ADVANCE II PERSUAP Amendment 2:

Request for Additional Insecticides

for Fall Armyworm (FAW)Management

in

USAID/Ghana Feed the Future Programs

Contract number AID-641-A-14-0001

Agricultural Development and Value Chain Enhancement Program

(ADVANCE II)

Additional to the original ADVANCE II PERSUAPAmendment #1 submitted to USAID Ghana in September 2016. Submitted to AFR BEO Feb. 2017

ACDI/VOCA-Ghana

A&C Square, Jungle Road, East Legon, Accra

P. O. Box KD138, Kanda, Accra

Tel: +233 302 520231/2

February 2017

PROGRAM/ACTIVITY DATA:

Program/Activity Number: Aid-641-A-14-0001

Country/Region:Ghana/West Africa

Program/Activity Title:Agricultural Development and Value Chain Enhancement Feed the Future Activity (ADVANCE II). PERSUAP Amendment 2: Fall Armyworm

Funding:Ghana Feed the Future Program

Funding Begin:February 5, 2014Funding End: Sept 30, 2018

LOP Amount: $37,556,780

PERSUAP Prepared by: Victor M. Mombu, Environmental Specialist (ADVANCE II) with additions by Walter Knausenberger (Ph.D. Entomologist),AFR/SD Sr. Env.Policy Advisor

Current Date: February 2017

PERSUAP Amendment (Y/N):Yes

ENVIRONMENTAL ACTION RECOMMENDED: (Place X where applicable)

Categorical Exclusion: N/A Negative Determination:__X__

Positive Determination: _N/A __Deferral:_N/A__

ADDITIONAL ELEMENTS: (Place X where applicable)

CONDITIONS: X_PVO/NGO: X_ EMMP (SUAP): X _ ERR:

RELATED DOCUMENTATION:

  1. Bilateral USAID Ghana Feed the Future
  1. Ghana ADVANCE II PERSUAP, 2016. Amendment #1. Approved 5/11/2017 (ECD Link). Also refer to BFS Programmatic PERSUAP for Fall Armyworm below (ECD Link).
  2. Ghana_ADVANCE_PERSUAP_071812(DOCX)(PDF), approved 07/18/2012.
  3. Ghana Feed the Future Program, Agriculture Technology Transfer (ATT) PERSUAP (IFDC), approved 04/17/2014. Details for file #Ghana_FTF_EE_2011_2015(DOCX)(PDF).
  4. Ghana Commercial Agriculture Project (GCAP): Public Private Partnership, USAID & World Bank co-financing. Pest Management Plan.
  5. USAID Ghana_FTF_EG_IEE_120611.(DOCX)

West Africa Regional Programs

  1. West Africa Regional Programmatic PERSUAP (P-PERSUAP) Covering Nine Target Countries with USAID West Africa Programs:Sahel/Savannah zone (covered by CILSS/INSAH): Burkina Faso, Chad, Mali, Niger and Sénégal; Humid/Tropical zone: Benin, Côte d’Ivoire, Ghana and Liberia. Approved 3/16/2015: (PDF)
  1. West Africa PERSUAP for CORAF/WECARD - Feed the Future (FTF) Activities by National Agricultural Research Systems in eleven West African Countries. Details for file #West_Africa_CORAF_WECARD PERSUAP_2013_2017_BEOcleared(DOCX)(PDF), approved 04/17/2014. Operating Unit: West Africa. Countries:Benin, Burkina Faso, Cote d'Ivoire, Ghana, Liberia, Mali, Niger, Nigeria, Senegal, Sierra Leone, Togo.

Bureau for Food Security Central Programs in Ghana

  1. Programmatic PERSUAP for Fall Armyworm Management in Africa. Version 1. May 2017. Approved 5/16/2017 (AFR, BFS & DCHA BEOs). Revised 5/22/2017.(ECD Link)

(url:

  1. AGRA Scaling Seeds and Technologies Partnership in Africa (SSTP): PERSUAP, approved 01/29/2105. Details for file #BFS_AGRA_SSTP_PERSUAP(DOCX)(PDF). Approved 01/29/2015 BureauFood Security. Countries / Operating Units: Ethiopia, Tanzania, Ghana, Senegal, Malawi, Mozambique.

