SAFER USE ACTION PLAN (SUAP)

Phosphine Gas Fumigation Management Plan (FMP)

Prepared by:

Md. Abdur Rashid Advisor - Environment

Advisor - Environment

SHOUHARDO III, CARE Bangladesh

Revised date: 04/25/2017

USAID APPROVAL OF ENVIRONMENTAL ACTION(S) for SHOUHARDO Ill:

Food for Peace, Mission (or Regional O ffice, as appropriate*):

Food for Peace Officer* Date: -------

J .2 / o I / :(o I 6

Food for Peace, Washington:

Agreement Officer's Representative ____________ Date: ______ _

DCHA Bureau Environmental Officer Date: ------------ ------~

Regional Environmental Officer** -------------Date:-------

* FFP/MIR environmental officer clearance is mandatory; clearance by the FFPIM/R FFP officer is optional. **REO clearance is optional.

2

1/20/2017 Correo de Sun Mountain International LLC - Fwd: SHOUHARDO III SUAP

https://mail.google.com/mail/u/1/?ui=2&ik=8813a818a3&view=pt&search=inbox&msg=159b898c929b9c8a&dsqt=1&siml=159b898c929b9c8a 1/4

DCHA GEMS Support <dchagemssupport@smtn.org>

Fwd: SHOUHARDO III SUAP

Erika Clesceri <eclesceri@usaid.gov> 19 de enero de 2017, 18:18Para: Sultana Rebeka Akhter <sakhter@usaid.gov>Cc: Tofayel Alam <talam@usaid.gov>, Mahbub Zaman <mzaman@usaid.gov>, Sabinus Anaele <sanaele@usaid.gov>,Kristin Childress <kchildress@usaid.gov>, DCHAGemsSupport@smtn.org, "Clesceri, Erika(DCHA/FFP/PTD)"<eclesceri@usaid.gov>

Dear Rebeka,

please accept my apologies, but I missed this email when you sent it earlier. Digging ou my emails from my break over theholidays. For continuity, please always CC the BEO Backstoppers at: DCHAGemsSupport@smtn.org

With kind regards to you, Erika 

Erika Clesceri, Ph.D. DCHA Bureau Environmental Officer (BEO)Bureau for Democracy, Conflict and Humanitarian AssistanceU.S. Agency for International Development Washington DC (USA)(w) 202­712­0453, eclesceri@usaid.govDCHA BEO Google Site 

On Tue, Jan 3, 2017 at 11:52 PM, Sultana Rebeka Akhter <sakhter@usaid.gov> wrote: Dear Tofayel Bhai Attached is the MEO reviewed SUAP for your further action. I hope it will now clarify your question.  Addressing comments in Track Change version is highly suggested.     Thanks On Tue, Jan 3, 2017 at 4:13 PM, Sultana Rebeka Akhter <sakhter@usaid.gov> wrote: Dear Tofayel Bhai Attached is the MEO reviewed SUAP for your further action. Please feel free to come to me for any clarification.  Addressing comments in Track Change version is highly suggested.     ThanksRebeka  On Mon, Dec 26, 2016 at 9:39 AM, Sultana Rebeka Akhter <sakhter@usaid.gov> wrote: Dear Tofayel Bhai As of today I have received EMMP and SUAP from your end. What's about FMP? ThanksRebeka    On Thu, Dec 22, 2016 at 2:45 PM, Tofayel Alam <talam@usaid.gov> wrote: Hi Rebeka, Please find attached the SUAP for the pest management plan for CARE SHOUHARDO III program. 

SAFER USE ACTION PLAN (SUAP)

Phosphine Gas Fumigation Plan (FMP) 1. Background Description of SHOUHARDOIII Program The program has the provision of managing by direct delivery roughly 13190 metric tons of wheat, vegetable oil and Yellow Split Peas over the period of FY 2016 – FY 2019, planned to be stored and distributed respectively 4320 MT in FY 16, 3300 MT in FY 17, 3920 MT in FY 18 and 1650 MT in FY 19 as the assistance to address key behavioral and systematic constraints related to food availability, access and utilization underlying socio political issues that bear upon the abilities of individuals and communities as well to exercise rights and make decisions impacting their lives and livelihood. CARE Bangladesh in managing the program food commodity selected 8 warehouses which will be used for regular dispatches, stacking, handling and delivery of food/nonfood commodities as per the field distribution plan and requirements. As per logistic plan, the food commodities will be unloaded through Chittagong port and Transport to each region for storing in district and Upazila level warehouses prior to the distribution at beneficiaries level. Local private transport agency has been assigned for transportation of commodity to the all Warehouses and Food Distribution Points (FDP). Again, storing at the district and Upazila level, fumigation, transportation and delivery including internal delivery up to the FDP will be doing by aforesaid regional offices of CARE Bangladesh with local level commodity management staff and community based organizations or groups. 2. Fumigation PERSUAP from SHOUHARDO II (approved August 3, 2011): The SHOUHARDO III program has requested and received USAID approval to follow the Fumigation PERSUAP approved for the predecessor project. Below summarizes the program-specific requirements for safer use, including the template for the Fumigation Management Plan (FMP) that will be completed with each fumigation event. Fumigation PERSUAP from SHOUHARDO II: http://gemini.info.usaid.gov/document.php?doc_id=37615. 3.1. USAID Fumigation PEA: With the approval of the “Commodity Protection in USAID Food Assistance Programs by Phosphine Fumigation” Programmatic Environmental Assessment (“Fumigation PEA”), USAID for the first time will have uniform, mandatory environmental, health and safety requirements regarding phosphine Fumigation of food commodities. USAID Fumigation PEA: http://www.usaidgems.org/fumigationpea.htm The Fumigation PERSUAP from SHOUHARDO II complied with the USAID Fumigation PEA, and SHOUHARDO III will use this same Fumigation PERSUAP to meet Regulation 216.3(b), USAID’S Pesticide Procedures. In addition, the information provided herein and the Fumigation Management Plan (FMP) template provided below will be used by SHOUHARDO II. Additional guidance may also be sought by SHOUHARDO II directly from the USAID Fumigation PEA as necessary. 3.2. FMP Requirements for USAID Partners. Fumigation compliance requires USAID partners to complete a Fumigation Management Plan (FMP) for each fumigation event and to keep these FMPs on file for 2 years. SHOUHARDOIII recognized such compliance and will

