vol. 3 STOCKPILES OGRAMME - World Bank Documents

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _E 9 1 6vol. 3

STOCKPILES OGRAMME

Country Environmental and Social Assessmentfor ETHIOPIA (CESA 1)

with specific reference to disposal component of the"Prevention and Disposal of Obsolete Pesticide Stocks in

Ethiopia - Phase-Il"

GCP/ETH/064/FIN

UTF/ETH/065/ETH

UTF/ETH/066/ETH

Revised 12 October 2006 based on Comments from the World Bank

The Ministry of Agriculture and Rural DevelopmentEthiopia

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Table of contentsAbbreviations .............................................................. 1Executive Summary .......................................................... 21 Project Objectives and Description ............................................ 3

1.1 Objectives of CESA I and the CESA 11 ...................................... 41.2 Background to Phase-I ................................................ 51.3 Phase-Il project Objectives ............................................. 61.4 Organisation Structure ................................................. 71.5 Institutional Arrangements for Project Implementation .......................... 101.6 Outline of the Current Pesticides Disposal Component of Phase-l ................. 121.7 Project basis, protocols and standards ..................................... 141.8 Project Status ...................................................... 14

2 Policy, Legal, and Administrative Framework .................................... 152.1 Relevant International Legal Instruments ......................................................... 152.2 Relevant Ethiopian National Legal Instruments ............................... 162.3 Legislative Framework for European Hazardous Waste Incinerators ................ 173 Baseline Data and Review of the Clean up Operation to date ......................... 183.1 Overview of known sites .......................................................... 183.2 Detailed Environmental and Social Characterization of sites ............................................... 233.3 Criteria for Distinguishing Atypical from Typical Sites ........................... 273.4 Quality and training of staff/ workers ................................... 29

4 Review of Disposal Strategy to Date .......................................................... 294.1 Inventory development ................................................ 304.2 Environmental Assessment ......................................................... 324.3 Selection of Major Collection Centres .................................... 324.4 Prioritization Strategy ................................................. 324.5 Planning for Repackaging ....................................... 334.6 Repackaging ....................................,. ............ 354.7 Transport from store to MCC ....................................... 364.8 Management of MCCs ................................................ 364.9 Contractor activities at MCCs ........................................... 374.10 Transport from MCC to Djibouti port ............................ ....... 374.11 Sea Transportation . .................................................. 384.12 Arrival and Transport in UK or Germany ................................... 384.13 Disposal Strategy ................................................... 394.14 Disposal Operations ................................................. 39

5 Analysis of Alternatives ................................................... 395.1 Do nothing ........................................................ 395.2 Repackage and stockpile indefinitely at a central location ....................... 405.3 Cement Kiln Disposal ................................................ 405.4 Rail Transportation .................................................. 40

6 Typical sites ........................................................... 416.1 Environmental Mitigation Plan for typical sites ................................ 416.2 Monitoring Plan for typical sites .............................................. 45

7 Atypical sites ............................................................................... 487.1 Environmental Mitigation Plan for atypical sites .............................................. 497.2 Monitoring Plan for atypical sites ......................................... 498 Environmental Management Training Requirements .............................. 498.1 Current training requirements ........................................... 498.2 Training requirements for the ASP .............................................. 509 Changes needed to any contracts or guidelines or policies .......................... 509.1 Changes to Veolia's contract ........................................... 509.2 NGO monitoring .................................................... 5010 Public Consultation and Disclosure ........................................... 5110.1 Routine Consultation and Disclosure ...................................... 5110.2 Consultation and disclosure procedure for the CESA .......................... 5211 Next Steps ............................................................ 53

Abbreviations

ADR International Regulations for the carriage of hazardous substances by roadASP Africa Stockpiles ProgrammeBTC Belgian Technical CooperationCA Competent Authority (Basel Convention)CESA Country Environmental and Social AssessmentCLE CropLife EthiopiaCLI CropLife InternationalDMR Duly Motivated Request (Basel Convention)ECA Economic Commission for Africa of the United NationsEMP Environmental Management PlanEMTK FAO's Environmental Management Tool KitEPA Environmental Protection AgencyFAO Food and Agriculture Organization of the United Nations

Environmental risk factor for a store as per FAO's Environmental ManagementFe ITool kitFM Field ManagerFp Pesticide risk factor for a store as per FAO's Environmental Management Tool kit

F ~Normalised pesticide risk factor for a store as per FAO's EnvironmentalFp Management Tool kitGoB Government of BelgiumGoD Government of DjiboutiGoE Government of EthiopiaGoF Government of FinlandGoJ Government of JapanGPS Global Positioning SystemIMDG International Maritime Dangerous Goods CodeIMO International Maritime OrganizationIC International ConsultantMCC Major Collection CentreMoARD Ministry of Agriculture and Rural DevelopmentMoH Ministry of HealthNGO Non Governmental OrganizationNPCC National Project coordinating committeeNPM National Project ManagerOM Operational ManualPANUK Pesticide Action Network UK (NGO)PMT Project Management TeamPOPs Persistent Organic Pollutant (Stockholm Convention)PPE Personal Protective EquipmentPSC Project Steering Committee for the Phase-Il projectte Tonnes (Metric)WHO World Health Organisation

Executive SummaryEthiopia is currently engaged in the second phase of a project to dispose of 1,100 tonnes of publicly heldobsolete pesticides located in 705 sites spread across the country. In the first phase Ethiopia has alreadydisposed of 1,507 tonnes of obsolete pesticide which were located in 243 sites that posed the highest risk to theenvironment and public health. The first phase included a detailed Environmental Assessment that conformed toUSAID standards.

Ethiopia is well advanced with its disposal activities in Phase II, using the principles of FAO's EnvironmentalManagement Toolkit, which provides a process for prioritizing sites and regions, and for developing anEnvironmental Mitigation Plan for safeguarding and disposal activities. The experience in Ethiopia has helped torefine the EMTK such that it will be used as the basis for managing disposal projects under the Africa StockpilesProgramme (ASP). The ASP is due to fund components of the Ethiopia Phase II project. The ASP is a WorldBank Category "A" project and as such requires a number of conditions to be met for the Grant Aid to be agreed.The World Bank requires a limited Country Environmental and Social Assessment (CESA) and an EnvironmentalMitigation Plan (EMP) to be prepared for the current disposal operations. The recommendations of this CESAwhich draws on the original Environment Assessment in Phase I, should be included in the final agreement withthe Government of Ethiopia for the ASP.

A full CESA and EMP for all the other components of the project will be prepared once the grant aid agreementhas been signed.

The repackaging operations and removal of stocks from the 705 sites is being undertaken by the Ethiopianproject team using the principles of the FAO guidelines. Although minor non-conformances were noted duringthe field visits to sites, the disposal strategy is sound and the operation as a whole is being executed well and allappropriate environmental and social safeguarding measures are being undertaken. The non-conformanceswere raised with the project team and mechanisms for their resolution were agreed.

The review of the 705 sites in Phase II identified two that were atypical in that they had large stocks in poorcondition. The two atypical sites are at Gode in the Somali region and at Abobo in the Gambela region. In the2001 inventory both sites were recorded as having close to 50 tonnes of pesticides in leaking drums, but securityconsiderations prevented them from being remediated during Phase I. The sites will be revisited in theforthcoming months and the security situation will be reassessed. If possible they will be remediated duringPhase II.

The 2001 inventory data for the Gode site is used as a benchmark for determining whether any of the other 705sites are also atypical, using FAO's Environmental Management Toolkit the risk factors for all the sites Thisexercise determined that none of the remaining sites was atypical, and all had pesticide risk factors (Fp) below25%.

The review of the current activities identified that appropriate measures are being taken to prevent and mitigaterisks of impairment of the environment and public health in Ethiopia.

The main recommendations are for establishment of an independent monitoring programme to be undertaken byan NGO, improved public communications, and closer supervision of the field teams by the National ProjectManager and the International Technical advisors.

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1 Project Objectives and DescriptionThe current project is the second Phase-I of the FAO project "Prevention and Disposal ofObsolete Pesticide Stocks in Ethiopia". To understand the current project and itsenvironmental and social issues, it is important to consider activities undertaken hitherto andthe level of funds needed to address both in Phase-I and Phase-l1 as summarised below.

Ethiopia has a well-documented history of problems associated with obsolete pesticides.Past initiatives to deal with this problem have been successful in addressing areas related toscattered stocks of obsolete pesticides and ensuring development of initial strategies toprevent future accumulation. The project objective is the cleaning up and disposal ofobsolete stocks and the development of "sound pest and pesticide managementstrategies". To achieve this, the ASP project will build on the existing initiatives and will aimto:

Ensure safe and environmentally sound elimination of obsolete pesticide stocks,and associated wastes such as heavily contaminated soils, buried pesticides andcontaminated containers / equipment which are outside the scope of existinginitiatives.

* prevent future accumulation of new stocks of obsolete pesticides through buildingon the previous / on-going initiatives to improve pesticide management, storage,distribution, by the adoption of international regulations such as the FAO Code ofConduct (2003), by the promotion of the correct use of pesticides, by improvedawareness and communications on pesticide related issues and by the use ofalternatives to chemical pesticides by adoption of agricultural systems such asIntegrated Pest Management (IPM);

* Develop national capacity in pesticide and chemicals management at national andgrass roots level in Ethiopia.

These objectives however could have not and can't be achieved without the necessaryfinancial support. In this connection Project Phase-I managed to secure a total of US$ 4.42million from the following donors in addition to Government budget support:

Donor Amount in million USDThe Netherlands Embassy 2.25Swedish International Development Agency (SIDA) 1.17USAID 1.00Total 4.42

Likewise for Project Phase-l1, a total of close to US$ 9.66 million is expected from thefollowing sources listed in table-1.

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Table 1: Financial sources

Category Total by Multi-lateral Co-Financing Bilateral Govt

Source o sPrivat

fu ane for xxx GEF ADB FAO Private Belgium Japan Finlandfund ad for(Est.)

Cleanup & 6.430 800 680. 0 700 3.080 0 790 380Disposal

Prevention 1.470 0 450 0 0 50 910 0 60

CapacityBuilding & 575 0 355 0 0 140 80 0 0InstitutionalStrength

PMU 1.185 0 15 0 0 800 140 230 0

Total $9.660 $800 $1.50 0 $700 $4.070 $1.130 $1.020 $440

This is where the need for CESA is needed because of the requirements that both theenvironment and human health issues are addressed to in compliance with the requiredstandards.

1.1 Objectives of CESA I and the CESA 11

The Country Environmental and Social Assessment (CESA) was prepared for the second phase of theFAO project "Prevention and Disposal of Obsolete Pesticide Stocks in Ethiopia". To understand thecurrent project and its environmental and social issues it is important to consider all the activities thathave preceded it.

Ethiopia is currently engaged in the disposal of approximately 1,100t of publicly held obsoletepesticides. Approximately 300t has already been repackaged and shipped out by the contractor totheir incineration and disposal facilities in the UK and Germany. The contract has been signedbetween the FAO and the European disposal contractor Onyx Environmental on behalf of theGovernment of Ethiopia. The contract is financed from a grant from the Belgium Government andcontributions from the Government of Finland and Crop Life International which are channelledthrough the FAO. The disposal operation is taking place based on a preliminary environmentalassessment and according to FAO best practice disposal standards.

As Ethiopia is going to participate in the ASP-P1 and will receive funds in this regard, it is arequirement to complete a country environment and social assessment (CESA) and to implement anenvironmental mitigation plan (EMP) to meet Bank requirements. This CESA is expected to review thecurrent FAO disposal guideline documents and the implementation of the Ethiopian disposal operationand to propose any changes which might be required for the remainder of the project. The TORs arein Attachment X

While current activities, in the main, focus on repackaging, transporting and shipping stockpiles to finaldisposal centres have been assessed to be done properly, following UN guidelines (i.e., properlylabelled pesticide drums; secured loads of drums in trucks for safe transportation etc.) a considerablechallenge remains in correctly analyzing environmental and social impacts, devising, implementingand monitoring in a timely fashion a mitigation plan commensurate to identified impacts.

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A second CESA will be prepared during Project implementation to review and assess that activities for

the GEF funded Africa Stockpiles Programme Ethiopia Project (ASP-P1 Ethiopia). The disclosure of

the second CESA will be a condition of disbursement of the funds for the disposal contract. This CESAwill prepare in detail a project environmental and social impacts analysis, assorted with environmentalmitigation plan (EMP) and a clear description of the institutional arrangements for implementation of

the EMP. Also, the CESA will address especially following issues:

3 The lack of environmental capacity within the PIU to oversee the implementation of

mitigation plan commensurate to identified impacts be they environmental or social

and in part to the lack of clear and coherent delineation of roles and responsibilities

of the various actors in charge of project safeguard. To this day, planning and

conducting activities in the context this operation has occurred almost in isolation of

key players, such as EPA and Ministry of Health. Notwithstanding their

representation in the project Steering Committee, the vital role they can play in

project success has been overlooked or not been assessed.

- EPA has reasonable capacity, facilities and equipment to help determine the types ofenvironmental impacts (i.e., on soil and water resources, both ground and surface water),although it needs strengthening. They have a laboratory which specializes in testingcontaminated environmental resources. However, they lack certain equipment and chemicalsto engage full-fledge in systematic testing of areas that may be declared contaminated whenthe results of CESA 2 become available. In addition, specialized short-term training may

needed for two of their agent who will be tasked with sampling and testing those contaminatedresources and interpreting results. Provisions for training and capacity building will be included

in the budget and Project documents

> Monitoring and ensuring that mitigation measures, as they relate to project environmental and

social impacts, are properly and timely implemented is paramount to the success of theproject. Oversight responsibility of project overall compliance with national and Bank

safeguard policies should be devolved to Ethiopia Environmental Protection Authority (EPA).This task falls within the realm of their mandate and once their capacity is strengthened,based on the proposal submitted, they will do a job in ensuring that the project comply with

Bank and national safeguard policies. Their capacity will also be supplemented with otherentities in specialized areas, such as health issues, impacts analysis, remediation measuresand technical backstopping in the event of pesticides effects on flora and fauna.

1.2 Background to Phase-IPhase-I commenced in September 1999 with a Grant Aid from USAID, which funded an

Environmental Review, from which this CESA draws. Following further contributions from

the Governments of Sweden and the Netherlands, and CropLife International (CLI), the

project became operational at the end of 2000 and finally completed operation in December

2003. The project had sufficient funds for the disposal of 1507 tonnes of pesticides, i.e. the

initial estimate of Ethiopia's stockpile.

The contract for the disposal of 1,500 tonnes of obsolete pesticide stocks was subject to an

international tender compliant with FAO procurement rules. The contract was awarded to a

Waste Management Company called Ekokem Oy Ab of Finland.

The data collected in 2001 during a new inventory of stocks confirmed that over 2500

tonnes of obsolete chemicals plus a minimum of 1000 tonnes of contaminated soils existed

in over 900 sites across Ethiopia. Large quantities of empty containers and contaminatedspray equipment were also found. All these posed serious threat to the environment and

population of Ethiopia due to poor storage conditions which prevail in the country.

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The confirmation of the additional stocks posed the project team in Ethiopia a problem. ThePhase-I budget was only sufficient to remove for disposal of 1500 tonnes of materials. Thequestion as to which stocks should be sent for disposal and which stocks should be includedin a subsequent Phase-Il project needed to be addressed. The team adopted a "risk based"approach to the selection of key sites which should be regarded as a priority. Factors suchas the quantity of stocks, the amount of leaking materials in a store, the structure of thestore and the proximity of stores to major population centres and water sources were allfactored into the site selection process. This resulted in Phase-I removing stocks from 243priority sites scattered across the country. The risk based approach was adopted inpreference to a simple geographical approach which would have left some Regions inEthiopia completely free from stocks whilst others would remain with highly hazardousstores which would continue to pose a direct threat to public health and environment. Therisk based approach identified two priority sites at Gode and Abobo, Gambella that wereinaccessible due to security consideration as already indicated above.

The project mechanism involved the pesticides at the prioritized sites being repackaged intonew containers or placed in salvage drums. The safeguarding activities were undertaken byteams of local operators supervised by Ekokem staff. The project team identified 8-storesthat were suitable to be used as Major Collection Centres (MCC) for the storage of therepackaged pesticides prior to their transport to Ekokem high temperature destructionfacilities. The MCCs were all existing stores that were selected on the basis of there goodlocation with respect to road networks, the low risk that they posed to the environment andpublic health, and their storage capacity. In some cases the stores were modified to bringthem up to the required specification. PANUK undertook an independent EnvironmentalRisk Assessment of each store based on the US/AID environmental scoping system beforeit was confirmed as being useful and acceptable MCCs. A detailed summary of Phase-Iactivities is provided in the FAO Terminal Report submitted an annex to the OperationalManual.

There were issues with receiving the funds from CLI, because there were difficulties invalidating the quantity of materials that was attributable to their members as well as protocolissues with the mechanism to receive the funds on to of the fact that CLI wanted toreimburse only after the obsolete stocks traced back to the Association of the Chemicalindustries were destroyed. This made it difficult as the Waste Management Companyneeded to be paid for its services. Although it had been difficult, it was finally resolved withCLI's payment in 2005 but only after FAO aid the cost of incineration by diverting fund fromother commitments.

1.3 Phase-lI project ObjectivesPhase-Il is made up of 3 separate projects with funding from the Governments of Belgium,Finland and Japan. The ASP is also due to fund Phase-Il. Phase-Il is a natural extensionof the activities successfully completed under Phase-I of the project. Each projectdocument defines its own objectives. The combined objectives of all three projects can bedescribed as follows:

. to remove and safely dispose of approximately 1000 tonnes of obsolete pesticidesscattered over 705 storage sites identified under Project Phase-I;

* to build on effective prevention strategies developed as part of Phase-I of the Project byinitiating a series of pilot projects on Integrated Pest Management (IPM);

- to continue the review of existing regulations of pesticide usage through the full life cycleof the chemical from initial needs assessment to final safe disposal;

* to examine potential technologies which could be used in the Ethiopian context for thesafe disposal of old pesticide containers and soils contaminated with pesticides. This willinclude procurement of specialized equipment for use in Ethiopia;

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* to decontaminate soils and areas where pesticides have been buried using technologieswhich can be successfully operated in Ethiopia;

* to strengthen pesticide storage and management.

The Phase-lI project commenced in December 2003 with the engagement of two-twoAdvisors, one International Consultant (IC) for the Disposal Component and the second thesecond a Technical Advisors (TA) for the Prevention Component under the BelgianTechnical Cooperation (BTC project). In June 2004 national project staff members wereengaged, including the appointment of the National Project Manager (NPM) from the CropProtection Department (CPD) of the Ministry of Agriculture and Rural Development. InSeptember 2004 the inventory verification and repackaging activities commenced.

The institutional arrangements for financing the project are described in detail in theOperational Manual and relevant organogram/s are provided below.

1.4 Organisation StructurePhase-l1 uses the existing forum for stakeholder involvement that was developed underPhase-I. In Phase-I it was realised that the wide variety of government, donor and otherstakeholders needed reg ular updates on project activities.

The overall project structure for the implementation of Phase-l1 is shown in Figure-I below

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Figure 1: Structural representation of multilateral and ASP project operations

Project Steering Committee(PSC)

Chair, State Minster(MoARD)

Members of PSC Admin Technical

/ FAO, Donors, Head CPD,Finance and personnel EPA, PMT

MoARD Js Donor Funds

Head of Crop Protection 1*Belgium, Finland, Japan, ASP

Belgium Comanaged fund

Financial & Admin Project Management TeamAssistant Officer Project Manager, ConsultantOvresdpoa

Disposal, Advisor Prevention Overseas disposal4 Waste managementCounter part Prevention contractor

Field Managers Regionl and Zonal

Four technical staff Agriculturat and EPA

(Tow from Phase-I) Counter parts | pro,rct

D r ind^ect Technicians | Paramedic Nurse and Project drivers(Clean up and repackaging) Storekeeper/Purchaser

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Figure 2: Collaborative management structure and organization involving severalstakeholders and some of those indicated in Figure-1

National Project Coordinating Committee

Project Steering Commitee

Project Management Team/UNIT |

Field Managers

|Dies||Technicians | tore Paramedic Recgiona IKee vr NreCounter'a

The involvement of all relevant stakeholders concerned in the project is demonstrated inFigure 2. The National Project Coordinating Committee (NPCC) is a forum in which eachvarious stakeholders meet as and when necessary to discuss about the project plans,management progress, technical issues, health, environment, and any matters related toproject and shares ideas among members reflecting the project. The NPCC is chaired byFAO as overall coordinator of the technical inputs to the project and as financial manager tothree of the project funds. The NPCC is an informative forum and conducts its meetings in amanner where the necessary advice and guidance are highlighted and shared. Themembers of the NPCC include the following and it is open to invite others interested:

(a) The Food and Agricultural Organization of the United Nations(b) Ministry of Agriculture and Rural Development(c) The donor community particularly those providing financial support to the project

both during Phase-I and 11 Representing the Governments of:

(i) the Netherlands,(ii) Finland(iii) Sweden/Swedish International Development Agency,(iv) US/AID(v) Belgium(vi) Japan, etc.)

(d) Canadian International Development Agency (CIDA)(e) CropLife Ethiopia representing the Association of Chemical Industries/Pesticide

producers, exporters(f) Representative of the Association of NGOs in Ethiopia

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(g) The Environmental Protection Authority of Ethiopia involving Head of the PollutionControl Unit

(h) Ministry of Public Health(i) Ministry of Foreign Affairs(j) The African Union(k) The UN Economic Commission for Africa

MoARD is the executing agency for the Phase-l1 project in Ethiopia. It assumes overallresponsibility for the implementation of various project activities and is the principal point ofcontact for the main project stakeholders (Governments of Belgium, Finland and Japan,FAO, NGOs, Ministries, public and private institutions) and is responsible for submitting allrequired reports.

A Project Steering Committee (PSC) has been established under the agreement betweenthe GoE, GoB and FAO. The PSC is chaired by the State Minister of Agriculture and RuralDevelopment and comprises the FAO Representative in Ethiopia to the African Union andthe Economic Commission for Africa of the United Nations (ECA), the CountryRepresentative of Belgium Technical Cooperation (BTC), the Department Head (CropProtection Department of the MoARD) and members of the Project Management Team(PMT) serve as the Secretariat of the PSC.

The PSC is charged with the responsibility of overseeing the project activities and ensuringadherence to agreed principles and policies. The PSC is responsible for the examinationand approval of all work plans and the Belgium budget of the project. The other bilateraldonors have confirmed they do not wish to become part of the PSC and are satisfied withthe administration of their contribution through the usual FAO processes.

A formal Project Management Team (PMT) has been established since the start of Phase-Il of theproject in 2004, funded through the locally managed component of the GoB contribution to the project.The PMT is responsible for the implementation of project activities on a daily basis.

1.5 Institutional Arrangements for Project Implementation

The Crop Protection Department of Ministry of Agriculture and Rural Development will be responsiblefor the over all implementation of the project.

At a national level there will be a number of key bodies established to ensure effective ASP-P1 projectcoordination and implementation. Many of these bodies are currently operational under the Phase IIproject and the ASP will dovetail into these existing structures wherever possible.The national bodies are:

(i) A National Project Steering Committee (NPSC);(ii) National Project Coordination Committee (NPCC);(iii) The Project Management Team (PMT) comprising the following positions:

* National Project Manager (NPM) from CPD.* National Prevention Coordinator (PC) from the CPD;* Intemational Technical Advisor Disposal (ITADs);* Financial and Administrative Assistant (FAA).* Procurement Assistant Officer (PAO)* Pesticide registration team leader from CPD

(iv) Field Staff including:* Field Managers (FM) from CPD;* Regional counterpart staff from the department of agriculture;* EPA Focal point at national and regional level;* Project technicians employed through the CPD;* Project paramedic nurse;* Project logistics and store manager.

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(v) Support Staff:* FAO employed project administrative assistant;* FAO employed drivers.

Figure 3: Proiect Management Structure

NPSC l

| PMT v NPCC |

Prevention TT Disposal |

TA Support

|Laboratory |+ ommunicati | CSA for ASP--

Asessment I n

r Psiie ||Pesticide dsoa Containerl Soil------|Buried pesticides Manaqeme Remediation -

The implementation of the ASP-PI project in Ethiopia will be coordinated through the NPSC and PMT.The PMT will establish two task teams of national experts. A prevention task team from relevantdepartments within government, NGO representatives and other stakeholders will be developed toensure delivery of project outputs in the 3 key areas of prevention. The role of each stakeholder ineach individual aspect of the prevention programme will be developed at the on-set of the project andwill be monitored thereafter by the PMT. Similarly, a disposal task team will be developed and will my

focus initially on the completion of a national CESA in FAO / WB format. The CESA will focus onallowing the country team to develop a feasible strategy for the disposal of the various waste streamsremaining in Ethiopia after completion of the Phase II project. Inputs from technical advisors may beneeded during this process. Once the disposal strategy is developed the responsibility forimplementing the various disposal components will pass on to existing project staff (the FieldManagers).

A memorandum of understanding (MOU) will be developed between MoARD and EPA to clarify the ndifferent roles and responsibilities and the institutional collaboration for the implementation of ASP-P1..

1.5.1 Project Monitoring Evaluation

The role of monitoring and evaluation of the disposal activities will pass on to the National EPA. Thedisposal component will have a clear set of monitoring and evaluation (M&E) criteria for each set ofactivities. The criteria are based on the procedures and standards which have been developed by theFAOITSU in the EMTK, FAM and other technical guidelines. EPA is expected to employ this set ofM&E criteria. These will provide for continuous monitoring and improvement in the quality of thedisposal operation. The TSU and the WB will review monitoring data during supervision missions.

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Through appropriate M&E the ASP aims to continually improve the standards of operation to minimizethe potential for adverse impacts on human health and the environment.

In order to undertake an effective monitoring and evaluation EPA will be supported by the projectunder the capacity building component. The support will include training of key lab staff and upgradingexisting lab equipments.

1.6 Outline of the Current Pesticides Disposal Component of Phase-lIThe scope of this CESA and the initial disposal component of Phase-Il are limited to thedisposal of publicly owned pesticides from the 705' sites identified in the original Phase-Iinventory in 2001. It does not include:

* Disposal of privately owned pesticides* Disposal of pesticides from stores that have been identified subsequent to the 2001

inventory* Disposal of the containers of the pesticides, once they have been repackaged- Disposal of other empty containers in the country* Disposal of contaminated soils* Disposal of contaminated equipment* Decontamination of the 705 sites* Re-inspection and decontamination of the 243 sites addressed in Phase-I* Disposal of buried pesticides

The disposal strategy is based on the same FAO Guidelines that are proposed to be appliedto all ASP country projects.

With the capacity building and experience gained in Phase-I, it was determined that forPhase-Il there was sufficient capability within the country for some elements of the project tobe undertaken solely by country staff without the involvement of an international contractor.

1.6.1 Prioritization StrategyAs the high risk stores had been addressed in Phase-I, the remaining stores were deemedto all have similar levels of priority. Transport of the repackaged pesticides was identified asthe highest risk activity to the project, so a strategy based on maximizing the logisticalefficiency was developed. This also had the advantage of improved cost effectiveness andreduced time for implementation. The strategy is based on geography with the sitesrepackaged zone by zone within each region.

1.6.2 Activities undertaken by Country StaffThere are two activities undertaken by country staff:

inventory data verificationCleaning up, repackaging and transportation of repackaged obsolete stocks to MCCs

The number of sites was determined as 705 rather than 753 as originally thought. Each site hasbeen given a unique identification number by the project team. Some sites however do have morethan one store. For the purpose of this report the statistics based on sites maintains consistency withthe numbering system used by the project.

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Inventory data verification: The inventory data of each of the 705 sites has to be checkedand updated so that it reflects the current situation. A team, which comprises a FieldManager, a representative of the Crop Protection Department of the Region, arepresentative of the EPA and a representative of CropLife, tours each region and inspectseach of its stores. The team updates the inventory; completes an environmentalassessment of the store using FAO's Environmental Management Toolkit methodology;assesses the road conditions to help determine the safest route for transportation of therepackaged items; completes a site and store plan; photographs the store and the materials;and obtains all the contact details and emergency information necessary for therepackaging activity. The Field Manager and the representative of CropLife agree theinventory and the materials that are attributable to CropLife member companies.

RepackagingA cleaning up and repackaging plan are developed for the region based on the informationgathered during the verification. The repackaging team takes the appropriate quantity ofpackaging materials and goes to the site. The team comprises a Field Manager, arepresentative of the Crop Protection Department of the Region, a representative of theEPA, operators, nurse, and drivers. The team sets up safe working areas and undertakesthe process of cleaning up and repackaging. At the end of the cleaning up andrepackaging, the site is re-inventoried to record the quantity of contaminated equipment andcontainers that will have to be collected and decontaminated later under ASP.

Transportation to Major Collection Centres (MCCs)

The repackaged materials are stowed on a vehicle, which may proceed to another store torepeat the activities or return to an Interim Collection Centre or to a given the MCC todeposit the repackaged materials. The team is escorted by a police vehicle and there isanother vehicle with emergency response equipment.

Management of the MCCs

The repackaged materials are segregated into their material types for loading into ShippingContainers. Where drums are not completely full, they are consolidated with compatiblematerials. Unknown materials are dispatched to the Gottera MCC in Addis Ababa wherethey are analyzed and characterized.

1.6.3 Activities undertaken by International ContractorSupply of equipmentThe contractor is responsible for the supply of all protective clothing; UN certified drums,repackaging equipment and materials, spill kits, fire extinguishers and first aid kits.

Labelling drums:The contractor is responsible for labelling the drums at the MCC to IMDG standards.

Shipping ContainersThe contractor arranges delivery of empty Shipping Containers to the MCC and stows therepackaged materials. Shipping Containers to be used for drums of liquids have steel drip-trays to ensure that the container does not get contaminated and that liquid pesticides don'tflow out of containers.