Purpose of This Document

This amendment #2 of the Ghana Feed the Future PERSUAP is intended to assist USAID Ghana programs support Fall Armyworm (FAW) pest management interventions as necessary, and as part of a comprehensive FAW Action Plan (Annex 3 & 4). It is to be seen as supplemental to the Programmatic PERSUAP for Fall Armyworm Management in Africa (May 2017), cited above. The FAW P-PERSUAP addresses FAW basic biology, distribution, and a discussion of possible control methods with a focus on Integrated Pest Management (IPM).

The present Ghana FtF PERSUAP Amendment (herein) approves all pesticides identified in the Ghana MOFA FAW Pest Management Decision Guide (PMDG) (Annex 1), and the FAW P-PERSUAP. Review the Annexes, esp.

  • Annex 1. Ghana Fall Armyworm Pest Management Decision Guide (Dec. 2016), produced by Ghana MOFA PPRSD & CABI Plantwise (Dec. 2016/March 2017), and
  • Annex 3. Ghana Comprehensive Action Plan for Management of the Fall Armyworm (May 8, 2017)(source: CABI Plantwise)

Then develop a collaborative Safer Use Action Plan to support FAW control operations, appropriate to the partners and localities where the Action Plan will be implemented.

A.SUMMARY

This document is a request for approval of Spinosad for the control of the newly invasive Fall Armyworms(Spodoptera frugiperda) under the USAID Ghana Feed the Future ADVANCE II project. It also includes a revised Safer Use Actions Plan for the ADVANCE PERSUAP. In January 2015, the ADVANCE project submitted for approval, a PERSUAP for the second phase of the ADVANCE project (ADVANCE II). A revised version of the PERSUAP was submitted requesting the approval of 36 new products made of 19 active ingredients (submitted to AFR BEO Sept. 26, 2016). Table 1 represents a side-by-side listing of the insecticidesapproved for control of insect pests in field crops in USAID supported programs in Ghana.

Table 1. Summary List of Approved active insecticides in the ADVANCE II PERSUAP Amendment (2016)[1] & FtF Agricultural Technology Transfer (ATT, 2014) PERSUAP[2]

ADVANCE II / FtF Ag. Tech. Transfer
No. / Active ingredient/
Chemical / Commercial Product Namesin Ghana / Active ingredient/
Chemical / Commercial Product Namesin Ghana
Insecticides / Insecticides
Abamectin / Bomec EC / Abamectin / Mektin 1.8EC
Acetamiprid + Cypermethrin / Chemiprid 88EC / acetamiprid + cypermethrin / Clomaprid 88 (actamiprid)
16 + cypermethrin 72)
acetamiprid +
lambda-cyhalothrin / K-Optimal / acetamiprid + lambda-cyhalothrin / Optimal 170 (acetamiprid 20 + lambda-cyhalothrin 150)
acetamiprid + bifenthrin / Aceta Star 46EC
Bifenthin / 10%EC & 2.5% ULV
acetamiprid / Golan SL / acetamiprid (systemic) / Golan 20SL
Cypermethrin / Cymethrin
cypermethrin + dimethoate / Cymetox Super 280 (cypermethrin 30
+ dimethoate 250)
Cydim 45EC (cypermethrin 15% + dimethoate 30%)
Cymethoate Super
Deltamethrin / Deltapaz 12.5%
dimethoate / Dimeking EC / Dimethoate
fenvalerate / Sanitox 20EC / Fenvalerate / Sumicidin
imidacloprid (systemic) / Confidor 200SC
Akape
imidacloprid / Consider Supa, Dimiprid 20SL / imidacloprid + beta-cyfluthrin / Vector 210 + beta-cyfluthrin 90 WP
imidacloprid + thiram / Insector TDS
indoxacarb +
acetamiprid / Viper 46EC
lambda-cyhalothrin / Sunhalothrin, Lambda Super, Lambdacot,
Striker, Lambda Master, Rainlambda / lambda-cyhalothrin: / Lambda Super 2.5EC, Kombat 2.5EC, Sunhalothrin 2.5EC, Kilsect 2.5EC, Icon 10CS, Zap 2.5,K-Optimal
lambda-cyhalothrin + thiamethoxam / Eforia 45EC
Malathion / EnviGold / Malathion / Envigold 70 SL for stored grain pests
mineral oil / EOS white mineral oil
neem seed artisanal extract / natural neem seed extract plus soap and water
Thiamethoxam / Do no not spray when plants in flower due to pollinator risk
Table 2. Proposed for Addition to List for Fall Armyworm Control in Ghana with this PERSUAP Amendment (March 2017)
Active ingredient/
Chemical proposed by ADVANCE II / Commercial Product Namesin Ghana
22. / Spinosad[Fermentation product of Saccharopolyspora spinose] / Success, Appat