prepare well ahead of each fumigation in all of the warehouses of the program. FMP compliance further requires that the plan and the fumigation event itself substantively confirm with the FMP template that follows. 3.3. Comply Key “safer fumigation” requirements per PEA: Fumigation Services RFQs and contracts require conformity with acceptable fumigation practices per annex T-6 of the USAID Fumigation PEA, including: • Required use of full faced canister respirators or self-contained breathing apparatus (SCBA), • Required hazard & efficacy monitoring, • Required maintenance of an exclusion zone for duration of fumigation event (7-10 days) each fumigation event must have a fumigation management plan (FMP) conforming to these practices. USAID partners shall enforce these requirements and take corrective actions as required. • Report on compliance with these requirements. • Have formal authorization under USAID’s environmental procedures to contract for (generally, “support”) such fumigation. These includes other necessary and relevant elements for safer fumigation work described in this document will carefully be followed and comply in the fumigation process of the SHOUHARDOIII program. 4. USEPA Registered and Approved Pesticides planned to be used on Warehouse Storage Commodities in SHOUHARDO III. 4.1. Legal and Policy Issues: The SHOUHARDO III Program has the concern of ensuring the uses of pesticides in case of storing food, wheat, vegetable oil and yellow peas (likely food and perishable and or non-perishable items) and also ensuring no or minimum effect of pesticides uses as well. In such case, because of risk concerns presented by pesticides, the USAID environmental regulations require that at least the 12 factors outlined in the pesticide procedures described in 22 CFR 216.3 (B) (1) (I) be addressed in the program that includes assistance for the procurement or use of pesticides. The Fumigation PERSUAP for SHOUHARDO II met this 12 factors requirement and is being adapted for use again with SHOUHARDO III. The pesticides listed herein are in compliance with the USAID approved Fumigation PERSUAP for SHOUHARDO II. 4.2. Analysis of Available Relevant Pesticides: In SHOUHARDO III Program, it is necessary to store commodities/food for direct distribution to target beneficiaries' includes food for work activities and for stockpiling of emergency relief materials for future disaster response. Commodities like wheat, yellow split peas and vegetable oil need to store in suitable / standard conditions during unloading of commodities from ships/vessel until the time of its distribution to beneficiaries' level. It is often necessary to store these commodities for up to twelve or few months in regional warehouses. To protect these commodities from the action of pests, it is necessary to use some of the recommended pesticides like Actellic, Agriphos, Dursban, Quick-Fume, Sanphos and Ustad are registered in the host country Bangladesh as well as in US EPA. [Status of these pesticides usually uses for storage of commodities are shown in Table 1and 2 respectively]. SHOUHARDO III, warehouse pest control activities for protection of stored agricultural commodities will be performed by trained and certified pest control exper t s . Products of those are approved in Bangladesh for control of pests in warehouses and its surroundings will be used by approved fumigators.

Actellic (generic name Pirimphos-methyl) is a USEPA (United States Environmental Protection Agency) - registered pesticide that is classified for “general use”. It is an organophosphate with a USEPA Toxicity Class of III (Caution). It controls a wide range of pests affecting grains and other stored products. It is a rapid acting chemical with a 7-day toxicity cycle and is effective in warm and humid climates. Actellic acts through fumigation and ingestion and has a low mammalian toxicity. Actellic is highly recommended for use on stored grains and is approved for this purpose in the Supplementary Environmental Assessment completed for USAID. It is registered by the

Department of Agricultural Extension (DAE), Ministry of Agriculture, for use on stored grains and is the least toxic of other available products. Previous experience by users has confirmed that it is the most effective product for this purpose. Agriphos, Quick-Fume and Sanphos (generic name Aluminum Phosphide) are USEPA-registered pesticide that is classified for “restricted use”. It is an inorganic Phosphide with a USEPA Toxicity Class of I (Most Toxic, Danger-Poison) and used as tablets, pellets and partially spent dust. It releases hydrogen Phosphide / Phosphine gas if it is exposed to moisture from the air or it comes into contact with water. It controls a wide range of pests affecting grains and other stored products. It is a rapid acting chemical with a 48-72 hrs. Toxicity cycle and is effective in warm and humid climates. This group of product acts through fumigation and ingestion and has high mammalian and nesting bird toxicity. Aluminum Phosphide is highly recommended for use on indoor agricultural food commodities, animal feeds, processed food commodities and non-food commodities (tobacco) as well as for outdoor fumigation for burrowing rodent and mole control. It is registered by the Department of Agricultural Extension (DAE), Ministry of Agriculture, Bangladesh, for use on stored grains and is the least toxic among other available products. Dursban (generic name Chloropyriphos) is a USEPA-registered pesticide that is classified for “restricted use”. It is an organophosphate with a USEPA Toxicity Class of II (Moderate Toxic-Warning). It is used as liquid form and effective for the control of a wide range of insect pests of commercial importance. It controls a wide range of pests and crawling insects affecting grains and other stored products. It is a rapid acting chemical with a dependence on the soil type; microbial metabolism of Chloropyriphos may have a half-life of up to 279 days and is effective in warm and humid climates. Dursban is used through high or low volume spraying and ingestion and has a low mammalian, birds and other organisms’ toxicity. Dursban is highly recommended for use on wide range of insect pests of commercial importance such as crops, soil, livestock and pest control operation in and around buildings. It can be used to successfully control crawling insects. It is also termed as public health pesticide. It is registered by the Department of Agricultural Extension (DAE), Ministry of Agriculture for the said use. Ustad (generic name Cypermethrin) is a USEPA-registered pesticide that is classified for “restricted use”. It is an organophosphate with a USEPA Toxicity Class of II (Moderate Toxic-Warning). It is used as liquid form and effective for the control of a wide range of insect pests of commercial importance. It controls a wide range of pests and crawling insects affecting grains and other stored products. It is a rapid acting chemical with no detectable decomposition at normal ambient temperatures and for at least 3 months at 50 degrees Celsius to date and is effective in warm and humid climates. Ustad is used through high or low volume spraying and ingestion and has a low mammalian, birds and other organisms’ toxicity. Cypermethrin, a parathyroid, is extremely toxic to fish. It is highly toxic to bees exposed to direct treatment on blooming crops or weeds. Ustad is used as liquid form and effective for the control of a wide range of insect pests of commercial importance. It controls a wide range of pests and crawling insects affecting grains and other stored products. It is a rapid acting chemical with no detectable decomposition at normal ambient temperatures and for at least 3 months at 500 C and is effective in warm and humid climates. However, these products are registered by the Department of Agricultural Extension (DAE).

Table 1: Status of Recommended Pesticides Used in Bangladesh

Sl. #

Trade Name

Chemical Name Origin Action Toxicity Class

EPA EPA Reg.

