USAID/GHANA ENVIRONMENTAL COMPLIANCE FIELD EVALUATION OF PRESIDENT’S MALARIA INITIATIVE INDOOR RESIDUAL SPRAYING ACTIVITIES

MAY 2015

This document was produced for review by the United States Agency for International Development. It was prepared by Sun Mountain International for the E3 Global Environmental Management Support II (GEMS II) Project.

USAID/GHANA

ENVIRONMENTAL COMPLIANCE FIELD EVALUATION OF PRESIDENT’S MALARIA INITIATIVE (PMI) INDOOR RESIDUAL SPRAYING ACTIVITIES

Report Author: Dr. John Nene-Osom Azu

Prepared by Sun Mountain International under: The E3 Global Environmental Management and Support II (GEMS II) Contract, Award Number AID- OAA-13-00018. The Cadmus Group, Inc., prime contractor. Sun Mountain International, principal partner.

The Cadmus Group, Inc. Sun Mountain International, LLC 100 Fifth Avenue, Suite 100 75212 Dr. Phillips BLVD Suite 50647 Waltham, MA 02451 Orlando, Florida 32819 Tel: 617-673-7000 Tel: 202-241-4610 Fax: 617-673-7001 www.smtn.org www.cadmusgroup.com

DISCLAIMER The author’s views expressed in this publication do not necessarily reflect the views of the United States Agency for International Development or the United States Government

Cover Photo- Pre-departure briefing of field staff at an operational site in the Northern region of Ghana

Photo Credit: Dr. John Nene-Osom Azu.

TABLE OF CONTENTS

Acronyms ...... vi Executive Summary ...... viii Background and Objectives ...... viii Briefing Sessions Prior to Trip to the Field and Key Subject Areas Inspected ...... ix Region, Districts, Sites and Sub-Sites Visited:...... ix Findings and Recommendations ...... x PMI Spray Activities ...... x Status of Key Issues Identified in the 2013 Environmental Compliance Inspections ...... xiii 1.0 Background and Objectives ...... 15 1.1 Objectives of Field Evaluation ...... 16 2.0 Preparation for and the inspection Visit ...... 17 2.1 Coordination with GEMS, Mission PMI, and Abt associates ...... 17 2.2 Desk Review of Environmental Management and Compliance Documents ...... 17 2.3 Briefing Sessions Prior to Trip to the Field ...... 17 2.4 Field Visits to IRS Activities in Selected districts sites and communities of the northern region ...... 17 2.6 Region, Districts and IRS Sites and communities Visited: ...... 18 3.0 Findings and Recommendations ...... 19 3.1 Management and Supervision ...... 19 3.2 Residents’ Health and Safety/IEC ...... 19 High Compliance with BMPs ...... 19 Areas of low-compliance with BMPs ...... 20 Associated issues not specifically covered by the BMPs ...... 21 3.3 Worker Health and Safety ...... 21 High Compliance with BMPs ...... 21 Associated issues not specifically covered by the BMPs ...... 23 3.4 Storage and Stock Control at the Central, District and IRS Site Stores ...... 24 High Compliance with BMPs ...... 24 Areas of low-compliance with BMPs ...... 25 Associated issues not specifically covered by the BMPs ...... 25 3.5 Transportation of Pesticides Supplies and Equipment ...... 26

High Compliance with BMPs ...... 26 3.6 Spraying Operations ...... 26 High Compliance with BMPs ...... 26 Areas of low-compliance with BMPs ...... 28 Associated issues not specifically covered by the BMPs ...... 28 Areas of low-compliance with BMPs ...... 28 3.7 Clean-Up Facilities, Post-Spraying Activities and Wash Water Disposal ...... 28 High Compliance with BMPs ...... 28 3.8 Solid Waste Disposal ...... 29 High Compliance with BMPs ...... 29 Associated issues not specifically covered by the BMPs ...... 30 4.0 STATUS OF KEY ISSUES IDENTIFIED IN 2014 AND 2015 ENVIRONMENTAL COMPLIANCE INSPECTIONS ...... 30 4.1 USAID MEO’S MONITORING RECOMMENDATIONS, May, 2014 ...... 31 4.2 PRE-Spraying INSPECTION REPORT 16th – 22 February, 2015, aBT ASSOCIATES...... 31 4.3 PRE-Spraying INSPECTION REPORT, eNVIRONMENTAL PROTECTION AGENCY (EPA) 2015 ...... 33 5. Annexes ...... 35 Annex 1: Photo Gallery ...... 35 Annex 2: Terms of Reference...... 52 Annex 3: Planned Schedule For IRS Environmental Compliance Evaluation - NORTHERN REGION/GHANA – DR JOHN AZU ...... 54 Annex 4: List of Documents Consulted ...... 56 Annex 5: List of People Contacted ...... 57 Annex 6: Other Issues that Determine Level of Success of Environmental Compliance and IRS Operations ...... 62 A6-1 Some Key activities contributing to success of the program ...... 62 Annex 7A: zOIL sERVICES LIMITED INCINERATOR ...... 64 ANNEX 7B: IRS Waste Destruction Certificate ...... 65 Annex 7C: iNCINERATION INVOICES ...... 66 Annex 8A: Material Safety Data Sheet for ACTELLIC CS ...... 68 Annex 8B: Material Safety Data Sheet for ACTELLIC 50 EC ...... 69 Annex 8C: Material Safety Data Sheet for ACTELLIC 900 ...... 70

ACRONYMS

AchE Acetylcholine esterase Enzyme

ACTs Artemisinin-Based Combination Treatments

AIRS Africa Indoor Residual Spraying

BCC Behavior Change Communication

BMP Best Management Practice

BYD Bunkpurugu Yunyoo District

DA District Assembly

CS Concentrated Suspension

DOCs District Operations Coordinators

ECO Environmental Compliance Officer

EMD East Mamprusi Disitrict

EMMP Environmental Mitigation and Monitoring Plan

EPA Environmental Protection Agency

FY Fiscal Year

GEMS Global Environmental Management Support

GF Global Fund

GHI Global Health Initiative

HIV/AIDS Human Immunodeficiency Virus/Acquired Immunodeficiency Syndrome

IEC Information, Education and Communication

IP Implementing Partner

ITNs Insecticide Treated Nets

IPTp Intermittent Preventive Treatment of Malaria in Pregnancy

IRS Indoor Residual Spraying

LLIN Long-Lasting Insecticidal-Treated Net

MaVCOC Malaria Vector Control Oversight Committee

MDGs Millennium Development Goals

M&E Monitoring and Evaluation vi

MEO Mission Environmental Officer

MMD Mamprugu Moaduri District

MoH Ministry of Health

MSDS Material Safety Data Sheet

NIRMOP National Insecticide Resistance Monitoring Partnership

NGO Non-Governmental Organization

NMCPs National Malaria Control Programs

NMIMR Noguchi Memorial Institute for Medical Research

PSECA Pre-Season Environmental Compliance Assessment

PMI President’s Malaria Initiative

PPE Personal Protective Equipment

PSI Pounds per Square Inch

RBM Roll Back Malaria

SEA Supplementary Environmental Assessment

SOs Spray Operators

SOCs Spray Operations Coordinators,

SOP Standard Operating Procedures

STTA Short-Term Technical Assistance

TBD To Be Determined

TOR Terms of Reference

USAID United States Agency for International Development

USG United States Government

WHO World Health Organization

WMD West Mamprusi District

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EXECUTIVE SUMMARY

BACKGROUND AND OBJECTIVES The United States President’s Malaria Initiative (PMI) began supporting Indoor Residual Spraying (IRS) for malaria control in Ghana in 2007 with a focus on local capacity building, strict environmental compliance, and entomological monitoring. In consultations with the Ghana Health Service (GHS), a cluster of districts in the Northern Region was selected for IRS due to the high rate of malaria (greater than 40% parasitemia, children under 5), poor healthcare and economic infrastructure, and a relatively short malaria transmission season. In 2008, Ghana, in close collaboration with GHS and local communities, began implementing IRS with the support of PMI by spraying five districts in the northern region (Tolon- Kumbungu, Savelugu-Nanton, West Mamprusi, Gushegu, and Karaga), which covered approximately 601,000 people. By the end of 2011, the number of beneficiary districts grew to nine with the addition of four new districts (East Mamprusi, Saboba, Chereponi, and Bunkpurugu-Yunyoo), covering approximately 926,699 people. In 2013, IRS was scaled down to four districts (Savelugu-Nanton, East Mamprusi, West Mamprusi and Bunkpurugu-Yunyoo), which resulted in 197,354 structures sprayed and 534,060 people protected. In August 2011, Abt Associates was awarded a three-year Africa-wide Indoor Residual Spraying (AIRS) project, which is funded by USAID under the United States President’s Malaria Initiative (PMI). In September 2014, Abt Associates was awarded a three-year follow-on project called The PMI AIRS Project (or the Project) to support the implementation of IRS in 15 African countries, including Ghana. Abt works in close collaboration with the ministries of health (MOHs), national malaria control programs (NMCPs), district health offices, local non-governmental organizations, and community and business leaders to ensure that the government, the private sector, and communities are able to sustain and direct future IRS and malaria control programs. The 2015 spray campaign is targeting five districts in the northern region: Bunkurugu/Yunyoo, East Mamprusi, Kumbungu, Mamprugu Moaduri, and West Mamprusi. The campaign will target approximately 231,345 structures and seek to protect 596,706 people using the long-lasting IRS product containing Actellic 300 CS - pirimiphos-methyl, an organophosphate insecticide. Due to the program’s high risk related to environmental pollution, user-safety, and health hazards, regular monitoring is required to determine appropriate mitigation practices in order to reduce the risk potentially caused by the various adverse impacts. The spraying operations take place and run concurrently in all target-districts during the most active malaria transmission period. This period corresponds to the start of the current spraying round, which runs from April 14 through May 18 in all the target-districts. The environmental compliance inspection was planned to coincide with this spray period. The primary objective of the assignment was to conduct an environmental field evaluation of PMI spray activities in conjunction with the Abt-administered spray campaign in five districts of the Northern region of Ghana using the Agency-approved Environmental Mitigation and Monitoring Plan (EMMP) for PMI Indoor Residual Spraying (IRS) activities, which are found in the newly approved (2015) Supplementary Environmental Assessment (SEA), and the Best Management Practices (BMPs) for IRS activities developed collaboratively between the Global Health Bureau and implementing partners (IPs) through the PMI program. Another associated objective was to provide problem-solving support, as required, to the USAID Mission and the PMI IP (and any sub-contracting entities). This field evaluation also highlights the risks associated with particular program activities and therefore enables improved program monitoring and training. Workers and community health and safety are a crucial component of IRS activities sponsored by PMI and implemented by Abt and its partners. This report assesses the extent to which the PMI-IRS Program in Ghana has fulfilled the minimum mitigation and monitoring requirements expected of the IRS viii

Programs, the extent to which the IRS Program has adhered to environmental compliance requirements specified in the BMP and SEA, and, finally, the ways in which Abt’s mitigation monitoring procedures may be improved. Several reports and environmental compliance documents were reviewed in order to provide a solid understanding of the IRS program in Ghana and the requirements of the USAID environmental regulations. A list of all the documents reviewed during preparation of this report can be found in Annex 4.

BRIEFING SESSIONS PRIOR TO TRIP TO THE FIELD AND KEY SUBJECT AREAS INSPECTED Briefing sessions were held with USAID PMI staff, Ministry of Health (MoH), Abt’s IRS program Chief of Party, Environmental Compliance Officer and key staff, to get their advice, pointers, concerns, participation, specific information they would like to get from the evaluation report and, above all, to understand the program from their unique perspectives. The key subject-areas inspected during the evaluations, consistent with the BMP, include the following:  Management and supervision;  Resident health and safety/Information, Education and Communication (IEC);  Worker health and safety;  Storage and stock control: central, district and parish stores;  Transportation of pesticides and equipment;  Spraying operations;  Clean-up facilities, post-spraying activities and liquid waste disposal; and  Solid waste disposal.

REGION, DISTRICTS, SITES AND SUB-SITES VISITED: The field evaluation occurred at the same time with the PMI implementing partner’s (Abt Associates’) spray campaign in the five selected districts in the Northern region of Ghana. Details of the specific places visited are as follows:  Accra: MoH Office, USAID Mission;  Tamale: IRS office, Environmental Protection Agency, Ministry of Health, IRS central warehouse  West Mamprusi District: Wungu operational site, IRS Site Office Stores, and communities and Kpasinkpe operational site and District Assembly;  East Mamprusi District: IRS Office Staff, District Assembly, IRS stores, IRS operational Sites in Langbisi, Gambaga and Sakogo.  Bunkpurugu/Yunyoo District: District Assembly, Operational Sites (Nakpanduri, Bindi and Gbunkurugu, IRS stores and communities ix

 Mamprugu Moaduri District: District Assembly, IRS Site offices and stores, soak pits (Kubori and Yizesi) and selected communities.  Kumbungu District: District Assembly, IRS Site offices and stores, soak pits (Dalun and Kumbungu) and selected communities.

Details of the specific people contacted during the field evaluation are found in Annex 5.

FINDINGS AND RECOMMENDATIONS Detailed areas of high compliance and low compliance with BMPs, as observed and evaluated during the field inspection, are presented in the main text. The following sections summarize the principle findings for the different aspects of IRS activities.

PMI SPRAY ACTIVITIES Management and Supervision: Management systems developed and in use, along with lessons learned from past Abt activities in Ghana and elsewhere in Africa, are being applied, resulting in high adoption of best practices in the IRS program. Abt has demonstrated its commitment to support staff development, performance improvement, and compliance with USAID’s agency-approved BMPs and SEA (EMMP) for IRS activities, Ghana’s EPA regulations, and Abt policies and regulations through extensive skills development and training of both the IRS senior and mid-level management teams, as well as staff of partner organizations. Key tools and program improvement activities are in place for management and supervision of IRS activities, including: planning tools and processes that are inclusive of partners; pre-spray, mid-spray and end-of-spray inspections, and various implementation strategies and M&E tools. These strategies and tools include: increase in the frequency of data verification by the M&E teams; promotion of performance feedback from stakeholders; targeted Short-Term Technical Assistance (STTA) to support capacity building of external stakeholders; inclusive monitoring and supervision; research/evidence-based decision making; integration of program into national and local administrative structures; multi-sectoral coordination; and mutual accountability mechanisms – performance appraisals and review, review and revision of the program’s IEC materials to improve delivery by field staff.

Residents’ Health and Safety: Abt has implemented a community engagement strategy and field results indicate a high level of compliance with BMPs. However, children and livestock were occasionally observed loitering around the compounds being sprayed. The risk of exposure to the chemical remains a constant danger.

Recommendation: More emphasis should be placed on instructing spray operators and supervisors to pay attention to this aspect of safety precautions. Children must be kept away from the vicinity of the spray operations and all animals and birds must be kept locked in safe places during and shortly after the spraying period. Workers’ Health, Safety/IEC, and Bio-monitoring of selected program field staff: Observations during field inspections, which were conducted in multiple communities at eleven of the sixteen operational sites, confirmed that all minimum conditions required for protection of the health and safety of store keepers and spray operators, including use of personal protective equipment, were being fulfilled. Strategies used to ensure proper attention is paid to compliance with best management practices include: adequate preparation, training, coordination, and equipping of store keepers and spray operators, and ongoing monitoring to ensure proper implementation and allow for correction of mistakes, if observed.