The purpose of this amendment to the revised ADVANCE II PERSUAP (dated September 2016)is to seek approval to add spinosad to the list of approved pesticides. Spinosad is needed to help control an anticipated infestation of armyworm in Ghana during the upcoming wet season[3].

Several documents that detail steps (especially non-chemical measures) that can be taken to identify armyworm and to effectively combat this potential infestation are available. These resources are included in Annex I and include:

  • Pest Management Decision Guide, Fall Armyworm on Maize[4]
  • Proposed Fall Armyworm (FAW) emergency action plan for affected countries (Ghana)
  • How to Identify Fall Armyworm (two versions)[5]

For any pesticide not addressed in the submitted PERSUAP, a Negative Determination with

Conditions is recommended pursuant to §216.3 (b)(1)(i)(a - l). More specifically,§216.3 (b)(1)(v) requires that “If the project includes assistance for the procurement or use, or both of pesticides but the specific pesticides to be procured or used cannot be identified at the time the IEE is prepared, the procedures outlined in §216.3(b)(i) through (iv) will be followed when the specific pesticides are identified and before procurement or use is authorized”.

All issues related to pesticides, safer use of pesticides, and Integrated Pest Management have been fully and thoroughly discussed in the PERSUAP already submitted. Included in the said document is a full discussion of the 12 factors related to pesticides mandated by §216.3(b)(1)(i)(a - l). Only the new pest and pesticide issues, not already addressed in the original PERSUAP are discussed in this document. Table 3 below shows the progress made so far with implementation of the safer use actions outlined in the submitted PERSUAP.

Table 3: Progress with implementationof Safer Use Actions

Objective/Issues / Interventions required / Progress of implementation
  1. PESTICIDE RISK AWARENESS

A1.Reduce reliance on pesticides.
  • Local pest control options are limited.
  • Pesticides are costly and may not be used safely.
/
  • Follow GAPs recommendations
  • Use of IPM
  • Practice crop rotation
  • Select resistant varieties
/
  • In collaboration with private companies the project promoted 2 striga tolerant maize see varieties (Wang-data and Senzalsima).
  • All GAPs trainings include training on integrated pest management.

A2.Promote use of PPEs
  • Farmers do not fully appreciate the importance of PPEs
  • Farmers do not fully appreciate the potential hazards of using pesticides.
/
  • Continuous education of farmers on the importance of PPEs
  • Promote use of less hazardous agrochemicals
/
  • The number of farmers using PPEs is on the increase. Between 2015 and 2016 the increases were as follows:
-Gloves: 28% to 58%
-Overalls: 35% to 55%
-Boots: 74% to 85%
-Hat: 24% to 62%
-Goggles: 17% to 42%
-Nose mask: 16% to 51%
A3.Discourage re-use of pesticide containers
  • Containers are used to store household items including food.
  • Farmers are unaware of the dangers involved.
/
  • A sustained campaign to discourage re-use of containers.
  • Provide a central point for collecting and disposing containers.
/
  • The project has, in collaboration, with the EPA developed a radio jingle to educate farmers against re-using pesticide containers. The jingle which was aired on 8 radio stations in local languages, reached on 3million listeners. These radio jingles will be repeated this year.
  • Out of 262 communities where demos were located in the 2016 crop season, only one community reported evidence people re-using pesticide containers. In 2015 the number of communities with reported evidence of container re-use was 8.

A4.Discourage women and children from pesticide application
  • Limited farm labour compelling women to apply pesticides.
  • Inability of women to pay for SSP services.
/
  • Provide special training to women on the effects of pesticides on women and children.
/
  • The project has, in collaboration, with the EPA developed aradio jingle to educate women against pesticide applications. The message in the jingle particularly targets pregnant and lactating mothers. The jingle which was aired on 8 radio stations in local languages, reached on 3million listeners. These radio jingles will be repeated this year.

