E916March 17 2004

The First Africa Stockpiles Programme - Project I (ASP-P1)

Environmental and Social Assessment

Synthesis Report

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March 17, 2004

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Table of Contents

I. INTRODUCTION

1. Background2. Objective of the study3. Methodology4. Organization of the Report

II. THE POLICY, LEGAL AND INSTITUTIONAL FRAMEWORK

1. International Framework for Hazardous Chemicals and Hazardous Waste

2. World Bank Safeguard Policies3. National Legal Frameworks of Participating Countries

4. Legal Frameworks of Countries Where Disposal May Occur

III. PROJECT DESIGN

1. Long-term Vision and Program2. The Proposed First Phase Project

a. Project Development Objectiveb. Project Beneficiaries and Project Area

c. Project Components

IV. BASELINE CONDTIONS IN BENEFICIARY COUNTRIES

1. Lifecycle of Pesticides in Africa2. Overview of Current Conditions in Beneficiary Countries

V. ENVIRONMENTAL AND SOCIAL IMPACTS OF ASP-P I

1. Overview2. Stage I Activities and Risks3. Stage 2 Activities and Risks4. Socio-Economic Impacts5. Cumulative Impacts6. Compliance with World Bank/IDA Safeguard Policies

7. Overall Program and Reputational Risks

VI. PARTICIPATORY APPROACH

I. Project Preparation Phase2. Project Implementation Phase

VII. ANALYSIS OF ALTERNATIVES

VIII. ENVIRONMENTAL MANAGEMENT PLAN (EMP)

I1. Overall Design of the Environmental Management Plan2. Key Components of the Environmental Management Plan

a. Inventory of Obsolete Pesticidesb. National/Institutional Capacity Assessmentc. Identification of Priority Sitesd. Emergency Response Plane. Publication Consultation and Awarenessf. Preventiong. Pesticide Removal and Site Remediation

3. Program and Reputational Risk

IX. MONITOR[NG AND EVALUATION

1. Assessing the Effectiveness of Mitigation Measures Under Stage I2. Triggers for Moving to Stage 23. Assessing the Effectiveness of Mitigation Measures Under Stage4. Conclusion

Preamble

This Synthesis Report is largely based on the study "The Africa Stockpiles Programme:

Framework Environmental Assessment (FEA) and Environmental and Social Management

Framework (ESMF)" (prepared by TerraChoice/Jacques Whitford under a World Bank contract,

and referred to throughout as the "Consultant Report"), and the participating country project

documents.

The Consultant Report is available for more detailed reference as an attachment to the

present Synthesis Report, and as part of the project documentation.

The Synthesis Report makes specific reference to specific sections of the ESMF, which is

the subject of part 2 of the Consultant Report. The ESMF will be reflected in each country's

project operational manual.

Abbreviations and Acronyms

ASP Africa Stockpiles ProgramESA Environmental and Social Assessment

EU European UnionASP-PI The First Africa Stockpiles ProjectEMP Environnemental Management Plan

POPs Persistent Organic PollutantsAMCEN African Ministerial Conference on the Environment

WWF World WildLife FundWHO World Health OrganisationUNIDO United Nations Industrial Development Organisation

INTARCLI Crop Life InternationalSBC Secretariat of the Basel ConventionNEPAD New Partnership for Africa's Development

GEF Global Environnent FacilityAU African UnionESMF Environmental and Social Management Framework

UNEP United Nations Environment Programme

CP-ESA Country Project Environmental and Social Assessment

PICPDO Project Development ObjectivePMU Project Management UnitNGOs Non Governmental OrganizationsCUTSUCCMEAIPM Integrated Pest ManagementMARPOLIMDGC International Maritime Dangerous Goods Code

I. INTRODUCTION

1. Background

1. The use of pesticides and other chemicals toxic to both human health and theenvironment, grew dramatically during the last 40 years in the African continent,. Due to poorpesticide management practices and the imposition of bans in the use of particular chemicals,virtually every African country has a stockpile of obsolete pesticides and in particular persistentorganic pollutants (POPs') and associated wastes, amounting to an estimated 50,000 tons2. Thisposes a serious threat to human health, local and global environment i.e. land and waterpollution, marine environment, habitats of wildlife.

2. Obsolete pesticide3 stockpiles exist in virtually all of the 53 Countries of Africa; they aregenerally a mixture of different pesticides, some of these are POPs, or mixtures including somePOPs, and fall under the new Stockholm Convention4 on POPs. These chemicals have long half-lives causing them to accumulate in the environment, and therefore causing potentially significantecological and human health risks. If the organo-pesticide mix is incinerated under less thanoptimal conditions, additional POPs may also be produced (dioxins, furans and HCBs). Most ofthe countries in Africa lack adequate technical, institutional and financial capacity to create thenecessary regulations and associated infrastructure including enforcement and the resourcesnecessary to properly manage the clean up of contaminated wastes/sites and destroy obsoletestocks of pesticides in an environmentally sound manner. They also suffer from weak importcontrols, inadequate storage and stock management, a lack of training and education onappropriate pesticide use, and there is widespread misuse of pesticides.

3. While the production, distribution and management of these potentially toxic chemicalsare currently highly regulated in developed countries; many developing countries lack theresources necessary to implement adequate management strategies resulting in the build up ofstockpiles of obsolete pesticides across Africa.

4. The existence of obsolete pesticide stockpiles, continuing stockpile accretion and lack ofremediation make the problems acute. Contributing to the problem is the fact that the removal ofold and obsolete chemicals (even toxic and dangerous ones) is not generally considered as adevelopment issue. Both recipient countries and donor agencies are often reluctant to divertfunds allocated to poverty alleviation, food security or other elements of sustainable developmentto this issue of environmental, social and economic risk reduction and waste disposal. A strategicprogrammatic approach for the African continent, building on activities and efforts from theinternational community as well as the provision of additional funds dedicated specifically topesticide / hazardous waste management and environmentally sound disposal, was agreed amongthe key stakeholders.

I POPs as addressed under the Stockholm Convention, and therefore, this project are: Aldrin, Dieldrin,Endrin, Chlordane, Heptachlor, DDT, Mirex, Hexachlorobenzene and Toxaphene.2 This rough estimate (illustrated in Annex 1) which does not include contaminated soils, will be refinedthrough country specific detailed inventories, which constitute key activities in the proposed project.3 The Africa Stockpiles Programme classifies pesticides as obsolete because they have been banned, havedeteriorated or are damaged, have passed their expiration date, cannot be used for another reason or are nolonger wanted by their owner.4 The Stockholm Convention on Persistent Organic Pollutants was adopted on May 22, 2001, inStockholm, Sweden.

5. The adoption by AMCEN (African Ministerial Conference on the Environment), July

2002, in Kampala, Uganda, and the 2001 Rabat Declaration on the environmentally sound

management of hazardous wastes, is the culmination of a long process in the region to solve the

obsolete pesticides stockpile problem. On the basis of a strong demand from African countries,

the Africa Stockpiles Program (ASP) was developed to prevent, clean-up and destroy obsolete

pesticide stockpiles from the region. The program has been conceived and designed by a

partnership of NGOs (World Wildlife Fund (WWF), Pesticides Action Network-UK (PAN-UK)

and PAN-Africa), UN specialized entities (UN-Economic Commission for Africa, FAO, UNEP,

UNIDO, WHO, UNITAR) and other international organizations including the African Union

(AU) and its member countries, the New Partnership for Africa's Development (NEPAD

Secretariat), the European Union (EU) the World Bank, SBC (Secretariat of the Basel

Convention), and the private sector, represented by CropLife International, as well as the Global

Environment Facility (GEF), which, as an interim financing mechanism for the Stockholm

Convention on POPs and has also contributed preparation funding along with other financial or

in-kind resources from bilateral donors .

2. Objective and Scope of the Environmental and Social Assessment

6. At the request of African countries, and in collaboration with all program partners, the

first proposed project ( Project 1) under the Africa Stockpiles Programme, ASP- PI, has been

designed to significantly and sustainably reduce the risk from publicly held stocks of obsolete

pesticides to human and environmental health in affected areas within six of the seven

beneficiary countries,.

7. Early in project conceptualization and development, an identification of the potential

effects of the project lead to the conclusion that despite its focus mitigating a major source of

environmental risk, the project itself is potentially a source of significant adverse impacts,

including on the reputation of the program partners. Therefore, the project was classified as

category "A", according to World Bank policies, resulting in the need for the preparation of a

comprehensive environmental and social assessment study, which was then was conducted by the

program partners, as part of the preparation of ASP- P1 The findings and recommendations of

this study are summarized in the present report.

8. The environment and social assessment study has two inter-related objectives:

i. The first objective is to identify a set of sound environmental and social principles to

guide the implementation of the project, based on a comprehensive analysis and review

of the potential environmental and socio-economic impacts associated with the Africa

Stockpiles Program in general, and ASPI in particular; and

ii. The second objectives is to prepare an Environmental Management Plan (EMP) in order

to (i) mitigate the potential negative impacts of project activities, as well as enhance the

positive impacts; and (ii) to guide the implementation of program activities at the country

level.

9. The implication of these objectives in terms of the structure and content EMP is that the

first part of the EMP contains "sector and program issues," and associated mitigation measures,

and the second part of the EMP is a "an environmental and social management framework,

(ESMF)" since the nature and extent of certain activities (e.g., disposal) will only be well defined

during project implementation, because they depend on the results of certain other key activities(e.g., detailed inventory of obsolete pesticides and prioritization of sites). 5

10. It is important to point out that while the environmental and social assessment seeks toprovide comprehensive analysis and guidance both at the program level and at the country projectlevel, its scope is-by design of ASP-PI--limited to obsolete pesticide stocks stored at wholesaleor retail locations (mostly publicly held), and therefore the environmental and social excludesobsolete pesticides stored at individual (end-user) sites. In addition, the environmental andsocial assessment does not extend to issues related to manufacturing and distribution prior topurchase, as well as the application ofpesticides.

11. Furthermore, since the World Bank will be the project implementing agency for GEF, aswell as the manager of the multi-donor project Trust Fund, the preparation of the environmentand social assessment study was guided by the requirements of the World Bank's environmentaland social safeguard policies (under the umbrella Operational Policy 4.01: EnvironmentalAssessment, 2001 and its various Annexes, as well as the international framework for regulatinghazardous chemicals and hazardous waste (including the requirement of ratification of theStockholm Convention by all participating countries), and the national environmental regulationsof the countries participating in the project.

3. Methodology

12. Data collection and consultations. The environmental and social assessment has beenprepared by a team of consultants (with extensive expertise and experience in the areas ofmanagement and remediation of toxic chemicals and pesticides), using a combination of literaturereview, desk research, country project documents, extensive consultations with ASP partners andother stakeholders, and from information collected during country site visits (see list of referencesat the end of this report). Although all participating countries were visited by pre-appraisalteams, the study consultants focused their field visits on Ethiopia and Mali because theyrepresented two ends of the spectrum of ASP implementation at the country level. In Ethiopia theprogram is relatively well advanced, with a completed inventory and capacity to implement theprogram already established. By contrast, Mali has yet to complete a full inventory and at thetime of the visit had only limited capacity "on the ground" for implementation of the programme.A particular feature of Mali is also the high level of contaminated (pesticide saturated) soils.

