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Version: Dated 20 th November 2015 Draft Inception Report and Action Plan Comprehensive reduction and elimination of Persistent Organic Pollutants in Pakistan Ministry Of Climate

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Version: Dated 20th November 2015

Draft Inception Report and Action Plan

Comprehensive reduction and elimination of Persistent Organic Pollutants in Pakistan

Reducing human health and environmental risks by enhancing management capacities and disposal of POPs in Pakistan

November 2015

Ministry Of Climate Change

TABLE OF CONTENT ACRONYMS..................................................................................................................................3

1. PROJECT INTRODUCTION..................................................................................................5

2. OBJECTIVE, PROCESS AND PARTICIPATION OF THE MEETING..................................6

3. INTRODUCTORY SESSIONS AND BRIEFINGS..................................................................9

3.1. Introduction to the POPs.....................................................................................................9

3.2. The New POPs/ Amendments to the Stockholm Convention...........................................13

3.3. Stockholm Convention and Pakistan................................................................................15

3.4. National Implementation Plan...........................................................................................18

3.5. The situation of POPs Stockpiles in Pakistan...................................................................18

3.6. Pakistan National Implementation Plan on POPs.............................................................23

4. REGULATORY POLICY AND ENFORCEMENT SYSTEM TO REDUCE POPs RELEASES.................................................................................................................................25

4.1. Agriculture Sector – POPs Management (Regulation, Authorization and Enforcement and Inspection)................................................................................................................................25

4.2. POPs and the Health Ministry (Malaria)............................................................................27

4.3. Role of NARC in POPs-Pesticides Management..............................................................29

5. POPs PROJECT AND PROVINCES...................................................................................32

5.1. EPA Punjab:......................................................................................................................32

5.2. EPA AJK...........................................................................................................................32

5.3. EPA – Sindh......................................................................................................................32

5.4. EPA Gilgit-Baltistan...........................................................................................................32

6. PARTICIPATORY ACTION PLAN FOR POPs PROJECT.................................................33

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ACRONYMS

ADB Asian Development BankAEB Area Electricity BoardsAJK Azad Jammu KashmirAPA Agricultural Pesticides ActAPO Agricultural Pesticide OrdinanceAPTAC Agricultural Pesticides Technical Advisory CommitteeBAT Best Available TechniqueBEP Best Environmental PracticeBHC Benzene HexachlorideCEO Chief Executive OfficerCIPAC Collaborative International Pesticides Analytical CouncilCOP Conference of the PartiesDDT DichlorodiphenyltrichloroethaneDISCO Distribution CompanyDPP Department of Plant ProtectionDPRU Development Policy Research UnitEC European Commission EDB Engineering Design Bureau EPA Environmental Protection AgencyEU European UnionFAO Food and Agriculture OrganizationFESCO Faisalabad Electric Supply CompanyGEF Global Environment FacilityGENCO Generation CompanyGESCO Gujranwala Electric Supply CompanyGHS Globally Harmonized SystemGOP Government of PakistanHCH HexachlorocyclohexaneHESCO Hyderabad Electric Supply CompanyIESCO Islamabad Electric Supply CompanyIGR Insect Growth RegulatorINC Intergovernmental Negotiating CommitteeKE Karachi ElectricKPK Khyber PakhtunkhwaLESCO Lahore Electric Supply CompanyM&E Monitoring and EvaluationMESCO Multan Electric Supply CompanyMOCC Ministry of Climate ChangeMT Metric tonNA Not applicableNARC National Agricultural Research CenterNEP National Environment PolicyNEPRA National Electric Power Regulatory AuthorityNEQS National Environmental Quality StandardsNIFA Nuclear Institute of Food and AgricultureNIP National Implementation PlanNPM National Project ManagerNPSL National Physical and Standard LabsNTDC National Transmission and Power Dispatch Company

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PAC Public Accounts CommitteePARC Pakistan Agricultural Research CouncilPBDE Polybrominated Diphenyl EthersPCB Polychlorinated biphenylPCRWR Pakistan Council of Research in Water ResourcesPCSIR Pakistan Council of Scientific and Industrial Research PEPA Pakistan Environmental Protection AgencyPESCO Peshawar Electric Supply CompanyPOP Persistent Organic PollutantPOPRC Persistent Organic Pollutants Review CommitteePPG Planning Policy Guidance PVC Polyvinyl ChlorideQESCO Quetta Electric Supply CompanyR&D Research and DevelopmentSAICM Strategic Approach to International Chemicals Management SESCO Sukkur Energy Supply CompanyTEQ Toxic EquivalencyTESCO Tribal Electric Supply CompanyUN United NationsUNDP United Nations Development ProgrammeUNEP United Nations Environment ProgrammeUSD United States DollarWAPDA Water and Power Distribution AuthorityWHO World Health Organization

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1. PROJECT INTRODUCTION The Comprehensive reduction and elimination of Persistent Organic Pollutants Programme in Pakistan aims at reducing human health and environmental risks by enhancing management capacities and disposal of POPs in Pakistan through: i) development and implementation of a regulatory, policy and enforcement system to reduce POPs releases and to regulate POPs waste disposal; ii) capacity building of stakeholders to reduce exposure to and releases of POPs; iii) collection, transport and disposal of 300t of PCB and 1200t of POPS Pesticides; and, iv) improved monitoring, evaluation, learning and adoption of the project.

The elimination of POPs pesticide stockpiles became even more urgent after the 2010 floods, which damaged some of the storage sites of hazardous chemicals and pesticides. To ensure environmentally sound disposal of POPs, a facility to be upgraded, tested and permitted in compliance with Stockholm Convention BAT/BEP. As an alternative, the project will also explore options of shipment of POPs waste abroad for disposal, in compliance with the Basel Convention, if at an early stage it will result evident that the POPs cannot be disposed of using the technologies available in the country.

Pakistan and the Stockholm ConventionThe Stockholm Convention on Persistent Organic Pollutants (POPs) was signed by Pakistan on December 6, 2001 and ratified on April 14, 2008. In the context of enabling activities, the National Implementation Plan (NIP) was submitted on 16 July 2010. This document provides a policy framework, which lays out the guidelines for addressing the specific issues of POPs pesticides and PCBs in Pakistan.

Continuing efforts are being made to improve the existing policy and regulatory systems under the National Implementation Plan (NIP) ‐ POPs, and to strengthen enforcement, monitoring & compliance. The project is in line with the national priorities and interests as defined in the NIP on Persistent Organic Pollutants. The strategy of the Government of Pakistan is to have a sound POPs management system established and operational as soon as possible. The project proposes a series of activities to strengthen the existing legal and regulatory framework for POPs management and build technical, enforcement & monitoring capacity of local communities, concerned governmental departments and relevant stakeholders.

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Stockholm Convention on Persistent Organic Pollutants (POPs) is an international Environmental Treaty signed in 2001 and effective from May 2004, that aims to eliminate or restrict the production and use of persistent organic pollutants (POPs).

Over 150 countries signed the Convention and it entered into force, on 17 May 2004, 90 days after the ratification by the fiftieth country.

The Stockholm Convention focuses on eliminating or reducing releases of 12 POPs, the so-called "Dirty Dozen".

In August 2010, nine new chemicals were added to the Stockholm Convention's annexes.

2. OBJECTIVE, PROCESS AND PARTICIPATION OF THE MEETINGThe UNDP Pakistan POPs project – in collaboration with Ministry of Climate Change, Pakistan and GEF Project – organized an Inception Workshop on November 11, 2015 in PC Bhurban, Murree. The workshop aimed at:

i) Introducing UNDP POPs project and its components to the stakeholders;ii) Instigating discussion on project components, mainly role of stakeholders in regulatory,

policy and enforcement system to reduce POPs releases; and,iii) Developing a comprehensive project action plan for year 2016 and collectively sharing

responsibility for its implementation.