Status

1 Actellic Pirimphos Methyl UK Store Grain

Insecticide III

Slightly Toxic (Caution)

Yes GUP

2 Agriphos Aluminum Phosphide CHINA Store Grain

Insecticide I

Most Toxic (Danger-Poison)

Yes RUP

3 Dursban Chloropyriphos USA Public Health Pesticide

II Moderate Toxic

(Warning) Yes RUP

4 Quick-Fume

Aluminum Phosphide INDIA Store Grain

Insecticide I

Most Toxic (Danger-Poison)

Yes RUP

5 Sanphos Aluminum Phosphide INDIA Store Grain

Insecticide I

Most Toxic (Danger-Poison)

Yes RUP

6 Ustad Cypermethrin INDIA Wide Spectrum Insecticide

II Moderate Toxic

(Warning) Yes RUP

GUP: General use pesticide; RUP: Restricted use pesticide; a: Oral toxicity (I = Most Toxic, II = Moderate Toxic, III = Slightly Toxic)

Table 2: Status of Recommended Pesticides Used in Bangladesh

Sl#

Trade Name

Reg. Status in Host

Country Reg. No

Recommended Pest

Recommended Dose

1 Actellic Yes PHP-10

Wheat & Rice Weevil 10mL/1000kg or 2g/m2

2 Agriphos Yes AP-174 Commodity insecticide, Rodenticides

6 tablets/1000 kg

3 Dursban Yes

PHP-05 PHP-85 AP-93

Termite Mosquitoes, Larvae

0.125L/a i/ha or 62.5mL/ha

4 Quick Fume

Yes AP-254 Commodity Insecticide, Red Grain Beetle

6 tablets/1000 kg

5 Sanphos Yes AP-663 Commodity Insecticide, Red Grain Beetle

6 tablets/1000 kg

6 Ustad Yes PHP-82 Wide Spectrum Insecticide 2mL with 24 cc water/100m3

area 4.3. Extent to which the proposed pesticide is the part of integrated pest management (IPM): The use of Aluminum Phosphide in a series of CARE Bangladesh controlled storage trials /demonstrations designed to evaluate effectiveness and the cost/benefit of its appropriate usage for its commodity warehouse. The use of “Actellic” by other users to control disease carries and nuisance pests including mosquitoes, ant, wasps, flies, cockroaches, fleas and other crawling insects. As it is most toxic class of compound, it cannot be used as a part of Integrated Pest Management (IPM). However, the program will undertake IPM practices during the commodity storage period as appropriate referred in next clauses of this document. The use of Dursban in CARE Bangladesh for commodity warehouse maintenance. It has a strong action on wide range of insect pests of commercial importance such as crops, soil, livestock and pest control operations in and around buildings. It can be used to successfully control crawling insects termed as public health pesticide. The use of Ustad in CARE Bangladesh for commodity warehouse maintenance. It has a strong action on wide range of insect pests and miticide. It can also be used to successfully control crawling insects termed as public health pesticide. Due to long half-life and intense effect it may not be used as a part of IPM.

4.4 Proposed methods of application, including availability of appropriate application and safety equipment: The precautionary recommendations included on the packaging of this products will be strictly followed, including the i) use of a mask over mouth and nose, ii) wearing protective clothing, iii) immediate removal of clothing used during application iv) hand / rubber gloves and boots and v) burning of used containers v) prior to application and as per recommendations on the pesticide container, the product may be stored in its original container in CARE Bangladesh warehouses (if convenient), which will not be used again for the storage of food items vi) Warehouses will be locked and well ventilated vii) Any person entering the warehouses will be informed of its existence and be aware of the toxicity of the product. 4.5. Provisions made for training of users and applicators: Proposed pesticide will be applied by registered and experienced fumigation company staffs and technicians under the close supervision of CARE Bangladesh warehouse managers/ environmental compliance specialist and other concerns who have previous experience of working in the correct handling, use and management of warehouse fumigation work. The whole commodity warehouse inspection and commodity storage program will be under the control of experienced persons, who have worked with proposed pesticides. Provisions will be made for detail training of users and applicators for occupational health and safety measures. Under SHOUHARDO III program, commodity warehouse management staff and fumigation workers will be provided with orientation and refreshers in each year during the program period. 4.6. Provisions made for monitoring the use and effectiveness of the pesticide: During application, preparations to apply proposed pesticides to the commodities will follow the instructions on the label, in the proper sequence. No one will handle the product without the proper protective mask, clothing and soap and water will be available for immediate cleaning of hands and eyes. Partially used containers will be securely sealed during the application process and returned to storage. After completing the application, the empty containers will be punctured and burnt (as per the “The Pesticides Ordinance, 1971 Bangladesh”). The clothing and other equipment used during the application will be thoroughly cleaned (the clothes will be ashes separately from other clothes). As the application will take place within a controlled area using sacks and drums, there should not be drifting problems (movement of pesticide dust away from the commodities to be treated). Application will take place in the early morning (prior to 10:00 AM), avoiding the hottest part of the day. No food or drink will be consumed within the warehouse during application. Should anyone show signs of pesticide poisoning, the application will be stopped and first aid will be immediately sought. First aid kits are to be stored on site and individuals will be trained in basic first aid procedures. The treated commodities will be used after complete aeration of the warehouses. There will be subsequent applications during the storage period as prescribed by the manufacturer of pesticides. The storage trials may be set up following prescribed protocols and closely monitored by SHOUHARDO III staff of the organization. Experts will collect and analyze the data and present the findings in CARE Bangladesh annual / other reports. 5. Safe Use Practices and Precautions: CARE authorized agencies will use pesticides/fumigation before and after the storage of food commodities. Assigned agencies has the mandate to fumigate all warehouses with least/moderate or high toxic pesticides registered in the country following the appropriate methods of pesticides handling, storage, transport, use and disposal according to local and EPA guidelines. 5.1. Specifications for Fumigation (GAS-Proof) Sheets or Tarps and Proper Care of Sheets: CARE will ensure the fumigation sheets / tarps and care through Fumigation contractors / company

as per the specifications given in FMP as attached (Ref. T – Annexes of the USAID FUMIGATION PEA). Recommended Sheets Specifications are a) Sheets must be resistant to ultraviolet light, resistant to tearing along both length and width and impermeable to phosphine (gas loss should be less than 1 mg/day/m2). Sheets must be 250 microns thick (1 micron = 1/1000 of a mm), and light weight (200-250 g/m2). Standard 18 x 12 m and available in market (18x4.5 mm), Sheets must be in good condition, with all holes and tears mended with material-specific adhesive and patch. Care of Sheets: The program / fumigator will carefully ensure the following as a) to prevent tears, sheets should not be pulled or dragged over rough ground or walked onto it. b) Sheets should be stored in a place where they will not be damaged by rodents’) Prior to each use, hang sheets on long supports and inspect against light for any holes. 6. Recommended Precautionary Measures in Phosphine Gas Fumigation Process: General precautions for the handling and use of all fumigants will be considered by the fumigator agencies assigned of CARE Bangladesh under the four main headings; those will be taken as preliminary, those taken during application, those taken during the exposure period and post-treatment. Preliminary Precautions: Under this heading may be listed advance precautions of a more general or permanent nature and also preliminary measures applying specifically to each fumigation job. In any fumigation, large or small, no person will work alone. Because poisonous gases are being used, serious consequences may ensue if a fumigator becomes sick or faint and is unable to finish or control the operation. No matter how small the dosage or the scale of the work, at least one more / other person will be present in case of emergency. Precautions during Application: In addition to proper respiratory protection, care will be taken to ensure that fumigant formulations or liquids do not come into contact with the skin. If clothing or footwear becomes contaminated, it should be removed immediately and affected areas of the skin washed thoroughly with soap and water. Precautions during Exposure Period: Every precaution would be under taken to avoid exposure to escaping fumigant and to prevent unauthorized entry into treated space. Warning signs that indicate the type of fumigant in use and the date of the treatment would be put in appropriate places and will be removed after the treatment is completed. Post-Treatment Precautions: After adequate aeration of the treated area, gas detection equipment will be used to ascertain that all fumigant has been removed. As the process of desorption can vary greatly with different fumigants, different commodities and different environmental conditions, precautions will be taken to ensure that harmful levels of gas do not subsequently accumulate where personnel could be exposed. 6.1. Mandatory Precautionary Measures (Part – I): 6.1.1. First Aid Training: All members of fumigation crews and in warehouse management will be thoroughly trained in basic first aid, with additional emphasis placed on artificial respiration techniques for gas poisoning. Such training is valuable not only for its immediate practical purpose, but also because it serves to emphasize the need for care in all aspects of fumigation management.

