E916 March 17 2004 The First Africa Stockpiles Programme - Project I (ASP-P1) Environmental and Social Assessment Synthesis Report .~~~~ March 17, 2004 rB 4 & i Z@ Table of Contents I. INTRODUCTION 1. Background 2. Objective of the study 3. Methodology 4. Organization of the Report II. THE POLICY, LEGAL AND INSTITUTIONAL FRAMEWORK 1. International Framework for Hazardous Chemicals and Hazardous Waste 2. World Bank Safeguard Policies 3. National Legal Frameworks of Participating Countries 4. Legal Frameworks of Countries Where Disposal May Occur III. PROJECT DESIGN 1. Long-term Vision and Program 2. The Proposed First Phase Project a. Project Development Objective b. Project Beneficiaries and Project Area c. Project Components IV. BASELINE CONDTIONS IN BENEFICIARY COUNTRIES 1. Lifecycle of Pesticides in Africa 2. Overview of Current Conditions in Beneficiary Countries V. ENVIRONMENTAL AND SOCIAL IMPACTS OF ASP-P I 1. Overview 2. Stage I Activities and Risks 3. Stage 2 Activities and Risks 4. Socio-Economic Impacts 5. Cumulative Impacts 6. Compliance with World Bank/IDA Safeguard Policies 7. Overall Program and Reputational Risks VI. PARTICIPATORY APPROACH I. Project Preparation Phase 2. Project Implementation Phase VII. ANALYSIS OF ALTERNATIVES VIII. ENVIRONMENTAL MANAGEMENT PLAN (EMP) I1. Overall Design of the Environmental Management Plan 2. Key Components of the Environmental Management Plan a. Inventory of Obsolete Pesticides b. National/Institutional Capacity Assessment c. Identification of Priority Sites d. Emergency Response Plan e. Publication Consultation and Awareness f. Prevention g. Pesticide Removal and Site Remediation 3. Program and Reputational Risk IX. MONITOR[NG AND EVALUATION 1. Assessing the Effectiveness of Mitigation Measures Under Stage I 2. Triggers for Moving to Stage 2 3. Assessing the Effectiveness of Mitigation Measures Under Stage 4. Conclusion Preamble This Synthesis Report is largely based on the study "The Africa Stockpiles Programme: Framework Environmental Assessment (FEA) and Environmental and Social Management Framework (ESMF)" (prepared by TerraChoice/Jacques Whitford under a World Bank contract, and referred to throughout as the "Consultant Report"), and the participating country project documents. The Consultant Report is available for more detailed reference as an attachment to the present Synthesis Report, and as part of the project documentation. The Synthesis Report makes specific reference to specific sections of the ESMF, which is the subject of part 2 of the Consultant Report. The ESMF will be reflected in each country's project operational manual. Abbreviations and Acronyms ASP Africa Stockpiles Program ESA Environmental and Social Assessment EU European Union ASP-PI The First Africa Stockpiles Project EMP Environnemental Management Plan POPs Persistent Organic Pollutants AMCEN African Ministerial Conference on the Environment WWF World WildLife Fund WHO World Health Organisation UNIDO United Nations Industrial Development Organisation INTAR CLI Crop Life International SBC Secretariat of the Basel Convention NEPAD New Partnership for Africa's Development GEF Global Environnent Facility AU African Union ESMF Environmental and Social Management Framework UNEP United Nations Environment Programme CP-ESA Country Project Environmental and Social Assessment PIC PDO Project Development Objective PMU Project Management Unit NGOs Non Governmental Organizations CUTSU CCMEA IPM Integrated Pest Management MARPOL IMDGC International Maritime Dangerous Goods Code I. INTRODUCTION 1. Background 1. The use of pesticides and other chemicals toxic to both human health and the environment, grew dramatically during the last 40 years in the African continent,. Due to poor pesticide management practices and the imposition of bans in the use of particular chemicals, virtually every African country has a stockpile of obsolete pesticides and in particular persistent organic pollutants (POPs') and associated wastes, amounting to an estimated 50,000 tons2. This poses a serious threat to human health, local and global environment i.e. land and water pollution, marine environment, habitats of wildlife. 2. Obsolete pesticide3 stockpiles exist in virtually all of the 53 Countries of Africa; they are generally a mixture of different pesticides, some of these are POPs, or mixtures including some POPs, and fall under the new Stockholm Convention4 on POPs. These chemicals have long half- lives causing them to accumulate in the environment, and therefore causing potentially significant ecological and human health risks. If the organo-pesticide mix is incinerated under less than optimal conditions, additional POPs may also be produced (dioxins, furans and HCBs). Most of the countries in Africa lack adequate technical, institutional and financial capacity to create the necessary regulations and associated infrastructure including enforcement and the resources necessary to properly manage the clean up of contaminated wastes/sites and destroy obsolete stocks of pesticides in an environmentally sound manner. They also suffer from weak import controls, inadequate storage and stock management, a lack of training and education on appropriate pesticide use, and there is widespread misuse of pesticides. 