  1. PREVENT ENVIRONMENTAL POLLUTION & DAMAGE TO HUMAN HEALTH

B1.Promote safe disposal of pesticide containers
  • Empty pesticide containers are either left on farms or re-used for domestic purposes.
  • Some farmers are not aware of the proper methods of disposal.
/
  • Set up container collection centers with NFs where all containers used by out-growers will be collected.
  • Destroy and bury containers or return to manufacturers for re-use.
/
  • As part of our SSP programs trained persons are required to have large plastic bags for retrieving empty pesticide containers for safe disposal. A total of 9,802 containers were safely disposed of in the 2016 crop season by burning the containers in a pit and burying the ashes.
  • Out of 275 beneficiary farms monitored in the 2016 crop season, 244 (88.7%) of them had no pesticide containers disposed on their farms.

B2.Minimize ground and surface water contamination.
  • Pesticide use near water bodies.
  • Pesticide use on wet fields with flowing water.
  • Pesticide use immediately after rainfall.
/
  • Reduce soil disturbance through reduced tillage.
  • Leave a buffer of at least 5m to rivers and streams when spraying:
-Flat land: 5m
-Gentle slope: 10m
-Slope >30o: 15m /
  • The project has so far promoted minimum tillage practices by introducing farmers to ripping. In the 2016 crop season farmers were exposed to the benefits of ripping through 36 demo plots, 5 cover crop systems, 19 model farms and 43 outgrower farms.
  • Environmental Review Reports for 33 tractor grant recipients included mitigation actions for farms near rivers and streams to observe the recommended distances during land preparation and pesticide applications.

B3.Follow Spray Drift Management Protocols
  • Impacts to bee colonies
  • Impacts to surface water bodies and aquatic invertebrates
/
  • Do not spray in areas of blooming foliage or when bees are actively foraging
  • Do not apply to any perennial water body
/
  • [JM1]

B4.Minimize potential for using pesticides more than necessary.
  • Farmers may apply pesticides, especially for storage grain, without actually encountering the threat of a pest invasion leading sometimes to avoidable high cost of agrochemicals and over application of pesticides.
/
  • Promote GAPs and IPM to reduce over reliance on pesticides.
/
  • Together with GAPs and IPM trainings through field days, the project is also promoting patronage of SSPs who have been trained on proper knapsack calibration to minimize the potential to apply wrong doses of pesticides.

  1. ACTIONS TO ENSURE COMPLIANCE

C1.Conduct safe pesticide use training
  • Farmers and other persons who handle pesticides have inadequate knowledge of pesticide products and labels.
/
  • Develop training content targeting specific groups – farmers, women, dealers, partners etc.
/
  • All farmers who attend GAPS training are trained on safe pesticide use.
  • GAPs trainings are supported by radio jingles on safe pesticide use in local language

C2.Promote the services of SSPs
  • Farmers may do their own spraying because they have no access to trained spray service providers.
  • Farmers who do their own spraying often do not wear PPEs and may apply more chemical than needed.
/
  • Work with NFs and FBOs to include spray services in their extension support to out-growers.
  • Provide regular training to SSPs on environmental safety procedures.
/
  • One hundred and eighty (180) individuals have so far been trained and equipped to provide commercial spray services to farmers. In the 2016 crop season they provided services to 3,724 farmers (38% of them being women)

C3.Avoid the use of highly toxic products
  • Farmers do not appreciate the short and long term consequences of very toxic products on their health and the environment.
  • Some farmers simply do not know the toxic levels of the products they use and the need to avoid them.
/
  • Train farmers to read and understand the symbols and colours on pesticide labels.
  • Promote use of non-chemical pest control option
/
  • The project continues to use PERSUAP recommended chemicals as a guide for farmers. As part of pesticide use monitoring on demos, pesticide active ingredients used on demos were compared with those used by farmers who hosted demos to determine the extent to which farmers are adopting pesticide use practices on demos. Except for 2 active ingredients, farmers used the same active ingredients on their farms.

