processing. As in the case with the Plantain operation, a fumigation machine was donated by USAID and thus USAID/contractors have the responsibility to prepare a PERSUAP, as that machine will use fungicides. It may be the case with potatoes, honey, etc.

Findings of potential impacts and need for mitigation measures for the EMMP:1. Trash was visible all around the washing/processing plant outside of the cement area. Given that the plant is processing food, the trash can cause vectors and disease to occur. It is also an eyesore and a negative impression to the companies that come to buy the products.

Recommendation: A simple mitigation measure of informing workers of keeping the area clean, and placing trash bins away from the plant and cleaned each day, would minimize this impact.

See the recommendations for water and construction above that should be implemented as mitigation measures as well.

Additional Direction for the EMMP:

4

The need for preparing an Umbrella EMMP that shall include small scale renovation/construction (including water use for post-harvest operations), installation of USAID donated equipment, and any connected actions related to Pesticides/PERSUAP shall follow the REA’s previous email of last week (February 13th) outlining the need for the EMMP. Nathan has given a sub-grant to a subcontractor for honey processing that included donated equipment. All subcontractors shall contribute to the EMMP and shall be informed of the implementation of mitigation measures and use of the PERSUAP if pesticides are used.

The lack of environmental compliance documentation over the life of this Activity is a serious infraction especially as pesticides will be used and the contract outlined the requirements for the EMMP and a PERSUAP if using pesticides (included in the IEE).

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Annex 4 Pesticides Factsheets

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Annex 5 Exposure to Pesticides, Toxicological Hazards and Mitigation Measures8

Farmers who use pesticides are exposed to poison and it is crucial to keep such exposure to the absolute minimum. The hazard can be reduced by following appropriate safety procedures. Most pesticide poisonings result from neglect or lack of knowledge of safe pesticide management.

The time it takes to learn about safety procedures is an investment in the health and safety of yourself, your family, and others.

Pesticides can enter the body in four main ways: the skin, the mouth, the nose and the eyes. The following checklist helps users avoid these different routes of overexposure to pesticides.To avoid dermal exposure (skin):

• Check the label for special instructions or warnings about dermal exposure• Wear recommended protective clothing and other equipment on the label.• Do not return to the treated area until the sprayed pesticide has dried, or until the re-entry

interval (waiting period) has passed.

To avoid oral exposure (mouth):

• The label for special instructions or oral exposure warnings.• Never eat, drink, or smoke while working with pesticides.• Wash thoroughly with soap and water before eating, drinking, smoking or chewing tobacco.• Do not touch contaminated objects with your lips (such as nozzles).• Do not clean your mouth with contaminated hands or clothing.• Do not expose food, beverages, drinking glasses, or cigarettes to pesticides.• Wear facemasks when handling concentrated pesticides.

Avoid exposure by inhalation (respiration):

• Read label to see if respiratory protection is needed.• If respiratory protection is required, use only an approved respiratory device.• Stay upwind while applying.

To avoid exposing the eyes:

• Read the label to see if eye protection is needed.• If eye protection is needed, use eye protection to protect your eyes or face and eye

protection.• While pouring, the keep the pesticide container below eye level.

The speed at which first aid against pesticide poisoning is urgent. If you are alone with the victim, you should first pay attention to the victim, especially that he/she start breathing again, separating the victim from the source of the pesticide, and decontaminating the victim's skin. If there is

8This section was taken entirely from Rovesti, Luciano, V. Gómez y R. Delgado, 2011. Evaluación y Plan de Acción para uso seguro de plaguicidas (PERSUAP) Proyecto FECOPROD Paraguay.

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someone else with you and the victim, one of you must provide first aid, the other should seek professional assistance as described above.

Quickly recognize signs and symptoms of pesticide poisoning and follow proper procedures to help save a person's life, but first aid is never considered a substitute for professional medical treatment. First aid only helps the patient to be able to get medical care.

Action to take:

1. Stop exposure immediately by separating the victim from the source of the pesticide.2. If victim is unconscious, check to see if victim is breathing. If not, give artificial respiration. If

there is highly toxic material in the victim's mouth or airway, use chest compression and no mouth-to-mouth.

3. Immediately decontaminate the victim by washing the pesticide residues off the skin, and remove-contaminated clothing. Speed is essential in this step.

