Environmental Assessment and Pest Management Plan

EA Classification
Pest Management Plan
Assessment of institutional capacity and relevant policies
Expertise
Screening of pest control products
Criteria for selection and use of pest control products
EA Classification
For general information regarding EA classification of projects: see OP 4.01
BP 4.01 Annex C stipulates that projects are classified as Category A if these include the manufacture, use, or disposal of pest control products in quantities that are significant from an environmental or health perspective.
Whether or not quantities are significant from environmental or health perspective requires informed judgment. The term significant does not only refer to the size of quantities, but also to the risk. Relative small quantities of pesticides can pose high risks and thus be significant from environmental or health perspective. Relevant factors in this respect are: human toxicity, persistence of product, risk to end-user, capability for safe storage and disposal, potential impact on agro-ecosystem, environment and wildlife.
Projects that involve procurement of large volumes of pesticides (e.g.: locust control, malaria control, economic/agricultural rehabilitation projects procuring pesticides, etc.) are always classified as Category A.
Projects that directly or indirectly involve use of pesticides may not be classified as Category C.
Such projects are classified as Category B if these do not meet the above criteria for Category A.
Pest Management Plan
Pest and pesticide management issues relevant to the project are addressed in the EA. Preparation of a specific Pest Management Plan (PMP), in accordance with BP 4.01 Annex C, is required when there are significant pest management issues or when procurement of substantial quantities of pesticidesis envisaged. The PMP is part of the Environmental Management Plan.
A PMP is designed to minimize potential adverse impacts on human health and the environment and to advance ecologically based IPM. It describes pest and pesticide management issues relevant to the project and provides a strategy and plan for IPM implementation. It determines whether current or proposed use of pesticides is justified under an IPM approach, and whether it is economic (seejustifying pesticide use). Hazards associated with the transport, storage, handling, use and disposal of pesticides are identified and assessed. Measures are provided to reduce these hazards to a level that can be managed by the envisaged users of the products concerned. Preparation of a PMP also includes screening of pest control products if financing of such products is envisaged (seescreening of pest control products).
What BP 4.01 Annex C says about the preparation of a Pest Management Plan
A pest management plan is a comprehensive plan, developed when there are significant pest management issues such as:
  1. New land-use development or changed cultivation practices in an area;
  2. Significant expansion into new areas;
  3. Diversification into new crops in agriculture, particularly if these tend to receive high usage of pesticide, like cotton, vegetables, rice, etc.
  4. Intensification of existing low-technology systems;
  5. Proposed procurement of relatively hazardous pest control products or methods;
  6. Specific environmental or health concerns (e.g., proximity of protected areas or important aquatic resources; worker safety);
A pest management plan is also developed when proposed financing of pest control products represents a large component of the project.
A pest management plan reflects the policies set out in OP 4.09. The plan is designed to minimize potential adverse impacts on human health and the environment and to advance ecologically based IPM. The plan is based on on-site evaluations of local conditions conducted by appropriate technical specialists with experience in participatory IPM. The first phase of the plan - an initial reconnaissance to identify the main pest problems and their contexts (ecological, agricultural, public health, economic, and institutional) and to define broad parameters - is carried out as part of project preparation and is evaluated at appraisal. The second phase – development of specific operational plans to address the pest problems identified - is often carried out as a component of the project itself. As appropriate, the pest management plan specifies procedures for screening pest control products.
The EA and where relevant the PMP:
  1. Provides an assessment of current relevant pest management practices;
  2. Identifies specific practices and conditions that could and should be improved (e.g. calendar-based spraying, use of overly toxic or otherwise inappropriate pesticides, failure to apply available non-chemical methods, insufficient access of farmers to information about IPM, policy biases towards chemical control, deficiencies in institutional capacity to implement IPM and control of pesticide use, etc.);
  3. Provides measures and activities to be taken under the project to improve the situation;
  4. Provides a monitoring scheme to determine the effectiveness of these measures and enable correction where necessary.
Attention to pest management practices and pesticide handling is particularly important for projects to which any of the following points apply:
  1. The pesticide financing proposed represents a large component;
  2. The procurement of pesticides in WHO hazard Class II is proposed (Class I is excluded from Bank financing);
  3. Farmers or other laypeople without proper training, equipment, protective gear, storage and disposal facilities, are the envisaged end-users in client countries;
  4. There are specific environmental or health concerns (e.g., proximity of the project area to protected or sensitive areas, or important aquatic resources);
  5. The government capacity to control the use of pesticides is limited;
  6. Pesticide use is subsidized and thus may induce irrational use and/or provide a disincentive for the uptake of IPM.
The Technical Menu provides an outline for a Pest Management Plan (PMP). The outline can also be used as a checklist if a PMP is not required and pest management issues are addressed in the EA.