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A salient issue, however, is that multiple positive test results for mild cases of plasma cholinesterase depression occurred during bio-monitoring of selected program staff. Bio-monitoring of selected program staff: Physiologically significant exposure to organophosphate pesticides—including Actellic (pirimiphos methyl) as used in AIRS Ghana IRS operations—results in depression (inhibition) of cholinesterase, an enzyme required for proper regulation of nerve impulse transmission. Cholinesterase depression is the mechanism by which organophosphate poisoning occurs, which in severe cases can be fatal. PPE BMPs and other worker-safety BMPs are intended to limit exposure to Actellic (or other pesticides used in IRS operations) below a harmful level. Field-portable blood tests exist to measure cholinesterase. Such bio-monitoring of cholinesterase requires establishment of an initial baseline, and periodic, systematic repeat testing of potentially exposed individuals. The current PMI BMPs for IRS activities do not require bio-monitoring of IRS workers for cholinesterase inhibition, nor does WHO recommend bio-monitoring for IRS operations using pirimiphos methyl. However, the 2012 Malaria Vector Control PEA does require inter alia, that “organophosphate bio-monitoring will be part of each [spray] program that will be using OPs” and that “PMI will evaluate various approaches for monitoring sprayer exposure to Organophosphates (OP), and will develop protocols based on these evaluations. PMI will use these protocols to guide the implementation of the OP monitoring program” and amend PMI’s IRS Best Management Practices accordingly. With respect to this requirement and to agreement of the Ghana NMCP, PMI determined that AIRS Ghana would implement PMI’s first IRS worker bio-monitoring program during the 2015 spray season. Abt AIRS developed the program under the supervision and direction of PMI, and with technical support from the National Farm Medicine Center (US) via GEMS. The program was sent to selected sites near medical facilities, using trained medical professionals. It tested spray operators, storekeepers and washpersons at the selected sites. At the time of this report, Abt AIRS is analyzing the data and developing a report on the bio-monitoring program and its results. Analysis conducted on a rolling basis over the spray period did show cholinesterase depression above threshold for some workers, though no clinical symptoms had manifested at the time of this report. It is not with the remit or technical expertise of this exercise to interpret the bio-monitoring results, nor to advise on any policy decisions to be made in response to these results. However, the following observations are offered regarding PPE, whose use is a central focus of the inspection exercise and this report:  Assuming that cholinesterase depression is attributed to actellic exposure and potential dermal exposure is determined to be of concern, there are opportunities to strengthen PPE without moving to fully impermeable (and thus likely intolerably hot) overalls. Possibilities include a protective hood (to reduce forehead/neck/shoulder exposure), or alternative gloves more suitable for use during repair of congested sprayers.  Assuming that cholinesterase depression is attributed to actellic and potential oral/inhalation exposure is determined to be of concern, filter masks worn could be upgraded. Per the Material Safety Data Sheet (MSDS) for Actellic CS (Annex 8a), provided by the project for Actellic 300CS, a particulate filter respirator "may be needed". All Abt sprayers are reported to be using NIOSH 95 certified particulate filters. However, this MSDS does not distinguish between use for crop protection and for indoor residual spraying. The MSDS for Actellic 50 EC (Annex 8b), a xi

different formulation with the same active ingredient (pirimithos-methyl) indicate that a combination gas, vapor and particulate respirator may be necessary. Similar recommendations are defined by the MSDS for Actellic 900 (Annex 8c). Storage and Stock Control at the Central and Operational Site Stores: All stores inspected abided by the recommended arrangements, protection, security, activities, and operations prior to and during and after spraying, demonstrating a high compliance with established best management practices. Records were up-to-date and all safety rules were observed. The remnant stock of the previous year’s insecticides, which had more than two years outstanding before the expiry date, was issued first from the Abt central store and utilized first at the operational sites. Transportation of Pesticides and Equipment: Presently, an international logistics company appointed by the supplier handles the cargo, on arrival in the country (at the port of entry). The containerized-insecticides are sent directly to the central warehouse in Tamale from where they are subsequently distributed by Abt to operational sites where the IRS activities are being implemented. Covered, secured, and insured trucks are used to transport the insecticides to the districts and IRS sites. The drivers of these vehicles have been trained in how to handle emergencies and decontaminate their vehicles in case of accidental spillage. All drivers involved in moving insecticides from the operational sites were wearing supplied overalls. No accidents have been reported during the transportation of insecticides to operational sites and communities at the time of the inspection. Secured stores are located at the various IRS operational sites to serve the communities where the spraying activities are to be undertaken. This arrangement ensures that on the day of spraying each spray operator, who resides in the same site receives his/her supplies at the store in closest proximity to the target spraying area. The sprayers (both men and women) are transported in rented, dedicated buses from the operational site to their areas of operation after which they disperse to the communities and reach the target-households. The spraying equipment, containerized water and boxes of insecticide are secured in the buses that transport the spray operators to their respective locations to ensure safety and security of everyone in the bus. No evidence of compliance issues was identified in the movement of spray operators from their operational sites to the target sites and back to the store and wash area on completion of work at the end of the day. Spraying Operations: Observation of spray operators in action in various households showed that the spray operators demonstrated good understanding of the established best management practices and they followed them in their work. There was high compliance with the best management practices followed by spray operators. Problems with some of the spray pumps such as breakage of the plastic lockers of the Goitzer pump and leakage at the junction between the pump casing the rubber hose at the bottom remain. There were also reports of occasional blockage of the nozzles of both the Goitzer and the Hudson pumps. These problems, apart from wasting the time of spray operators, also call for handling of the leakage and cleaning of the nozzles that could be a cause of contamination. (It is a formidable task to do these repairs with the hands in the gloves and the temptation to remove the gloves is high) Recommendation: Abt should look critically at the performance of the pumps and also systematically training and instructing spray operators and supervisors to ensure that gloves are always worn when such emergency repairs have to be made in the field. Clean-Up Facilities, Post-Spraying Activities and Wash Water Disposal: All observed wash facilities were well-sited with good signage written in English and adequately secured by a wire fence and lock. All observed soak pits had been rehabilitated and the wash area equipped with all the containers and supplies for triple rinsing and bathhouse facilities for men and women. There was high compliance with BMPs.

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Solid Waste Disposal: There was high compliance with BMPs. The processes for the collection, segregation, transportation, and destruction of IRS-generated solid waste are well implemented by Abt based on field observations. There is a suitable incineration facility, Zoil Services Limited in the Central region of Ghana, where contaminated waste stored in sealed containers is sent for destruction. The availability of the modern incinerator has provided the means for the program to appropriately destroy the accumulated contaminated waste. The collection and safe storage of IRS wastes was on-going during the visit. This waste will be sent eventually to be recycled or incinerated depending on the type. Disposal of Actellic plastic containers: Actellic insecticide that is being used in the current IRS round is a liquid formulation in a 1-liter plastic bottle and hence requires a different strategy for waste disposal than other used pesticide sachet wastes. Recycling empty 1-liter plastic pesticide containers, that have been triple-rinsed during the spraying and securely stored at the Abt central warehouse to prevent re-use at the community-level, is the preferred means of disposal. The recycled materials are subsequently used to manufacture products such as waste bins and other products. Disposal of carton boxes: The insecticide carton boxes have been recycled in the past at the Cyclus Elmina Plastic Recycling Ltd. This company is currently not in a position to recycle the boxes because of internal problems. The project is currently exploring the possibility of supplying these paper-cartons to other paper recycling national companies, which are willing to use them provided they are not contaminated by leaked insecticide. Recommendation: During the field evaluation there were indications that at least one firm is interested in recycling these empty pesticide containers, subject to getting information on the quality of the plastic. Abt should pursue this recycling option. However, although pesticide container recycling processes are becoming more common and have been shown to render plastics largely free of residues (less than 0.01 % concentrations), these plastics are still typically restricted for use in non-household materials (sign posts, etc.) due to public perception of these wastes as hazardous. Abt should verify the types of products the interested recycling firm intends to produce with the recycled plastics and weigh the potential risk of the public’s perception of the products to be made from recycled pesticide containers. Any disposal solution selected should receive prior approval from USAID PMI.

STATUS OF KEY ISSUES IDENTIFIED IN THE 2013 ENVIRONMENTAL COMPLIANCE INSPECTIONS Various issues were identified in reports produced by the USAID Ghana MEO, EPC and Abt environmental compliance Officer inspections and include the following:  Construction/Maintenance of old soak-pits: Poor condition of some soak-pits being used for a couple of spray rounds need to be rehabilitated or rebuilt  Plastic sheets for spray operators: Plastic sheets for covering immovable furniture from rooms prior to spraying need to be provided. Old and torn sheets need to be replaced  Community mobilization: Effectiveness of community mobilization and sensitization is needed to make community residents responsive and mindful of the IRS provisions.  Danger signage: Worn-out signage need to be replaced with laminated ones.  Security of store: Need to secure windows of those stores that currently lack security.  Expired atropine medication: There is a need to replace all outdated/expired atropine lodged with the health centers.  Stores cleanliness: Need to clear and clean all stores before the start of the spray campaign xiii

 Lack of operational site at Kumbungu district: Need to establish an operational site with all the required facilities.  Leaky insecticide store roofing: Need to repair all leaky roofs at operational sites  Weak wooden pump hangers: Need for strong wooden hangers that can support the weight of all the pumps hung to dry At the time of the field inspection by the consultant, all the issues that have been raised in the previous inspections by the MEO of USAID, the managers of the IRS program dealt appropriately with Abt Environmental Compliance Officer and the Environmental Protection Agency during 2015. Work has been completed on the soak pits, stores burglar-proofing and rain-proofing, Atropine supplies, re-filling of fire extinguishers, supply of new plastic sheets for covering immovable furniture, replacement of pump hangars, sensitization, training etc.

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1.0 BACKGROUND AND OBJECTIVES

Malaria prevention and control is a major foreign assistance objective of the U.S. Government (USG). In May 2009, President Barack Obama announced the Global Health Initiative (GHI) in order to promote healthy communities and families around the world. Through the GHI, which is a global commitment to invest in healthy and productive lives, building upon and expanding the USG’s successes in addressing specific diseases and issues in a sustainable fashion, the United States will help partner countries improve health outcomes. They will focus particularly on improving the health of women, newborns, and children. The President’s Malaria Initiative (PMI), launched in 2005 along with HIV/AIDS and tuberculosis, is a core component of the GHI. The project is a five-year, $1.2 billion expansion of U.S. Government efforts to reduce the intolerable burden of malaria and help relieve poverty on the African continent. PMI is a key component of the U.S. Government's Global Health Initiative. The goal of PMI is to reduce malaria-related deaths by 50 percent in 19 countries in Africa that have high malaria rates by expanding coverage of four highly effective malaria prevention and treatment measures to the most vulnerable populations: pregnant women and children under five years of age (USAID 2005). These interventions include: insecticide-treated mosquito nets (ITNs), indoor residual spraying (IRS) with insecticides, intermittent preventive treatment for pregnant women (IPTp), and prompt use of artemisinin-based combination therapies (ACTs) for those who have been diagnosed with malaria. The 2008 Lantos-Hyde Act (H.R. 5501 (110th)) authorized an expanded PMI program for 2009- 2013. As a result, the PMI strategy (USAID 2010a) was revised to achieve an Africa-wide impact by halving the burden of malaria in 70 percent of at-risk populations in sub-Saharan Africa – or approximately 450 million people. Now in its seventh year of funding, PMI has expanded to 19 countries plus one region. PMI, in partnership with National Malaria Control Programs (NMCPs) and, in support of country-level strategic plans, is providing technical, managerial, and commodity support for IRS campaigns in all PMI countries that implement IRS. Through GHI and PMI, the USG is committed to working closely with host governments and within existing national malaria control plans. Efforts are coordinated with other national and international partners, including the Global Fund to Fight AIDS, Tuberculosis and Malaria (Global Fund), Roll Back Malaria (RBM), the World Bank Malaria Booster Program, and the non-governmental and private sectors, to ensure that investments are complementary and that RBM and Millennium Development Goals are achieved. Malaria is a major public health problem in Ghana. An estimated 60,000–80,000 malaria deaths occur annually on the Mainland among all age groups. Approximately 10 to 12 million clinical malaria cases are reported annually by public health services and more than 40 percent of all outpatient visits are attributed to malaria. IRS is a component of Ghana’s current National Malaria Control Strategy and Ghana’s Strategic Plan for Malaria Control 2014-2020, specifically employed in areas with high malaria burden (parasitemia >40% among children under 5 years). USAID/Ghana’s Country Development Cooperation Strategy is implementing President Obama’s U.S. Global Development policy in the Ghanaian context. The FY 2014 to 2015 IRS Work Plan for Ghana was developed in close consultation with the National Malaria Control Program (NMCP) and with the participation of many national and international partners involved in malaria prevention and control in Ghana. The plan aligns with the vision of the National Malaria Strategy and will build on investments made by PMI and other partners to improve and expand malaria-related services. In line with Ghana’s national malaria control strategy, PMI is supporting the Ghana IRS program with a budget of $5,439,144. Under the GHI, PMI will assist Ghana in achieving the following targets in populations at risk for malaria by the end of 2020: 1) Reduce malaria mortality by one-third from 2015 levels in PMI-supported countries, achieving a greater than 80 percent reduction from PMI’s original 2000 baseline levels; 2) Reduce malaria morbidity in PMI-supported countries by 40 percent from 2015 levels, and; 3) Assist at

15 least five PMI-supported countries to meet the WHO criteria for national or subnational pre- elimination. The PMI/Ghana strategy includes all of the major interventions supported by PMI to reach the most vulnerable groups, which are children under five years of age and pregnant women, with proven preventive and therapeutic measures, including artemisinin-based combination therapies (ACTs), insecticide-treated nets (ITNs), intermittent preventive treatment of pregnant women (IPTp), and indoor residual spraying (IRS). PMI began supporting IRS in Ghana in 2007, with a focus on local capacity building, strict environmental compliance, and entomological monitoring. In consultations with the Ghana Health Service (GHS), a cluster of districts in the Northern Region was selected for spraying due to their high malaria burden (>40% parasitemia, children under 5), minimal healthcare and economic infrastructure, and a relatively short malaria transmission season. In 2008, working in close collaboration with GHS and local communities, Ghana began implementing IRS with the support of PMI, by spraying five northern region districts (Tolon-Kumbungu, Savelugu-Nanton, West Mamprusi, Gushegu, and Karaga), and covering approximately 601,000 people. By the end of 2011, the number of beneficiary districts grew to nine with the addition of four new districts (East Mamprusi, Saboba, Chereponi, and Bunkpurugu-Yunyoo), covering approximately 926,699 people. In 2013, IRS was scaled down to four districts (Savelugu- Nanton, East Mamprusi, West Mamprusi and Bunkpurugu-Yunyoo), which resulted in 197,354 structures sprayed and 534,060 people protected. In August 2011, Abt Associates was awarded a three-year Africa-wide Indoor Residual Spraying (AIRS) project, which is funded by USAID under the United States President’s Malaria Initiative (PMI). In September 2014, Abt Associates was awarded a three-year follow on project called The PMI AIRS Project (or the Project) to support the implementation of IRS in 15 African countries, including Ghana. Abt works closely with ministries of health (MOHs), national malaria control programs (NMCPs), district health offices, local non-governmental organizations, and community and business leaders to ensure that government, the private sector, and communities are able to sustain and lead future indoor residual spraying (IRS) and malaria control programs The 2015 spray round is targeting five districts of the northern region (Bunkurugu/Yunyoo, East Mamprusi, Kumbungu, Mamprugu Moaduri, and West Mamprusi) and will target approximately 231,345 structures and protect 596,706 people with the long-lasting IRS product containing Actellic 300 CS - pirimiphos-methyl, an organophosphate insecticide. The program has a high risk for environmental pollution, user-safety, and health hazards and, therefore, requires regular monitoring to determine appropriate mitigation practices to reduce the risk of the various adverse impacts. The spraying operations will take place and run concurrently in all target-districts during the most active malaria transmission period. This period corresponded to the start of the current spraying round beginning from April 14 through May 18, in all the target-districts and hence the environmental compliance inspection was planned to coincide with this spray period.

1.1 OBJECTIVES OF FIELD EVALUATION The primary objective of the assignment visit was to complete an environmental field evaluation of PMI spray activities in concert with the Abt-administered spray campaign in five districts of the Northern region of Ghana using the Agency-approved Environmental Mitigation and Monitoring Plan (EMMP) for PMI Indoor Residual Spraying (IRS) activities found in the newly approved (2015) SEA, and the Best Management Practices (BMPs) for IRS activities developed collaboratively between the Global Health Bureau and implementing partners (IPs) through the PMI program. Another related objective was to provide problem-solving support, as may be required, to the USAID Mission and the PMI IP (and any sub-contracting entities). This field evaluation also highlighted the risks associated with particular program activities and therefore enabled improved program monitoring and training.

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Workers and community health and safety are a crucial component of IRS activities sponsored by PMI and implemented by Abt and its partners. This report assesses the extent to which the PMI-IRS Program in Ghana has fulfilled the minimum mitigation and monitoring requirements expected of IRS Programs, the extent to which the IRS Program has adhered to environmental compliance requirements specified in the BMP and SEA, and the ways in which Abt’s mitigation monitoring procedures may be improved.

2.0 PREPARATION FOR AND THE INSPECTION VISIT

2.1 COORDINATION WITH GEMS, MISSION PMI, AND ABT ASSOCIATES Based on the communications among the Global Environmental Management Support Project (GEMS) Consultant, USAID Mission-PMI staff, and Abt Associates management, the date for the field evaluation was fixed on 29th April, 2015, a Terms of Reference (ToR) was prepared and a comprehensive itinerary was prepared and agreed on by all parties. The ToR and final itinerary are found in Annexes 2 and 3, respectively.

2.2 DESK REVIEW OF ENVIRONMENTAL MANAGEMENT AND COMPLIANCE DOCUMENTS The field evaluation was undertaken using the Agency-approved Environmental Mitigation and Monitoring Plan (EMMP) for PMI Indoor Residual Spraying (IRS) activities for Ghana, and the Best Management Practices (BMPs) for IRS activities developed collaboratively between the Global Health Bureau and Implementing Partners (IPs) through the PMI program. Several reports and environmental compliance documents, such as the Standard Operating Procedures (SOPs) for Indoor Residual Spraying Operations in Ghana, were reviewed to provide a good understanding of the IRS program in Ghana and the requirements of the U.S. Government regulations. A list of the documents reviewed is found in Annex 4.

2.3 BRIEFING SESSIONS PRIOR TO TRIP TO THE FIELD Briefing sessions were held with USAID PMI staff, National Malaria Control Program (NMCP) – Ministry of Health (MoH), the Environmental Protection Agency (EPA), and the respective District Assemblies (DAs). These briefings and those held with the Abt’s IRS program Chief of Party, Environmental Compliance Officer and key IRS staff, sought to solicit advice, pointers, concerns, participation, specific information they would like to get from the evaluation report and above all, their understandings and perspectives of the program.

2.4 FIELD VISITS TO IRS ACTIVITIES IN SELECTED DISTRICTS SITES AND COMMUNITIES OF THE NORTHERN REGION Abt’s IRS Team members who accompanied the Consultant to the IRS operations in the districts were: 1. Abukari Yakubu, Abt’s Environmental Compliance Officer; and 2. Site managers, District Operations Coordinators (DOCs) and Supervisors for each of the sites visited.