4. Get professional help (call a poison control center or the nearest doctor).

In any case, consider the protection of yourself properly, and others close to the incident. This is critical in the event of a large pesticide spill.

When the victim has received care and sought professional help, take these additional steps. As well as in first aid procedures, properly consider your safety and that of those around you.

• Carry the label and MSDS for delivery to the doctor and poison control center. In addition, you must keep the container of the pesticide and all the remaining pesticide, in case the official requests to see it.

• Eliminate the source of contamination, or prevent or reduce the risk of others that may be exposed to the pesticide. In case of a significant pesticide spill, trained professionals will have to to respond to this type of emergency.

• Decontaminate all clothing or equipment as required. Never wear previously contaminated clothing with pesticide, and always wash contaminated clothing separately in water with detergent.

Table 12 Action in case of poisoning emergency

WHAT TO DOFor skin poisoning Act quickly

Take off contaminated cloths and wash the skin with waterWas skin and hair completely with water and detergentDry the victim and wrap in a blanket

For chemical burns Take off contaminated clothsWash with lots of fresh waterImmediately cover the burnt area with a clean, soft and loose clothAvoid the use of ointments, oil, powder or other medicationTreatment for shock, keep the patient lying down, warm and talk to calm him/her down until the doctor arrives

Poison in the eyes Keep eyes openWash eyes immediately with fresh, clean water. Use large amounts of water. Continue washing for 15 minutes or more. A few minutes delay can increase the seriousness of the lesion

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WHAT TO DODo not use chemicals, or medications when washing with water. This could increase seriousness of the injury.

Inhaled poison If the victim is in a closed space, do not try to rescue the victim without the appropriate respiratory equipmentTake the patient immediately to clean air. Loosen tight clothe. Apply mouth-to- mouth respiration if the patient has stopped breathing or if breathing irregularly. Request emergency assistanceAvoid the person from getting cold (wrap the patient in a blanket, but not too hot). The patient should talk the least possibleIf the patient is having seizures, observe his breathing and protect the patient from falling and hitting his/her head on the floor or Wall. Keep the patient’s head raised for the airways to be free to breath.

Poison on the mouth or swallowed

Wash mouth with abundant water.

Request emergency assistance immediately. If a non-corrosive substance has been swallowed, induce vomit as indicated in the label instructions, MSDS or medical staff from the Poison Control Center.Induce vomit only if instructed in the label or by qualified personnel *

* Procedure to induce vomiting:

• Place the victim face down or tilted forward and kneeling; Do not allow the victim to lie on his or her back because the vomit may enter the lungs and cause additional damage.

• Place a finger or the blunt end of a teaspoon into the back of the victim's throat or administer ipecac syrup.

• Store a vomiting sample for the doctor if you do not know what the poison was.• Do not use saline solution to induce vomiting.

When to AVOID induce vomiting:

• If the victim is unconscious or convulsing.• If the victim has ingested corrosive poison (e.g., strong acid or alkaline solution). This

poison burns the throat and mouth when it comes down and when it rises again. It can also penetrate the lungs and burn them too

• If the victim has ingested an emulsifiable concentrate or oily solution. They can cause severe damage to the lungs if inhaled during vomiting.

The importance of having well designed poisoning emergency plans before an emergency occurs cannot be overstated. It is especially important to have contact information on hand wherever pesticides are handled. This information should include name, address, and telephone number of poison control facilities, and telephone number for poison control centers.

Symptoms of pesticide poisoning are similar to other types of poisoning and other illnesses. Fatigue from heat, food poisoning, asthma, and other discomforts are sometimes confused with pesticide poisoning. Just because a person gets sick after using or being near pesticides is not proof that he has been poisoned. Symptoms of poisoning described herein may occur in someone who has been suddenly exposed to large amounts of toxic material. They can also occur in a person who has been continuously exposed to small amounts of toxic material for extended periods. If symptoms appear, call your doctor and inform him / her of the name of the pesticide involved.

