Environmental Assessment and Pest Management Plan

Environmental Assessment and Pest Management Plan
EA Classification
Pest Management Plan
Assessment of institutional capacity and relevant policies
Screening of pest control products
Criteria for selection and use of pest control products
EA Classification
For general information regarding EA classification of projects: see OP 4.01
BP 4.01 Annex C stipulates that projects are classified as Category A if these include the
manufacture, use, or disposal of pest control products in quantities that are significant from an
environmental or health perspective.
Whether or not quantities are significant from environmental or health perspective requires
informed judgment. The term significant does not only refer to the size of quantities, but also to
the risk. Relative small quantities of pesticides can pose high risks and thus be significant from
environmental or health perspective. Relevant factors in this respect are: human toxicity,
persistence of product, risk to end-user, capability for safe storage and disposal, potential impact
on agro-ecosystem, environment and wildlife.
Projects that involve procurement of large volumes of pesticides (e.g.: locust control, malaria
control, economic/agricultural rehabilitation projects procuring pesticides, etc.) are always
classified as Category A.
Projects that directly or indirectly involve use of pesticides may not be classified as Category C.
Such projects are classified as Category B if these do not meet the above criteria for Category A.
Pest Management Plan
Pest and pesticide management issues relevant to the project are addressed in the EA.
Preparation of a specific Pest Management Plan (PMP), in accordance with BP 4.01 Annex C, is
required when there are significant pest management issues or when procurement of substantial
quantities of pesticides is envisaged. The PMP is part of the Environmental Management Plan.
A PMP is designed to minimize potential adverse impacts on human health and the environment
and to advance ecologically based IPM. It describes pest and pesticide management issues
relevant to the project and provides a strategy and plan for IPM implementation. It determines
whether current or proposed use of pesticides is justified under an IPM approach, and whether it
is economic (see justifying pesticide use). Hazards associated with the transport, storage, handling,
use and disposal of pesticides are identified and assessed. Measures are provided to reduce
these hazards to a level that can be managed by the envisaged users of the products concerned.
Preparation of a PMP also includes screening of pest control products if financing of such
products is envisaged (see screening of pest control products).
What BP 4.01 Annex C says about the preparation of a Pest Management Plan
A pest management plan is a comprehensive plan, developed when there are significant pest
management issues such as:
New land-use development or changed
cultivation practices in an area;
Significant expansion into new areas;
Diversification into new crops in agriculture,
particularly if these tend to receive high usage of pesticide, like cotton, vegetables, rice,
Intensification of existing low-technology
Proposed procurement of relatively hazardous
pest control products or methods;
Specific environmental or health concerns
(e.g., proximity of protected areas or important aquatic resources; worker safety);
A pest management plan is also developed when proposed financing of pest control products
represents a large component of the project.
A pest management plan reflects the policies set out in OP 4.09. The plan is designed to
minimize potential adverse impacts on human health and the environment and to advance
ecologically based IPM. The plan is based on on-site evaluations of local conditions conducted
by appropriate technical specialists with experience in participatory IPM. The first phase of the
plan - an initial reconnaissance to identify the main pest problems and their contexts (ecological,
agricultural, public health, economic, and institutional) and to define broad parameters - is
carried out as part of project preparation and is evaluated at appraisal. The second phase –
development of specific operational plans to address the pest problems identified - is often
carried out as a component of the project itself. As appropriate, the pest management plan
specifies procedures for screening pest control products.
The EA and where relevant the PMP:
Provides an assessment of current relevant pest management practices;
Identifies specific practices and conditions that could and should be improved (e.g.
calendar-based spraying, use of overly toxic or otherwise inappropriate pesticides, failure
to apply available non-chemical methods, insufficient access of farmers to information
about IPM, policy biases towards chemical control, deficiencies in institutional capacity to
implement IPM and control of pesticide use, etc.);
Provides measures and activities to be taken under the project to improve the situation;
Provides a monitoring scheme to determine the effectiveness of these measures and
enable correction where necessary.
Attention to pest management practices and pesticide handling is particularly important for
projects to which any of the following points apply:
The pesticide financing proposed represents a large component;
The procurement of pesticides in WHO hazard Class II is proposed (Class I is excluded
from Bank financing);
8. Farmers or other laypeople without proper training, equipment, protective gear, storage
and disposal facilities, are the envisaged end-users in client countries;
9. There are specific environmental or health concerns (e.g., proximity of the project area to
protected or sensitive areas, or important aquatic resources);
10. The government capacity to control the use of pesticides is limited;
11. Pesticide use is subsidized and thus may induce irrational use and/or provide a
disincentive for the uptake of IPM.