6.1.2. First Aid Kit: All persons to be engaged in pest control and monitoring work will carry with them, or will have access to, an adequately provisioned first aid kit. Included in this kit should be pertinent information on the nature of poisoning by fumigants or other pesticides used, together with suggestions for remedies. This information would be especially useful to a physician called in to treat an emergency case. 6.1.3. Medical Checkup / Supervision: It is essential for the program that those regularly will be engaged in fumigation is under proper medical checkup / supervision and physician will be fully informed of the chemicals used as well as manner of their application. 6.1.4. Respirators (Gas Masks): The respirator is the most important piece of equipment used for the protection of persons working with fumigants. CARE will ensure the procurement and supply of Respirators (Gas Masks) as the fumigation will be carried out regularly for personal protection which are approved for the purpose by a recognized government authority in the country of purpose or manufacture or import as per. 6.2. Mandatory Precautionary Measures (Part – II): 6.2.1. Literature and pesticides level review: Concerned warehouse staff and fumigators will read and review relevant literature, product information, expiry dates, registration etc. in each of the fumigation period. 6.2.2. Preparatory work: The program will prepare necessary drawing or layout of structures, stacks, surroundings and inspection of the suitability of the structure to be fumigated. 6.2.3. Engaging Trained Fumigator: The program will ensure certified fumigation applicators / trained applicators are engaged who have fumigation procedures, gas detector training, respiratory equipment training and fit tested as medically approved. 6.2.4. Public / Neighboring Dwellers Awareness: The program will undertake adequate arrangements for safety of people not involved in fumigation, briefing on emergency response procedures, placement of placards that contains the symbol of ‘danger’ with skull and crossbones as well as details about the fumigant product names including its registration status, timing of fumigation, name, address and 24-hour mobile phone numbers of applicators will be placed in a visible sites. Hoisting of red flags all other visible places nearby especially on four corners of the area to be fumigated, ensure official notification of fumigation submitted earlier to the fire service department, police and local administration 24 hours prior to the fumigation work in a particular warehouse. 6.2.5. Proper Doses / Mixture: Proper doses / exposure time calculations are to be done to ensure effective fumigation. Sealing of the area and volume of commodities to be fumigated is to be ensured and recorded by the SHOUHARDOIII program. 6.2.6. Fumigation Monitoring: Monitoring of gas concentration is to be done to ensure safety and efficiency of the fumigant, checking fumigant concentration with a gas detector before re-entry, opening and aeration of the fumigated site to be done properly and ensuring safe disposal of deactivated spent fumigant will be assured by the program. Warehouse office activity will be arranged outside (Exclusion Zone) the warehouse building / campus to avoid dust and toxic actions immediate after fumigation. A quick reference guide with toxicity, safety equipment required, safe use, and environmental cautions, will be provided as the useful for pesticide supervisors and applicators for choice decisions.

6.2.7. Sanitation and Water Supply: Each of the warehouses will have the provision of sanitary toilet or improved toilet and sufficient potable water facility for the warehouse workforce at the warehouse premises. 6.2.8. Primary Health Care Arrangement: Warehouses will have first aid boxes and workers and personnel be given health orientation. Contracts telephone numbers of nearby clinic or hospital will also be made available in a convenient corner or place in the warehouses as convenient. 6.2.9. Necessary lighting: Adequate exterior and interior lighting arrangement especially around outside grounds, parking lots, doorways, loading locks and storage areas will be ensured by the program. 6.2.10. Regular Patrolling and Guarding: Regular patrolling system will be in force outside and around the warehouse campus. Entrance or access to inside the warehouse will be restricted and monitored. 6.3. Accessibility of Protective Clothing and Equipment: The program would be responsible to provide and ensure the protective clothing and safety equipment for all pesticide handlers, users, applicators and others present while application occurs to prevent dermal toxicity, skin irritation potential, inhalation toxicity and eye irritation etc. In regard, following materials like cover all worn over long – sleeved shirt and long pants, socks, chemical resistance footwear, chemical resistance dry cotton gloves, individual respirators, goggles, phosphine gas detectors, possibly the self-contained breathing apparatus (SCBA), portable micro-climatic condition i.e. temperature and humidity measuring equipment will make available earlier as essentials to each of the fumigation cycle of each warehouse of the SHOUHARDOIII program. 6.4. Operational monitoring initiatives and IPM Practices: Detailed operational approach in the field level will be ensured to maintain quality control and effectiveness of alternative insecticides under local conditions including safe and effective uses by warehouse concerned staff and fumigators. Mechanical pest control devices (rodent trap, glue board, insect light) will be used as a part of IPM. Extracts from Neem trees are effective insecticides that may also will use as necessary, moreover, warehouse staff will also be advised for rearing pet cat (huntsman) as rat and other insecticide seeker or threat to those of entering into the warehouse. 6.5. Providing Mandatory Training and Refreshers with Safe Use Training Materials to Fumigators and Commodity Management Staff: One way to remind applicators of safety issues are through the production and use of high quality training materials and safe use posters. Fumigant staff of assigned agencies and staff of SHOUHARDOIII program are responsible for warehouse management will mandatorily be given a detail two full days training on fumigation work covering safe uses action plan (SUAP) for well standard management of stored commodities. Similarly, refresher of such as convenient will also be arranged in each year for fumigation applicators, supervisors, monitors, cleaners, guards and other laborer staff. 6.6. Assignment, Roles and Responsibilities: Respective Warehouse Officers (WO), Infrastructure and environmental officer (I&EO) and Regional Commodity and Logistics Manager (RCLM) with fumigation staff will be entrusted with the responsibilities of overall planning i.e. preparing FMP, scheduling, fumigation supervision and overall fumigation management as per FMP. Warehouse Officers will be responsible for drawing up simple monitoring plans, to collect data on reduction in efficacy and any other known environmental impacts / hazard leading to a change to a new or different pesticide. These findings will be reported to the headquarters