2.5 THE KEY SUBJECT- AREAS INSPECTED DURING THE EVALUATION  Management and supervision;

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 Resident health and safety/Information, Education and Communication (IEC);  Worker health and safety;  Storage and stock control: central, district and parish stores;  Transportation of pesticides and equipment;  Spraying operations;  Clean-up facilities, post-spraying activities and waste-water disposal; and  Solid waste disposal; and  Other Issues that Determine Level of Success of Environmental Compliance and IRS Operations Country

2.6 REGION, DISTRICTS AND IRS SITES AND COMMUNITIES VISITED: The field evaluation was concurrent with the PMI implementing partner –Abt Associates’ spray campaign. The inspection was carried out in all the districts of the Northern region where the spraying campaign was being implemented. The consultant and Abt team visited a total of 11 of the 16 operational sites. Various consultations held in Accra and Tamale are listed below and the districts and IRS operational sites of the Northern region visited are listed below as well:  Accra: USAID Mission –PMI office and Mission Environmental Officer (MEO).  Tamale: IRS office, Environmental Protection Agency (EPA), Regional Health Directorate of Ghana Health Service, IRS central warehouse.  West Mamprusi District: Wungu operational site, IRS Site Office Stores, Sub-Site and communities and Kpasinkpe and District Assembly (WMD).  East Mamprusi District: IRS Office Staff, District Assembly, IRS stores IRS Sites (Langbisi, Gambaga and Sakogo).  Bunkurugu/Yunyoo District: District Assembly, Operational Sites (Nakpanduri, Bindi and Gbunkurugu, IRS stores and communities.  Mamprugu Moaduri District: District Assembly, IRS Site offices and stores, soak pits (Kubori and Yizesi) and selected communities.  Kumbungu District: District Assembly, IRS Site offices and stores, soak pits (Dalun and Kumbungu) and selected communities. Details of the specific places and people visited are found in Annexes 3 and 5.

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3.0 FINDINGS AND RECOMMENDATIONS

3.1 MANAGEMENT AND SUPERVISION

Abt’s goal is to build and increase capacity of both its own staff and those of its stakeholders in project management, spray operations, technical leadership, financial reporting, monitoring, and quality control and to be responsive to PMI’s needs. Several staff changes have been made to recruit new staff including Operations Manager, IEC Coordinator, Environmental Compliance Officer, and three District Operations Coordinators. Based on consultations, Abt seeks to demonstrate its commitment to comply with USAID’s agency-approved BMPs, SEA (EMMP) for IRS activities, and EPA regulations through extensive skills development and training of both the IRS senior and mid-level management teams. Key tools and activities have been put in place for management and supervision of IRS activities, including: planning tools and processes that are inclusive of partners, pre, mid-spray, and end of spray inspections, various implementation strategies and M&E tools, including increase in the frequency of data verification by the M&E teams, promotion of performance feedback from stakeholders, targeted Short-Term Technical Assistance (STTA) to support, capacity building of external stakeholders, inclusive monitoring and supervision, research/evidence-based decision making, integration of program into national and local administrative structures, multi-sectorial coordination, mutual accountability mechanisms – performance appraisals and review, and, finally, review and revision of the program’s IEC materials to ensure for effectiveness and sustainability planning.

Discussions with various stakeholders, storekeepers, supervisors, and spray operators showed their satisfaction with the IRS program planning, implementation, monitoring and evaluation, and review of the programs activities. Several stakeholders interviewed pointed to the joint planning and training as key factors contributing to the high level of compliance with the established best management practices and success of the IRS program.

The IRS team has continued to work in close collaboration with the Ghana Health Service (GHS), the National Malaria Control Program (NMCP), and the Malaria Vector Control Oversight Committee (MaVCOC) to plan and implement the various IRS operations and to promote uniformity of IRS in those districts supported by Global Fund/Anglogold Ashanti and other partners, such as Zoomlion Ghana Ltd., who are invited for joint planning, information sharing, training opportunities, and shared facilities. For instance, support and collaboration of the program with the Noguchi Memorial Institute for Medical Research (NMIMR) strengthened the capacity of the Abt entomologist and generated critical data regarding the efficiency and effectiveness of the spray program and potency of the insecticide for decision-making. Several observations were made during the field visits and in discussions with various key stakeholders engaged in the planning, implementation, monitoring and evaluation of the IRS activities in the Northern region. Although these observations are not directly related to the environmental compliance inspection undertaken, they constitute key, foundational elements for many of the best practices being undertaken by the program. These observations, which have various implications to the effectiveness, efficiency and future sustainability of the IRS program in Ghana, are found in Annex 6.

3.2 RESIDENTS’ HEALTH AND SAFETY/IEC

AREAS OF COMPLIANCE WITH BMPS

The direct engagement of Abt project’s IEC officer at the regional level, IEC zonal implementers, and Community-Based surveillance volunteers integrated with spray teams at the community level, community dialogue, door-to-door mobilization strategies, and engagement of traditional opinion leaders

19 have been very effective in communicating safety requirements on the side of residents as well as ensuring high coverage of spray teams.

 IEC extension agents of the Ministry of Health mobilizers and both district and community mobilizers were found to have communicated all the necessary information to residents regarding the spray program. IEC agents were present in the communities when the IRS teams were spraying.  The IEC effort appeared very effective in educating residents as to their responsibilities for IRS including the clearing of their rooms of mats, furniture, cooking implements, and foodstuffs prior to spraying. In cases where furniture could not be moved it was observed that these household items had been moved to the center of the room and covered by a plastic sheet, before the spraying was done.  Spray operators specifically tell house owners not to plaster, paint or clean the sprayed surfaces and they also inform the house owners to wait for at least two hours before re-entering the house, then sweep up dead mosquitoes and other insects and deposit them in the latrine and then open windows to allow ventilation of the premises before allowing children or animals inside the house or compound.  From interviews with local residents whose houses were being sprayed, there was evidence that most residents understood and applied the rules on keeping children and large ruminants/ livestock away from the spray area.  Residents interviewed also confirmed that they have been told that in case of contamination with the insecticide, they should wash the contaminated area with soap and water. Also, if they have any reactions or itchy skin that they should go to the nearest health clinic if they are experiencing any symptoms of pesticide poisoning.

AREAS OF LOW-COMPLIANCE WITH BMPS

The points below indicate the areas where low-compliance was observed and the recommendations to achieve compliance in the future.

 Based on our observations in some communities, most children were usually found in safe places around the compound-houses but some were found loitering around in search of their parents or trying to observe what was happening when the spray operator was busy at work. This practice interferes with the spraying process when the spray operator has to shout out instructions for the resident to get the children to safe distances.

Recommendation: In places where children are found loitering around the compound being sprayed, the spray operators, before the start of spraying, must specifically ask the house owners to keep an eye on them and ensure that they do not come close to the house(s) during spraying. The sprayers must also inform them about the need to prevent such incursion until the required two hours after spraying has elapsed and the rooms have been cleaned and ventilated.  In most cases, livestock was tethered a safe distance away from the house or kept in their stalls during and after the two hours upon completion of spraying. However, stray animals and poultry were usually found in the immediate vicinity of the spray area picking things from the ground or trying to enter the compound in some places visited. Recommendation: The mobility of poultry and livestock and their propensity to pick up materials in the spray area are high if they are not enclosed during and the period of 2 hours after spraying

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ends. House owners must be more responsive to the danger this poses to their animals and receive additional instruction on the need to keep all poultry and other animals in secured premises during this period. Extra attention should be paid to this problem by the IEC personnel and mobilizers and highlighted during the mobilization process.

ASSOCIATED ISSUES NOT SPECIFICALLY COVERED BY THE BMPS

In order to increase coverage, the Project has adopted various strategies including the following:

 Engagement of packers for removing items from households prior to spraying in some areas where packing is a problem so that there will be more households willing to accept IRS, reduce unnecessary delays of spraying, and increase the speed of spraying by the spray operators.  Engagement of one IEC/BCC officer for each operational site to handle all the IEC/BCC issues related to the communities in that operational site.  Start the IEC activities as early as 10 weeks before the IRS campaign  Enter mobilization data before the start of the spray operations in order to create reports on the number of compounds mobilized before IRS begins, guide spray operators to specific compounds to spray, help supervisors to supervise SOPs since they will know which compounds they have visited, and, lastly, to avoid missing compounds during spray operations.  Generate data for communities and compounds with low coverage for the district teams to develop re-visit plans and follow-up on specific compounds to ensure that re-visits are effective.

3.3 WORKER HEALTH AND SAFETY

Areas of high and low compliance for worker health and safety, as observed and evaluated during the field visit, are presented below. However, multiple positive test results for mild cases of plasma cholinesterase depression during bio- monitoring of selected program staff is a salient issue.

Bio-monitoring of selected program staff:

Physiologically significant exposure to organophosphate pesticides—including Actellic (pirimiphos methyl) as used in AIRS Ghana IRS operations—results in depression (inhibition) of cholinesterase, an enzyme required for proper regulation of nerve impulse transmission. Cholinesterase depression is the mechanism by which organophosphate poisoning occurs, which in severe cases can be fatal. PPE BMPs and other worker-safety BMPs are intended to limit exposure to Actellic (or other pesticides used in IRS operations) below a level that results in harm.

Field-portable blood tests exist to measure cholinesterase. Such bio-monitoring of cholinesterase requires the establishment of an initial baseline, and periodic, systematic repeated testing of the potentially exposed individuals.

The current PMI BMPs for IRS activities do not require bio-monitoring of IRS workers for cholinesterase inhibition, nor does WHO recommend bio-monitoring for IRS operations using pirimiphos methyl. However, the 2012 Malaria Vector Control PEA does require inter alia, that “organophosphate bio-monitoring will be part of each [spray] program that will be using OPs” and that “PMI will evaluate various approaches for monitoring sprayer exposure to Organophosphates (OP), and

21 will develop protocols based on these evaluations. PMI will use these protocols to guide the implementation of the OP monitoring program” and amend PMI’s IRS Best Management Practices accordingly.

With respect to this requirement and to agreement of the Ghana NMCP, PMI determined that AIRS Ghana would implement PMI’s first IRS worker bio-monitoring program during the 2015 spray season. Abt AIRS developed the program under the supervision and direction of PMI, and with technical support from the National Farm Medicine Center (US) via GEMS. The program was sent to selected sites convenient near medical facilities, using trained medical professionals. It tested spray operators, storekeepers and washpersons at the selected sites.

At the time of this report, Abt AIRS is analyzing the data and developing a report on the biomonitoring program and its results. Analysis conducted on a rolling basis over the spray period did show cholinesterase depression above threshold for some workers, though no clinical symptoms had manifested at the time of this report.

It is not with the remit or technical expertise of this exercise to interpret the biomonitoring results, nor to advise on any policy decisions to be made in response to these results. However, the following observations are offered regarding PPE, whose use is a central focus of the inspection exercise and this report. :  Assuming that cholinesterase depression is attributed to actellic exposure and potential dermal exposure is determined to be of concern, there are opportunities to strengthen PPE without moving to fully impermeable (and thus likely intolerably hot) overalls. Possibilities include a protective hood (to reduce forehead/neck/shoulder exposure), or alternative gloves more suitable for use during repair of congested sprayers.  Assuming that cholinesterase depression is attributed to actellic and potential oral/inhalation exposure is determined to be of concern, filter masks worn could be upgraded. Per the Material Safety Data Sheet (MSDS) for Actellic CS (Annex 8a), provided by the project for Actellic 300CS, a particulate filter respirator "may be needed". All Abt sprayers are reported to be using NIOSH 95 certified particulate filters. However, this MSDS does not distinguish between use for crop protection and for indoor residual spraying. The MSDS for Actellic 50 EC (Annex 8b), a different formulation with the same active ingredient (pirimithos-methyl) indicate that a combination gas, vapor and particulate respirator may be necessary. Similar recommendations are defined by the MSDS for Actellic 900 (Annex 8c).

AREAS OF COMPLIANCE WITH BMPS

Observations showed that all conditions required for protection of the health and safety of storekeepers and spray operators are fulfilled in the field. Training of all personnel including selected health care providers in safe handling of the insecticide and provision of technical support for environmental compliance are primary vehicles for ensuring that attention is paid to compliance with best management practices, including the following:

 Storekeepers and spray operators wear the appropriate uniform of Personal Protective Equipment (PPE).  There are extra clean PPE and spraying equipment available in the central store and other stores visited.

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 Each store visited had a pesticide Material Safety Data Sheet (MSDS) and a fully stocked emergency first aid kit for spray activities.  All visitors to the store are given nose masks and the storekeepers wear appropriate PPE.  There is soap and water available for washing hands at the soak pits.  Before the beginning of the spray round, all storekeepers, supervisors and spray operators underwent a refresher training in all the best management practices to be followed during the current round of spraying to ensure that all staff understood the importance of following best practices.  Storekeepers have been trained to recognize the symptoms of pesticide poisoning; they know where the nearest health facility is located and how to treat suspected pesticide poisoning.  There are health clinics in the vicinity of all the stores and the health clinics have the capacity to treat patients for pesticide poisoning and have been provided with the antidote, Atropine.  All women who have been selected to participate in the IRS activities undergo pregnancy tests before the start of the program.  Women who are breastfeeding are prohibited from spraying the pesticide or washing contaminated items.  All spray operators undergo a medical test to establish their health-status and the site manager at each operational site has filed all medical test records so they know the status of each person working in the field.  SOs were observed wearing the PPE on the way back to the site office wash site.  All SOs completed their daily report forms that were checked by spray supervisors.  All empty tripled-rinsed bottles and unused bottles were returned to the storekeeper who ensures that they were counted and stored in labeled, sealed containers.  All wash persons with the responsibility to wash overalls used during each day of spraying were supplied with appropriate PPE which they were wearing at all required times and places during the visits.

ASSOCIATED ISSUES NOT SPECIFICALLY COVERED BY THE BMPS

 A pre-spray environmental compliance inspection was undertaken by a team of inspectors including the Abt Environmental Compliance Officer, EPA official, and other staff in order to ensure that adequate preparations have been made to guarantee full compliance to the BMPs and the spraying activity. A mid-spray environmental compliance inspection was also in progress during this period to ensure that the spraying operations were being implemented successfully.  Environmental Compliance Guidelines and checklist drawn from the PMI/IRS BMP manual have been developed to be used for training, quick reference material for all staff and for pre, mid, and end of spraying assessments.

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3.4 STORAGE AND STOCK CONTROL AT THE CENTRAL, DISTRICT, AND IRS SITE STORES

The Abt central store, which is located in Nyohin in Tamale on the premises of the regional medical store (provided by the Ghana Health Service MOH), and the various district/site stores in West Mamprusi, East Mamprusi, Bunkpurugu/Yunyoo, Mamprugu Moaduri and Kumbungu were visited and observed during the arrangements, protection, security, activities, and operations prior to and during the spraying. High compliance with the established best management practices was observed.

AREAS OF COMPLIANCE WITH BMPS

 The central store, provided by the Ministry of Health, is fenced in and has air conditioners and fans installed to control the high temperatures that are typical of the region. The central store has 24-hour security-detail.  Although the buildings at the operational sites are not fenced, they are fairly well secured and are guarded 24 hours a day. Two padlocks secure every store and the windows are barred. The observed guards were wearing appropriate overalls. A robust wire fence that is locked when not in use secures all the soak pits.  The storage facilities were provided by the district assemblies and refurbished by Abt. All visited sites were properly secured, have double locks and secured windows, and adequate ventilation windows and fans. All the facilities have “danger warning” signs marked with “cross bones” at appropriate places with warning in the English language.  The local fire department and medical centers in each location are aware of the facility and its contents. And all supervisors interviewed knew the location of the nearest health facility. They also know how to treat people with symptoms of pesticide poisoning. Abt has trained all relevant medical staff members in the clinics regarding how to handle pesticide-poisoning cases and atropine antidotes were supplied to all the health facilities.  The warehouse supervisors and storekeepers were all observed wearing appropriate PPE and all those entering the store wore masks.  All stores have extra clean PPE and fully stocked emergency first aid kits specifically for spray activities. There is soap and water available for hand washing in all the facilities visited.  All the stores have a system of recording stock cards and all were up to date, which allowed the storekeeper to indicate what quantity to date has been used and what quantity of the stock remains.  All stores have a filing system and the insecticides are properly labeled and shelved in an orderly manner on wooden pallets.  The pesticide Material Safety Data Sheet (MSDS) and other laminated safety guidelines have been posted on the walls of all stores visited.  No insecticides that had expired were found in any of the stores visited.  All used insecticide plastic bottles were counted and stored in correctly labeled boxes and bags.  All other solid wastes were counted and stored in labeled boxes in the stores.  Insecticide stocks were stored on wooden pallets and were not piled higher than 2 meters.

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 There was an emergency-kit consisting of a bucket of sand and a shovel, as well as a fire extinguisher. There was also soap and water available for hand washing.  Only spraying and cleaning-related equipment and supplies were stored in the stores. All extra equipment was clean and stored properly in the stores  Windows allowed adequate ventilation, the floor was impermeable and there was a strategy in place for disposing of segregated solid waste at the end of the spray season by sending them to the central store, where they are re-sorted, packed into containers, and sealed while awaiting transport to the incinerator for destruction.  All the storage facilities were located away from nearby watercourses, domestic wells, markets, school, and hospitals.  Every store has a thermometer for monitoring daily temperature in the storage facility.  All the operational sites have soak pits and associated supplies, such as drums for triple rinsing, along with space for washing and drying of items contaminated with PPE. There are also male and female bath stalls for personal cleaning at the end of the day’s work.  The old stock of insecticide from the previous year’s campaigns was issued out on “first in first out basis by the storekeepers.