13. Analysis using a "process approach" and "activity-impact interaction matrices" toidentify, prioritize, and develop mitigation plans. The data collected from the processdescribed above were analyzed using a structured approach. This approach was based on thedevelopment of a simple life cycle analysis of pesticides within Africa (summarized in Figure 1,and with more details provided in the Consultant Report), and resulted in the identification offour main activities (and associated sub-activities) in the pesticides life cycle, relevant to ASP-PI:

i. Storage: includes conducting inventory, relocating/securing pesticides within storagefacility, repackaging6, secondary containment, and long-term management of storagefacility;

5 This distinction is also reflected in the structure of the background EA study, "The Africa StockpilesProgramme: Framework Environmental Assessment (FEA) and Environmental and Social ManagementFramework (ESMF)" (consultant report).6 Repackaging can occur during inventory (phase 1) or during preparation for disposal (phase 2).

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ii. Transportation: includes repackaging for transportation, loading/unloading trucks,

trucking to storage or disposal facility, and possible accidents;

iii. Disposal: includes disposal in non-African countries, long-term storage, disposal on the

African continent (through thermal neutralization, landfill, or chemical treatment); and

iv. Site Remediation: includes delineation, water testing, soil testing, and cleanup.

14. The potential risks associated with conducting these activities (and sub-activities), were

identified and prioritized through the use of "activity-impact interaction matrices," which provide

a simple but systematic way of assessing whether an activity has impacts in terms of sixteen

biophysical and socio-economic criteria:

i. Terrestrial environment, including soil, biodiversity, and habitat;

ii. Aquatic environment, including surface water quality, ground water quality, aquatic

habitat;iii. Atmospheric environment, including local air quality, and long range airborne

contaminants;iv. Human health, including worker health, local resident health, short and long term risks;

andv. Socio-economic environment, including health and safety, property and land rights,

employment and income revenues, agricultural productivity, level of education and

technical capacity, the role of traditional knowledge, access to cultural property and other

important resources.

15. Distinction between prevention and cleanup activities within the project

components. As part of "scoping" and delineation of activities to be included in the project, a

distinction is made between (i) pre-disposal and remediation activities-i.e., prevention activities-

-leading to the preparation of country specific clean-up plans (subsequently referred to as Stage 1

activities), and (ii) the development and implementation of country-specific clean up plans-i.e.,

cleanup activities--(subsequently referred to as Stage 2 activities). This distinction allows

mitigation measures for stage I activities to be included in the EMP, while mitigation measures

for stage 2 activities will be defined during project implementation, once inventories of obsolete

pesticides are completed and country specific EA are undertaken.

16. The EMP refers to the Environmental and Social Management Plan for ASP-P1, and

includes specific activities related to the preparation of country cleanup (disposal) plans, for

which country environmental and social assessments will be required. These country

environmental and social assessments will be referred to as "CP-ESAs" (where CP stands for

country program), and their environmental and social management plans will be referred to as

"CP-EMPs." As will be discussed in section VIII, the EMP includes a environmental and social

management framework (ESMF) which will guide the preparation of CP-EMPs.

4. Organization of the Report

17. The report is organized in nine section. Section I provides a brief description of project

background, as well as the objectives and methodology for the environmental and social

assessment. Section II reviews the policy and institutional framework under which the

environmental and social assessment has been prepared. Section III describes the project

development objective and components. Section IV summarizes baseline conditions across

participating countries. Section V presents the key environmental and social impacts associated

with the project. Section VI summarizes the participatory approach used in preparing the

environmental and social assessment. Section VII gives a brief overview of the analysis of

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alternatives considered. Section VIII presents the Environmental management plan, includingestimated cost and implementation arrangements. Finally, section IX presents the plan formonitoring the implementation of the EMP.

II. THE POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK

18. As a multi-stakeholder international initiative, ASP-P1 is designed to complement and

work within the existing framework of international conventions and national regulations that

addresses issues of chemical and hazardous waste management, as well as within the framework

of World Bank's policies and directives. Therefore, the environmental and social assessment for

ASP-P I has been prepared under the following policy, legal and administrative frameworks.

1. International Framework for Hazardous Chemicals and Hazardous Wastes

19. Several international conventions exist to regulate chemical and hazardous waste

management, disposal and transportation. Such conventions seek to ensure the environmentally

sound management of these issues, both through establishing international codes and criteria and

by requiring national governments to enact legislation enabling the implementation of these codes

and criteria at the country level. These conventions are explicitly acknowledged by ASP-P1, and

are addressed within the criteria for country eligibility for disposal or prevention projects.

Eligibility will take into account whether countries have signed or ratified agreements such as the

Stockholm, Basel, Bamako, and Rotterdam Conventions.

20. While the ratification of the Stockholm Convention is a requirement for participation in

the program, irrespective of type of activity and stage, in case transport is required (which will

only be known once preparatory activities are completed), then ratification of the Basel

Convention will also be a requirement. Moreover, participating countries will be encouraged to

ratify the Bamako and Rotterdam Conventions as part of strengthening their prevention programs.

21. Stockholm Convention. The Stockholm Convention on Persistent Organic Pollutants

was adopted on May 22, 2001, in Stockholm, Sweden. The aim of the convention is to protect

human health and the environment from the harmful effect of some of the world's most toxic,

volatile and persistent chemicals by calling for the outright destruction and banning of persistent

organic pollutants (POPs). As of May 06, 2003, 151 countries have signed the Convention, of

which 30 have ratified. Of the 12 chemicals slated for elimination in the Stockholm Convention,

9 are pesticides. The Convention requires that any stockpiles of wastes containing POPs be

managed in a safe and environmentally sound manner, taking into account international

regulations, guidelines and standards. Certain trade restrictions are also imposed under the

Convention.

22. The existence of the Stockholm Convention will affect decisions regarding disposal

choices by ASP, particularly in regard to issues of obsolete pesticide incineration and the

unintentional production of POP chemicals. The Convention prescribes that pesticide wastes

shall be "disposed of in a way that the persistent organic pollutant content is destroyed or

irreversibly transformed (...) or otherwise disposed of in an environmentally sound manner when

destruction or irreversible transformation does not represent the environmentally preferable

option (...). "7 The Convention goes on to state that the Conference of Parties will establish the

necessary levels of destruction or irreversible transformation and will determine what methods of

destruction are considered environmentally sound disposal under the Convention. The

formulation of such guidelines will presumably take place sometime in the future, but not

'Stockholm Convention on Persistent Organic Pollutants, Article 6, 1 d) ii.

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necessarily within the timeframe of ASP-PI. Therefore, careful monitoring and closecollaboration with the Convention Secretariat will be needed by ASP program partners.

23. Basel Convention. The Basel Convention on the Control of Transboundary Movementof Hazardous Wastes and their Disposal was adopted in Basel, Switzerland, on March 22, 1989,and entered into force in May 1992. The Basel Convention was put in place in order to end toxicdumping (or illegal waste trafficking), to set up a framework to control movement of hazardouswastes across national frontiers, and to ensure their environmentally sound management anddisposal. As of April 3, 2003, the Basel Convention is ratified by 156 countries, including 36 ofthe 53 African countries.

24. At a ministerial-level meeting held in Rabat, Morocco in January 2001, the problemsposed by stockpiles of obsolete chemical wastes were recognized. African countries resolved towork with members of civil society to rid the continent of obsolete stockpiles within one decade.The resulting Rabat Programme of Action aims to increase national capacities to: (i) preventfuture accumulation of unwanted pesticides; (ii) dispose of existing stockpiles in anenvironmentally sound manner; (iii) develop partnerships with stakeholders to addressenvironmentally sound management practices for dealing with unwanted stocks of chemicals;and, (iv) strengthen existing, and pursue alternative, financial and logistical approaches to preventthe buildup and dispose of unwanted stocks of pesticides, PCBs and used oils.

25. The implementation of the ASP-P1 objectives, notably the disposal of obsoletepesticides, remediation of current stockpile sites, and the environmentally sound management ofpesticides stocks, as well as the provision of funds to enable these activities, will provide practicaland tangible support for the objectives of the Basel Convention and Rabat Programme ofAction.

26. Rotterdam Convention. The Rotterdam Convention on the Prior Informed ConsentProcedures for Certain Hazardous Chemicals and Pesticides in the International Trade (PIC)was adopted September 10, 1998. As of April 25, 2003, there were 42 parties to the Convention,and 73 signatories. The Rotterdam Convention builds on the pre-existing Prior Informed ConsentProcedure administered by UNEP and FAO since 1989, by creating a legally binding obligation.The aims of the convention are to: (i) promote shared responsibilities and co-operative effortsbetween the parties in the trade of certain hazardous chemicals in order to protect human healthand the environment from potential harm; and (ii) to contribute to environmentally sound usethrough the exchange of information.

27. The Conventions requires that exporters of chemicals covered by the convention obtainthe prior informed consent of the importer for any export to occur. The Convention establishes ameans by which the decisions of importing countries regarding the future imports of specificchemicals can be disseminated to exporting countries, and that these decisions can be enforced.The Convention also contains provisions to ensure that information regarding the potentiallyhazardous chemicals be made available to the importer and exporter. The chemicals initiallyspecified in the Convention include 22 pesticides and five commercial chemicals, however thenumber of chemicals is expected to increase. ASP-PI will work within the framework of theRotterdam Convention and will use the PIC procedures in the implementation of its ownobjectives.

28. Bamako Convention. The Bamako Convention on the Ban of the Import into Africa andthe Control of Transboundary Movement and Management of Hazardous Wastes within Africawas adopted in Bamako, Mali, on January 30, 1991, and entered into force on April 22, 1998. Itis open to member States of the African Union.

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29. The convention aims to: (i) protect human health and the environment from the harmful

effects of hazardous chemicals by reducing their production or reducing their hazard potential;

(ii) adopt precautionary measures to ensure proper disposal of hazardous wastes; and (iii) prevent

'dumping' of hazardous wastes in Africa. The objective of the Bamako Convention is to create a

framework of obligations to strictly regulate the transboundary movement of hazardous wastes to

and within Africa. ASP-PI will have to work within this framework if the movement of

stockpiled pesticides across country boundaries is necessary for the disposal of obsolete pesticide

stockpiles.

Country Ratification of theReleyant Conventions(a f M arch 84,2004)

Convention Mali Tunisia Tanzania Morocco Ethiopia South Nigeria

___ ___ ___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ A fric a _ _ _ _ _

Stockholm x x x -8 x x x

Basel x x x x x x x

Rotterdam x x x x x x

Bamako x x x x

x = ratified; - = not ratified; ? = to be determined

2. World Bank Safeguard Policies

30. Since ASP-P1 will be executed through the World Bank, in collaboration with the ASP

program partners, the project needs to meet the requirement of the World Bank Group Safeguard

policies. These environmental and social safeguard policies are a cornerstone of the Bank's

support to sustainable development and poverty reduction. They have been developed to ensure

that Bank-financed projects (including as an executing agency for GEF ) both prevent and do no

harm to people and the environment. Moreover, in addition to ensuring that projects are

environmentally sound, these policies often provided a platform for the participation of

stakeholders in project design, and have been an important instrument for building ownership

among local populations and project proponents.