The meeting started with the recitation of the Holy Quran followed by a brief introduction by Mr. Rahman Hamid, NPM POPs Project. He thanked everyone for participation and went through the agenda of the day. The workshop is an outcome of 1st Annual Technical Review meeting held during last month on the project “Comprehensive Reduction and Elimination of Persistent Organic Pollutants in Pakistan”. This workshop played a vital role in bringing sector experts and national and provincial stakeholders into one platform to discuss and agree on actions that need to be taken to achieve the objectives of the project. The brief on session-wise workshop agenda is as under:

Session # 1. Introductory Phase: The introductory phase involved brief talks from Secretary MOCC, UNDP Assistant Country Director and POPs National Project Manager. The brief of these three talks are as under:

i) Note from Secretary MOCC: The Secretary MOCC emphasized that the Ministry of Climate Change, Government of Pakistan is determined to eliminate the POPs as soon as practicable by implementing the National Implementation Plan in line with the requirements of the Stockholm Convention and to undertake review of the relevant policies and legislation for effective implementation of the Stockholm Convention as well as other related conventions and international processes on chemicals management. He also said that this shall facilitate strengthening of capacity of institutions that deal with POPs including the establishment of mechanisms for coordination, reporting and monitoring of POPs and the review and updating of the NIP. He informed the participants that Government also realizes the importance of generating and dissemination of public information and creation of public awareness at all levels to tackle concerns of POPs in a comprehensive way. In doing so, the Government within its limited capacity, shall make deliberate efforts to implement its obligations under the Stockholm Convention and hence eliminate POPs as scheduled. On implementation, he said that the Government of Pakistan will take appropriate measures to ensure implementation of the national priorities on POPs as would be specified in the Action Plans. The main priority issues would be grouped in six major areas namely, elimination of POPs, rational management of obsolete stockpiles/ contaminated sites, strengthening legal and institutional framework for managing POPs and chemical pollutants; establishing monitoring program for POPs and other chemical pollutants; enhancing transfer of appropriate technology for control of POPs releases; and improving public information, awareness and education.

ii) Note from UNDP Assistant Country Director: The UNDP ACD thanked all stakeholders for their participation. He considered identification of the stockpiles as a first priority and then making arrangements for its safe disposal. He confirmed that UNDP is committed to support GoP and other stakeholders/ departments on the agenda

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of POPs reduction and will make every possible contribution to this cause. He assured that (if and when needed) project would engage international experts and import technology to support elimination and safe disposal of waste. The UNDP ACD again acknowledged participants for their interest and participation in the Project and development of its comprehensive action plan for year-2016.

iii) Note from UNDP POPs Project NPM: The POPs NPM emphasized on collective efforts in reducing POPs and also informed the participants that the project entails a comprehensive plan on: a) development and implementation of a regulatory, policy and enforcement system to reduce POPs releases and to regulate POPs waste disposal; b) capacity building to reduce exposure to and releases of POPs; and, c) collection, transport and disposal of 300t of PCB and 1200t of POPS Pesticides. The NPM also updated the participants on POPs project activities that are being carried out during year 2015 to build foundation for year-3 activities. These activities are: i) reconfirmation of Stockpiles in Punjab, ii) development of curriculum / contents for POPs Pesticide, iii) development of training manual for the POPs pesticide industry, and, iv) pilot disposal of 4 MT of POPs. The NPM reaffirmed that reduction of POPs and its control in future is a huge agenda and all stakeholders should play their role in implementation of POPs NIP and other obligations under the Stockholm Convention.

Session # 2. Discussion on Project Components: This session involved briefing by UNDP Project Technical Director on POPs, its releases and dispersion, effects on human/ animals, the Stockholm Convention and its obligations on countries such as Pakistan, and the National Implementation Plan. This also briefed the participants on Project, “Comprehensive Reduction and Elimination of POPs in Pakistan” and its components including development of regulatory, policy and enforcements systems to reduce POPs, importance of capacity building and coordination to reduce exposure to and releases of POPs, collection, transportation and disposal of existing stocks of POPs Pesticides and monitoring, evaluation, learning and adoption. This session also involved question and answer on various concerns, clarification and suggestions on the issues of POPs and UNDP project components and activities.

Session # 3. Discussion on Regulatory and Policy Framework: This session was led by Mr. Waseem-Ul-Hassan who briefed the participants about the POPs persistent in agriculture sector. He also informed that pesticides are the main reasons for POPs; otherwise no direct pollutants are being produced in agriculture sector. He focused on need to: i) control the import of substandard pesticides in the country; ii) regulate the pesticide policy and practices, iii) provide an appellant forum to the pesticide manufacturer, distributors and retailers by counter analysing the samples in Federal Pesticide Testing & Reference Laboratory, and iv) monitor and keeping a record of the pesticide availability position in the country. Afterwards, Mr. Hassan briefed the participants on the existing regulations, institutional arrangements and actions taken to control POPs in agriculture. His session was followed by an open discussion and Q&A by the participants.

Session # 4. POPs Project and Provinces/ EPAs: This involved presentation by each of the EPA (Punjab, Sindh, KPK, GB and AJK) on status of POPs stockpile in the provinces. The EPAs identified the issues of policy regulations and its enforcement and need for building provincial capacity to properly manage and safely transport and dispose-off the existing stockpiles. Need for continues monitoring of POPs have also been discussed and stressed. All the Provincial EPAs considers and acknowledges the need to engage private sector and communities in this initiative, as they are the key stakeholders and could not be neglected. They

Inception Report and Action Plan, UNDP POPs Project Page 7

Maksim Surkov, 11/25/15,
Not very clear – has to be explained in more details on what is behind these intentions. Quite small amount and for what kind of pilot disposal – if for cement kilns business that can only be done after several preparatory activities: (-) checking readiness of the cement kiln to accept such waste including environmental impact assessment and social impact assessment to be performed; (-) checking infrastructure of those if they are able to handle storage and feeding of the waste – pesticides have to be missed in other liquids and PCBs are liquids, (-) planning carefully – a programme of several activities – for test burns (in line with GEF STAP guidance on POPs disposal), including selection of a sub-contractor who can make measurements to air emissions and ash and report on findings etc.If export, then the amount is a bit small, and 300 tons of PCBs and 1,200 tons of POPs pesticides can be split into three parts – your international expert can help guide you and I have to be involved in the tendering with him/her – some parts can be exported (remember chlorine content is a factor on how fast each 500 tons can be destroyed – and of everything is sent to one plant, it can take time). In case cement kiln(Holcim) is ready with all local clearances and test burns (this may take a 1.5 year time in fact depending on how fast we move), then partly the waste can be tested there, which I doubt will be the way. On the argument that funding stays in the country, due to foreign ownership of Holcim, it is effectively same issue as export, but less responsibility when export is done.When export is done, in the RFP we delegate responsibility for his hazwaste to the operator – a company that removes it from the country.Any tender will be international and all will have to compete from technical capability point of view (GEF STAP guidelines on POPs destruction parameters will have to be used in the RFP formulation and review of bids), and then financially.

also identified the need to conduct research in the area to get more clarify on province/ context specific issues of POPs production and its releases.

Session # 5. Discussion on Regulatory and Policy Framework: POPs and Health Sector: The session was led by Dr. M. Mukhtar who briefed the participants about relevance of POPs project in the health sector. He briefed that prevalence of malaria is the greater issue in Pakistan, particularly in FATA, KPK and Baluchistan and use of public health pesticides – which are very common – is the biggest threat. Similarly he explained that use of Public Health Pesticides (PHPs) for control of VBDs in Pakistan is very common and it has a long history. He expressed that Ministry of Health is strongly committed to implement the recommendations of Stockholm Convention through its attached departments (DoMC), which is the key department of M/o Health for use of PHPs in Pakistan and taking all necessary actions to protect environment from POPs. In 2010/11, DoMC conducted nation-wide survey to review the susceptibility level of local vector species against all 4 groups of insecticides including DDT and Dieldrin. In Sind and Punjab, malaria-carrying mosquitoes showed resistance whereas in FATA & Balochistan 100% susceptible to DDTl. Dr. Mukhtar also presented actions taken by MoH in controlling and eliminating POPs. His presentation concluded on challenges and identification of initiatives that need to be taken to bring this agenda forward through collective efforts.