Environment Management Specialist of SHOUHARDO III accordingly for USAID periodical reporting. FMP will again be reported / submitted to USAID, as the mandatory part of SUAP by each period of fumigation as prior. The Fumigation management monitoring results overall to be reported to USAID yearly includes FMP Tracker and as a section along with other reporting requirements. Warehouse officers will be responsible for detection and immediate notification about any outbreaks of pests or weevils in the stored commodities. In such cases, Fumigation Company will be notified by concerned staff of the program immediately to start fumigation process. RCLM, Warehouse Officers, I&EO includes assigned fumigators with the support from Environment al Management Specialist of the program will prepare over all Fumigation Management Plan (FMP) well ahead of each fumigation cycle for each warehouse and will submit to USAID for having approval or concurrence as necessary. Monitor fumigation work and fill up the Fumigation Management Tracker as attached with this report will be provided to all warehouses. Program Infrastructure & Environmental Officers (I&EO) will be assigned to maintain all necessary maintenance and repairing works like roof, walls, floor and electric wiring etc. inside warehouses. Environmental Compliance Management staff will continue to work closely in any necessities and support with the Department of Environment (DOE), Department of Agricultural Extension (DAE), and Ministry of Agriculture (MOA) and partner NGOs to stay abreast of development in the local regulations and registration aspects, if any updates of pesticides. 6.7. Mitigation measures and waste disposal provisions: It is necessary to have clear conception and awareness about measures regarding USEPA recommended pesticides, avoidance of treatment and washing equipment in water bodies including spill prevention and cleaning up of bulk pesticides and disposal provision of used pesticides containers. For monitoring purposes, USAID concerned will need to have report from SHOUHARDO III program of CARE Bangladesh for changing to less toxic products on the list of pesticides recommended. The SHOUHARDO III program will continue to use Aluminum Phosphide, Chloropyriphos, Cypermethrin, Pirimphos-methyl pesticides as mentioned in Table - 1 and 2 above following the highest precautionary measures and procedures recommended in this SUAP FMP and more specifically following the T-Annexes, which are the Tool Annexes from the USAID Fumigation PEA. Fumigation residues will be disposed following recommended guidelines (T-Annexes). In this case a deactivating solution must be used by adding half cup of liquid detergent into a large half full of water bucket and be stirred well. Residue from the trays should be poured into the solutions (but never vice versa). The solution will have to stir until all the dust settle at the bottom. Mixture will be left alone until all the gas bubbles present are ceasing off. When decomposition is complete, the mixture then would be disposed onto a small pit in the ground. As alumina is present in the mixture, it does not pollute the atmosphere. Mixtures would not be poured in a toilet. Paper and foils used to collect the dust will be burnt properly in a safe place inside the warehouse premises. Empty containers and aluminum tubes will not be buried in the ground. Dead insects, lizards, rodents and birds would be buried underground conveniently around premises instead of throwing those at the open places or dustbins. [Selected Fumigators will earlier be provided hands on training / demonstration by the program].

Annexed Logs and Documentation

11

ANNEX T-3 [Template]

PHOSPHINE FUMIGATION MANAGEMENT PLAN (FMP) (SHEETED STACKS ONLY)

THIS FMP TEMPLATE PROVIDES A STEP BY STEP PROCESS TO ENSURE SAFE AND EFFECTIVE FUMIGATION AND TRAIN FUMIGATION PERSONNEL

I. COMMODITY AND OWNERSHIP

ATTENTION: To ensure full safety and efficacy,

completion of this FMP is mandatory for each fumigation

event. *

*Some information may remain the same across fumigation events.

PLANNED FUMIGATION DATES:

A. OVERALL PROGRAM & CONTACT INFORMATION Lead Awardee

Program Name

Fumigation Compliance Lead

Compliance Lead Contact Information

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B. FACILITY INFORMATION

Name of Facility

Location

Responsible Manager

(Name, Organization &Title )

Contact Information

C. FUMIGATOR INFORMATION

Lead Fumigator

Organization

Contact Information

Certification # & Expiry Date (if any)

D. COMMODITY TO BE FUMIGATED

Commodity(ies) & Amount in tons (est) (e.g. maize 200mt)

Commodity Owner

E. FUMIGANT PRODUCT INFO & DOSAGE

E1. Fumigant (product name/description)

E2. Ambient Temp(Expected indoor temp range)

E3. Quantity Required

D. COMMODITY TO BE FUMIGATED Commodity

How commodity is packaged

# of stacks & size (e.g., 4 stacks 3m X 2m X 2m)

Last fumigation Enter date if known. Otherwise, enter “unknown” Condition Moldy? Visibly infested?

Moisture %

Purpose of Fumigation

E. FUMIGANT PRODUCT INFO & DOSAGE

E4. Required time @ concentration*

(e.g. 7 days @ 200ppm)

E5. Planned downtime*

(Days + hours, includes aeration.)

*REQUIRED: DOCUMENT CALCULATIONS E3, E4 & E5 IN ANNEX #A. NOTE THAT EFFECTIVE PHOSPHINE FUMIGATION TYPICALLY REQUIRES 7-10 DAYS. .

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II. EMERGENCY PLANNING AND SAFETY

F. CONTACT INFORMATION: MEDICAL FACILITY, EMERGENCY RESPONSE AUTHORITIES

LOCATION TELEPHONE

Police

Fire Service

Clinic/Hospital

Other Local Authority (specify Port Authority, District Council, Chieftaincy, etc.)

Pesticide Regulatory Authority

Chief of Party (or commodity point of contact)

G1. ADVANCE NOTIFICATION PLAN FOR ABUTTERS

Specify the procedures for notifying those living and working within 100m of the facility. The fumigation team needs to alert relevant entities, particularly households, about fumigation activities.

Specify the procedures for notifying those living and working within 100m of the facility. The fumigation team needs to alert relevant entities, particularly households, about fumigation activities.

G2. ADVANCE NOTIFICATION PLAN FOR LOCAL AUTHORITIES

Specify the procedure for notifying local authorities, as required or agreed with these authorities.

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I . FUMIGATION PLAN & EXCLUSION ZONE

REQUIRED ACTION: Y N CONFIRMING INITIALS

I1. Obtain plot or make scale sketch map of facility and surroundings. (note grid paper is provided as final page of this template)

I2. Mark locations of stacks to be fumigated.

I3. On plot, mark exclusion zone that maintains at least a 6M perimeter from stacks to be fumigated, and which INCLUDES buildings or rooms with walls common to the room in which the stack is being fumigated. An exception must be requested if the exclusion zone cannot be maintained.

I4. Determine if a watchman or watchmen will be required to maintain the Exclusion zone. If yes, inform the facility manager immediately.

I5. On plot, mark shut-off points for electricity, water, gas, if any.

I6. On plot mark doors/gates to be secured to enforce exclusion zone and locations of warning signs to be posted.

I7. On plot, mark locations of hazard monitoring (at least 3 locations just outside exclusion zone, where gas is mostly likely to accumulate).

I8. On plot, mark locations of phosphine trays and monitoring lines.

I9. Attach plot to this Fumigation Management Plan as Annex #F

H. EMERGENCY RESPONSE PLAN Describe the procedure to be followed if phosphine concentrations exceed (1) 0.3ppm (or local TLV, if more stringent), or (2) 1 ppm (or local STEL, if more stringent) (TLV= threshold limit value; STEL = short term exposure limit. See PEA Annex T-9).

