The USAID Fumigation Programmatic

Environmental Assessment:

A Four Year Retrospective

Erika Clesceri, PhD, Bureau Environmental Officer, Bureau for

Democracy, Conflict and Humanitarian Assistance, USAID

Integrated Pest Management and Fumigation Safety Training

January 24-26, 2017

Kansas State University, Manhattan, Kansas, USA

Purpose of the Fumigation PEA

• The Problem:

• Stored commodity losses due to insect infestation

• Ineffective fumigation is dangerous, with serious risks

to human health and possible pesticide resistance

• PVOs raised concern about fumigant residues on

fumigated commodity for beneficiaries

• The Solution: The Fumigation PEA

• BEO led, Food for Peace funded under GEMS contract

• Developed guidance, tools and templates for USAID-

funded projects

Content of the Fumigation PEA

• Main Body:

• Purpose, goals and methodology of the PEA

• Environmental and human health risk evaluation

• Mitigation measures for phosphine fumigation

• Annex A: Tools for implementation:

• Guidelines and templates for the fumigation

• Annex B: Background Information:

• Information collected and reports developed during the

elaboration of the Fumigation PEA

Development Timeline

• 2011: Scoping Statement for

Fumigation PEA

• 2013: Original PEA

• 2015: First Update to PEA

(Template Improvements)

• 2016: Second Update to PEA

(Applies to Entire Agency)

PEA Methodology

• PEA Team of experts in Environmental Impact

Assessment, Fumigation, Social Sciences Surveying,

Community Engagement, under GEMS project

• Stakeholder consultation of FACG members,

including USAID staff, PVOs, World Food Program

etc.

• Field Work in the USA (Manhattan, Kansas),

Uganda, Ethiopia and Djibouti

• Human Health Risk Evaluation of phosphine

fumigation for beneficiaries, fumigation service

providers, warehouse workers, and nearby residents

Over 125 stakeholders

consulted from:

Supreme Fumigation Services

Ltd

Star Pest Control

Smayaz Transact International

Zollo Pest Control

Gibe Freight Transporters

Hebret F.T.O.A

Compass Transport

Tared Transport

BMMI Djibouti and many more

Assessing Safety:

Human Health Risk Evaluation (HHRE)

Repeat application by fumigation

providers, multiple acute exposure,

chronic impacts?

PEA Findings: Environmental and

Human Health

• Poor practices can affect the health of fumigant applicators,

warehouse staff, and even nearby residents

• Beneficiary health impacts are not significant

• Poor fumigation will compromise the quality of food

• Solid Waste from Fumigation process + inadequate handling

and disposal of fumigant and waste could present a danger,

water reactive/explosive

• Recent domestic example in Texas where people died (2017)

Has USAID made any changes in

policies and procedures as a result of

this assessment?

Annex A: Tools for Implementation

1. Pesticide Evaluation Report and Safer

Use Action Plan (PERSUAP)

2. Fumigation Management Plan (FMP)

3. Solicitation and Contract Language

…Reduce redundancy globally…Consistent template...

Prepared PER... Focus on the SUAP and implementaion...

Pesticide

Evaluation

Report & Safer Use

Action Plan

Analysis of toxicology,

hazards, EPA registration,

IPM

Identifies actions for

mitigation

Annex A: PERSUAP Template

22 CFR 216.3(b), USAID Pesticide Procedures

Annex A: Fumigation Management

Plan (FMP) Template

• First ever for USAID

• Step by Step for safe, legal

and effective fumigation

• Follow steps assures

success

• Contents:

– Describes commodity and

ownership

– Establishes emergency plan and

safety

– Lists equipment and supplies

– Confirms steps are met for

application and monitoring

– Confirms steps are met for disposal

and cleanup

Annex A: FMP Template

• IPM section added to

original template in 2016

• Increase focus on non-

chemical approaches

• Contents:

– Warehouse Inspection for clean,

sealed warehouse and vacuuming

underneath pallets

– Proper handling of commodity

– Guidelines for infested, damaged

commodities

– Required actions to ensure a clean

yard area surrounding the

warehouse, free of weeds, trash

and water ponds.

Annex A: Solicitation and Contracts

Language

Fumigation Service

Quotation Request

Model Contract

Partners select better-

qualified service

providers

What are the gaps observed…?

…are we correcting them?

Common Issues found in

USAID Fumigation: PPE

“Painters Mask” will not stop gas

Big Obvious: • No canister masks

• Bare hands (and feet)

More Nuanced: • Only one mask

• Expired canister masks

Correcting.

Common Issues from

Fumigation: Gas Monitoring

Direct Read-out Meter

Color-Metric Tube

Detectors

Draeger Tube

Detectors

Gas Monitoring Equipment:

• Efficacy (under tarps)

• Safety (outside of tarps)

• No gas equipment found in

the entire country

• Imported from US, EU

• Custom Issues

Procured, but still

use problems.

Common Issues Found:

Siting of Warehouse

Safety of staff and nearby residents

– Warehouses not always sited at least 100m from

nearest residential/human habitation/businesses

– Warehouse not always sealed during fumigation

– Nearby resident not always alerted before every

fumigation

• Must have placard/post signs in English and

local language,

• Drawings especially among illiterate

populations or populations unfamiliar with

fumigants

Correcting.

Common Fumigation Issue: Tarps

• Procurement of Tarps that are too thin, not for

phosphine

• Reuse of tarps for too long, damages

• Culture of Mending the tarps, challenges

FAO, 2000

In Progress.

Common Issues, Gas Exposure:

Duration and Concentration

:

• Range of Standards and Practices

– PEA Recommendation:

• 5 days for 150ppm or 7 days for 100pm

– WFP Standard:

• 5 days at or above 150ppm

– Some PVOs, asked for shorter time periods, like 3

days due to program operations, without “any sign

of resistance”

Requirement: follow fumigant label instructions!

In Progress.

Follow On Activities as a

Result of PEA*

• Allocation of FFP ITSH funds for fumigant equipment

• >25 FFP programs with approved PERSUAPs

• Integration of PEA findings in:

• Nine (9) TOPS Commodity Management Workshops

• TOPS Warehouse Safety Handbooks and Posters

• TOPs Commodity Guide

• TOPs IPM & Fumigation Training and Webinar

• FFP required performance indicator for commodity

*(as of August 2016)

Country Examples:

Zimbabwe

• Coordination with WFP,

Harare

• Zimbabwean PhD

Entomologist heading

FSP, Entomon

• Resistance monitoring

• FFP using same FSP

Uganda

• Karamoja secondary

warehouse

• High praise for the FMP

• Including the FMP in

solicitation, used

template language

• Avoided hiring a

problematic FSP as a

result, Shared with

Mission and WFP

Other Impacts of the

Fumigation PEA?

• As baseline for bagging technology research by MIT

(Cambridge, MA) Higher Education Support Network

(HESN) Comprehensive Initiative for Technology

Evaluation (CITE)

• Interest by hermetically-sealed bags private industry and

the Wall Street Journal commodities editor

• Agency resource for food security programs, esp.

USAID’s Bureau for Food Security (BFS)

• Ability for USAID to speak authoritatively with scientific-

evidence basis to justify, Leadership

• Spill over improvements in-country warehousing and

market standards

With a special thanks to Dr. Bhadriraju

Subramanyam (Subi) for his fumigation expertise!

USAID Programmatic Environmental Assessment for Commodity

Fumigation located at:

http://www.usaidgems.org/fumigationpea.htm

Erika Clesceri

DCHA Bureau Environmental Officer (BEO)

eclesceri@usaid.gov