Session # 6. Role of NARC in POPs-Pesticides Management: Mr. Karam Ahad presented institutional arrangements, including establishment of Ecotoxicology Research Programme, NARC to monitor fate of pesticides residues in the environment, evaluate their implications on non-targeted beneficial species and to study occupational and accidental exposure to these chemicals. He also briefed the participants on their recently launched project on establishment of National Pesticide Residues Monitoring System (NPRMS) in Pakistan. He also displayed a graph indicating a consistently increasing use of pesticides quantity from 1980 to 2014 and then dropping from there onwards. He also shared status of POPs Pesticides in soil and water samples from Hotspots across 4 provinces (Punjab, KPK, Baluchistan and Sindh) of Pakistan. Apart from demonstrating examples of various hazardous and devastating impacts of POPs on human, animals and overall environment, he concluded with his concerns that the soils of obsolete pesticide stores in Pakistan contain high levels of POPs-pesticides that threaten human health, our water resources and the environment; hence proper arrangement should be made to remove these toxic heaps.

Session # 7. Closing Remarks and POPs Project Action Plan: The UNDP POPs project NPM concluded the workshop with the word of thanks to participation for their participation, insight and commitment to the issue. He also committed to consolidate the recommendations of all the stakeholders including NARC, MoH, Provincial EPAs, and others stakeholders and development of a detailed action plan for the UPDP POPs project for year-2016, with shared responsibilities and collective engagement.

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Maksim Surkov, 11/25/15,
One project on looking for DDT alternatives in Mauritius we are now finalizing. Perhaps its experience could be important for discussion in Pakistan.

3. INTRODUCTORY SESSIONS AND BRIEFINGSAs explained above, the 2nd session of the Inception Workshop was dedicated to introducing the participants about the POPs, its releases and dispersion, effects on human/ animals, the Stockholm Convention and its obligations on countries such as Pakistan, the National Implementation Plan. This section of the report also includes brief on Project Comprehensive Reduction and Elimination of POPs in Pakistan and its components including development of regulatory, policy and enforcements systems to reduce POPs, importance of capacity building and coordination to reduce exposure to and releases of POPs, collection, transportation and disposal of existing stocks of POPs Pesticides and monitoring, evaluation, learning and adoption. The details of topics introduced in the Review Meeting are as under:

3.1. Introduction to the POPs The Persistent Organic Pollutants (POPs) included in the Stockholm Convention are a group of chemical substances that have four basic characteristics in common:

i. Adverse effects: They are toxic for human and animals ii. Bioaccumulation: They have a chemical structure that allows them to be absorbed

in human and animal tissue. Since they are also persistent (see below) they can accumulate in the body over a long period of time in increasing levels of concentration.

iii. Persistence: They are not easily degradable but persistent, with the potential to remain for years or decades before degrading.

iv. Long-range Transport: They can be spread over long distances (e.g. through migratory species, or long range air transport) and may therefore have an impact far away from their original sources.

These intrinsic properties of POPs create a dangerous combination that makes it practically impossible to effectively control them, once they are released into the environment.

Release and dispersion of POPsPOPs can be released into the environment, transported, and redeposited in water and on land far from their sources. Similarly, POP may be transported over long distances far away from their original sources. Transport may occur through long range air dispersion, through accumulation in migratory species, and also through human activities e.g. (transport of equipment or waste containing POP).

POPs are characterized as “organic” since their basic chemical structure is formed by various carbon atoms, and this means that they tend to be soluble in oils and fats (a characteristic referred to as lipid solubility). The twelve POPs prioritized in the Stockholm Convention also have various chlorine atoms linked to the carbon structure, making them even more fat soluble.

POPs are capable of “bioaccumulating.” When they are released into the environment, they are absorbed by the fatty tissues of plants and animals, and they become increasingly concentrated in those tissues, through a process called bioaccumulation. This concentration biomagnifies, or increases by hundreds and even millions of times, as organisms exposed to POPs are eaten by their predators, and this allows the pollutants to move through the different links in food chains. In this way, POPs become more highly concentrated in species

Inception Report and Action Plan, UNDP POPs Project Page 9

that are at higher levels in food chains, such as fish, predator birds and mammals, including polar bears, otters, seals, dolphins, whales and human beings.

Effects of POPs on Wildlife/Humans:i. Animals: Rapid decline in the population of some species, in particular species at the

top of the food chain (predators such as eagles)ii. Human beings: POPs even contaminate breast milk, affecting new generations (also

in analogy with the case for animals – humans are often at the top of the food chain)

POPs have a transgenerational effect. Exposure to these substances begins at conception. PCBs have been found in semen. POPs that accumulate in fatty tissues can pass into the blood and can pass through the placenta during embryonic and fetal development. They can be excreted in breast milk and thus transferred to breastfed babies. Consequently, we find that human beings and other mammals are exposed to the highest levels of these pollutants during the period of life when they are the most vulnerable —in the uterus and as babies, when their bodies, brains, nervous systems and immunological systems are in the delicate process of being developed.

POPs enter the human body primarily through the food we eat. POPs can accumulate in milk products, fish and meat —in very small amounts that cannot be perceived through the senses. We cannot see them, smell them or feel them. POPs released into the atmosphere enter into the food chain when it rains, contaminating pastures and crops used to feed livestock., POPs discharged into water bodies accumulate in soil or sediments and contaminate fish, and subsequently reach human beings. Even though food is the primary way in which humans are exposed to POPs, the levels of these substances in food are not monitored in most countries —not even dioxins, furans or PCBs. In the United States, exposure to dioxins through food occurs at levels that are near or above the levels that cause adverse effects in tests with laboratory animals.

The World Health Organization has established acceptable daily intake limits for some POPs, such as dioxins, furans and PCBs. These are based on risk assessments in accordance with an average diet (from 1 to 4 pg. TEQ per kg body weight per day). A normal diet in industrialized countries frequently contains dioxins in amounts that are greater than these limits. In addition, it is certainly questionable whether these “tolerable” limits actually represent protective measures, since there is no “safe dose” for endocrine disruptors, nor is there a “safe dose” for cancer-causing substances, such as POPs. Research on endocrine disruptors demonstrates that some effects are found with very low concentrations instead of with high doses, as normally occurs with toxicological assessment procedures. Furthermore, studies indicate that the moment when exposure occurs is just as or more important than the amount, especially if exposure takes place during the embryonic period of development.

POPs form part of the toxic body burden that is passed on to future generations. The term “body burden” refers to the total amount of chemical substances present in the human body at a given point in time. Some scientists estimate that everyone alive today carries at least 700 pollutants in his/her body, and these include POPs, as well as many other chemical substances that have not yet been the subject of thorough study. Toxic chemical substances enter the human body when they are inhaled, or when contaminated food or water is ingested, and in fact, they can be absorbed through our skin. A pregnant woman can pass toxic substances to her developing fetus through the placenta, and a woman who nurses her child can pass these substances through breast milk. Chemical substances can have

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different effects on humans and on wildlife, depending on the intrinsic toxic properties of the specific substance and the amount, timing, duration and pattern of exposure. Nevertheless, the effects of the combination of this “cocktail” of chemical substances found in the human body have not been studied, and government regulations that establish “tolerable limits” for some of these particular substances in food and in the environment do not take into consideration this multiple, accumulated nature of exposure.

Chemical substances and their transformation products (metabolites) remain in organisms for only a certain amount of time before they are excreted through urine or perspiration, as occurs with some organophosphate pesticides. However, continuous exposure can create a persistent body burden. Some persistent, bioaccumulative chemical substances, such as POPs, are not easily discharged by the body, and may remain for years in our blood, fatty tissue, semen, muscles, bones, brain tissue and other organs. DDT, for example, can remain in the body for 50 years, and PCBs can remain in fatty tissues for 25 to 75 years, since they are resistant to metabolic transformation.