3. While the production, distribution and management of these potentially toxic chemicals are currently highly regulated in developed countries; many developing countries lack the resources necessary to implement adequate management strategies resulting in the build up of stockpiles of obsolete pesticides across Africa. 4. The existence of obsolete pesticide stockpiles, continuing stockpile accretion and lack of remediation make the problems acute. Contributing to the problem is the fact that the removal of old and obsolete chemicals (even toxic and dangerous ones) is not generally considered as a development issue. Both recipient countries and donor agencies are often reluctant to divert funds allocated to poverty alleviation, food security or other elements of sustainable development to this issue of environmental, social and economic risk reduction and waste disposal. A strategic programmatic approach for the African continent, building on activities and efforts from the international community as well as the provision of additional funds dedicated specifically to pesticide / hazardous waste management and environmentally sound disposal, was agreed among the key stakeholders. I POPs as addressed under the Stockholm Convention, and therefore, this project are: Aldrin, Dieldrin, Endrin, Chlordane, Heptachlor, DDT, Mirex, Hexachlorobenzene and Toxaphene. 2 This rough estimate (illustrated in Annex 1) which does not include contaminated soils, will be refined through country specific detailed inventories, which constitute key activities in the proposed project. 3 The Africa Stockpiles Programme classifies pesticides as obsolete because they have been banned, have deteriorated or are damaged, have passed their expiration date, cannot be used for another reason or are no longer wanted by their owner. 4 The Stockholm Convention on Persistent Organic Pollutants was adopted on May 22, 2001, in Stockholm, Sweden. 5. The adoption by AMCEN (African Ministerial Conference on the Environment), July 2002, in Kampala, Uganda, and the 2001 Rabat Declaration on the environmentally sound management of hazardous wastes, is the culmination of a long process in the region to solve the obsolete pesticides stockpile problem. On the basis of a strong demand from African countries, the Africa Stockpiles Program (ASP) was developed to prevent, clean-up and destroy obsolete pesticide stockpiles from the region. The program has been conceived and designed by a partnership of NGOs (World Wildlife Fund (WWF), Pesticides Action Network-UK (PAN-UK) and PAN-Africa), UN specialized entities (UN-Economic Commission for Africa, FAO, UNEP, UNIDO, WHO, UNITAR) and other international organizations including the African Union (AU) and its member countries, the New Partnership for Africa's Development (NEPAD Secretariat), the European Union (EU) the World Bank, SBC (Secretariat of the Basel Convention), and the private sector, represented by CropLife International, as well as the Global Environment Facility (GEF), which, as an interim financing mechanism for the Stockholm Convention on POPs and has also contributed preparation funding along with other financial or in-kind resources from bilateral donors . 2. Objective and Scope of the Environmental and Social Assessment 6. At the request of African countries, and in collaboration with all program partners, the first proposed project ( Project 1) under the Africa Stockpiles Programme, ASP- PI, has been designed to significantly and sustainably reduce the risk from publicly held stocks of obsolete pesticides to human and environmental health in affected areas within six of the seven beneficiary countries,. 7. Early in project conceptualization and development, an identification of the potential effects of the project lead to the conclusion that despite its focus mitigating a major source of environmental risk, the project itself is potentially a source of significant adverse impacts, including on the reputation of the program partners. Therefore, the project was classified as category "A", according to World Bank policies, resulting in the need for the preparation of a comprehensive environmental and social assessment study, which was then was conducted by the program partners, as part of the preparation of ASP- P1 The findings and recommendations of this study are summarized in the present report. 8. The environment and social assessment study has two inter-related objectives: i. The first objective is to identify a set of sound environmental and social principles to guide the implementation of the project, based on a comprehensive analysis and review of the potential environmental and socio-economic impacts associated with the Africa Stockpiles Program in general, and ASPI in particular; and ii. The second objectives is to prepare an Environmental Management Plan (EMP) in order to (i) mitigate the potential negative impacts of project activities, as well as enhance the positive impacts; and (ii) to guide the implementation of program activities at the country level. 