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The following is a risk assessment for aluminum ammonium sulfate (Alum)

Table 13 Risk Assessment Aluminum Ammonium Sulfate (Alumbre)

Risk Cause Source of Hazard

Likelihood of occurring Control Measures Frequency Responsible

Use of appropriatedose, use of EPI,

safety brochure and

Chemical substance Intoxication

Aluminum ammonium

sulfate (Alum)

Low

sheets, brochure and supplier

requirements valid product (not expired), training and use and

Every time used in

banana or plantain.

Person in charge of the

plant, in charge of doses.

GMP measuresagainst accidents inthe packing plant.

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Annex 6 EPA Recommended Worker Protection Standard9

Pesticide labels provide critical information on the safe handling and legal application of pesticide products. Unlike most product labels, pesticide labels are controlled by law, and all have the following statement: "It is a violation of federal law to use this product in an inconsistent manner with its label." That is, the label is law

The EPA's Label Review Manual (2011) provides instructions to produce legible, unambiguous, and enforceable pesticide labels according to the law. It also provides a lot of useful information on how to identify the Correct Product Specific PPE when the correct toxicity category has been established, as summarized in the table below. The Handbook is available online (in English) and can be downloaded at http://www2.epa.gov/pesticide-registration/label-review-manual

Table 14 Toxicity Category by Exposure Route and final use of the product

Exposure routeToxicity Category by Exposure Route and final use of the product

I HAZARD

II WARNING

III PRECAUTION

IV PRECAUTION

Possible toxicity irritation1

dermal or

skin

Jumpsuit over long sleeve shirt and long pant

Jumpsuit over short sleeve shirt and short pants

Long sleeved shirt and long pant

Long sleeved shirt and long pant

Socks Socks Socks SocksChemical agents resistant footwear

Chemical agents resistant footwear

Footwear Footwear

Chemical agents- resistant or impervious gloves2

Chemical agents- resistant or impervious gloves2

Chemical agents- resistant or impervious gloves2

There minimum4

is no

Toxicity inhaling

from Respiratory protection device3

Respiratory protection device3

There is no minimum4

There minimum4

is no

Potential irritation5

for eye Potential for eye irritation5

Potential for eye irritation5

There is no minimum4

There minimum4

is no

1 If there are variations of the categories of dermal toxicity and skin irritation is Category I or II, see Section 2 of the manual to determine if more PPE is needed from that specified in the table.

2 See Section 3 of the manual, Table 3, to determine the specific type of permeable or chemical products resistant gloves.

3 See Section 4 of the manual to determine the specific type of respiratory protection4 Although there is no minimum, PPE required for these toxicity categories and exposure routes, an EPA

requirement could be the use of PPE for specific products.5 Instead of “goggles” and or “face protection” and/or “safety goggles” and similar terms, the term “Eye

Protection” will be used to describe the protection of the eye, at least in some diagnostic where a specific eye protection is required, for appropriate protection.

Many PPE statements on pesticide labels have been changed because of the Agricultural Pesticides Worker Protection Standard (WPS). These modified statements are more precise as to the type of

9 This section was taken completely from Rovesti, Luciano, V. Gómez y R. Delgado, 2011. Evaluación y Plan de Acción para uso seguro de plaguicidas (PERSUAP) Proyecto FECOPROD Paraguay.

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PPE to be used by pesticide handlers (mixers, loaders and applicators). The terminology that is used to describe PPE is uniform from one label to another, although it is bound to be summarized, and some authors have tried to clarify which PPE is necessary for mixers, loaders and applicators, so that each label agrees (see ex., Fishel FM, 1995, revised in 2013. Interpretation of PPE Statements in Pesticide Labels).

Table 15 Personal Protective Equipment (PPE) (body protection)

Label Warning Acceptable PPE

Long sleeve shirt and long pants

Long sleeve shirt and long pants, orWoven or non-woven fabric jumpsuitJumpsuit covered with plastic or any other barrier, orPlastic or rubber suit

Jumpsuit over short sleeve shirt and shorts

Jumpsuit over short sleeves and shorts, orJumpsuit over long sleeved shirt and long pants, orJumpsuit over another jumpsuit, orJumpsuit covered with plastic or any other barrier, orPlastic or rubber suit

Jumpsuit on long sleeved shirt and long pants

Jumpsuit over long sleeved shirt and long pants, orJumpsuit over another jumpsuit, orJumpsuit covered with plastic or any other barrier, orPlastic or rubber suit