Thus, just as we have the right to know what pollutants are present in the air, water and soil, we also have the right to know what pollutants form part of our body burden, and to demand that authorities and the industrial producers of these substances adopt measures that prevent their formation and release into the environment. The body burden of persistent toxic substances such as POPs should not be accepted as a natural, irreversible fact, since it violates the fundamental right to a quality of life characterized by human dignity. In particular, the presence of these substances in the human body violates the reproductive rights of women, their right to pregnancy and breastfeeding free from pollutants, and the rights of children to a healthy diet and to conditions that will permit their full development. Women’s groups and organizations created to defend children’s rights have an opportunity to play a significant role in the fight to eliminate POPs. The Stockholm Convention explicitly mentions that governments must report to and consult with these groups during the process of developing National Implementation Plans.

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May 2001 - Stockholm Convention + Treaty- Conference on Stockholm

Convention 129 countries participated, 92

countries and the EC signed treaty.

90’s - Global action on the 12 POPs + POPs Intergovernmental Negotiating Committee (INC)

Work on POPs begun in various forums.

Intergovernmental Forum on Chemical Safety (June 1996)

UNEP/GC Decision 19/13C (February 1997)

70’s & 80’s - Taking Commitements

Many governments take national action

1962 - Realization

Rachel Carson’s “Silent Spring”.

3.2. The New POPs/ Amendments to the Stockholm Convention At its fourth and fifth meeting held in 2009 and 2011, the Conference of the Parties (COP), by decisions SC-4/10 toSC-4/18 and decision SC-5/3, adopted amendments to Annexes A (elimination), B (restriction) and C (unintentional production) of the Stockholm Convention to list ten additional chemicals as persistent organic pollutants (new POPs).

By decision SC-4/19, the COP decided to undertake a work programme to provide guidance to Parties on how best to restrict and eliminate these newly listed persistent organic pollutants and invited Parties to support work on the evaluation of alternatives and other work related to the restriction and elimination of these new POPs. 

At its fifth meeting in April 2011, the Conference of the Parties adopted decision SC-5/5 that encourages Parties and other relevant stakeholders to implement where appropriate, taking into account national circumstances, the recommendations of POPRC set out in the annex to decision POPRC-6/2 on the elimination from the waste stream of brominated diphenyl ethers that are listed in Annex A to the Convention and on risk reduction for perfluorooctane sulfonic acid, its salts and perfluorooctane sulfonyl fluoride. Parties were invited to submit to the Secretariat information on their experiences in implementing the recommendations for consideration by the COP at its sixth meeting. Furthermore in decision SC-5/9, on measures to reduce or eliminate releases from wastes, the COP requested that the recommendations be made available to the appropriate bodies of the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal to support their work.

At its sixth meeting in May 2013, the Conference of the Parties adopted decision SC-6/7 on the work programme on brominated diphenyl ethers and perfluorooctane sulfonic acid, its salts and perfluorooctane sulfonyl fluoride, where it encourages parties and observers to implement where appropriate the recommendations that pertain to them.

Implications of listing new chemicals/ POPsThe implications, for the implementation of the Stockholm Convention, of listing new chemicals include:

i. Implement control measures for each chemical (Article 3 and 4);

ii. Develop and implement action plans for unintentionally produced chemicals (Article 5);

iii. Develop inventories of the chemicals' stockpiles (Article 6);

iv. Review and update the National Implementation Plan (Article 7);

v. Include the new chemicals in the reporting (Article 15);

vi. Include the new chemicals in the programme for the effectiveness evaluation (Article 16).

Pesticides (Agriculture)

Industry (power equipment)

Unintentional by-products/emissions

13 chemicals 1 group 10 chemicals (two also in pesticides formulations)

Solids Liquids Emissions into the air during uncontrolled burning (plastic, e-waste)

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The 9 new POPs: At its fourth meeting in 2009, the COP decided to amend Annexes A, B and C of the Convention by adding the following chemicals:

– Chemical– Annex– Specific exemptions / acceptable purposes

S. # The Nine (9) New POPs Pesticides Industrial chemicals

By-products

1 Alpha hexachlorocyclohexane X X

2 Beta hexachlorocyclohexane X X

3 Chlordecone X

4 Hexabromobiphenyl X

5 Hexabromodiphenyl / Commercial Octabromodiphenyl

X

6 Lindane X

7 Pentachlorobenzene X X X

8 Perfluorooctane sulfonic acid, its salts and perfluorooctane sulfonyl fluoride

X

9 Tetrabromodiphenyl / Pentabromodiphenyl /Commercial Pentabromodiphenyl

X

Pesticides (Agriculture) Industrial (flame retardants) By-products

Chlordecone

Alpha/beta-HCH (hexachlorocyclohexane)

Lindane

Pentachlorobenzene

Endosulfan

Hexabromobiphenyl

Pentachlorobenzene

Perfluorooctane sulfonic acid

Perfluorooctane sulfonyl fluorid

HBDE/TBDE/PBDE

Alpha-HCH

Beta-HCH

Pentachlorobenzene.

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3.3. Stockholm Convention and Pakistan i. Adopted in May 2001, entered into force in May 2004.ii. Status of participation (2006): 151 signatures, 124 Parties.

Objective (Article 1): To protect human health and the environment from persistent organic pollutants. 3 groups of chemicals: Annex 1: Intentionally produced chemicals to be eliminated.

Annex 2: Intentionally produced chemicals with restrictions.

Annex 3: Unintentionally produced chemical.

The Stockholm Convention on Persistent Organic Pollutant (“Stockholm Convention”) came into force in May 2004. This is thereby the newest global environmental treaty in effect.

The objective is simply to protect human health from the impact of POPs. This refers both to direct and indirect effects, and thereby also by necessity includes any kind of release of POP into the environment, regardless of whether humans or animals are the most exposed groups.

12 chemicals are targeted by the convention, but the option to add more chemicals into the convention coverage is clearly stated in the convention text. The 12 POPs are grouped into thee categories:

i. Intentionally produced chemicals that the convention requires are be eliminated.

ii. Intentionally produced chemicals that the convention still allow restricted use of.

iii. Unintentionally produced chemical, the generation of which is to be eliminated as far as possible.

Pakistan adopted the conference on 6th Dec 2001 as a participant and signatory

The ratification or implementation in Pakistan after the approval of parliament occurred on17thApr 2008.

Chemicals Targeted – The “Dirty Dozen” The “Dirty Dozen” is the nickname for the 12 particularly nasty cancer causing POPs targeted by the Stockholm Convention. While many countries have banned the pesticides on the list, urgent action is needed to tackle the industrial chemicals, by-products and stockpiles.

1. Aldrin: Pesticide used to protect crops from soil insects.

2. Chlordane: Pesticide used to protect crops from termites.

3. DDT: Pesticide used on crops for vector control. Used on troops during WWII to stop malaria, typhus and other diseases.

4. Dieldrin: Pesticide used to control of insects and disease vectors.

5. Endrin: Pesticide used on field crops and to control rodents.

6. Heptachlor: Pesticide used against soil insects and termites.

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7. Hexachlorobenzene (HCB): Pesticide and industrial by-product released when plastics are manufactured.

8. Mirex: Pesticide used against various ants, termites, wasps and bugs. Also used as a fire retardant in plastics, rubber, paint paper and electrical goods.

9. Toxaphene: Pesticide used on cotton, grains, fruits, nuts and vegetables, and to control ticks and mites in livestock.

10. Polychlorinated biphenyls (PCBs): Industrial chemical used in heat exchange fluids, paint additives, carbonless copy paper, plastics and various other industrial applications. Released as by-product.

11. Dioxins: Chemicals produced unintentionally due to incomplete combustion, as well during the manufacture of pesticides and other chlorinated substances. They are emitted mostly from the burning of hospital waste, municipal waste, and hazardous waste, and also from automobile emissions, peat, coal, and wood.

12. Furans: Persist in the environment for long periods, and are classified as possible human carcinogens. Food, particularly animal products, is the major source of exposure for humans.