List of Annexes: Additional Resources for Combatting Armyworm Infestation

  • Annex 1. Ghana Fall Armyworm Pest Management Decision Guide (Dec. 2016), produced by Ghana MOFA PPRSD & CABI Plantwise (Dec. 2016/March 2017)
  • Annex 2. African Armyworm Pest Management Decision Guide (March 2016), by Ghana MOFA PPRSD & CABI Plantwise
  • Annex 3. Ghana Comprehensive Action Plan for Management of the Fall Armyworm (May 8, 2017)(source: CABI Plantwise)
  • Annex 4. Synoptic Proposed Fall Armyworm (FAW) Emergency Action Plan for Affected Countries (generic)(source: CABI Plantwise. Feb. 2017).
  • Annex 5: Matrix of Ghana FTF Agricultural Technology & Trade (ATT) Crops with Primary Production Constraints, PERSUAP-Recommended Pest Prevention GAP/IPM Tactics & PERSUAP-Recommended Curative Tools and Tactics (ATT PERSUAP 2014).
  • Annex 6. Guidelines for Pest Management Plans (PMPs) for Ghana Crops and Beneficiaries (from USAID Ghana ATT PERSUAP)
  • Annex 7. Elements of Integrated Pest Management (IPM) Program (USAID Ghana ATT PERSUAP)

Note: Also refer to Programmatic PERSUAP for Fall Armyworm Management in Africa. Version 1. May 2017. Approved 5/16/2017 (AFR, BFS & DCHA BEOs). Revised 5/22/2017. ECD Link:

APPROVAL OF THE RECOMMENDED ENVIRONMENTAL ACTION:

CLEARANCE:

USAID/Ghana Mission Director: cleared parent Amendm #1 Date: 8/25/16 Andy Karas

CONCURRENCE:

AFR Bureau Environmental Officer: ______Date: 5/25/2017 Brian D. Hirsch

Approved:

Disapproved:

Filename: GhanaADVANCE II PERSUAP Amendment 2 Fall Armyworm_FAW_(May2017)

ADDITIONAL CLEARANCES:

AOR/COR:______signed original amendment ______Date: 5 June 16

Pearl Ackah

Mission Environmental Officer: ______Date:

Justice Odoi

AFR/SD/ Regional Environmental Officer: ______n/a______Date: n/a

(Washington, D.C.)Walter Knausenberger

EG Office Director:signedoriginal amendment Date:7 July 2016

Kevin Sharp

CC:

ADVANCE II CoP, Technical Officers

B.PESTICIDE EVALUATION REPORT FOR SPINOSAD

1.USEPA and Ghana EPA registration status of proposed pesticide

Spinosad is registered in Ghana under the trade name Success Appat and distributed by Chemico Ghana Ltd based on the current Ghana EPA register of pesticides (December 2015). The USEPA registration status of Spinosad was also verified from the USEPA pesticides database for projects in Africa[6].Table 112 provides a summary of the registration status of spinosad.

Table 1: Registration status of proposed pesticide

Active Ingredient / Commercial
Product Name
in Ghana / USEPA Registration Status / USEPA Toxicity Class / Gh EPA
Registration
Status / Gh EPA
Toxicity
Class / Target Crops
Spinosad (0.24g/l) / Success Appat / GUP / III / GUP / U / Maize, Rice, Soya

2.Basis for selecting the recommended pesticide

Spinosad is a biologically rational pesticide with low toxicity to the environment and users. It will be used in alternation with other products such as lambda-cyhalothrin to reduce the potential for insect resistance in fall armyworm control.

3.Acute and long term toxicological hazards associated with the proposed use, and measures available to minimize hazards

The acute and chronic hazards associated with the use of spinosad are summarized in Table 2 based on the Africa Product List database mentioned above (this database in not definitive, and has not been updated since 2009).

Table 2: User and environmental hazards associated with the proposed pesticide

Active ingredient/
Chemical / Commercial
Product Names
in Ghana / Acute/Chronic Toxicity / Eco-toxicity / Groundwater Contamination Potential
Spinosad (0.24g/l) / Success Appat / May cause slight irritation to eyes / Slightly toxic to earthworms,
Moderately toxic to fish,
Highly toxic to bees. / Very low potential for ground water contamination

4.Extent to which the proposed pesticide use will be part of an IPM Program

Spinosad will be used to control fall armyworms in their early stages of development. ADVANCE will use pheromone traps to detect when armyworm moths begin egg laying. This will serve as an early worming system to farmers and a monitoring system for armyworms through the year. At the early stages of egg laying farmers will be advised to apply Spinosad. Farmers will be advised to alternate the use of spinosad with other products such as lambda-cyhalothrin [JM2]to prevent insect resistance. See