Obtaining Transboundary Movement Authorization under the Basel ConventionThe contractor provides the financial guarantees and movement tracking forms and obtainsauthorisation for the international shipment to UK or Germany

TransportationThe contractor is responsible for the transport of the Shipping Containers from the MCC tothe disposal facilities in UK or Germany. The transport within Africa must be accompaniedby escort vehicles with emergency response equipment.

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DisposalDisposal takes place under high temperature incineration facilities of the repackagedpesticides (including the packaging materials).

An international tender was organised under FAO procurement rules and a contract wasawarded to Shanks Chemical Services which following a take-over, was renamed as VeoliaEnvironmental Services.

1.7 Project basis, protocols and standardsThe project has been developed based on FAO procedures, guidance documents andtraining modules. In particular:

Inventory guidelinesEnvironmental Management Tool Kit (EMTK)Disposal guidelines

. Training modules (project management skills; project planning; supervision; safeworking methods; transportation; safeguarding and repackaging; use of personalprotective equipment; emergency procedures; first aid; and communications)

The EMTK provides the basis for the selection of the site prioritization strategy and thetransport and disposal plan. It is a huge document and so cannot be included with thisCESA but is available at the Project operation base and relevant staff keep own copies forreferences.

The project team developed an Operational Manual in Phase-I which continues to beupdated as new guidance is developed and as per the generic guidelines of the ASP. Allactivities undertaken in the project should conform to this Operational Manual.

1.8 Project StatusThe status of the Phase-Il project September 2006 is summarised below.

Table 2 - Project Status at 5 October 2006

Percent of theMajor Total No Total total Percent of the

No. Collection sites Repackaged repackaged total stocks ofCentre cleaned up (tones) stocks of 1100

754.51 A. Ababa 361.6 47.93 36.162 Nekemte 131 17.36 13.103 Awassa 504 110.2 14.61 11.024 Jimma 89.7 11.89 8.975 Mekele 62 8.22 6.20

Total 754.5

The 754.5 tonnes includes 67 tonnes repackaged stocks left behind from Phase-I

The Target for cleaning up and repackaging under Phase-Ill is 1000 tonnes

So far shied over seas and incinerated 381 tonnes

14

Last revised Ale following Bank 1't comments received from the W8

2 Policy, Legal, and Administrative Framework

2.1 Relevant International Legal InstrumentsThere are 3 international conventions that impact the disposal component of the project butEthiopia has ratified them all. They are:

Stockholm Convention: The Stockholm Convention which was adopted on May 22, 2001on Persistent Organic Pollutants (POPs) calls for outright banning and destruction of 12Persistent Organic Pollutants, 9 of which are pesticides. These are:

Pesticides POPs: Aldrin, Chlordane, DDT, Dieldrin, Endrin, Heptachlor, Hexachlorobenzene,Mirex, Toxaphene

Industrial POPs: Dioxins, Furans, Polychlorinated biphenyls (PCBs)

Basel Convention: The Basel Convention on the Control of Transboundary Movements of -

Hazardous Wastes and their Disposal was concluded in Basel on March 22, 1989, andentered into force in May 1992. The shipments from the MCCs, through Djibouti, by sea tothe disposal facilities must comply with the requirements of the Convention

Bamako Convention: The Bamako Convention on the Ban of the Import into Africa and theControl of Transboundary Movement and Management of Hazardous Wastes within Africawas adopted on January 30, 1991, in Bamako, Mali. Compliance with the Convention isachieved through compliance with the Basel Convention.

Dates of Ethiopia's Ratification of these International Conventions are shown below;

Table 3 -Ethiopian Ratification Dates for International Conventions

No Convention Ratified Proclamation No ResonsibleN Covninacceded National Agency

1 Stockholm 17-5-02 July 2002 2079/2002 EPA

2 Basel . 10 Feb 2000 19212000 EPA

3 Bamako Acceded 2002 55/2002 EPA

In addition to these conventions, the following international regulations apply to the shipmentof hazardous cargos by sea and road:

International Maritime Dangerous Goods Regulations issued by the IMO are mandatoryfor all international shipments and prescribe standards for the packaging and labelling ofcontainers.

ADR is the international regulation for the transport of dangerous substances by road.

2.1.1 Requirements of the Basel ConventionThe detailed requirements for compliance with the Basel Convention are set out in Annex D.The process involves the following:

Agreement between GoE and GoUK under Article 11 of the Basel Convention and Article19 of Council Regulation (EEC) No. 259/93 to import waste into the UK. An agreement hasbeen made on 15 February 2005 for the period to 14 February 2008.

Financial Guarantee must be put in place in favour of the Competent Authority (CA) of theDisposal Facility to be used in the event that the Disposal Facility is unable to accept thewaste. The UK Environment Agency has issued a Certificate of Satisfaction.

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Last revised Ale following Bank 1 St comments received from the WB

Notification of Competent Authorities in countries of transit has to be made. Theholder of the waste notifies the CA of each transit country of the proposed shipments.

Authorisation from the Competent Authority of the Disposal Facility has to be sought.The holder of the waste notifies the CA of the Disposal Facility of all the proposedshipments, including movement tracking forms. Tacit consent can be assumed if the CAdoes not raise an objection within 70 days.

Movement Tracking forms authorised by the CA of the disposal facility must accompanyeach consignment throughout its movement to the Disposal Facility. The Disposal Facilityconfirms to all CAs that the consignment has been received.

Disposal must be completed within 180 days of receipt of the materials at the disposalfacility. The disposal facility must complete the tracking forms to confirm that the materialshave been finally disposed.

Special Notification of the Government of Djibouti must be made 10 days before thecontainers arrive at the Ethiopia/Djibouti border crossing. The notification has to include theidentification numbers of the Shipping containers, their weights, and the anticipated day ofarrival at the border. The notification has to be delivered through formal diplomatic channelsby the Embassy of Ethiopia, in Djibouti. In addition, the timing of the arrival of the shippingcontainers at the border crossing, should allow them to be transported to the port to coincidewith the arrival of the ship. The containers have to be loaded directly from their vehiclesdirectly on-board ship. These conditions are in excess of the requirements of the BaselConvention, and add to the costs of the project.

2.2 Relevant Ethiopian National Legal InstrumentsThe legislative structure in Ethiopia encompasses both Federal and Regional Laws. In thecase of this project all the legal requirements are set by Federal legislation.

Table 4: Relevant Ethiopian national legal instruments

Legislation Comment Agency Activities Regulated

This policy provides the framework forE P environmental management. Not all Repackaging

Environment Policy has yet been converted into regulations, EPA Disposal2 April 1997 but it is used as the basis of decision Storage

making CommuniGations

Environmental Only applies to the constructions of newImpact Assessment stores - if the stores pre-existed, it isIolmatont not necessary to undertake an EIA. EPA Selection of MCCsProclamation However the proclamation's principles

were used in the selection of MCCs

Environmental This is the most important proclamation RepackagingPollution Control as it applies directly to the disposal EPA Disposalproclamation activities. Storage300/2002 CommunicationsPublic HealthProclamation Includes occupational health control Ministry of Verficaion200/2000 Health Repackaging

Labour Proclamation Occupational Safety, health and Min of Labour Verification377/2003 working environment & Social Repackaging

Transport Vehicle testing, speed limits etc Limits Ethiopian299 (reison vehicles carrying hazardous cargos to a Transport Transport27 161(revisions maximum speed of 40 km/hr Authority

Pesticide Enables regulations to be made for safe MoARD DisposalProclamaion disposal and storage of pesticide waste Storage

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Last revised Ale following Bank 1 5 comments received from the WB

2.2.1 Guidelines and StandardsThe EPA is in the process of developing a guideline document on Hazardous Waste, but itis unlikely to be available before the end of 2006. The EPA however has confirmed that itexpects that the practices currently adopted for the project will conform to the guidelines.

The EPA has published two guidelines on environmental standards:

. Ambient Environment Standards for Ethiopia which specifies standards for quality -standards for air; water; soil and ground water; and noise.

0 Standards For Industrial Pollution Control in Ethiopia:

2.2.2 Ethiopian Administrative structuresThe Administrative structure for Ethiopia is on 5 levels:

Federal

Regions

Zones

Werede

Kebele (village)

This structure is important as much of the Federal proclamations are implemented andregulated at the regional level. It is also important for the communications strategy as themessages have to be received at the Kebele and Woreda levels.

Local government entities consist of Regional States, Regional Bureaus, Zonal and WoredaBureaus. The Federal Government is responsible for drawing up general policies pertainingto common interests and benefits while Regional Governments are usually implementers ofthese policies. Local governments, on their part, facilitate project implementation andpeople's participation in implementing the policies.

2.2.2.1 Reorganisation of administrative areasThe administrative areas have undergone a reorganisation in 2005. This has had an impacton the project because pesticide stocks at some sites have been split between twoadministrative areas. This has added to the administrative burden of the project.

2.3 Legislative Framework for European Hazardous Waste IncineratorsEuropean incinerators have to conform to the minimum operating standards set out in theEU Incineration directive (2000/76/EC). Each incinerator must have an authorisation tooperate granted by its competent authority under the EU Integrated Pollution Prevention andControl Directive (96/61/EC). The Veolia (previously called Shanks/Onyx) incinerator atFawley, UK has the authorisation number AG8047 granted by its competent authority, theEnvironment Agency in Winchester, Hampshire UK. This is the same authority that isresponsible for the Transboundary movement forms. The contractor also has the option tosub-contract the disposal operation to AVG Abfall-Verwertunge-Gesellschaft mbh,Hamburg, Germany. AVG's hazardous waste incineration plant is subject to the statutoryrequirements of the Federal Emission Control Act (BlmSchG). The pollutant content of theflue gas is required to be continuously measured prior to entry into the stack. Themeasurement data is required to be transferred via online transmission to the competentmonitoring authority of the Free and Hanseatic City of Hamburg.

l

17

Last revised Ale following Bank 15i comments received from the WB

3 Baseline Data and Review of the Clean up Operation to date

3.1 Overview of known sitesAt the beginning of Phase-l1 there were 705 known sites that remained after thesafeguarding and disposal of the high risk sites in Phase-I. Figure 3a below shows thedistribution of these sites based on their individual stock levels of obsolete pesticides. Thisshows that 96% of the 705 sites had stock levels below 5 tonnes and 99% below 10 tonnes.

The disposal activities therefore focus on the removal of approx. 1100 te of obsoletepesticides scattered across in Ethiopia in the 705 storage locations and/or affected sites.The pesticides under consideration are publicly held stocks used for agricultural productionand under the control of the Ministry of Agriculture and exclude stocks held for Malariavector control under the control of the Ministry of Health. The disposal of the stocks requiresthe development of a coherent strategy for repackaging, collection, storage, transport andfinal disposal. Based on the capacity developed during the implementation of Phase-I it wasdecided to use a team of well trained local staff to complete the repackaging, collection andstorage steps through the process (referred to as "safeguarding") and to tender a contractfor the onward shipment / transport and final disposal based on FAO procurement systemsand technical guidance. It was also agreed that the project would request the internationaldisposal contractor to supply all necessary equipment for the repackaging exerciseaccording to the technical specifications provided from FAO. The contractor (VeoliaEnvironmental Service in the UK (formerly Shanks Chemical Solution) was selected in late2004 and equipment was supplied to allow the start of safeguarding activities in Ethiopia inearly 2005. Subsequent to the start of operations in Ethiopia over 600 te has beensafeguarded, cleaned up, repackaged and moved from the original storage location to aseries of Major Collection Centres (MCC) at Gottera in Addis Ababa, Nekemte, Awassa andJimma as shown. These three MCCs are among the eight in the country chosen because oftheir strategic and safe locations for retaining obsolete stocks brought in from theproximities of the various affected sites until shipment overseas for destruction. Thequantities of stocks involved to be kept in each MCC and the relative locations of the eightMCCs in the country have been clearly plotted on a map and highlighted in the OperationalManual (OM) submitted.

As was pointed out in the footnote in section 1.6, there is a flaw in the baseline data as afew of the sites actually refer to more than one store. However it is crucial for the disposalof the contaminated containers, soil and equipment under the ASP project that reliableinformation is held on the precise location of each store. The project team has been madeaware of this issue and, as part of the verification process currently under way, is recordingthe details of all the stores. The increased number of stores will have an impact on theworkplan and reporting later in the project

For the purpose of this CESA the statistics based on sites maintains consistency with theoriginal numbering system used by the project i.e. 705 sites. In order to have an idea of thesize of stocks and distributions by different regions and zones and number of affected sites,reference need to be made to the figures given in the table and maps below.

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Last revised Ale following Bank i's comments received from the WB

Table 5: Number of Zones and Sites per Region, Quantity of Obsolete Stocks (in weight (kg)and in volume (litres) and locations of Major Collection Centres

(*) A complete inventory of obsolete stockpiles is separately availableCentralized Stores Region zone No. of Sites LT KG Total

SouthTigray 14 11,085.00 13,542.00 24,627.00

Tigray EastTigray 12 11,37200 16,187 50 27,559.50

Mekele Central Tigray 23 1157701 12,266.70 23,843.70

Afar Zone - 4 1 700.001 0.00 700.00

,NorthWollo ID 8,214.50 4,18.30 1402.80

SotAh Wollo 12 11,820.00 4,040.60 15860.602 Kroorricha Oroya 6 9,120.80 4,68.00 t380a80

NorthShoa 41 7,661.70 23,690.00 3035170

M e8 .dar W"t 34 43,037.00 24,12.50 67,166.80

NorthGorder 29 10,614.00 18,092 00 26,706.00

South Gorieer 1 6,297.00 3,951.50 10,248.50AW1t Goj8 26,879 00 19,663.00 46,542.00

3 Awi 5 4,783.00 1,594.00 6,377.00BaNr Dar _ _ _ _ _ _ _ _ _ _ _ _ _

Metel 2 1,861.00 187.00 2,048.00

Baresh nga Gumut East Gojam 23 10O839.00 34,739.00 45-578.00Wrghmra 6 2,083.00 557 00 2,640 00

Assosa 5 2,607S0 2,142.50 4,750.00

3Kenashe 797.55 2,480.00 3,277.56

4 Nekne West Wolega 21 18.857.00 27,09590 45,952 90

:EKl Wolega 68 26,985.00 46,939.00 73,924.00

SNNPR NorthOrno a 23,571.0t 7,893.00 31,464.00 ,

Jirnam 36 5,57B.50 43,107.10 48,685.60.

Yamsn2 2 ,090.00 497.00 2 ,537.00

Oroniya Bench M i 394.5C 2,805,50 2,900.00 _

Kdicho Shekicho 4 4,269.00 7,140.07 11409.07

lluioor 26 11,475.00 20,076.50 31,55tSO

2 45,189.00 650.15 45,839.15

. 2 - 6 x~~9 ones - 1Gungie 33 IO,670.00 20,438.00 31,108.00 H

Sidans 11 20,474.00 32,794.20 53,268.20 4

Gede9 6,599.50 8,1800.00 14,899.501SNNPR Hdiya 13 2,768.80 15.946.30 19.715.10

6 Awassa KAT 18 5,710.00 3,708.00 9,418.00 .

SOAh Om15 9,568.00 7,649.00 17,21700

. Borr 9 5.347.30 4,995.70 10,343.00

1Bal t0 12,274.00 9.55&00 21,839.00

Somali Gods 3 57,257.00 9800 0 58,219.00

AddlsAb ba A ditAb bs 7 14,843.00 80t4 22,864.40

N. W. Shos 31 7,820.00 8832t,8.

.East Shoa 39 9,817.30 368.04,7,'a Add,s Ababa Oromya West Sho a 49 15,962.00 349500,E7(f

, ri36 35,830.00 23,064.001 58 ,9~4,01

1 -- 5 398.98 557,190.C5 1,089,5569.0

19


Baseline data

The baseline data could be summarised from the above verified inventory data for eachstore. This could be in the form of a table with a row for each store, with columns indicatingtotal quantity of pesticide (kgs), the total pesticide risk factor and Environmental risk factorsusing the FAO Environmental Tool Kit (EMTK), of the Store building, of the Storageconditions, and of the environment around the store.

Each store could be plotted on the Environmental Assessment matrix in relation to the siteat Gode (see lot below) to demonstrate that there are no other atypical sites as is the caseat the moment because stocks with the highest environmental and human health risks havebeen removed from a total of 243 sites and destroyed during Phase-I. It is also possible tolist each unit of stocks of obsolete pesticides in each store, but definitely this will then be atable extending to hundreds of pages and is therefore impossible to include in this documentand is therefore unlikely to be of help. However, the information of all stores whose studieshave been completed is available in the record files within the Project office.

Figure 3a: Distribution of stores by stock level

Distribution of Stores by Stock Level

200 i-

150

500 5,500 10,500 15,500 20,500 25,500 30,500 35,500 40,500 45,500

Stock level (kgs)

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Last revised Ale following Bank 1s' comments received from the WB

Distribution of 705 Sites by stock-level

500-kg 1 te

< 500 kg

- . -. .. .- -. . . ................ .-! 15 -10 te | i Q10-5 e F25tel * < |25-50te|.,,

Figure 3b - Distribution of Sites by Stock Level

The 4 stores with significantly higher stock levels which are shown in Table 6 below

Table 6 - Sites with more than 15 te

Store # Region Zone ] Site Location j Tonnes j

783 SOMALI GODE ' GODE SETTLEMENT 48.8

936 GAMBELA GAMBELA ABOBO 40.6 i

750 S.ETHIOPIA SIDAMA AWASSAAISCO 27.4

704 S.ETHIOPIA HADYA HOSAENAAISCO 16.0

The sites at Gode and Abobo were excluded from Phase-I because they were notaccessible due to security considerations in the area. There were reports that the stocks atthese sites were in very poor condition and there have been complaints from the public. Assuch these two stores should be considered as atypical sites (see section 7). The securityin Gode continues to be an issue, but the project team intends to inspect and assess the A

site in the near future. A third site at Gambella with a recorded stock level of 750 kgalthough has been inaccessible for the same reason but as of the first quarter of 2006Abobo and Gambella have been cleaned up.

The Awassa AISCO and Hosaena AISCO sites in South Ethiopia have already beensafeguarded in the early stages of Phase-l1. They were excluded from the safeguardingactivities of Phase-I because the stores were in good condition and posed very low risks tothe environment and public health. The stocks that they contained were also in goodcondition. Neither store is atypical using the methodology for determining atypical stores setout in section 3.3.

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Last revised Ale following Bank 1$ comments received from the WB

Following the publicity surrounding the completion of Phase-I and awareness raising withthe stakeholders in the project steering committee, the project team is receiving notificationof other sites in the country with stockpiles of obsolete pesticides. As of 31 March 2006, 17new stores have been identified. These sites are outside the scope of the current disposalcontract but will be included later in Phase-Il. There are 3 stores with significant stock-holdings which are detailed in Table 7 below:

Table 7 - new stores with large stockpiles

New Store Name TonnesMinistry of Health, Addis Ababa 1 5?:Upper Awash Agro Industy 17Agricultural Equipment & Technical Services S. Co. 27

The Ministry of Health site in the centre of Addis Ababa is the most significant with 150tonnes of DDT quantity wise. This is the largest stock-holding of any known store as of 31March 2006. It is possible that this site might be atypical when it is assessed. Currently thissite is scheduled to be safeguarded as part of the ASP, with funding from the GrantAgreement, but the MoH would like it safeguarded as soon as possible. The PMT hasprepared an outline budget for the likely costs for safeguarding, repackaging and disposal.This has been presented to the MoH in the hope that sufficient funds can be raisedimmediately to allow the project team to safeguard the site ahead of schedule.

3.1.1 Geographic distribution of sitesThe maps in Figure 4 and Figure 5 respectively show the Ethiopian zones with their densityof sites and the weight of their obsolete stocks as at the beginning of Phase-Il.

v ,Legend:

] 5- sitesIk~ ~ U5-lO0sitesI, / ;*

10 - 20 sites

Jr- tX 20-30 sitesi 30-40 sites

40-50 sites

* >50sites

Figure 4 - Map showing density of sites at beginning of Phase-lI

22


Legend:

*e . ( < 1020 teU 2- 20Ote* ,'. 20 - 30 te

i/30 - 40 te-40 - 50 te

50 - 60 te -

. >60te

Figure 5 - Map showing concentration of stocks by weight at beginning of Phase-lI

3.2 Detailed Environmental and Social Characterization of sitesFAO's Environmental Management Toolkit (EMTK) provides an objective mechanism tocharacterize the environmental and social characteristics of a site. The toolkit allows storesto be scored on the basis of a standard questionnaire. The project team is using thismethodology as part of the verification process. The questionnaire (an example is includedin Annex E) covers the environmental and social risk categories and elements shown inTable 8:

Table 8 - Environmental and Social Risk Categories

Maximum Risk Maximum RiskRisk Category score for Risk Element score for

Category ElementConditions of 20 n/a n/athe store 20_n_a_n_a

Content of the store 5Storage Security 5conditions Management procedures 3

safety 5Hazards affecting the store 15Human settlements 20

Environmental 62 Water sources and soil 20conditions Agriculture, Livestock Activities,

Wildlife and Biodiversity

The EMTK uses the abbreviation Fe to indicate the total Environmental and Social riskfactor for a store.

23


The EMTK also objectively assesses the risks associated with the pesticides in the store.For each pesticide in the store, a risk factor is calculated based on the toxicity of itsformulation, its physical state, the condition of its containment and its quantity. Summingthe risk factors for each of the pesticides in the store gives the total risk factor due to thestores contents, which the EMTK terms Fp.

The sites in Gamu Gofa, Sidama, and Wolaita, Dawro and Konta zones demonstrate thetypical range of Environmental and Social risks encountered in Ethiopia. All these storeshave now been repackaged. Figure 6 below shows the EMTK's Site Characterization matrixfor these stores, where their pesticide risk factors have been benchmarked against theatypical site at Gode. All the sites in these regions fall outside the Critical quadrant, withpesticide risk factors between 0 and 25% and environmental risk factors between 30% and80%.

[SITE CHARACTERIZATIONI

- 0 50 100

FE

Figure 6 - Site Characterization matrix for Gamo Gofa, Sidama, and Wolaita, Dawro

and Konta zones

A typical site is characterized by the following:

Store constructed with corrugated iron walls and roof (in the main waterproof);The floor is often permeable;Store doors are generally lockable but without fences or lockable gates;Security is generally provided by the village guards;Storekeepers do not wear protective clothing;The stores are not inspected and managed regularly;There is no fire prevention equipment;Often other materials (e.g. fertilizer, seeds, sprayers, building materials, rubbish, etc.)are stored along with the pesticides;The pesticides are not stored properly as they should;

24

Last revised Ale following Bank l't comments received from the WB

* Generally soil contamination is not reported (the stores with soil contamination are to beprioritized in the later stages of Phase-Il);

* Generally located in or close to a human settlement;* The sites are generally long way from water courses (the sites in river valleys were

prioritized in Phase-I);* When located in a settlement, some are close to drinking water wells;* Often located near to cultivated land or animal husbandry;* There are no stores inside national park/s.

The photographs that follow show three stores from the Gemu Gofa zone: Arba Minch(highest Fp), Masta (highest Fe) and Beto (a typical store):

Picture I - Zonal Store No. 735

Arba Minch Zonal store has sound external construction but is poorly managed and is poorlysited close to a human settlement. It had large stocks which gave it the highest Fp for thezone.

ATq

4.

,.-l

Picture 2-Masta Delapidated store No 771 -

Masta store (the overgrown construction on the left of the photograph) was completelydilapidated and so scored the highest environmental risk factor in the zone. Its smallquantity of pesticide materials were in appalling condition which gave it a similar Fp to theother stores in the zone.

25

Last revised Ale following Bank 1i' comments received from the WB

;.

h -w"T"~ -7

Picture MoARD store No. 769

Beto store is typical of most stores that are found throughout Ethiopia. The building issound with a waterproof roof. It contains a small quantity of pesticides, along with othermaterials, equipment and rubbish. The store is not managed.

The potential impacts of these stores are generally temporary. Once the pesticides havebeen repackaged and removed to the MCC, the environmental and social risks reducesignificantly. The only cases in which the risks remain are where:

A poorly located store continues to be used for the storage of pesticides; or. There is soil or groundwater contamination. It is planned that sites with soil and

groundwater contamination will be addressed under the ASP project.

3.2.1 Review of impacts to soil, water, air, human health, and biotaThe major environmental risks to the project are identified in Table-9 below

Table 9- Risks and impacts

PotentialRisk Media Scale of Potential for Permanence

ImpactSpillage or release Soilduring repackaging water high Contamination can be containeddustringe arand decontaminatedor storage a Health

Water The pollution will disperse, butFire during storage Airor repackaging Soil high will leave a high concentration

Human health close to the site of the fire.

Spillage or release AirSping or Water high Contamination can be containeddringpro Soil and decontaminatedtransport BiotaSpillage or release Water high Marine salvage could recoverduring sea transport water_high _sunk containersRelease during water medium permanent

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Last revised Ale following Bank 1" comments received from the WB

3.3 Criteria for Distinguishing Atypical from Typical SitesAn atypical site is one that represents a significantly higher risk than the typical stores andwill have some of the following characteristics:

* large quantity of leaking pesticides;* located close to human settlement or public buildings;& contamination that threatens ground water or water sources.

As already mentioned in the preceding paragraphs, the only atypical sites identified so far inPhase-l1 are the MoARD sites in Gode, and Abobo both of which have large quantities ofleaking containers. These sites are close to human habitation. These sites were notaddressed in Phase-I because security considerations prohibited access.

The methodology for determining whether a site is atypical involves two steps.

Step IReview the condition of the site. If it requires human resettlement, or the desisting ofagricultural or other activities on or adjacent to the site, i.e. it triggers any one of the WorldBank's policies on involuntary resettlement or land acquisition), the site is immediatelydeemed to be atypical. If Step 1 does not deem the site to be atypical, it is necessary to ^proceed to Step 2 to determine whether the quantity and condition of the pesticides and the jcondition of the site make the site atypical.

Examples of when a Step 1 review would deem a site to be atypical include:

* cases where people were living in the store building* contaminated land was being used for agricultural activities, school playgrounds, etc* the only water source in a village was contaminated, and no alternative water was

available

Step 2Use FAO's EMTK methodology to undertake a comparative risk assessment of the site(s)using the atypical site at Gode as a benchmark. The Gode site is the site with the highestrisk due to its pesticides. The pesticides risk factor Fp for Gode is 1,500,000. Themethodology plots Fp* (the normalised such that the Fp* of the site with the highest Fp is100%) and Fe for the site(s) in question and that of Gode onto the site characterizationmatrix. Any site that falls within the critical quadrant is deemed atypical.

A atypical site will have an environmental risk factor (Fe) greater than 50% and a pesticiderisk factor (Fp) greater than half that of the Gode site

An example of the stores in Gemu Gofa benchmarked to identify atypical sites is shown ascan be seen in the matrix the only critical site is the benchmark site, Gode. Therefore, inGamo Gofa, no atypical sites have been identified on the basis of benchmarking in Step 2.

2,

27

Last revised Ale following Bank 1 st comments received from the WB

| Site Characterization

Figure 7a - Gamo Gofa stores benchmarked to Identify atypical

If a site is not deemed to be atypical in both step 1 and step 2, then illis considered to be atypical site

Gode

Arba MinchiBeto

Figure 7b - Three stores relative benchmarks in relation to Gode which is atypical store

28

Last revised Ale following Bank 1" comments received from the WB

3.3.1 Institutional responsibilities for identifying atypical and typical sitesIt is the responsibility of the PMT to classify each site as typical or atypical. The FieldManagers at the time of undertaking the verification activities and the Environmental RiskAssessment (ERA) should use the methodology above to assess the sites. Where theyconsider a site should be classified as atypical, the NPM should be informed and it is he thatmakes the decision. The NPM should also review the ERA information to ensure that theFMs have identified all atypical sites. Once a site has been deemed as atypical the FAOTSU, MoARD, the EPA and the regional Administration are informed and the processesdetailed in section 7 should be Initiated. ¶

3.4 Quality and training of staff/ workersThe current PMT and operational staff have been in place throughout Phase-I and Phase-Il.During that time they have undergone extensive training both by FAO and the Contractors(Ekokem and Veolia). The training included:

Project management skillsInventory takingEnvironmental Risk Assessment

* Safeguarding and repackaging* Safe working practices* Use of personal protective equipment. Transport* First aid* Communications

Recommendation: When the project moves into its Phase-Il under the ASP and addressescontaminated equipment, contaminated containers and contaminated soils, new trainingprogrammes should be developed to cover the environmentally sound management of thesematerials.

All the operational staff members employed by Veolia have over 5-years experience in theinternational logistics and disposal of hazardous wastes. As an organization, the FieldServices Division of Veolia has over 15-years experience of obsolete pesticide projects indeveloping countries.

4 Review of Disposal Strategy to DateBest Practice for many aspects of obsolete pesticides management has been developingcontinuously during the lifetime of the Phase-I and Phase-Il projects. Much of FAO'sguidance has been honed as a result of the experiences of the Ethiopian projects. Wherebest practice has been refined and improved, attempts have been made to reintegrate it intothe Ethiopian projects.

VW

2 'i4

29

Last revised Ale following Bank ls comments received from the WB

4.1 Inventory development

4.1.1 2001 InventoryThe inventory in Ethiopia was developed in 2001 using FAO guidelines as they were at thetime. The inventory process captured information about the site, including its address,region, zone, condition, location, plan and its proximity to settlements and water sources.The pesticides and other contaminated materials were listed together with information ontheir active ingredient, formulation, concentration, type of packaging, condition of thepackaging, pesticide group, WHO classification. This information was stored and analysedin a spreadsheet.