31. There are 10+1 safeguard policies, including the Bank's umbrella policy on

environmental assessment (OP 4.01 and its Annexes) which guides the entire process and the

scope and depth of environmental and social assessment required as part of project appraisal. The

other safeguard policies are: Involuntary Resettlement (OP 4.12); Cultural Property (OP 4.11);

Indigenous Peoples (OD 4.20); Pest Management (OP 4.09); Forests (OP 4.36); Natural Habitats

(OP 4.04); Safety of Dams (OP 4.37); Projects in Intemational Waters (OP 7.50); and Projects in

Disputed Areas (OP 7.60). The eleventh policy (in the group of 10+1) is the Bank Disclosure

Policy (OP 17.50). In addition, all environmental and social assessment documents that are

prepared as part of Bank supported project are subject to a consultation and disclosure process

which need to be carefully documented.

3. National Frameworks of Participating Countries

8 The ratification process of the Stockholm Convention by Morocco has been initiated and is anticipated

shortly.

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32. The implementation of ASP-PI through country projects will also be subject to the legaland institutional framework of each participating country, including review, disclosure, andapproval by the appropriate authorities. Although all ASP-PI countries have some form ofEnvironmental Assessment regulation, the existing legal and administrative structure will differgreatly from country to country, as will the government agencies' responsibilities, particularly inrelation to the management of pesticides and other chemicals. Identifying the adequacy of thisframework (including reference to the international conventions referred to above) will thereforebe a key preliminary task for implementation of ASP-PI at country level.

4. Legal Frameworks of Countries Where Disposal May Occur

33. In case where the selected disposal option (s) involve off-continent disposal or any othercountry that is not a program participating country, the legal framework in the receiving country(or countries) will be reviewed and adhered to. This is particularly relevant in case final disposalis to be undertaken in a European Union (EU) member country, in which case, for example, theEU's ban on import of soil will have to be strictly adhered to, and therefore may influence thefinal selection of disposal option (s).

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III. PROJECT DESIGN

1. ASP Vision and Long-Tem Program

34. The African Stockpiles Programme grew out of a vision by African countries and their

development partners to rid the continent of an estimated 50,000 metric tons of stockpiles of

obsolete and highly toxic pesticides, and to ensure that policy and institutional frameworks are

put in place so that the problem does not reoccur. Putting such a vision into practices has taken

about 3 years of preparatory work, focused on stakeholder and resource mobilization, partnership

building, and preparatory technical work, resulting in the design of an inclusive and ambitious

program that would take some 15 years and significant financial resources to implement.

35. But given the magnitude of the problem, the availability of resources, and the state of

preparedness of different countries, it will not be possible to work in all the countries of Africa at

the same time. Therefore, the program partners have agreed to a phased implementation. Out of

the seven countries participating in the first project, Nigeria has been selected as a test case for

the development of a program template for effective prevention of accumulation of obsolete

pesticides 9.

2. The Proposed First Phase Project: ASP-P1

a. Project development objective (PDO) and project design

36. The project will support the strategic objective of reducing or eliminating, through clean

up and prevention, the risks from stocks of obsolete pesticides to human and environmental

health in participating countries affected areas. Furthermore, the project will contribute regional

and global benefits through the implementation of the Stockholm Convention on POPs.

37. ASP-P1 will implement various clean up and site remediation measures to mitigate the

impacts of the publicly held pesticide stocks on people and the environment, including global

environment. At the same time, ASP-P1 will strengthen the regulatory and institutional

framework, management practices (including promotion of integrated pest management), and

public awareness to prevent an increase of pesticide risks in the future. Achievement of the PDO

will be monitored through a set of indicators related to risk reduction (pesticides removed and

sites cleanup, as well as improved human and environmental health conditions), capacity building

(institutional capacity for pesticide effective management vastly improved), and quality of

technical assistance and technology transfer to participating countries.

The project design is based on a recognition that the existing level of information on the

extend, geographic distribution and characteristics of the obsolete pesticide stockpiles is

insufficient for planning and implementing pesticide disposal and site remediation measures.

The design, therefore, reflects the need to carry out, in all project countries, extensive

preparatory and prevention activities, including detailed pesticide inventories, selection of

disposal technologies and preparation of country-specific environmental and social

assessments (stage 1 activities). Only following the adequate completion of these activities,

the clean up and disposal will take place (stage 2 activities).

9 The choice of Nigeria is based in part by the interest expressed by the country to deal with the problems

and the interest of government of Canada to provide support through the ASP.

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b. Project beneficiaries and project area

38. ASP-PI is designed to eliminate or reduce a major source of risk to human health andenvironmental resources. Therefore, the benefit flows from the project are mostly in terms of riskreduction, quality of life improvement, and capacity building. While some of these benefits willaccrue directly to a large number of communities (once detailed inventories, site assessments, andbaseline socio-economic surveys are undertaken as part of project implementation), other benefitswill accrue at regional level, in terms of improved management capacity, lower social costs dueto ill health, and higher productivity of environmental resources.

39. Project area. Designed as a first phase of a longer term program, the project will pilotthe ASP approach in 7 countries, including: Ethiopia, Mali, Morocco, Nigeria, South Africa,Tanzania and Tunisia. The project will target areas-and surrounding communities-- wherepesticides stocks are stored, mostly at wholesale or retail location, and in government warehousesand distribution centers.

c. Project components

40. The project includes four components:

41. Component 1: Country Obsolete Pesticides Operations (estimated cost $44.13 million).This is the main component of the project, which includes all clean up and prevention activitiestoward achieving the project objectives in the participating countries. The majority of theservices provided by the remaining three components will support this components whichinclude four types of activities:

(i) Clean up and disposal activities will be based on a detailed inventory of pesticide stockpilesand contaminated sites, determining the identity of the contaminant, its quantity, proximityto people. Country project management units (PMU) will carry out the inventoryimmediately after the project launch. The inventory will allow determining the priority ofcontaminated sites based on the risk to people and environment they represent. Inventorieswill also feed new data into the design of the clean up and remediation operations forindividual contaminated sites. Once the inventory is complete, a plan for clean up andremediation will be developed by the PMU. This plan will be subject to a detailedEnvironmental and Social Assessment (ESA). The clean up and remediation will includevarious interventions including removal of pesticides from their storage point, transport tointerim storage facility, decontamination of the site, decontamination or disposal of emptycontainers, repackaging of pesticides and pesticide disposal. Where possible, the disposalwill employ in situ approach and involve reuse, recycling or reformulation; otherwise itwill employ internationally recognized destruction technologies, including shippingoverseas for incineration in specialized facilities'". In exceptional cases, the disposaloperations will include contaminated soils. Where health risks from soils are extremelyhigh, (e.g. in Mali where the large spill of POPs and other pesticide threatens importantdrinking water sources in the Sahara, the contaminated soils will be treated as pesticidesand destroyed using appropriate soil disposal technologies.

'0 This is not to be interpreted as giving priority ex ante to in-situ re-use, recycling or reformulation(including re-use and recycling of storage drums, containers, etc). If viable, these kind of activities canonly be done under strictly controlled conditions once the exact composition and quality of the pesticideshave been defined.

(ii) Prevention of pesticide accumulation activities include strengthening of pesticide

management through improvement of pesticide registration, licensing, enforcement of

import controls, stock management, waste management, and formulation of effective

procurement strategies; and promotion of alternatives to chemical pesticides through

improvement of pest control strategies with particular attention to Integrated Pest

Management for agriculture and Integrated Vector Management for health care. Prevention

activities will also include development of emergency response plans, awareness and

training for pesticide distributors, users and others to encourage safe pesticide handling and

alternative pest control.(iii) Capacity building activities will include enhancement of laboratory capacity for reliable

analysis, health and safety training, epidemiological and pollution studies, environmental

monitoring as well as provision of equipment, vehicles and staff training for effective

pesticide management.

(iv) Project management and monitoring. The country program management activities will

include establishment of a Coordination Unit (CU) in each country with the responsibility

to implement the country level activities, solicit external technical support, monitor and

evaluate project activities, and coordinate their implementation with the GEF funded

National Implementation Plans for the Stockholm Convention (NIPs) and similar

initiatives. Country level management will also include establishment of a national steering

committee that will represent key stakeholders and oversee the work of the CU.

42. Component 2: Technical Support (estimated cost $3.28 million) . This component will

finance technical and specialized expertise required for preparation (including ESA), design,

implementation, supervision and monitoring of country level activities outlined under Component

1. The key technical support services that the component will provide will include technical

advice requested by the CUs for preparing and implementing country projects, design and

delivery of training, production of technical guidelines for clean up and prevention operations,

assistance in managing technical aspects of procurement and supervision of specialized

contractors, advice on linking countries with other specialized agencies and organizations,

enhancement of health and safety, assessment of laboratory capacities and oversight of

monitoring and evaluation. FAO will host a Technical Support Unit (TSU) to manage delivery of

technical services envisaged under this component and tap into expertise of other ASP partners,

e.g., UNIDO, UNEP, WHO, Basel Convention Regional Centers, NGOs and CLI.

43. Component 3: Cross-Cutting Activities (estimated cost $3.64 million). This component

will finance knowledge management and outreach services across the entire Africa Stockpiles

Programme to capture synergies and cost savings from tackling the problem of obsolete

pesticides through a coordinated multi-country, multi-partner. The key component activities will

include outreach to promote ratification of the Stockholm convention, raising funds from private

and bilateral donors, building NGO capacity, hosting the ASP website, knowledge management

and communication. Importantly, the component will include preparation of strategic studies on

topics common to the entire ASP, e.g., preferred disposal technologies, IPM for locust control

and prevention of pesticide smuggling. WWF International will host a Cross-Cutting Activities

Management Entity (CCMEA) responsible for delivery of support services under this component.

The CCMEA will mobilize the WWF in-house capacity, engage other ASP partners, procure

consultants and award competitive grants to maximize the efficiency of service delivery.

44. Component 4: Project Coordination (estimated $1.41 million). This component will

finance: a small unit that will consolidate work programs, budgets, financial and project reports;

12

and serve as a secretariat to the ASP Steering Committee. The World Bank will host the ASPCoordination Unit (ASP-CU) under ASP-P 1.

13

IV. BASELINE CONDITIONS IN AFRICA

1. Lifecycle of Pesticides in Africa

45. Virtually every African country is currently home to obsolete pesticide stockpiles, as well

as to tens of thousands of tonnes of contaminated soils. The World Bank estimates that 20% of

obsolete pesticides in Africa are POP chemicals, and another 30% are an inseparable mixture of

POPs and non-POPs chemicals." The ongoing deterioration of pesticide containers and lack of

necessary management of the current storage sites continue to increase the risk of greater

contamination of soil, air and water, leading to major risks to human health.

46. The lack of comprehensive management strategies over the past 40 years, combined with

a number of key factors, including government policy, contributes to the ongoing accumulation of

pesticides. These factors include: (i) product bans: banned pesticides that remain unused over

time; (ii) inadequate storage and stock management: pesticides have a limited shelf life which is

shortened if they are not stored properly, etc.; (iii) unsuitable products or packaging: poor

product specifications, unavailability of required application equipment, labels in foreign

languages, etc.; (iv) donation or purchase in excess of need: excess products often deteriorate

during storage; (v) lack of co-ordination among donor agencies: duplicated, unsolicited or

excessive donations; (vi) commercial/entrepreneurial interest: over-assessment of need,

inappropriate product supply, corruption; and (vi) government policy: central procurement, heavy

subsidies, procurement for special programs like locust control, and lack of record keeping,

follow up, especially post deregulation of the sector.