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J. COMMUNICATION AND TRAINING

REQUIRED ACTIONS Y N CONFIRMING INITIALS

J1. Fumigation team reviews product label, MSDS, and applicator/product manual. Lead applicator provides detailed verbal briefing if required.

J2. Lead applicator briefs the team regarding the symptoms of Phosphine poisoning and first aid. (See Fumigation PEA Annex T-10)

J3. Lead applicator briefs the team regarding the planned fumigation process with reference to the site plot (I10) WITH FACILITY MANAGER PRESENT

J4. Lead applicator briefs the team & facility manager on EMERGENCY RESPONSE PLAN (H1) & roles and responsibilities for implementing the plan are agreed.

J5. All employees engaged in fumigation instructed on the use, impact, and mitigation measures of phosphine fumigation.

III. EQUIPMENT AND SUPPLIES

K. NUMBER OF SHEETS, SAND SNAKES AND TRAYS REQUIRED

REQUIRED ACTION: QUANTITY REQUIRED

K1. Determine number of fumigation sheets required (note that joining sheets requires a 1(one) meter overlap, tightly rolled & then clipped or weighted. If clips are used, they must be applied every 20cm.)

(Indicate number & size of sheets, standard 18meterX12meter sheets preferred)

K2. Determine length of sand snakes required (double rows must be used) (in meters)

K3. Determine number of phosphine tablet trays required

L. CONDITION, QUANTITY & ADEQUACY OF EQUIPMENT & SUPPLIES

FUMIGATION MAY NOT PROCEED UNLESS ALL ANSWERS ARE “YES”

CONFIRM THAT: Y N CONFIRMING INITIALS

L1. Required quantity of sheets (K1) meeting specifications (M1) are available

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L2. Required length of sand snakes (K2) are available

L3. Required number of tablet trays (K3) are available

L4. Respiratory equipment and protective gear meeting specifications (M2) are available FOR THE FULL TEAM and all personnel can achieve a complete face seal. No one enters the fumigation area without protective gear.

L5. (1) Dry, clean cotton gloves in good condition; (2) rubber boots; (3) liquid-tight coveralls are available FOR THE FULL TEAM

L6. Detection (monitoring) equipment meeting specifications (M3) is available to monitor HAZARD

L7. Detection (monitoring) equipment meeting specifications (M3) is available to monitor EFFICACY

L8. Warning signs (placards) IN APPROPRIATE LANGUAGES and WITH APPROPRIATE PICTOGRAMS and compliant with host country regulations (if any) are available in quantity required by plot (I6)

L9. Required quantity of fumigant (E3) is available

M. SPECIFICATIONS FOR SHEETS, RESPIRATORY & DETECTION EQUIPMENT

M1. FUMIGATION SHEETS M2. RESPIRATORY PROTECTION

Sheets must be:

• resistant to ultraviolet light • tear-resistant along BOTH

length and width

• of material impermeable to phosphine (gas loss must be less than 1 mg/day/m2

• in good condition with ALL holes and

Properly maintained canister-type full facemask respirator. The canister must (1) be rated to protect against phosphine, (2) not expired, (3) not damaged, and (4) canisters previously used must not be opened more than 6 months ago & not have exceeded their rated time-in-use. OR Properly maintained self-contained breathing apparatus.(SCBA) Other varieties of respiratory protection may be acceptable, see PEA Annex T-9.NOTE. Canister/cartridge type respirators are NOT adequate to enter a fumigation enclosure (e.g. go into a sheeted container)

Tears will be mended with material-specific adhesive and patch.

• light enough to carry (200-250g/m2) a full standard-size (18mX12m) sheet

250-micron (0.25mm) thickness PVC sheet, PVC on a nylon or M3. MONITORING EQUIPMENT

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terylene scrim, or multi- layer thin-film laminates is all acceptable. Thin coatings on widely woven materials and annealed polypropylene sheets NOT acceptable.

All equipment must be properly calibrated and maintained. Detector tubes, if used, must NOT be expired. Efficacy monitoring equipment must be able to read in the 200-500ppm + range. Hazard monitoring equipment must be able to accurately read in over the 0.3-3ppm + range. See PEA Annex T-9 for more information

N. RESPIRATORY AND DETECTION EQUIPMENT

Required Action: Complete log of all Respiratory and Detection Equipment.

DESCRIPTION

e.g., Canister Respirator

MANUF & MODEL # MANUF DATE (IF KNOWN)

SERIAL NUMBER

*Note: advance notice of 24 or more hours may be required by country laws or regulations.

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IV. APPLICATION AND MONITORING

O. SUITABILITY OF FACILITY, STACKS AND TEAM FOR FUMIGATION BY FOLLOWING THESE STEPS, MANADATORY FUMIGATION WILL BE SAFE

AND EFFECTIVE. FUMIGATION MAY NOT PROCEED UNLESS ALL CRITERIA ARE MET. CRITERION IS. . .

MANDATORY STEPS. CONFIRM THAT: MET NOT MET

CONFIRMING INITIALS

O1. Commodities being fumigated are not required for use before the end of the planned down time (E5) + 1 day

O2. Expected temperature during the fumigation period will be 15⁰C or above.

O3. Stacks are NOT built around pillars or against walls, and that there is Sufficient clearance (1m) around each stack to effectively sheet and seal.

O4. Surface issues: EITHER (1) the floor under and for 1 (one) meter around stack is crack-free concrete OR (2) the stack is placed on top of intact fumigation tarps. (If multiple tarps are used, they must be joined by tightly rolling a 1m overlap & weighting or clipping the join).

O5. The marked exclusion zone (see I3) can be maintained for the duration of the fumigation (7-10 days or more). (Exclusion = no people EXCEPT for fumigation personnel with proper breathing equipment in this zone.)

O6. A trained 2-person (or larger) team is available for application of fumigant and aeration and the team holds any required country licenses.

O7. If watchmen are required to maintain the exclusion zone, they will be available over the entirety of the fumigation period, including aeration time.

O8. The warehouse contains only the commodity to be fumigated.

P. WARNING SIGNAGE AND SECURITY REQUIRED ACTIONS Y N CONFIRMING INITIALS P1. Notify Abutters per Notification Plan (G1). In particular, ensure that nearby residents have been informed of activity,

P2. Notify Workers and any others with customary access to the exclusion zone. Brief on emergency response plan (H1)

P3. If applicable, execute Local Authorities Notification Plan (G2)*

P4. Post warning signage at all points indicated by fumigation plot (I6)

P5. Assure that doors are ready to be locked. (Locks and keys available)

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P6. Assure that watchmen are on-site, if required to maintain the exclusion zone.

Q. PLACING SHEETING AND COVERING STACKS REQUIRED ACTIONS IN EXACTLY THIS ORDER Y N CONFIRMING

INITIALS Q1.Position sheets. Carry, do not drag the sheets into position

Q2. Cover stacks. Unfold the sheets towards the stack. Place the sheet over the stack and position with 1 (one) meter of sheet lying on the ground. Unroll the sheet to cover the entire stack. If more than one sheet is used, join the sheets. Joins require a 1(one) m overlap, tightly rolled, and then clipped every 20cm or weighted.