This inventory data was sufficient for the project team to identify the high priority sites inPhase I. The criteria used for selecting priority sites were:

* Greater than 5 tonnes of leaking pesticidesLocated near human settlementLocated near to water courses or wells

* The inventory was effective as in the Inventoryverification process (see below) has not identified anynew high priority sites;

Assessment: . As detailed earlier some sites actually comprisedmore than one store, sometimes widely spread out.This is a flaw with a risk that individual stores aremissed with follow-up activities.

4.1.2 Verification of the Inventory data in Phase-l1The 2001 inventory data of each of the 705 sites is checked and updated so that it reflectsthe current situation. A team, which comprises a Field Manager, a representative of theCrop Protection Department of the Region, a representative of the EPA and arepresentative of CropLife, tours each region and inspects each of its sites. The FieldManager and the representative of CropLife agree the inventory and the materials that areattributable to CropLife member companies. The Field Manager updates the inventory inthe spreadsheet. Where multiple stores are found, the inventory is annotated to record theprecise number of stores, and which material is in each. However the data is still recordedunder the original single site number. A site plan is drawn showing all the stores at the site.During the observation of the verification activities for the preparation of this CESA, it wasnoted that a task based risk assessment (TBRA) was not routinely undertaken beforeentering a store.

The verification process has found only a 10% variance between the current inventory andthat of 2001.

30


. The pesticide information is properly recorded and insufficient detail to allow for accurate assessmentusing the EMTK;

Assessment: A task based risk assessment was not routinely doneAs n before entering a store;

* Reconciliation of the stocks with CropLife shouldavoid any disputes over CropLife's financialcontributions to the project.

. Reinforcement of the need to undertake task basedrisk assessments and use appropriate Personal

Rt Protective Equipment (PPE) for verification activities.Recom mendation: * The NPM to undertake quality control monitoring

visits to the operations in the field.. Establish an NGO monitoring programme.

4.1.3 Environmental Characteristics and other Store informationPart of the verification process includes the preparation of an environmental risk analysis ofthe store. The questionnaire used by the team is the current version set out in the EMTK.The scores from the questionnaire are recorded in a spreadsheet with the store information.Other information is gathered including: the Global Positioning System (GPS) co-ordinates;location and contact numbers of emergency services; the storage available for safeguardingequipment; and dimensions of store.

. Best practice (EMTK) is used to record theenvironmental characteristics of the store;

. Best practice is used in gathering other storeinformation

Assessment: . Where there are multiple stores with a single sitenumber in the 2001 inventory, only one of the storeshas a questionnaire completed. This is a failing. Forthe subsequent activities records will be needed forall stores and the field team took note of.

. At the repackaging stage, stores without their ownRecommendation: environmental characterisation and location details,

should be recorded on the proper inventory forms

4.1.4 Assessment of RoadsDetailed road maps of Ethiopia are not available and so currently are not also available tothe team. The team uses experienced driver knowledge, local knowledge in the form of theRegional Administration counterpart to find the location of the stores. The Field Managerprepares a topological map (see example in Annex F) showing the locations of the stores,indications of the distances between stores and the quality of the road. This is used to planthe logistics for the repackaging activities.

Assessment: * The topological maps are adequate for planningpurposes.

. Other international organisations have developedRecommendation: their own detailed maps of the country. It might be

good if the project obtains copies.

31


4.1.5 Verification CommunicationsIt is the responsibility of the Regional Administration counterpart in the verification team tomake the Woreda and Kebele administrations aware of the verification activities and thesafeguarding that will follow. The communication is normally done by phone. It is left to thelocal administration to make the local populace aware of the activities and the reasons forthem. A communications programme is also undertaken in advance of the safeguardingactivities, which is described in section 4.5.5.

* Communications with the local administration isAssessment: effective

. To ensure that the local administration communicateseffectively with the local populace, standardinformation sheets in the local language should alsobe distributed. The information sheet should explain

Recommendation: the reason for and nature of the activities beingundertaken, what will be happening to make the storesafe, and instructions for the local populace. Itshould also include a mechanism for the populace toprovide feedback in advance of any work beingundertaken.

4.2 Environmental AssessmentThe data gathered from the inventory is assessed to identify atypical sites using EMTK andthe methodology set out in section 3.3. If no atypical sites are found all the stores in thezone will be treated as an equal priority and repackaged on the basis of logistical efficiencyand minimised transport risk.

Assessment: | Environmental assessment uses best practicetechniques

4.3 Selection of Major Collection CentresThe MCCs were selected as part of the Phase-I project, when they were brought up to aspecification suitable for storing large quantities of pesticide. The stores were selected onthe basis of their access to main trunk road systems, their low environmental risk and theirproximity to concentrations of obsolete pesticides stocks. The stores were independentlyassessed by PANUK during Phase-I, using the principles of the Ethiopian Environmentalimpact Assessment proclamation.

|Assessment: Best practice was used in selecting the MCCs

4.4 Prioritization StrategyThe verification process has identified that there is a close correspondence between thecurrent and the 2001 inventories (only a 10% variance). This underlines the justification forusing the 2001 inventory information as the basis for prioritizing the order in which sites arerepacked. The characterization of the sites in section 3.2 also confirms that the sites posebroadly similar environmental risks. This supports the justification for prioritizing therepackaging activities to minimise the distance that pesticides are transported. Thistranslated into a geographic based strategy, where the country was divided up into 8 areasbased on logistics to the 8 MCCs.

The order in which the areas were planned to be repacked is shown below:

32


No Area / MCC Status 31 st March

1 Addis / Arsi Cleaned up repackaged

2 Nekemte / Benishangul- C p a2 Gumuz Cleaned up repackaged

3 Awassa Cleaned up repackaged

4 Jimma Cleaned up repackaged

Abobo in Gambella RegionAtypcal iteCleaned up repackaged

___Atypical siteGambella Town inGambella Region Cleaned up repackaged

Verified and close to finalization of5 Mekele cleaning up and repackaging

Being verified and already leaking stocks6 Bahr Dar in one store repackaged

7 Kombolcha Cleaned up repackagednot started (Gode) Security situation need

8 Dire Dawa to be assessed and so will have to beIdelayed till June 2007

Addis / Arsi area was chosen as the first area to cleaning up and repackaging because itwas most proximate to the project office and allowed the NPM and IC to provide the fieldteams a high level of support and supervision, while they gained experience and confidence.

The geographic prioritization strategy minimises theAssss t I environmental risks of the project.

4.5 Planning for Repackaging

4.5.1 Repackaging equipmentThe Field Managers review the verified inventory to identify which materials can bepackaged together. On the basis of this they identify the equipment that will be required torepackage each of the stores. They identify the precise and number of each type of UNapproved drums for each packaging group. They also plan sufficient drums forcontingencies. The other equipment includes amongst other things: salvage drums, tools,protective clothing, pumps, and plastic sheeting for preparing and constructing to ensuresafe working areas. The standard of equipment confirms to guidance provided by FAO.However, as was noted during the visit to the repackaging activities in Jimma, someessential equipment (spill kits, fire extinguishers, first aid kits and temporary fencing) wasmissing owing to late arrival from the central store/s at the Gottera MCC in Addis Ababa.

33 '

Last revised Ale following Bank ls comments received from the WB

. The planning for the repackaging equipment wasAssessment: adequate, however although planning the emergency

response equipment should have arrived on siteconcerned way in advance.

* The checklists should be reviewed to ensure allRa required emergency response equipment is included

Recommendation . The NPM should monitor the planning for therepackaging in a more frequent manner.

4.5.2 Transport plan for repackagingTransport represents the highest risk activity in the whole project but fortunately none wereencountered since Phase-I Project except a minor truck accident which quickly addressed.

The field managers review the inventory and plans of cargos based on the hazardousproperty of the pesticides. This ensures that compatible cargos can be loaded andtransported all together in one vehicle. They plan the route on the basis of the mapprepared in the verification stage. They use strictly the guidelines in Tool F of the EMTK toselect the most direct route presenting the lowest risk. They give consideration to avoidingareas of high environmental sensitivity such as high population density, national parks,schools etc. Where road conditions are very bad, rough and tumble, they may select alonger but safer route.

They select the appropriate vehicles for loading and transporting the cargos, the operatorsand support staff (including a nurse in the case of an injury). The convoy includes an escortvehicle which should contain emergency response equipment in the case of an accident orspillage. The vehicles were not however fitted with spill trays. Spill trays are recommendedas an additional precautionary containment measure in the event of a drum leaking duringtransport.

Assessment: . The strict transport planning conforms to FAOguidelines

a All vehicles used to transport pesticides should beRecommendation fifted with a spill tray if longer road distance is

I covered.

4.5.3 Repackaging plan-On the basis of the conditions of the store, the quantity of materials to be repackaged andthe distances to be travelled, the field Manager prepares a detailed plan for repacking all thestores in the zone.

Assessment: g ood project management practice is used

4.5.4 NotificationPrior to the repackaging and transportation the Regional Environmental Authority is notifiedof the proposed movement in compliance with the Environmental Pollution Controlproclamation 300/2002. Members of the Zonal authorities also accompany the repackagingteams.

I Assessment: | Legal obligations are discharged adequately

4.5.5 CommunicationsThe Regional counterparts write to the Zonal authorities to explain what activities will beundertaken in their zone. The Zonal counterparts forward the message to the Weeds whothen communicate to the Kebele.

The Zonal counterpart staff informs the police, fire service and local hospital of the activitiesbeing undertaken.

34

Last revised Ale following Bank IS" comments received from the WB

The Zonal counterpart staff, that is assigned to the repackaging team, communicatesverbally to the community leaders at the Kebele and the local police to inform them aboutthe repackaging. They explain the activity and that the pesticides are no longer usable andare dangerous to human health. They ask the community leader to keep the local populaceaway from the store. If there are houses nearby, the residents are instructed to vacate theirhouses and leave their windows and doors closed. For typical sites, the local populace areallowed to return to their buildings in the evenings and without restriction at the conclusion ofthe repacking activities (which normally takes no more than 2 days). Warning tape withhazard signs are put up around the each and every working site.

Assessment: * Official communications are undertaken. The verbal communication to the community leader

should be reinforced with a written document (in thelocal languages) explaining the activity and giving

Recommendation instructions to the local populace. Thecommunication should also be suitable for use as anotice. A proposed template for the communication -is included as Annex-G.

. The warning signs should be in the local language

4.6 RepackagingThe Field Team constructs a safe working area and excludes access to the site forunauthorised persons. The site is zoned according to the Field Application Manual (FAM)endorsed by the Secretariat to the Basel Convention. The FM undertakes a Task BasedRisk Assessment of the repackaging activities to determine the appropriate workingmethods and appropriate protective equipment. The FM briefs the team and workprogresses. The FM supervises the activities at the site.

For using PPEs, FAO guidelines are observed, including for the teams pumping liquids,liquid proof type 3 overalls. These should always be used in such cases and not type 4.

Working areas are set up. Where activities such as pumping liquids is taking place the flooris covered with an impermeable membrane spread over plywood to avoid leaks and spillcontaminating the floor.

The repackaging activities start with the high risk items, i.e. WHO class IA and leakingmaterials. The liquid materials are repackaged into close head 200 litre drums and thesolids into open head 200 litre drums. All drums are UN certified. In cases where therepackaging will be done at the MCC (e.g. for partly filled drums that cannot beconsolidated), the drum concerned is placed inside a salvage drum to make it safe fortransportation. The exterior of the drums is wiped clean before it leaves the store to be puton the vehicle. The team writes on each drum its unique number and its contents. Duringthe review of repackaging activities at Jimma, it was noted that the drum pump did not havean exit valve, and the teams did not have an earthing strap just for that site to electricallyearth the drums to prevent electrostatic sparks. The team did not have a spill kit or a drumvacuum cleaner but was made clear that it would make available from the MCC which snearby if the need arises for using one. This equipment is available at the central store inGottera.

The repackaging work is hot, humid and arduous, so there is a danger of heat exhaustionand dehydration. The team takes breaks every hour in order to cool off and take in morefluids to avoid the risk of dehydration. There is always a member of the team in protectiveclothing outside the working area who can enter the store in the event of an emergency oraccident. The team includes a nurse who is available to deal with injuries and illness.

At the completion of the repackaging the FM completes a document transferring theownership of the pesticides from the Zonal authorities to the project. The drums are loadedonto the vehicles using the on-board cranes.

35 L


. Repackaging activities strictly conformed to FAOstandards.

Assessment: . There were however a few minor non-conformancesthat were brought to the attention of the FM, who hasimmediately undertaken to remedy the matters.

. NPM to regularly undertake unannounced audits ofRecommendation each of the project activities.

. Establish an NGO monitoring programme.

4.7 Transport from store to MCCA transport log is prepared which details the drums in the consignment. The drums aretransported to the MCC with an escort vehicle. The route is that determined during theverification activities. The convoy does not exceed 40km/hr, the legal maximum forhazardous materials, and where road conditions are poor the speed is much lower.

However the guidance in the EMTK is currently not being followed as follows:

* The vehicles transporting drums of liquids do not have a spill tray fifted;The vehicles do not carry a first aid kit but was quickly addressed.

* The escort vehicle doesn't always carry emergency response fire extinguishersAll this equipment is available in the project's central store in Addis Ababa and limited onesare carried to operation sites, and needs to be deployed. The NPM has undertaken to makeavailable these items during the 3rd week of April 2006.

* There have not been any accidents either Phase-I orduring Phase-l1

Assessment: * The transport was not often compliant with FAOguidelines, but steps were taken to become sofollowing this CESA mission.

. NPM to regularly undertake unannounced audits ofRecommendation the transport activities to ensure that the emergency

response equipment is deployed appropriately.. Establish an NGO monitoring programme

4.8 Management of MCCsThe drums are checked in and added to the stock list for the MCC. Where there are partlyfilled drums, they are consolidated with identical pesticides or compatible materials. When adrum is finalised, it is weighed and its weight written on the drum and the stock list. Thedrums are segregated into pesticide types and solids and liquids, and stored in doublestacked rows 2 drums deep.

Unknown materials are segregated awaiting analysis.

The store keeper maintains a record of the current stock, both in terms of a list of drums butalso a pictorial layout of the segregated groups of drums inside the store.

At the Jimma MCC the store keeper is not always present but the guard did not have arecord of the stocks. The fire service had been informed of the nature of the store but noemergency plan had been drawn up in case of a fire or an accident. There was only one9kg fire extinguisher. There was not a spill kit. Sawdust mixed with lime was being used asa packing medium for small packages rather than Micafil as specified in the Veolia contract.Electrical wiring within the store had been repaired inappropriately.

36


The management of the MCC strictly conformed toFAO guidelines except for the lack of emergency andpackaging equipment. This will become compliantfollowing this CESA mission.

. NPM to regularly undertake unannounced audits toensure that management of the MCCs are not slack.

Recommendation . Establish an NGO monitoring programme. Agree an emergency plan with the fire and police

services in the case of an accident or fire.

4.9 Contractor activities at MCCsThe contractor labels the drums according the requirements of the IMDG, with its propershipping name, UN number and hazard classification.

Empty shipping containers are consigned to the MCCs. Those that are to be used fortransporting drums of liquids have a metal spill tray constructed within the container. Thespill trays in the shipping containers observed at the Gottera MCC in Addis Ababa had beenfilled with sawdust rather than chemical absorbent granules. The sawdust being flammablemight presents a potential fire hazard and needs to be avoided. Veolia were notified of thisnon-conformance and they have undertaken to remove the sawdust and replace it withgranules before shipment.

The contractor stows the containers with appropriate and compatible drums from the MCC.The shipping containers are weighed and sealed. The contractor prepares a packing list foreach shipping container.

The contactor notifies the PMT of the shipping container numbers and weights and the dateof the arrival of the vessel at the Port of Djibouti, to enable the PMT to initiate the specialprocess for authorisation to transit Djibouti.

Assessment: , IMDG standards are strictly observed

4.10 Transport from MCC to Djibouti portInternational shipment cannot commence until all the authorisations have been received forthe transboundary movement of hazardous waste under the Basel Convention (see section2.1.1) and the formal 10 days notice has been provided to the Government of Djibouti. Thetransport has to be organised such that the arrival of the containers to the dock coincideswith the docking of the vessel so that the containers can be loaded directly onto the vessel(a requirement of the Govemment of Djibouti). This is the result of unnecessary restrictionsimposed by the Environmental Protection Authority of Djibouti and so the transport time fromthe Ethiopia-Djibouti border to the port remains inconvenient. Therefore negotiations at theGovemment level should be pursued for the Djibouti Authorities to provide a dedicated sitefor keeping hazardous wastes as often is the case in all orts at least for few days beforeloading waste on ship thus avoiding rushing to the port from the border each time shipsdock at the port.

The Shipping Containers are loaded onto vehicles and transported to the Ethiopia-Djiboutiborder with an escort provided by the project team and the police. From Djibouti to thedock, the escort is provided by the shipping company and the Djibouti police. Once thevehicles arrive at the dock the containers are loaded directly on board the vessel which thenproceeds with its route.

The consignment is accompanied by its Transboundary movement tracking form, packinglist for each container, IMDG dangerous goods declaration, and list of transit countries

37


. FAO guidelines on transport are observedAssessment: . Transport is compliant with the Basel Convention and

IMDG. The additional requirements imposed by the

Government of Djibouti, are over and above thosestipulated in the Basel Convention. They significantly

Recommendation increase the administrative burden and transportcosts of the project. The Secretariat of the BaselConvention should be consulted to facilitate therelaxation of these additional req uirements.

4.11 Sea TransportationThe sea transportation is organised through the shipping agent, Warrant Logistics ofFelixstowe, UK. The shipping line is Maersk Sealand whose vessel has the following route:

To Felixstowe UK To Bremerhaven, Germany

Port Country/ Authorisation Port Country/ Authorisation

Djibouti Djibouti Djibouti Djibouti

Jeddah Saudi Arabia Jeddah Saudi ArabiaJeddah (transhipped) (transhipped)

Aden Yemen Aden Yemen

Salalah, Oman Salalah, Oman

Via Suez Canal Egypt Via Suez Canal Egypt

Gioia Tauro Italy (ITOO) Gioia Tauro Italy (ITOO)

Algercieras Spain (ESOO)Spain___ESOO__Transhipped

Algercieras Transhipped Felixstowe UK (G BOO)

Bremerhaven Germany (GEOO)Transhipped

Both routes require the shipping containers to be transhipped multiple times. Thetranshipment process can pose a risk of damage to the contents of the shipping container ifit is not handled both correctly and appropriately. Unfortunately the number of shipping linesthat accept waste as cargo is very limited so there are few alternative routes. These routesare the shortest to the UK and Germany. The containers and drums are designed towithstand the rigorous conditions of sea transport.

Assessment: . Sea shipment conforms to all appropriate standardsand particularly that of the Basel Convention andIMDG.

4.12 Arrival and Transport in UK or GermanyThe containers are offloaded at the dock and loaded onto a transport vehicle andtransported to the disposal site. The transport within Europe is not accompanied by anescort vehicle. All normal EU transport regulations apply and therefore strictly followed.

38

Last revised Ale following Bank 1 't comments received from the WB

Assessment: As the UK and German roads are of a high standardit is not necessary for the containers to be escorted.

4.13 Disposal StrategyAt the outset of the Phase-I a review of the legal framework in Ethiopia identified thathazardous wastes had to be disposed of in a manner that did not harm the environment orpublic health. No detailed Ethiopian guidance is currently available on acceptable disposalstandards for disposal of pesticides. In this case FAO guidance stipulates the use ofrecognised international standards such as the EU hazardous waste directive/s and wasteincineration directives. After a review of alternatives (see section 5) did not find a suitablelocal option, the decision was made that exporting the waste for high temperatureincineration was the only available course of action. FAO disposal guidelines identify hightemperature incineration as the only currently available and economically feasible solutionfor the disposal of high concentration pesticide wastes.

4.13.1 Selection of the ContractorThe selection of the contractor was done by means of an international tender organisedunder FAO procurement rules. The Ethiopian PMT reviewed the technical and financial bidsof each of the tenderers by liaising with FAO and selected Veolia as the contractor. Thecontract was placed using FAO procurement rules.

A . FAO procurement rules were observed.Assessment:I I The contract is drawn up appropriately

4.14 Disposal OperationsThe disposal operations of both high temperature incinerators are closely regulated by thelocal environmental authorities. The consignments have to be incinerated within 180 daysof their arrival at the site.

* Incineration is currently best practice for pesticides.. The two incinerators nominated by the Contractor are

fully authorised to destroy pesticidesAssessment: * No incidents have been reported relating to the

disposal of the pesticides from Ethiopia both duringPhase-I and for whatever quantities have so farshipped during Phase-Il.

5 Analysis of AlternativesThe following alternatives were considered and deemed inappropriate.

5.1 Do nothingThe first alternative is to do nothing and to leave the obsolete pesticides in the stores wherethey are located. This alternative was dismissed on the basis that the environmentalimpairment and impact on public health would worsen as the containers degraded andleaked, causing wide spread soil and ground water contamination.

39

Last revised Ale following Bank Is comments received from the WB

5.2 Repackage and stockpile indefinitely at a central locationIt is possible to repackage the pesticides and remove them from their current locations to bestored indefinitely at a central stockpile (i.e. without disposal being undertaken). Thisalternative removes the risks of environmental and health impacts in the current store orlocations around the country but extended storage will again cause deterioration of the newcontainers and leakage would occur and thus causing contamination of the environment atthe new site and thus nullifying the exercise and the effort of repackaging and relocatingthem at alternative locations or stores elsewhere.

However the materials and new containers would continue to degrade even in a wellmanaged and designed central stockpile. The materials would have to be repackagedregularly to avoid the risk of leakage. The site of the central store would represent a majoraccident hazard risk in the event of a fire. Locating such a central store would be fraughtwith legal, community and political problems. Eventually a final solution to their disposalwould have to be sought.

5.3 Cement Kiln DisposalCement kilns are a recognised technology for the disposal of hazardous wastes in Europe,the US and other parts of the world but using extraordinary additional gadgets andadvanced technical innovations and using constant and reliable control measures to avoidemissions of dangerous fumes or pollutants into the atmosphere. This is because cementkilns require significant modification to be able to destroy hazardous waste, particularly inthe case of solid hazardous waste. The operating regime has to be finely controlled toensure that the wastes are destroyed appropriately. A number of unsuccessful attemptswere made in the past to modify cement kilns in Africa for the disposal of pesticides(Tanzania and Mozambique) but never worked or the civic the society. NGOs, etc. severelyprotested and blocked or averted the proposal for use of cement kilns. .

As part of the Task Force Mission in December 1998, the Mugher Cement Factory wasreviewed for suitability for destroying waste. Although the kiln could have potentially beenadaptable to burn liquid pesticides, the conclusion of the Mission report was that hightemperature incineration was the only appropriate option for the relatively small quantity ofmaterials requiring disposal and at the same time the Government was not favourable tousing kilns,

If, in the future, the Government of Ethiopia determines that there is a strategic need for ahazardous waste disposal facility within the country, and seek ways to modify and adapt theMugher Cement Factory for the purpose of destroying hazardous wastes, the option to usethis cement kiln for pesticide disposal should be thoroughly and carefully studied andreviewed not to face similar civic outrages that took place in Mozambique a few years ago.

5.4 Rail TransportationThere is a railway line from Addis Ababa to Djibouti. Statistically transportation accidentsare less likely to occur during transportation by rail than by road.

However to use the existing railway line increases the number of times the shippingcontainers would have to be loaded and offloaded onto vehicles. The movement from theMCC to the Addis Ababa railhead and the movement from Djibouti to the ship would stillhave to be made by road. This would require two additional transhipments by cranebetween railway and vehicle. The reduced risk of accident by rail is offset by the increasedrisk of accident during the additional crane movements.

Additional safeguards have been put in place to ensure the safety of the road transport,such as the police escort and the speed restriction to 40km/hr.

40


In addition, the requirement for the containers to be monitored and escorted during theirmovement in Ethiopia and Djibouti is more complex by rail. In conclusion the road transportoption is the better option.

6 Typical sites

6.1 Environmental Mitigation Plan for typical sitesThe guiding principle for the Environmental Mitigation Plan (EMP) in Phase-Il is FAO'sEMTK. The EMTK has been referred to at length in section 3 where its tools namely A, Band C are used to identify atypical sites. The detailed implementation plan for Phase-Il hasbeen set out in the Section 4, the review and critical assessment of the disposal strategy.This section details the preventive and mitigation measures that are and need to be put inplace to address the potential environmental and social impacts identified in section 3.2.1.

41


Activity Impact Preventive Measure Mitigation* There is a first aid kit in the vehicle;

Before entering the store for verification, the FM * The verification team has identified theshould review the 2001 inventory, and, from nearest hospital or clinic and notified them of

Health of operators due outside, review the actual condition of the interior their activities;to contact with of the store. Then undertake a Task Based Risk * Project staff members have medical checks

Verification pesticides Assessment to determine the appropriate every 6 months, including blood tests toPersonnel Protective Equipment required determine if there are adverse impacts fromundertaking the verification, working with pesticides. Where impacts are

found, the operators are assigned to activities-__ -that do not involve contact with pesticides.

Public Health * The public are informed about the verificationactivity and instructed to stay away from the store.

* the FM undertakes a Task Based RiskAssessment of the hazards of materials that willbe repackaged and the nature of the repackaging * Regular medical checks;activity. This determines the type of Personal

Health of operators due Protective Equipment required * Emergency shower set up at the site.Repackaging to contact with * The specification of repackaging equipment, such * Full-time presence of project nurse

pesticides as drum pumps, has been selected such that it * The nearest hospital or clinic has beenminimises the necessity for contact with identified and notified about the project team'spesticides activities in each given area, zone or location/s

* The exterior of the drums is wiped clean beforethey are taken from the store.

* The local populace are usually informed toevacuate the immediate area around the storewhile work is going on. For a typical store thesafeguarding activities are generally concludedwithin 2 days. The populace is allowed to return

Health of local to their dwellings during the night when there arepopulace no site activities and when risks are unlikely to

occur.* The site zoned off with fencing, hazard tape and

warning signs.* Doors and windows of the store are covered to

prevent the egress of dust and vapour.

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Activity Impact Preventive Measure Mitigation* All electrical and other equipment used inside the * The fire service is notified about the activities

store is flameproof; taking place at the site so they are in a state of* Where possible flammable materials are preparedness;

Release to air through excluded from the store; * Fire extinguishing equipment is part of thea fire * Incompatible materials are not mixed together. emergency response kit carried by the team

They are either completely separated or * Appropriate and recommended substancessegregated and where necessary adequate fire are made available for extinguishing givenand physical barriers are erected between chemicals in case of fire outbreaks.dangerous chemicals.

* The areas where liquids are repacked areprotected with plastic and plywood sheeting;

* Pumping equipment is controllable directly by theoperators filling the drums; * Where spills occur, the team carries

Spillage contaminates * The pumps have foot-valves to avoid leakage as emergency spill kits which include absorbentsoil and ground water the pump is transferred to a new drum; materials and sand snakes to stop spills

* The new drums are specified to UN standards for spreading.Repackaging the materials to be pumped into them.

* The floors are cleaned by sweeping and/orvacuuming.

* The door ways and windows are covered withplastic sheeting to keep the dust and fumes within

Release to air the store ensuring adequate ventilation away fromthe public to avoid accidental explosion;

* Dust suppression techniques are used.* The drums are specified for intemational

transport;* Drums to be repackaged and consolidated at the

MCC are placed in salvage over-drums;Transportation by Spillage to soil, water * The vehicles should be lined with a spill tray to * The escort vehicles carry emergency spill kitsroad to MCC due to an accident catch any leaks; in the event of an accident.

* The transport route has been assessed andselected as the safest and most direct;

* The maximum speed of the vehicles is set to40km/hr.

43

Last revised Ale following Bank 1 st comments received from the WB

Activity Impact Preventive Measure Mitigation* The MCC stores have been selected on the basis

Spillage to soil and of their specification which includes impervious * Spill kits are made available at MCCs.groundwater floors and their proximity to all necessary safety

outlets.* The fire service is notified of the dangers of

the store;Storage at MCC * The storage of drums within an MCC is * The fire service should develop an evacuation

Release to air due to a segregated according the types and hazards of plan for the area around the MCC;Fire - materials - Incompatible materials should be * The store keeper maintains records of the

segregated; positions and contents of each drum within the* Electrical wiring should be intrinsically safe. store;

* Adequate number of fire extinguishers shouldbe available at the MCC.

* The shipping containers for drums of liquid areSpillage or accident lined with a steel spill tray to contain any leaks; * The convoy of containers is escorted by

Transportation to leads to soil, * each containers is stowed with compatible The ovo o ners iesorte byDjibouti groundwater materials; vehicles with emergency response spill

contamination * Stowage of materials within the shipping equipment and police vehicles.-_ containers strictly conforms to IMDG standards.

Transportation by Sea Containers or whole * The stowage of drums within the container is * Marine salvage would be required to rescueship sinks such that the materials should not leak. the containers.

* The incineration facilities are equipped with stateof the art pollution abatement technology;

Emissions to * The emissions are analysed to conform that they * Facilities have action and evacuation plans toDisposal atmosphere, water and meet specification; conform to the EU Seveso directive.

soil * The facilities have fail-safe emergency shutdownprocedures to stop waste buming if a seriousfailure in the process occurs.

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6.2 Monitoring Plan for typical sites

Environmental Management Plans

Environmental Management Plans (EMP) is undertaken with an aim to maximize basiccompliance of rules and guidelines in use and to minimize harm to the environment andhuman health. The level of detail and length of the EMP may vary depending on the seriousof contamination, intensity and extent of contamination and the likely risk of complexity andso basic understanding of environmental responsibilities are in the frontline of fieldoperations. Therefore, at the outset of each specific operation the list of relevant operationactivities draw guidance from pertinent compliance directives such as the following but without being limited to:

. Policy

.Planning

Implementation and operation

Checking and corrective action

Management review and commitment to improvement

Each of these five points has specific areas that need to be paid attention to such as forexample on policy issues the following are relevant.