47. Obsolete pesticide stores can be found in numerous locations, and as a result of

accumulation at various steps in pesticide distribution and use, as illustrated in the lifecycle

diagram in Figure 1. Pesticides are often imported into Africa, although some may be

manufactured on continent. Following their manufacture and/or import into Africa, the pesticides

are transported to wholesale storage and distribution sites. The pesticides are then sold and

distributed to major users, retail stores and individual users. Major users, such as government

agencies, major industries, or industrial farms, may then either store or apply the pesticides.

Smaller retail stores will resell pesticides in smaller quantities to individual users, or store them

for sale at a later date. Individual user may immediately apply the pesticides, or store them for

later use. The potential exists at each of these sites (wholesale distributor site, major user, retail

store and individual user) for pesticide obsolescence to occur.

48. Pesticides that are not sold prior to their expiration date become obsolete, and may be

found within wholesale sites and in smaller stores. Pesticides that were purchased either by major

users or by individual users and were not used may also become obsolete. The sources of

obsolete pesticides are indicated on Figure I in red and yellow. Although individual users may

own and store obsolete pesticides which may pose grave health risks, these sources are outside

the scope of the project and the environmental and social assessment.

Africa Stockpiles Programme, 2002. Programme Overview. June 2002 (www.africastockpiles.org).

14

Figure 1. Pesticide Life-cycle

Issues covered by ASP- Material ExtractionPl's Environmental andSocial Assessment

Sources of ObsoletePesticides Included inscope of ASP-P1 ManufactureSources of ObsoletePesticides not coveredby the Environmental Taptiand Social Assessment TransportationStudy

Reformulation

.Persistence in theEnvironment

15

2. Overview of Current Country Conditions

49. Although the conditions of pesticide stores vary from country to country, the overall

condition of current stores (confirmed by sites visits in several countries) present serious human

health and environmental risks. Although some countries have begun inventory, clean-up and

disposal activities, many African pesticide stores have yet to be inventoried, let alone stabilized

and subjected to remediation.

50. In many cases, pesticide containers have deteriorated and pesticides are able to escape

into the surrounding environment. One recent country report stated that "containers have

deteriorated, corroded and started leaking, while bags have perished, spilling their contents on

floors or directly on the soil"12 . The stores themselves are often in poor condition and do not

comply with FAO guidelines on pesticide storage13.

51. Storage sites may lack proper ventilation and pose serious health risks due to their

proximity to houses and workplaces, their location on flood plains or near areas with high water

tables. The risks posed by such stores include the risk of fire, and of contamination of local

drinking water from infiltration through contaminated soils.

52. One of the greatest challenges facing ASP programme and project planners is the

uncertainty surrounding the quantity and location of obsolete pesticide stores currently in Africa.

Although several countries have completed initial and/or detailed inventories, many others have

yet to gain a clear idea of the quantities, nature, locations and conditions of pesticide stores within

their boundaries.

53. Furthermore, the experience of countries who have already completed detailed

inventories has shown that estimated numbers are generally lower than those found upon detailed

investigation. The amount of obsolete pesticides stocks within Ethiopia was initially estimated to

be approximately 1500 tonnes of obsolete pesticides with 500 tonnes of contaminated soils at 400

sites"4. After a subsequent detailed inventory, the numbers were revised to 2900 tonnes of

obsolete pesticides, 1000 tonnes of contaminated soils in 900 sites. The investigation further

revealed that 400 tonnes of the stock was still useable, and was re-channeled for later use.

Similarly, other countries have revised estimates upward after beginning inventory activities.

54. Much of the difficulty in estimating the total quantity of obsolete pesticides (and the

associated heavily contaminated soils and packaging) can be attributed to decades of varying

degrees of record keeping and documentation of pesticide imports and stockpiling, as well as

little to no detailed inventory assessment. Efforts to gain a detailed understanding of the nature

and distribution of obsolete pesticide stores may be hampered by a number of factors, including:

damaged, worn containers and leaked pesticides; missing or worn off labels; existence or location

of small storage sites not recorded; remote location of some storage sites; and, no inventories at

storage sites.

"2 The United Republic of Tanzania, Obsolete Stockpile Programme, Obsolete Waste Disposal Project

country report, February, 2003, p.7.13 The Federal Democratic Republic of Ethiopia, Africa Stockpiles Programme, Obsolete Pesticides Project,

Second Phase Country Report, February 2003, P.7.14 The Federal Democratic Republic of Ethiopia, Africa Stockpiles Programme, Obsolete Pesticides Project,

Second Phase Country Report, February 2003, P. 9.

16

55. An additional difficulty in estimating the quantity of obsolete pesticides in Africa is thepotential for fluctuations in the amount of obsolete pesticides within individual storage sites asuseable pesticides pass their expiration dates and become obsolete. Where no inventories have yetbeen undertaken there is an urgent need to begin detailed inventories to help verify the status ofthe stock and the need for clean up and disposal. Such data is essential to programme and projectplanners to ensure that the sites that pose the greatest environmental and human health risks arestabilized and cleaned up.

56. Table I below summarizes the status of information on amount of obsolete pesticide andstorage sites for countries participating in ASP-Pl.

Table 1. Summary of Available Data and Project Activities in ASP-PI Project Countries

Country Number of Amount of Amount of Project Projectstorage sites pesticide contaminated P&P C&D

(tons) soils (tons) Activities ActivitiesEthiopia 900 2,500 1,000 Yes YesMali 76 500 40,000 Yes YesMorocco 225 700 500 Yes YesNigeria N/A 50 (incomplete) N/A Yes NoS. Africa Na 250 N/A Yes YesTanzania 350 1,200 1,300 Yes YesTunisia 17 452 & 16,600 N/A Yes Yes

Liters

P & P = Preparation and PreventionC &D = Pesticide Clean-up and Disposal

17

V. ENVIRONMETAL AND SOCIAL IMPACTS

1. Overview

57. The stockpile of obsolete pesticides in the seven countries participating in ASP-P1`5 is

recognized as having potential to generate wide ranging environmental, human health and socio-

economic impacts. In the broadest sense these impacts are associated with the high degree of

toxicity of the substances involved, their recognized persistence within the environment and the

degree of control exercised over their storage. While circumstances vary from country to

country, currently many obsolete pesticides are stored in inappropriate facilities that are widely

distributed, generally located within or adjacent to human settlements and by extension therefore,

close to drinking water supplies.

58. Clearly, the assessment, removal and disposal of obsolete pesticides and the remediation

of storage sites in ASP-P1 countries will have considerable positive environmental and social

impacts in these countries and globally. However, inherent in this process (that is in the proposed

ASP-PI project), are unique environmental and social risks, which are identified and described in

details in this section, and which form the basis for the Environmental Management Plan (EMP)

presented in section VIII.

59. In the short term, the activities associated with the removal and transport of pesticides

may be expected to increase the risk of uncontrolled releases into the environment, while the

introduction of technologies to dispose of obsolete pesticides and for the remediation of

contaminated storage sites will, in themselves, introduce a new spectrum of potential impacts.

60. The potential environmental and social impacts associated with ASP-P1 can arise from

the following sources:

> Release of pesticides from project activities involving storage, handling and

transportation;> Non-pesticide related project activities, including impacts arising from the construction/

rehabilitation of buildings and facilities, other infrastructure, and institutional capacity

building;> Construction and operation of pesticide disposal facilities;

> Potential effects associated with the clean-up and remediation of contaminated sites;

> Socio-economic impacts on local communities; and,

) Cumulative environnemental impacts.

61. As described in the methodology section (Section 1-3), the analysis and review of the

potential environmental and socio impacts of ASP-P1 leads to the distinction between two types

of risks associated mostly with the implementation of the component I of the project:

i. Risks associated with country specific "preparatory to clean-up activities" (Stage 1

activities); andii. Risks associated with the development and implementation of country specific clean-up

plans (Stage 2 activities).

5 "ASP-P 1 countries" will be used throughout to refer to the seven countries supported through ASP-P1.

18

62. It is important to note that the nature and scope of risks associated with Stage I activitiesis qualitatively and quantitatively different from those raised at Stage 2. In particular, Stage Irisks relate to preparatory activities that will have limited adverse environmental and socio-economic impacts, or where mitigation measures can be developed based on generically availableinformation (e.g., conducting inventories using FAO standards). By contrast, risks associatedwith Stage 2 activities are potentially greater and will require country specific clean-up plandetails in order for mitigation measures to be developed. While a more detailed description ofthe nature and scope of each stage's risks is presented in subsequent section, the interrelationshipbetween the key activities is shown in Figure 2, and the main potential environmental socialimpacts and risks associated with project activities are summarized in Table 2.

Figure 2. Project Activity Sequence and Stage

NationalConduct institutional Prevention

Inventory and Legal PublicAssessment Consultations

Pro Emergency 4

F Draft Stage 2 Plan (Country Plan)

Environmental andSocial Assessment

Public Consultations

Staae I ActivitvPesticideRemoval and Site Prevention Action Stae 2 ActiviRemediation tivit7v71

19

Table 2. Summary of Key Impacts

Stage 1 Activities Project Key environmental and social impacts

(all ASP-Pl coiftries) Component

a) Inventory and I (i) Increased risk of exposure to workers and local

emergency repackaging communityIncreased risk of contamination of environment,especially land and surface/ground waterDisturbance of local communities through inventory

process

b) National legal and I (iii), 2, 3 Potential positive benefits in terms of education and

institutional capacity capacity building

buildingc) Identification of priority I (i) No direct impacts - however will influence the

sites effectiveness of Stage 2 activities through

d) Development of I (ii), 2,3 No direct impacts - however will influence the

emergency response plans effectiveness of Stage 2 activities

e) Public consultation and I (ii), 2,3 Potential positive benefits in terms of avoiding

education exposure and prevention of build up of additional

stocks of obsolete pesticides

f) Development of I (ii), 2,3 Potential positive benefits in terms of prevention of

prevention plans build up of additional stocks of obsolete pesticide

stocks

g) Development of draft 1 (i) No direct impacts - however key step in ensuring

country specific country specific issues are addressed (including

implementation plans choice of disposal method(s), infrastructurerequirements and extent of site remediation required)

h) ESA of draft country 1(i) No direct impacts - provides for development of

specific plans mitigation measures

Stage 2 Activities Project Key environmental and social impacts

(all ASP-Pi countries Component

except Nigeria)a) Review and 1 (i) Highest risk of contamination of environment,

implementation country especially land and surface/ground water from

specific clean up movements of obsolete stocks

b) Prevention plans Disposal of hazardous wastes (both obsoletepesticides and contaminated materials or soils),

potentially including international waste transfers and

shipmentsPotential for disruption of communities and socio-

economic issues associated with project activities

Potential environmental and socio-economic impacts

from construction of in country facilities andinfrastructure

2. Stage 1 Activities and Risks

63. The principal source of direct environmental and socio-economic impacts during conduct

of Stage I activities is related to: (i) planning and conducting a country inventory, and (ii) any

20

emergency repackaging arising from poor/dangerous storage conditions discovered during theinventory phase and requiring immediate attention.

64. The types of hazards involved are site specific and include pesticide exposure to both theworkforce and the surrounding inhabitants and their environment from airborne exposure (dustsetc), contamination of water sources, and accidental ingestion. In addition, the impact oncommunities may include temporary restrictions on access during the inventory process, andcommunity fears and concerns over the nature of the process being undertaken.