Chemical resistant apron or over jumpsuit, or very long sleeved shirt and long pant

Chemical resistant apron or over jumpsuit, or very long sleeved shirt and long pant, or jumpsuit covered by another barrier, or suitPlastic or otherRubber or other

Chemical resistant protection suitJumpsuit covered with plastic or other barrier, orRubber or plastic suit

Water resistant suitJumpsuit covered with plastic or other barrier, orRubber or plastic suit

Table 16 Personal Protective Equipment (PPE) (Hands Protection)

Label Warning Acceptable PPEImpervious gloves Any pair of gloves that resist the task performed

Chemical Resistant Gloves

Gloves laminated with barrier, orOther gloves that appear in the glove selection tables or guide documents that indicate being chemical resistant to the pesticide for the time needed for the task performed

Chemicals resistant gloves as butyl or nitrile gloves

Butyl rubber gloves, orNitrile glove, orOther gloves that appear in the glove selection tables or guide documents that indicate being chemical resistant to the pesticide for the time needed for the task performed

Table 17 Personal Protective Equipment (PPE) (eyes protection)

Label Warning Acceptable PPE

Eye protectionSafety adjusted goggles, orComplete coverage mask, orGoggles, or

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Full face respirator

GogglesGoggles, orFull face respirator

Table 18 Personal Protective Equipment (PPE) (foot protection)

Label Warning Acceptable PPE

Footwear

Leather, canvas or cloth shoes, orChemical resistant footwear, orChemical resistant boots, orChemical resistant shoe covers (booties)

Chemical resistant boots Chemical resistant boots

Table 19 Personal Protective Equipment (PPE) (airways protection)Label Warning Acceptable PPE

Cartridge Respirator

Respirator with cartridge against organic vapor and pesticide pre-filter, orRespirator with deposit, approved for pesticides, orRespirator with air tank

Respirator with air tank or automatic respiration equipment (ERA)

Respirator with air tank, orAutomatic respiration equipment

Respirator with dust/fog filter

Respirator with dust/fog filter, orRespirator with dust/fog filter cartridge, orRespirator with organic steam cartridge and peptide pre- filter, orRespirator with air tank

Respirator with deposit (gas mask)Respirator with deposit, approved for pesticides, orRespirator with air tank

Table 20 Personal Protective Equipment (PPE) (Head protection)Label Warning Acceptable PPE

Chemical resistant Hood or broad rimmed hat

Safari type hat covered with rubber or plastic, orFirefighter style hat, covered with rubber or plastic, orHood covered with plastic or other barrier, orRubber or plastic hood, orComplete Hood or helmet that are part of some respirators

There is much information on PPE for workers protections and publications that can be downloaded (in English) at: http://www.epa.gov/agriculture/awor.html#pesthandlers.

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Annex 7 Mitigation of Potential Pesticide Hazards and General Measures to Ensure Safe Use10

In case there is no feasible alternative to the use of pesticides, the following measures should be taken to mitigate and reduce the risk to human health and the environment. Note that risk is a function of toxicity and exposure. Reducing risk means (1) selection of less toxic pesticides and (2) selection of pesticides that lead to less human exposure before, during and after use.

Reduce Exposure Time or Degree of Exposure

Training is an extremely important component of any activity involving the use of pesticides and should be given to all relevant stakeholders (users, marketers, transporters, etc.) before they engage in any pesticide activity. The training must be continuous; it must correctly identify the level of the public and adapt to ensure that the messages are received.

Before Use

Transportation

• Separate pesticides from other materials being transported• Protect pesticides from very high/low temperatures (follow directions on labels)• Trust the transportation of pesticides only to trained/qualified personnel.