9. The implication of these objectives in terms of the structure and content EMP is that the first part of the EMP contains "sector and program issues," and associated mitigation measures, and the second part of the EMP is a "an environmental and social management framework, (ESMF)" since the nature and extent of certain activities (e.g., disposal) will only be well defined during project implementation, because they depend on the results of certain other key activities (e.g., detailed inventory of obsolete pesticides and prioritization of sites).5 10. It is important to point out that while the environmental and social assessment seeks to provide comprehensive analysis and guidance both at the program level and at the country project level, its scope is-by design of ASP-PI--limited to obsolete pesticide stocks stored at wholesale or retail locations (mostly publicly held), and therefore the environmental and social excludes obsolete pesticides stored at individual (end-user) sites. In addition, the environmental and social assessment does not extend to issues related to manufacturing and distribution prior to purchase, as well as the application ofpesticides. 11. Furthermore, since the World Bank will be the project implementing agency for GEF, as well as the manager of the multi-donor project Trust Fund, the preparation of the environment and social assessment study was guided by the requirements of the World Bank's environmental and social safeguard policies (under the umbrella Operational Policy 4.01: Environmental Assessment, 2001 and its various Annexes, as well as the international framework for regulating hazardous chemicals and hazardous waste (including the requirement of ratification of the Stockholm Convention by all participating countries), and the national environmental regulations of the countries participating in the project. 3. Methodology 12. Data collection and consultations. The environmental and social assessment has been prepared by a team of consultants (with extensive expertise and experience in the areas of management and remediation of toxic chemicals and pesticides), using a combination of literature review, desk research, country project documents, extensive consultations with ASP partners and other stakeholders, and from information collected during country site visits (see list of references at the end of this report). Although all participating countries were visited by pre-appraisal teams, the study consultants focused their field visits on Ethiopia and Mali because they represented two ends of the spectrum of ASP implementation at the country level. In Ethiopia the program is relatively well advanced, with a completed inventory and capacity to implement the program already established. By contrast, Mali has yet to complete a full inventory and at the time of the visit had only limited capacity "on the ground" for implementation of the programme. A particular feature of Mali is also the high level of contaminated (pesticide saturated) soils. 13. Analysis using a "process approach" and "activity-impact interaction matrices" to identify, prioritize, and develop mitigation plans. The data collected from the process described above were analyzed using a structured approach. This approach was based on the development of a simple life cycle analysis of pesticides within Africa (summarized in Figure 1, and with more details provided in the Consultant Report), and resulted in the identification of four main activities (and associated sub-activities) in the pesticides life cycle, relevant to ASP-PI: i. Storage: includes conducting inventory, relocating/securing pesticides within storage facility, repackaging6, secondary containment, and long-term management of storage facility; 5 This distinction is also reflected in the structure of the background EA study, "The Africa Stockpiles Programme: Framework Environmental Assessment (FEA) and Environmental and Social Management Framework (ESMF)" (consultant report). 6 Repackaging can occur during inventory (phase 1) or during preparation for disposal (phase 2). 3 ii. Transportation: includes repackaging for transportation, loading/unloading trucks, trucking to storage or disposal facility, and possible accidents; iii. Disposal: includes disposal in non-African countries, long-term storage, disposal on the African continent (through thermal neutralization, landfill, or chemical treatment); and iv. Site Remediation: includes delineation, water testing, soil testing, and cleanup. 14. The potential risks associated with conducting these activities (and sub-activities), were identified and prioritized through the use of "activity-impact interaction matrices," which provide a simple but systematic way of assessing whether an activity has impacts in terms of sixteen biophysical and socio-economic criteria: i. Terrestrial environment, including soil, biodiversity, and habitat; ii. Aquatic environment, including surface water quality, ground water quality, aquatic habitat; iii. Atmospheric environment, including local air quality, and long range airborne contaminants; iv. Human health, including worker health, local resident health, short and long term risks; and v. Socio-economic environment, including health and safety, property and land rights, employment and income revenues, agricultural productivity, level of education and technical capacity, the role of traditional knowledge, access to cultural property and other important resources. 