65. While the above issues are significant (including the potential loss of human life, in aworst case scenario) the current--internationally established and used--controls and processes aresufficiently developed to manage and mitigate these risks to an acceptable level. Thesemitigation measures, involving the use FAO Worker Training and Equipment Guidelinessupervised by international experts, are outlined in Section I of the ESMF.16

66. Other activities that will be undertaken as part of this Stage 1 (planning and programbuilding stage) are: (i) identification of priority sites; (ii) national institutional/legal capacityassessment; (iii) development of an emergency response plan; (iv) public consultation andeducation; and (v) prevention planning (including activities such as IPM plans). These activities,which are essential for the development and assessment of country specific plans, will have lowor negligible environmental and socio-economic impact.

3. Stage 2 Activities and Risks

67. Stage 2 activities and risks are by comparison to those covered under Stage 1 greater bothin magnitude and scope, and require in depth country and site specific information and analysisfor their adequate assessment and for development of mitigation measures. They include thephysical clean-up of obsolete pesticide stocks and the development and implementation ofprevention programs that fall outside the scope of those delineated as Stage I activities. Inaddition, Stage 2 prevention programs would include development and implementation of countryspecific programs for reduction in reliance of pesticides, involving for example, introduction ofbiological controls.

68. Stage 2 activities may include the building and operation of physical storage andtreatment/disposal facilities; bulk transport of obsolete pesticide stocks; and assessment andclean-up (to an extent limited by the scope of the Africa Stockpiles Programme) of contaminatedsoils and groundwater.

69. The biophysical and socio-economic risks associated with such activities are highlysignificant and program activities related to this stage should not be undertaken without the priorcompletion of a country level environmental assessment. Therefore, the preparation of a countryspecific ESA'7

4. Socio-Economic Impacts

16 The ESMF is described in details in Part 2 of the Consultant Report.'7 Given the nature and scope of risks involved, country ESAs will need to meet the requirements of WorldBank's category "A" projects, and will include a resettlement Policy Framework to deal with potentialsocial impacts.

21

70. Human health and the well-being of communities, socially and economically, are of

special concern in the development and implementation of ASP-PI. Many of the burdens of

obsolete pesticide stocks are bome disproportionately by poorer communities. A number of

factors influence this. Many obsolete stockpiles are located within poorer communities,

increasing the risk of exposure on a day to day basis. This exposure can arise through a number

of pathways. Direct exposure can arise through simple proximity to the store or through the

scavenging of materials (such as containers) to be reused for other purposes. The dangers

associated with such scavenging are exacerbated by the low levels of literacy amongst the poor,

who are often unable to read warning labels or to follow printed instructions. Indirectly, human

populations may also be effected by contamination of water sources or of agricultural land arising

from run off from unprotected stockpiles.

71. A key objective of ASP-PI is the alleviation of such burdens and the protection of

communities from the reoccurrence of the problems created through effective prevention

measures, including public education and outreach. In doing so, however, it is also important to

ensure that that additional socio-economic burdens are not created or imposed through the

development and implementation of the project activities themselves.

72. To a certain degree, socio-economic impacts may be generated by almost any project

activity, however, their potential incidence of occurrence and severity is greatest during the

conduct of inventories and associated emergency repackaging and during Stage 2 activities of

clean up and prevention. In the case of Stage I activities (inventory and repackaging) socio-

economic impacts are likely to be restricted in nature to those associated with human health

(through increased risk of exposure), potential temporary restriction of access and community

fears and concerns over the nature and reason for the process being undertaken. These may be

significant issues at the local level and the inventory process should be conducted in a manner

that is sensitive to these factors. Section I of the ESMF sets out mitigation measures to be

followed in this respect.

73. Stage 2 activities, by contrast, have the potential for more wide reaching impact. The

precise nature of these impacts will vary on a case by case basis, however, it can be anticipated

that Stage 2 activities may create potential concerns over such issues as:

> Human health;> Property rights and divisions, including under exceptional cases, resettlement;

> Land values;> Agricultural quality of land and associated yields and production;

> Economic opportunities, including employment and other sources of income;

> Education and skills/technology transfer;> Accessibility to important resources;> Cultural heritage and its links to a specific geographical location; and

> Traditional knowledge, as embedded in the members of the community.

74. Examples of Stage 2 activities that may create such concerns include:

0 Construction and/or operation of physical infrastructure required to implement the project

at the country level such as transport infrastructure, storage facilities; treatment and

disposal facilities;> Where carried out under the scope of the project, the remediation of contaminated soils

and waters; and> The development and implementation of country specific pest management strategies.

22

75. The above activities may have both positive and negative socio-economic consequences,for example the construction of a new storage facility may have adverse implications for propertyrights and land values for specific individuals while creating new economic opportunities for thewider community.

76. Because of the widespread and high potential for such impacts arising from Stage 2activities, these will form an important component of the country level ESA required prior to thecommencement of this stage. Given the nature and scope of risks involved, country EASs need tomeet the requirements of World Bank's category "A" projects, and will include a resettlementPolicy Framework to deal with the potential social impacts described above. Further guidance onthis matter is provides in Section 7 of the ESMF and Annex B of the Consultant Report.

5. Cumulative Impacts

77. Potential cumulative environmental or social impacts of ASP-P1 are those impacts thatwill continue beyond the project, and which are essentially linked: (i) on the negative side, to thetype of obsolete pesticide disposal option selected at the country level,'8 and (ii) on the positiveside, to the institutional capacity building developed by the project.

78. Potential negative cumulative impacts. Where local disposal options are chosen forlower risk material the operation of such facilities will generate cumulative impacts. Theoperation of landfills will generate a continued risk of contamination arising from improperdesign/operation or closure. Such risk will increase over time as the quantity of landfill increasesand the landfill site ages. In order to manage this risk effectively, all such disposal sites should besited to accepted standards and should be operated according to an agreed "Operating Plan". Thisplan should include: (i) the nature of waste(s) to be accepted; (ii) how waste is to be filled; (iii)inspection and monitoring requirements; and (iv)instructions on steps to be taken in the event ofan accident.

79. In addition to operational concems for such facilities, consideration must also be given totheir continued financial viability and responsibility for the maintenance and/or safe closure ofthe site should the operator go out of business. This is often handled through the form of afinancial bond or guarantee.

80. The addition of waste generated through ASP-P1 and the longer term program toEuropean incineration volumes may be a potential cumulative impact, however, informationcollected from a number of European waste companies indicates that the industry is technicallyand commercially capable of handling the nature and volume of waste streams expected to begenerated by the ASP program as a whole.

81. Potential positive cumulative impacts. The positive consequence of infrastructure andinstitutional capacity building should be a key benefit of the project This will include:

> The development of new regulations and frameworks, which may then be applied toaddress issues other than obsolete pesticides;

> The development of human capital through training and experience; and

18 A detailed discussion of these options together with advantages and disadvantages is given in Annex F ofthe Consultant Report.

23

The provision of new physical infrastructure, where required, such as roads, bridges and

port facilities.

6. Compliance with World Bank/IDA Safeguard Policies

82. This section briefly summarizes the conditions under which the World Bank Safeguard

Policies may be triggered by project activities involving storage, transportation, disposal and site

remediation, and which are detailed in the Environmental and Social Management Framework

(ESMF).

83. As indicated in Table 3, two of the Safeguard Policies are certain to be triggered by ASP-

P1 implementation activities, while several others may be triggered in certain circumstances, to

be determined during the preparation of country specific clean-up plans and associated ESAs.

Table 3: World Bank Safeguard Policies

Safeguard Policy Triggered Nature of Activities and timingby ASP-P 1Activities

Environmental Assessment (OP Yes Pesticide Removal and Site Remediation

4.01, BP 4.01, GP 4.01)Pest Management (OP 4.09) Yes Pesticide Removal and Site Remediation

Prevention

Naturel Habitats (OP 4.04, BP Possibly Pesticide Removal and Site Remediation

4.04, GP 4.04)Identification of Priority Sites

Indigenous Peoples (OD 4.20) Possibly Pesticide Removal and Site Remediation

Identification of Priority Sites

Involuntary Resettlement Possibly Pesticide Removal and Site Remediation

(OP/BP 4.12)Identification of Priority Sites

Cultural Property (OP 4.11) Possibly -

Forestry (OP 4.36, GP 4.36) No -

Safety of Dams (OP 4.37, BP No -

4.37)Projects in International Waters No -

(OP 7.50, BP 7.50, GP 7.50)Projects in Disputed Areas (OP No -

7.60, BP 7.60, GP 7.60)

7. Overall Programme and Reputational Risks

84. The successful implementation of the Africa Stockpiles Programme in general (starting

with ASP-PI) is based in a number of explicit and implicit assumption. This section briefly

24

reviews the risks associated with the potential failure of these assumptions, as distinct from therisks associated with specific project activities and described previously.

85. There are at least seven major types of Programme risks (summarized in Table 4) two ofwhich may be considered "high risk:" (i) international public opposition to off-continent disposaloption (in case this option is selected); and (ii) damage to the reputation of World Bank Group,GEF and other partners arising from potential problems with implementation of programcivilities.

86. Sources of reputational risk. The nature of the programme activities, their potential toattract attention from diverse groups (including NGOs and the media, both at national andinternational levels) and the potential "downside" if there is a major programme failure despite allthe controls, implies that ASP is a source of "reputational risk" both to the Bank and to majorprogramme partners. Perhaps the most significant source of such risk is the global attention thatwould follow a single catastrophic programme failure (such as a major accidental release of POPpesticides from a bulk transport operation, or failure to follow international conventions leadingto a shipment being refused landing at the destination port). As the implementing agency for theASP the Bank would, under such circumstances, likely be judged as "guilty by association" evenwhen it may have taken all reasonable measures to prevent the event. This would not onlyadversely impact the Bank's public image but would also cast doubt on the Bank's "corporatemanagement" competency with existing and future programme partners and stakeholders. Thisissue is considered further as a separate element in the overall Environmental Management Planfor the ASP.

87. Mitigation of repuational Risk Important measures to reduce or eliminate these highrisks focus on:

i. maintaining an open and transparent approach to implementing the ASP;ii. relying on multi-sectoral approaches to build understanding, commitment and public

trust;iii. maintaining strict adherence to the World Bank's Safeguard Policies; andiv. ensuring that all participating countries have signed or ratified the Stockholm Basel, and

Rotterdam Conventions.

88. These same measures are highly effective in addressing other Programme risks that maynot be ranked as high, such as the risk that a participating African country may reduce itscommitment to the Programme, or that the Programme may need to operate in an area of conflict.

89. It is important to note that the above approach to reputational and programme riskmitigation is relies to a significant degree on the capacity and willingness of participatingcountries to develop, implement, operationalize and enforce environmental legislation that meetsthe requirements of relevant international conventions (in particular the Basel Convention andStockholm Convention). Therefore, the importance of proper completion of Stage 1 planningactivities cannot be underestimated - and in particular those activities that relate to the legislativeand environmental management capacity within each participating country. Where such capacitydoes not exist or is not adequate, building and establishing this capacity will be an essentialelement in the management of this risk.'9

19 The case of Nigeria which proposes to focus exclusively on prevention and capacity building activities aspart of ASP-PI, is a pilot case to watch in this regard.