The Technical Menu provides an outline for a Pest Management Plan (PMP). The outline can
also be used as a checklist if a PMP is not required and pest management issues are addressed
in the EA.
Preparation of a PMP includes identification of specific risks and the design of measures to
reduce these risks. If pesticides are being financed it may be necessary to insist on supply of
hazard reduction packages along with the pesticides. Such packages may include protective
gear, training, application equipment, etc. The Technical Menu provides guidance in identifying
hazards and suggests measures to manage such hazards and reduce risks.
Certain groups of projects require special attention because of the high volumes of pesticides that
tend to be procured (e.g. emergency control of locust and other migratory pests; routine control of
human and animal disease vectors (malaria, onchocerciasis, rodents, ticks, tsetse)), or because
of the impact such projects may have on policy development relevant to pest management (e.g.
research and extension projects; agricultural sector investment or management projects). The
Technical Menu provides further information on these groups of projects.
Note 1: BP 4.01 Annex C exempts procurement of impregnated bed nets and WHO Class III
insecticides for intradomiciliary malaria control from the requirement of preparing a pest
management plan. In those cases preparation of a hazard assessment would suffice. A hazard
assessment identifies risks associated with the transport, storage, handling and use of the
pesticides concerned and provides measures to minimize these risks.
Note 2: As an exception, the PMP may be limited to pest control product screening when all of
the following conditions are met:
12. Expected quantities of pest control products are not significant from a health or
environment standpoint (for a description of the term 'significant' see section on EA).
13. No significant environmental or health concerns related to pest control need to be
14. The project will not introduce pesticide use or other non-indigenous biological control into
an area, or significantly increase the level of pesticide use.
15. Products to be financed fall in Class III or table 5 of the WHO Classification of Pesticides
by Hazard. Table 5 refers to pesticides unlikely to present acute hazard in normal use*.
* The present text of point 7D of BP 4.01 Annex C is inconsistent with OP 4.09 and has been put
forward for updating. Under OP 4.09, Class I pesticides are excluded and Class II pesticides
Assessment of institutional capacity and relevant policies
OP 4.09 states that the Bank assesses the capacity of the country's regulatory framework and
institutions to promote and support safe, effective, and environmentally sound pest management.
As necessary, the Bank and the borrower incorporate in the project components to strengthen
such capacity.
Capacity building and policy reform is an investment for the longer term and provides the do-good
element of OP 4.09. This element is particularly relevant to sector or program lending.
Institutional capacity development may include strengthening of IPM training capacity and/or
strengthening of the regulatory framework for the control of pesticides. Attention for policies is
important because these can have a strong influence on pest management practices. Relevant
policies include pest management policies (research orientation, extension messages, incentives
for input use), food safety (pesticide residues), public health and environmental protection
(selection of pesticides and use restrictions).
Guidance for the assessment of capacity is provided under the following items of the Tools Menu:
Assessment of capacity;
Outline for a Pest Management Plan:
Pesticide Management;
Policy tools to support IPM.
IPM and pesticide management are highly specialized technical fields for which expert advice
should be sought. The borrower should involve local expertise in the preparation of a Pest
Management Plan or section on pest management in the EA (such expertise may for instance be
found through a national IPM program; Plant Protection Department of the Ministry of Agriculture,
or relevant university departments). Assistance of an international specialist may be required.
For projects with significant pest management issues it may be necessary to include a pest
management specialist /crop protection policy specialist in the team for the identification or
preparation mission.
The decision on whether or not to include expertise should be taken in consultation with the
Regional EA team, quality assurance team, or safeguard policy advisor.
Note: Experts involved in the preparation of a Pest Management Plan should not have linkages to
entities involved in the sale of pesticides or other pest management products, because of
potential conflict of interest.
Note: The Systemwide Programme on IPM (SP-IPM), of which the Bank is a co-sponsor, offers
assistance in the identification of experts.
Screening of pest control products
BP 4.01 Annex C stipulates that pest control product screening is required when a project
finances pest control products. The screening establishes an authorized list of pest control
products approved for financing, along with a mechanism to ensure that only the specified
products will be procured with Bank funds (see also 'negotiations' and 'implementation').
Generally, screening is linked to the preparation of a Pest Management Plan, which puts
pesticide use in a broader context and first determines to what extent pesticides are actually
required under an IPM approach.
Main steps in the financing of pesticides:
The Pest Management Plan outlines to what
extent pesticide use is required under an IPM strategy;
Actual requirements are established with
involvement of an IPM specialist and are based on the specific pest problem and local
The borrower prepares an authorized list of
pest control products, based on requirements under an IPM approach, the selection
criteria of OP 4.09 and national pesticide legislation;
The Task Team Leader checks that: (a) the
justification for chemical control is satisfactory (optimum use is made of available nonchemical techniques; pesticide use is economically justifiable) (see justifying pesticide
use), (b) the proposed list of pesticides authorized for procurement under the project
meets the criteria of OP 4.09, (c) hazards have been assessed and are adequately
addressed. (Specialist advice may be required);
Procurement of pesticides should only be
authorized after risks have been assessed and, where necessary, adequate measures
have been taken to ensure that hazards can be managed by the envisaged users.