Preparation of a PMP includes identification of specific risks and the design of measures to reduce these risks. If pesticides are being financed it may be necessary to insist on supply of hazard reduction packages along with the pesticides. Such packages may include protective gear, training, application equipment, etc. The Technical Menu provides guidance in identifying hazards and suggests measures to manage such hazards and reduce risks.
Certain groups of projects require special attention because of the high volumes of pesticides that tend to be procured (e.g. emergency control of locust and other migratory pests; routine control of human and animal disease vectors (malaria, onchocerciasis, rodents, ticks, tsetse)), or because of the impact such projects may have on policy development relevant to pest management (e.g. research and extension projects; agricultural sector investment or management projects). The Technical Menu provides further information on these groups of projects.
Note 1: BP 4.01 Annex C exempts procurement of impregnated bed nets and WHO Class III insecticides for intradomiciliary malaria control from the requirement of preparing a pest management plan. In those cases preparation of a hazard assessment would suffice. A hazard assessment identifies risks associated with the transport, storage, handling and use of the pesticides concerned and provides measures to minimize these risks.
Note 2: As an exception, the PMP may be limited to pest control product screening when all of the following conditions are met:
  1. Expected quantities of pest control products are not significant from a health or environment standpoint (for a description of the term 'significant' see section on EA).
  2. No significant environmental or health concerns related to pest control need to be addressed.
  3. The project will not introduce pesticide use or other non-indigenous biological control into an area, or significantly increase the level of pesticide use.
  4. Products to be financed fall in Class III or table 5 of the WHO Classification of Pesticides by Hazard. Table 5 refers to pesticides unlikely to present acute hazard in normal use*.
* The present text of point 7D of BP 4.01 Annex C is inconsistent with OP 4.09 and has been put forward for updating. Under OP 4.09, Class I pesticides are excluded and Class II pesticides restricted.
Assessment of institutional capacity and relevant policies
OP 4.09 states that the Bank assesses the capacity of the country's regulatory framework and institutions to promote and support safe, effective, and environmentally sound pest management. As necessary, the Bank and the borrower incorporate in the project components to strengthen such capacity.
Capacity building and policy reform is an investment for the longer term and provides the do-good element of OP 4.09. This element is particularly relevant to sector or program lending. Institutional capacity development may include strengthening of IPM training capacity and/or strengthening of the regulatory framework for the control of pesticides. Attention for policies is important because these can have a strong influence on pest management practices. Relevant policies include pest management policies (research orientation, extension messages, incentives for input use), food safety (pesticide residues), public health and environmental protection (selection of pesticides and use restrictions).
Guidance for the assessment of capacity is provided under the following items of the Tools Menu:
  • Assessment of capacity;
  • Outline for a Pest Management Plan:
  • Pesticide Management;
  • Policy tools to support IPM.
Expertise
IPM and pesticide management are highly specialized technical fields for which expert advice should be sought. The borrower should involve local expertise in the preparation of a Pest Management Plan or section on pest management in the EA (such expertise may for instance be found through a national IPM program; Plant Protection Department of the Ministry of Agriculture, or relevant university departments). Assistance of an international specialist may be required.
For projects with significant pest management issues it may be necessary to include a pest management specialist /crop protection policy specialist in the team for the identification or preparation mission.
The decision on whether or not to include expertise should be taken in consultation with the Regional EA team, quality assurance team, or safeguard policy advisor.
Note:Experts involved in the preparation of a Pest Management Plan should not have linkages to entities involved in the sale of pesticides or other pest management products, because of potential conflict of interest.
Note: TheSystemwide Programme on IPM (SP-IPM),of which the Bank is a co-sponsor, offers assistance in the identification of experts.
Screening of pest control products
BP 4.01 Annex C stipulates that pest control product screening is required when a project finances pest control products. The screening establishes an authorized list of pest control products approved for financing, along with a mechanism to ensure that only the specified products will be procured with Bank funds (see also 'negotiations' and 'implementation').
Generally, screening is linked to the preparation of a Pest Management Plan, which puts pesticide use in a broader context and first determines to what extent pesticides are actually required under an IPM approach.
Main steps in the financing of pesticides:
  1. The Pest Management Plan outlines to what extent pesticide use is required under an IPM strategy;
  2. Actual requirements are established with involvement of an IPM specialist and are based on the specific pest problem and local conditions;
  3. The borrower prepares an authorized list of pest control products, based on requirements under an IPM approach, the selection criteria of OP 4.09 and national pesticide legislation;
  4. The Task Team Leader checks that: (a) the justification for chemical control is satisfactory (optimum use is made of available non-chemical techniques; pesticide use is economically justifiable) (see justifying pesticide use), (b) the proposed list of pesticides authorized for procurement under the project meets the criteria of OP 4.09, (c) hazards have been assessed and are adequately addressed. (Specialist advice may be required);
  5. Procurement of pesticides should only be authorized after risks have been assessed and, where necessary, adequate measures have been taken to ensure that hazards can be managed by the envisaged users.