4 Compliance in view of legal requirements with regard to both local and internationalrequirements and/or commitments.

Minimizing waste and preventing pollution at every level of field activities including instores and on the roads.

Continual improvement in performance aimed at protecting the environmental,particularly work areas, staff handling hazardous substances, the community, etc.

* Sharing information on environmental performance with the community.

On the other hand the planning aspect of the EMP is done with an intention not to contradictthe requirements of the basic environmental footprint and to ensure every operation aspectpossible to achieve the intended environmental goals/objectives of the project with theintention to maximize and ensure positive impact on the environment.

As is repeatedly mentioned and indicated the Environmental Management Plan and themethodologies followed strictly depends on the unique guidelines and strategies of the FAOEnvironmental Management Tool Kit at the field level. The FAO toolkit of course aims toeliminate the subjective component in risk assessment as far as possible and propose andprovide a format which will ensure reliable and reproducible results and hazard managementprocedures whoever is responsible in carrying out given field or store activities or trained toundertake and completes given field work related to cleaning up, repackaging andtransportation of obsolete stocks. The toolkit is extensive and well elaborated guidelinesrunning to about 70 pages taking into consideration the various possible worst casescenarios that might likely be encountered while undertaking field operations involvinghazardous materials.

45

45

,,

Last revised Ale following Bank is' comments received from the WB

When the EMTK was developed a variety of significant levels of inputs were taken intoconsideration involving various specialist consultants and organizations such as the GermanTechnical group with fundamental experience in obsolete stocks management, the CropLifeInternational (CLI), individuals, the FAO's wealth of experience, and a variety of nationalexperts from country project management teams. All these were actively involved over anextended period during testing, perfecting and in completing the EMTK in the managementof disposal process of obsolete pesticides. Therefore the FAO EMTK was built up based onreal situations and wherever obsolete pesticides existed in whatever form or conditions. Thistherefore makes the EMP the only and perhaps the best management tool under fieldconditions dedicated to obsolete pesticides which the CESA for ASP-P1 would and shouldrely on with full confidence.

In each and every case monitoring is undertaken by members of the project team involving(the Field Managers (FMs), National Project Manager (NPM), and International TechnicalAdvisor or Consultant (TAs,), other government agencies (e.g. the Environmental ProtectionAuthority of Ethiopia (EPA) and Regional Authorities operating out of the Regional Bureausof Agriculture and EPA representatives based in various regions and localities) and FAOTechnical Support Missions monitoring and simultaneously providing backstopping advicesand follow up from the FAO Headquarters, etc.

6.2.1 Project Team Monitoring

6.2.1.1 Field ManagersThe day to day monitoring of the field activities is undertaken by the FMs. A variety ofstandard forms to communicate and monitor activities which among others include the list ofthe following and each of which are maintained in the database within the project office andfiles and electronically both for reference, follow-up and auditing. Forms and detailsconcerning

Daily BriefingsProject check listsDaily Progress ReportsWeekly Progress Reports

* Work PlansThe blank forms for these documents are included in Annex 3 of the Operational Manuai forPhase-Il, prepared by the PMT in November 2003 and are summarised below.

Daily BriefingsThe field managers provide daily briefings to the operational staff in the field. Thesebriefings include the principle activity for the day, a review of progress, Task Based RiskAssessment, and PPE requirements and issues that need addressing.

Project Check listsThe field managers have a project check list to ensure that all items are in place toundertake the day to day activities safely. The list includes sections on:

documentation required;Working area;Worker training;Daily briefing given to Regional Administration, counterparts, hired labourers, drivers;PPE (correct use) by counterparts, hired labourers, and visitors;Storekeeper (on time, co-operative);Variations to work plan;Packages and labelling;

46


* Health monitoring.

Daily Progress Report

* List of project staff;* Planned activity for the day;* Actual activity undertaken;

Weekly Progress Report

* Principle tasks undertaken;* Progress against work plan;* Safety issues;a Update risk assessment;a Variation;* Instnuctions issued;* Operations planned f or the following week.

Work Plans

Weekly plan with detail for each day;Zone work plan with summary detail. -

Forms and details related to each of the activities are given in Annex-K of this document toshow a better picture of what is going on in addition to the above generic type of listing.

6.2.1.2 NPM and IC MonitoringThe NPM and IC undertake regular visits to the field to observe the teams' activities.

. The frequency of these observation missions shouldbe increased so that each team is observed as often

Recommendation: as necessary. The observations should be unannounced to ensure

that normal behaviour is observed '

The NPM also monitors the effectiveness of the Contactor.

6.2.2 EPA and Regional AuthoritiesOften the EPA and the Regional Authorities are present on site with project teams andmonitor their performance. In the case of verification activities the EPA and RegionalAuthorities actively participate in the verification processes and the compilation of inventorydata. This potentially compromises their roles as being independent but unfortunately ateam work is necessary as long as transparency of work ethic is maintained. .

47


Monitoring by the regulatory authorities should beundertaken by a Government entity that is bothcompetent in waste, environmental matters,

Recommendation: occupational health and transport; and is not directlyinvolved in the project. It is possible that bywithdrawing from the participation in the datagathering, the EPA would be the appropriategovernment monitor.

6.2.3 ContractorThe contractor observes the performance of the team working at the field level and theMCCs and reviews the quality of the process from time to time of cleaning up andrepackaging of drums. At the end of one of the recent audit visits by the representative ofthe Waste Management Company Veolia, the representative concerned expressed fullappreciation, confidence and satisfaction by the field activities undertaken at the local level.

6.2.4 FAO Technical SupportThe FAO Technical Support team undertakes regular missions to Ethiopia at least twice peryear and the missions include visits to the field to observe the project teams at work and tomonitor the activities of the contractor.

6.2.5 NGO MonitoringThere is no formal arrangement for an NGO to monitor the project activities and to interfacewith civil society. The only monitoring is that done officially by the national and localgovernment agencies, the team itself and international agencies. This is a weakness whichis beyond the capacity of the project team which is mainly a result of the Government policyparticularly in involving NGOs. It has been confirmed that the GoE has no objection to anNGO monitor but current protocols prevent it from using project funds to pay for it. Thismeans that members of the association of NGOs would have to find their own means offunding.

. A funding mechanism should be established toRecommendation: finance an NGO to monitor the project, particularly

Rt the communications and safety issues with thepublic. Possible options are discussed in section 9.2

7 Atypical sitesThere are two definite atypical sites at Gode, Somali region and at Abobo in Gambella.Both these sites were inaccessible during Phase-I owing to security considerations.Verification, cleaning up and repackaging in the Gambella was successfully completedrecently. Likewise, missions are planned to Gode in June to assess the site and latestsituation concerning product and store conditions. The MoH site is also a possible thirdatypical site but cannot be addressed within the current contract because it is outside thefinancial scope. It is planned to be addressed during the ASP. If the MoH is able to attractsufficient funds independently the project team will be able to address it sooner.

48


7.1 Environmental Mitigation Plan for atypical sitesThe process that the PMT is using to address all sites, whether typical or atypical, conformsto international standards. There is a single high standard for the environmental mitigationplans for each site. As such, there is no need for a separate guidelines or higher standardfor the management of atypical sites. However, because an atypical site represents a muchhigher risk or could perhaps involve involuntary resettlement or land acquisition, thedevelopment of the EMP requires more technical support from FAO and, in the case ofinvoluntary resettlement, from the Bank. The process involves the MT drawing up a sitespecific EMP and workplan for each atypical site on the basis of FAO's safeguardingguidance, and in particular the EMTK. The plan should address all the issues that havebeen outlined in earlier sections. It should also address the issues that make the siteatypical:

The potential necessity to invoke World Bank policies on Involuntary Resettlement(OP4.12) or land acquisition. In many cases if involuntary resettlement is necessary,it is likely to be only a temporary measure and never permanent;The scale of the environmental risks that it poses; or

* The security issues for the teams operating in the field

The EMP and workplan should be approved by FAO's Technical support unit before anywork is undertaken at the site. Communication will take place with the Bank TTL to make apreliminary finding on whether or not OP4.12 on Involuntary Resettlement is triggered ornot. In the event that OP4.12 is triggered, no work will take place on the site until aresettlement plan has been approved by the Bank with the necessary measuresimplemented.

7.2 Monitoring Plan for atypical sitesThe monitoring plan should be similar to that of a typical site as set out in section 6.2. If theEMP requires a temporary resettlement plan to be implemented, the monitoring plan shouldinclude an assessment of the accommodation and household services. In addition, becauseof the increased risk and sensitivity, the NPM should take greater direct involvement in thesupervision of the planning and implementation of the project. The support of an NGOmonitoring programme would assist in dealing with the public and the independentmonitoring of the implementation of the temporary Resettlement Plan.

8 Environmental Management Training Requirements

8.1 Current training requirementsThe project team has had significant training over the 5-years of Phase-I and Phase-Il. Thishas included:

* Safeguarding. EMTK

InventoryContractor training by Veolia

. CESA

49

Last revised Ale following Bank 1't comments received from the WB

This training is sufficient for the team to carry out all the activities currently being undertaken

under Phase-Il. As has been noted in section 4, during the preparation of this CESA some

non-conformances with FAO guidelines and training modules were identified. When

questioned the NPM and FMs were fully aware of requirements of the FAO guidelines and

training modules. Repetition of the training is therefore not required, but it should be

reinforced through closer and more frequent monitoring and supervision by the NPM.

8.2 Training requirements for the ASP

Further training will however be required when the ASP starts. The EMTK and Inventory

guidelines have been improved since the commencement of Phase-Il. The new guidelines

will need to be trained in advance of the inventories being undertaken for the other materials

to be included in the ASP.

The team will require training in the use of the Obsolete Pesticide Management System in

order for them to use if for recording and analysing the inventory of empty drums,

contaminated equipment and contaminated soils. In addition to the training, it will be

necessary to upgrade the internet access to the office to broadband and to replace the two

old office computers.

Once the ASP Monitoring and Evaluation framework has been finalised the FMs and NPM

will require to be trained in it.

Training in monitoring will also be required by the EPA and the NGO engaged as an

independent monitor.

9 Changes needed to any contracts or guidelines or policiesThe project is proceeding appropriately and successfully within the bounds of the current

contract, guidelines and policies. There are no changes that are required to be made in

order for the current objectives to be achieved.

However in preparation for the ASP, there are some potential changes that could be

required.

9.1 Changes to Veolia's contract

Currently nothing has been identified that would require a change to the Veolia contract.

However, if the quantity for pesticides was found to have increased and there was a desire

for them to be disposed of in advance of the ASP, the contract would require to be

amended. This could be the case if the MoH find sufficient funds to address their stockpile

of DDT in Addis Ababa.

9.2 NGO monitoringNGO monitoring is a key element of the ASP. Where funding is routed through the GoE, it

will be a requirement to change current government policy that prevents it from providing

funds to an NGO.

Alternatively, funding for the monitoring activities could be routed directly to the NGO andnot pass through the GoE. Direct funding has the advantage that it makes the NGO entirelyindependent of the Government, and free to report impartially about the project'sperformance.

50


10 Public Consultation and DisclosureThis section covers the routine consultation and disclosure that is undertaken by the PMT aspart of the current project, and the consultation and disclosure procedure for this CESA. Atthe end of the completion of the SESA document it has been disclosed to members of theNational Project Coordinating Committee (NPCC), the FAO Representation and members ofthe NGO which the latter should have access to the grass-root level. This was alsodisclosed to public by placing copies of the document in the libraries of the Crop ProtectionDepartment CPD) and the separately at the main library of the Ministry of Agriculture andRural Development. Some verbal feedbacks were received all expressing satisfaction of theundertaking in making the information to reach the public. The disclosure of CESA andOperational Manual having been taken under similar circumstances the process ofdisclosure is considered satisfactory.

10.1 Routine Consultation and DisclosureThere are two levels of public consultation undertaken by the project:

* Official consultation about the project as a whole* Consultation with communities in which activities are undertaken.

10.1.1 Official ConsultationThe EIA Proclamation 299/2002 sets out a requirement for public consultation anddisclosure. Although Phase-Il did not involve any major constnuctions that would haveinvoked the proclamation, its principles were observed. The Environmental ManagementFramework for example was made available for consultation for the required period of 120days both for CESA and the OM under similar conditions.

Details of the project are disclosed through the NPCC meetings and the Stakeholdermeetings both of which are held on a quarterly basis. Similarly workshops and meetings areheld with Donors and Universities.

10.1.2 Consultation with communitiesThe need for consultation with the communities and public that live and work near the storesis extremely important as they could be affected by the repackaging and disposal activities.The detail of the current consultation process has been set out in section 4.5.5

The Regional counterparts write to the Zonal authorities to explain what is going to beundertaken in their zone. The Zonal counterparts forward the message to the Weeds whothen communicate to the Kebele.

The Zonal counterpart that is assigned to the repackaging team communicates verbally tothe community leaders at the Kebele and the local police to inform them about therepackaging. They explain the activity and that the pesticides are no longer usable and aredangerous to human health. They ask the community leader to keep the local populationaway from the store while the work is undertaken. If there are houses nearby, the residentsare instructed to vacate their houses and leave their windows and doors closed. Highlyvisible warning tapes with hazard signs are put up around the store to exclude publicaccess.

The communication process between the Zonal counterpart and the community leader couldbe improved by providing a written notification in the local language which explains theactivities that will be undertaken and sets out simple "dos and don'ts". This could be in theform of a laminated sheet that could be affixed to notice boards and electricity poles and/orother poles around given Kebeles. A template for the written notification is included asAnnex-G.

51


The local public health centres are often made aware of the activities.

The warning signs that demarcate the site should also be in the local language.

10.2 Consultation and disclosure procedure for the CESA

The process for public consultation and disclosure for this CESA involves the following

steps:

Consultation in EthiopiaInclusion of comments and recommendations from the consultation as an Annex to the

CESA although so far no written reactions for or against have been received except

verbal encouraging responses over the phones from various sources.

Submission of the CESA to the World Bank for approval

Once approved, the disclosure of the CESA in Ethiopia and internationally

10.2.1 Consultation with Stakeholders in Ethiopia

The consultation process within Ethiopia should involve all interested and affected parties.

The project has already identified these interested and affected parties, and has established

the National Project Co-ordination Committee as a mechanism for involving them in the

project. The NPCC represents a suitable forum for public consultation of the CESA.

Although so far no negative reactions of feedback have been received about the CESA

distributed, it is worthwhile if the PMT convenes a specific workshop for members of the

NPCC, ensuring to include all the government departments involved in the project Steering

Committee.

The PMT should record all the comments and recommendations if any that are made by

members of the NPCC during the workshop and added to the CESA as an annex in future.

In the case of recommendations that will be adopted by the PMT, the body of the CESA

should also be amended.

The workshop should also address the issue of the mechanism for the CESA's public

disclosure once it has been approved. The workshop should determine:

The format for the document for disclosure. It is recommended that it is available both in

hard copy and as a downloadable soft copy if conditions permit. The hard copy should

be available by any convenient means for viewing free of charge at predetermined

locations although this has already been done as mentioned above.

The duration of the period in which the documents will be available.

The locations where the document can be viewed.

The organisation to which the public should submit their comments and questions about

the project and the CESAThe duration of the consultation period.

. A mechanism for reviewing the comments from the public, agreeing an appropriate

response and responding to them.At the end of the consultation period the comments and the government's responses

should be published. The NPCC should agree a mechanism and the timescale of the

publication of the results of the consultation.

The workshop should give consideration to the Ethiopian Government's policies and

proclamations regarding disclosure, for example for Environmental Impact Assessments.

52


10.2.2 Submission to the World BankThe appropriate government authorities in Ethiopia should formally submit the CESAdocument to the World Bank for approval. This has already been done and because ofsome comments received it has been revised. This was necessary because the World Bankapproval of this CESA is a prerequisite for the signing of the ASP Grant aid agreement. Thegovernment authorities should also submit a copy of the CESA to FAO. -The World Bank will confirm to the government authorities their approval of the CESA or,where deficiencies are found, will provide details of any improvements that are required.In the case that the Bank does not approve the CESA, the government authorities maymodify their procedures to comply with the requirements of the Bank, revise the CESA andresubmit it.

10.2.3 Public DisclosureOnce the Bank has confirmed its approval, the CESA should be disclosed in Ethiopia and bythe Bank.

The disclosure mechanism in Ethiopia should be that agreed during the consultationworkshop described above.The Bank will disclose the document on its intranet and through its Infoshop.

10.2.4 Publication of the results of the Public ConsultationThe Government of Ethiopia should publish the results of the public consultation in the modeagreed during the NPCC workshop described in section 10.2.1.

11 Next StepsThis section briefly describes the next steps which are:

1. The PMT reviews the CESA document, and resolves any outstanding questions ormakes its amendments.

2. The PMT circulates the revised draft to the World Bank (appropriate office) FAOTSU and the consultant that did the draft.

3. The PMT organises the stakeholder consultation process within Ethiopia, which isoutlined in section 10.2.1.

4. The PMT adds an annex of comments from the Consultation and makes anynecessary changes to the document.

5. The PMT arranges for the Government of Ethiopia to formally submit the finalisedCESA to the World Bank for approval.

6. The World Bank reviews the CESA and confirms its approval.7. The Public Disclosure process is initiated as per section 10.2.3.

:.

53

PR

ANNEX-A

List of Preparers

Annex A: List of Preparers

The following persons assisted Richard Thompson in the preparation of this report through the provision of

documents, data and information. Dr. Alemayehu Wodageneh extensively revised, formatted and updated

the CESA following comments received from Ms Stefanie Brackmann, Water, Environment, Social and

Rural Development Department (MNSRE), World Bank, Washington office and following

discussions over the phone with her on 13 October 2006 organized by Ms. Azeb Fissha of the

World Bank, Country office, Addis Ababa.

Mr Biratu Oljira PMT, Project Manager, MoARD

PMT, International Technical Advisor, BTC,Dr Alemayehu Wodageneh (Disposal)

PMT, International Technical Adviser, BTCMr. Olivier Machiels (Prevention)

Mr. Alemayehu Woldamanuel PMT, Counterpart Prevention, MoARD

Dr Kevin Helps FAO Technical Support Unit, South Africa

Mr Chris Warner World Bank, Pretoria

Ali Haribou FAO Representative in Djibouti

Regional Field security Coordination Officer,

Mr Sorrien Scott Ethiopia-Djibouti & chief Security Advisor a. i.Ethiopia

Mr Kiros Tarekegne Regional counterpart for Amhara region, PlantProtection clinic, Kombolche

Mr Mehari Wondimagegn EPA, Addis Ababa

Getachew Cherinet Croplife International

Yismayike Yitagesu PMT Field Manager

Dr Teferi-Bel Amakeletch Agronomist,

Shimelis Hassen PMT, Field Manager

Melese Denboba PMT, Field Manager

Regional counterpart from Jimma Plant HealthTeshome Tafese clinic

Barbara Dinham Director, Pesticide Action Network UK

Angela M Mwandia ASP Co-ordinator WWF, Nairobi

Dr Abou Thiam Co-ordinator, Pesticide Action Network, Africa

ANNEX-BANNEX-B Site visits

Two field missions were made. The first from 2 9th to 315' March 2006 met up with the inventory verification team in North Showa, Amhara region. The second missionwas to Jimma from 7th to 8'h April 2006 to observe the repackaging team in action and to visit the Jimma MCC. On 10th April the Gottera site in Addis Ababa was visitedto inspect the equipment store, the Addis MCC and the Shipping containers that had been stowed by Veolia Waste Management Company and were waiting to beshipped.

Verification

Rema #99

The store was situated on the outskirts of Rema. The populace were very interested in us when we arrived and crowded around us. They did not appear to have been-. : .. made aware of the visit or its purpose.

- -. The store contained drums of sumithion supplied as aid' by the Government of Japan, and a drum. The store

had an earth floor and was used to store sacks of>4 cement and old sprayers.

The verification process identified two items in the 2001inventory were no longer present.

- - The verification team did not wear protective clothing.The 2001 inventory included items in ripped sacks, sothere was risk that the dirt on the floor included

-- - - residues. A TBRA should have identified the need to-v ,wear boot covers..! . ....... ......

Fp 4355

- Fe 38

Meragna #91Three stores were found at Meragna, 2 belonging to MoARD and the third to AISCO. The storekeeper for the AISCO store could not be contacted, and with the storedoor locked, it was not possible to verify its contents. The other two stores were listed as #91a and #91b. However the site plan, store plan and environmentalquestionnaire were only completed for 91a.

91a

, 1 f 1 1 1l

ANNEX-B

ANNEX-B Site visits--

The building is located in a secure

-) .ra L - compound within the village of Meragna and

- , it has three stores. From the left of the

picture there was a wood store with no

. -" 4 pesticides, then the MoARD store and on

the right the AISCO store.

There was one drum of Diazinon and a large

pieof new and used spray equipment.

-- it Fe = 31

91bX- The building is located amongst other village buildings and houses. It contains one

drum of Dursban.

i r : ,<Fp = 2600

V- -Fe = was not properly recorded but is likely to be of the order off 40 - a slightly higher

- risk because it is outside the compound and close to village houses.

2


Merhabete # 92

71 _

r;-- -- -- t- SW - *' E -. r)-;

The two Merhabete stores are separate parts of the same building. The building had a water proof roof and walls and a concrete floor, which made it attractive forstoring other materials. #92 had a large pile of wheat at one end of the store and pesticides at the other. Fe = 30 and Fp 78989 which was calculated based on theaggregate of pesticide stocks for both #92 and #93. This is gives the Fp for the building but, to comply with the principles of the EMTK, separate calculations should bedone for each store. Closer supervision needs to be provided by the NPM to ensure that correct procedures are followed for the calculations of risk factors.

Merhabete # 93

11 The floor of this store was covered with a layer of lindanedust between I and 2 cm deep. A pile of high quality sawnand planed timber was also in the store and had beenplaced on top of the dust.

1 The FM avoided contact with the lindane by climbing from5 the door step directly onto the pile of wood. Other

members were about to walk onto the lindane when the FMalerted them to the necessity to wear boot covers.Around the far side of the wood there were split cardboardkegs and sacks of lindane.

- r,,.q9Fe = 38

Fp =78989

The Team calculated Fp for the combination of #92 and #93 as noted above. This isgives the Fp for the building but to comply with the principles of the EMTK, separatecalculations should be done for each store.

Alem Ketema # 937

3

ANNEX-B

ANNEX-B Site visitsx- S - ~ - The Alem Ketema store has a concrete floor

and corrugated iron roof. It was raining at thetime of the inspection and there was evidenceof rainwater penetrating the roof at the centreof the store. The store is located within a

fenced compound. The store contained

pesticides and contaminated equipment indisorderly piles. The materials comprised 1.5tonnes of organophosphorus pesticides and

A, lindane.

The photographs show the store; verificationprocess; the layout of materials in the store;

and the documentation used to record the

environmental risk factors of the store.

The team calculated the EMTK risk factors as:

5 Fe = 35

A-- $..Fp

= 26400

4


Repackaging at Jimma

Jimma Rural Development Research Centre #486--- a - - --==l

n ~ ~ ~ ~ - F ' o-

Photo 1 shows the set-up of the site. The workin'g areas had been zoned according to FAO Guidelines. The entrance to the store was covered with a plastic sheet toprevent dust and fumes from escaping to the environment. One technician, wearing appropriate PPE remained outside the store on standby in the case of anemergency or accident inside the store. There was an emergency shower and washing facilities (photo 2). The zone in front of the store was covered in plastic sheetingwith bowls for cleaning footwear, and screened with hazard warning tape to segregate it from the clean area. The nurse had set up a first aid post adjacent to theemergency shower (photo 4). The First Aid kit was that provided by Ekokem, which has instructions in Finnish - New First Aid kits that have English instructions areavailable at the central stores. Minor injuries are not being recorded. The photo 2 shows the CESA team preparing to enter the store and photo 3 shows the teamhaving exited the store, removing protective clothing and depositing contaminated clothing in a drum for disposal.Photo 5 shows the technicians using a drum pump to transfer chlorpyrifos-methyl to new UN approved drums. The drum

-pump had a foot valve to enable the pump to be closed off and moved between drums without spilling pesticides.Anumber of non-conformances with FAQ guidelines were noted and were raised with the Field manager, in particular:

The operators were wearing class 4 overalls rather than the liquid proof class 3 ones;No earth strap for preventing electrostatic build-up on the drumsNo spill kit in case of a leak

Ph 1 Transparent outlet tube had become opaque and needed to be replaceda There was no toolkit available in the store

5

ANNEX-B

ANNEX-B Site visits

Photo 6 shows the technicians placing sacks of cypermethrin into open-head UN approved drums. The floor sweepings were

shovelled up and also placed in the drums. The technicians used the appropriate PPE for the activity.

The inspection team noted that the technicians did not have a drum vacuum cleaner to clean residual dust from the floor.

Drum vacuum cleaners had been purchased and are available to the central stores at Gottera.

A!

Photo 7 shows the UN coding of the drums used to repack the pesticides - blue background is for the solid materials and red

background is for liquids. The standard for the drums is appropriate for the intemational shipment of pesticides.

-; , rPhoto 8 shows the list of the team members involved in the repackaging at the store # 486.

Photo 9 shows the Project Daily checklist completed for the day that the CESA team vistited the

repackaging activities at Jimma. All documentation complied with FAO procedures.

6


I Photo 1 0 shows the Task Based Risk Assessment for store #486. The assessment wasprepared following FAO guidelines. However the selected specification of overalls (type4) was not appropriate for handling liquids, which should have been type 3 whichprovides better protection. The technicians do not like wearing type 3 overalls. Thefabric is heavier and does not 'breath', so causes the wearers to sweat and overheat

- ,more rapidly than type 4. To compensate it is important that the technicians take regularbreaks and drink sufficient water to avoid dehydration.

Other observationsSawdust mixed with lime was recommended by the contractor to be used as anabsorbent and packing medium. This is not appropriate because:* sawdust is a potential fire hazard.A- -Hardwood sawdust can be carcinogenic* Finely divided sawdust when mixed with air can be an explosion hazard.

The CESA team confirmed that the contractor should supply inert absorbent granulesfor tackling spills and Micafil (vermiculite) as a packing medium.

- The vehicles did not carry spill kits or first aid kits. Sufficient spill kits and first aid kits10 have been supplied by the contractor and are available in the central stores.e g m s he b s b t Arrangements were made for both spill kits and first aid kits to be distributed to the. .-.. field teams during week commencing 10t April.

* Orange fencing materials have been supplied by the contractor. These provide a physical barrier to prevent human and animal entry to a site, and is much morerobust than the plastic hazard tape. The warning signs were only in English - The site should show warning signs in both English and the local language.

* The vehicles used to transport repackaged materials to the MCC did not have a drip tray.

7

ANNEX-B

ANNEX-B Site visits

Jimma Major Collection Centre

-~ Photo 1 shows the plan of the stocks within the Jimma MCC. There are two stores: the small equipment

store at the bottom of the plan that is used to store protective clothing, new drums, and packaging materials;

and the main pesticide store, which has all the repackaged materials that have been brought back from the

outlying stores in the region.

Observations

* The pesticide store had its stocks well laid out and segregated into liquids and solids. The drums were safely

* double stacked with plywood sheeting between the layers of drums. There was only one 9kg fire

extinguisher which is insufficient (the central stores has enough to be able to supply each MCC with 3

extinguishers). There was no spill kit (they are available at the central stores).

In some stores the repackaging team had found bottles of different pesticides which they packed into the

same open-head 200 litre drums. They had not checked that the materials were compatible. This

3 -represents a potential risk of the-contents reacting and causing a fire or leakage. This is poor practice and

does not conform to FAO guidelines. The FM was instructed to identify all the drums with mixed contents,

and to repack them such that they contained a single pesticide product or a number of compatible pesticide

products. In future, where the repackaging team finds small containers of different pesticides they have been

- instructed to pack each material in a separate drum. The drums should then be consolidated with identical or

compatible materials from other stores at the MCC.

j .The nurse and a vehicle would normally have been located at the MCC such that in an emergency she can

be rushed to the site of the emergency or the hospital which ever is most appropriate

The guard did not have an up to date stock list of the content and layout of stocks within the store. The FM

agreed to provide the guard with the stock list and instructions in the event of an emergency in the local

10 language.

There was no formal plan of action in the event of a major leak or fire at the MCC. It was agreed that the FM should meet with the local fire service and agree an

evacuation plan for the local populace and a strategy for dealing with the incident.

- ~Photo 11 shows the door to the pesticide store and the signage (all in English). Signs

in the local language should also be displayed.

Photo 12 shows two drums with mixed contents sumithion and endosulfan; and round-

up and 2,4-D. These drums must be checked for the compatibility of the contents andwhere necessary be repacked.

8


Gottera Major Collection Centre

- . ;Photos 1 and 2 show the Gottera store in Addis Ababa,f. -- which has been used to store the materials that wereTb- repackaged from the stores around the capital in the initial

stages of Phase 11. It is currently used for storage of theexcess materials that cannot be housed in the Awassa MCC.

r, I The store is well ordered.

*iI 1The site also had shipping containers that had been stowedI -, by Veolia and were waiting to be shipped. The ShippingContainers were inspected and found to be stowed andf-labelled correctly. The only issue was that sawdust had-. been used as an absorbent material inside the steel spilla - trays. The CESA team contacted Veolia and instructed the

-- sawdust to be removed and replaced with inert absorbentgranules.

Photo 3 shows a close-up of the steel spill tray filled with sawdust.

Photo 4 shows the stowing of the drums within the shipping containerPhoto 5 shows the stowing of FIBCs of solid pesticides within the shipping container. TheF N 1 Photo | certification of the FIBCs allowed for double stacking within the shipping container.