Packaging

• Follow international and national standards and guidelines• Use packaging that is tailored to your needs (e.g., small-sized packages for farmers)• Avoid re-use of packaging materials (even if they are cleaned, it is dangerous to

reuse pesticide containers)• Storage• Develop strict storage guidelines for farmers or at village level• Ensure that they are labeled permanently and well-marked• Observe and respect national/international standards (locked doors, fire extinguishers

available, etc.)• Use appropriate language (Spanish / Guarani) and approved pictograms• Use and respect appropriate toxicological colors• Protect pesticides from very high/low temperatures (follow directions on labels)

During use

Conditions of the environment

• Ensure the evacuation of anyone not involved with the pesticide application process• Establish buffer zones around residential or public areas, environmentally sensitive

areas (e.g., water bodies, protected areas, etc.)• Make sure that the ambient conditions are suitable for the application (e.g. wind

speed, rain risk, etc.)• Mark the areas treated with warning signs, if possible

Protective clothing and equipment

10 (extracted and modified from http://pdf.usaid.gov/pdf_docs/PNADK154.pdf)

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• Must be adapted to local climatic conditions• Must be adapted to the needs and resources of the user• Eliminate exposure and not only reduce exposure, if possible.

Application equipment

• Must be adapted to the needs and possibilities of the user• Must be in good technical condition (be sure to maintain and spare parts and

service) After use

• Respect and enforce any period of exclusion of the treated area (REI, etc.)• Be sure to clean and rinse properly:

- the preparation equipment and application applicators- clothes of the applicators- storage containers

• Develop a functional monitoring and evaluation system to:

- Make it consistent with national and international pest and pesticide management policies

- Effects on the health of applicators, the local population and domestic animals - efficiency in targeted pests

- Impacts on the environment: water, soil, etc.- Disposal of pesticide residues and containers

Pesticide Application: Important Precautions

Avoid applying sprayed or powdered pesticide if you see that the leaves and small plants move in the wind (i.e., when the wind moves at 4 meters/second). If the wind carries too much pesticide from the treatment area, there is the possibility that the pests will not be affected. In addition, volatile pesticides can harm the environment in other areas: it can affect human settlements, pollute waterways, and contaminate adjacent crops that are about to be harvested.

Refrain from applying pesticides during the hottest hours of the day. As a general rule, do not make applications between 10 a.m. and 6 p.m. Avoid applying pesticides if you think it can rain before 12 hours, rain will probably wash the pesticide. It is to waste the pesticide and go into the runoff to water bodies or other inappropriate places.

The disposal of unwanted pesticides, which is a potentially dangerous undertaking, is difficult to do this safely. Avoid this problem by buying only the amount needed for a single season, and mix only the amount needed for the area you want to treat.

Wear the recommended protective clothing at all times. Never consume food, drink, or smoke while applying pesticides; tobacco absorbs them. Do not carry tobacco, food or drink when you are fumigating. Keep out of the wind from the spray and keep others away from the area. If a nozzle is capped, do not try to blow it with your mouth to clean it; Use a small brush or a soft rod.

After applying pesticides, wash the equipment and protective clothing and store them in a safe area. Wash your face, hands and other exposed parts of the body with soap and plenty of water. Wash contaminated clothing separately from other clothing. As always, do not contaminate rivers, lakes, or

8

potable water wells during cleaning. If you or a colleague show signs of pesticide poisoning, stop spraying immediately and begin first aid.

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Annex 8 Pesticide Disposal Options11

• (modified by Nesheim O.N. and Fishel F.M. (2005)) available in English at: https://www.google.com.ec/?gfe_rd=cr&ei=dK4AVt7VKNaK-Norman + Nesheim + and + Frederick + M. + Fishel2% 22)

Proper disposal of pesticide residues is an important part of the responsible use of pesticides. Inappropriate disposal may lead to contamination of soil, ground water, and surface water, and consequently health problems. Everyone who handles pesticides must know how to properly dispose of pesticides.

• There are five types of pesticide residues:

• Empty Containers• Blend of leftover pesticide• Leftover product• Water after rinsing of containers and application equipment• Material generated from spill and leakage cleaning

According to US law, waste is classified in two, which affect the disposal of these types of pesticide residues. These are:

• Toxic waste• Solid waste

A waste is toxic if it has the following characteristics:

• Flammable: wastes that are inflammable or combustible substances. If they have an ignition point of less than 140 °F or an alcohol content of 24% or more, then these are hazardous waste.

• Corrosive: debris that can burn skin or corrode metal. Liquids with a pH of 2 or less or12.5 or more are corrosive.

• Reactive: wastes that are unstable and may explode or have violent reactions with water or other materials.

• Toxic: wastes containing certain heavy metals in concentrations higher than specified, such as chromium, lead or cadmium, or toxic organic chemicals.