25

90. In order to maintain an open and transparent approach to the implementation of the

programme it is recommended that:

i. The partnership and consensus based approach used to date in the development of the

programme (and in particular in the resolution of specific programme issues, such as the

inclusion of contaminated soils in the scope of the ASP) be maintained;

ii. All major programme decisions be taken in a participatory manner, where all

stakeholders are given the opportunity to make input to the decision making process;

iii. Clear communications are maintained with all programme partners and stakeholders and

that the rationale for key decisions is clearly stated and explained both to programme

partners and (to the wider audience) through public communications;

iv. Issues and lessons arising from the implementation of ASP-P1 in specific countries are

used to inform key programme decisions and that such issues and lessons are made

readily available to all partners and stakeholders;v. No one organization or sub-set of programme partners may make significant changes in

programme scope or direction without consultation with all partners in the ASP; and

vi. Finally, that an independent audit of programme activities be conducted on a minimum of

an annual basis, with the audit scope addressing the extent to which the above factors are

being maintained as well as the progress of the ASP towards its overall goals and

objectives.

Table 4: Summary of Assessments of Key Programme Risks

Programme Risks Likely Level Risk Mitigation Measuresof Risk

Reduced commitment by Low * All participating countries have signed or ratified

a participating African Stockholm , Basel and Rotterdam Conventions

government at * Country programme to be based on multi-sectoral

implementation stage national steering committees

* Close liaison with technical support unit

Poor interagency Medium to * Country programme to be based on multi-sectoral

cooperation in country High national steering committees* Public awareness, as well as capacity building

activities

Need to carry out ASP Low * All participating countries have signed or ratified

activities in an area of Stockholm and Basel Conventions

conflict * Country programme to be based on multi-sectoral

national steering committees* Close liaison with technical support unit

* If risks are high, consideration will be given topreclude ASP activities in area of potentialconflict

26

Programme Risks Likely Level Risk Mitigation Measuresof Risk

Catastrophic accident Low * Ensure highest standards of vessel safety and(e.g., breakup of securitycontainer vessel * Close liaison with technical support unitcontaining hazardous * Compliance with international maritimematerials) conventions such as MARPOL Annex III and the

International Maritime Dangerous Goods(IMDG) Code

Country public Medium * Open and transparent development of ASPopposition to ASP * National and local awareness/ education/activities outreachInternational public High * All participating countries have signed or ratifiedopposition to off- Stockholm and Basel Conventionscontinent disposal option * Open and transparent development of ASP

* Involvement of NGOs during implementationProblems with ASP High All participating countries have signed or ratifiedimplementation damage Stockholm and Basel Conventionsreputation of World Rigorous enforcement of Safeguard PoliciesBank, GEF and other Open processpartners Multi-sectoral advisory committee

27

VI. PARTICIPATORY APPROACH

1. Project Preparation Phase

91. Since its inception in December 2000, the Africa Stockpiles Programme has evolved as a

partnership initiative based on the involvement and participation of all stakeholders, expressed

through both formal and informal communications and consultations. In addition to partners

meetings involving country representatives 20, international NGOs, the private sector, and

international development institutions, in the course of preparing their individual projects,

participating countries have also conducted consultative workshop among key internal

stakeholders.

92. The most recent formal consultation was the "Partner's Meeting and Country Workshop"

held in Midrand, South Africa, between September 9 and 19, 2003. This was attended by key

partners in the ASP and by representatives from seven countries involved in Phase 1 of the ASP.

The workshop presented country updates for Ethiopia, Tanzania, South Africa Nigeria, Mali,

Morrocco and Tunisia. Key issues emerging from this workshop were:

* Ratification of the Stockholm Convention on POPs - Ethiopia, South Africa and Mali have

already ratified the convention, while the process is almost complete for Tanzania and

Nigeria, and well underway in Morocco and Tunisia. Ratification of the Stockholm

Convention is seen as a key pre-cursor to participation in the ASP;

* The concept of dividing each country project into two or three stages was discussed and

generally agreed. There was consensus that a two stage approach would provide the degree

of monitoring and control required and that detailed triggers for release of Stage 2 funding

should be identified. Stage 1 would cover some activities for the life of the project (project

management and some prevention activities) while Stage 2 would cover clean-up of sites.

This has implications for project funding and for the timing of country level environmental

assessments; and* The responsibility of the ASP for remediation of contaminated soils remains an issue. There

was consensus that soils would be dealt with only when there is evidence that soils

contamination results in very high risks for public health and the environment. Mali is

quoted as an example where this is expected to be the case, while Morocco and Tunisia are

quoted as more contentious examples. The view of the meeting was that the scope and

magnitude of soil remediation activities under the ASP should be addressed on a case by case

basis and can only be fully defined at the time of appraisal of Stage 2 activities.

93. It is important to note that the consultative process during the preparation phase of ASP-

P1, has been critical in influencing project design and shaping the analysis and conclusions of the

environmental and social assessment.

2. Project Implementation Phase

94. The consultative process started during programme preparation is expected to continue

and intensify all through the implementation of ASP-PI and beyond, and particularly through two

key stage I activities, as part of the preparation of country clean-up plans (see Figure 2):

20 Meetings were held in Paris (February 2003), Rome (April 2003) and Washington (February 2004).

28

Public consultation and education activity (part of project component 2), focused on:

* Developing and implementing a comprehensive and integrated public awareness,education and consultations programme to support implementation of the ASP-P1 atthe national and local levels, as well as efforts aimed at prevention (reducing thestream of obsolete pesticides); and

* build longer term capacity in the country for engaging citizens and communities inaddressing national and local environmental challenges.

Public consultation, as an integral part of the preparation of country ESAs.

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VII. ANALYSIS OF ALTERNATIVES

95. Because ASP-Pt is fundamentally about environmental and social sustainability, the

analysis of alternatives considered as part of the preparation of the environmental and social

assessment has significantly influenced the final design of the project. While the main design

alternative--to the current design- considered is to continue "business as usual," the assessment

also focused on the analysis of disposal options.

96. The "Without project" alternative, represented the current or moderately enhanced

individual effort of FAO and other donors in separate country initiatives. This alternative was

rejected because it did not offer any of the economies of scale, synergies and visibility captured

by the current ASP-PI design. In addition, the unique set of risks posed by stocks of obsolete

pesticides across the continent, despite differences in scale and spatial distribution, requires that

an overall common approach, consistent with international standards and experience, be used in

order to marshal a critical mass of technical know-how, political visibility and support, and

sufficient financial resources, to provide a viable and sustainable solution to the problem.

Although the actual social and environmental cost of the "business as usual" scenario has never

been attempted-partly because of the paucity of reliable data-all assessments point to the fact

that project benefits significantly outweigh its cost. The willingness of the international

community to provide grant resources through GEF is an indication of "willingness to pay" for a

risk perceived to be substantial. Moreover, the expected project benefits in the areas of

institutional capacity building are also expected to have a multiplier effect in terms of the

capacity of the participating countries to mainstream environment into national development

plans.

97. Alternatives disposal options. As part of the ASP mandate, on-site obsolete stores will

be identified and inventoried, repackaging for transport and site remediation will take place.

Obsolete pesticides will be repackaged and should then be removed to centralized storage to be

stored until a disposal method is available. Several options are open to the project for the

disposal of obsolete pesticides and pesticide wastes. The suitability of disposal options will

depend on the obsolete pesticide formulations in need of disposal, the quantity of obsolete

pesticides, the infrastructure in existence to support the disposal facility, and the technical and

scientific capacity of the region. Disposal options range from relatively simple methods to

technologically and logistically complex options. Prices vary according to the options and the

necessary infrastructure.

98. The options reviewed at length as part of this assessment2" have been grouped into three

main categories:

i. Off-continent disposal (export to a disposal facility in a non-African country);

ii. Long term storage; and,iii. African disposal, including thermal neutralization techniques, chemical treatment and

landfill.

x. Although the technical option of reformulating obsolete pesticides does exist, it is not

permitted within the Stockholm Convention. The Convention states that pesticides deemed

obsolete are "not permitted to be subjected to disposal operations that may lead to recovery,

2i See Annex B of Consultant Report

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recycling, reclamation, direct reuse or alternative uses of persistent organic pollutants".22Reformulation of useable pesticides may be permitted under the Convention, but falls outside theFEA mandate and will not be discussed.

22 Stockholm Convention on persistent organic pollutants, Article 6, 1 d).

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VIII. ENVIRONMENTAL MANAGEMENT PLAN (EMP)

1. Overall Design of the EMP for ASP-Pl

99. The Environmental Management Plan (EMP) describes the actions (including mitigation

measures, cost, and institutional arrangements) that must be taken in order to ensure that ASP-P I

implementation is undertaken in an environmentally sound manner and without adverse socio-

economic impacts. The structure of the EMP is linked to the "staging" of project activities and is

driven by the following three issues:

i. The importance of ensuring that the "inventory activity" is conducted in a manner that

minimizes risks to the environment, to inventory workers and to local communities;

ii. The importance of successful completion of Stage 1 activities as a precursor to starting

Stage 2 within any country; andiii. The need to conduct a country project environmental and social assessment (referred

to "CP-ESA") prior to commencing Stage 2.

100. A key element of the EMP is the ESMF, which seeks to guide implementation of the ASP

at the country level by detailing: (a) the mitigation measures required to eliminate or reduce to an

acceptable level the environmental and socio-economic impacts associated with the conduct of

Stage I activities (describes in section V above); and (b) the issues to be considered in the

conduct of a CP-ESA for Stage 2 activities.

101. The role of the EMP is to provide an overall programme for the management of the

environmental and social impacts associated with ASP-PI, while the ESMF is to provide practical

guidance to those responsible for the planning and implementation of ASP-P1 at the country

level. The ESMF (Figure 2) therefore provides more detailed information on mitigation measures

and is an integral part of in EMP. In addition, it is important to note that country level CP-ESAs

which will guide the design and implementation of stage 2 activities (i.e., essentially disposal) in

each country will have their own detailed EPMs (called CP-EMPs).

102. It is important to note that except for Nigeria, which will be involved in stage 1

(prevention) activities only, the other six countries participating in ASP-Pt will be subjected

to a condition of disbursement in their Grant Agreements, reflecting the requirement and

the need to prepare a CP-ESA which meets the World Bank requirements for category "A"

projects, before they can proceed to stage 2 activities.

103. Because of the intrinsically environmental nature of ASP, there is an important overlap

between key program activities and mitigation measures which are part of the EMP. Therefore,

the EMP is presented below on the basis of the total estimated costs of seven key program

activities, as well as incremental costs associated with these activities.

104. Moreover, it is important to note that the EMP is designed on a "per country" basis.

Given the wide range of individual country circumstances, it is by its nature a "generic" EMP

which should be used for guidance purposes and will need to be adapted the EMP are in the order

of $1.75 per country23 to individual country circumstances. This implies that the need for setting

23 This estimate includes includes an "offset" figure which relates to an estimate of the potential to reduce

the "per country" cost by the use of centralized management planning or programme development. This

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aside some resources at the program level in a "unallocated" cost category in order to adjust tospecific country needs as the implementation of the EMP gets underway.

105. While there will be variation on a country by country basis, the EMP is typicallyexpected to take up to 3 years to implement (when starting from scratch) and costs associatedwith It should be noted that this cost and time-scale includes only those factors that ensure soundenvironmental management of the programme and that can be reasonably estimated at this time.Costs and time-scale associated with construction of ASP-PI related infrastructure and theoperational implementation of Stage 2 activities are therefore excluded These will be providedunder the operational planning activities for ASP-P1I.