AREAS OF LOW-COMPLIANCE WITH BMPS

Although the stores were well secured, all had a single entry and exit door and so the access and exit pathways must be clear at all times. In some locations, the pathways were not very clear of obstructions.

Recommendation: With regard to the singular entry and exit door in all stores, it was observed that, with the exception of the central store in Tamale, these buildings, mainly provided by the District Assemblies in the operational sites, were relative small (about 14ft x 14ft) and so are relatively easy to vacate in case of any problem. It is, however, recommended that Abt’s personnel responsible for these warehouses remain vigilant and observe all the guidelines for preventing fire outbreaks, such as the provision of adequate ventilation to keep temperatures at low levels in the stores. Furthermore, the pathways to the exit door must be kept clear of all pallets, cartons, boxes, and other hindrances so that there will be easy and quick exit from the store in case of fire or any accident and posting appropriate signs indicating the danger of fire outbreaks in the stores and how to exit the room in case of an emergency. The practice of installing two air conditioners in the central warehouse in Tamale and fans in the stores at operational sites, in order to keep temperatures low and reduce the chance of overheating of the facility, is commendable.

ASSOCIATED ISSUES NOT SPECIFICALLY COVERED BY THE BMPS

The Central Warehouse and stores of the operational sites visited have thermometers for measuring and monitoring temperature-levels twice a day in the storage facility. All the daily records observed were up to date. The time demanded by this activity could, however, be reduced if an electronic temperature-measuring device was installed.

Recommendation: This process of daily recording the temperature in the insecticide store could be automated to remove the daily time required. Electronic, data loggers are now available cheaply and will record temperatures at 30-minute or hourly intervals for long periods of time. The log data is simply downloaded onto a computer that has logger software installed. For an example of an electronic data logger, see http://www.onsetcomp.com/products/data-loggers/u12-012.

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3.5 TRANSPORTATION OF PESTICIDES SUPPLIES AND EQUIPMENT

AREAS OF COMPLIANCE WITH BMPS

 Presently, on arrival in the country, an international logistics company appointed by the supplier handles the cargo. The containerized-insecticides are sent directly from the receiving port in Tema to the central warehouse in Tamale before being subsequently distributed to the 16 permanent operational sites and one temporary site in the five target districts where the IRS activities are being implemented.  Through a competitive bidding process, the Project contracts local transport unions within the targeted districts to provide pick-up buses and motorbikes for the daily transportation of the spray-teams and district officers to and from the operational sites during the period of spray operations.  Covered, secured container-trucks are used to transport the insecticides to the districts and IRS sites.  The drivers of these vehicles used in this activity have been trained in how to handle emergencies and to decontaminate their vehicles in case of accidental spillage. To date, no accidents have been reported during the transportation of the insecticides to the districts and IRS sites.  The stores are located in the various IRS operational sites where the spraying activities are to be undertaken. On the day of spraying each spray operator, who resides in the same operational area, receives his/her supplies at the store nearest to the targeted spraying area. The sprayers (both men and women) are transported in rented buses to the communities where they will be spraying.  Certified and trained drivers drive these buses and each vehicle is provided with supplies of first aid kits and clean-up tools. The drivers has received training regarding what to do in case of an accident and/or a spill.  The spraying equipment is secured in such a way that the possibility of spillage is eliminated. In interviews with some of the spray operators, they indicated that there have been no accidents or spillage associated with the use of the buses.  At the end of the spraying session, the spray operators get back to their base-store, which has the wash area with the “triple rinse” facilities, the soak pit, and the bath areas for cleaning up. There are no compliance issues in the movement of spray operators from their base to the target sites and back to the store and wash area at the end of the day.

3.6 SPRAYING OPERATIONS

AREAS OF COMPLIANCE WITH BMPS

The spray operators demonstrated their understanding of the established best management practices (detailed below) and as they were observed worked they appear to follow them to the best of their ability.

 Pumps are checked and tested prior to being issued out to spray operators by the team leaders and supervisors at each IRS operational site.

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 All the stores visited have a first aid box with recommended medicines and supplies and storekeepers have been trained in first aid and in treating insecticide exposure. Based on interviews, all storekeepers know where the nearest health clinic is located.  During the start of a typical workday, the storekeeper and supervisor arrive early in the morning of the workday; count and record the number of insecticide bottles in order to maintain an up-to-date record of stocks received, held, and issued. Meanwhile, the SOs receive breakfast before they start the day’s activities. After eating, the SOs congregate for a briefing session after which the equipment and insecticide are issued to them by the team leaders who arrange all the clean PPE and spraying equipment outside for the spray operators in their teams. The full set of appropriately-sized PPE which the spray operators receive and wear prior to receiving their final instructions include: face shield, nose-and mouth-covering mask, overalls, gloves, boots, and a flashlight.  The storekeepers and supervisors were all observed to be wearing appropriate PPE prior to dispatching spray operators.  Interviews with spray operators confirmed that they kept their eyes on the pressure gauge to ensure that the pressure was always close to 3.8 bar (55psi).  The observed spray operators at various locations were never seen eating, smoking, or drinking water while spraying.  The spray operators were observed to be applying all the best management practices associated with distance from the wall, use of vertical swaths with downward and upward motion, observance of pressure gauge, overlapping of spray swaths by 5cm, evenness of spraying, and how to deal with clogged nozzles.  All walls, thatch roof, and wooden or straw doors were sprayed according to the specific instructions provided.  Spray operators interviewed confirmed their adherence to the practice that floors, metal roofs, doors, glass, inside of cupboards, food storage structures, curtains, latrines, and animal pens should not to be sprayed.  The sprayers add leftover insecticide and water from triple rinse for the day to the pumps to be used the next day when they prepare to fill their spray tanks.  IRS operations are carried out with all the precautions in order to avoid contamination of both surface and underground water by conducting spraying indoors and not spraying within 100 meters from any water body. These precautions apply to all aspects of IRS spray operations, including the store and soak pit location.  IRS insecticides that contain pirimiphos-methyl are poisonous and a danger to bees. Interviews with some of the spray operators demonstrated their understanding that spraying is not done within 100 meters from any apiary. In fact, reconnaissance trips are conducted prior to the spraying activities to ensure that there are no beekeeping operations at the spraying sites.  All belongings, except immovable ones, had been moved outside of the room(s). Harvested produce was also moved out of the structure in which they were located so that they were not sprayed.

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AREAS OF LOW-COMPLIANCE WITH BMPS

Some spray operators experienced nozzle clogging and had to stop work and unclog them. This delayed the work and increased the risk of contamination, especially if the bulky hand gloves were removed in order to use the brush needed for cleaning such nozzles.

Recommendation: Both Goizper and Hudson sprayers have sieves (filters) installed in them and each spray operator has been provided with a filter to use in case the water available at the community level is not very clean. The cause of nozzle clogging could be due to poor shaking of the insecticide and water mixture. Greater emphasis on the mixing technique during the pre-departure briefing could be minimize or eliminate the problem. Furthermore, there is a need to constantly check the performance of the nozzles and to ensure that they are worn and/or faulty ones are replaced. It is also important to advise SOs to check the condition of the filters in the pumps and also use the supplied filters that they have in their bags to eliminate particles larger than the nozzle diameter.

ASSOCIATED ISSUES NOT SPECIFICALLY COVERED BY THE BMPS

An orientation and clear instructions covering good practices to be followed in the field is provided at the beginning of the day.

Due to good distribution of information in their communities through radio spots and local community leaders prior to the day of spraying regarding their roles and responsibilities, high coverage of households exist. In the communities visited, homeowners were prepared for the sprayers at the time of their arrival. Interviews with other spray operators indicated that residents were most often prepared.

AREAS OF LOW-COMPLIANCE WITH BMPS

To save costs, the Project did not hire pump mechanics for each of the operational sites but rather provided training for the team leaders (site managers and supervisors) as pump mechanics and provided each site with pump repair kits to enable them to repair pumps when they broke down. Problems with the pumps were observed and reported by spray operators during the spray operations due to leakages at the hose/tank junction and nozzle clogging. Also occasional breakages of the plastic plunger’s locker occurred. The problems were mainly associated with the Goizper pump and this delayed the work of the affected spray operators and put a lot of pressure on the team leaders to get them fixed quickly since they had only two spare pumps in each store.

Recommendation: The project needs to increase the number of spare pumps and pump repair kits at each of the operational sites and promptly respond to requests for repair kits by site managers. The project must also consider contracting on-call pump repairers, in cases of acute needs that could not be provided by team leaders in the field. The Project should also take a closer look at the performance of the Goizper spray pump.

3.7 CLEAN-UP FACILITIES, POST-SPRAYING ACTIVITIES AND WASH WATER DISPOSAL

AREAS OF COMPLIANCE WITH BMPS

 The spray operators were seen wearing PPE while returning from the day’s activities to the wash site, which is in close proximity to the store at the operational site. No one at the facility was seen eating, drinking, or smoking.

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 All the wash sites were equipped with barrels of water, soap, fenced soak pit with drying areas above and facilities for doing triple rinsing when cleaning the pump. There were also male and female bath stalls for face, hands, and body washing.  All the soak pits have been rehabilitated recently and they are up to the standards related to the recommendations of best management practices.  Seven plastic barrels are used for progressive triple rinsing technique of used spray pumps. These barrels are arranged on the inwardly sloped cement floor sloped towards the soak pit in the middle of the wash area to direct any spills into the soak pit during the rinsing process.  Progressive triple rinsing process uses 7 barrels. Barrels 2, 4, 6 contain water for the rinsing out spray pumps and barrels 3, 5, and 7 receive the product of the rinsing from spray pump. Barrel 1 receives remaining insecticide solution from the field, though in most cases SOPs come back from the field with no remaining insecticide solution. After completing all progressive rinsing the more concentrated insecticide solutions in barrels 1, 3 and 5 are reused by SOPs to fill their pumps the next day. The spray operators come in to complete and hand over their daily report forms and as well as full and empty sachets which are received, counted and stored in a labeled sealed box by the storekeeper.  All the washers were observed to be wearing their PPE, receiving contaminated PPE for washing at the soak pit, and observing the same rules when doing the washing at the soak pit area.  A secure wire fence protects all the soak pits and a latched door with a lock secures the entrance. During and after the spraying rounds when the pits are not in use, they are locked to prevent animals, children, and unauthorized persons from getting into the soak pit. There is a skull and cross bone warning sign is posted on the four sides of the soak pit.  During the spraying season, a 24-hour security watch protects the stores and soak pits. After the spraying round, the wire-fenced soak pits are securely covered and locked to deny access to any intruders and wildlife. Where temporary structures for after-spraying cleaning by field spraying teams have been erected, the structures are dismantled and site is cleaned and decommissioned. The seven triple-rinse barrels are covered when not in use to exclude birds, bees, and other wildlife, which are not barred by the wire fence installed at the soak pit area.

3.8 SOLID WASTE DISPOSAL

AREAS OF COMPLIANCE WITH BMPS

 The processes for the collection, segregation, transportation, and destruction of IRS-generated solid waste are well established and followed by Abt. Zoil Company Ltd, which has state-of-the- art, double-chamber incinerators that are capable of reaching over 1,300 degrees Centigrade. They currently undertake the destruction of contaminated materials from the spraying program.  All contaminated materials accumulated during the spray season, including the triple-rinsed plastic insecticide bottles, used nose masks, polythene sheets used in covering immovable household items during spraying, torn gloves, and insecticide cartons, are segregated, packed, and stored at the operational-site stores until the end of the spray season. At that time, they are subsequently transported to the central warehouse located in the Central Medical Stores of the Ministry of Health in Tamale

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 The waste materials are segregated and documented at the central warehouse and subsequently transported to the final destination for disposal.  Disposal of Actellic plastic containers and insecticide cartons: Actellic insecticide that is being used in the current IRS round is a liquid formulation in a 1-liter plastic bottle. Recycling empty 1-liter plastic pesticide containers that have been triple-rinsed is the preferred means of disposal. Incineration is not recommended. Empty plastic pesticide containers once triple-rinsed are considered in many European and North American countries (including by the United States Environmental Protection Agency (EPA)) to be non-hazardous wastes, according to the WHO Guidelines on Management Options for Empty Pesticide Containers. Although they still may hold some minimal amount of pesticide residues and should not be re-used. The plastic bottles have been sent to Cyclus Elmina Plastic Recycling Ltd. in the past but due to operational challenges being faced by the company, the project has decided to send all to Zoil Services Ltd., in Takoradi, Ghana for recycling.

ASSOCIATED ISSUES NOT SPECIFICALLY COVERED BY THE BMPS

 Insecticide cartons: The insecticide carton boxes have been recycled at the Cyclus Elmina Plastic Recycling Ltd., in the past but now are under the services of Zoil Services Ltd. The Project is currently exploring the possibility of supplying these paper-cartons to paper recycling companies in the country which are willing to use them provided they are not contaminated by leaked insecticide.  Disposal of all other contaminated waste materials: The rest of the contaminated materials, including used nose masks, polythene sheets used in covering immovable household items during spraying, and torn gloves are sent to the Zoil incinerator in Takoradi. It has been, however, proposed that the Project should explore supplying these products to plastic and rubber recycling companies for recycling.

Recommendation: It is important for the Abt to verify the types of products the recycling firm intends to produce with the recycled plastics and weigh the potential risk of the public’s perception of products being made from recycled pesticide containers. Any disposal solution selected should receive prior approval from USAID PMI.

4.0 STATUS OF KEY ISSUES IDENTIFIED IN 2014 AND 2015 ENVIRONMENTAL COMPLIANCE INSPECTIONS

No independent consultant environmental compliance inspection was undertaken during the 2014 campaign to specify key issues that needed attention. There are, however, various issues raised in the monitoring reports of the Mission Environmental Officer (MEO), The Environmental Protection Agency monitoring report in 2015, and those identified in the pre-spraying environmental compliance inspection report of 2015. The status of these issues was determined during this current inspection. The issues identified in the above-mentioned reports and their current status is provided below:

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4.1 USAID MEO’S MONITORING RECOMMENDATIONS, MAY, 2014 ISSUE RECOMMENDATIONS STATUS In Savulegu/Nanton, All torn plastic sheets for covering All worn-out plastic sheets have some plastic sheets used immovable items in rooms must be been withdrawn and new ones by the sprayers are checked and those found to be worn- issued to spray operators. worn out and should be out replaced. replaced Some residents refused There must be increased sensitization Sensitization involving opinion entry of SOs to their efforts in areas where refusal is leaders, assembly men and premises because they prevalent. women, and traditional did not feel comfortable authority, along with the use of having the sprayers radio stations and information enter the rooms. Some vans from the Ministry of Health also suggested they have have been increased and proved too many things to pack to be working. out. A few spray operators in Briefing sessions prior to the This issue continues to be Savelugu/Nanton were departure of the spray operators addressed during the morning observed to be drinking should emphasize the importance of pre-departure briefing session water during the time not drinking water, eating, or smoking. by site managers and when they were actively supervisors. spraying household structures.

4.2 PRE-SPRAYING INSPECTION REPORT 16TH – 22 FEBRUARY, 2015, ABT ASSOCIATES. ISSUE RECOMMENDATIONS STATUS It was observed that Check, categorize, and rehabilitate all All the faulty soak pits have been most of the soak pits soak pits that have developed cracks rehabilitated and some new had developed cracks and hence are unsafe to continue using ones built before the start of the and need some 2015 campaign. rehabilitation Almost all of the “ The Project should print and supply New Danger signs have been Cross bone and Skull” new Danger warning signs to all produced, sent, and posted at all Danger warning signs operational site. operational sites. posted at critical locations have faded out and will need replacement Most of the windows The project should bar all windows at All windows at the storage are screened but not the operational sites. facilities have been barred at the barred. They are not time of the inspection. secured enough to prevent theft.

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ISSUE RECOMMENDATIONS STATUS New structures are There is a need to address this issue Extra precautions have been springing-up close to the by strengthening the management of taken to ensure the vigilance of current offices rendering the facilities and being vigilant in the 24-hour guard. them unsafe for insecticide management in the stores. pesticide storage. The Sakogu, Wungu, Four new soak pits should be The four new soak pits have Kumbungu, and Dalun constructed in Sakogu, Wungu, been built in the specified operational sites need Kumbungu, and Dalun before the locations. new soak pits. beginning of the spray season. Atropine medication for All outdated Atropine supplies must Outdated atropine medication poison management in be recalled and replaced with new was recalled by the project and all the health facilities ones. new batches supplied to all visited will be expiring in relevant medical facilities. February or March 2015. Some unwanted The storekeeper should rid the store The stores have been cleaned materials were found in of all unwanted material and clean the and the new stock has been the Central Warehouse store before arrival of the new stored. prior to the arrival of consignment. the new consignment. As at the time of the An operation site has to be provided A new facility has been acquired inspection the with operational-site facilities quickly and appropriately furnished to Kumbungu district did to make it functional for the 2015 meet the required standards to not have an operational spraying campaign. serve as an operational site. site. The life span of the fire All fire extinguishers at the district All expired fire extinguishers extinguishers in the level and central warehouse should be have been recalled, refilled, and central and district refilled. sent back to the operational stores have expired and sites. need to be refilled. Some stores including Rehabilitate the roofs of the affected Roofs of all the affected stores those at Nasuan, stores. have been rehabilitated. Nyankpanduri, and Kubori have leaky-roofs. Newly-built insecticide All the required window cups stores and shelves at have been installed at all the Dalun, Kumbungu, Install window cups to protect the newly-constructed insecticide Sakogu and Wungu newly-built insecticide stores and stores do not have window shelves to prevent rain from entering cups to prevent rain the rooms in these locations. from entering the store rooms.