So far, the Stockholm Convention is mainly covering pesticides (so perhaps less tailored to industry), but the Convention already has clauses for copying with other chemicals (this will be explained later during this session).

S. # POPs – The Dirty Dozen Pesticides Industrial chemicals

By-products

1 Aldrin X

2 Chlordane X

3 DDT X

4 Dieldrin X

5 Endrin X

6 Heptachlor X

7 Mirex X

8 Toxaphene X

9 Hexachlorobenzene (HCB) X X X

10 Polychlorinated biphenyl (PCBs) X X

11 Chlorinated dioxins X

12 Chlorinated furans X

Inception Report and Action Plan, UNDP POPs Project Page 16

Requirements for different kinds of POPANNEX A - Each Party shall prohibit and/or take the legal and administrative measures necessary to ELIMINATE:

Its production and use of chemicals in Annex A; Its import and export of chemicals in Annex A.

ANNEX B - Production and use of chemicals in Annex B should be ELIMINATED, EXCEPT FOR “acceptable purposes”:

Currently listed: only DDT used for disease vector control. Industry must cease production of new PCBs immediately; Industry must eliminate use of in-place PCB equipment by 2025; Industry must achieve the environmentally sound management of PCB wastes as

soon as possible and latest by 2028.

ANNEX C - Parties are to take measures to MINIMIZE or ELIMINATE releases of the unintentionally produced POPs.

Unintentionally produced POPsManufacturing process where use of chlorine-containing materials is essential:

o Pulp & paper (bleaching)o Chlorinated chemical productions (synthesis of chlorinated aromatic chemicals,

chlorinated solvents, PVC, ..)o Oil refining and catalyst generation

Production application/use with chlorine-containing materials:o Preservation of wood, leather, textileso Textile and leather dyingo Industrial bleaching processeso Processes which involves solventso Water and wastewater disinfection

Thermal processes with chlorine-containing materials incidentally present Other thermal processes

o Metallurgical process, primary and secondary processes (Cu, Fe, Al, Zn)o Coke production and carbo-chemical processeso Mineral processing; especially cement kilns

Controlled combustion processes:o Waste incinerationo Coal and oil combustiono Landfill gas/biogas

To reduce release of POPs BY-PRODUCTS, each Party shall:

Inception Report and Action Plan, UNDP POPs Project Page 17

i. Develop and implement an action plan to evaluate release and then take steps to address them;

ii. Promote application of measures to achieve realistic and meaningful levels of release reduction or source elimination;

iii. Promote development and use of substitute or modified materials, products and processes to prevent release of POPs.

To manage STOCKPILES and WASTE, each Party shall:

i. Develop strategies for identifying stockpiles, products and wastes containing POPs;ii. Manage POPs stockpiles and wastes in an environmentally sound manner;iii. Dispose of POPs wastes in manner consistent with international rules;iv. Disposal that recycles POPs is not permitted;v. Transport of POPs wastes is not permitted without taking into account international

rules.

3.4. National Implementation PlanParties to the Stockholm Convention are required to prepare a plan on how they are going to implement the obligations under the Convention and make efforts to put such plan into operation.

The National Implementation Plan (NIP) is not a standalone plan for the management of POPs but is a part of a national sustainable development strategy of the Party preparing and implementing such plan.

Also, the national implementation plan is a dynamic document as it is to be reviewed periodically and updated to address new obligations under the Convention.

NIP Development, Review, and Updating – Summary of PhasesThe process of developing, reviewing, and updating a NIP can be subdivided into five phases:

i. Establishment of a coordinating mechanism and organization processii. Establishment of POPs inventories and assessment of national infrastructure and

capacityiii. Priority assessment and objective setting iv. Formulation of the NIP v. Endorsement and submission of the NIP

3.5. The situation of POPs Stockpiles in PakistanBased on the inventory survey conducted during the NIP preparation, there are approximately 6033 MT of obsolete stocks of POPs pesticides (3800 MT Punjab, 2016 MT Sindh, 48 MT KPK, 135 MT Balochistan, 31.5 MT AJK and 0.5 MT Northern areas). Large stocks of obsolete pesticides are situated in areas of intensive cash crops/ agricultural activities.

Since stockpiles are located in towns or villages and near water bodies, there are potential human health and environmental risks. In 2010, a disastrous flood affected some of the areas where pesticide stockpiles are located, therefore the existence of these stockpile (has been

Inception Report and Action Plan, UNDP POPs Project Page 18

recently) reconfirmed by site surveys. The initial information consisted in media reports informing that some of the pesticide stocks in Balochistan (Pasni), Punjan (District Muzaffargarh) and Sindh (Khairpur) were washed away during the floods. Indeed, most of the warehouses and stores of pesticides have very old and poorly developed infrastructure that is currently in very fragile condition as has also been observed during the site visits carried out under PPG activities to District Rahim Yar Khan, Bahawalpur and parts of Sindh province that a large proportion of the pesticides was leaking into soil during the heavy rains causing environmental pollution. As explained in other parts of this document, the site surveys carried out during PPG activities were independently carried out by UNDP still in course of verification and endorsement by the government. In any case, the risk that these hazardous chemicals may enter the environment because of further floods are significant and to destroy these stockpiles in an environmentally sound way is an extremely urgent task.

The inventory survey of POPs stockpiles carried out in 2004-2005 – mainly based on information dated back to 1970s and 1980s - during NIP preparation delineated the following situation:

In Punjab a total of 167 stock piles have been reported which contain 3800 tons of POPs pesticide

In Sindh, 2016 tons of POPs pesticides are reported. The biggest dump was reported to be in Provincial Store, located in Malir city, Karachi that contained about 400 tons of obsolete pesticides; however Hyderabad holds largest stock pile of POP pesticides.

In KPK, presence of Dieldrin is reported in the custody of Agriculture Officer Nawagai Circle Store, contained in two iron drums about 25 km away from Daggar.

In Balochistan, the presence of large quantity of the POPs pesticides has been reported in the stores of the public sector Departments at Quetta. The stock piles mainly contain Eldrin, Dieldrin, Endrin, Heptaclor, Chlordane and BHC. However, few small quantities of BHC & Dieldrin are reported at Loralai, Ziarat and Dera Murad Jamali. The exact quantity of the B.H.C has not been measured as it is very difficult to do so due to poor storage conditions.

DI Khan District works as transportation route of POPs pesticides smuggled items from Iran via tribal areas through Afghanistan due to its geographical location.

In Azad Jammu and Kashmir (AJK) 31.5MT and in the Northern areas 0.5MT of POPs pesticides have been reported.

Comparison of the POPs pesticide stockpiles between 2014 and 2004-05 in PakistanIn the course of project preparation activities, site visits to the pesticide stockpile areas were conducted by UNDP consultants to verify the status of the stockpiles and update – on the basis of visual inspection and collection of data and records – the amount of POPs and obsolete pesticides still stored.

During recent site visits, it was found that a large part of pesticide dumps were displaced from 1994-97. However, some of the major sites in Sindh, Punjab and KPK have been visited to reconfirm. These sites still contain major stocks of POPs pesticides as well as PCBs contaminated equipment due to agro-industrial activities that have been and are currently taking place in these areas. The pesticides stocks visited in KPK are intact but a large part was also either leaked or stolen. The condition of stocks is highly dilapidated. DPP has assured to provide some quantitative data that is still awaited. These data may not be accurately available except the best estimates as made by the Department of Plant Protection. Due to financial as well as management issues, DPP has not been able to update the data. The data available was

Inception Report and Action Plan, UNDP POPs Project Page 19

mostly collected during 1970s and 1980s and very little could be updated of only some of the sites.

In the summary table reported below, the outcome of this survey are summarized. Some of stocks were reduced in volume or disappeared altogether due to poor storage infrastructure, leakage in the soil, intermittent theft for relabeling and resale for control of household pests and also due to planned transportation and dumping in the desert areas of Cholistan, Mianwali and Dera Ghazi Khan. During recent site surveys, some of these sites have also be located. In few cases, the survey evidentiated larger amount of chemicals compared to the previous estimates, either because of likely underestimation on the previous survey, or because of actual increase of chemicals collected and stored in these sites.