Q3. Set sand snakes. Smooth out any wrinkles and folds in sheets, and then place two rows of sand snakes on the sheets along the sides of the stack. Ensure that a good seal is achieved along the whole length and take special care at the corners.

Q4. Place monitoring lines. Place two monitoring lines from the top and one from the bottom of each stack for efficacy monitoring. Cut small holes to insert tubes and seal holes in gas sheets with tape. Gas monitoring lines should extend outside of the exclusion area. Place duct tape over the free tube ends, except when measuring gas concentrations. Tubes MAY NOT be located near placement positions for phosphine tablets.

R. APPLYING FUMIGANT ATTENTION: PHOSPHINE GAS BEGINS FORMING AS SOON AS THE AIR-TIGHT PACKAGING OF

PHOSPHIDE PELLETS/TABLETS IS OPENED. IT IS A DEADLY POISON. IT IS FLAMMABLE. CONTACT OF PHOSPHIDE WITH WATER WILL CAUSE FIRE OR EXPLOSION. SMELL IS NOT A RELIABLE

INDICATOR OF DANGER. REQUIRED ACTIONS IN EXACTLY THIS ORDER Y N CONFIRMING INITIALS

R1. Watchmen go on duty (if required to maintain the exclusion zone) & remain OUTSIDE the zone until aeration is complete (W9)

R2. Verify ONLY personnel involved in fumigation are in the exclusion zone

R3. Turn off electric lights & any sources of sparks

R4. Ensure that all fumigation personnel are wearing PPE, including respirators, as per L4 & L5

R5. Lay out the trays for aluminum phosphide tablets/pellets around the stack. Remove the sand snakes that hold down the sheets next to the trays.

R6. Distribute UNOPENED tablets/sachets next to the trays

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R7. Position tablets/pellets in a single layer on each tray. To avoid fire risk, do not pile tablets or pellets. Slide trays under the sheets and replace the sand snakes. To minimize worker exposure to gas being released, placement of trays should be completed within 15 minutes. Work from the back of the stack towards the exit doors. Pellets may NOT touch bagged commodities.

R8. Assure all opened tablets/pellets are used

R9. Leave the warehouse and lock ALL doors

S. MONITOR GAS CONCENTRATIONS FOR EFFICACY AND HAZARD & LOG RESULTS REQUIRED ACTIONS Y N CONFIRMING

INITIALS S1. Hazard Monitoring. 1 hour, 2 hours, 4 hours & 24 hours after applying fumigant, and every 24 hours thereafter, monitor for hazard at all points designated on the fumigation plot (I7). Record results on attached log (#D).

S2. Hazard Monitoring Response. If concentrations exceed 0.3ppm (or the local TLV,* if more stringent), assure that individuals move through the area only in passing. If concentrations exceed 1.0ppm (or the local STEL, if more stringent) evacuate the area. NOTE ANY SUCH ACTIONS IN EXCEPTIONS LOG (#C).

S3. Efficacy Monitoring: Monitor EACH monitoring line 24 hours after fumigation application; every 24 hours thereafter. Monitor within stacks to confirm it was an effective fumigation application. Record results in attached log sheet (#E). NOTE ANY EXCEPTIONS IN LOG.

S4. Efficacy Monitoring Response. If concentration does not reach or falls below 200ppm before additional fumigant may be added IF SCBA apparatus are used. NOTE ANY SUCH ACTIONS IN EXCEPTIONS LOG (#C).

*threshold limit value. **short-term exposure limit see PEA Annex T-9.

T. CERTIFY FUMIGATION COMPLETE OR ABORTED REQUIRED: CERTIFY WHICH OF THE FOLLOWING APPLIES. ! REQ’D TIME @

CONCENTRATION e.g. 200 ppm @ 7 days T1. Efficacy monitoring results show that the required

phosphine gas concentration was sustained over the required period in each stack

T2. Efficacy monitoring results show that the required concentration was NOT sustained over the required period in one or more stacks.

(Copy from E4)

U. AERATE REQUIRED ACTIONS IN EXACTLY THIS ORDER Y N CONFIRMING INITIALS

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U1. Fumigation team puts on respirators and other PPE per L4 and L5 before entering exclusion zone.

U2. Open all doors and ventilators. Turn on fans, if any. U3. Remove sand snakes from the corners of up to 2 stacks so that sheet covering each can be lifted. (If the stacks are large relative to the size of the room, ONLY 1 stack can be opened at a time.)

U4. Pull the free corner of each sheet up to the top of the stack with a rope. Team leaves exclusion zone immediately.

U5. Allow gas to leave stack and warehouse for a half-day to 1 day

U6. Repeat U1, U4 & U5 until remaining stacks are opened

U7. Repeat U1. Then completely remove all sheets covering stacks.

U8. Monitor inside warehouse and directly next to stack until phosphine gas concentration is less than 0.3 ppm (or local TLV value, if more stringent.)

U9. ONLY AFTER CONCENTRATION IS LESS than 0.3 ppm (or local TLV value, if more stringent), lead fumigator informs facility manager that the area is safe to enter.

V. DISPOSAL AND CLEANUP

V. ALUMINUM PHOSPHIDE RESIDUE REMOVAL & DISPOSAL ATTENTION: Residues contain 3-5% unreacted materials and are hazardous to breathe and

touch! ATTENTION: NEVER DISPOSE OF UNUSED TABLETS/PELLETS WITH THESE METHODS.

NEVER PLACE UNUSED PELLETS/TABLETS IN A DRUM WITH OR WITHOUT DETERGENT AS A FIRE OR EXPLOSION MAY OCCUR. REQUIRED ACTIONS Y N CONFIRMING INITIALS

V1. Personnel involved put on respirators and other PPE per L4 & L5.

V2. Collect residue from trays in bucket or drum. Do not allow any residue to touch food commodity

V3. Remove residue to a safe outdoor area

V4. Remove warning signs & stand down watchmen

V5. Standing upwind to avoid any evolved phosphine, mix residue slowly into soapy water, assuring the residue is fully reacted.

V6. After any reaction is complete, dispose of mixture in a 0.5m deep disposal pit, at least 100m away from warehouse structures. Fill in hole.

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W. CLEAN-UP

ATTENTION: Dead animals should be considered a biohazard & must be disposed as soon as possible after aeration is complete REQUIRED ACTIONS Y N CONFIRMING INITIALS

W1. Crush empty Phosphide tablet/pellets containers and dispose per host country requirements. If none, bury.

W2. Inspect entire warehouse with flashlight, including under pallets and under-roof area for dead rodents and birds

W3. Collect all dead animals wearing disposable gloves (if available). If not available, pick up with shovel or inside-out plastic bag.