15. Distinction between prevention and cleanup activities within the project components. As part of "scoping" and delineation of activities to be included in the project, a distinction is made between (i) pre-disposal and remediation activities-i.e., prevention activities- -leading to the preparation of country specific clean-up plans (subsequently referred to as Stage 1 activities), and (ii) the development and implementation of country-specific clean up plans-i.e., cleanup activities--(subsequently referred to as Stage 2 activities). This distinction allows mitigation measures for stage I activities to be included in the EMP, while mitigation measures for stage 2 activities will be defined during project implementation, once inventories of obsolete pesticides are completed and country specific EA are undertaken. 16. The EMP refers to the Environmental and Social Management Plan for ASP-P1, and includes specific activities related to the preparation of country cleanup (disposal) plans, for which country environmental and social assessments will be required. These country environmental and social assessments will be referred to as "CP-ESAs" (where CP stands for country program), and their environmental and social management plans will be referred to as "CP-EMPs." As will be discussed in section VIII, the EMP includes a environmental and social management framework (ESMF) which will guide the preparation of CP-EMPs. 4. Organization of the Report 17. The report is organized in nine section. Section I provides a brief description of project background, as well as the objectives and methodology for the environmental and social assessment. Section II reviews the policy and institutional framework under which the environmental and social assessment has been prepared. Section III describes the project development objective and components. Section IV summarizes baseline conditions across participating countries. Section V presents the key environmental and social impacts associated with the project. Section VI summarizes the participatory approach used in preparing the environmental and social assessment. Section VII gives a brief overview of the analysis of 4 alternatives considered. Section VIII presents the Environmental management plan, including estimated cost and implementation arrangements. Finally, section IX presents the plan for monitoring the implementation of the EMP. II. THE POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK 18. As a multi-stakeholder international initiative, ASP-P1 is designed to complement and work within the existing framework of international conventions and national regulations that addresses issues of chemical and hazardous waste management, as well as within the framework of World Bank's policies and directives. Therefore, the environmental and social assessment for ASP-P I has been prepared under the following policy, legal and administrative frameworks. 1. International Framework for Hazardous Chemicals and Hazardous Wastes 19. Several international conventions exist to regulate chemical and hazardous waste management, disposal and transportation. Such conventions seek to ensure the environmentally sound management of these issues, both through establishing international codes and criteria and by requiring national governments to enact legislation enabling the implementation of these codes and criteria at the country level. These conventions are explicitly acknowledged by ASP-P1, and are addressed within the criteria for country eligibility for disposal or prevention projects. Eligibility will take into account whether countries have signed or ratified agreements such as the Stockholm, Basel, Bamako, and Rotterdam Conventions. 20. While the ratification of the Stockholm Convention is a requirement for participation in the program, irrespective of type of activity and stage, in case transport is required (which will only be known once preparatory activities are completed), then ratification of the Basel Convention will also be a requirement. Moreover, participating countries will be encouraged to ratify the Bamako and Rotterdam Conventions as part of strengthening their prevention programs. 21. Stockholm Convention. The Stockholm Convention on Persistent Organic Pollutants was adopted on May 22, 2001, in Stockholm, Sweden. The aim of the convention is to protect human health and the environment from the harmful effect of some of the world's most toxic, volatile and persistent chemicals by calling for the outright destruction and banning of persistent organic pollutants (POPs). As of May 06, 2003, 151 countries have signed the Convention, of which 30 have ratified. Of the 12 chemicals slated for elimination in the Stockholm Convention, 9 are pesticides. The Convention requires that any stockpiles of wastes containing POPs be managed in a safe and environmentally sound manner, taking into account international regulations, guidelines and standards. Certain trade restrictions are also imposed under the Convention. 