Pesticides classified as hazardous waste:

• They are regulated in the Resource Conservation Recovery Act (RCRA);• Are on the list of a section of federal regulations; and• Must be disposed properly, usually need to be done by an authorized hazardous waste contractor.

• On the other hand, pesticides that are not classified as hazardous waste:

11 Esta sección fue tomada en su totalidad de Rovesti, Luciano, V. Gómez y R. Delgado, 2011. Evaluación y Plan de Acción para uso seguro de plaguicidas (PERSUAP) Proyecto FECOPROD Paraguay.

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• These can be disposed of as normal solid waste or garbage;• Are regulated by state law;• These must be disposed of according to the instructions on the label; and• Should be disposed carefully.

The label shall not contain an indication that a product is classified as a hazardous waste (see table at the end of this annex).

Farmers are exempt from complying with most of the RCRA; commercial applicators are not. Under state law, a farmer may dispose of waste and containers after triple rinsing on farmer property if:

• The waste has been generated on the property of that farmer;• Waste is not a source of groundwater or surface water pollution; and• The form of disposal is consistent with the instructions on the label.

The disposal method must always consider local conditions. For example, under the law of most countries, burying containers after triple rinsing is acceptable, but should be avoided in areas with a high mantle, because of the risk of contaminating groundwater.

Method of disposing of empty containers

Empty bags. Should be shaken until clean. Can be buried in a landfill if the operator allows this.

Empty barrels, bottles or cans Triple flushing should be done as follows: (i) empty the pesticide concentrate into a spray tank and empty the container vertically for 30 seconds; Ii) Fill the container to 1/4 or 1/5 of water and rinse thoroughly. Put this rinse water in your tank. Be sure to let the pesticide container drain for several seconds; Iii-iv) repeat the rinse and empty two more times. Now add water to the tank and fill it to the required level; V) Drill holes in the container to prevent its reuse. Properly rinsed containers can be buried in landfills, if permitted by the operator and local regulations.

Plastic containers that have been properly cleaned can also be recycled. Recycling is the best handling option for containers. The energy value of the plastic is retained, and the containers are removed from the property of pesticide user -preventing them from becoming a potential liability.

Some of the states allow outdoor flushing of rinsed containers and bags that have been shaken. Outdoor burning is permitted in an open field if:

• You are the owner of the crop, employee authorized by the owner or manager, or commercial pesticide applicator that has contracted the owner or manager;

• The label indicates that the empty container may be burned;• Containers come from fumigation operations on that property.

When burning the containers, you must:

• Burn only the accumulation of one day at a time (500 lb. maximum);• Burn outdoors, 60 meters or more from inhabited buildings or agricultural workers, and

30 meters or more of public roads;

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• Burn the containers between 9 a.m. and an hour before sunset;• The person responsible for the burn must be present until the flame and smoke have

dissipated;• Make sure that outdoor burning does not produce as much smoke, soot, odors, visible

emissions, heat or flame that it could be a nuisance; and• Place containers in a non-combustible container or excavated in the ground covered with

a metal grate.

Method of disposing leftover mixture

The leftover mixture is the diluted pesticide remaining in the sprinkler tank after a pesticide application. Avoid the problem of excess mixing by gauging and calibrating carefully. Fill your sprinkler tank with just the amount you need to get the job done. Do not generate leftovers. If you do, the way to dispose of the leftover mixture is to use it in a labeled place. Generally, it cannot be stored.

Method for disposing of leftover product

The leftover product is unused pesticide, which is not needed or is no longer legal. To avoid the problem of surplus product, buy only what you can use in one season. The best way to dispose of the surplus product is to find someone who can use it - if the product can still be used legally. Check with the supplier or manufacturer to determine if they accept it on return. Small amounts of surplus product may be available during waste collection programs sponsored by local solid waste management agencies. If you cannot use it, give it away or dispose of it through a local hazardous waste collection program, you must arrange for an authorized hazardous waste contractor to dispose of it.

Method of disposing of the rinse water

Improper disposal of rinse water when washing application equipment has great potential of causing contamination of groundwater and surface water.