W4. Dispose of carcasses by (1) burying, wrapped in newspaper or plastic bag 0.6-1.2m deep and at least 60m from any shallow well or surface water; OR (2) burning, where it will not cause a public nuisance and in accordance with local laws; or (3) otherwise in accordance with local laws.

W5. Wash hands thoroughly with soap.

VI. ANNEXED LOGS AND DOCUMENTATION

#B. FUMIGATION TIME LOG #B1. Planned down time (days + hrs.) (from H5)

#B2. Fumigant Applied (Date & Time)

#B3. Efficacy Reached (Day & Time that H4 is achieved)

#B4. Aeration Start (Date & Time)

#B5. All-Clear Given (see V9) (Date & Time)

#A. DOCUMENTATION OF DOSAGE CALCULATION Document the calculations/information used to determine the quantity of fumigant required

and the “time @ concentration” efficacy threshold (e.g. 200 ppm @ 7 days) General recommendation is 3 ALP tablets/metric ton but will vary with commodity, temperature & moisture content. 6 tablets/metric ton may be needed for highly sorptive commodities such as paddy rice, brown rice & pulses. Consult product label.

#C. ISSUES, INCIDENTS AND EXCEPTIONS LOG

Log here any issues, incidents or exceptions that arise during the fumigation, including but not limited to phosphine concentrations > TLV outside the exclusion zone, violations of the exclusion zone, known or suspected problems with PPE discovered after the initial inspection, members of the fumigation team who become ill, addition of fumigant to reach or sustain required concentrations, etc.

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#D. PHOSPHINE CONCENTRATION LOG: HAZARD MONITORING Per S1, log phosphine gas concentrations taken at designated locations outside the exclusion area, in ppm. LOCATION* MONITORING TIME (TIME 0 = APPLICATION OF FUMIGANT) 1 hr. 2 hr. 4 hr. 24

hr. 1 day 2

days 3 days

4 days

5 days

6 days

7 days

8 days

9 days A

B

C

*As designated on plot map, Annex #F. Add locations as needed. #E. PHOSPHINE CONCENTRATION LOG: EFFICACY MONITORING Per S3, log phosphine gas concentrations taken from monitoring lines, in ppm.

MONITORING TIME (TIME 0 = APPLICATION OF FUMIGANT) MONITORING LINE* 24

hrs. 2 days

3 days

4 days

5 days

6 days

7 days

8 days

9 days

10 days

1

2

3

4 *As designated on plot map, Annex #F. Add lines as needed.

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#F. SCALE MAP/PLOT OF FACILITY AND SURROUNDINGS, SHOWING EXCLUSION ZONE

(Use this grid for a sketch map, if a more formal site map is not available. See section I for requirements)

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1

[SHOUHARDOIII] Fumigation Safer Use Action Plan Compliance Tracker

[This is an integral part of the PERSUAP and must be submitted annually with Environmental Status Report (ESR)].

PROGRAM & CONTACT INFORMATION DATE OF ANNUAL REPORTING SUBMISSION:

Awardee CARE Bangladesh Annual Update #1

Year 2017

Program Name

SHOUHARDO II I (Strengthening Household Opportunities to Respond to Development Opportunities)

Annual Update #2

Year 2018

Fumigation Compliance Lead

Md. Abdur Rashid, Advisor – Environment Annual

Update #3 Year 2019

Contact Information

Abdur.rashid@care.org; telephone: 880-2-9889009, 01779591551

Annual Update #4

Year 2020

FUMIGATION LOG (record all fumigation events since the last annual update)

Warehouse Type Dates

Location (Town or City) P* S* T*

Commodity & Quantity Fumigated

Key Exceptions/Incidents per FMP log.

2

P=Primary, S=Secondary, T=Tertiary

REQUIRED COMPLIANCE MEASURES

ACTIONS PLANNED TO ACHIEVE & MAINTAIN COMPLIANCE (w/ deadlines & responsible party)

STATUS OF COMPLIANCE ACTIONS (for instance text)

Good Housekeeping IPM Measures. Fully implement the daily/weekly warehouse and commodities inspection checklist (Fumigation PEA Annex T-5) and take maintenance/corrective actions specified. NOTE: compliance with this checklist implements a set of IPM measures that are essential complements to fumigation.

CARE Bangladesh will ensure the necessary conditions following the daily/weekly warehouse and commodities inspection checklist (Fumigation PEA Annex T-5).

Fumigation Management Plan. A fumigation management plan (FMP) will be implemented for each fumigation event. The FMP and the actual fumigation process will substantively conform to the plan provided as Annex T-3 to the Fumigation PEA, EXCEPT for changes specified below and/ or subsequently approved by the DCHA BEO. Each completed plan shall be retained for 2

CARE Bangladesh will plan and implement the FMP in each Fumigation events following Annex – T-3. Exceptions in any of the clauses /actions in context will be coordinated subsequently with the DCHA BEO/ MEO – USAID Bangladesh.

3

years.

Complementary Use of Contact Pesticides will (1) be limited to the pesticide(s) authorized by this PERSUAP and substantively conform to contact pesticide best practices as set out in Fumigation PEA Annex T-6, EXCEPT for changes specified below and/or subsequently approved by the DCHA BEO.

CARE Bangladesh will plan and implement the FMP in each Fumigation event following approved PERSUAP. Will follow the IPM Practices and inspection checklist following the Annex – T-6. Exceptions in any of the clauses /actions in context will be coordinated subsequently with the DCHA BEO/ MEO – USAID Bangladesh.

Storage and Transport of Aluminum Phosphide and Contact Pesticides, if under program control, substantively conform to contact pesticide best practices as set out in Fumigation PEA Annex T-6, EXCEPT for changes specified below and/or subsequently approved by the DCHA BEO.

Not Applicable

When Using a 3rd-Party Fumigation Service Provider: The provided model RFQ and contract (or substantive equivalent) will be used to procure fumigation services and proposals/quotes will be evaluated based on ability to comply with specified safer

CARE will ensure all compliance issues on Warehouse Storage Commodity Fumigation for each event, to be done by fumigation service provider/ fumigator.

4

When Using a 3rd-Party Fumigation Service Provider: The provided model RFQ and contract (or substantive equivalent) will be used to procure fumigation services and proposals/quotes will be evaluated based on ability to comply with specified safer use practices.

CARE will ensure all compliance issues on Warehouse Storage Commodity Fumigation for each event, to be done by fumigation service provider/ fumigator.

Monitoring and Corrective Action. Program will actively monitor compliance with above-listed conditions and undertake corrective actions as needed.

SHOUHARDO III Program of CARE Bangladesh will actively monitor the compliance with above-listed conditions and undertake corrective actions if needed, for each events.

REQUESTED EXCEPTIONS AND CHANGES TO SPECIFIED MANAGEMENT PRACTICES Enter here specific requested exceptions or changes to fumigation practices as per template Fumigation Management Plan provided by the Fumigation PEA Annex T-3 or storage, transport, and contact pesticide practices per Annex T-6. Reference by number & provide justification in each case. Alternately, a strike-through edit of the FMP may be submitted.