Summary EMP Activity Costs and Estimated Estimated EstimatedTimeline date of Total Cost of Incremental

Completion Activity Cost of(from start) Activity

1.0 Conduct Inventory Month 18 $0.75-$1.5 $0.3752.0 National Institutional/Legal Capacity Month 6 $0.5 $0.13.0 Identification of Priority Sites Month 24 $0.25-$0.5 04.0 Emergency Response Plan Month 24 $0.25 $0.1255.0 Public Consultation and Education Month 24 $0.25-$0.75 $0.36.0 Prevention (stage 1) Month 24 $1.0 07.0 Pesticide removal and site remediation Month 36 $1.0 $0.85

(stage 2)Total Cost Estimate $4.0-$5.5 $1.75

*** Month of completion assuming activities conducted concurrently (as indicated in Figure 2).

2. Key elements of the Environmental Management Plan24

may be achieved through existing resources (the ASP team) or by expansion of resources to facilitate such"central development" of program elements.

24 Information contained in summary EMP tablesMitigation measure - shows summary of action to be takenResponsibility: Proj = Responsibility of the country project team

Proj/Prog = Principle responsibility is country project team - support from programmeProg/Proj = Programme team to provide co-ordination - project team to implement

locallyNeed for measure - shows reasons that measure requiredCost - shows estimated costs for sub-activities plus overall estimate for total activityTime required - shows estimated time for sub-activities plus overall estimate for total activityESMF reference - identifies element of ESMF providing more detailed mitigation measure

Cost assumptions* Costs are for indicative purposes only and may vary from country to country as a result of specificcircumstances** Time required is for indicative purposes. Total time required assumes that some sub-activities may beplanned to be completed concurrently-

33

106. The following sections provide a breakdown of the key elements of the EMP. *The tables

at the end of each section provide details on the costs, and timeframe associated with each

activity.

a. Inventory of Obsolete Pesticides (Stage 1 Activity)

107. The first essential step required for establishment of an ASP programme in a specific

country is the conduct of an accurate inventory. This inventory provides the country project

manager with the baseline information required to plan and implement the later steps of the

project. At the same time the data collected during this process will provide the quantitative and

qualitative information needed for the conduct of the country environmental assessment required

prior to commencement of any Stage 2 activities. This information will include the location of

obsolete pesticide stores, types and quantities of obsolete pesticides contained in each store and a

review of storage conditions (state of pesticide containers and storage structures). It is also

recommended that during the course of the inventory, a preliminary assessment of sensitivity of

the surrounding environment to impacts from the project is conducted. This initial scan should

encompass such issues as proximity of obsolete pesticide stores to human dwellings, places of

work, schools, areas of agriculture, drinking water sources and biophysical features, such as

wetlands and rivers and an initial assessment of potential for wider contamination. This

preliminary assessment will provide information to be used in later Stage 1 activities and

specifically in the prioritization of sites.

108. The conduct of the inventory also provides an opportunity for immediate action that will

reduce the threat to the environment and human health posed by obsolete pesticides stored in

deteriorated packaging or containers. While this action increases the risk of exposure to

pesticides, particularly to the workforce (through handling and repackaging activities), these risks

can be mitigated through following the recommended steps contained in the ESMF. By contrast,

the potential gains to be made in terms of human and environmental protection are significant and

should not, without due cause, be delayed.

Table 5. EMP for Conduct of Inventory

Mitigation Measure Responsibility Need for measure Cost* Time required- ESMF ref:

1.0 Conduct Inventory $0.75 to $1.5 M 12 to 18 months ESMF #1

1.1 Training Prog/Proj To ensure inventory staff < $0.25 M 3 to 6 monthsare aware of and able tofollow safe working andenvironmental practices.

1.2 Equipment and PPE Prog/Proj To protect inventory staff < $0.25 M <3 monthsfrom human health hazards (assumes no needand protect the environment to construct newand local communities from safe storagecontamination during the fadlities)inventory process.

1.3 Conduct of inventory Proj Define scope of problem in $0.5 -$1.0 M 6 to 12 monthsthe country with respect tovolume, type, location ofobsolete pesticides as wellstorage conditions.

1.4 Analysis of results Proj To provide information < $0.1 M I to 3 monthsrequired to developpestidde rerno4al and deanup plan.

b. National Institutional/Legal Capacity Assessment (Stage 1 Activity)

109. The second element of the EMP, development of legal and institutional capacity, is acomplex area that in many instances (for example, the state of development of the nationalenvironmental legislative framework) is impacted by factors substantially outside the control ofASP-P1. A key step in implementing the ASP at the country level will, however, be a gapanalysis of the existing legal and institutional framework and the subsequent delineation of howany significant gaps (for example, lack of environmental assessment regulations) are to be filled.An understanding of national regulations and institutions should be a formative step completedprior to the commencement of any project activities in a given country, however, the task of gapanalysis and subsequent actions is likely to continue throughout the life of the country project.The ESMF provides guidance to the country project manager on how to manage the aboveprocesses and indicates their importance to the preparation of the environmental assessmentrequired prior to commencement of any Stage 2 activities.

Table 6. EMP for National Institutional/Legal Capacity

Mitigation Measure Responsibility Need for measure Cost* Time required** ESMF ref:

2.0 National Institutional/Legal Capacity $0.5 M 6 months ESMF #22.1 Legislative Gap Analysis Proj To establish the state of < $0.1 M 1 to 3 months

development andenforcement of nationallegislation.

2.2 Develop/Apply Prog/Proj Where legislation and < $0.25 M 3 to 6 monthsStandards standards are not to the

level required to supportimplementation of ASP atthe country level, developand apply suitablestandards.

2.3 Management Regime Proj To establish the effectivess < $0.1 M 1 to 3 monthsGap Analysis of the existing regulatory

management process.2.4 Develop Management Proj Where the existing < $0.25 M 3 to 6 months

Regime regulatory process is notsuffcient to supportimplementation of ASP atthe country level, developsuitable managementregime.

c. Identification of Priority Sites (Stage 1 Activity)

110. For any programme such as the ASP, identification of priority sites is a natural step inprogram planning. For ASP-PI, identification of priorities should be carried out using the datacollected from the inventory process, including that relating to site sensitivity. Therefore, it isimportant to use a process for prioritizing sites that is simple, transparent and readily understood.To this end, a simple risk assessment tool is provided as part of this element of the ESMF. Inaddition, it is recommended that the country project manager must be able to conduct thisassessment in a timely fashion, following the conduct of the inventory. For countries with a largenumber of sites the potential for changes in the inventory, through for example, additional stocksof pesticide becoming obsolete, need to be borne in mind throughout the ASP process.

35

Table 7. EMP for identification of priority sites

Mitigation Measure Responsibility Need for measure Cost* Time required* ESMF ref:

3.0 Identification of priority sites $0.25 to $0.5 M 3 to 6 months ESMF #3

3.1 Establish risk Prog/Proj To ensure that risk < $0.1 M I to 3 months

assessment team and assessment is conducted in

guidelines a defined and consistentmanner.

3.2 Conduct risk assesment Proj Process by which priorities < $0.25 M 3 to 6 months

will be assigned for cleanup of sites at Stage 2.

d. Emergency Response Plan (Stage 1 Activity)

111. Data gathered from the first three elements of ASP-PI will form key inputs to the fourth

element of the ESMF, that of emergency response planning. The assessment recognizes that,

particularly during Stage 2 of a country project, significant risks to the biophysical and human

environments may be presented. The explicit recognition of such risks and the development of

mitigation measures are indeed a key role of the present study, however, it is prudent to recognize

that even with such planning unforeseen emergencies (such as accidental releases during

transport) may still occur. This fourth element of the ESMF therefore seeks to ensure the

necessary responsibilities, decision processes, communication channels and resources (including

trained personnel and equipment) are in place to respond to any such emergencies in a rapid and

effective manner, such that their impacts may be best contained and minimized. The

development of an emergency response plan for each country project will form a key part of the

mitigation measures contained in the country environmental assessment required prior to moving

to Stage 2 activities in any given country.

Table 8. EMP for Emergency Response Plan

Mitigation Measure Responsibility Need for measure Cost* Time required* ESMF ref:

4.0 Emergency Response Plan $0.25 M 3 to 6 months ESMF #4

4.1 Set up ER planning Prog/Proj To establish the process for < $0.25 M 1 to 3 months

team and guidelines ER planning and ensureparticpation in the processby appropriatenational/regional bodiesand authorities.

4.2 Establish ER Team and Proj To resource the ER plan < $0.25 M 3 to 6 months

equipment. with personnel andequipment.

4.3 Establish ER Prog/Proj To ensure ER is < $0.1 M 1 to 3 months

Management Regime coordinated and controlled,including reporting regimes,ongoing training and testingof response capability.

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e. Public Consultation and Education (Stage 1 Activity)

112. The ASP is recognized as a significant project both in terms of the African continent andin terms of the involvement of the international community. The need to consider and balance awide range of stakeholder interests and viewpoints will therefore be a key factor in the overallsuccess of the program. As the GEF Implementing Agency of the ASP it is the Bank's role tofacilitate the synthesis of those interests and views to form a cogent plan for the program as awhole. In a similar fashion, it will be the role of the executing agency and project manager at thecountry level to ensure that public participation and education is undertaken such that the countryprocess mimics the participative nature of the program overall. This element of the EMPprovides guidance for the country project manager with regard to the planning and conduct ofsuch processes. The information and knowledge gathered during this Stage I activity will beused to meet the public consultation requirements of the environmental assessment requiredbefore moving to Stage 2 of any country project.

Table 9. EMP for Public Consultation and Education

Mitigation Measure Responsibility Need for measure Cost* Time required* ESMF ref:

5.0 Public Consultation and Education $0.25 to $0.75M 6 to 12 months ESMF #55.1 Set up PCE planning Prog/Proj To ensure that PCE is < $0.25 M 1 to 3 months

team and guidelines conducted in a planned andconsistent manner and thatall groups are identified.

5.2 Conduct PCE with ProJ/Prog To ensure that local $0.25 to $0.5 M 6 to 12 monthsappropriate groups communities have a say in(identified from 5.1 the development of the ASPabove) and that the education

objectives of theprogramme are achieved.

f. Prevention (Stage 1 Activities only)

113. A recognized aim of ASP-PI is to seek to stop the future build up of obsolete pesticidestocks, thereby preventing the reoccurrence of the issues now faced. This study recognizes thatsuch prevention activities divide into those that can be conducted under Stage I of the programand those for which a further environmental assessment would be required. Broadly speaking,Stage I prevention activities are those where the focus is on better management of pesticidestocks or on policy review. These include generic reviews of available options for reduction ofreliance on pesticides, training on storage and management of pesticides and the development ofactions to better track pesticide stocks. Stage 2 activities would represent a significant change inpest management strategies and approaches, such as the planned introduction on targetedbiological controls. Stage 2 Prevention activities should be considered under the country ESA.

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TablelO. EMP for Prevention

Mitigation Measure Responsibility Need for measure Cost* Time required* ESMF ref:

6.0 Prevention (Stage 1) $1.0 M up to 18 months ESMF #6

6.1 Set up Prevention Prog/Proj To establish prevention < $0.25 M 3 to 6 monthsPlanning team and planning activites within theguidelines country.