• Do not flush the rinse water on the soil.• Do not flush rinse water to septic systems - this increases the chance that it will reach

groundwater.• Do not discharge rinse water to ditches or streams - it is illegal and can damage

neighbors' crops or trees or can be dangerous to fish and other wildlife.• Do not bury rinse water-it can contaminate groundwater.• Do not minimize rinse water-wash equipment only when necessary.• You can re-apply rinse water to a labeled site-his is permitted by law and will not result in

a concentration above the label recommendation.• Reuse the rinse water to dilute the following formulation, provided that the site where the

rinse water is applied is a labeled site.

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Table 21 Pesticides Regulated as Hazardous Toxic Wastes or Extremely Hazardous Toxic Wastes

Hazardous Toxic Waste Extremely Hazardous Toxic Wasteamitrole aldicarbácido cacodílico aldrinClorobencilato fosfuro de aluminioclordano aminopyridinediallate dimethoateDBCP dinoseb1,2-D disulfoton1,3-D endosulfan2,4-D endothallDDT famphurdibromoetano de etileno heptaclorolindano metomilohidracide maleico metil paratiónbromuro de metilo paratiónmetoxiclor phorate

Hazardous Toxic Waste Extremely Hazardous Toxic Wastepronamide toxafenothiramwarfarina (3% o menos) warfarina (mas de 0.3%)fosfido de zinc (10% o menos) fosfato de zinc (más de 10%)

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Annex 9 Websites on Pesticides12

Those marked with an asterisk are the most useful for the elaboration of the PERSUAP.• http://www.pesticideinfo.org (PAN base de datos de plaguicidas más completo)• http://extoxnet.orst.edu/pips/ghindex.html (base de datos Extoxnet de la universidad Oregón

State)• http://www.epa.gov/ecotox/ (base de datos de la EPA Ecotox)• http://www.cdpr.ca.gov/docs/epa/m2.htm (vínculo al sitio OPP)• http://cfpub.epa.gov/oppref/rereg/status.cfm?show=rereg (EPA Registr.Eligib.Decisions)• http://www.epa.gov/pesticides/biopesticides/ai/all_ais.htm (biopesticidas regulados por la EPA)• http://www.epa.gov/opppmsd1/RestProd/rupjun02.htm (pesticidas de uso restringido por la EPA)• http://www.epa.gov/pesticides/health/tox_categories.htm (Clasificaciones de toxicidad de la

EPA)• http://www.epa.gov/opppmsd1/PPISdata/index.html (información de productos de plaguicida de

la EPA)• http://www.chemfinder.camsoft.com (base de datos de sustancias químicas y búsqueda internet,

gratis y pagado)• http://www.hclrss.demon.co.uk/index.html (compendio de nombres comunes de plaguicidas)• http://www.agf.gov.bc.ca/pesticides/f_2.htm (todo tipo de equipo de aplicación)• www.who.int/ipcs/publications/pesticides (clasificación de la OMS)• www.kellysolutions.com (para información de estatus de registro de formulaciones)• www.greenbook.net and www.cdms.com para información sobre eficacia y Hojas de Datos

sobre la Seguridad de Materiales encontrados en las etiquetas de plaguicidas

CABI Site for Crop Protection Compendium (CPC)• http://www.cabi.org/compendia/cpc/index.htm para entrar a CABI CPC para crop/pest reccs.

Obsolete Pesticides• http://www.fao.org/ag/AGP/AGPP/Pesticid/Disposal/en/103401/index.html

Pesticide Toxicitydad on Honeybees• http://www.entm.purdue.edu/Entomology/ext/targets/e-series/EseriesPDF/E-53.pdf• http://www.ohioline.osu.edu/hyg-fact/2000/2161.html (Ohio State Extension site)****

Pesticide Toxicity on Natural Enemies (Beneficial)• http://www.ipm.ucdavis.edu/PMG/r108900111.html****

List of Biological Pesticides• http://www.koppert.com (empresa holandesa de biológicas que comercializa a nivel

internacional)• http://www.biobest.be (empresa belga de biológicas que comercializa a nivel internacional)

http://www.epa.gov/pesticides/biopesticides/ai/all_ais.htm (lista de biopesticidas de la EPA)• http://www.bio-bee.com/english/welcome.html (empresa de biopesticidas en Israel)

PERSUAP Sites• http://www.encapafrica.org/sectors/pestmgmt.htm (guía para PERSUAP)

12 This annex was taken completely from Lardizabal, R, K Menczer y A. Medicott, 2011. Evaluación y Plan de Acción para uso seguro de plaguicidas (PERSUAP) Proyecto ACCESO Honduras.