Independent Evaluation of sites by UNDP POPs Inventory by GOP-MOCC

Province District/Location Reported Quantity

2014 2004-05

Punjab Lahore (Walton & Dharampura)

Plant Protection Department

100 Tons 43 Tons (Reported during different surveys)

Rawalpindi (Murree Road-Data Gunj Baksh Road, Plant Protection Department)

N.A (The store could not be opened)

N.A (No data incorporated in the inventory)

Bahawalpur

(Opposite to Baghdad Railway Station), Plant Protection Department

1,000+ Tons 42.1 Tons

Rahim Yar Khan

(Lakki Wala Farms, Chak-101), Plant Protection Department

500+ Tons 10.8 Tons

Sindh Karachi (Malir Halt)

Shifted and dumped in Thatta (Gharo) during 1994-97. Now Malir District Court established at the same site.

20 Tons and 15,425 liter

Hyderabad Official infrastructure 2 Tons

Inception Report and Action Plan, UNDP POPs Project Page 20

Maksim Surkov, 11/26/15,
Does it mean these are POPs only, or POPs and other organic pesticides?
Maksim Surkov, 11/26/15,
Careful study might be needed to update information – especially on the area of contaminated soils.For the latter, we might need to think about some project opportunities on soil remediation depending on scale of contamination.GEF prefers only technology demonstration programmes and backed by cash co-finance to help with full treatment of target soils.

raised on the store site

Nowshero Feroze, Kandiaro, Benazirabad, Sukkur, Larkana (Agricultural Extension Department, Sindh)

800 Tons

still intact stores with obsolete pesticides of the Provincial AEDs

Nowshero Feroz (78.3 Tons)

Kandiaro (1.2 Tons)

Benazirabad/Nawabshah (22.6 Tons)

Sukkur (9.4 Tons)

Larkana (37.3 Tons)

Balochistan Quetta, Brewery Road

Still intact store with obsolete pesticides mostly with BHC stocks. 2 trucks of Malathion recently added

Quetta 49 Tons,

Pasni Few Kgs, mostly BHC stocks but washed away during floods of Shadi Core dam

NA

Gawadar, Turbat, Panjgur

15 tons. Stores are still intact

(Pangur 102 Tons)

(Turbat 94 Tons)

KPK AED Tarnab Farms, Peshawar

6.3 tons still intact in the store

400 Ltr.

Nowshera at DDT Factory site

Site demolished and converted into housing society. Stocks dumped near Kabul River and some in Nizampur area

NA (No data incorporated in the inventory)

PPD, Jamrud Road, Peshawar

Obsolete pesticides stock still available but in highly dilapidated form

NA (No data incorporated in the inventory)

Most of the stocks with AED Department, KPK

Dumped at barren sites; some along Kabul River and Nizam pur area.

N.A

It is important to underline that the comparison of obsolete / POPs contaminated pesticide stockpiles has been prepared through an independent third party evaluation conducted by UNDP Pakistan for the purpose of ProDoc preparation. However, it still needs endorsement by

Inception Report and Action Plan, UNDP POPs Project Page 21

the relevant Departments of Government of Pakistan that is in process. In addition to this, some of the sites in District Bahawalpur (Cholistan desert, Yazman Mandi), District Mianwali (Satrah) and District D. G. Khan have been identified where obsolete / POPs contaminated pesticides were dumped at different intervals that also need government endorsement. There is no proper record of thousands of tons of the obsolete / POPs contaminated pesticide stocks available with pesticide dealers and some of the pesticide companies. This indicates that there is a clear need to examine the cause of data gap as well as to identify and secure POPs stockpiles for storage and disposal.

There are several gaps with regard to POPs-pesticides management in the country. These include: inadequate policies, lack of implementation mechanism, lack of planned monitoring and poor legislation to govern POPs-pesticides management, monitoring, search for suitable alternatives, liability for POPs waste disposal and remediation of sites contaminated with POPs, public information dissemination, education and awareness.

There are no guidelines to guide POPs waste management and remediation of POPs contaminated sites. All the gaps that were individuated at NIP preparation stage were reconfirmed in the recent fact finding mission carried out in the course of project preparation. These are:

Weak enforcement of the existing legislation relevant to POPs management; Inadequate capacity and experience for tracking human and environmental effects

caused by POPs and their alternatives; Few institutions have laboratory facilities and trained personnel that can facilitate

monitoring of POPs and their alternatives; these laboratories run usually on project basis, therefore the specialized personnel leave at the end of the project, and very often the equipment is left unused for years;

Other deficiencies include: limited research on alternatives of intentionally produced POPs, poor documentation system of POPs information both in the private and government institutions and lack of awareness at all levels.

Also there is lack of planned information dissemination strategy to inform the public on POPs issues and weak mechanism to facilitate coordination and reporting on POPs issues

Country Status and Issues– Inadequate legal provisions on POPs production, screening, importation, use and

disposal of their waste. Also on identification, liability and management of contaminated sites;

– Weak enforcement mechanisms, for example on disposal of wastes; illegal imports of POPs pesticides etc;

– The Plant Protection Act does not address detailed framework for the identification and quantification of pesticides stockpiles;

– Lack of legal provision focusing on public awareness on health and environmental risks associated with POPs

– Lack of adequate legal provision for monitoring of POPs release and their effects to human environment;

– There are no legal provisions focusing on POPs life cycle.– Inadequate awareness of importers and custom officers on imports requirements;– Inadequate information on the past production, use, import and export;– Lack of continuing education to update skills for evaluation of technical data submitted

during registration of pesticides;

Inception Report and Action Plan, UNDP POPs Project Page 22

Maksim Surkov, 11/26/15,
Hope it has not resulted in illegal dumping causing soil contamination

– Lack of specialized skills and analytical equipment for identification of undeclared pesticides ingredients and monitoring of POPs levels;

– Inadequate POPs inspectorate services;– Lack of guidelines on risk minimization procedures for handling, transportation, storage

and disposal of obsolete stocks;– Inadequate specialized skills, financial resources, equipment and working tools by

respective institutions dealing with POPs;– Poor storage facilities and inappropriate disposal facilities;– Improper disposal of empty containers of pesticides and PCBs equipment;– Very few studies and little data on POPs environmental and health impacts;– Poor information exchange and data keeping;– Inadequate resources for dissemination of information on the viable POPs alternatives;– Lack of resources to ascertain suitability of alternatives and assess their risks to human

health and the environment;– Inadequate resources to support preparation and execution of training and awareness

raising programs;– Lack of socio-economic and cultural studies on the acceptability and affordability of

alternatives; and– Inadequate record keeping of inventories for all POP

3.6. Pakistan National Implementation Plan on POPsi. Phased elimination of 167 sites, with a total of 3,600 MT of obsolete POPs containing

pesticides, with immediate action given to sites causing public nuisance.ii. In coordination with the Federal authorities and other Provincial governments,

undertake a market survey of illegal POPs pesticides, with a view to identifying :(i) the pesticides involved in illegal use,(ii) the extent of the problem of illegal use, and (iii) the possible origin of illegal POPs pesticides.

iii. Undertake a survey of the PCBs content of (i) leaking transformers still in use, (ii) transformers in-service, (iii) contaminated sites, including transformer reclamation workshops.

iv. Establish environmentally sound and safe storage facilities for used PCB oils and PCB contaminated equipment.

v. Develop and implement an environmentally sound management plan for (i) domestic waste, (ii) medical/hospital waste, and (iii) industrial waste**

vi. Develop and implement POPs issues awareness programmes for the public and relevant sectors**

vii. In consultation with Federal authorities, consider if any Provincial or Local Authority legal action is required in relation to regulatory action to implement the Stockholm Convention.