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ISSUE RECOMMENDATIONS STATUS Spill response These critical documents have procedures and MSDS Spill response procedures and MSDS been laminated, supplied, and are currently in should be laminated and posted in all posted at all the operational unprotected paper Project insecticide stores including the sites. versions making them central warehouse in Tamale. amenable to wear and tear. Pump hangers in some Weak pump hangers must be replaced New pump hangers have been operational sites are with new ones. constructed and supplied to all weak and cannot hold all operational sites. spray pumps after the post-spraying cleaning operations.

4.3 PRE-SPRAYING INSPECTION REPORT, ENVIRONMENTAL PROTECTION AGENCY (EPA) 2015 ISSUE RECOMMENDATION STATUS Some of the soak pits There is a need for the project to The operational sites in question and were identified to have conduct similar monitoring visits others were examined during the been prone to flooding during the rainy season to determine inspection and it was observed that during heavy downpour, the ground status. although there were gullies in the especially the Gambaga vicinity of these soak pits, indicating and Wungu sites. These flooding of the area, all soak pits have sites could pose a threat been sited on higher ground and to people living within provided with a foot-high platform to the immediate prevent flooding of the soak pit and environment. thus are considered safe.

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ISSUE RECOMMENDATION STATUS It was also observed that There is the need for proper toilet The temporary bathrooms, one each the Nasuan and Bindi and urinary facilities to be for males and females, are intended sites did not have well- constructed at these locations in the to serve the purpose of post-spray constructed toilets and foreseeable future to reduce washing only by spray operators bathrooms within the potential for Environmental Pollution during the month-long spraying buildings. ‘’Zana mats’’ and improve air quality levels within period and did not need to be have been improvised to the respective environments. permanent structures. create room for They will be de-commissioned after workers to free the campaign to decontaminate the themselves when location. necessary. The temporary structures observed do not serve as toilet facilities. Indeed, toilets are provided for all field operators at all the operational site offices adjacent to the wash area. In the case of Bindi and Nasuan, new toilet facilities have been constructed with the aid of the Environmental Health Officer of the Bunkpurugu- Yunyoo District Assembly. Some sites did not have Efforts should be made to provide The project has installed fans in the sufficient ventilation and adequate lighting and create enough facilities that have electrical power lighting systems in the ventilation in the stores to reduce and those that do not have adequate insecticide stores, which the potential threat of over-heating. vents to reduce the temperatures could lead to warming of during the peak hot periods of the the storerooms as well day. Adequate lighting has also been as pose a potential provided where this was considered threat to fire outbreaks. a problem. Some of these sites include Nasuan and Bunkpurugu.

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5. ANNEXES

ANNEX 1: PHOTO GALLERY

Arrangements in the central warehouse, Tamale. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

Air conditioning and ceiling fan to keep temperatures down in central warehouse, Tamale. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

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Typical clean-up facilities at the Tamale Central Warehouseshow. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

Pre-departure briefing of spray operators by the Environmental Compliance Officer and Supervisors at Wungu in (West Maprusi District (WMD).

Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

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Water supplied by contractor for spray operators and washpersons at Wungu, WMD. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

A typical well-constructed and secured soak pit at operational site at Wungu. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

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Spray operators ready to leave for work in the communities at Wungu Operational Site. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

Type of bus used to transport spray operators from operational sites to communities at Wungu Operational Site. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

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Packing of insecticide and contaminated materials at the Wungu operational site’s chemical store. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

Washpersons doing their work within the perimeter of the soak pit, Wungu. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

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Up-to-date temperature logging in insecticide stores at Kpasinkpe operational site - WMD. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

Orderly triple rinsing by spray operators and cleaning of sprayers after the day’s work at Kpasinkpe, WMD. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

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The consultant and environmental compliance officer of Abt with spray operator before commencement of work in a household at Gbensi, WMD. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

Tired spray operators waiting their turn to clean their sprayers at the soakpit in Kpasinkpe, WMD. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

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Routine cleaning of spray pump by a spray operator at Kpasinkpe, WMD. Photo Credit: Dr. John Nene- Osom Azu, GEMS Consultant.

Post-spraying debriefing by the Environmental Compliance Officer whilst spray operators wait their turn at the soak pit at Kpasinkpe, WMD. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

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Field supervisor checking the documentation of a spray operator at Gbungu, East Maprusi District (EMD). Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

Consultant meets with community mobilizer and Abt IEC coordinator while they are doing their work in the field at Gbungu. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

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Typical raised platform of well-secured soak pit at Langbensi in East Mamprusi District (EMD). Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

Analysis of blood samples by laboratory technician and recording of the results by the Abt ECO in the bio-monitoring program at the Bunkpurugu operational site, Bunkpurugu Ynyoo District (BYD). Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

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A supervisor at work assisting and solving problems of spray operator at Gbungu in EMD. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

A spray operator at work in a household at Kunkwa, MMD. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

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Community mobilizer ensuring that all items have been removed from the room prior to spraying at Kunkwa, MMD. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

House owner assisting with the supply of water to be used to mix the insecticide at Kunkwa, MMD. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

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Interaction with District Coordinating Director at the Yagaba District Assembly, MMD location of an operational site. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

Staff at Kubori operational site. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

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Staff at Kumbungu operational site. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

Typical arrangement in supplies store at Dalun operational site, Kumbungu District (KD). Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

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Typical operational site offices and stores at Dalun, KD provided to the program by the Chief of the community. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

Interactions between the ECO, the Kumbungu operational site manager, and store assistant. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

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Pre-spraying checks by supervisor and spray operators at Kumbungu. Photo Credit: Dr. John Nene- Osom Azu, GEMS Consultant.

Householders ensuring that all items are removed from the rooms prior to spraying at Kunmbungu. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

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Recycled insecticide plastic containers from Universal Plastic Products Recycling (UPPR) Co Ltd., a mother company of Zoil Services Ltd and Cyclus Elmina Plastic Recycling Ltd.. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

A product manufactured from recycled plastic containers by Universal Plastic Products Recycling Ltd. Tema. Photo Credit: Dr. John Nene-Osom Azu, GEMS Consultant.

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ANNEX 2: TERMS OF REFERENCE

GEMS Independent Environmental Compliance Field Evaluation of USAID’s President’s Malaria Initiative (PMI) Indoor Residual Spraying (IRS) Activities in Ghana Scope of Work To conduct an independent environmental compliance field evaluation of PMI Indoor Residual Spraying (IRS) activities in Ghana Background. The USAID Global Health Bureau has tasked the GEMS project with undertaking field evaluation visits to support USAID Missions in ensuring that the environmental management plans associated with their malaria indoor residual spraying programs are being effectively implemented. This Scope of Work establishes the responsibilities and technical approach for an expert evaluator (Consultant) to undertake such an environmental field evaluation of IRS activities in Rwanda. The field evaluation will be concurrent with the PMI Implementing Partner (Abt Associates) February – March, 2015 spray campaign in the following geographic area(s): . Bunkpurugu-Yunyoo District . East Mamprusi District . West Mamprusi District . Mamprugo Maudori District . Kombungu District Specific Objectives of Field Evaluation  The Consultant is expected to complete an environmental field evaluation of PMI spray activities in concert with the Abt Associates-led spray campaign in the above-noted geographic areas.

The field evaluation shall be undertaken using the Agency-approved environmental mitigation and monitoring plan (EMMP) for PMI Indoor Residual Spraying activities, and the Best Management Practices (BMPs) for IRS activities developed collaboratively between the Global Health Bureau and Implementing Partners through the PMI program. The Consultant will also provide problem-solving support, as may be required, to the USAID Mission and the PMI Implementing Partner. These efforts will also highlight risks associated with particular program activities and therefore enable improved program monitoring and training. Specific Tasks. To achieve these objectives, the Consultant will: A. Review past evaluation visit reports, the latest environmental compliance documentation, and field reports (SEAs, Amendments, Inspection Reports) from the USAID Mission and PMI Team so as to develop an up-to-date understanding of the program, its achievements and challenges if any, from the environmental perspective. B. Undertake a pre-field visit e-mail exchange and/or teleconference with the Mission Environmental Officer (MEO) and/or PMI Mission Point of Contact in order to: 1. identify/confirm specific issues to be addressed during the field evaluation, with particular reference to those identified during past visits and changing circumstances of program implementation;

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2. confirm mission staff participation (if any) in the environmental field evaluation program; and 3. develop a program for the environmental field evaluation, including soliciting mission guidance on logistical support for the field work. C. With these understandings, contact the Implementing Partner (Abt Associates) country program director and/or logistical director to develop a specific field evaluation program focused on accompanied site visits to ongoing IRS spraying activities and the range of facilities designed to support it. D. Carry out the accompanied field visit program referenced under item C, above. E. Discuss monitoring observations in-depth with PMI Mission Point of Contact, the Abt Associates IRS team (as approved by PMI), and potentially the local National Malaria Control Program Point of Contact. F. Following conclusion of environmental field evaluation visits, conduct an out-briefing with the USAID/Rwanda PMI team, and Abt Associates team (if PMI requests Abt participation). G. Within one week of return from the field, produce a draft field visit report that will highlight the issues and opportunities noted during the field evaluation visits and draw conclusions and recommendations for the country program and follow-up support actions by GEMS, Global Health, or PMI, as may be required. This report will also highlight the lessons learned in the country that the Consultant expects will contribute to compiling and further developing environmental best management practices (BMPs) for the program. This draft report will be submitted to the GEMS Team Leader or his designee for review and for circulation to the Mission and the Global Health Bureau Environmental Officer (BEO) for review and comments. H. Pending timely receipt of comments on draft report, a final version of the field visit report will be submitted to the GEMS Team Leader or his designee for formal transmission to USAID within two weeks after return from the field.

Mission and Implementing Partner Support. Successful execution of this SOW will require mission and Implementing Partner (Abt Associates) support, as noted in the discussion of tasks above. The nature and extent of logistics support from the mission and Abt Associates will be determined under tasks B & C above, and may include Abt Associates being asked to facilitate the securing of a vehicle and driver for the site visits (the cost of which will be borne by GEMS). Locations: Bunkpurugu-Yunyoo, East Mamprusi,Mamprugo Maudori, West Mamprusi, and Kombungu Districts. Duration and Timing: 7-10 working days to complete field evaluation visits depending on the intensity of the spraying program and on the issues and opportunities the Mission specifically raises for evaluation/inspection. In-country portion of the field evaluation will commence on STILL TBD; nominally mid-April Total Ceiling LOE: 15 days (3 days prep., 10 working for field evaluation, 2 days reporting/wrap- up) + any necessary allotment for travel. Deliverables: 1) Detailed draft program for field evaluation visits; 2) Draft field evaluation report within one week of completion of evaluation visits; 3) Final field evaluation report within 2 weeks of completion of evaluation visits submitted in English.

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ANNEX 3: PLANNED SCHEDULE FOR IRS ENVIRONMENTAL COMPLIANCE EVALUATION - NORTHERN REGION/GHANA – DR JOHN AZU

DATE AND TIME ACTIVITY LOCATION REMARKS Monday, 9:00am: In-brief meeting US Embassy, Accra John will go to the with the Accra appointments AOTR/USAID/Ghana by himself Mission, Abt and key national IRS stakeholders

Tuesday, 21st April, Meet with Director EPA, Accra 2015 Tuesday, 21st April Meet with Director Ghana Malaria Control Program Wednesday, April 29 Arrival in Tamale and Tamale Hotel Class  John will be picked settling in of Dr. John One up at the airport by Azu, environmental Abt Project driver compliance consultant  Check in at a Tamale Hotel “Modern City Hotel”  Field visit transport to be organized by Abt 8.30am 8.30am In-briefing Tamale Consultative meeting meetings at Abt office EPA Tamale

Wednesday, April 29 10.00 am EPA Tamale Tamale Consultative meeting

11.00 am Visit to Tamale Inspection of Facility Central Warehouse 12.00 Noon Visit Tamale Consultative meeting Regional Ghana Health Service Offices Thursday, April 30 Travel to West Wungu Operational Site John travelling with Mamprusi Abukari Yakubu - Env. Kpasinkpe OS Compliance Officer of Abt. Meet with district manager/officer Abt to organize field transport for John to In-brief with District conduct inspection Assembly

Visit IRS sites to observe District stores Visit various sites for

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DATE AND TIME ACTIVITY LOCATION REMARKS and inspection Selected communities with field activities Friday, 1st May East Mamprusi Langbisi Operational John travelling with Mr. National Holiday Site (OS) Abukari Yakubu, Abt Environmental Visit to three IRS sites Gambaga OS Compliance officer Abt to organize Sakogo OS transport for John to conduct inspections at these sites Saturday, May 02 Gunkurugu/Yunyoo Nakpanduri OS, Traveling with Abt staff Bindi OS, to this district and sites Gunkpurugu OS to conduct inspection Return to Tamale after visits Sunday, May 03 Tamale Modern City Hotel Resting Day/Re- organization Monday, May, 04 Mampurogo Moaduri Kubori OS Visits will include District courtesy calls to Visit District Assembly Yizesi OS District local Ghana Health Service government office(s) Visit to two IRS sites. Abt to organize transport for John Tuesday, May 05 Kumbungu District Kumbungu OS Abt to organize Visit District Assembly Dalon OS transport for John to hold consultative Ghana Health Service meetings with District Visit to two IRS sites. assembly and conduct inspection at the operational sites and communities Wednesday, May 06 Debriefing Sessions at Tamale office of Abt Abt to organize Abt transport for John Departure to Accra by Abt to organize evening flight transport for John Thursday, May 07 Debriefing with USAID USAID Office, Accra Meet with PMI/MEO

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ANNEX 4: LIST OF DOCUMENTS CONSULTED

1. Environmental Compliance Inspection Report—Zanzibar and Lake Zone (Mwanza, Mara, and Kagera) Prepared for: U.S. Agency for International Development/Ghana Prepared by: Autman Tembo, RTI International April 7, 2013. 2. Environment Compliance Inspection Report –Ghana 2008 Contract GHN-I-00-06-00002-00. Prepared for: Ghana Mission: United States Agency for International Development by Tito Kodiaga, Environment Specialist RTI International. 3. Environmental Compliance Report to the USAID Ghana Mission. Prepared by Justice Odoi, Mission Environmental Officer. 2014. 4. FAO Storage and Stock Control Manual, 1996. www.fao.org/AGP/AGPP/Pesticide/.../103809_en_No 3_Storage pdf 5. PMI|Africa IRS (AIRS) Project Indoor Residual Spraying (IRS 2) Task Order Four. March 2013. Ghana End of Spray Report, Bethesda, MD., Abt Associates Inc. Contract No.: GHN-I-00-09- 00012-00 Task Order: AID- GHN-I-00-09-00013 Submitted to: United States Agency for International Development/PMI (April 23-July 31, 20 12 and October 29 – November 24, 2012) 6. PMI|Africa IRS (AIRS) Project Indoor Residual Spraying (IRS 2) Task Order Four. October 2014. Ghana End of Spray Report, Bethesda, MD., Abt Associates Inc. Contract No.: GHN-I-00-09- 00012-00 Task Order: AID- GHN-I-00-09-00013 Submitted to: United States Agency for International Development/PMI April 14 to May 31 2014. 7. PMI Africa IRS (AIRS 2) Task Order Four, 2014, Ghana End of Spray Report. Spray Campaign: April 29 – June 28, 2013. Submitted January 2014 8. PMI Africa IRS (AIRS 2) Task Order Six. 2015. Ghana Supplemental Environmental Assessment for Indoor Residual Spraying for Malaria Control, 2015-2020. Nationwide Pyrethroids, Carbamates, Organophospates and Chlorfenapyr. 9. President’s Malaria Initiative BMP Manual. Best Management Practices (BMP) for Indoor Residual Spraying (IRS) in Vector Control Interventions, USAID. July,2010 10. The PMI Africa Indoor Residual Spraying (AIRS) Project. Ghana Work Plan & Budget: November 1, 2014 – December 31, 2015. Bethesda, MD. The PMI AIRS Project, Abt Associates Inc. 11. Report On Pre-Season Environmental Compliance Assessment (PSECA) Ghana PMI AIRS Project. 16th -22nd February, 2015. Prepared By Abukari Yakubu (AIRS Ghana Environmental Compliance Officer). 12. Report On Pre-Season Environmental Compliance Assessment Of Insecticide Stores And Soak Pits Under The Africa Indoor Residual Spraying Project In Northern Region. Prepared By the Ghana Environmental Protection Agency 2015 13. Standard Operating Procedures for Indoor Residual Spraying Operations in Ghana, 2014. 14. WHO 2006.Indoor Residual Spraying: Use of Indoor Residual Spraying for Scaling up Global Malaria Control and Elimination. WHO position Statement, 2006.