I Photo 6 shows the International Maritime Dangerous Goods code labels affixed to the side ofthe shipping container.

kF . ~ -

- . .*6

53 ~' f -9

ANNEX-C

List of References

List of References

ASP Project 1 - Environmental and Social Assessment - Category A Environmental Assessment, SummaryReport - World Bank October 2004

ASP Project 1 - Environmental and Social Assessment - Synthesis Report - World Bank March 2004

World Bank Operational Policy- Environmental Assessment OP4.01 January 1999

World Bank Operational Policy- Pest Management OP 4.09 January 1998

World Bank Operational Policy - Involuntary Resettlement OP 4.12 January 2001

Obsolete Stocks in Ethiopia - Task Force Mission Report - FAO December 1998

Prevention and Disposal of Obsolete Pesticide Stocks in Ethiopia - Programmatic EnvironmentalAssessment - FAO November 1999

Prevention and Disposal of Obsolete Pesticide Stocks in Ethiopia - Phase I Terminal Report - FAO January2004

Operational Manual for the Prevention and Disposal of Obsolete Pesticide Stocks Project in Ethiopia, Phase-II - PMT November 2003

Operational Manual for ASP and Prevention and Disposal of Obsolete Pesticides in Ethiopia, Phase II - Draft3 November 2005

Mid-Term Review Mission Report - Prevention and disposal of obsolete pesticide stocks in Ethiopia - Phase-11 - Belgian Technical Cooperation January 2006

Environmental Management Tool kit - Final Draft FAO September 2005 (available at www.fao.org)

Guidance Document - The Preparation of Inventories of Pesticides and Contaminated Materials - Final draftFAO September 2005

ANNEX-DCompliance Procedure for Basel Convention

Annex D: Compliance Procedure for Basel ConventionIMPORT INTO THE UNITED KINGDOM FOR INCINERATION AT FAWLEY

1. DULY MOTIVATED REQUEST (DMR)

The UK may accept imports for disposal from countries outside the EU that do not have, andcannot reasonably acquire, the technical capacity and necessary facilities to dispose of the wastes inquestion in an environmentally sound manner. Govemments of states that are parties to the BaselConvention must seek the agreement of the UK competent authorities to dispose of wastes in theUK by making a Duly Motivated Request under Article 11 of the Basel Convention and Article 19 ofCouncil Regulation (EEC) No. 259/93. The Duly Motivated Request is submitted to the EnvironmentAgency (TFS National Service) who process the DMR in liaison with DEFRA and the FCO.In the UK, the DMR must be acceded to before a TFS application can be submitted.The DMR for Ethiopia was acceded to 15 February 2005 for the period to 14 February 2008.

2. TFS PROCESS

The application

Once the DMR is in place, a package containing the following documents is sent to the EA TFSNational Service (Acting as Competent Authority of Destination for England and Wales):* Original Notification Form completed and signed in block 23* Original Movement Tracking Form completed in certain blocks and not signed or dated* Associated annexes to the Notification* Non-commercial Agreement between the Notifier and the Consignee* Calculation of the financial guarantee* Details of liability coverage during transportation* Payment!

At the same time copies of the complete packages are sent to the Competent Authority of Despatchand the Competent Authorities of Transit (see separate listing)

The Environment Agency TFS National Service will acknowledge a Notification package once all theelements considered necessary under their minimum acceptance criteria have been received. Withinthree days of receipt of all the required information, the Agency will issue a formalacknowledgement. This acknowledgement is sent to the Notifier and all other Competent Authorities.(As Veolia ES Onyx Limited are authorised by the Notifier to act on their behalf in all matterspertaining to the TFS application, we also receive a copy of the acknowledgement).

TFS National Service now passes on responsibility for the remainder of the assessment to theregional office for the disposal site - in this case Winchester.

The assessment

A 70-day period of assessment applies to Notifications for imports of waste from outside of the EU.For shipments for Disposal (this project is D10 - Incineration on Land), tacit consent can beassumed if written authorisation/consent/objection is not received within this period.

1

ANNEX-D

Compliance Procedure for Basel Convention

FINANCIAL GUARANTEE

As early as possible into the assessment period, the financial guarantee is put in place. Veolia ESOnyx Limited, as Consignee, arrange for this to be put in place. The original guarantee is sent to thelocal office (Winchester) as beneficiary. Any other competent authority may ask to receive a copy(Spain always asks to see a copy).

Before any shipments may commence using the approved TFS, we must obtain from the EA aCertificate of Satisfaction (with the financial guarantee).

3. PRENOTIFICATION OF SHIPMENT

Prenotification of shipment to include the following:

* M/T form for each shipment completed in blocks 4 (serial number) 17 18 21 and signed anddated in block 22

* Annexes* Certificate of Satisfaction* Details of vessel, Estimated Date of Departure and Estimated Date of Arrival at Felixstowe

Must be sent to each of the Competent Authorities of Despatch, Destination and Transit at leastthree working days before the waste shipment may commence (from site). In the case of shipmentsfrom Ethiopia, additional recipients are as follows:

* Saudi Arabia - Port Authority for Jeddah* Egypt - Suez Canal Authority* Italy - Captain of the Port of Gioia Tauro* UK - EA East Anglian Region (for Port of Felixstowe)

IMPORT INTO GERMANY FOR INCINERATION AT AVG

1. DULY MOTIVATED REQUEST (DMR)

The German Competent Authority of Destination (Freie und Hansestadt Hamburg) is happy to receive theDMR with the Notification Packages. In Germany, we are required to submit two TFS documents one eachfor solids and liquids.

The application process is the same as for imports for disposal into the U.K.

2. FINANCIAL GUARANTEE

Freie und Hansestadt are happy to receive a financial guarantee covering both TFS documents which hasbeen put in place by Veolia ES Onyx Limited. However, as the U.K. is named as a transit country, we stillhave to obtain a Certificate of Satisfaction from EA TFS National Service by sending them a copy of theguarantee before shipments can commence.

2

ANNEX-DCompliance Procedure for Basel Convention

The pre-notification process is the same.

AFTER RECEIPT OF WASTES AT THE DISPOSAL SITE.

The disposal site is required to complete block 24 of the M/T form on receipt of the waste and, within threeworking days, to send copies to each of the competent authorities.With 180 days, the same authorities must receive copies of the M/T signed off as complete in block 25.

COMPETENT AUTHORITIES

GB005688 (Year 1) GB006676 (Year 2)

Competent Authority of Despatch National Environmental Protection AuthorityP.O. Box 12760Addis AbabaEthiopia

Competent Authority of Destination Environment AgencyRichard Fairclough HouseKnutsford RoadLatchfordWarringtonCheshireWA4 1HGUnited Kingdom

Competent Authorities of Transit Ministere de l'Habitat, de l'Urbanisme, de l'Environnement etde I'Amenagement du TerritoireB.P. 11Djibouti

Meteorology and Environmental Protection Administration(MEPA)P.O. Box 1358Jeddah 21431Saudi Arabia

Egyptian Environmental Affairs Agency30 Misr Helwan El-Zyrae RoadMaadiCairoEgypt

Ministero dell'Ambiente e Della Tutela del TerritorioDirezione per la Gestione dei Rifiuti e delle Bonifiche Via CristoforoColombo 4400147 RomeItaly

Jefe del Area de Gestlon de Residuos y Jefe del Serviclo deDiseno de PlanesSubdirrecion General de Calidad AmbientalDirrecion General de Calidad y Evaluacion Ambiental

3

ANNEX-D

Compliance Procedure for Basel Convention

Ministerio de Medio AmbientePlaza de San Juan de la Cruz s/n28071 MadridSpain

DE1350/143583 and 4 (Year 1) DE1350/143928 and 9 (Year 2)

Competent Authority of Despatch National Environmental Protection AuthorityP.O. Box 12760Addis AbabaEthiopia

Competent Authority of Destination Frele und Hansestadt HamburgBehorde fur Stadtentwicklung und UmweltBillstr. 8420539 HamburgGermany

Competent Authorities of Transit Ministere de l'Habitat, de l'Urbanisme, de l'Environnement etde l'Amenagement du TerritoireB.P. 11Djibouti

Meteorology and Environmental Protection Administration(MEPA)P.O. Box 1358Jeddah 21431Saudi Arabia

Egyptian Environmental Affairs Agency30 Misr Helwan El-Zyrae RoadMaadiCairoEgypt

Ministero dell'Ambiente e Della Tutela del TerritorioDirezione per la Gestione dei Rifiuti e delle Bonifiche Via CristoforoColombo 4400147 RomeItaly

Jefe del Area de Gestion de Residuos y Jefe del Servicio deDiseno de PlanesSubdirrecion General de Calidad AmbientalDirrecion General de Calidad y Evaluacion AmbientalMinisterio de Medio AmbientePlaza de San Juan de la Cruz s/n28071 MadridSpain

Environment AgencyRichard Fairclough HouseKnutsford RoadLatchfordWarringtonCheshireWA4 1HGUnited Kingdom

4

ANNEX-EFAO Environmental Management Tool Kit (EMTK)

Environmental Risk Analysis Questionnaire based on FAO EMTK

1.1 Is there a roof? Yes= x 4-No=1 4

1.2 Is the roof waterproof? Yes=- x4=Nlo- -=, II-ff there is no roof, write NO

+1.3 Are there complete walls' Yes= O x 4 =FTo --I

1.4 Are the walls solia and impermeaole? Yes= o x 4 =No= IIf there are no walls write NO .

1.5 Is there a solid and impermeable floor? Yes=No- 1 x X4= |l

2 s there any additional material or equipment stored together Yes=2 with pesticides?

I INo= x I-.

+2.2 Are there any foodstuffs stored together with pesticides? tYes- 1 X 1 =

-

+

1Yes= I2.3 Are there any fertilizers stored together with pesticides? No - 0 x l-

+24 peIs there any veterinary product stored together with Yes= I x| X =| pestlcides?

F No = O

2.5 Are there any chemicals (other than pesticides. fertilizers or Yes= 1 x2 veterinary products) stored together with pesticides? No = | - l

3.1 Does the store have a door that can be locked? Yes= x xINo= =

3.2 Is there a fence around the store? [Yes=O x I

ANNEX-E

FAO Environmental Management Tool Kit (EMTK)+

3.3 | Does the fence have a lockable gate? Yes- x I

If there is no fence write NO +

- Yes= o3.4 Is/are there any guard(s) Noe= 1 x 1

+

3.5 Is/are the guard(s) assigned 24 hours a day? Ne I x 1

Is there any storekeeper assigned for the management of the Yes= w x +store? FNo- = I

42 Does the storekeeper check pesticides containers at least once Yes-- 0 =42a week? NIo = 1 x

If there is no storekeeper assigned for the management of the store write NO +

4.3 Are pesticide containers safely stacked on shelves or pallels? Yes= - x 1Are=N=

- 5.1 Is there any fire safety equipment in the store? Yes= x 1i Ye= I

5.2 Is there a first-aid kit in the store? Yes| = 1 X 1No = i

5.3 Is there any means of communication (radio telephone etc)? Nos- | x 1=

| Is appropriate personal protective equipment available for the YesZ 0 x 1-storekeeper? |No = 1 -

+

5.5 Does the storekeeper wear personal protective equipment? Nes=o x 1=

ANNEX-EFAO Environmental Management Tool Kit (EMTK)

6.1 Is thestr loae in a znprntoaualdste?YsI 10 =I

NEnvironmental hazards: flood, hurricane, landslide, earthquake... +

6.2 Is the store safely located in close proximity to industrial hazards Yes= I x 5(less than 1 km)? |No = 0OIndustrial hazards: chemical industries, oil industries.. If the store is in adesignated industrial zone with adequate services answer No.

7.1 Is the store located in an urban area? Yes| I x 5 =

+.Ns= 17.2 Is there any human settlement within 500 meters from the store? Yes= I x 5 =

- =+

7.3 Is there any public facility within 500 meters from the store? Yes I x 5 =I No= =0Public facility: school, hospital, health facility

74 Does the public complain about pesticide odours around the Yes= I X 5 =vicinity of the store? |No 0 o

|e -

Imbv

8.1 Is the store located wilhin 250 meters from a borehole or a well? Yes x 5=FNo _0I-

+8 2 Is the store located within 500 meters from a lake. a pond or a | yes I I x l82 river? [-No-0=- 5

8.3 Is the store located up-stream or uphill from a borehole, a well or Yes= 1 x =surface water? No=O IIf there is no fence write NO

+

8.4 Has soil contamination been reported? Yes=1 x 5FNo~ 0

ANNEX-E

FAO Environmental Management Tool Kit (EMTK)

9.1 Is the store located within 250 meters from crops and pastures' Ns I x 3 =

+

9.2 Is the store located within 250 meters from storage of food and Yes= I x 3feedstuff? No7= O

+

9.3 Is the store located in a national park or recreational area? Nos- = 0 x I=

ANNEX-FExample of Topological map of Stores and Roads which equally true to each and everyDesticide store in the countrv

Roadmap For Seteta at632,633,634&

Woliso Area 943

The radto

411/ 114BI

>WoTole

AStote

/ / >6t636, 637, 638,/ / 69&640

ANNEX-GTemplate for Consultation with the Public around the site

Safeguarding and Disposal of Obsolete Pesticides in

[name of store][street name]

[name of Kebele]

The Ministry of Agriculture and Rural Development plans to carry out clean this store and toremove all the obsolete pesticides that it contains. These pesticides are no longer usablebecause they are too old, are dangerous to human and animal health, or pollute theenvironment.The work will be carried out to international standards set by the Food and AgricultureOrganization of the United Nations. Once the store has been cleaned it will no longerrepresent a threat to the health or environment of [name of Kebele].Duration of workThe work is planned to commence on [date of commencement] and is expected to completeon [date of completion].PrecautionsFor your safety, there are some precautions that must be taken while the store is beingcleaned:* the area around the store will be fenced, and unauthorised access is not allowed;* animals should be kept away from the area of the store* Buildings close to the store will be required to be vacated from [starting time] to [finishing time]

while the store is being cleaned. The owners of the effected buildings will be notified in advance.During the working day all the windows and the doors of the effected buildings should be closed.These buildings can be reoccupied outside the working hours and when the store has beencleaned.

Consultation and ComplaintsIf you require further information; wish to provide information about the store, its pesticidesor other areas of pesticide contamination; or have a complaint about the clean-up activities,please contact:[Name of Person][Address][Telephone number]Your enquiry will be treated in the strictest confidence.

Signed:

Local Administration

Annex-HBackground information of the obsolete pesticides Problem

ISSUES AND PROBLEMS OF OBSOLETE PESTICIDESIN ETHIOPIA

Updated June 2006


CONTENTS PageIssues and problems of obsolete in Ethiopia ................................... 4

Chemicals: The long and short-term ramification ............................... 4Overview ................................................................. 4Issues and Problems of Obsolete and Banned Pesticides ......................... 4

Causes for accumulation of obsolete pesticide stocks ............................ 4The first line of action in addressing the issue of stockpiles ......................... 5

The problem at its root ................................................. 5What are obsolete pesticides? ............................................ 6When are pesticides obsolete? ............................................ 6Survey activities ................................................................................. 7

Destruction of waste ....................................................... 7Policy Issues .................................................................................. 8Actions that need to be taken ............................................. 9

Guidelines on obsolete stockpiles ............. .......................................... 9Status of obsolete pesticides in Ethiopia .......................................... 9Outputs expected as a result of cleaning up and disposal operation ................ 1.... 11The media and NGOs as important tools and sources of information ................. 12Global outlook ............................................................ 12

3


Issues and problems of obsolete in Ethiopia

Chemicals: The long and short-term ramification

Overview

Issues and Problems of Obsolete and Banned Pesticides

Pesticides and leaking and corroding pesticides containers are worldwide and seriousenvironmental issues. They exist in both urban areas and in populated zones. Most of the rurallandscapes of developing countries are littered with obsolete stockpiles involving pesticides of alltypes, POPs pesticides, empty and contaminated containers of all types, makes and sizes. Thesestockpile leftovers are constant threats to the human health in the agricultural world they weredesigned and meant to help. They are affecting not only the agriculture and its environment, butalso the health of people and consequently development. The global environmental tragedy is adirect result of several decades of mishandling and wrong agricultural, aggressive pesticide salesand distribution, etc. The problem is most serious and dramatic in the developing world wherethere are no awareness, facilities, expertise and above all funds for cleaning up the toxic waste.Conservative estimates find well over 500 000 tonnes of obsolete pesticides in developingcountries and a staggering quantity existing in Africa.

The alarming inventory information gathered by FAO in just few years provided concrete evidenceof the real and immediate danger resulting from stockpiles in many of the countries covered inAfrica and other parts of the world. The collaborative programme on disposal of obsoletepesticides underlines the urgency, the importance and the need for both commitment andconcerted international effort to solve the problem. The Indication confirms that at least over 500million dollars will be required to clean up critical areas of the developing world but considering ongoing unit cost of disposal, this total sum might be far less than what will be required. The task ofcleaning up the toxic mess is a complex. It is technical, dangerous and expensive. Operation hasto be undertaken and managed by professional staff with skills and adequate background and forthis to be achieved successfully adequate financial resources will be required. If the problem isdelayed or left without solution, it will be far more expensive and the potential for environmentaldisaster will be much greater.

Causes for accumulation of obsolete pesticide stocks

The causes of accumulation stockpiles are many and differ from country to country including thevariety and types of toxic waste involved. The following are some of the known causes:1. Inadequate storage facilities and improper pesticide containers. It is true that some 96% ofthe stores in the developing world are substandard including stores owned bygovernments, state and private farms and also those owned and managed by the pesticidevendors or distributors.

2. Pesticides banned while in storage,-

4


3. Prolonged storage of products with short shelf-life

4. Inability to forecast pest outbreaks such as locusts, birds, grasshoppers, armyworms, etc.5. Poor or no ability to make correct assessment of pesticide requirements6. Unawareness of the inherent danger of pesticides and associated short and long-term

environmental consequences7. Poor stock management and lack of record-keeping in almost all cases8. Inappropriate pesticide provisions or unethical dumping under a pretext of donations9. Uncoordinated donations of pesticides arriving from different sources at about the same

time for the same purpose10. Over-purchase through government budget allocations11. Ineffective distribution system or lack of means and facilities for coordinated actions12. Aggressive profit motive by vendors13. Illegal cross-border trading, etc.

The first line of action in addressing the issue of stockpiles

The first line of action in addressing the problem is to conduct countrywide surveys and to takeappropriate inventory of stocks. The following should be taken into consideration.

1. The issue of obsolete pesticides is complicated and far reaching. The points listed below (a tog) need to be taken into consideration:

(a) Knowledge of causes of accumulation of stockpiles in each case.(b) How and by what means further accumulation can be avoided?(c) Studying how to get prepared to get rid of accumulated stocks and to find the means

to do it.(d) What alternative methods of pest control are available for use?(e) What policies should be put in place to minimise the use of pesticides and move to

other alternative methods of agricultural and vector pest control?(f) How soon governments concerned can enact identified measures?(g) What resources are available and how to implement effectively new or existing rules

or regulations?

2. Studying and analysing the above few and basic questions is useful so as to find solutions torecurring problems of stockpiles and widespread environmental havoc.

3. Study, understand and compare disposal methods available. Disposal by means of incinerationis increasingly opposed by Non-Governmental Organizations (NGOs), the Civil Society, thepublic awareness group, Green Peace, etc. Opposition is stiffer when cement-kilns are chosenfor destruction of waste. Basically use of cement kiln is not acceptable simply because dioxinemission/s into the environment is unavoidable. Dioxins are highly dangerous than a given setof pesticide waste intended for destruction. Toxic waste solids such as containers can't behandled buy cement kiln.

The problem at its root

Hazard pesticides are more devastating and more dangerous in the developing world simplybecause:

5

Annex-HBackground information of the obsolete pesticides Problem1. People and governments in developing countries are unaware of the inherent dangerof pesticides,

2. The necessary financial resources are either scarce or don't exist,3. Facilities either for containing the waste or for destruction are not available,4. Appropriate legal measures don't exist or of if they do are either impossible or difficultto implement,

5. Environmental activists are either absent or weak to stage public demonstration and6. Expertise or skilled manpower is not available, etc.

However, developed countries having most cases all the above six important tools often manageto get rid wastes considered hazardous.

What are obsolete pesticides?

1. Obsolete, banned and unwanted pesticides. These are pesticides that are no longeruseful for the purpose for which they were/are intended. These usually are liquids, granules,powders, emulsions, gasses, etc.

2. Emptv pesticide containers. These are equally as dangerous as pesticides and thereforeshould be included in an inventory in whatever form or make they might exist such asdrums, Jerry Cans, plastics, paper or jute bags, contaminated cartoon boxes, etc.3. Heavilv contaminated soils. These are often sources of serious surface and groundwatercontamination requiring careful studies and assessment.4. Buried pesticides. These are often found either in marked or unmarked sites. Burial beinga long-term source of contamination needs careful identification of the affected sites andaccurate estimates of quantities involved and extent of the area involved.5. Washouts that are often referred to as rinsates from pesticide containers are alsoconsidered obsolete as they are as dangerous as obsolete and actual pesticides, etc.

When are pesticides obsolete?

Obsolete pesticides are defined as stocked pesticides that can no longer be used for their originalpurpose or any other purposes and therefore require disposal. Common causes of this situationinclude the following:

The product has been withdrawn for health or environmental reasons (e.g. throughbanning; withdrawal of registration; policy decision by the Ministry of Agriculture);* The product has deteriorated as a result of improper or prolonged storage and can nolonger be used according to its label specifications and use instructions, nor can it easily bereformulated to become usable again;The product is not suitable for its original use and cannot be used for another purpose, norcan it easily be modified to become usable.

6


A product has deteriorated when:* It has undergone chemical and/or physical changes that result in phytotoxic effects on the

target crop, or an unacceptable hazard to human health or the environment;• The product has undergone an unacceptable loss of biological efficacy because of

degradation of its active ingredient and/or other chemical or physical changes;* Its physical properties have changed to such an extent that it can no longer be applied with

standard or stipulated application equipment.

Survey activities

FAO has developed a format that is widely used for inventory taking. The format is simpleto use. It is useful for exchanging of information for updating the FAO global database onstockpiles. It provides bases for initiating disposal operations.

FAO started gathering information and taking inventories of obsolete stocks since 1994.Between 1994 and 2001, the FAO Collaborative Programme on Disposal of ObsoletePesticides, identified stockpiles in many countries mainly in Africa and the Near East.Currently information on inventories and stock data is available from 46 countries in Africa,nine in the Near East, seven in the Far East and 12 in Latin and Central America and theCaribbean. However, inventories secured are only indicative and in most cases are farunder estimated and not taken into consideration the four components of stockpilesdescribed above. In each case and in each country, inventory results need and should beregularly updated.

Destruction of waste

Destruction often requires high temperature incineration in dedicated hazardous wastefacilities. At least at the moment these are the preferred means of destruction. There are anumber of different facilities but almost all are either under development or are not widelyused or accepted in many countries. These are:

1. Chemical treatment2. Engineered landfill3. Long term controlled storage4. Reuse/reformulation5. New technology

* Gas phase hydrogenation* Electrochemical Oxidation- Molten Metal* Molten salt* Solvated Electron Process* Supercritical Water Oxidation* Plasma Arc

The above methods of destruction can be debated by indicating advantages anddisadvantages. Most of each of the technologies either updated or being revised while fewof them continue to be used on a limited scale in limited countries.

7


The method of engineered land-filling is often available if Government policies supportthem. However, owing to long-term negative impacts on environment and owing to the factthat they require constant maintenance, such methods of waste disposal is graduallydiscouraged. In fact many developed countries are avoiding their widespread use. In manydeveloped countries old land-filled sites are being excavated and decontaminated at muchhigher cost. Despite widespread oppositions, currently dedicated high temperatureincinerations are being widely used. Dedicated facilities have strict emission controlmechanisms backed by constant monitoring and supervisions to ensure safety ofoperations and zero release of dioxins. But since such sophisticated incinerators areexpensive to install, developing countries can't afford them. The usual practice therefore isto clean up stockpiles professionally, repackage them in new UN approved repackagingmaterials/containers, transport them overland to a major port and then tranship themoverseas such as to countries where waste destruction facilities exist and where waste isaccepted. The cost of such operations varies between US$3,000 and US$4,500 per tonnedepending on a number of factors. However, with increased competition among wastetreatment companies, the cost of disposal per unit weight or volume is expected todecrease.

Policy Issues

Past mistakes have been recognised and measures are being taken to prevent repetition.But still large quantities of obsolete pesticides remain as a heritage since over 30 years ofmisuse. Unless coordinated international action is taken, the current situation will continueto worsen. However, the following are ongoing efforts that are currently beingimplemented:

1. Organizing basic effort to dispose of existing hazardous chemicals and to avoidfurther accumulations.

2. Providing monitoring services to ensure that contractors comply with internationalsafety and environmental standards.

3. Ensuring more cooperation among donor governments, aid agencies, andagrochemical companies. Each needs to assume some of the responsibilities forthe current situation by giving high priorities.

4. Promoting methods of pest management that will reduce total reliance on pesticidesby providing guidelines that should limit stocks of pesticides to short-termrequirements

5. Recommending or enforcing agrochemical companies to take back and dispose ofunused or substandard products they supplied at their own cost including the returnof collection of pesticide containers.

6. Seeking funding sources for disposal operations by establishing joint fundingarrangements as and when necessary.

8


- Actions that need to be taken

* Surveying and monitoring of potential problems of existing stockpiles,* Developing and distributing guidelines for safe storage, for preventing accumulation

and for removal and destruction of waste,* Initiating and formulating disposal activities., Organising, national, seminars,

workshops and group discussions,* Sensitising and mobilizing the public through awareness raising,* Supervision, monitoring and follow-up of disposal operations at field level,* Raising awareness by sharing information, etc.

Guidelines on obsolete stockpiles

FAO has produced and published a series of guidelines and related documents on themanagement and proper storage of pesticides, safe disposal operations, etc. The followingare available in hard copies, in electronic formats and on the Internet.

1. FAO Environnemental Management Kit (EMTK)r- 2. Prevention of Accumulation of Obsolete Pesticide Stocks,

3. Pesticide Storage and Stock Control Manual,4. Disposal of bulk quantities of obsolete pesticides in developing countries5. Guidelines for the management of small quantities of unwanted and obsolete

pesticides

6. Assessing soil contamination (A reference manual)7. Baseline study on the problem of obsolete pesticide stocks8. Training manual in waste management,

9. Country guidelines to help governments in developing countries as to how toaddress the problem and to how to coordinate the various stakeholders, etc.

Most of these guidelines are already available in English, French, Spanish and Arabic andthose that are not will soon be available.

Other related documents on prevention and disposal are also available. Most of theguidelines can be referred to and downloaded from the FAO homepage on the Internet:- http://www.fao.org at the following website:

http ://www.fao.org/WAICENT/FAOINFO/AGRICU LT/AGP/AGPP/Pesticid/Disposal/in dex en.htm

Status of obsolete pesticides in Ethiopia

For nearly four decades Ethiopia has experienced a series of natural problems such as droughtand famine. This, coupled with changes in the social and political structure, has resulted in theneed to seek assistance from overseas.

9


One such area where assistance has been needed is in an effort to feed a rapidly increasingpopulation. This has lead to an increase in importation of materials such as pesticides, fertilisersand related chemical either through donations or by means of direct purchases.Many organisations within Ethiopia required these materials. Organisations and GovernmentDepartments such as State Farms, Agricultural Inputs Supply Enterprise, Agricultural Equipmentand Technical Services Enterprises, Ministries such as Agriculture, Health, Coffee and Tea, alongwith organisations such as the Desert Locust Control for East Africa. All sectors were able toacquire pesticides as and when they were needed, with little or no emphasis on stockmanagement, suitability of product and whether the material was needed. As some of theseorganisations changed or went out of existence the problem of responsibility for stocks was notaddressed. Many institutions inherited large stocks of material which were not theirs.

While some of the materials and most supplies acquired were used at or near the time of deliveryfor the purpose for which they were intended, a large stock of pesticides remained due to overestimation of requirements. As new outbreaks of pests occurred new stocks of pesticides wereacquired. The organisations involved in importing/selling of these pesticides often lackedknowledge on pesticide management and imported pesticides without prior identification ofproblem of pest or shortage of the pesticide required. This problem was often compounded by thesupply of pesticides packed in large containers that were not suitable for sale or direct use, Theabsence of registration of pesticide until recently contributed to the accumulation of obsoletepesticides.

The net result was that a large stockpile of old, often obsolete, stocks grew. Many of these stockswere left in stores or in the open for many years. These obsolete stocks now pose a seriousproblem to the people of the Ethiopia and the environment in general.The reasons for the accumulation of these stocks are varied. Organo-chloride compounds such asDDT, Aldrin and Deldrin are no longer approved for use in agriculture and hence have beenreplaced by other less persistent compounds which pose less risk to consumers of treatedproducts and the environment at large.

Mercurial and Arsenical pesticides have similarly been replaced by safer alternatives. Otherstocks of materials such as Organo-phosphate pesticides have outlived their shelf life; theirchemical and physical characteristics have changed making them unusable and or ineffective. Addto this the cases where donors have supplied pesticides in containers with no labels or flimsypaper labels which quickly deteriorate and the scope of the problem starts to become apparent.The stores themselves vary greatly in their suitability for intermediate / long term storage. Thisshortage of proper storage facilities throughout the country has further aggravated the problem.Over crowded storage and poor quality stores have resulted in leakage/spillage affecting old andnew arrival pesticides. This leakage has also resulted in widespread soil contamination andpossible groundwater contamination. Almost all the stores are located in populated or urban areaswith no thought to urban growth or proximity to ground water supplies. Some stores have beensubject to looting resulting in the illegal sale of products and use of old containers for domesticpurposes.

The latest FAO guidelines urge a move away from the intermediate to long term storage ofpesticides in developing countries, with an aim to eliminate the accumulation of obsolete stocks infuture. It is aimed to promote a network of pesticide supply that reacts quickly to the first signs of apest outbreak. The shear geographical area of Ethiopia and the often remoteness of pest affectiveareas will make such a Just in Time approach to pesticide stock management very difficult to10


implement. It is believed that a certain baseline of stocks will need to be kept. It is the correctmanagement of these stocks at Technical grade level (pre-formulation) that will pose one of thechallenges to Ethiopia if future accumulations are to be avoided.