Procurement of pesticides is restricted to the
authorized list and quantities should not exceed a one year requirement.
The authorized list of pest control products is specific to the pest problems that need to be
addressed and is based on the criteria listed below. Proposed products that do not meet these
criteria should be rejected. In such cases, the Bank makes every effort to help identify suitable
alternative control methods or pesticides. The positive list should be open to modification by
agreement between the Bank and the borrower so as to take into account new information or
requirements that may emerge during the life of the project.
Criteria for selection and use of pest control products
Procurement of the wrong type or quantity of products may result in: acute poisoning of users;
chronic poisoning of people, leading to cancers and birth defects; damage to ecosystems and
drinking water supplies; leftover pesticides becoming unusable/obsolete and turning into
hazardous waste; etc. Pesticides can cause harm to people. It is therefore important to pay
detailed attention to selection and procurement procedures to minimize these significant risks.
Provisions of the OP/BP:
The procurement of any pesticide in a Bank-financed project is contingent on an assessment of
the nature and degree of associated risks, taking into account the proposed use and the intended
users. With respect to the classification of pesticides and their specific formulations, the Bank
refers to the World Health Organization's Recommended Classification of Pesticides by Hazard
and Guidelines to Classification (For an explanation see Technical Menu: Selection and
procurement of pesticides.)
The following criteria apply to the selection and use of pesticides in Bank-financed projects:
They must have negligible adverse human health effects
(see below).
They must be shown to be effective against the target
They must have minimal effect on non-target species
and the natural environment. The methods, timing, and frequency of pesticide application
are aimed to minimize damage to natural enemies (example). Pesticides used in public
health programs must be demonstrated to be safe for inhabitants and domestic animals
in the treated areas, as well as for personnel applying them.
Their use must take into account the need to prevent the
development of resistance in pests.
The Bank does not finance formulated products that fall in WHO classes IA and IB, or
formulations of products in Class II, if (a) the country lacks restrictions on their distribution and
use; or (b) they are likely to be used by, or be accessible to, lay personnel, farmers, or others
without training, equipment, and facilities to handle, store, and apply these products properly.
Further guidance regarding criteria provided by OP 4.09
Adverse human health effects comprise acute toxicity and chronic health impact due to prolonged
exposure to health-affecting chemicals. The restrictions related to WHO Hazard Classes address
concerns about acute toxicity. The Bank does not finance Class I products and restricts the
financing of Class II products. The latter can only be financed for use by professional/dedicated
applicators, which are adequately trained and have appropriate application equipment and
protective gear, and provided there are assurances that these products will not be used by
others. Pesticides envisaged to be used by small-scale farmers or other laypersons (e.g. use by
villagers for bed net impregnation) generally do not meet the above criteria, and therefore cannot
include Class II products. Safe-use training for farmers has its limitations and generally does not
satisfy the above criteria. The Technical Menu provides guidance on how to determine the WHO
Hazard Class of products.
Regarding the longer-term impact on human health and the environment, the Bank does not
finance products that are on the UNEP list of Persistent Organic Pollutants, with the possible
exception of DDT for malaria control under specific circumstances. The same generally applies to
other products that are being phased out for health or environmental concerns by an increasing
number of countries (e.g. persistent products, products known to have endocrine disrupting
properties, etc.). Indicators to help identify such products include:
The list of products subject to the Prior Informed
Consent Procedure. In most cases these products will be excluded from procurement on
the ground that these provide unnecessary risk to the environment and human health.
Products of which the use is not permitted for
environmental or health reasons in countries or groupings with advanced pesticide
registration schemes like the USA, Canada, European countries and the European Union
(registration rejected or canceled – see pesticide management issues).
The intended use of the selected pesticides should be (a) permitted under the national legislation,
and (b) in compliance with the criteria of OP 4.09. Pesticides that are permitted under national
legislation, but do not meet the criteria of OP 4.09, cannot be financed.
The selected pesticides should have minimal effect on non-target species and the natural
environment. This is a difficult but important requirement, which is particularly relevant regarding
impact on predators of common pests that potentially affect the crop concerned. Ignoring this
requirement may lead to further pest outbreaks with significant negative effect on yields and
unnecessary increase in cost of chemical control. This is one of the reasons why a Pest
Management Plan needs to be prepared before selecting pesticides.