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ANNEX 5: LIST OF PEOPLE CONTACTED

NO DESIGNATION/ORGANIZAT NAME CONTACT . ON

CDC Resident Malaria Advisor, 1 Philip Ricks Ghana [email protected] President's Malaria Initiative, USAID

2 Justice Odoi MEO/USAID [email protected]

Chief of Party Abt Associates IRS [email protected] 3 Dr. Yemane Yihdego Project, Ghana 0542 231977

Abt Environmental Compliance [email protected] 4 Abukari Yakubu Officer, Abt 0504 394882

Logistics and Procurement [email protected] 5 Eric Amankwah Coordinator, Abt 0249 784276

[email protected] 6 Kofi Aidoo Logistics Assistant, Abt 0204 801889

[email protected] 7 Abu Idrdrisu Regional Director (EPA) 0203 247375

8 Jafaru Musah Program Officer (EPA) 0501 301601

Ghana Health Service, West [email protected] 9 Agunga Bruno Mampusi District (WMD) 0246 531448

District Operations Coordinator, [email protected] 10 Bugri Sanday Gumah Abt 0244969667

District Information Officer, Ghana [email protected] 11 Anioh Raymond Health Service WMD 0505 897029

Spray Operator( SOP) WMD 12 Daa Joseph 0502389386 Kpasinkpe

13 Puso Sahioratu SO, Kpasinkpe, WMD 0505599784

14 Wuni M Pufa Team Leader Kpasinkpe, WMD 020083465

15 Suewieba Sulemana Store Assistant Kpasinkpe WMD 0246077776

16 Aguriba Lawrence SOP Kpasinkpe WMD 0205 512113

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NO DESIGNATION/ORGANIZAT NAME CONTACT . ON

17 Musa Yidana Majeed SO Kpasinkpe 0206080230

18 Banyolinya Mavis SO 0243853361

19 Seidu Tijani SO 0241706275

20 Yakubu Falilatu SO 0203035378

21 Mahammed Rukaya SO 0507803481

22 Anaab Charity SO 0504223688

23 Baba Sufudoniya SO 0202129499

24 Adam Mandiaya Portia SO 0206385573

25 Mumuni Musa Site Manager, Kpasinkpe WMD 0507550845

[email protected] 26 Seth K. Kpormegbe Regional M&E Manager, Abt 0244 968556

27 Kuyilogo Kofi Security Langbensi, EMD

28 Mubarik Beyensi Site Manager Gamaga EMD [email protected]

[email protected] 29 Sualihu Faisal Logistics Assistant, EMD 0244 543966

[email protected] 30 Michael Mensah M&E Assistant 0244912814

[email protected] 31 Yakubu Aishetu Stor Assistant, Gambaga, EMD 0207519980

[email protected] Fuseni Mohammed 32 Site Manager, Sakogu EMD m Mashood 0247 930164

Alhassan Mohamed [email protected] 33 Store Assistant, Sakogu, EMD Bashiru 0244978356

[email protected] 34 Imoran Sumaira IEC Assistant Sakogu, EMD 0241820622

[email protected] 35 Yahaya Mohammed Supervisor, Gambaga, EMD 0246 959995

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NO DESIGNATION/ORGANIZAT NAME CONTACT . ON

[email protected] 36 Mumuni Adam Supervisor, Gambaga 0201558222

[email protected] 37 Abdulai Tahiru Team Leader Gambaga EMD 0207854564

38 Abubakari Tawfik SO Gambaga EMD 0542977403

39 Saapaka Dimbe SO Gambaga 0508851602

40 Ellen Amegbelitor Regional IEC Coordinator 0244868897

[email protected] 41 Adam Fuseina IEC Assistant, Gambaga sub-district 0246079613

[email protected] 42 Issaka Himida SO Gambaga 0206665711

43 Nnumbawuula Razak Site Manager, Langbinsi EMD 0203512370

[email protected] 44 Seidu Rukaya Store Assistant Langbinsi 0209395601

45 Abaga Gladys Supervisor Langbinsi 0208369137

[email protected] 46 Katara Sulemana Supervisor, Langbinsi 0200518387

[email protected] 47 Mahama Saibu Mumuni Site Manager, Napkpnduri, BYD 0202 442822

[email protected] 48 Samuel Fant District Operations Coordinator 0208096889

District Environmental Health officer [email protected] 49 Millio Abdallah BYD 0208725260

[email protected] 50 Issifu Zachari Dindan M&E Assistant, BYD 0202821701

0205720270 51 Louk Emmanuel Site Manager Bunkpurugu Site BYD

[email protected] 52 John Kwotuah Supervisor BYD 0247900304

59

NO DESIGNATION/ORGANIZAT NAME CONTACT . ON

[email protected] 53 Abdul-Rahim Briamah Site Manager BYD, Bindi Site m 0249184449

[email protected] 54 Adam Yakubu Logistics Assistant BYD 0246838404

55 Salaam Comfort B. Store assistant BYD 0547 489135

[email protected] 56 Salamatu Issah Data Clerk BYD 0240508727

[email protected] 57 Fatima Mumuni Data Clerk BYD 0204854966

58 Amankwaah Akilu Data Clerk BYD 0202670135

59 Saaka Asmaw Washer MMD 0544717272

[email protected] 60 Iddrisu Mohamed Site Manager, Kubori MMD 0203861976

District Operations Coordinator [email protected] 61 Issaiah F. Y. Wumbee MMD 0208407990

[email protected] 62 Musah Libabatu Logistics Assistant MMD 0200766880

63 Salifu Asana Store Assistant MMD 0506385372

Mahama Bukari [email protected] .uk 64 District Coordinating Director MMD Mumuni 0244566410

[email protected] 65 Mborignam John Assistant Planning Officer, MMD 0208407638

[email protected] 66 Issifu Abukari M&E Assistant MMD 0243016945

Store Assistant Kumbungu District [email protected] 67 Atsu Btty Yayra (KD) 0502272408

[email protected] 68 Zakiyu Saibu Logistics Assistant, KD 0243618015

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NO DESIGNATION/ORGANIZAT NAME CONTACT . ON

[email protected] 69 Issahaku Mohammed Site Manager, KD 0203031314

[email protected] 70 Iddrisu Richard District Operations Coordinator 0207921973

[email protected] 71 Biney Alfred Jojo Site Manager KD 0249399655

[email protected] 72 Ahassan Mariama Store Assistant KD 0202677734

73 Seidu Abubakari Iddi Supervisor KD 0245373809

[email protected] 74 Hamidu Aminu Disease Control Officer KD 0201270653

District Director of Health Services, [email protected] 75 Hadjara Haruna KD 0208076025

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ANNEX 6: OTHER ISSUES THAT DETERMINE LEVEL OF SUCCESS OF ENVIRONMENTAL COMPLIANCE AND IRS OPERATIONS

There were several observations in the field as well as insights that were collected during the discussions held with various technical and district administration officers, various officers of the National Ghana ministries, departments, agencies, and during the review of the program’s documents. Many of the issues and their impact on the program and its future sustainability are discussed below:

The IRS program is expected to provide, among others, technical support to various activities including the following:

 Training, capacity building, and advocacy at the national, regional, and district levels as a means of achieving IRS sustainability. This included building the capacity of government officials and partners to undertake high-quality IRS.  Regular monitoring and evaluation (M&E) of the IRS program.  Logistics assessment and coordination of all procurement, shipping, delivery, and storage of spray pumps, spare parts, insecticides, and personal protective equipment (PPE);  Safe and correct insecticide application, thus minimizing human and environmental exposure to IRS insecticides, in compliance with the Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP) and Supplemental Environmental Assessment (SEA);  Coordination of information, education and communication (IEC), sensitization, and mobilization activities with other stakeholders to raise the populations’ awareness of IRS and to encourage ownership;  Promote cost-efficiency through due diligence and efficiency of operations.

A6-1 SOME KEY ACTIVITIES CONTRIBUTING TO SUCCESS OF THE PROGRAM

 The Ghana IRS team continues to work in partnership with the Ghana Health Service, the National Malaria Control Program, and other key institutions to harmonize relationships, coordination mechanisms, and key processes. All these organizations/persons are involved at various levels in the implementation of the program through joint planning, coordination, and review meetings that ensure the inclusion of all stakeholders up to the village level.  There is a strategic vision, multi-year strategic framework, and effective multi-stakeholder coordination across all sectors to guide the development, implementation, and monitoring and evaluation of program activities. There is also assured donor support and high-level political leadership in Ghana. The advocacy meetings, that are held at the regional, district, and community levels all include relevant stakeholders, are a key mechanism for effective coordination of activities across the different sectors involved in the IRS program.  The IRS team continues to provide technical support to local staff and community members for implementation of IRS operations as well as support for entomological monitoring with the support of Noguchi Institute of Medical Research (NMIR). The program is also involved in the operational research by the US Center for Disease Control (CDC) to monitor anemia and parasitemia levels among children less than five years of age, as well as engagement in the routine epidemiologic monitoring.

62

 The Ghana IRS team has supported the establishment of a National Insecticide Resistance Network by working with Noguchi Memorial Institute for Medical Research to finalize the Malaria Vector Control Oversight Committee (MaVCOC) concept paper and to establish a functioning network as well as engage in entomological monitoring to guide proper targeting of IRS,  The team- supports micro-planning meetings as part of the preparations for IRS operations.  The team conducts environmental and logistics assessments for efficiency and effectiveness of operations and environmental staff.  The team collaborates with officials from GHS, EPA, and other key stakeholders to conduct joint pre-season environmental assessments and compliance inspections.  All staff, including mobilizers, IEC assistants, logistics and store assistants, M&E coordinators and GHS staff, spray operations coordinators, site managers, database managers, health workers involved in poison management, those involved in applied entomology, and drivers are adequately trained to carry out their duties as efficiently as possible.  There is adequate monitoring and supervision at all levels throughout the different stages of the spray campaign (before, during and after). All teams, comprising the Chief of Party, Operations manager, M&E manager, Database manager, IEC Specialist, Environmental Compliance officer, spray operations coordinator, district M&E coordinator, district logistics officer, the site managers, field supervisors and team leaders, are all equipped with standardized AIRS supervision and monitoring tools for spray quality, environmental compliance and data verification tools.

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ANNEX 7A: ZOIL SERVICES LIMITED INCINERATOR

64

ANNEX 7B: IRS WASTE DESTRUCTION CERTIFICATE

65

ANNEX 7C: INCINERATION INVOICES

66

67

ANNEX 8A: MATERIAL SAFETY DATA SHEET FOR ACTELLIC CS

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SECTION 1. IDENTIFICATION OF THE SUBSTANCE/MIXTURE AND OF THE COMPANY/UNDERTAKING

1.1 Product identifier Productname : ACTELLIC CS Designcode : A15293BA

1.2 Relevant identified uses of the substance or mixture and uses advised against Use : Insecticide 1.3 Details of the supplier of the safety data sheet Company : SyngentaCropProtectionAG Postfach CH4002 Basel Switzerland Telephone : +41613231111 Telefax : +41613231212 Emailaddress : [email protected]

1.4 Emergency telephone number Emergency tel e- : +441484538444 phone number

SECTION 2. HAZARDS IDENTIFICATION 2.1 Classification of the substance or mixture ClassificationaccordingtoRegulation(EU)1272/2008 Acuteaquatictoxicity Category1 H400 Chronicaquatictoxicity Category1 H410 ForthefulltextoftheHStatementsmentionedinthisSection,seeSection16. ClassificationaccordingtoEUDirectives67/548/EECor1999/45/EC N,Dangerousfortheenvironment R50/53:Verytoxictoaquaticorganisms,maycauselongtermadverseeffectsintheaquaticenviron ment.

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2.2 Label elements

Labelling:Regulation(EC)No.1272/2008 Hazardpictograms

Signalword : Warning Hazardstatements : H410 Verytoxictoaquaticlifewithlonglastingeffects. Precautionarystatements : P102 Keepoutofreachofchildren. P270 Donoteat,drinkorsmokewhenusingthisproduct. P273 Avoidreleasetotheenvironment. P391 Collectspillage. P501 Disposeofcontents/containertoanapprovedwaste disposalplant. Supplementalinformation : EUH401 Toavoidriskstohumanhealthandtheenvironment, complywiththeinstructionsforuse. Hazardouscomponentswhichmustbelistedonthelabel: Labelling:EUDirectives67/548/EECor1999/45/EC Symbol(s)

Dangerous for the envi- ronment Rphrase(s) : R50/53 Verytoxictoaquaticorganisms,maycauselongterm adverseeffectsintheaquaticenvironment. Sphrase(s) : S2 Keepoutofthereachofchildren. S13 Keepawayfromfood,drinkandanimalfeedingstuffs. S20/21 Whenusingdonoteat,drinkorsmoke. S35 Thismaterialanditscontainermustbedisposedofin asafeway. S36/37 Wearsuitableprotectiveclothingandgloves. S57 Useappropriatecontainertoavoidenvironmental contamination. Additional Labelling : Toavoidriskstomanandtheenvironment,complywiththeinstructions foruse. Version1 Page2of11

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2.3 Other hazards

Noneknown.

SECTION 3. COMPOSITION/INFORMATION ON INGREDIENTS

3.2 Mixtures Hazardous components ChemicalName CASNo. Classification Classification Concentration ECNo. (67/548/EEC) (REGULATION(EC)No Registrationnum 1272/2008) ber pirimi 29232937 Xn,N AcuteTox.4;H302 28.3%W/W phosmethyl 2495285 R22 AquaticAcute1;H400 R50/53 AquaticChronic1;H410 solventnaphtha 64742956 Xn,N Flam.Liq.3;H226 1 9%W/W (petroleum), 2651990 R10 STOTSE3;H335 lightarom. R37 STOTSE3;H336 R51/53 Asp.Tox.1;H304 R65 AquaticChronic2;H411 R66 R67 SubstancesforwhichthereareCommunityworkplaceexposurelimits. ForthefulltextoftheRphrasesmentionedinthisSection,seeSection16. ForthefulltextoftheHStatementsmentionedinthisSection,seeSection16. SECTION 4. FIRST AID MEASURES 4.1 Description of first aid measures Generaladvice : Havetheproductcontainer,labelorMaterialSafetyDataSheetwithyou whencallingtheSyngentaemergencynumber,apoisoncontrolcenteror physician,orgoingfortreatment. Inhalation : Movethevictimtofreshair. Ifbreathingisirregularorstopped,administerartificialrespiration. Keeppatientwarmandatrest. Callaphysicianorpoisoncontrolcentreimmediately. Skincontact : Takeoffallcontaminatedclothingimmediately. Washoffimmediatelywithsoapandplentyofwater. Ifskinirritationpersists,callaphysician. Washoffimmediatelywithplentyofwater. Eyecontact : Rinseimmediatelywithplentyofwater,alsoundertheeyelids,foratleast 15minutes. Removecontactlenses. Immediatemedicalattentionisrequired.

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Ingestion : Ifswallowed,seekmedicaladviceimmediatelyandshowthiscontaineror label. DoNOTinducevomiting. 4.2 Most important symptoms and effects, both acute and delayed Symptoms : Thesymptomsareofcholinesteraseinhibition 4.3 Indication of any immediate medical attention and special treatment needed Medicaladvice : CallSyngentaattheemergencynumbershowninthisdocument,apoi soncontrolcenterordoctorimmediatelyfortreatmentadvice. Considertakingvenousbloodfordeterminationofbloodcholinesterase activity(useheparintube) Administeratropinesulfate,eitherbyintramuscularorintravenously, depandantonseverityofpoisoning Specificantidotesareoximes(e.g.Pralidoxime)orToxogonin SECTION 5. FIRE-FIGHTING MEASURES

5.1 Extinguishing media Extinguishingmediasmallfires Usewaterspray,alcoholresistantfoam,drychemicalorcarbondioxide. Extinguishingmedialargefires Alcoholresistantfoam or Waterspray Donotuseasolidwaterstreamasitmayscatterandspreadfire.

5.2 Special hazards arising from the substance or mixture

Astheproductcontainscombustibleorganiccomponents,firewillpro ducedenseblacksmokecontaininghazardousproductsofcombustion (seesection10). Exposuretodecompositionproductsmaybeahazardtohealth.

5.3 Advice for firefighters Wearfullprotectiveclothingandselfcontainedbreathingapparatus. Donotallowrunofffromfirefightingtoenterdrainsorwatercourses. Coolclosedcontainersexposedtofirewithwaterspray. SECTION 6. ACCIDENTAL RELEASE MEASURES

6.1 Personal precautions, protective equipment and emergency procedures Refertoprotectivemeasureslistedinsections7and8. 6.2 Environmental precautions Preventfurtherleakageorspillageifsafetodoso. Version1 Page4of11

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Donotflushintosurfacewaterorsanitarysewersystem. 6.3 Methods and materials for containment and cleaning up Containspillage,andthencollectwithnoncombustibleabsorbentma terial,(e.g.sand,earth,diatomaceousearth,vermiculite)andplacein containerfordisposalaccordingtolocal/nationalregulations(seesection 13). Iftheproductcontaminatesriversandlakesordrainsinformrespective authorities. 6.4 Reference to other sections Refertoprotectivemeasureslistedinsections7and8. Refertodisposalconsiderationslistedinsection13.