Inception Report and Action Plan, UNDP POPs Project Page 23

Provincial Level Actions: PUNJAB: Phased elimination of 167

sites, with a total of 3,600 MT of obsolete POPs containing pesticides, with immediate action given to sites causing public nuisance

KPK: Phased elimination of 3 sites, with a total of 49 MT of obsolete POPs

SINDH: Phased elimination of 205 sites, with a total of 2016 MT of obsolete POPs

BALOCHISTAN: Phased elimination of 5 sites, with a total of 136 MT of obsolete POPs

viii. Collaborate with Federal and other Provincial authorities, in implementing harmonized data collection and management as required under action plan

ix. Promote the development of human resources required at Provincial level to implement the NIP∗.

x. Actions for the Medium term (5 to 10 years)xi. Phased implementation BAT and BEP for specific industrial processes, initially for (a)

production of chemicals and consumer goods, (b) Steel melting & Rerolling (c) Electricity Generation + Transmission.

xii. Actions for the long term (10 years and beyond)xiii. Decontamination and rehabilitation of sites contaminated with POPs, particularly

PCBs and POPs pesticides.

4.

Inception Report and Action Plan, UNDP POPs Project Page 24

4. REGULATORY POLICY AND ENFORCEMENT SYSTEM TO REDUCE POPs RELEASES

4.1. Agriculture Sector – POPs Management (Regulation, Authorization and Enforcement and Inspection) Agriculture holds great significance for Pakistan. The total area of Pakistan is 79.61 m. ha and from that, the surveyed area is 57.07 m. ha. Cropped area is 23.13 m. ha (40%). Moreover, in this cropped area, 19.02 m. ha (33%) is irrigated and 4.11 m. ha is un-irrigated. Forest covers 4.02 m. ha (7%) and the culturable waste is 8.12 m. ha (14%). In this sector, Agricultural Pesticides Rules 1973 was enacted by the GoP in 1973. The rules give the detailed procedures for complying with the provisions of the main law. They contain provisions giving details of registration procedure and grounds for refusal to register. Certain pesticides including some POPs need to be labelled as Poison. The Ministry of National Food Security & Research, Government of Pakistan and its allied departments have established a comprehensive and tiered system of pesticides management, which is:

i. Pesticide legislation / regulation by Ministry of National Food Security & Research, Government of Pakistan

ii. Pesticide registration/authorization by Department of Plant Protectioniii. Pesticide facility licensing by Department of Plant Protectioniv. Pesticide enforcement/inspection by Department of Plant Protection as it regulates

pesticides through the Agricultural Pesticides Ordinance (amendment) Act 1992 & 1997, while the import of pesticides is exclusively in the private sector.

v. Pesticide health and environmental monitoring by Sindh Medical college & National Poison Control Centre (WHO Collaboration Centre) and Pakistan Environmental Protection Agency, Ministry of Environment, Islamabad.

vi. Pesticide research / testing by Federal / Provincial Pesticide Testing Labs.vii. Pesticide Training Extension by the Provincial Government and the technical staff of

the industry, The Provincial Secretaries of Agriculture and Director General, Director Generals of Provincial Research Institutes, Director General / Director Plant Protection of the all provinces and Integrated Pest Management (IPM) Programme

viii. Pesticide Industry Association including Croplife Pakistan, Pakistan Crop Protection Association

Inception Report and Action Plan, UNDP POPs Project Page 25

Scope:i. To control the import of substandard pesticides in the country.ii. To regulate the pesticide policy and practices.iii. To provide an appellant forum to the pesticide manufacturer, distributors and retailers by

counter analysing the samples in Federal Pesticide Testing & Reference Laboratory.iv. To monitor and keep a record of the pesticide availability position in the country.

Pesticide Policy in Perspective:

Until 1971 Pesticides import was carried out by the Federal Govt. and distributed among farmers through the provinces

1971 Since promulgation of the Agricultural Pesticides Ordinance 1971, read with (Amendment) Act 1992 & 1997 & Agricultural Pesticides Rules 1973 framed thereunder, the Department of Plant Protection, Ministry of National Food Security & Research (formerly Ministry of Food & Agriculture) is regulating import and standardization of pesticides.

Inception Report and Action Plan, UNDP POPs Project Page 26

Enforcement of Plant Quarantine Act 1976 and Agricultural Pesticide Ordinance 1971

Regulatory

Locust surveyCrop pest control by airTraining of locust and other staffSurvey/Control

Advise the Government on allaspects of plant protection incluing international obligations.

Advisory

Disinfestations of fruit pests like Fruit fly with Vapor Heat Treatment plant.

Research

1980 Subsidy abolished and Trade Shifted to Private Sector

1992 Introduction of Liberalized Import Policy

Responsibility:Federal Govt. (Department of Plant Protection)

i) Standardization & import of pesticides through registration.

ii) Quality control at import stage

iii) International obligations & regulatory affairs

iv) Appeal cases for quality control

Provincial Govt.

i) Registration of pesticide distributors & dealers

ii) Quality control through monitoring, inspection and analysis of pesticides in Provincial pesticide laboratories

iii) Efficacy trials of the pesticide at Research Institutes for two crop seasons.

iv) Standardization of product

4.2. POPs and the Health Ministry (Malaria)The prevalence of malaria is the highest in Pakistan, particularly in FATA, KPK and Baluchistan and use of public health pesticides are very common is the biggest threat. Similarly use of Public Health Pesticides (PHPs) for control of VBDs in Pakistan is very common and it has a long history. In 1952 Malaria Board was established and Pakistan joined Global Malaria Eradication Campaign in 1959. The Use of DDT was key PHPs through IRS (Blanket Spray). The ME campaign was extremely successful till 1965 (API Dropped from 19/1000 to 0.9/1000). In 1968, Malaria Resurgence & Regional Epidemic 1972 (Resistance in mosquitoes against DDT), and despites this DDT continued to be used. Later in 1979 Pakistan Banned DDT, however BHC & Dieldrin were used for malaria control till 1985. In the very next year i.e. 1986, Organophosphate (Malathion) was introduced but its effectiveness was reported as short-time-Resistance 1989-1992. In 1995, Pyrethrpid (Deltamethrin, al-cypermethrin, permethrin, cyhalothrin etc) was introduced and OP are still being used for the control of larval stage of malaria vectors (anophelines). For two decades Pyrethroids are being used for the control of vectors of public health importance. Currently there is no production, import and use of DDT, BHC & Dieldrin (POPs) in public health in Pakistan

POPs and MOs Health: Contribution

Inception Report and Action Plan, UNDP POPs Project Page 27

i. M/o Health is strongly committed to implement the recommendations of Stockholm Convention through its attached departments (DoMC)

ii. DoMC is the key department of M/o Health for use of PHPs in Pakistan and taking all necessary actions to protect environment from POPs

iii. In 2010/11DoMC conducted nation-wide survey to review the susceptibility level of local vector species against all 4 groups of insecticides including DDT and Dieldrin In Sind and Punjab, malaria carrying mosquitoes showed resistance against DDT,

Dieldrin In FATA & Balochistan: 100% susceptible to DDT However, on technical grounds and management issues DoMC-Pakistan is NOT

promoting the use of DDT, and Dieldrin in public health in Pakistan. iv. National IRM Decision Making Body 2015v. TACOM 2013/14vi. National IRM strategy 2014vii. Revision National Implementation Plan (NIP) 2015viii. Declaration/nomination of National Focal Point ix. Promotion of public health awareness and education x. Development of Quality Assurance Protocol for handling of pesticides (storage,

transportation & Disposal) xi. Reporting on POPs (2012-2014)

Challenges and Way Forwardi. Fragile coordination for sharing of information between all line departments &

stakeholders ii. Establishment of inventory of POPs iii. Preparation of inventory of contaminated sitesiv. Identification of stockpiles of obsolete pesticides v. Lack of Disposal Facilities of obsolete pesticides vi. Financial constrains for regular meetings of TACOM; National IRM Decision Making

body vii. Lack of awareness

4.3. Role of NARC in POPs-Pesticides Management National Agricultural Research Centre (NARC), Islamabad established in 1984, is the largest research centre of the Pakistan Agricultural Research Council (PARC). NARC established its Ecotoxicology Research Programme (ERP) in 1993 to monitor fate of pesticides residues in the environment, evaluate their implications on non-targeted beneficial species and to study occupational and accidental exposure to these chemicals. In addition to this, different projects on pesticide residues and their implications has been accomplished with PPD Denmark (Inter-lab. Comparison, CIPAC (Collaborative studies on Benfuracarb), Food and Agriculture Organization (3 projects, pesticide residues and human health risk), European Union (Colonial waterbirds), WWF-Pakistan (Fresh water pollution in cotton belt), Pak-EPA (POPs Enabling activities) , HEC/AMC (Tobacco belt in KPK), PARC/RADP (Cotton belt Multan Division). Current NARC is implementing 5-years (2014 –2019) PSDP Project on National Pesticide Residues Monitoring System in Pakistan

Trend of Pesticides use in Pakistan: The survey study conducted by NARC indicating the following trends of pesticides use in Pakistan.