  6. Procurement of pesticides is restricted to the authorized list and quantities should not exceed a one year requirement.

The authorized list of pest control products is specific to the pest problems that need to be addressed and is based on the criteria listed below. Proposed products that do not meet these criteria should be rejected. In such cases, the Bank makes every effort to help identify suitable alternative control methods or pesticides. The positive list should be open to modification by agreement between the Bank and the borrower so as to take into account new information or requirements that may emerge during the life of the project.
Criteria for selection and use of pest control products
Procurement of the wrong type or quantity of products may result in: acute poisoning of users; chronic poisoning of people, leading to cancers and birth defects; damage to ecosystems and drinking water supplies; leftover pesticides becoming unusable/obsolete and turning into hazardous waste; etc.Pesticides can cause harm to people. It is therefore important to pay detailed attention to selection and procurement procedures to minimize these significant risks.
Provisions of the OP/BP:
The procurement of any pesticide in a Bank-financed project is contingent on an assessment of the nature and degree of associated risks, taking into account the proposed use and the intended users. With respect to the classification of pesticides and their specific formulations, the Bank refers to the World Health Organization'sRecommended Classification of Pesticides by Hazard and Guidelines to Classification(For an explanation see Technical Menu:Selection and procurement of pesticides.)
The following criteria apply to the selection and use of pesticides in Bank-financed projects:
  1. They must have negligible adverse human health effects (see below).
  2. They must be shown to be effective against the target species.
  3. They must have minimal effect on non-target species and the natural environment. The methods, timing, and frequency of pesticide application are aimed to minimize damage to natural enemies (example). Pesticides used in public health programs must be demonstrated to be safe for inhabitants and domestic animals in the treated areas, as well as for personnel applying them.
  4. Their use must take into account the need to prevent the development of resistance in pests.
The Bank does not finance formulated products that fall in WHO classes IA and IB, or formulations of products in Class II, if (a) the country lacks restrictions on their distribution and use; or (b) they are likely to be used by, or be accessible to, lay personnel, farmers, or others without training, equipment, and facilities to handle, store, and apply these products properly.
Further guidance regarding criteria provided by OP 4.09
Adverse human health effects comprise acute toxicity and chronic health impact due to prolonged exposure to health-affecting chemicals. The restrictions related to WHO Hazard Classes address concerns about acute toxicity. The Bank does not finance Class I products and restricts the financing of Class II products. The latter can only be financed for use by professional/dedicated applicators, which are adequately trained and have appropriate application equipment and protective gear, and provided there are assurances that these products will not be used by others. Pesticides envisaged to be used by small-scale farmers or other laypersons (e.g. use by villagers for bed net impregnation) generally do not meet the above criteria, and therefore cannot include Class II products.Safe-usetrainingfor farmers has its limitations and generally does not satisfy the above criteria. The Technical Menu provides guidance on how todetermine theWHO Hazard Class of products.
Regarding the longer-term impact on human health and the environment, the Bank does not finance products that are on the UNEPlist of Persistent Organic Pollutants, with the possible exception ofDDT formalaria controlunder specific circumstances. The same generally applies to other products that are being phased out for health or environmental concerns by an increasing number of countries (e.g. persistent products, products known to have endocrine disrupting properties, etc.). Indicators to help identify such products include:
  1. Thelist of products subject to the Prior Informed Consent Procedure. In most cases these products will be excluded from procurement on the ground that these provide unnecessary risk to the environment and human health.
  2. Products of which the use is not permitted for environmental or health reasons in countries or groupings with advanced pesticide registration schemes like the USA, Canada, European countries and the European Union (registration rejected or canceled – see pesticide management issues).
The intended use of the selected pesticides should be (a) permitted under the national legislation, and (b) in compliance with the criteria of OP 4.09. Pesticides that are permitted under national legislation, but do not meet the criteria of OP 4.09, cannot be financed.
The selected pesticides should have minimal effect on non-target species and the natural environment. This is a difficult but important requirement, which is particularly relevant regarding impact on predators of common pests that potentially affect the crop concerned. Ignoring this requirement may lead to further pest outbreaks with significant negative effect on yields and unnecessary increase in cost of chemical control. This is one of the reasons why a Pest Management Plan needs to be prepared before selecting pesticides.