SECTION 7. HANDLING AND STORAGE 7.1 Precautions for safe handling Nospecialprotectivemeasuresagainstfirerequired. Avoidcontactwithskinandeyes. Whenusingdonoteat,drinkorsmoke. Forpersonalprotectionseesection8. 7.2 Conditions for safe storage, including any incompatibilities

Nospecialstorageconditionsrequired. Keepcontainerstightlyclosedinadry,coolandwellventilatedplace. Keepoutofthereachofchildren. Keepawayfromfood,drinkandanimalfeedingstuffs. 7.3 Specific end uses RegisteredCropProtectionproducts:Forproperandsafeuseofthis product,pleaserefertotheapprovalconditionslaiddownontheproduct label. SECTION 8. EXPOSURE CONTROLS/PERSONAL PROTECTION

8.1 Control parameters Components Exposurelimit(s) Typeofexpo Source surelimit pirimiphosmethyl 3mg/m3 8hTWA SYNGENTA solventnaphtha(pe 19ppm,100mg/m3 8hTWA SUPPLIER troleum),lightarom. Thefollowingrecommendationsforexposurecontrols/personalprotectionareintendedforthemanu facture,formulationandpackagingoftheproduct.

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8.2 Exposure controls

Engineeringmeasures : Containmentand/orsegregationisthemostreliabletechnicalprotection measureifexposurecannotbeeliminated. Theextentoftheseprotectionmeasuresdependsontheactualrisksin use. Ifairbornemistsorvaporsaregenerated,uselocalexhaustventilation controls. Assessexposureanduseanyadditionalmeasurestokeepairborne levelsbelowanyrelevantexposurelimit. Wherenecessary,seekadditionaloccupationalhygieneadvice. Protectivemeasures : Theuseoftechnicalmeasuresshouldalwayshavepriorityovertheuseof personalprotectiveequipment. Whenselectingpersonalprotectiveequipment,seekappropriateprofes sionaladvice. Personalprotectiveequipmentshouldbecertifiedtoappropriatestan dards. Respiratoryprotection : Nopersonalrespiratoryprotectiveequipmentnormallyrequired. Aparticulatefilterrespiratormaybenecessaryuntileffectivetechnical measuresareinstalled. Handprotection : Chemicalresistantglovesarenotusuallyrequired. Selectglovesbasedonthephysicaljobrequirements. Eyeprotection : Eyeprotectionisnotusuallyrequired. Followanysitespecificeyeprotectionpolicies. Skinandbodyprotection : Nospecialprotectiveequipmentrequired. Selectskinandbodyprotectionbasedonthephysicaljobrequirements. SECTION 9. PHYSICAL AND CHEMICAL PROPERTIES

9.1 Information on basic physical and chemical properties

Physicalstate : liquid Form : liquidopaquefreeflowing Colour : beigetobrown Odour : characteristic OdourThreshold : nodataavailable pH : >5.07.5 at100%w/v Meltingpoint/range : nodataavailable Boilingpoint/boilingrange : nodataavailable Flashpoint : >100°C Evaporationrate : nodataavailable Flammability(solid,gas) : nodataavailable Lowerexplosionlimit : nodataavailable Upperexplosionlimit : nodataavailable Vapourpressure : nodataavailable Relativevapourdensity : nodataavailable Density : 1.06g/cm3at20°C Solubilityinothersolvents : Miscible inWater Partitioncoefficient: : nodataavailable Version1 Page6of11

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noctanol/water Autoignitiontemperature : 570°C Thermaldecomposition : nodataavailable Viscosity,dynamic : nodataavailable Viscosity,kinematic : nodataavailable Explosiveproperties : Notexplosive Oxidizingproperties : notoxidizing 9.2 Other information : nodataavailable SECTION 10. STABILITY AND REACTIVITY

10.1 Reactivity Noinformationavailable.

10.2 Chemical stability Noinformationavailable.

10.3 Possibility of hazardous reactions Noneknown. Hazardouspolymerisationdoesnotoccur. 10.4 Conditions to avoid Noinformationavailable. 10.5 Incompatible materials Noinformationavailable. 10.6 Hazardous decomposition products

Combustionorthermaldecompositionwillevolvetoxicandirritantvapors. SECTION 11. TOXICOLOGICAL INFORMATION 11.1 Information on toxicological effects Acuteoraltoxicity : LD50malerat,>5,000mg/kg : LD50femalemouse,>5,000mg/kg Acutedermaltoxicity : LD50maleandfemalerat,>5,000mg/kg Skincorrosion/irritation : rabbit : Nonirritating Seriouseyedamage/eye : rabbit:MinimallyIrritating irritation Respiratoryorskinsensiti : guineapig:Notaskinsensitizer. zation Germcellmutagenicity pirimiphosmethyl : Didnotshowmutageniceffectsinanimalexperiments. Version1 Page7of11

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Carcinogenicity pirimiphosmethyl : Didnotshowcarcinogeniceffectsinanimalexperiments. Teratogenicity pirimiphosmethyl : Didnotshowteratogeniceffectsinanimalexperiments. Reproductivetoxicity pirimiphosmethyl : Didnotshowreproductivetoxicityeffectsinanimalexperiments. STOTrepeatedexposure pirimiphosmethyl : Noadverseeffecthasbeenobservedinchronictoxicitytests. SECTION 12. ECOLOGICAL INFORMATION

12.1 Toxicity

Toxicitytofish pirimiphosmethyl : LC50 Oncorhynchusmykiss(rainbowtrout),0.64mg/l,96h Toxicitytoaquaticinvertebrates pirimiphosmethyl : EC50 Daphniamagna(Waterflea),0.21g/l,48h Toxicitytoaquaticplants pirimiphosmethyl : ErC50 Pseudokirchneriellasubcapitata(greenalgae),4.9mg/l,96h EbC50 Pseudokirchneriellasubcapitata(greenalgae),1mg/l,96h

12.2 Persistence and degradability Stabilityinwater pirimiphosmethyl : Notpersistentinwater Stabilityinsoil pirimiphosmethyl : Notpersistentinsoil. 12.3 Bioaccumulative potential pirimiphosmethyl : Pirimiphosmethylhashighpotentialforbioaccumulation 12.4 Mobility in soil pirimiphosmethyl : Pirimiphosmethylhaslowmobilityinsoil. 12.5 Results of PBT and vPvB assessment

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pirimiphosmethyl : Thissubstanceisnotconsideredtobepersistent,bioaccumulatingnor toxic(PBT). Thissubstanceisnotconsideredtobeverypersistentnorverybioac cumulating(vPvB). 12.6 Other adverse effects Noneknown. SECTION 13. DISPOSAL CONSIDERATIONS

13.1 Waste treatment methods Product : Donotcontaminateponds,waterwaysorditcheswithchemicalorused container. Donotdisposeofwasteintosewer. Wherepossiblerecyclingispreferredtodisposalorincineration. Ifrecyclingisnotpracticable,disposeofincompliancewithlocalregula tions. Contaminatedpackaging : Emptyremainingcontents. Triplerinsecontainers. Emptycontainersshouldbetakentoanapprovedwastehandlingsitefor recyclingordisposal. Donotreuseemptycontainers. SECTION 14. TRANSPORT INFORMATION

Land transport (ADR/RID ) 14.1 UN number : UN3082 14.2 UN proper shipping name : ENVIRONMENTALLYHAZARDOUSSUBSTANCE,LIQUID,N.O.S. (PIRIMIPHOSMETHYL) 14.3 Transport hazard class(es) : 9 14.4 Packing group : III Labels: 9 14.5 Environmental hazards : Environmentallyhazardous

Sea transport (IMDG ) 14.1 UN number : UN3082 14.2 UN proper shipping name : ENVIRONMENTALLYHAZARDOUSSUBSTANCE,LIQUID,N.O.S. (PIRIMIPHOSMETHYL) 14.3 Transport hazard class(es) : 9 14.4 Packing group : III Labels: 9 14.5 Environmental hazards : Marinepollutant

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Air transport (IATADGR ) 14.1 UN number : UN3082 14.2 UN proper shipping name : ENVIRONMENTALLYHAZARDOUSSUBSTANCE,LIQUID,N.O.S. (PIRIMIPHOSMETHYL) 14.3 Transport hazard class(es) : 9 14.4 Packing group : III Labels: 9

14.6 Special precautions for user

none 14.7 Transport in bulk according to Annex II of MARPOL 73/78 and the IBC Code

notapplicable SECTION 15. REGULATORY INFORMATION

15.1 Safety, health and environmental regulations/legislation specific for the substance or mix- ture GHSLabelling Hazardpictograms

Signalword : Warning Hazardstatements : H410 Verytoxictoaquaticlifewithlonglastingeffects. Precautionarystatements : P102 Keepoutofreachofchildren. P270 Donoteat,drinkorsmokewhenusingthisproduct. P273 Avoidreleasetotheenvironment. P391 Collectspillage. P501 Disposeofcontents/containertoanapproved wastedisposalplant. Remarks : ClassifiedusingallGHShazardclassesandcategories. WheretheGHScontainsoptions,themostconservativeoptionhas beenchosen. RegionalornationalimplementationsofGHSmaynotimplementall hazardclassesandcategories. Hazardouscomponentswhichmustbelistedonthelabel:

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15.2 Chemical Safety Assessment AChemicalSafetyAssessmentisnotrequiredforthissubstance. SECTION 16. OTHER INFORMATION

Further information FulltextofRphrasesreferredtoundersections2and3: R10 Flammable. R22 Harmfulifswallowed. R37 Irritatingtorespiratorysystem. R50/53 Verytoxictoaquaticorganisms,maycauselongtermadverseeffectsinthe aquaticenvironment. R51/53 Toxictoaquaticorganisms,maycauselongtermadverseeffectsintheaquatic environment. R65 Harmful:maycauselungdamageifswallowed. R66 Repeatedexposuremaycauseskindrynessorcracking. R67 Vapoursmaycausedrowsinessanddizziness. FulltextofHStatementsreferredtoundersections2and3. H226 Flammableliquidandvapour. H302 Harmfulifswallowed. H304 Maybefatalifswallowedandentersairways. H335 Maycauserespiratoryirritation. H336 Maycausedrowsinessordizziness. H400 Verytoxictoaquaticlife. H410 Verytoxictoaquaticlifewithlonglastingeffects. H411 Toxictoaquaticlifewithlonglastingeffects. TheinformationprovidedinthisSafetyDataSheetiscorrecttothebestofourknowledge,informationand beliefatthedateofitspublication.Theinformationgivenisdesignedonlyasaguidanceforsafehandling, use,processing,storage,transportation,disposalandreleaseandisnottobeconsideredawarrantyor qualityspecification.Theinformationrelatesonlytothespecificmaterialdesignatedandmaynotbevalid forsuchmaterialusedincombinationwithanyothermaterialsorinanyprocess,unlessspecifiedinthe text. Changessincethelastversionarehighlightedinthemargin.Thisversionreplacesallpreviousversions. ProductnamesareatrademarkorregisteredtrademarkofaSyngentaGroupCompany.

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SAFETY DATA SHEET according to EC directive 2001/58/EC

ACTELLIC 50 EC Version 7 Revision Date 11.04.2006 Print Date 11.04.2006

1. IDENTIFICATION OF THE SUBSTANCE/PREPARATION AND OF THE COMPANY/UNDERTAKING

PRODUCT INFORMATION Product name : ACTELLIC 50 EC

Design Code : A5832B

Use : insecticide Company : Syngenta Crop Protection AG Harmful Dangerous for Postfach the environment CH-4002 Basel Switzerland Telephone : +41 61 323 11 11 Telefax : +41 61 323 12 12 Emergency : +44 1484 538444 telephone number

2. COMPOSITION/INFORMATION ON INGREDIENTS

Hazardous components Chemical Name CAS-No. EC-No. Symbol(s) R-phrase(s) Concentration pirimiphos-methyl 29232-93-7 249-528-5 Xn, N R22 48.5 % W/W R50/53

Poly(oxy-1,2- 9016-45-9 Xi R41 0 - 5 % ethanediyl), a- R52/53 W/W (nonylphenyl)-w- hydroxy- solvent naphtha 64742-95-6 265-199-0 Xn, N R10 40 - 50 % (petroleum), light R37 W/W arom. R51/53 R65 R66 R67

benzenesulfonic 26264-06-2 247-557-8 Xi R38 0 - 5 % acid, dodecyl-, R41 W/W calcium salt

For the full text of the R phrases mentioned in this Section, see Section 16.

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3. Hazards identification

This product contains an anticholinesterase compound. Do not use if under medical advice not to work with such compounds. Flammable. Harmful if swallowed. Irritating to eyes and respiratory system. Very toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment. Harmful: may cause lung damage if swallowed. Vapors may cause drowsiness and dizziness.

4. FIRST AID MEASURES General advice : Have the product container, label or Material Safety Data Sheet with you when calling the Syngenta emergency number, a poison control center or physician, or going for treatment.

Inhalation : Remove to fresh air. Keep patient warm and at rest. If breathing is irregular or stopped, administer artificial respiration. Call a physician or Poison Control Centre immediately.

Inhalation : Remove to fresh air. Keep patient warm and at rest. If breathing is irregular or stopped, administer artificial respiration. Call a physician or Poison Control Centre immediately.

Skin contact : Take off contaminated clothing and shoes immediately. Wash off immediately with soap and plenty of water. If skin irritation persists, call a physician. Wash contaminated clothing before re-use.

Eye contact : Rinse immediately with plenty of water, also under the eyelids, for at least 15 minutes. Remove contact lenses. Immediate medical attention is required.

Ingestion : If swallowed, seek medical advice immediately and show this container or label. Do NOT induce vomiting.

Symptoms : The symptoms are of cholinesterase inhibition

Medical advice : Call Syngenta at the emergency number shown in this document, a poison control center or doctor immediately for treatment advice. Consider taking venous blood for determination of blood cholinesterase activity (use heparin tube) Administer atropine sulfate, either by intramuscular or intravenously, depandant on severity of poisoning Specific antidotes are oximes (e.g. Pralidoxime) or Toxogonin

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5. FIRE-FIGHTING MEASURES

Suitable extinguishing : Extinguishing media - small fires media Use water spray, alcohol-resistant foam, dry chemical or carbon dioxide. Extinguishing media - large fires alcohol-resistant foam

Extinguishing media : Do not use a solid water stream as it may scatter and spread which must not be used fire. for safety reasons

Specific hazards during : As the product contains combustible organic components, fire fire fighting will produce dense black smoke containing hazardous products of combustion (see section 10). Exposure to decomposition products may be a hazard to health. Flash back possible over considerable distance.

Special protective : In the event of fire, wear self-contained breathing apparatus. equipment for fire- fighters

Further information : Do not allow run-off from fire fighting to enter drains or water courses. Cool closed containers exposed to fire with water spray.

6. ACCIDENTAL RELEASE MEASURES

Personal precautions : Refer to protective measures listed in sections 7 and 8. Keep people away from and upwind of spill/leak. Beware of vapours accumulating to form explosive concentrations. Vapours can accumulate in low areas. Remove all sources of ignition. Pay attention to flashback.

Environmental : Prevent further leakage or spillage if safe to do so. precautions Do not flush into surface water or sanitary sewer system.

Methods for cleaning up : Contain and collect spillage with non-combustible absorbent material, (e.g. sand, earth, diatomaceus earth, vermiculite) and place in container for disposal according to local / national regulations (see section 13).

Additional advice : If the product contaminates rivers and lakes or drains inform respective authorities.

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7. HANDLING AND STORAGE

HANDLING Advice on safe handling : Avoid contact with skin and eyes. When using, do not eat, drink or smoke. Take precautionary measures against static discharges. Use only in an area containing flame proof equipment. For personal protection see section 8.

STORAGE Requirements for storage : Keep containers tightly closed in a dry, cool and well-ventilated areas and containers place. Keep out of the reach of children. Keep away from food, drink and animal feedingstuffs. Keep away from heat and sources of ignition. Keep away from combustible material. Keep in an area equipped with sprinklers. No smoking.

Other data : Physically and chemically stable for at least 2 years when stored in the original unopened sales container at ambient tmperatures.

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8. EXPOSURE CONTROLS / PERSONAL PROTECTION

Components with workplace control parameters Components Exposure limit(s) Value type Source pirimiphos-methyl 3 mg/m3 8 h TWA SYNGENTA

solvent naphtha 100 mg/m3 8 h TWA SUPPLIER (petroleum), light arom.

ENGINEERING MEASURES Containment and/or segregation is the most reliable technical protection measure if exposure cannot be eliminated. The extent of these protection measures depends on the actual risks in use. If airborne mists or vapors are generated, use local exhaust ventilation controls. Assess exposure and use any additional measures to keep airborne levels below any relevant exposure limit. Where necessary, seek additional occupational hygiene advice.

PERSONAL PROTECTIVE EQUIPMENT Protective measures : The use of technical measures should always have priority over the use of personal protective equipment. When selecting personal protective equipment, seek appropriate professional advice. Personal protective equipment should be certified to appropriate standards.

Respiratory protection : A combination gas, vapor and particulate respirator may be necessary until effective technical measures are installed. Protection provided by air-purifying respirators is limited. Use a self-contained breathing apparatus in cases of emergency spills, when exposure levels are unknown, or under any circumstances where air-purifying respirators may not provide adequate protection.

Hand protection : Chemical resistant gloves are not usually required. Select gloves based on the physical job requirements.

Eye protection : If eye contact is possible, use tight-fitting chemical safety goggles.