Inception Report and Action Plan, UNDP POPs Project Page 28

Pesticides Related Issues:i. Environmental Implications (Pollution, Environ. degradation, Extinction of biodiversity)ii. Human Health Risks (Occupational, Consumer, Intentional/Unintentional)iii. Trade Concerns (WTO, SPS & TBT measures)iv. Pest Resistance

POPs-Pesticides residues in Soil and Water from Selected Obsolete Pesticide Stores in Pakistan (POPs-Enabling Activity)Soil samples were collected from the obsolete pesticide store rooms and courtyards while surface and groundwater samples were collected from the nearby sources.

Sampling Sites:KP: Nowshera, Bunair, and D.I. Khan;

Punjab: Faisalabad, Multan, Lodhran, Ahmadpur Sharqia, Sahiwal, Kalashakaku, Wazirabad and Simriyal;

Sindh: Karachi, Hyderabad, Nawabshah, Dadu, Larkana, Khairpur and Nara

Status of POPs Pesticides in Soil Samples from Hotspots of Pakistan:

Inception Report and Action Plan, UNDP POPs Project Page 29

Occurrence (%) of POPs Pesticides in Water Samples from Hotspots in Pakistan

EU-Project: Colonial Waterbirds as bio-indicator of Pollution (Italy, Spain and Pakistan)

Study areas:

Industrial/Urban Pollution

Agricultural/Rural Pollution

Relatively Less Pollution

Contamination Levels (ug/g) of POPs in different matrices:

Inception Report and Action Plan, UNDP POPs Project Page 30

Inception Report and Action Plan, UNDP POPs Project Page 31

5. POPs PROJECT AND PROVINCES This session involved briefings from Provincial EPAs on the management of POPs at provincial level. The Provincial EPAs also discussed issues, concerns/ challenges and support needed for the better enforcement and management of POPs. The province wise discussion led by Provincial EPAs is as under:

5.1. EPA Punjab: Punjab has already consolidated inventory of POPs stockpiles from 28 districts, however the consistency and reliability of data is still a challenge. There is a strong need for development of methodology and local capacities to first validate this data on POPs stockpile so it is finalized and accepted by all stakeholders. In addition, support is requested from UNDP POPs project on awareness raising on the issue and promoting string engagement with private sector.

5.2. EPA AJKThe EPA AJK raised their willingness to formally engage with UNDP POPs project on the initiative. They also requested for Assurance that they are on board. EPA AJK was also advised and requested to quarantine imported fruit and chilies from India as it contains pesticides. Also EPA AJK is requested to take random sample from imported fruits and other eatables for inception.

5.3. EPA – Sindh EPA Sindh informed that after 18th amendment Sindh was the first province to make the Sindh Environment Protection Act. Section 2 defines hazardous substance and POPs are included in that. The issue was raised that no survey has been conducted yet in Sindh to identify the quantity of POPs stockpiles and if there are any statistics on this, these should be shared with Federal Government and UNDP POPs project for implementation of project activities. The EPA Sindh informed that currently about 205 stockpiles are relocated and probably to Maleer Port but no one knows how they were transported from there. Need was identified to develop a proper mechanism/ system and guidelines to collect, transport and dispose POPs.

5.4. EPA Gilgit-Baltistan EPA G-B was established in 2008 and it has identified 0.5 M. Tones of POPs stockpiles, however these are not the confirmed numbers as the methodology and source of this is not known. The EPA G-B also requested UNDP POPs project to build the capacity of local staff on identification, testing, inception and management of POPs.

Inception Report and Action Plan, UNDP POPs Project Page 32

Maksim Surkov, 11/26/15,
I assume this relates to product quality monitoring by sanitary inspections. What kind of implications does it plan to have for the project?

6. PARTICIPATORY ACTION PLAN FOR POPs PROJECT The Inception Workshop involved instigating discussion on the issue of POPs, its causes and role of various departments/institutions in the development and enforcement implementation of a regulatory, policy and enforcement system to reduce POPs releases and to regulate POPs waste disposal, capacity building of stakeholders to reduce exposure to and releases of POPs, collection, transport and disposal of 300t of PCB and 1200t of POPS Pesticides, and, in improving monitoring, evaluation, learning and adoption of the project. The discussion led to the development of a comprehensive plan for UNDP POPs project which will be implemented by the project but in close coordination and consultations with stakeholders. The Action Plan emerged from the Inception Workshop includes the following priority areas:

Component 1: Development and implementation of a Regulatory, Policy and enforcement system to reduce POPs releasesThe activities involved strengthening of POPs regulatory and policy instruments and its adoption by Government enforcement agencies and other organizations involved in regulating POPs management. Specific activities include:

i. Development of a POPs (PCBs) related National Legislation Developed;ii. Training on improving PCB inventory and technical capacity for Environmentally Sound

Management (ESM) of PCB equipment and materials;iii. Development of National Technical POPs (PCBs) Management guidelines and training

of relevant stakeholders on these guidelines;iv. Compilation, updation and elaboration of data and chemicals profile for Pakistan; and,v. Situational Analysis on National Legislation for POPs PCB

Component 2: Capacity building of local communities and public and private sector stakeholders enhanced to reduce exposure to and releases of POPs.The proposed activities involve capacity building of Governance, enforcement agencies and communities in controlling POPs. Specific activities are:

i. Training of staff from central and Provincial level administration on enforcement of POPs related provisions;

ii. Training and awareness raising on POPs pesticides among key target groups, such as decision makers, staff in high/risk occupations etc.;

iii. Training of institutes, laboratories and communities on POPs (Pesticide) issues

COMPONENT 3: Transport and Disposal of PCBS and POPs PesticidesThis involves improving the physical capacity of relevant provincial authorities and institutions to undertake environmentally safe disposal of particularly risky POPs stockpiles and the sound disposal of POPS Pesticides and PCBs. Specific activities proposed were:

i. Reconfirmation and inventory development of amount & location of POPs stock piles In Sindh & Baluchistan, including mapping of priority sites;

ii. Development of TOR for selecting the vendor for disposal / transportation/handling;iii. Safe disposal (handling/ transportation) of 600 MT POPs stockpile from Punjab Province

COMPONENT 4: Monitoring, Learning, Adaptive feedback and Evaluation This involves numerous activities to continues learning, adoption and consultative process during the implementation of the project and afterwards. Specific activities proposed were:

Inception Report and Action Plan, UNDP POPs Project Page 33

Maksim Surkov, 11/26/15,
The overall target is more than double this 600 tons and includes PCBs – has to be corrected.Also see previous explanation on the cement kilns business – using the draft TOR currently the recruitment of international expert has to start to guide the national team and the government through this process properly.

i. Regular Project Technical Review Meetings;ii. Interactive website development and its regularly maintenance/ updation; iii. Regular field visits and meetings by the Project staff and UNDP staff; and,iv. Learning and training visit of NPD, Project Staff and DG EPA Punjab for BAT / BEP of

POPs.

Inception Report and Action Plan, UNDP POPs Project Page 34