It has been found on this mission that the vast majority of pesticide stocks are held on StateFarms. Small farmers are generally unable to afford pesticides.

The Ministry of Agriculture has introduced a framework of pesticide registration. It will be theenforcement of this policy that will be the strongest tool in control of pesticide use in the future. Ifthis registration policy is to be a success it will require support by all Government departmentswhich use pesticides. Reports of registration not being enforced to allow quick imports for flowercultivation must be investigated and action taken to prevent future violations in the future.

It is against this background that the Task Force has attempted to formulate a strategy for clean upand prevention of future accumulations. A wide variety of solutions to the problem in Ethiopia havebeen examined. These include possible re-formulation of useful stocks past their sell by date butnot yet classed as obsolete, the use of local cement kilns to provide capacity for destruction infuture and the re-packaging of the inventory of obsolete stocks for disposal at a licenseddestruction facility overseas. All of these have a common feature. That is the large amount of workthat has to be done on the ground in Ethiopia, by Ethiopian personnel, before any meaningfuloperation can proceed successfully. This will require the training of selected staff from all overEthiopia and their co-ordination to provide a nation-wide retrieval and repackaging programme.Investment in new stores will be needed to allow the stocks of obsolete material to be marshalledand stored awaiting a final disposal operation.

Ethiopia is experiencing a two-phase disposal operation. Phase-I disposal operation lasted from2000 to mid 2003. This phase was successfully completed with a disposal of over 1,500 tonnes ofobsolete stocks. The entire stock was destroyed under high temperature incineration operating atno less than 1,200 Degrees Celsius in Finland. The whole operation did cost a total of about US$4.6 million. The management was under the Food and Agriculture Organization of the UnitedNations with the Ethiopian Nationals having been fully participating in the cleaning up, repackagingof all pesticide wastes and containers involved. The entire financial commitment was secured fromthree major donors namely in the order of contribution were (a) the Government of theNetherlands, (b) Sweden through its Swedish International Development Agency (Sida) and (c) theUSA through the United Stated Aid for International Development (USAID). The Government ofEthiopia also contributed greatly through providing the necessary technical manpower and officesthrough the Ministry of Agriculture and Rural Development (MoARD) and all initial costs.

On completion of Phase-I, Ethiopia embarked on Phase-Il disposal operations with financialcontributions over US$ 6 million secured from donors namely: (a) Belgium, (b) Finland, (c) Japan.In addition to these three there is a positive move to secure financial support from the AfricaStockpiles Programme (ASP). The phase-Il will likely dispose of a total of 1, 500 tonnes despitethe initial contractual target is about 1,100 tonnes. The operation was initiated in late 2003although the actual field operation started in September 2004. The difference between Phase-I andPhase-l1 is that the latter includes adequate programmes for (a) Prevention of accumulation ofobsolete stocks in future and (b) capacity building.

Outputs expected as a result of cleaning up and disposal operation

1. Compiled information on disposal options,

2. Increased knowledge on disposal and prevention methods,

11


3. Availability of technical, legal and logistical information to governments, aid agencies,organisations and NGOs,

4. Provision of advice on IPM and Ecological Agriculture through linkage with IPM-Globalfacility, and

5. Ensured public-private partnerships aimed at commitment to disposal and preventionstrategies.

The media and NGOs as important tools and sources of information

The media in general such as the TV, radio, News Papers and discussions on topics of publicinterest affecting the environment and human health in particular is the only reliable way and thebest tool available to communicate. It is best for informing the public, create mass awareness andmobilize the public to minimize problems and the environmental demise, raising funds wherepossible to help the poor, etc. Well informed public would help accelerate protection of theenvironment and minimise health risks.

Global outlook

The mounting risks of exposure to synthetic chemicals: (accidental contact, bloaccumulation, andunpredictable synergies in the environment are much to be concemed about).The following extract from the World Watch Environmental Magazine in USA at(www.worldwatch.orq) is worth to consider.

Despite some gaps in our understanding of chemicals and their interactions with living things,evidence from laboratory studies, observations in the field, and some tragic experiences withpharmaceuticals have provided sharp warnings that some of the "common" chemicals now soomnipresent in our homes and workplaces - in our food and water, our clothes, our carpets, ourcleaning fluids and heating vents - may be dangerously undermining human, as well as ecological,health. Yet, these warnings have been largely ignored. History has taken things far past the pointwhere human beings could envision living without some of the services synthetic chemical provide,but it has also taken all to the point where the problem can longer be shrugged off from suchwarnings.

Today, there are roughly 70,000 different synthetic chemicals on the global market, and manyothers are emitted as by-products of their production or incineration.

Pesticides are designed to be usefully lethal. Many, however, are not meant to have toxic effects,or are not meant to come in contact with living creatures in any case, yet turn out to be both highlytoxic and pervasive. For example, when polychlorinated biphenyls (PCBs) were created in 1929,they were intended only for use in electrical wiring, lubricants and liquid seals. But old buildings aredemolished and old machines are junked, and the residues that remain in them - some proving tobe dangerously toxic - often leach into the ground water. Today, these PCBs - along with morethan 250 other synthetic chemicals - can be found in the body of almost anyone who lives in thedeveloped world. Furthermore, since a mother will pass some contaminants on to the developingfoetus during pregnancy, even an unborn child is at risk of exposure. It has been estimated that amother's exposure to some persistent chemicals will still be detectable five generations later.

12

Annex-HBackground information of the obsolete pesticides ProblemExposure can occur almost anywhere. Pesticides such as Dursban and methoxychlor are sprayedin offices and schools without the knowledge of workers or students. Other chemicals are pumpedinto livestock and poultry or sprayed liberally over fruits and vegetables only to show up on thedinner table. They are absorbed into the body through mouth contact with soft plastic toys orpacifiers, through skin contact with synthetic fabrics, and through direct consumption. Ironically,some of the chemicals most specifically intended to protect human health - by killing pests thatwould otherwise infest food - end up having the opposite effect: The residues accumulate in thetissues of people who are vulnerable to long-term exposure, whereas the rapidly reproducing pestsmutate fast enough to develop resistance.

Many of these chemicals will persist and build up in the environment long after they are released.For example, chemists estimate that the solvent chloroform, which is toxic to birds, fish andhumans, will persist in water for 1,850 years. Yet, it is continually being dumped into rivers or lakesvia municipal waste treatment plants and accidental spills. Phorate, an organophosphorusinsecticide, was used around a South Dakota wetland at only three-quarters of the recommendeddose yet persisted through the winter despite assurances from the US Environmental ProtectionAgency that it would degrade. The following year, it killed a number of waterfowl. Thecontaminated fowl were scavenged by bald eagles, which also died.The most notorious of the persistent chemicals are organohalogens: carbon-based substancescontaining chlorine, fluorine, bromine or iodine. The majority is chlorine containing, ororganochlorines. Around 11,000 organochlorines have been identified, most of which do not occurnaturally. They include roughly 50 pesticides such as toxaphene and DDT(dichlorodiphenyltrichloroethane); solvents such as perchloroethylene; and multiple-use chemicalssuch as PCBs. However, the relative indestructibility of these chemicals, a boon for industry, hasbecome a threat to the environment.

As these chemicals accumulate in human bodies and surroundings, so too does the evidence oftheir harmful effects. Although there is an indisputable connection between certain chemicals andcertain diseases

In addition to suppressing the immune system, manufactured chemicals may be wreaking otherinsidious form of damage. In the last few years, a growing body of reports has suggested thatPCBs, DDT and at least 50 other chemicals now at large in the environment may be harmful toreproduction and development - both in wildlife and in people. Some scientists believe that thesechemicals are interfering with the endocrine system - the body's hormone-making and signallingsystem, which regulates growth and development as, well as behaviour and brain function.According to their findings, some of these chemicals are mimicking natural oestrogens - spreadingan insidious kind of biological confusion. Others are blocking the effects of natural hormones andaltering their effectiveness. Although the mechanisms remain puzzling, reports of subtle,chemically induced effects on reproduction and development have been building.Because persistent pollutants can contaminate locations far from their source, effectivemanagement of persistent organic pollutants (POPs) may not be possible without implementationof a comprehensive international agreement. The International Forum on Chemical Safety (IFCS),a cooperative group of government representatives and non-governmental organizations for thepromotion of environmentally sound management of chemicals, has made a very modest start bycalling for the reduction, and eventual ban, of 12 persistent organic pollutants.In the absence of any viable means of keeping up with testing and screening, the histories of DDT,chlordane and PCBs will likely repeat themselves. Ultimately, there may be no realistic choice butto undertake a sweeping, worldwide search for non-chemical alternatives.

13

ANNEX-IEthiopia Scooing Statement Phase-I

PREVENTION AND DISPOSAL OF OBSOLETE PESTICIDE STOCKS IN ETHIOPIA ............... 21. PR EFACE .................................................................

22. GENERAL PROJECT DESCRIPTION .............................................

23. ENVIRONMENTAL ASSESSMENT ISSUES ........................................

43.1. SIG N IFICA N T ISSU ES .................................................................

43.1.1. Current environmental threat ..........................................43.1.2. Removal of pesticides from storage sites .................................53.1.3. Store and site decontamination .........................................63.1.4. Transportation of pesticides and related hazardous materials .................. 63.1.5. Centralisation store location and upgrade ................................. 63.1.6. Transboundary transportation of hazardous waste ..........................3.1.7. Destruction or treatment of the pesticides and other waste .................... 73.1.8. Community awareness ...............................................

S3.1.9. Prevention measures ................................................3.1.10. Environmental monitoring .............................................8

4. CONTENT AND FORM........................................................9

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ANNEX-IEthiopia ScoDing Statement Phase-I

PREVENTION AND DISPOSAL OF OBSOLETE PESTICIDE STOCKS IN ETHIOPIA

SCOPING STATEMENT DOCUMENT FOR AN ENVIRONMENTAL ASSESSMENT

1. PREFACE

The USAID environmental regulation 22 CFR 216, commonly known as REG 16, establishes theprocedures necessary for environmental review of USAID activities. The regulations define a class ofactions normally considered to have a significant effect on the environment. Such actions require thepreparation of an Environmental Assessment. A significant effect is defined by REG 16 to meanadverse effects.

2. GENERAL PROJECT DESCRIPTION

An estimated 1,500 tonnes of obsolete pesticides are threatening the health of the Ethiopian peopleand contaminating their environment. These stocks have accumulated over the past forty years for acombination of reasons including lack of co-ordination in donations and procurement, inappropriateproduct supply, poor storage conditions and stock management, and oversupply of products.

The legacy of years of neglect and mismanagement can be found today in over 400 stores, whichcontain leaking drums and burst sacks of some of the most hazardous and toxic pesticides evermanufactured. Many of these products are banned for use internationally, yet in Ethiopia they exist inhuge quantities.

The Netherlands Government has funded the FAO programme on obsolete pesticides since 1994.The programme has made continuous efforts to put the issue of obsolete pesticides high on theinternational agenda and to inform donor governments, international organisations and the pesticidemanufacturing industry of the scope of the problem with the aim of generating support for disposaloperations.

As a result of such efforts, large-scale disposal operations have been successfully carried out to clearYemen, Zambia and Seychelles of obsolete pesticides. Various donors have similarly completedadditional disposal operations independently. The problem of obsolete stocks in Ethiopia is far moreserious than any project proposed by FAO to-date. The sheer size of the obsolete stocks, initiallyestimated at over 1,150 tonnes plus a minimum of 500 tonnes of grossly contaminated soils, dwarfssimilar problems in most other developing countries.

The obsolete stocks in Ethiopia were a major discussion topic at the Third FAO Consultation held inRome in March 1998. Due to the gravity of the problem it was decided to organise an expert taskforceto report back on the scope of the problem, the actual state of the obsolete stocks and to formulate adisposal strategy. The taskforce visited Ethiopia in November/December 1998 and found:Prevention and Disposal. Ethiopia Project 1999 2http7l/www fRo nrn/WAICENT/FAOINFOIAGRICULT/AGP/AGPP/Pestirid/Dlispos2l/default htm formerly andnow http//ww'v fanoorg/ag/obstocks htm

ANNEX-IEthioDia Scoping Statement Phase-I

- The estimate should be over 1500 tonnes excluding heavily contaminated soil, which is estimatedat a minimum of 500 tonnes, with the final figure likely to be over to 1000.* The pesticides are stored in over 400 sites. Materials are not stored in compliance with the FAOguidelines on pesticide storage. Materials are not segregated and little care is taken to ensureincompatible materials do not mix.* Many of the locations pose serious health hazards and the risk of fire at some stores is a reality.The stores represent a chemical time-bomb with a very short fuse due to the deterioration ofpackaging material and inevitable mixture of chemicals.* Many stores are located in areas of high water tables and on flood planes or in close proximity tohousing and work places. The inadequate containment of the pesticides means that people areconstantly exposed to unacceptable levels of contamination in their water, air and food.a A number of the stores visited are in urban areas. Of particular note is the main Addis storemanaged by the Ministry of Agriculture. The store is in urgent need of emergency repair assections of the prefabricated roof and walls have fallen into disrepair. At this store pesticides arestrewn over the floor area of the building. Leakage and contamination of large areas of ground isclearly visible. Problems of odour are evident and dust migration over the site poses a real risk tothe public. Critically, this store is positioned adjacent to the main grain silo in Addis Ababa andclose to residences. This store was described by Task Force members as "one of the worst sitesever visited".

* The situation in-terms of stock management is more serious and urgent than was anticipated.Spillage and contamination of soils is widespread and the detrimental effect to the population andthe environment cannot be underestimated.* Owing to enormity of the quantities involved, and their widespread distribution, the disposaloperation will have to be completed as a series of phases, each requiring careful definition andprecise planning.

Currently Ethiopia does not have any disposal facility of its own. The preferred means of destruction ofthe types of waste found on the inventory is high temperature incineration. This conclusion and allother recommendations on disposal are in keeping with current FAO guidelines. The process involvesrepackaging of the obsolete stocks in UN approved containers and shipping them overseas wheresuch disposal facilities are operated.

The project for the prevention and disposal of obsolete pesticides in Ethiopia is a two year $4.5 millionproject designed to remove all known obsolete pesticide stocks from Ethiopia and strengthen nationalcapacity for the prevention of any future accumulation of obsolete pesticide stockpiles. Currently anestimated 1500 tonnes of obsolete pesticides and their containers, and an additional estimated 1000tonnes of heavily contaminated soil are dispersed in 402 identified storage locations throughout thecountry. The project will be coordinated by FAO in partnership with the Ministry of Agriculture CropProduction and Protection Technology and Regulatory Department.

The project consists of four phases which are:1. Training, site upgrade, and centralisation of stocks.2. Commissioning of laboratory and analysis of unknown materials.3. Issue of Tender for overseas disposal.4. Repackaging, transport and disposal of identified stocks.

Prevention and Disposal. Ethiopia Project 1999 3http /Iwww-fagoorg/WAIC(FNT/FAOI NFO/AGR ICUI T/AGPlAGPP/Pesticid/DisposaI/dpfariIlt htm formerly andnow http //www.fao. orolac/bstocl .s htm

ANNEX-IEthiopia Scoping Statement Phase-I

A concurrent parallel activity will address future pesticide management systems and prevention ofaccumulations.

The project proposal document Project prevention and disposal of obsolete stocks inRepackaging, transport and disposal of identified stocks. Ethiopia. MIAW - 10/98;GCP/INT/650/NET; 34 issued by FAO provides details of the background, operational strategy,organisational structure, costs, timeframe, Government obligations and beneficiaries from this project.

US-AID is a co-funder of this project in conjunction with other funding bodies. Of a total project cost of$4.5 million, US-AID has agreed to contribute $1.0 million which is to be fully utilised by 31 December2000. Other funding sources include the Government of the Netherlands, Sweden and contributions inkind from the Ethiopian Government. The Global Crop Protection Federation (GCPF) has also statedits willingness to make some contribution towards this project.

This scoping statement which identifies the issues to be addressed in the environmental assessmentof the project for the prevention and disposal of obsolete pesticide stocks in Ethiopia shall be reviewedand approved by the Africa Bureau Environmental Officer.

3. ENVIRONMENTAL ASSESSMENT ISSUES

3.1. SIGNIFICANT ISSUES

3.1.1. Current environmental threat

At present the health of local people and the quality of their environment may be severelycompromised by the presence of the obsolete pesticides and the conditions of their storage. Thethreat is common to some degree in all 402 storage locations which have thus far been identified.

Examples include a storage site adjacent to a tree nursery, a chicken farm and a well where there isclear evidence of pesticide leakage. Another site consists of several hundred full pesticide drums inthe open standing above a high water table and in a river flood plain. A third example in Addis Ababaconsists of a damaged corrugated iron structure close to a major grain storage facility and residentialarea. This storehouse has a large quantity of spilled, mixed pesticides which are partially exposed tothe elements.

The pesticides which have been identified throughout the stores are of a wide range of chemicalgroups and formulations many of which have been extensively studied and are known to presentserious adverse effects on human health and the environment. The pesticides are able, by virtue oftheir various physical and chemical properties to enter all environmental compartments and can enterhuman, other animal and plant organisms through various pathways.

Recommendation: The environmental assessment will identify, to the extent known, theenvironmental hazards presented by the current situation and explore the extent to whichthese hazards will be addressed by the project. This assessment will be based on an inventoryof known obsolete pesticide stocks and site visits to sample stores to assess the extent towhich the current situation threatens health and the environment. Assessment of the risk tohealth and the environment from the current situation will be based on visual assessment ofPrevention and Disposal. Ethiopia Project 1999 4http://www fanoorg/WAICENT/FAOINFO/AGRIC. LI T/AGP/AGPP/Pesticid/Dispnsaldefauit-htm fonrerly andnow http//www fau.oraglobstocks htm

ANNEX-IEthiopia Scoping Statement Phase-l

sample stores by experienced persons, but will not include detailed environmental samplingand analysis due to cost and time constraints.

3.1.2. Removal of pesticides from storage sitesDisturbance of existing chemical stores and the movement of chemicals may expose those working atthe sites to severe hazards and may cause additional environmental dispersion of hazardousproducts. This could result in exposure of people working nearby and other local inhabitants and theenvironment at large.

The chemicals in some of the stores have lain relatively undisturbed, in some cases for more than adecade. While many compounds have leaked from their containers as a result of chemical corrosionor physical trauma, any distribution through the environment has been entirely passive. The physicalmovement of these chemicals which will be required in order to remove them from their storage sitescould potentially contribute to further environmental dispersal.

Recommendation: The environmental assessment will identify the potential for personal orenvironmental contamination which may arise from the removal of pesticides from their storage sitesand which could compound existing contamination.

The environmental assessment will also determine:

* the potential risks to the health of persons working directly on the removal of pesticides from theircurrent storage sites and other persons who may be affected, and make recommendations on themitigating actions which should be employed including training, engineering controls and personalprotection;* Action to be taken in dealing with leaking containers and materials contaminated by the leakage ofpesticides from their original containers;

Prevention and Disposal. Ethiopia Project 1999 5http7/lww fno org/WAICENTIfAOI NFOIAGRICUI iT/AGP/AGPP/Pesticid/Dispossl/Idefault-htm

formerly andnow htti2/l/www fao org/ag/obstocks htri


3.1.3. Store and site decontamination

The stores and sites in which the pesticides are currently held will themselves be contaminated tovarying levels, depending on the degree to which pesticides have leaked from their containers and thetype of chemicals released. Other factors which will affect the level of contamination include soil type,climate, topography and chemical formulations.

Structures in which pesticides have been stored may in the future continue to be used for pesticidestorage, or possibly for other uses. Similarly sites on which pesticides or containers have stood forlong periods are also likely to be used for any number of purposes.

At each of the currently identified 402 sites the target for decontamination should be highestachievable level. A major factor influencing this target will be cost. Nevertheless, minimum standardsshould be determined which should be achieved as a result of this operation.

RECOMMENDATION: The environmental assessment will identify the potential for maximumsite decontamination within the scope of this project. It will also make recommendationsregarding additional action which should be taken where full decontamination may not beachievable.

3.1.4. Transportation of pesticides and related hazardous materials

Phase 1 of the project entails centralisation of stocks in eight regional stores. This operation willrequire transportation of pesticides and contaminated materials sometimes over long distances and indifficult conditions. This may create the potential for wider environmental contamination due toadditional dispersal of the chemicals.Recommendation:

The issues which the environmental assessment will address are:The integrity of pesticide containers to be transportedLabelling of containersThe type of vehicles usedMarking of vehiclesDriver and other staff trainingEquipment of vehicles and staff transporting the pesticidesCondition of roadsClimatic conditionsDecontamination of vehicles in relation to their future use

3.1.5. Centralisation store location and upgrade

The eight centralisation stores identified will be used for the reception and temporary storage of verylarge amounts of pesticides, containers and contaminated soil. In many cases the amounts willPrevention and Disposal. Ethiopia Project 1999 6httpW/www-fan ro/WAICENT/FAOINFC/,AGRICULI T/AGP/AGPP/Pestirid/Disposl/defauilt htm fornerly andnowv http//www faqoio-/ag/ohstocks htm

ANNEX-IEthiooia Scoping Statement Phase-I

significantly exceed 100 tonnes and in some cases over 200 or 300 tonnes.

The stores will need to be large enough to accommodate the arriving pesticides and will need to beserved by a well developed infrastructure to ensure safety and security at the sites.Recommendation: The location of the stores will be evaluated on the basis of local knowledge toensure that the safety of local populations and environmental protection will not be compromised bythe albeit temporary enlargement of the stores.

3.1.6. Transboundary transportation of hazardous wasteThe transboundary transportation of hazardous waste is regulated under the Basel and BamakoConventions which are primarily designed to protect countries receiving the waste. The marinetransport of hazardous materials is governed by the International Maritime Dangerous Goods Code.Phase 4 of the project entails repackaging, transport of the waste out of Ethiopia to their final place ofdestruction, and the destruction process itself. Consideration must be given to the requirements of theappropriate international control mechanisms and the way in which they will be applied in this project.RECOMMENDATION: In complying with the legislative requirements governing thetransboundary transportation of hazardous materials safety and environmental concerns willbe fully addressed. The Environmental Assessment will ensure that this is the case andaddress related issues such as port facilities to be used for shipments.

3.1.7. Destruction or treatment of the pesticides and other waste

Various technologies and methods exist which can neutralise, destroy or otherwise render pesticideand related waste materials harmless or useful. The most widely used method in the treatment ofobsolete pesticides from developing countries is high temperature incineration in dedicated hazardouswaste incinerators in Europe. This is also the method proposed in this project.Recommendation: The environmental assessment wi/l consider the various options which representalternatives to the proposed course of action. Some of these options will require management of thewaste in Ethiopia as opposed to transportation to another country. The viability, practicability andenvironmental impact of these altemative options will be explored in the environmental assessment.

Prevention and Disposal. Ethiopia Project 1999 7http/ww8 fno org/WAICFNT/FAOINFFO/AGR lC L]LT/AGP/AGPP/Pesticid/Disposal/default.

htm formerly and-now http7lwvww.fao.org/ag/obstocks.htm


3.1.8. Community awareness

Despite widespread media coverage during the Task Force mission of November/December 1998when the project was formulated, there appears to be a very low level of public awareness about thisproject. This is largely because the obsolete pesticides are owned by institutions and are on the wholeheld in secure buildings or compounds out of public contact.

The appearance of teams using personal protective equipment and the sudden activity at sites whichhave previously been dormant for years for the purposes of this project is likely to generate interestand concern.

Recommendation: Ways in which community awareness to the project using appropriate networksand communication channels will be explored.

3.1.9. Prevention measures

The prevention of future accumulation of obsolete pesticides is an integral element of this project.Recommendations and guidelines have been published by FAO which can help in the developmentand implementation of effective prevention strategies.

Prevention measures fall into four main categories and include regulation, procurement and supplycontrols, pesticide use and the management of waste materials.

Recommendations: The Environmental Assessment will determine the extent to which measuresaddressing these issues are already in place or in development. It will also determine the ways inwhich the project will support the development and implementation of prevention measures.

The environmental assessment will also investigate role of rural communities in future preventionstrategies to help avoid the accumulation of pesticides.

3.1.10. Environmental monitoring

The potential benefits to the Ethiopian people and the environment from successful completion of thisproject are significant. However, during its implementation significant hazards to both health and theenvironment may be generated. Many layers of safeguards exist including measures written into theproject document, professional guidelines, national and international law. Adherence to these shouldensure a high level of environmental protection.

Recommendation:The environmental assessment will determine what environmental monitoring procedures arein place and who the responsible parties are for monitoring and for addressing inadequaciesof relevant issues which arise from monitoring processes during the course of the project.

Prevention and Disposal. Ethiopia Project 1999 8httpIf/www.faa ooQmWAICENT/FAOINFO/AGRICU LTfAGP/AG PPIPcsticid/Dsposni/defait htm formerly andnow http:!Iww.wfan org/a2Iobstocks.htm


4. CONTENT AND FORM.

The Environmental Assessment shall be based upon the scoping statement and shall address thefollowing elements, as appropriate:

1. Summary

The summary shall stress the major conclusions, areas of controversy, if any, and theissues to be resolved.

2. Purpose

The Environmental Assessment shall briefly specify the underlying purpose and need towhich the Agency is responding in proposing the alternatives including the proposedaction,

3. Alternatives Including the Proposed Action

This section should present the environmental impacts of the proposal and its alternatives inr comparative form, thereby sharpening the issues and providing a clear basis for choiceamong options by the decision-maker. This section should explore and evaluate reasonablealternatives and briefly discuss the reasons for eliminating those alternatives which were notincluded in the detailed study; devote substantial treatment to each alternative considered indetail including the proposed action so that reviewers may evaluate their comparative merits;include the alternative of no action; identify the Agency's preferred alternative or alternatives,r- if one or more exists; include appropriate mitigation measures not already included in theproposed action or alternatives.

4. Affected Environment

The Environmental Assessment shall succinctly describe the environment of the area(s) tobe affected or created by the alternatives under consideration. The descriptions shall be nolonger than is necessary to understand the effects of the alternatives. Data and analyses inthe Environmental Assessment shall be commensurate with the significance of the impactwith less important material summarised, consolidated or simply referenced.(1) Environmental Consequences

- This section forms the analytic basis for the comparisons under paragraph (c)(3) of thissection. It will include the environmental impacts of the alternatives including the proposedaction; any adverse effects that cannot be avoided should the proposed action beimplemented; the relationship between short-term uses of the environment and themaintenance and enhancement of long-term productivity; and any irreversible or irretrievablecommitments of resources which would be involved in the proposal should it beimplemented. It should not duplicate discussions in paragraph (c)(3) of this section. ThisPrevention and Disposal. Ethiopia Project 1999 9httpI2//www-fao,ogM/WAICENT/FAOINFO/AGRICULTIACP/AGPP/Ppstridd/Dispos-/lldeftult

htm formerly andnow httpi/fwww-fao-org/ag/ohstockS.htm

ANNEX-I- Ethiopia Scoping Statement Phase-I

section of the Environmental Assessment should include discussions of direct effects andtheir significance; indirect effects and their significance; possible conflicts between theproposed action and land use plans, policies and controls for the areas concerned; energyrequirements and conservation potential of various alternatives and mitigation measures;natural or depletable resource requirements and conservation potential of variousrequirements and mitigation measures; urban quality; historic and cultural resources and thedesign of the built environment, including the reuse and conservation potential of variousalternatives and mitigation measures; and means to mitigate adverse environmental impacts.

(2) List of Preparers

- The Environmental Assessment shall list the names and qualifications (expertise,experience, professional discipline) of the persons primarily responsible for preparing theEnvironmental Assessment or significant background papers.

r

a-

!-

Prevention and Disposal. Ethiopia Project 1999 10

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ANNEX-JEthiopia Disposal Project Phase-1: Terminal Report

AG: GCPI/ETH/059/NET; GCPIETH1061/SWE; GCPIETH/058/USA

Terminal Report: Ethiopia Phase-I

ETHIOPIA TERMINAL REPORT REFLECTING SAFEGUARDING ANDDISPOSAL OF OBSOLETE PESTICIDE STOCKS

FAO/GOVERNMENT COOPERATIVE PROGRAMME

Prevention and Disposal of Obsolete Pesticide Stocksin Ethiopia - Phase I

Federal Democratic Republic ofETHIOPIA

PROJECT FINDINGS AND RECOMMENDATIONS

Report prepared for:The Governments of:

EthiopiaNetherlandsSwedenUnited States of America

FOOD AND AGRICULTURE ORGANIZATION OF THE UNITED NATIONS

Rome, January 2004

Terminal Report: AG: GCPI/ETHI0591NET; GCP/ETH/061/SWE; GCP/ETH/0581USA

ANNEX-J

The designations employed and the presentation of the material in this document do not implythe expression of any opinion whatsoever on the part of the Food and Agriculture Organizationof the United Nations concerning the legal status of any country, territory, city or its authorities,or concerning the delimitation of its frontiers or boundaries.

The Food and Agriculture Organization is greatly indebted to all those who assisted in theimplementation of the projects by providing information, advice and facilities.

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ANNEX-JTable of content

Page1. Introduction ............................... ....................... .41.1 Background to the project ...........................................

41.2 Outline of Official arrangements .......................................51.3 Objectives of the projects ................................ ........... 62. Results and Conclusions ..............................................72.1 Results ........................................................