22. The existence of the Stockholm Convention will affect decisions regarding disposal choices by ASP, particularly in regard to issues of obsolete pesticide incineration and the unintentional production of POP chemicals. The Convention prescribes that pesticide wastes shall be "disposed of in a way that the persistent organic pollutant content is destroyed or irreversibly transformed (...) or otherwise disposed of in an environmentally sound manner when destruction or irreversible transformation does not represent the environmentally preferable option (...). "7 The Convention goes on to state that the Conference of Parties will establish the necessary levels of destruction or irreversible transformation and will determine what methods of destruction are considered environmentally sound disposal under the Convention. The formulation of such guidelines will presumably take place sometime in the future, but not 'Stockholm Convention on Persistent Organic Pollutants, Article 6, 1 d) ii. 6 necessarily within the timeframe of ASP-PI. Therefore, careful monitoring and close collaboration with the Convention Secretariat will be needed by ASP program partners. 23. Basel Convention. The Basel Convention on the Control of Transboundary Movement of Hazardous Wastes and their Disposal was adopted in Basel, Switzerland, on March 22, 1989, and entered into force in May 1992. The Basel Convention was put in place in order to end toxic dumping (or illegal waste trafficking), to set up a framework to control movement of hazardous wastes across national frontiers, and to ensure their environmentally sound management and disposal. As of April 3, 2003, the Basel Convention is ratified by 156 countries, including 36 of the 53 African countries. 24. At a ministerial-level meeting held in Rabat, Morocco in January 2001, the problems posed by stockpiles of obsolete chemical wastes were recognized. African countries resolved to work with members of civil society to rid the continent of obsolete stockpiles within one decade. The resulting Rabat Programme of Action aims to increase national capacities to: (i) prevent future accumulation of unwanted pesticides; (ii) dispose of existing stockpiles in an environmentally sound manner; (iii) develop partnerships with stakeholders to address environmentally sound management practices for dealing with unwanted stocks of chemicals; and, (iv) strengthen existing, and pursue alternative, financial and logistical approaches to prevent the buildup and dispose of unwanted stocks of pesticides, PCBs and used oils. 25. The implementation of the ASP-P1 objectives, notably the disposal of obsolete pesticides, remediation of current stockpile sites, and the environmentally sound management of pesticides stocks, as well as the provision of funds to enable these activities, will provide practical and tangible support for the objectives of the Basel Convention and Rabat Programme ofAction. 26. Rotterdam Convention. The Rotterdam Convention on the Prior Informed Consent Procedures for Certain Hazardous Chemicals and Pesticides in the International Trade (PIC) was adopted September 10, 1998. As of April 25, 2003, there were 42 parties to the Convention, and 73 signatories. The Rotterdam Convention builds on the pre-existing Prior Informed Consent Procedure administered by UNEP and FAO since 1989, by creating a legally binding obligation. The aims of the convention are to: (i) promote shared responsibilities and co-operative efforts between the parties in the trade of certain hazardous chemicals in order to protect human health and the environment from potential harm; and (ii) to contribute to environmentally sound use through the exchange of information. 27. The Conventions requires that exporters of chemicals covered by the convention obtain the prior informed consent of the importer for any export to occur. The Convention establishes a means by which the decisions of importing countries regarding the future imports of specific chemicals can be disseminated to exporting countries, and that these decisions can be enforced. The Convention also contains provisions to ensure that information regarding the potentially hazardous chemicals be made available to the importer and exporter. The chemicals initially specified in the Convention include 22 pesticides and five commercial chemicals, however the number of chemicals is expected to increase. ASP-PI will work within the framework of the Rotterdam Convention and will use the PIC procedures in the implementation of its own objectives. 28. Bamako Convention. The Bamako Convention on the Ban of the Import into Africa and the Control of Transboundary Movement and Management of Hazardous Wastes within Africa was adopted in Bamako, Mali, on January 30, 1991, and entered into force on April 22, 1998. It is open to member States of the African Union. 