Skin and body protection : Assess the exposure and select chemical resistant clothing based on the potential for contact and the permeation / penetration characteristics of the clothing material. Wash with soap and water after removing protective clothing. Decontaminate clothing before re-use, or use disposable equipment (suits, aprons, sleeves, boots, etc.) Wear as appropriate: dust impervious protective suit

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ACTELLIC 50 EC Version 7 Revision Date 11.04.2006 Print Date 11.04.2006

9. PHYSICAL AND CHEMICAL PROPERTIES

Form : liquid clear

Colour : light brown

Flash point : 38 °C

Density : 1.03 g/cm3 at 20 °C

Water solubility : Miscible

10. STABILITY AND REACTIVITY

Hazardous decomposition : Combustion or thermal decomposition will evolve toxic and products irritant vapors.

Hazardous reactions : None known. Hazardous polymerization does not occur. Stable under normal conditions.

11. TOXICOLOGICAL INFORMATION

Acute oral toxicity : LD50 male Rat, 1,522 mg/kg

: LD50 female Rat, 1,732 mg/kg

Acute dermal toxicity : LD50 Rat, > 2,000 mg/kg

Skin irritation : Rabbit : slight

Eye irritation : Rabbit: Moderately Irritating

Sensitization : guinea pig not sensitizing

Long term toxicity Did not show carcinogenic, teratogenic or mutagenic effects in animal experiments.

12. ECOLOGICAL INFORMATION

ELIMINATION INFORMATION (PERSISTENCE AND DEGRADABILITY) Bioaccumulation : Pirimiphos-methyl has high potential for bioaccumulation

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Stability in water : Pirimiphos-methyl is not persistent in water

Stability in soil : Pirimiphos-methyl is not persistent in soil.

Mobility : Pirimiphos-methyl has low mobility in soil.

ECOTOXICITY EFFECTS

Toxicity to fish : LC50 Oncorhynchus mykiss (rainbow trout), ca. 1.3 mg/l , 96 h

Toxicity to aquatic : EC50 Daphnia magna (Water flea), 0.0005 mg/l , 48 h invertebrates

Toxicity to algae : ERC50 Algae, 2.4 mg/l , 72 h

13. DISPOSAL CONSIDERATIONS

Product : Do not contaminate ponds, waterways or ditches with chemical or used container. Do not dispose of waste into sewer. Where possible recycling is preferred to disposal or incineration. If recycling is not practicable, dispose of in compliance with local regulations.

Contaminated packaging : Empty remaining contents. Triple rinse containers. Empty containers should be taken for local recycling or waste disposal. Do not re-use empty containers.

14. TRANSPORT INFORMATION

Land transport

ADR/ RID: UN-No: 1993 Class: 3 Danger Label Number : 3 Packaging group III Proper shipping name : FLAMMABLE LIQUID, N.O.S. ( SUBSTITUTED BENZENOID HYDROCARBONS AND PIRIMIPHOS-METHYL )

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Sea transport

IMDG: UN-No: 1993 Class: 3 Danger Label Number : 3 Packaging group: III Proper shipping name : FLAMMABLE LIQUID, N.O.S. ( SUBSTITUTED BENZENOID HYDROCARBONS AND PIRIMIPHOS-METHYL )

Marine pollutant : Marine pollutant

Air transport

IATA-DGR UN-No: 1993 Class: 3 Danger Label Number : 3 Packaging group: III Proper shipping name : FLAMMABLE LIQUID, N.O.S. ( SUBSTITUTED BENZENOID HYDROCARBONS AND PIRIMIPHOS-METHYL )

15. REGULATORY INFORMATION

Labelling according to EC Directives Hazardous components which must be listed on the label: • pirimiphos-methyl • solvent naphtha (petroleum), light arom.

Symbol(s) : Xn Harmful N Dangerous for the environment

R-phrase(s) : R10 Flammable. R22 Harmful if swallowed. R36/37 Irritating to eyes and respiratory system. R50/53 Very toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment. R65 Harmful: may cause lung damage if swallowed. R67 Vapors may cause drowsiness and dizziness.

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S-phrase(s) : S 2 Keep out of the reach of children. S13 Keep away from food, drink and animal feedingstuffs. S20/21 When using do not eat, drink or smoke. S35 This material and its container must be disposed of in a safe way. S57 Use appropriate container to avoid environmental contamination. S62 If swallowed, do not induce vomiting: seek medical advice immediately and show this container or label.

Special labelling of : To avoid risks to man and the environment, comply with the certain preparations instructions for use.

Note : The preparation is classified as dangerous in accordance with Directive 1999/45/EC.

16. OTHER INFORMATION

Further information Text of R phrases mentioned in Section 2:

R10 Flammable. R22 Harmful if swallowed. R37 Irritating to respiratory system. R38 Irritating to skin. R41 Risk of serious damage to eyes. R50/53 Very toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment. R51/53 Toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment. R52/53 Harmful to aquatic organisms, may cause long-term adverse effects in the aquatic environment. R65 Harmful: may cause lung damage if swallowed. R66 Repeated exposure may cause skin dryness or cracking. R67 Vapors may cause drowsiness and dizziness.

The information provided in this Safety Data Sheet is correct to the best of our knowledge, information and belief at the date of its publication. The information given is designed only as a guidance for safe handling, use, processing, storage, transportation, disposal and release and is not to be considered a warranty or quality specification. The information relates only to the specific material designated and may not be valid for such material used in combination with any other materials or in any process, unless specified in the text. A vertical bar in the left margin indicates an amendment from the previous version. Product names are a trademark or registered trademark of a Syngenta Group Company.

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ANNEX 8C: MATERIAL SAFETY DATA SHEET FOR ACTELLIC 900

70

MATERIAL SAFETY DATA SHEET

ACTELLIC® 900 SOLVENT FREE LIQUID INSECTICIDE Date of Issue: June 2012

1. IDENTIFICATION OF THE MATERIAL AND SUPPLIER Product Name: Actellic® 900 Solvent Free Liquid Insecticide Other Names: Pirimiphos-methyl Recommended Insecticide Use: Supplier: AgNova Technologies Pty Ltd ACN: 097 705 158 Address: Suite 3/935 Station Street Box Hill North Vic 3129 Australia Telephone: (03) 9899 8100 Facsimile: (03) 9899 8500 Website: www.agnova.com.au Contact: Managing Director Emergency Telephone Number: 1800 033 111 (24 hours)

2. HAZARDS IDENTIFICATION

HAZARDOUS SUBSTANCE – DANGEROUS GOODS

Hazard Classified as hazardous according to the criteria of NOHSC. Classification: Classified as harmful according to NOHSC. Risk Phrases: R22 Harmful if swallowed Safety Phrases: None ADG Classified as a Dangerous Good according to Australian Code for Classification the Transport of Dangerous Goods by Road and Rail (see section 14) SUSMP Poisons Schedule 6 (S6) Classification (Standard for the Uniform Scheduling of Medicines and Poisons)

3. COMPOSITION / INFORMATION ON INGREDIENTS

Ingredients: CAS Number: Concentration % : Pirimiphos-methyl 29232-93-7 > 90 n-Butylalcohol 71-36-3 1-9 Methylisobutylketone 108-10-1 1-9 Emulsifiers - 10-29

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ACTELLIC® 900 SOLVENT FREE LIQUID INSECTICIDE Date of Issue: June 2012

4. FIRST AID MEASURES

If poisoning occurs, immediately contact a doctor or Poisons Information Centre (Phone 13 11 26), and follow the advice given. Show this Material Safety Data Sheet to a doctor.

Ingestion: If swallowed, rinse mouth with water and give water to drink. Immediately contact a doctor or Poisons Information Centre (Telephone: 13 11 26) and follow advice given. Only induce vomiting at the instruction of a physician. Inhalation: Remove to fresh air. Apply artificial respiration if necessary, and get medical attention. Skin Contact: If skin contact occurs, remove contaminated clothing and wash with soap and water. If irritation occurs seek medical advice. Eye Contact: Immediately flush eyes with copious quantities of water for 15 minutes. Seek medical advice. First Aid Facilities: Provide washing facilities in the workplace.

Symptoms: May cause eye irritation.

Medical Attention: Treat symptomatically.

Aggravated Medical None known. Conditions Caused by Exposure:

5. FIRE FIGHTING MEASURES

Extinguishing Water fog, fine water spray, foam or dry agent. Media:

Hazards from Will emit toxic fumes including oxides of carbon, nitrogen and sulphur. Combustion Heating can cause expansion or decomposition leading to violent Products: rupture of containers.

Special Protective Wear self-contained breathing apparatus and structural fire Precautions and fighters uniform. Equipment for Fire Fighters:

Hazchem Code: 3[Y]

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ACTELLIC® 900 SOLVENT FREE LIQUID INSECTICIDE Date of Issue: June 2012

6. ACCIDENTAL RELEASE MEASURES

Emergency In case of spillage it is important to take all steps necessary to: Procedures:  Avoid eye and skin contact.  Avoid contamination of waterways.

Methods and Wear full length protective clothing, boots and breathing Materials for apparatus. Containment and Prevent spill from entering drains, sewers or any body of water. Clean Up Contain and absorb with sand, earth or inert absorbent. Procedures: Scoop or shovel into sealable containers for disposal in accordance with applicable local, state and federal regulations. Decontaminate area with soap and minimal water.

7. HANDLING AND STORAGE

Precautions for Avoid contact with eyes and skin. Avoid breathing vapour/mist. Safe Handling: Use with adequate ventilation. If inhalation risk exists, wear organic vapour respirator meeting the requirements of AS/NZ 1715 and AS/NZ 1716.

Conditions for Safe Store in tightly sealed original containers in a cool, dry well- Storage including ventilated area out of direct sunlight. Store in a locked room any away from children, authorized persons, animals, food, Incompatibilities: feedstuffs, seed and fertilisers. Do not use containers for any other purpose. Avoid storing in cold conditions as crystallisation may occur at low temperatures (below 50C) resulting in separation of the active ingredient.

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ACTELLIC® 900 SOLVENT FREE LIQUID INSECTICIDE Date of Issue: June 2012

8. EXPOSURE CONTROLS / PERSONAL PROTECTION

National No occupational exposure standards have been established for the Exposure product. The supplier recommended hygiene standard for some of the Standards: ingredients: TWA STEL NOTICES ppm mg/m3 ppm mg/m3 Methylisobutyl- 50 205 75 307 ketone n-Butylalcohol 50 152 Peak limit Sk Pirimiphos-methyl - 3 - - Sk

TWA = the time weighted average airborne concentrations over a eight-hour working day, for a five-day working week over an entire working life. STEL = Short Term Exposure Limit – the average airborne concentration over a 15 minute period which should not be exceeded at any time during a normal 8 hour work day. Peak Limit – a ceiling concentration which should not be exceeded over a measurement period which should be as short as possible but not exceeding 15 minutes. “Sk Notice” – absorption through the skin may be a significant source of exposure. The exposure standard is invalid if such contact should occur.

Biological No biological limit allocated. Limit Values:

Engineering Ensure adequate ventilation. Ensure air concentrations are controlled Controls: below quoted hygiene standards.

Personal Eyes: Safety glasses. Protective Gloves: Elbow length impervious gloves. Equipment Respiratory: If inhalation risk, use an organic vapour respirator (PPE): meeting the requirements of AS/NZS 1715 and AS/NZS 1716.

9. PHYSICAL AND CHEMICAL PROPERTIES

Appearance: Clear amber liquid Odour: Solvent like odour pH: No data available Vapour Pressure: No data available Vapour Density: No data available Boiling Point: No data available Melting Point: No data available Solubility: Slightly soluble in water

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ACTELLIC® 900 SOLVENT FREE LIQUID INSECTICIDE Date of Issue: June 2012

Specific Gravity: 1.137 g/cm3 Bulk Density: Not applicable Flash Point: 550C Flammability No data available (explosive) Limits: Auto-Ignition No data available Temperature: Octanol/Water No data available Partition Coefficient: Particle Size: Not applicable Formulation: Liquid

10.STABILITY AND REACTIVITY

Chemical Stable under normal storage conditions. Stability: Conditions to Avoid storing in cold conditions as crystallisation may occur at low Avoid: temperatures (below 50C) resulting in separation of the active ingredient. Incompatible None known. Materials: Hazardous During a fire this product will emit toxic fumes including oxides of Decomposition carbon, nitrogen and sulphur. Products: Hazardous None Reactions:

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ACTELLIC® 900 SOLVENT FREE LIQUID INSECTICIDE Date of Issue: June 2012

11.TOXICOLOGICAL INFORMATION

Health Effects from Likely Routes of Exposure: This product is harmful according to NOHSC. Ingestion: No adverse health effects are expected from swallowing. Inhalation: Not harmful. Test on rats indicate this product is not harmful due to the inhalation of the active ingredient. Skin Contact: Not harmful. Test on rats indicate this product is not harmful following skin contact with the active ingredient. Eye Contact: May cause eye irritation. Other: The active, pirimiphos-methyl is an organophosphorous insecticide which inhibits cholinesterase activity, producing both local and systemic effects by interference with nerve transmission. Onset of symptoms may be delayed for several hours. Studies in animals show that repeated exposure produce no significant effects except for cholinesterase inhibition. No other known health effects.

Animal Toxicity Data: No data is available for the product so results are based on the active ingredient. Acute:

Oral Toxicity: LD50 Oral (ingestion) Rat > 2050 mg/kg

Dermal Toxicity: LD50 Dermal (skin contact) Rat > 2000 mg/kg

Inhalation LC50 (4 hr) Rat > 5.04 mg/L Toxicity: Skin Irritation: Slight irritant (rabbit) Eye Irritation: Slight irritant (rabbit) Sensitisation: Not a sensitiser

Chronic: The active, pirimiphos-methyl technical has been extensively tested in mammals and in test-tube systems. No evidence of mutagenic, carcinogenic, neurotoxic, tetragenic or reproductive effects was obtained. Cholinesterase levels will return to normal a few weeks after exposure

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ACTELLIC® 900 SOLVENT FREE LIQUID INSECTICIDE Date of Issue: June 2012

12.ECOLOGICAL INFORMATION ACTIVE INGREDIENT :Pirimiphos-methyl Ecotoxicity: The active ingredient, pirimiphos-methyl is very toxic to aquatic organisms. Pirimiphos-methyl is toxic to birds and bees. Results below are for the active ingredient.

Fish Toxicity: Acute LC50 (Rainbow Trout Oncorhynchus mykiss) = 0.64 mg/L (96 hours) Acute LC50 (Mirror Carp) = 1.4 mg/L (48 hours)

Daphnia Toxicity: EC50: 1.4 mg/L (48 hours)

Bird Toxicity: Chicken: Oral LD50 = 30 - 60 mg/kg Bobwhite Quail: Oral LD50 = 140 mg/kg Bee Toxicity: Pirimiphos-methyl is toxic to bees. Other: None known. Persistence and There is evidence of hydrolysis in soil and water. Degradability: Mobility: Low soil mobility. Environmental Liquid with low volatility. Active is sparingly soluble in water and has Fate: low mobility in soil. Bioaccumulative No data available. Potential: Other Adverse None known. Environmental Effects:

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ACTELLIC® 900 SOLVENT FREE LIQUID INSECTICIDE Date of Issue: June 2012

13.DISPOSAL CONSIDERATIONS

Disposal Methods: Dispose of empty, used containers by triple rinsing or preferably pressure rinsing containers with water. Add the rinsings to the spray tank. DO NOT dispose of undiluted chemicals on site. If recycling, replace cap and return clean containers to recycler or designated collection point. If not recycling, break, crush or puncture and bury empty containers in a local authority landfill. If no landfill is available, bury the containers below 500 mm in a disposal pit specifically marked and set up for this purpose clear of waterways, desirable vegetation and tree roots. Waste must not enter waterways. Contaminated Packaging: Dispose in accordance with applicable local, state and federal regulations. Special Precautions Empty containers and product should not be burnt. for Landfill or Incineration:

14.TRANSPORT INFORMATION

UN Number: 1224 Proper Shipping KETONES, LIQUID, N.O.S. (Contains PIRIMIPHOS-METHYL, Name: METHYL ISOBUTYL KETONE AND BUTANOL)) Class and Subsidiary Class 3 Risk: Packing Group: III EPG: HB76 Guide 17 Hazchem Code: 3[Y]

15.REGULATORY INFORMATION

SUSMP: Schedule 6

APVMA: Registered according to the Agricultural and Veterinary Chemicals Act 1994. APVMA Product Number: 59710

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ACTELLIC® 900 SOLVENT FREE LIQUID INSECTICIDE Date of Issue: June 2012

16.OTHER INFORMATION

Date of Preparation June 2012. or Revision:

Data Sources: Manufacturer product safety data and published data

Abbreviations and APVMA – Australian Pesticides and Veterinary Medicines Acronyms: Authority NOHSC – National Occupational Health and Safety Commission SUSMP – Standard for the Uniform Scheduling of Medicines and Poisons TWA – Time Weighed Average = The time weighted average airborne concentrations over an eight -hour working day, for a five-day working week over an entire working life.

Trademark ® Actellic is a Registered Trademark of a Syngenta Group Information: Company.

This MSDS summarises our best knowledge of the health and safety hazard information of the product and how to safely handle and use the product in the workplace. Each user should read this MSDS and consider the information in the context of how the product will be handled and used in the workplace including in conjunction with other products.

The opinions expressed herein are those of qualified experts with the manufacturer. Since the use of this information and of these opinions and the conditions of use of this product are not within the control of AgNova Technologies Pty Ltd, it is the user’s obligation to determine the conditions of safe use of the product.

END OF MSDS

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