2.1.1 Training, site upgrade, and centralisation of stocks: ........................72.1.2 Commissioning of laboratory and analysis of unknown materials: ..............82.1.3 Issue of Tender for overseas disposal: ................................. 82.1.4 Repackaging, transport and disposal of identified stocks: ....................92.1.5 Other matters that warranted further study: ............................. 102.1.6 Staffing ......................................I..........102.1.7 Independent monitoring

1..........................................2.1.8 Expenditures incurred: ...........................................12* 1) Balance of US$ 1,184 to be used for terminal reporting costs ................... 122.1.7 Difficulties encountered and solutions found: ............................ 132.2 Conclusions: 14...............................................

3. Recommendations .................................................. 164. Appendices ....................................................... 18Appendix 1: Project Staff ................. ....................... 18Appendix 2: Major Items of Equipment Supplied ............................. 18Appendix 3: List of Project Publications ................. ................... 19Appendix 4: Abbreviations .................. .....................

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1. Introduction

1.1 Background to the projectEthiopia, like most African countries, accumulated stockpiles of obsolete, banned and unwanted

pesticides over a period of many years. These are pesticides of which the use has been stopped forenvironmental or health reasons and pesticides that can no longer be used because they havedeteriorated as a result of prolonged storage. Obsolete pesticides are considered hazardous wasteand should be disposed of in an environmentally safe way.

In Ethiopia most of the obsolete pesticides were kept in sub-standard stores, some of whichlacked impermeable floors and/or had poor ventilation. At some locations containers were stored inthe open, exposed to direct sunlight, wind and rain, while many stores were accessible tounauthorised persons. As time goes by, containers deteriorated, corroded and started leaking, whilebags deteriorated and tore, spilling the contents on floors or directly on the soil. This process isaccelerated by unfavourable climatic conditions and high temperatures inside poorly ventilated stores.High temperatures also increase the pressure inside drums which subsequently leads to leakage. Theresult is a high incidence of leakage and a large number of severely contaminated stores while inmany cases the characterisation (name of the pesticide, manufacturing information etc.) of thecontaminated material or containers is missing and therefore require chemical analysis.

The technical, financial and institutional capabilities of the national institutions within the countryto take safeguarding measures and dispose of stockpiles of obsolete pesticides were consideredweak. As a result, various stocks of obsolete, banned and unwanted pesticide were scattered all overthe country, creating "hot spots" carrying significant environmental and public health risks, sometimesin the heart of densely populated urban areas (such as in Addis Ababa).

Various factors contributed to the accumulation of obsolete pesticides:

* Lack of appropriate storage facilities, poor coordination between the decentralized services ofthe Government ministries themselves and with other stock holders to optimally manage thedifferent stocks and finally, poor management capacities of the stocks (no regular inventory,inexistent stock positions, no feedback of centralized information, no monitoring procedures );

* Overstocking of pesticides, often as a result of excessive donations, wrong assessment ofneeds, poor stock management capacities, lack of co-ordination among different governmentinstitutions such as one importing, the other not releasing stocks on arrival at ports and thusleading to pesticides becoming obsolete before being cleared from customs;

* Ethiopia is also one of the eastern African countries which suffer from migratory pests,particularly desert locust and armyworm outbreaks. The ensuing crisis mobilization ofinternational assistance to combat the pests has resulted in sometimes excessive emergencyprevention stocks, overestimated need assessments, late arrival and other causes that havelead finally to the building up of obsolete stocks;

• Unsuitable products (not effective, wrong formulation) or unsuitable packaging (inappropriatesize; not stable; imported close to the expiry date of shelf-life) of pesticides that finally do notmeet the beneficiaries' needs;

. Banning of some pesticides while still in store or even still being purchased or locallyproduced;

* Decreasing demand in pesticides due to changes in agricultural policies, but above all to thereduction of the income in the agricultural sector;

a Lack of appropriate Government policies supporting or enhancing the use of alternativemethods of pest control such as biological control and in particular IPM;


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ANNEX-J. Lack of control or restrictions on trade of pesticide vendors and distributors, which often

exaggerate and advertise the benefits of pesticide use only with the focus to promoteaggressive sales and distribution of (sometimes highly dangerous) pesticides;And finally, lack of thoughtful planning of country requirements, poor selection of pesticides,inappropriate packaging and labelling of products, absence of stock management in stores,significantly contributed to accumulation of obsolete pesticide stocks.

In Africa and also in Ethiopia empty pesticide drums and containers are highly valued in bothrural and urban areas and are commonly used for domestic purposes. Hence contingency plans todispose also of pesticide containers would have to be developed and widespread awareness of thedanger and implications of the use of pesticides and containers would have to be undertaken.

Ethiopia, like all other countries in Africa, does not have safe environmentally acceptable wastedisposal facilities. The absence of appropriate facilities, combined with lack of funds for proper storageand maintenance of stocks, continued to lead to an increased accumulation and a no-action situationuntil about 1996.

The Federal Government of Ethiopia became aware of the enormity and the urgency of theproblem and decided to undertake countrywide surveys to determine the extent of the environmentalhazard and the risks to human life. In this connection a total of 700,000 Birr (approximately US$84,000) was spent allowing identifying preliminary quantities of stocks and contaminants.Subsequently a total of 1.8 million Ethiopian Birr (approximately US$ 215,000) was invested inupgrading a pesticide chemistry laboratory in Addis Ababa for analysis purposes. Based oninventories that became available in December 1997, and on the findings of an international task forcemission fielded in October 1998 (financed by Sweden), Ethiopia was identified as having the largestdocumented accumulation in sub-Saharan Africa, with more than 1,500 tonnes of over 200 differenttypes of obsolete, banned and unwanted pesticides (and an estimated 500 tonnes of heavilycontaminated soil) in 402 stores in 256 locations throughout the country.

Following the FAO-organised Third Consultation meeting held in Rome (March 1998) theFederal Government of Ethiopia invited in December 1998 in Addis Ababa donor interest in aconcerted programme to rid Ethiopia of its large stock of obsolete pesticides and heavily contaminatedsoil. The Ethiopian disposal and prevention programme would be mounted as a multi-donor andprivate sector co-financed operation, with a significant contribution of the Federal Government ofEthiopia. The costs to dispose of the provisionally identified 1,500 tonnes of stocks, including the mostheavily contaminated soil, were at that time estimated at approximately US$ 4.6 million. TheNetherlands, Sweden acting through SIDA and the USA acting through the USAID agreed to sharethe financial burden in separate FAO/Government Cooperative Programme agreements carrying thesame title: Prevention and Disposal of Obsolete Pesticide Stocks in Ethiopia - Phase 1.

Furthermore the Global Crop Protection Federation (representing the chemical industry - nowthe Crop Life International) pledged to contribute US$1 per kilo of stock attributable to its membercompanies. A cash contribution of Euro 860,000 towards incineration costs of obsolete pesticidesunder Phase I is still at present under negotiation but is likely to come forward soon.

1.2 Outline of Official arrangements

* The United States of America was the first donor to make a firm commitment:The project agreement was signed by the USAID and FAO in September 1999. The projectGCP/ETH/058/USA became operational in November 2000. The grant agreement was originallyscheduled to end on 10 December 2000. The grant was subject to conditions, in particular the


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ANNEX-Jidentification of additional donor(s), and an adequate environmental review. Once the commitmentsfrom the two other donors became official and after the preparation of the environmental review theproject was extended to December 2001 and later on until December 2003.The total approved contribution of the USA/USAID was US$ 1,000,000.

0 The Netherlands:The project agreement was signed by the Government of the Netherlands and FAO in July 2000. Theapproval took place soon after that the FDRE had ratified the Basel convention that was mentionedearlier during negotiations as a condition for the grant approval. Subsequently projectGCP/ETH/059/NET became operational in September 2000. It was scheduled to end on 31 August2003 and was later on extended until December 2003.The total approved contribution of the Netherlands was US$ 2,250,000 (at the official exchange rate ofNLG 5,355,000 at the time of signature).

- Sweden:The project agreement of GCP/ETH/061/SWE was signed by SIDA in May 2001 acting on behalf ofthe Government of Sweden and FAO and became operational in June 2001. It was scheduled to endon 30 June 2003; this date was later on extended until December2003.The total approved contribution of Sweden/SIDA was US$ 1,185,770 (at the official exchange rate ofSwedish Kronor 12,000,000 at the time of signature).

The total amount of the donor contributions was US$ 4,435,770.FAO was designated as the agency responsible for the implementation of the above threeclosely related and complementary projects. FAO would set up a management team that would bebased in the Crop Production and Production Technology and Regulatory Department in Addis Ababathat would provide office space and administrative support. All direct managerial control of localpersonnel who would be responsible for the day to day activities would remain with the appropriateEthiopian Government Department mentioned before.The technical overall supervision of the professional field staff was entnusted to the ObsoletePesticides Prevention and Disposal Office based at AGPP/AGP at FAO Head Quarters in Rome andwould include supervisory field visits.

The in kind contribution of the FDRE was estimated at 1,716,735 Ethiopian Birr (US$ 210,790)that would cover the provision of a project office, administrative staff and local labour.

1.3 Objectives of the projectsThe signed project agreements were based on a mission document prepared by amultidisciplinary taskforce fielded in October 1998. The Swedish International Development Agencycontributed the financial support for the quoted mission.The mission report provided a number of recommendations that were translated into a projectproposal with a phased strategy for elimination of the obsolete stocks. The aim of the phasedprogramme was to provide a co-ordinated approach involving all the stakeholders in the operation,including Plant Protection, FAO, pesticide suppliers and distributors, pesticide owners, disposalcompanies and NGOs.

The identified phases (to be considered as "objectives") of the operation and the relatedactivities were defined as follows:


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Phase 1: Training, site upgrade, and centralisation of stocks:

* Comprehensive training of personnel responsible for the initial collections of material andtransportation to the centralisation points;

* Selection of central stores based on geographical regions;Upgrade of facilitiesTransfer of obsolete stocks to eight strategic sites;

Phase 2: Commissioning of laboratory and analysis of unknown materials:

Identifying unknown materials, improving the national laboratory;

Phase 3: Issue of Tender for overseas disposal:

. Preparation of full detailed bill of quantities and a tender for the proposed packaging,transportation and disposal operation;

Phase 4: Repackaging, transport and disposal of identified stock:

* Awarding of the disposal contract and issuance of destruction certificates.

These four primary phases/objectives were regrouped into only one: Phase I

The quoted project proposal document identified also other areas which warranted further study:

1. Development of local incineration capacity, via the cement works, for disposal of future wasteraisings;

2. The accreditation of the Plant Protection Laboratory to international quality standards(IS09002);

3. Government support for sustainable low input farming systems such as IPM;4. Government led education and awareness programmes to prevent the future generation of

pesticide related waste;5. In-situ decontamination of soils not deemed to be sufficiently heavily contaminated to warrant

their export and incineration;6. Establishment of mechanisms for the management of empty pesticide containers and small

quantities of waste pesticides.

2. Results and Conclusions

2.1 Results

2.1.1 Training, site upgrade, and centralisation of stocks:

When the FAO Project Manager arrived in April 2000 in Ethiopia it became soon evident that theinventory had to be completed and carefully checked as additional quantities of (obsolete or not)pesticides continued to be reported. Some doubts arose also about the accurateness of the assessedquantities in a number of stores as some seemed overestimated and others underestimated. 39 out-posted persons from the Department of Crop Protection, of Plant Health Clinics and extension workerswere called to a workshop in Addis Ababa to be trained in inventory taking and subsequently assignedto one or more of the 50 geographical zones in Ethiopia. At a later stage out of these 25 were


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ANNEX-Jselected on merits of their work in order to continue with the selected contractor after the completionof the inventory. The 39 member inventory team was provided with PPE (Personnel ProtectiveEquipment). The Project Management visited each trained staff in the field and verified the reportedinventories. As a result 2,900 tonnes of pesticides stocks were confirmed. Of these quantities about400 tonnes were found to be still usable after chemical analysis. The Government decided that these- pesticides would become a strategic stock for migratory pest control. This meant that no new ordersfor such pesticides needed to be placed until depletion of this stock. As it wasn't possible to dispose of2,500 tonnes while funding for 1,500 tonnes was secured through donor contributions it was decided- to prioritise disposal on the basis of a risk assessment: 283 sites with more than 2 tonnes of obsoletepesticides, near water, in particular rivers, lakes and near to inhabited places were selected as wasapproved by the Project Advisory Committee and the Government authorities.

Following discussions with the MoA and the Project Advisory Committee it was also agreed thatthe repackaging and collection to strategic locations in Ethiopia would now be added to the proposedcontract for shipment and disposal. This decision was made due to the high risks of exposure toworkers of seriously leaking containers in most stores. The appointed disposal contractor provided inthe beginning of its field operations in March 2001a two weeks training course for the selected 25persons (mainly personnel of the Ministry of Agriculture), who then worked as local counterparts in thecontract implementation. FAO, local Red Cross and Ethiopian staff contributed to the training course.The comprehensive training covered matters related to responding to chemical spills and worker* protection issues; transport of dangerous goods by sea, a first aid course and various organisationalsubjects such as working methods, work distribution, and equipment to be used.A total of 8 stores were selected for strategic central storage based on their location in thegeographical regions of the country.

These stores were upgraded to conform to FAO standards. This work was subcontracted tolocal companies following FAO procedures.

2.1.2 Commissioning of laboratory and analysis of unknown materials:The project arranged for the commissioning of laboratory equipment (provided in 1998 by UNDPand others) through services of the original manufacturer of the equipment that was eventually traced.The project furthermore delivered supplies, in particular chemicals and glassware (Appendix 2), to thenational analytical laboratory, arranged for the upgrading of computer software and for the training ofthe laboratory staff in the use of the commissioned equipment. The national laboratory in Addis Ababanow has the capacity to analyse, verify and classify known chemicals. The laboratory commissioningfacilitated the definition of approximately 400 tonnes of stocks that were still usable. These stockswere earmarked for storage and use as a strategic stock to control possible future migratory pestoutbreaks. Unknown and unidentified obsolete pesticides and materials were analysed in order toconform to the requirements of the International Maritime Dangerous Goods Code. These materialswere also repackaged under the contractual arrangem ent for final disposal.

2.1.3 Issue of Tender for overseas disposal:The international tender issued by FAO in August 2000 and awarded in October 2000 coveredthe safe repackaging, centralisation, analysis, transportation and final disposal of up to 2,500 tonnesof obsolete and unwanted pesticide stocks and heavily contaminated soil that was held atapproximately 458 locations.

The tender requested the contractor to bid for the following elements:1 Training of local staff;

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ANNEX-J2 Upgrade of a number of strategically placed stores to allow the safe centralisation of the obsolete

stocks;3 Safeguarding, repackaging and collection of the wastes to the refurbished interim storage areas;4 Decontamination of the stores to acceptable standards;5 Identification of unknown materials and verification of the inventory of obsolete pesticides by

accepted analytical techniques;6 Inland transport and export of the repackaged and identified obsolete pesticides and contaminated

soil for safe disposal in an environmentally sound manner outside Ethiopia;7 Disposal to the highest international environmental standards.

The estimated quantity of obsolete pesticides to be disposed of by this contract had to be reduced toapproximately 1,500 tonnes as was possible within the available donor contributions. Further disposaloperations of the remaining 1,000 tonnes had to be postponed to Phase II once additional donorcontributions would materialise.

2.1.4 Repackaging, transport and disposal of identified stocks:

The contract was awarded to a Finnish company (Ekokem Oy Ab) in March 2001.The last kilograms of a total of 1,508,563 kg of repackaged, obsolete pesticides transported overlandand by sea to Finland were incinerated by December 2003. The related destruction certificates wereprovided. The cost of the contract charged to the 3 projects amount to $ 3,147,617. The total costhowever amounted to US$ 4,060,230 (hence a part has to be financed by Phase II).A summary of the waste removed from Ethiopia in Phase I of the project based on geographicaldistribution is shown in the following figures:

Figure 1 shows that waste was removed from 10 Regions plus Addis Ababa. A total of 1575 tonnes ofstocks were repackaged from 243 locations / stores as indicated in Figure 2 below. It should be re-emphasised that these locations represented the priority sites in Ethiopia based on the quantity ofstocks, condition of the store and potential for impact on population and environment. The waste wasshipped to Finland for disposal at the high temperature incineration facility operated by Ekokem OyAb. A total of 98 shipping containers, holding 1507 tonnes of obsolete stocks were removed fromEthiopia, with the final shipment being dispatched on July 4rh 2003. The remaining 67 tonnes of stockwhich was repackaged is currently stored at the Regional Collection Centre in Addis Ababa, awaitinginclusion in Phase II of the disposal operation in Ethiopia.

Q Amhara O Amhara

0 Oroiya: Oromlya, AOfa°rmY 0 Ai fa°rm/ > Dire Dawa El Dire DawaE Gambela U GambelaE Somali E Somali* Harar U Harar* Benshan Gum * Benshan Gum* Tigray E TigrayO SNNP r SNNP

Figure 1. Tonnages of stocks removed from | Figure Z No. of stores cleared from Regions


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ANNEX-JTable 1 below provides the detailed information concerning final tonnages and numbers of storescleared from each region in Phase 1.

Addis |Afar Amhara B.G. Dire Gambela Harari Oromiyia Somali SNNP TigrayAbaba

DwTonnage 1 282 | 152 108 130 149 0 10 483 22 169 70-stores 10 j 20 32 6 8 0 3 109 2 26 27Table 1. Distribution of stocks and storage sites included In Phase I of the project

There was one accident when a truck carrying obsolete pesticides overturned. There were noinjuries and only minimal contamination as the result of the high standards of work of the repackaging.There have been no health or environmental incidents or accidents as part of the disposal operationand all work has being conducted to the required standards of health, safety and environment as setout in the original Project document. Independent monitoring of field operations has thrown up anumber of minor operational issues; the general independent review of activities has confirmed that alloperations are conducted to the highest standard and that no short cuts or dual standards have beenadopted. This is largely due to the continued excellent performance of the local Ministry counterpartstaff assigned on monitoring the day-to-day activities/performance of the specialist disposalcontractor.

2.1.5 Other matters that warranted further study:The subjects recommended to be given attention as identified by the field mission of the

Taskforce were the development of a local incineration capacity, accreditation of the Plant ProtectionLaboratory to international quality standards, Government support for sustainable low input farmingsystems such as IPM, Government led education and awareness programmes to prevent the futuregeneration of pesticide related waste, in-situ decontamination of soils not deemed to be sufficientlyheavily contaminated to warrant their export and incineration, and the establishment of mechanismsfor the management of empty pesticide containers and small quantities of waste pesticides.The available project funds being limited, the major activities of Phase I were concentratedon disposal and therefore these matters have been included in the objectives of Phase 11. However a

series of IPM initiatives for implementation across Ethiopia were drafted. The final projectdevelopment and initiation for these IPM proposals will be incorporated into Phase It of the disposaloperation. The documents were submitted to the Global IPM Facility at FAO Head Quarters forevaluation, comments and action through a parallel fund from the Government of Japan in November2003.

2.1.6 StaffingAn FAO Project Manager was assigned to the field from April 2000 to July 2002. At this time it

was decided that sufficient local capacity had been developed to allow management of the day to dayactivities of the project to be passed to the National Counterparts to the project. An officialcommunication to the Minister of Agriculture from the FAOR in Ethiopia was made in early August2002. In order to address possible concerns from the Government a management system wasproposed which was based on periodic, quarterly visits from the FAO project manager (PM) toEthiopia. During these missions the FAO PM performed the following tasks:

* Review progress and set objectives for the next period;


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ANNEX-J* Convene a meeting of the National Project Coordination Committee (NPCC) which

includes representatives from the project donors, involved ministries, NGOs andinternational organizations;

* Conduct field missions to assess contractor and national counterpart performance;* Review progress on prevention strategies, most notably pesticide procurement, pesticide

registration and IPM;* Hold meetings with existing and potential donors to the project;* Review expenditures and authorize payments as required;. Complete any additional tasks as they arise.

Six field missions were made on an approximately three monthly basis. This arrangement for technical- advisory support to the field activities operated satisfactorily and was less costly than the continued

full time presence of a Project Manager.

2.1.7 Independent monitoringThis component was fully funded by DFID through a direct grant to PAN-UK. Ten independent

monitoring missions were conducted during the project implementation by PAN-UK with increasingr involvement of local NGOs. The missions focussed on developments in IPM, prevention work inparticular through the strengthening of local NGOs and the review of the disposal operations in thefield and the effective management of the project. The issues addressed to the project managementr included recommendations for adjustments and modifications in the disposal operations or appliedprocesses where needed. These missions were considered very useful.

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ANNEX-J2.1.8 Expenditures incurred:Expenses in US$

Object of expenditure GC P/ETH/058/USA GCP/ETH/059/NET GCPIETHI061 /SWE TotalSalaries Professional

240,686 240.686Salaries Geneiral Service

Staff 75,162

75.162SalariesConsultants

36,530 36 530Locally Contracted Labour 132532813.285 13,285

Contracts 105,000 1,976,729 1.065,888 3,147,617Travel 134.809 1,288 136.097Training 43,776

43,776Expendable Equipment 36,404

36.404Non ExpendableEquionment ! 95,211 107,275 202,486Hospitality

89 _ _89General OperatingExpenses

102.212 102,212Surport Costs

115.652 145.971 74,612 336.235Total

998,816*1) 2,231,263*2) 1,140,500 4,370,579* 1) Balance of USS 1,184 to be used for terminal reporting costs.* 2) Balance of US$ 18,737 to be used for terminal reporting costs and payment of un-liquidatedcommitments.

Donor support to Phase I is summarised below in figure 3 below. Figure 4 shows the expenditures forPhase I by main subject matter:

2% . ODisposalOUSAJO |%

E LaboratoryoCLS d n

a rya ethe landa

OIP PM|9 ' t 115 DCI

9 2 J PManagtement

mentFigure 3. Donor support to Phase I in US$Mexoressed in %

Figure 4. Expenditure in Phase i


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ANNEX-JFigure 3 includes an estimated contribution from the pesticide manufacturers association, Crop LifeInternational (CLI). It is estimated that approximately E 860,000 will be contributed through the CLImembers to the disposal of stocks included in Phase I of the project in Ethiopia.

Figure 4 shows that the vast majority of funding for Phase I was spent on the cost of disposal. A totalof US$ 4.06M was disbursed for the disposal of the 1508 tonnes of obsolete stocks, equivalent to aunit price of approx. USS 2,700 per tonne (metric ton/1000kg). An appreciable amount of the fundswas also used to cover the costs of project management, including office set-up costs andprocurement of equipment such as vehicles and computers, training of national counterparts and localtravel / transport of the national staff.

2.1.7 Difficulties encountered and solutions found:

Incomplete inventoriesThe inventory had to be updated and adjusted over almost the whole project life span. Rightfrom the start of the field activities it became clear that the reported quantities and sites had to be

verified for accurateness and that therefore competent staff had to be trained for inventory purposes.In some cases the amount found was much higher than was reported and in others lower, mainly dueto misunderstandings on the dimensions of the containers or even due to continued use of obsoletepesticides. New storage sites were also reported once it became clearthatthe disposal operation wasserious. would not trigger sanctions of whatever kind to the owners or store managers and wouldbenefit the environment of people living near stores and therefore their eagerness to report thepresence of stores and stocks.

Even at present it is not fully sure whether all obsolete chemical agricultural input stocks havebeen reported. For example the Ministry of Health is still reluctant to declare any stocks whether theseare obsolete or not. This may be partly due to the presence in Ethiopia of a DDT formulation plant andthe continued use of DDT in malaria vector control as a cheap, but on the long term anenvironmentally dangerous and persistent chemical that is on the list of internationally bannedproducts. The Government authorities should study and encourage alternative control measures ofvectors.

Difficult road conditions and lonq distancesLogistic planning was complicated in particular during the rainy season. All movements betweenstores took much more time than anticipated due to road conditions, longer distances than wouldappear from road maps and sometimes the unavailability of adequate Lorries. It is therefore necessarythat the contractor visits all stores before any operational movement to the site is started and a goodassessment of the likely condition of the road during different seasons has to be made.

Lack of skilled local labourIt proved to be difficult to find skilled local labour able to communicate in English. To solve this issuethe national counterparts translated all the operational instructions. It also proved impractical to usenew labour at each site as the new workers would have to be trained from scratch again. It wastherefore agreed to use the same local workers during the whole repackaging and transport operation.This has probably contributed to the fact that no serious incidents occurred as the trained andexperienced workers knew exactly what to do.

Notification proceduresThe procedures according to the Basel Convention require notification of various countries throughwhich the hazardous waste has to travel (by road and by sea). Ethiopia as a recent signatory didn'thave experience in the notification process and it took time before the competent authorities of theBasel Convention expedited qualified staff to Ethiopia to train local staff in this matter. The notification


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ANNEX-Jprocess should preferably be completed before a repackaging operation is started, the exact routinghas been agreed with a shipping agent and various customs procedures verified and clarified.CustomsThe contractor met some difficulties with the importation of the necessary equipment and supplies.Interventions of the FAO Representative limited the loss in time of the contractor to a month.Ethiopia doesn't have direct access to the sea. Time-consuming problems were met with customs ofDjibouti which applied ever changing requirem ents. It resulted in the need to submit documentationthrough bureaucratic diplomatic government channels between the Ministry of Agriculture, theEthiopian Embassy and finally customs in Djibouti, but it proved to be workable. The feasibility ofexporting (part of) the waste through Eritrea could not be pursued due to civil unrest and militaryoperations.

Lack of shippinq containersThe lack of shipping container units in Ethiopia resulted in additional delay in the dispatch of therepackaged wastes from Ethiopia. In total over 2 months were added to the contract execution as aresult of the quoted unavailability of units.

2.2 Conclusions:

The conclusions that can be drawn from the project implementation and the produced outputs aresummarized as follows:

1. PrioritizationThe level of funds spent for prevention activities was lower than originally earmarked due tothe higher than expected stocks to be disposed. The final inventory identified over 2400 tonnesof stocks for disposal in over 940 locations compared with initial estimates of 1500 tonnes fromover 400 sites. The funds allowed however to prepare a draft national IPM framework forEthiopia and a draft priority plan for IPM in Ethiopia released in November 2003.

2. Role of the GovernmentThe commitment of the local counterparts from the Ministry of Agriculture was high and thenational personnel assigned to the projects were very cooperative. Their assistance wasimportant to find the best solutions for the flexible progression of the field operations.The cooperation of all Government institutions was also considered as generally verysupportive. The Government contributions for local labour took time to mobilize but ultimatelymaterialised. The collaboration of the Ministry of Health was however ambiguous. Untilrecently the MoH refused to fully participate in the project and to declare their stocks oninventory. Further dialogue has now resulted in the reporting of their obsolete stocks. Thesestocks are estimated to total over 200 tonnes of additional stocks to be included in the Phase11. However inclusion will though be subject to financial limitations currently faced.The Departmental Project Advisory Committee provided useful support to the project team.Their role is to advise the national counterpart staff on technical issues in the project whichrelate directly to the broader mandate of the crop protection department and also to offersupport in the project decision making process. The Committee was given regular updates onproject performance and asked to provide advice on important decisions such as the design ofthe second phase of the project. The committee was also responsible for assisting in the fieldactivities by conducting ad-hoc missions to working sites and the appraisal of activities.


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3. Role of the Chemical Industry

Through a tripartite committee involving FAO, NGOs and the Association of the ChemicalIndustry represented by Crop Life International (formerly the Global Crop ProtectionFederation-GCPF) discussions on sharing the incineration costs by the Chemical Industrycontinued during the implementation of Phase 1. It is now likely to result in a contribution ofEuro 860,000 towards the incineration costs of Phase 1, at present provisionally covered by acontribution for Phase 11 by the Government of Finland until a practical solution is found for thedeposit of funds. These discussions have been difficult and delicate as the Chemical Industryshowed initially to be reluctant to recognize its share of the responsibility in the building up ofobsolete pesticides. International pressure from various sources including NGOs, discussionsat international platforms and the help of mass media have brought about a productivecollaboration.

4. Role of the private sectorThe private sector offered in the past various types of incentives to staff involved in planningand distribution of pesticides creating a vested interest at various levels. The project, in therelatively short time span given, could not address these issues completely but triggered eitherdirectly or indirectly through local NGO interventions agricultural policy changes that eventuallywill contribute to sustainable pest control practices and the resulting elimination of obsoletepesticide stock building up.The local pesticide industry trade association (EACA) collaborated with the project and startedfor example to provide training program mes for farmers on (on farm) pesticide storage. Thereview of the training programme indicated that various issues needed to be addressed andhad to be coordinated with the MoA. A collaborative training was developed while discussionscontinue with the private sector in the Project Advisory Committee.

5. Awareness raisingSome activities were dedicated to awareness raising. These activities involved Governmentofficials, local and international NGOs. A jointly financed workshop (PAN-UK and the projects)was held on "NGO lessons learnt" from 7 - 9 July, 2003. This workshop was attended by 50participants from Ethiopia and neighbouring count ries.

6. Generation of Practical Experience and Training of StaffThe project has given the opportunity to local staff at various levels to acquire practicalexperience in project management issues, the planning, handling and storing of chemicalagricultural inputs, and to some extent in the possibilities of planning alternative and moresustainable agricultural practices.Phase I of the project did benefit greatly from investment and training in the national laboratorycapacity: The relatively small cost resulted in more than 400 tonnes of reported obsoletestocks being still usable. The total quantity of stocks to be disposed was therefore reducedfrom 2,800 to 2,400 tonnes with a resulting considerable cost reductions. The benefit wasdouble as the Government didn't have to order new pesticides for migratory pest control. Thisis an important lesson for similar projects of this type.The training of local workers in the safe handling, repackaging and transport of obsoletepesticides through preparatory workshops and on the job training proved effective. Nonoticeable work related incidents took place.

7. Multi-Donor action PlanThe multi-donor approach was necessary as no single donor could commit to the full estimatedamount required for the disposal of the large quantities of obsolete stocks in Ethiopia. The


Terminal Report: AG: GCP//ETH/0591NET; GCPIETH/061/SWE; GCP/ETH/058/USA-

ANNEX-Jlocal representations of the three donors showed keen interest in the operation andparticipated in briefings and working sessions.The rather important time gaps between the approval of the first project (USA) and the twoothers required some flexible management decisions at FAO Head Quarters and in the field,but finally didn't cause major delays in the field. The major goal of the disposal programme ofPhase I was addressed successfully thanks to the generous cash contributions of the USA, theNetherlands and Sweden.