9

• http://www.wateriqc.com/millenium_conference/Proceedings/powerpoint_presentations/Day_4/1 030rossier.pps#285,10,Critical Pesticide Management Issues (EA History PPT)

International Conventions• http://www.pops.int/ (Sitio web POPs)• http://www.pops.int/documents/convtext/convtext_en.pdf (texto del Convenio POPs)• http://www.chem.unep.ch/pops/pdf/redelipops/redelipops.pdf (reducción y eliminación de POPs).

9

Annex 10 Photos

Photo 5 Water Discharge Pit Located in ACOPASCA Source: Michelle Rodríguez (MR), 2017.

Photo 6 Fumigation Chamber Source: MR, 2017.

9

Photo 7 Pesticide Mixture Tank Source: MR, 2017.

Photo 8 Water Discharge Pit Source: MR, 2017.

9

Photo 9 Storage Tank of Water from the Well Source: MR, 2017.

Photo 10 ACOPASCA workers without the full Personal Protective Equipment Source: MR, 2017.

Attachment 2

Climate Risk Screening and Management Tool for Activity Design – Central America Regional Trade Facilitation and Border Management ActivityOUTPUT MATRIX: CLIMATE RISKS, OPPORTUNITIES, AND ACTIONS

1.1: Tasks / Defined or Anticipated Tasks or

Interventions*

1.2: Time- frame

1.3:Geography 2: Climate Risks* 3: Adaptive Capacity 4: Climate

Risk Rating*5:

Opportunities

6.1: Climate Risk

Management Options

6.2: HowClimate Risks

are Addressed in the Activity*

7: Next Steps for Activity

Implementation*

8: Accepted Climate Risks*

10-years Borders and Heavy rains and flooding:● impact the timing and

participation at events.● power interruption

affecting interconnectivity between border control agencies.

● Small scale improvements (i.e. supporting infrastructure) for RFID systems may be affected or deteriorated.

Increased heat:● Humidity and heat may

affect IT structures and connectivity form optic fiber damage

Implementers, the Governments Low for Raise awareness Request climate The IEE conditions Incorporate Low inherent risk forcentral of Central America and Civil training, about climate change the activity to opportunities in the training, material

Objective 1: Central American government Society Organizations have material risk Create a considerations in prepare an solicitation package development and ITtrade related institutions offices of communication systems, financial development contingency the design of Environmental improvementsstrengthened Central resources, and infrastructure to and IT plan. required Mitigation and accepted.

American obtain climate information, and improvements. infrastructure Monitoring Plan Moderate inherentIntervention: countries identify and reschedule events RFID systems (EMMP) for small risk for small scale-Training and activities. Moderate for may help reduce scale improvements in-Material development small scale GHG emission by improvements in border facilities to-Improving IT systems and Additionally, most counterparts improvements reducing the border facilities to retrofit newinterconnectivity through and activities are located in in border time vehicles retrofit new equipment such assoftware and process urban areas that are less facilities to wait at borders. equipment such as RFID systems.development vulnerable to climate risk. retrofit new RFID systems.-Equipping at least two ports equipmentof entry with RFID (Radio- Power backup capacity is low, but such as RFIDFrequency Identification) government is working to build systems.systems contingency plans

Objective 2: Comprehensive 10-years Borders and Heavy rains and flooding:● Impact the timing and

participation at events.

Implementers, the Governments Low N/A N/A N/A N/A Low inherent riskImplementation of the WTO central of Central America and Civil accepted.Trade Facilitation Agreement government Society Organizations haveSupported offices of communication systems, financial

Central resources, and infrastructure toIntervention: American obtain climate information, and-Technical assistance countries identify and reschedule events(software developments, and activities.documented processes)

Cleared by: Luis Ramos, EG Date: June 27, 2017

1 Climate Risk Screening and Management Tool for Activity Design – Central America Regional Trade Facilitation and Border ManagementDrafted by: Lorena Aceto and Yolanda Martinez