6.2 Enforce regulations, Proj/Prog To implement Stage 1 $0.25 to $1.0 M up to 18 monthsimplement pesticide prevention activities and (excludes anymanagement practices, stop the build up of further costs of newimplement pest obsolete pesticide stocks. physicalmanagement practices, infrastructure,conduct education and such as safeoutreach. storage)

g. Pesticide Removal and Site Remediation (Core Stage 2 Activity)

114. This activity represents the core project activity, and has the greatest potential to create

adverse environmental and socio-economic impacts both on the African continent and -

depending on transport and disposal routes and methods chosen, elsewhere on the globe. The

environmental and social assessment clearly recognizes the potential significance of these

impacts and identifies that the nature of such impacts will be highly dependent on the individual

circumstances and conditions specific to each country. These factors are outside the scope of an

environmental assessment conducted at the project level, and therefore a country level

environmental and social assessment is required prior to starting this activity within any country

participating in ASP-PI. This country level ESA will be the principle mitigation measure

required for the country level Stage 2 project. It is important, however, that each country level

ESA is conducted under a common framework.

115. To ensure this the ESMF provides the country project manager with guidance as to issues

to be considered in the conduct of the country environmental assessment. This guidance deals

with the following key issues:

116. Defining scope of activities - a key decision in any country project will be the definition

of scope of activities to be covered. To this end the ESMF provides clear guidance to the country

project manager on the activities that are to be within the scope of ASP-P1. Such activities

include all operations relating to handling, transport and treatment or disposal of obsolete

pesticides and pesticide associated wastes (such as contaminated structures and packaging).

117. Reviewing information from Stage I activities - the program has been designed such

that much of the information required to conduct the country specific environmental assessment

will flow from undertaking Stage I activities. Review of this information and the filling of data

gaps will, however, be required prior to the completion of the country environmental assessment.

The ESMF provides guidance to the country project manager on this process.

118. Potential environmental and socio-economic impacts - the detailed nature of these

impacts will vary on a country by country basis and potentially over time (for example, as

technology or infrastructure changes and evolves). Therefore, the ESMF seeks to provide

guidance to the project manager on the impacts associated with major project decisions. This

guidance can be used in considering the consequences of project decisions and in reviewing and

38

developing the project strategy for any given country. Through this guidance environmentalassessments conducted under the project will operate within a similar frame of reference helpingto ensure consistency and continuity throughout.

Table 11. EMP for Stage 2 Activities

Mitigation Measure Responsibility Need for measure Cost* Time required** ESMF ref:7.0 Pesticide removal and site remediation $1.0 M up to 18 months ESMF #77.1 Prepare Draft Stage 2 Proj/Prog Required to develop $0.5 M 6 to 12 monthsPlan country specific strategy for

clean up of pesticides andstage 2 prevention

7.2 Conduct Project EA of Proj/Prog Process by which country $0.25 to $0.5 M 6 to 12 monthsDraft Stage 2 Plan specific impacts areassessed and mitigationmeasures are developed.

7.3 Finalize Stage 2 Plan Proj/Prog Formal adoption of Stage 2 < $0.1 M 1 to 3 monthsplan and mitigationmeasures.

7.4 Implement Stage 2 Plan Proj/Prog During this step monitor Costs dependent Time requiredStage 2 activities and on country setting dependent onenforce mitigation and scope and naturemeasures identified in the circumstances. of issuesStage 2 EA. Determined as identified in Stage

part of Stage 2 2 Plan.Plan.

N.B. Costs and time estimates for above exclude those associated with conduct of 7.4 (including buildingof any infrastructure required as part of implementation of the program. Such costs can only be determinedon completion of the Stage 2 plan.

3. Program and Reputational Risk

119. While this issue is not strictly an environmental or social impact, subject to mitigation inthe normal manner, the following steps should be considered in seeking to mitigate this risk.

i. Seek to ensure the effective implementation of all other steps of the EMP, therebyseeking to minimize the risk of crystallization of this issue, through avoiding significantprogram failures. Of particular importance here is ensuring that all legal safeguards andbest management practices are followed, including use of authorized and approvedcontractors for handling and transport of hazardous wastes.

ii. Continue to build the ASP in a consultative and open manner, obtaining the "buy in" tokey program decisions from all program and country partners.

iii. In the event of a programme failure likely to result in potential exposure to reputationalrisk:

> Through ASP planning be prepared to rapidly mobilize emergency response teams;> Have established and be able to rapidly implement a public communications process,

to ensure that factual issues are treated in an open manner and reducing the potentialfor distortion or misrepresentation;

> Have established and be able to rapidly implement a communications process withkey stakeholders (including stakeholders not involved with the ASP); and

39

Have established and be able to call upon a "contingency" fund to assist in the

mitigation of the biophysical and socio-economic impacts caused by the programme

failure.

120. Developing a fully integrated management programme to address the above issues,

including the identification of financial mechanisms to fund such activities (such as insurance,

performance bonds, fund retention) as well as administrative plans and tools should be an activity

conducted in conjunction with (if not prior to) the move of the first phase of countries into Stage

2 activates. Funding requirements for such a management programme is likely to be in the region

of $<0. I M and the programme may be expected to take approximately three to six months to

develop.

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IX. MONITORING AND EVALUATION

121. The ASP-PI project design includes a number of operational indicators to measure theprogress of the project against objectives and to evaluate operational and financial performance.The environmental and social assessment does not seek to duplicate this process, but ratherprovides a monitoring and evaluation framework for follow up on the mitigation measures thatare contained in the EMP (for Stage I activities) and those that will be required under countrylevel environmental assessments (for Stage 2 activities). The proposed indicators are qualitativeand quantitative in nature and are divided into three broad categories:

i. Indicators to monitor that Stage I mitigation measures are being followed during theconduct of inventories and emergency repackaging (including the audit of selected siteinventory exercises against the mitigation criteria referenced in the ESMF);ii. Indicators and conditions that must be met (from an environmental and socio-economic

safeguard point of view) in order for the country project to move to Stage 2; andiii. A framework of environmental and socio-economic indicators that can be used to guidemonitoring of impacts and their mitigation under the Stage 2 environmental assessment.

1. Assessing effectiveness of mitigation measures under Stage 1

122. Mitigation measures for Stage I activities are contained in the ESMF and it is essential,from a project management perspective, that the application and effectiveness of such measuresare monitored and assessed. Especially important in this regard are those measures surroundingthe conduct of inventory and emergency repackaging.

123. The following indicators for effectiveness of inventory and emergency repackaging areproposed:

(1) Numbers of inventory personnel trained in FAO guidelines for inventory taking, ascompared with numbers required;(2) Quantitative and qualitative review of incident and near miss reports; and(3) Quantitative and qualitative review of complaints or communications received.(4) In addition to the above it is recommended that, given the importance of following

the proper procedures during the inventory taking process, periodic audits areconducted of specific site inventories using the FAO guidelines as audit criteria.

124. The following additional indicators for measuring the capability to move from Stage I toStage 2 are proposed:

(5) Number and % (of total) completion of site inventories;(6) Number and % (of total) of sites requiring emergency repackaging;(7) Completion of legislative and institutional gap analysis;(8) Completion of a plan to address gaps in above (using relevant international standards

where required);(9) Number and % (of total) sites risk assessed;(10) Completion of a prioritized site clean-up plan;(11) Completion of development of emergency response plan (including a test scenario);(12) Completion of the development of the public consultation and education plan; and(13) Completion of the Stage I prevention plan.

41

2. Trigger for progressing to Stage 2

125. In order to move to Stage 2 activities the ASP country project must be able to

demonstrate that 100% of planned sites have been inventoried and risk assessed and that items 8,

9, 11, 12, 13, and 14 above have been completed. These items will form a key part of the draft

Stage 2 plan required prior to implementing Stage 2 activities.

3. Measures for measuring effectiveness of mitigation measures under Stage 2

126. For Stage 2 activities the indicators required to monitor the effectiveness of mitigation

measures will be set at the country specific level through the process of the environmental

assessment of the draft Stage 2 plan. The following should be considered during the country

specific environmental assessment.

(15) Economic value of land used for the development of ASP facilities and structures and

related infrastructure, together with value of compensation paid (including land made

inaccessible by project related activities);

(16) Net increase/reduction in agricultural production arising from use of land for ASP

related activities and structures (including land made inaccessible by project activities);

(17) Net increase/reduction in natural resources areas (such as wetlands, fisheries, subsistence

food sources, forests) arising from use of land for ASP related activities and structures

(including land made inaccessible by project related activities);

(18) Net increase/reduction in potable water supplies arising from ASP related activities;

(19) Net job gains/losses arising from ASP activities (identified by unskilled, traditional

skilled, technology skilled, and managerial);

(20) Numbers of people trained in pesticide management skills, including handling and

storage practices;(21) Loss of cultural heritage sites (or restriction in access to same) as a result of ASP related

activities;(22) Net increase/reduction in quality of the natural environment, including biophysical

parameters (such as water quality) and biodiversity of flora and fauna, (through

remediation, development or through deterioration) arising from ASP related activities;

and(23) Net increase/reduction in obsolete pesticide related human health impacts as a result of

ASP related activities.

Conclusion

127. The effective execution and mainstreaming the EMP into project activities, and

adherence to the principles and framework outlined throughout this document, implementation of

ASP-PI and the overall program will allow the considerable potential social and environmental

benefits of the project to be realized. Through direct clean up activities the project can make a

significant contribution to environmental and human health issues, while consultation, education

and outreach will play a pivotal role in ensuring that the problem of obsolete pesticide stocks does

not reoccur. The potential risks represented by Stage 2 clean up activities are significant,

especially if improperly or ineffectively managed, as is the potential for reputational risk to the

World Bank and key partners should there be a major failure. The need to comply with

international conventions and national legislation on hazardous wastes and to follow best

management practices is therefore paramount in ensuring safe and diligent implementation. For

any country project, the capacity to achieve this management capability must therefore first be

developed (and clearly demonstrated) through preparation activities identified under Stage I of

42

the programme - before this capability is critically assessed through the conduct of a countryspecific ESA. It is essential that no project moves to commence Stage 2 activities without firstgaining Bank approval for the country specific EA The effective implementation of measurescontained in the EA and the compliance with international and national conventions, legislationand codes must then be monitored and enforced, both through internal management regimes andthrough the auspices of the Bank's own programme review capacity.

43

References

Environmental Media Services. 2003. POPs and human health.. Washington.

FAO. 1995a. Prevention of accumulation of obsolete pesticide stocks. Provisional guidelines.

Rome.

FAO. 1995b. Guidelines for the packaging and storage of pesticides (revised version). Rome.

FAO. 1995c. Prevention and disposal of obsolete and unwanted pesticides stocks in Africa and

the Near East. The first FAO consultation meeting. Rome.

FAO. 1996a. Disposal of bulk quantities of obsolete pesticides in developing countries.

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ANNEX 1. Available estimated distribution of pesticides in Africa (2001)

(Need to change colors for better B&W readability)

Inventory of obsolete, unwanted andbanned pesticide stocks

Oty. in metric tonnes

= 500- 1,000

t X 50-500- 5-50 % @ f t- Not quantified

. Further full Inventory is necessaryAll require revised Inventory from time to time

Martin FodorL:\-AFTES\ASP\ASP-Env&Social Assessemnt-Final draft-h.doc

March 18, 2004 12:17 PM

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