3. Recommendations

The major recommendation ensuing from Phase I is that Ethiopia should continue to be assistedto dispose a remaining quantity of approximately 1000 tonnes of hazardous agricultural waste thatwas identified during Phase I. Additional funding arrangements were prepared and negotiated withnew donors resulting in a proposal for a Phase II that can be regarded as a natural extension of theactivities so far successfully completed under Phase I of the project.The aims of Phase II of the project can be summarised as:Removal and safe disposal of an estimated additional 1000 tonnes of obsolete pesticidesscattered over 764 storage sites which were identified under Phase I of the project;0 To build on effective prevention strategies developed as part of Phase I of the Project byinitiating a series of pilot projects on integrated pest management (IPM);* To continue the review of existing regulation of pesticide usage through the full life cycle of thechemical from initial needs assessment to final safe disposal;* To examine potential technologies which could be used in the Ethiopian context for the safedisposal of old pesticide containers and soils contaminated with pesticides. No disposal of thesematerials is considered under Phase II.

Work has also been completed on finalisation of a disposal plan for the second phase of theproject which will require the collection of small quantities of obsolete pesticides from over 700remaining stores. The distribution of stocks for Phase II is given below:

lo Amhara OAmhara

LI Oromiya l Orom iyaD Afar [3AfaroDire Dawa O Dire Dawa

0 i-ambela 13Gambela

* Somali *Somai,1 Ha rar

- Harar-Senshian Gum

EBenshan GumETigrayEl T"vgray 01 * ,SNN *GO SNNP OegSN14Reg 14

Rg1

Figure 3. Tonnages of stocks for Phaseil by Region

Figure 4. No. of stores for Phase 11 by Region

Terminal Report Ethiopia Phase I (2).doc '6

Terminal Report: AG: GCP/IETH/059/NET; GCP/ETH/0611SWE; GCPIETH/058/USA

ANNEX-JFigures 3 and 4 indicate the quantity of stocks and stores to be included in Phase II of thedisposal operation in Ethiopia. A total of 1082 tonnes will be removed from 705 locations indicated inthe inventory completed as part of Phase I of the project. The work will be completed by a projectmanagement team based at the Crop Production, Protection, Technology and Regulatory Department(CPPT&R) of the Federal Ministry of Agriculture (MoA) in Addis Ababa. The team will include keypersonnel who participated in Phase I of the project with technical support from a series ofinternational consultants and experts. The team will be responsible for the management of thecollection, repackaging and storage of the obsolete pesticides pending the appointment of aninternational contractor to complete transportation and shipment of the waste for environmentally

sound disposal overseas, subject to international tender through FAO. Table 2 below gives a moredetailed distribution of stocks to be included in Phase II. The total does not include stocks known to beheld by the Ministry of Health as indicated earlier.

Add is Afar Amhara B.G. Dire Gambela Harari Oromiyia Somali SNNP TigrayAbaba DawaTonnage 23 |1 209 101 1 45 1 405 58 194 143

No. of 7 1 160 10 1 2 1 325 3 144 83stores - _ _ _ _ _ _ j _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Table 2. Summary of stocks and locations to be included in Phase 11

Similarly, work has started on the drafting of a detailed work plan for prevention of accumulationin Ethiopia. This work is being completed in collaboration with the team at CPPT&R.

It is estimated that the completion of these activities will cost up to US$ 5,100,000 (Euro4,000,000). The costs associated with Phase II of the project will be met by contributions from twodonor governments, the Governments of Finland and Belgium. The mechanism for donor support willbe different in both cases at the request of the specific donor.

The Government of Finland will contribute Euro 1,000,000 by establishing a multi-lateral trustfund at FAO. The fund reference is GCP/ETH/064/FIN. The fund will be used to cover local costs ofadministering the project as set out in Annex 1 of this agreement. The fund will be used to procureadditional equipment and to cover salaries of staff hired locally under Phase I of the disposal project.The contribution also includes an element to cover any possible budget shortfall for the disposal of theinitial 1500 tonnes of pesticide covered under Phase I of the disposal operation. The justification forthe budget shortfall has been the subject of a separate communication from the FAO Representativein Ethiopia (insert FAO ref).

In addition to the multi-lateral trust fund established by Finland at FAO, the Government ofBelgium has agreed to support the implementation of Phase II of the project to an amount of Euro3,253,339. This fund will be provided on a bilateral basis. The fund will be used to cover specificbudget costs. Euro 3,152,700 of the fund will be used to cover the cost of disposal of the 1000 tonnesof obsolete pesticides earmarked for disposal under Phase II of the Project. The budget has beenformulated based on the following critical assumptions:

* The disposal contractor used for Phase I of the project is planned to continue as the disposalcontractor under Phase Il;* FAO remains the overall coordinating body for the project and will continue to have specificresponsibilities. The costs associated with the successful execution of these duties will be coveredunder the multi-lateral trust fund GCPIETH/064/FIN set up between FAO and the Government ofFinland;


Terminal Report: AG: GCP/IETH/059/NET; GCPIETH/061/SWE; GCPIETHIO58IUSA

ANNEX-JThe existing contract (plus all amendments) for the disposal of the obsolete pesticides inEthiopia between FAO and the contractor forms the basis of the costs and work plan under Phase IIof the Project.

Recommendation to the Government of Ethiopia:

Considering the results and findings of Phase I the Government of Ethiopia may wish in Phase II:a To develop contingency plans for empty containers and look at possibilities to include inpurchase orders for pesticides certain clauses for example the taking back of unused quantitiesafter e.g. one year, a local system of taking back empty containers and their acceptable localdisposal.* To set up a multidisciplinary team entrusted with the authority to review and monitor pesticideuse and pesticide purchase proposals* To set up a sustainable system of periodic controls of pesticide stores of the private sector anddevelop related sanctions.

To collaborate with national NGOs in order to reach an agreement on a mechanism of publicawareness raising and possibly independent monitoring of pesticide use.To encourage studies on alternative methods of (malaria and other) vector control.To pursue the efforts in the development of sustainable agricultural practices including IPM.4. Appendices

Appendix 1: Project StaffOne Project Manager from April 2000 to July 2002 and subsequently 6 technical backstoppingmissions;The expenditures reported under the subject of Consultants relate to the costs of independentmonitoring of the projects through PAN-UK, to the recruitment of a consultant to assist in thefield work period April-August 2003 and salary costs related to terminal reporting.One Secretary from April 2000 to December 2003.

Five drivers from April 2000 to December 2003

Appendix 2: Major Items of Equipment Supplied

GCPIETH/059N ET:a One Toyota Land cruiser Station Wagon, Diesel US$ 31,838V One Toyota Hilux 4 WD Pick-up Double Cabin, Diesel US$ 19,979* One Mitsubishi Canter FE 659 T, Diesel, forward control cabin,pay load 5.7 ton with a mounted HIAB Crane US$ 56,945

GCP/ETH/058/USA:* One Toyota Land cruiser hard top, Short wheel base, Diesel US$ 22,779* One Toyota Hilux 4 WD Pick-up Double Cabin, Diesel US$ 19,598* Two desktop computers

US$ 6,665* Two laptop computer US$ 5,800* Codan Page F radios, 4 units US$ 15,812One scanner, colour printer, UPS US$ 1,860* Safety equipment US$ 8,654* Laboratory supplies, glassware, reagents and chemicals US$ 92,463(including training in laboratory equipment use combined with the purchase


Terminai Report: AG: GCPIIETH/059/NET; GCP/ETH10611SWE; GCPIETH/058/USA

ANNEX-Jorder wvith the supplier)

Appendix 3: List of Project Publications

The project produced progress reports and various mission reports that were communicated to thedonors and the Government.The projects produced a video on the disposal operations.

Appendix 4: Abbreviations

AGP Plant Production and Protection Division (FAO)

AGPP Plant Protection Service (FAO)CPPT&R Crop Production, Protection, Technology and Regulatory DepartmentDFID Department for International Development (UK)FAO Food and Agriculture Organization

FDRE Federal Democratic Republic of Ethiopia

IPM Integrated Pest Management

MoA Ministry of Agriculture

MoH Ministry of Health

PAC Project Advisory Committee

PAN-UK Pesticide Action Network-United Kingdom (International NGO)NGO Non Governmental Organization

PPE Personal Protective Equipment

SIDA Swedish International Development AgencyUSAID United States International Aid Agency


ANNEX-KSequence of daily briefing activities at the field level and forms

Annex-K Twelve (12) blank formats used daily during the entire fieldoperation of the project

1 Daily progress report format

Daily Progress ReportLocal counterparts and hired labourersStore name: present:Store no.

Planned activities for today

Summary of work completed today

Hours worked:Hours lost due to delays:Is the project on schedule:Any incidents / accidents / near misses:Details of problems I delays / accidents / incidents / near misses

Planned operations for tomorrow

Signed: Position:

1


2 Daily briefing format

Daily briefing sheetAbsentees:

Staff members present:

Date and time:Given by:Location:

Previous days progress

Principal activities for day

Task based risk Variations to risk PPE requirementsassessment issued assessment issued

Signed: Position:

2


3 Daily check list format

Project Daily Check-ListCompleted By:Site Number:Site Name / Location (Zone and Region):Date:

No Item Task Yes No1. Documentation Site Inventoryl_ Pesticide Risk Assessments

_ l Site Task Risk AssessmentsResource List

-_ Working MethodsNotification of Store KeeperNotification of Region / Zone

2. Working area Warning signsBarriers in place_ ._ Decon unitr__l_Fire

extinguisherProtection - floors, wallsr Zoning - 1/2/3First aid kit

l_ Bunded areasRemoval of PPEr_ | Eating/drinking/smoking rules

3. Worker training Counterparts-_ Hired labourers

Drivers

4. j Daily briefing Regional Administration._ Counterparts

Hired labourersDrivers

5. | PPE (Correct use)CounterpartsHired labourersVisitors

Yes No7 6. Store keeper On timeCo-operative

I . Lost time/delays

7. Variations to work plan Delay - reason?

3

ANN EX-KSequence of daily briefing activities at the field level and forms

No Item Task Yes NoAddition material - detaiis

__ Less materials - details

8 Packages + Labeiling Package numbering correct___(tractability)Hardlbs

, Hazard labels_ __ IList of contents vs. inventory

I_ UN marksUN approved containers

r 9. Health monitoring Paramedic on site

Local clinic informed / locatedFirst aid equipment on site

I_ Any incident - details!_ l Eating, drinking, smoking

Water / meal breaks

'issued m Complete form giving details

Prohibition Notice issued Complete form giving detailsComments:

4


4 Material Safety Data Sheet FormatPesticide active ingredient:Pesticide common name:Pesticide manufacturer:

Reference dataMSDS data available

Pesticide manual data availableWHO Classification

EPA Classification

LD 50

Occupational Exposure Limit (EH 40)_

Exoosure hazards

Additional hazards - corrosive, flammable, irritant etc

Protective equipment required

Approved packaging type

Completed by:Date:

5


5 Safe working method

Safe Working Method No. X

Completed By:

Date:

Signature:

1. Introduction

2. Main Activities

3. Equipment

4. Environmental Protection

5. Personal Protection

6. Equipment

7. Reference Documents

6

Ji - l -I I I I I 1 1 1 -1 1 --1 -1

ANNEX-KSequence of daily briefing activities at the field level and forms - - -_-

6 Task based risk assessment format

Store number: Store location: Chemical present

Main activity:

Personnel involved:

Duain Contac-t rss Current Additional controlActions Frequency Duration risks Other risks control measures Commentsrk mmeasures

Completed__ by:_____

megasures ae

1.

2.

3

4.

5.

6.

7.

Completed by: Signature: Date:

Auhrsdb:Signature: Date:

7


7 Weekly progress report format

Weekly progress reportDate & time:

Principal tasks undertaken Progress

Safety issues Update risk assessment

Variations Instruction issued

Operations planned for next week

Signed: Position:

8


8 Mission report format

Location

Personnel

Date

Aims

Report

Achievements

Issues I Problems

Actions

Ethiopia Obsolete Pesticide Project

9


9 Movement of hazardous waste transport-log format

Date:Completed By:(Plus Signature)Departure Location:(Store Number/Store Name/Zone/Region)Destination:(Store Number/Store Name/Zone/Region)Route:Time of Departure:Estimated Time of Arrival:Transport Company:

Drivers Name:

Names of passengers (essential passengers only):

Has driver been briefed on rules for carrying pesticides:

Has driver been supplied with pesticide risk assessment cards?

Vehicle Plate Number:

Has drivers license been inspected:(Attach copy)

Has vehicle service record been provided?(Attach copy)

Does Vehicle have safety equipment (fire extinguisher etc)?

Escort Vehicle plate number:

Escort Vehicle driver name and passengers:

Does Escort Vehicle have necessary safety equipment?

Radio call sign:

Details of Load:(Attach list of products, package numbers and a store number)

Drivers Signature:

10

ANNEX-KSequence of daily briefing activities at the field level and forms10 Cargo list form format

Cargo list from To Date

Package Total No. o UN number Name of packaged pesticide Store No.type. Package name

_____________________

I____________________________._ __ i_

_. _.

I1


11 Weighing list format

Store

NO_466__ Empty pallet box =126 kg Tnt pallet=30 kg Fin pallet=26 Store Name._ ___N-46

Emptv open head drum=27 kg, Empty closed head drum=25.5 kgEmpty salvage drum =35 kg

Package No Type Un Information Trade name Gross wt. Net wet. Manufacturer

-3 l74

7

9I' 1 _ _

11 2

-~ 85 -_ _ _ _ _ _

14=-

1 5-~ 14 = _ _ __ _16 'l

2C 71819 _ _ _ _ _ _ _ _ _ _

2021 =222324 =25 126 12728 -2930 _ _ _ _ _ _

31 _ _ _

32 _ _ _ _ _ _

33__ _ _

34 __ _ _ _ _ _

35- 36

3738 _ _ _ _ _ __ _ _ _

1 2


12 Loading list format

Collection site:Container Number:Laver:

NoPackage Package Information Marine Gross Net RemarkNo. type Pollutant__ ______ weight_ weight _ _ _ _

13

AFRICA STOCKPILES PROGRAM (ASP-P1)ETHIOPIA COUNTRY ENVIRONMENTAL AND SOCIAL ASSESSMENT

(CESA))DRAFT TERMS OF REFERENCE (TOR)

Background

Ethiiopia is currently engaged in the disposal of approximately 1,I00t of publicly heldobsolete pesticides at what are termed "typical sites" Ethiopia has already disposed ofover 1,000t of obsolete pesticide through a previous clean up and disposal operationwllich addressed higlh risk obsolete pesticide sites including all known "atypical sites".The Bank understands that 3 obsolete pesticide sites are not currently accessible due tosecurity considerations in the area. The CESA will need to verify that this is indeed thecase and that the clean up of these sites will only be able to take place once the securitysituation permits.

Under the current disposal operation 300t has already been repackaged and shipped outby the disposal contractor to their incineration and disposal facilities in the UK andGermany. The contract has been signed between the FAO and the European disposalcontractor Onyx Environrnental on behalf of the Government of Ethiopia. The contract isfinanced from a grant from the Belgium Government and contributions from theGoveniment of Finland and Crop Life International which are channeled tlhrough theFAO. The disposal operation is taking place based on a preliminary environmentalassessment and according to FAO best practice disposal standards which will be appliedto the overall Africa Stockpiles Programme ASP-P1.

As Ethiopia is going to participate in the ASP-P1 and will receive funds in this regard, itis a requirement to complete a country environmcnt and social assessment (CESA) and toimplement an environmental mitigation plan (EMP) to meet Bank requirements. TheCESA is expected to review the current FAO disposal guideline documents and theimplementationi of the Ethiopian disposal operation and to propose any changes whiclmight be required for the remainder of the project. The CESA should be publiclydisclosed, reviewed and approved by the relevant Ethiopian EA authority prior to requestfor Bank approval.

Tlhis TOR is based on the Marclh 17, 2004 Africa Stockpiles Programme - Project 1(ASP-P1) Environmental and Social Assessment Synthesis Report. This will be aCategory A environlm2ental Assessment in terms of Bank policy OP4.12 and shouildmineet the niecessary standards.

The Development Objective of the ASP-P1 is for several African countries to eliminateinventoried publicly-held obsolete pesticide stockpiles and associated waste, andimplement measures to reduce and prevent future related risks. Seewwvw.africastockpiles.org.

ASP-PI will implement various cleanup and site remediation measures to mitigate theimpact of obsolete publicly-held pesticides stocks threatening communities, ecosystems,and the global environment. In parallel, ASP-P1 will strengthen the elements of aregLilatory regime, management practices, and public awareness to prevent a recurrenceof pesticide accumulation in the future.

The principal outputs of ASP-PI will be twofold.

(a) Tlhrough its cleanup activities, ASP-PI will eliminate, as far as is practicable,the risks from obsolete pesticides to communities, natural resources andecolouical systems in ASP-PI countries. At the same time, it will reduce therisks to the global environment from POPs and other persistent toxicpollutants.

(b) Through its prevention activities, ASP-P1 will reduce future risks fromobsolete pesticides by putting in place the key elements of effective pesticidemanagement, encouraging reduced reliance on pesticides through thepromotion of IPM and IVM policies.

The Project's success in meeting its Development Objective, ASP-PI will be based onfour indicators as summarized below, but explained in more detail in Annex 3 to thePAD.

(a) Risk Reduction - based on quantitative risk assessment methodologiesrelating to both health risks and environmental degradation, the Project willmeasure the percentage of publicly-held stocks removed and quality of ASP-P1 cleanup activities aiming to reduce pesticide stockpiles (Component 1).(b) Improved Pesticide Management - based on qualitative and quantitativeparameters, the Project will measure the adequacy of governrment strategies,including regulations, laws and institutional policies in bringing themanagement of pesticides and their associated wastes up to internationalstandards (Component 1).(c) Pesticide Disposal - based on quantitative parameters, the Project will trackthe amount of publicly held obsolete pesticide stockpiles that ASP-P1 willsafeguard or destroy (e.g., repackaging into safe containers, incineration, anddisposal of contaminated containers) (Component 1).(d) Service Delivery to ASP Countries - The Project will measure the quality,quantity and efficiency of support services, such as technical assistance,knowledge management, communications, and implementation support, thatthe international ASP-P1 technical assistance providers [initially FAO, WorldWildlife Fund (WWF), Pesticide Action Network - Africa (PAN-Africa), andPesticide Action Network- United Kingdom (PAN-UK)] deliver to the ASP-P1 countries (Components 2, 3 and 4).

Below is a brief description of the Ethiopia project.

rETHIOPIA

r Obsolete Stocks: Estimated 1,100 tonnes (number of sites to be confirmed).

A preliminary inventory of pesticide stocks has been completed. A contractis currently under implementation to remove most of this obsolete pesticidewaste. The contract is between the FAO, acting on behalf of the Ethiopian

n S s Govt, and the European contractor. It is financed by the Governments ofBelgium and Finland with an anticipated contribution from Crop LifeInternational..

r Project Objective: Support cleanup of obsolete pesticide wvaste and prevent re-occurrencethereof.

Z Budget: GEF: USS2.230 million. Total: USS8.950 million

Kev Donors: GEF, AFDB, Belgium, Finland, Japan, Crop Life International

Kev Counterpart: Crop Protection Department (CPD) of the Ministry of Agriculture and Ruralr_ Development (MARD).

Cleanup and Disposal: (Total: USS5.730 million)(a) produce a detailed inventory of obsolete pesticide stockpiles and associated waste. a CESA

including an EMP;(b) dispose of the additional identified quantities of obsolete pesticides;

I (c) produce a soil decontamination plan and undertake pilot cleanup of soils at heavily contaminated: sites: and

(d) carry out pilot decontamination and recycling of pesticide containers.

- S Prevention: (Total: USS1.270 million)° (a) reviev.' and strengthen pesticide legislation and management:

= (b) develop an IPM strategy and implement through pilot projects; andr (c) develop and implement an awareness raising and educational program for relevant stakeholders.

X Capacity Building: (Total: USSO.530 million)_ (a) improve the laboratory analysis capability of government staff,O (b) train store keepers on safe and effective pesticide management: andZ (c) develop training of trainers program for the EPA, National and Ministry of Environment (MOE)

staff

Project Management and Monitoring: (Total: USS1.42 million)(a) support the PMU in carrying out project coordination and implementation and M&E system.

Project Indicators:(a) inventory database of publiclv held obsolete pesticide stocks in place and being used by the PMUand the Recipient countries' govemment staff;(b) completion of CESA and implementation of each CESA's measures;(c) invenitoried publicly held obsolete pesticide stocks disposed of, as a result of the completion of theDisposal Services contracts in accordance with national and international laws and regulations;(d) identified contaminated soils also disposed of;(e) legal and regulatory framework for pesticide management improved, including measures tostrengthen compliance with the Basel Convention and the Rotterdam Convention,(t) training program is implemented and the knowledge so acquired is being used by the PMU and byRecipient countries' government staff; and(g) the PMU is functional and operating satisfactorily.

7 Proposed contents of the CESA.

Re-arding "atypical sites", Ethiopia has selected to produce a protocol for addressingF atypical sites in the unlikely event that they are found. This is to avoid possible delays infuture, associated with developing suchl a protocol. The CESA report will need to7 confin-n that, based on available information, no atypical sites are currently known toexist.

Note the table of contents below provides an organizing option.

Notwithstandinig the above, the CESA should address the followving:

Title PaLeTable of ContentsExecutive Summary

Section 1. Project Objectives and Description7 Section 2. Policy, Legal, and Administrative FrameworkSection 3. Baseline Data

7 Section 4. Review of Environrmental and Social ImpactsSection 5. Analysis of Alternativesr Section 6. Typical Sites

6.1 Proposed Mitigation Measures6.2 Environmental and Social Monitoring Plan

Section 7 Atypical SitesSection 8 Additional Environmental Management Training RequirementsSection 9. Changes needed to any contracts or guidelines or policies

Section 1 0. Public Consultation and Disclosure

Note: Sections 3-8 should be structured to provide a critical review/ assessment of thecurrent disposal operation and to secondly provide guidance for the remainder of theobsolete pesticide clean-up and disposal operation as per normal EA approach. Thisapproach is required as an existing disposal contract is being implemented and willcontinue to be ahead of Bank support.

TablesFiguresAppendixesAppendix A List of people who supported the CESA processAppendix B Site visitsAppendix C List of References

Guidance for each section of the CESA

Title Page and Table of Contents: These should be consistent with the proposed outlineabove (see previous page).

Executive Summarv

Tlhis section will consist of a brief overview of the adequacy of the pesticide disposaloperation to date and the key recommendations for the remainder of it.

Section 1: Project Objectives and Description

Present the project objectives and a brief overview of the status of the clean up anddisposal operation to date, the key FAO documents guiding it, financing and thearrangements for project implementation - Govt, FAO, TSU, Belgium Govt, contractoretc. This can be drawn from the draft Country Operational Manual.

Section 2: Policy, Legal, and Administrative Framework

Provide a brief and concise summary of the policy, legal, and administrative requirementsfor the implementation of the current clean-up and disposal strategy withrecommendations for strengthening. As disposal involves transport across Djibouti thelegal framework for this as well as shipping and disposal in UK and Germany must bedescribed.

For each of the regulations and standards discussed above the administrative body that isresponsible for implementing the regulation should be provided.

Review the current disposal contract with a view to proposing any amendments whichmay be required to accommodate the outcomes of the CESA.

Tables could be used for providing much of the above.

Section 3: Baseline Data and Review of the Clean up Operation to Date

Key features of the Ethiopia disposal methodology and ensuing compliance with theWorld Bank Safeguard policies (particularly OP 4.01 on Environmental Assessment, OP4.09 on Pest Management, and OP 4.12 on Involuntary Resettlement) should beprovided:* Provide a concise overview of all klnown sites including known baseline databased on known inventory/ sites and level of risk. Provide this in table format forr, coniciseness

* Provide a more detailed enviromnental and social characterization of a sample ofthe sites cleaned up as well as for a sample of the outstanding stockpiles/sites.Review impacts to soil, water, air, human health and biota. The review should tryto assess whetlher the environmental and social impacts are permanent ortemporary.

* Provide the criteria, framework or methodology for distinguishing between thetypical stockpile sites (majority) and hot spots (atypical sites) that requireadditional safeguards input and additional mitigation measures (e.g., sites thatrequire extensive clean-up and land acquisition or resettlement). There may infact be no such high risk sites as it is understood that they were cleaned up duringa previous operation. However, in the event that such sites do exist and will befinanced by the overall project, the procedures or protocol for gathering additionalinfonnation should be included in the CESA. This section of the study will beimportant in informing the EMP and monitoring requirements for typical andatypical sites. See section 6 below.r * The institutional responsibilities for identifying atypical and typical sites shouldbe stated.

* Review the quality and training of staff! workers and the need for future training.

Section 4: Review of the Disposal Strategy to date

Provide a critical assessment and review of the clean up and disposal operation to dateincluding inventory development, risk assessment, repackaging, transport, health andsafetv response, storage, disposal technology.

Section 5: Analysis of Alternatives

This section shall provide a review of the alternatives considered in relation to the aboveas well as any other alternatives which should be considered.

Section 6: Typical sites66.1 Environmental Mitigation Plan (EMP)

Drawing on the preceding work, the EMP will provide the necessary guidelines for thetreatment of typical sites as discussed in section 3 above. le an EMP framework includingthe mana-ement and monitoring approach and key responsibilities should be developedfor the typical sites. The typical framework is expected to be applied across Ethiopia.

For each potential impact identified as significant in Section 3 above, confirm theproposed mitigation measures in a way which correlates with the current clean up anddisposal strategy and documentation. In most instances the mitigation options meanrepackaging, store stabilization, occupational health and safety standards, transportarrangements, final store requirements before onward transport or disposal requirements.This approach to supporting the current process is important so that the current clean upstrategy can be continued with new mitigation measures very clearly and conciselyincluded wxhere needed. The EMP for typical and atypical sites will generally include: (a)the potentially significant impacts: (b) the proposed management and mitigating actions;(c) wlhen the action is to be taken and by whom; (d) public consultation and (e) associatedcosts for the mitigation measures if the CESA finds that they are unbudgeted in thecurrent project..

6.2 Monitoring Plan

The current monitoring framework and responsibilities for typical sites are to be reviewedand revised if need be. The review should identify (a) which parameters are beingmonitored and if these are the most appropriate ones (b) how and where the monitoring istaking place; (c) monitoring frequency; (d) institutional responsibilities; (e) costs andimplications of change in the event that the monitoring is different to what is currentlytaking place.

In reviewing/considering what is to be monitored, the following criteria are to be used:* Monitor all clean up/ mitigating activities to insure that they are properly

implemented (eg volume of waste repackaged correctly in relation to agreedrepackaging actions).

* Monitor key activities that are regulated by environmental law or are beingimplemented as best practice (eg monitoring of safe transport of obsoletepesticides out of the country to port).

Section 7: Atypical sites

As above for section 7. Identify the generic approach to be taken to atypical sites in sofar as this is possible including: (a) what criteria are used to determnine such sites; (b) whodetermines it; (c) any special EMP/site clean up requirements which can be identifiedupfront; (d) monitoring responsibilities; and (e) public consultation and any otherpertinent issues. It is suggested that the current FAO guidelines are reviewed to assessthe extent to which they currently provide an adequate framework for addressing suchsites as well as whether government is sufficiently prepared and trained to support such

operations. It may be useful to provide some background to how previous atypical sitesr_ were Identified and treated.

Section 8: Environmental Management Training Requirements

Any specific training requirements identified through the CESA should be identified andcosted out.

Section 9: Changes needed to any contracts or guidelines or policies

This section of the report will detail any amendments which are required to the currentdisposal contract to implement the CESA outcomes and any changes required to FAOGuideline documents.

Section 10: Public consultation and disclosure

Public consultation is an important part of all EA's. Therefore the project needs to have asimple public consultation strategy or process which is can be routinely undertaken at thesites proposed for clean-up. It should describe the general level of information providedanid the approach to issues and concerns. If a protocol or strategy exists, provide this withproposals for improvement if needed.

The consultant should consult with the public at the 3 - 4 typical sites with a view toinformning the above and reporting on findings.

The public consultation process in drawing up the CESA should be described. Once theCESA is approved by the Bank it will need to be made available at public places. The7 proposal should be described. The CESA will then be disclosed by the Bank in theInfoslhop at the Bank and a summary report will be provided to the Bank Board.

r ANNEXES

ANNEX A: List of Preparers - This annex shall include a list of individuals andorganizations involved in the preparation of the CESA document.ANNEX B: Site visits - Brief description of sites visited, findings and who waspresent.

A.nex C: List of References - This annex shall contain a list of written materialsused in the preparation of the CESA. The list shall include all materials,including unpublished materials available in manuscript or map forrn.Include copies of protocols or relevant procedures

The draft report will be submitted by the Borrower to Bank TTL to ASPEN for reviewand clearance. Prior to disclosure in-country and at Bank InfoShop, the report will be

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shared in a workshop format with relevant stakeholder groups, in order to benefit fromtheir input as well as to foster ownership on their part.

Consultant skills required7 Experienced consultant familiar with disposal of obsolete pesticides, FAO guidelines inr this regard, and environmental assessment. Knowledge of the Ethiopia pesticide

sector/disposal operation and or the Africa Stockpiles Programme as well as Bank7 safeguard policies would be an added advantage.

March 30, 2006

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vol. 3 STOCKPILES OGRAMME - World Bank Documents

Documents

Transcript of vol. 3 STOCKPILES OGRAMME - World Bank Documents