7 29. The convention aims to: (i) protect human health and the environment from the harmful effects of hazardous chemicals by reducing their production or reducing their hazard potential; (ii) adopt precautionary measures to ensure proper disposal of hazardous wastes; and (iii) prevent 'dumping' of hazardous wastes in Africa. The objective of the Bamako Convention is to create a framework of obligations to strictly regulate the transboundary movement of hazardous wastes to and within Africa. ASP-PI will have to work within this framework if the movement of stockpiled pesticides across country boundaries is necessary for the disposal of obsolete pesticide stockpiles. Country Ratification of theReleyant Conventions (a f M arch 84,2004) Convention Mali Tunisia Tanzania Morocco Ethiopia South Nigeria ___ ___ ___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ A fric a _ _ _ _ _ Stockholm x x x -8 x x x Basel x x x x x x x Rotterdam x x x x x x Bamako x x x x x = ratified; - = not ratified; ? = to be determined 2. World Bank Safeguard Policies 30. Since ASP-P1 will be executed through the World Bank, in collaboration with the ASP program partners, the project needs to meet the requirement of the World Bank Group Safeguard policies. These environmental and social safeguard policies are a cornerstone of the Bank's support to sustainable development and poverty reduction. They have been developed to ensure that Bank-financed projects (including as an executing agency for GEF ) both prevent and do no harm to people and the environment. Moreover, in addition to ensuring that projects are environmentally sound, these policies often provided a platform for the participation of stakeholders in project design, and have been an important instrument for building ownership among local populations and project proponents. 31. There are 10+1 safeguard policies, including the Bank's umbrella policy on environmental assessment (OP 4.01 and its Annexes) which guides the entire process and the scope and depth of environmental and social assessment required as part of project appraisal. The other safeguard policies are: Involuntary Resettlement (OP 4.12); Cultural Property (OP 4.11); Indigenous Peoples (OD 4.20); Pest Management (OP 4.09); Forests (OP 4.36); Natural Habitats (OP 4.04); Safety of Dams (OP 4.37); Projects in Intemational Waters (OP 7.50); and Projects in Disputed Areas (OP 7.60). The eleventh policy (in the group of 10+1) is the Bank Disclosure Policy (OP 17.50). In addition, all environmental and social assessment documents that are prepared as part of Bank supported project are subject to a consultation and disclosure process which need to be carefully documented. 3. National Frameworks of Participating Countries 8 The ratification process of the Stockholm Convention by Morocco has been initiated and is anticipated shortly. 8 32. The implementation of ASP-PI through country projects will also be subject to the legal and institutional framework of each participating country, including review, disclosure, and approval by the appropriate authorities. Although all ASP-PI countries have some form of Environmental Assessment regulation, the existing legal and administrative structure will differ greatly from country to country, as will the government agencies' responsibilities, particularly in relation to the management of pesticides and other chemicals. Identifying the adequacy of this framework (including reference to the international conventions referred to above) will therefore be a key preliminary task for implementation of ASP-PI at country level. 4. Legal Frameworks of Countries Where Disposal May Occur 33. In case where the selected disposal option (s) involve off-continent disposal or any other country that is not a program participating country, the legal framework in the receiving country (or countries) will be reviewed and adhered to. This is particularly relevant in case final disposal is to be undertaken in a European Union (EU) member country, in which case, for example, the EU's ban on import of soil will have to be strictly adhered to, and therefore may influence the final selection of disposal option (s). 9 III. PROJECT DESIGN 1. ASP Vision and Long-Tem Program 34. The African Stockpiles Programme grew out of a vision by African countries and their development partners to rid the continent of an estimated 50,000 metric tons of stockpiles of obsolete and highly toxic pesticides, and to ensure that policy and institutional frameworks are put in place so that the problem does not reoccur. Putting such a vision into practices has taken about 3 years of preparatory work, focused on stakeholder and resource mobilization, partnership building, and preparatory technical work, resulting in the design of an inclusive and ambitious program that would take some 15 years and significant financial resources to implement. 35. But given the magnitude of the problem, the availability of resources, and the state of preparedness of different countries, it will not be possible to work in all the countries of Africa at the same time. Therefore, the program partners have agreed to a phased implementation. Out of the seven countries participating in the first project, Nigeria has been selected as a test case for the development of a program template for effective prevention of accumulation of obsolete pesticides9. 2. The Proposed First Phase Project: ASP-P1 a. Project development objective (PDO) and project design 36. The project will support the strategic objective of reducing or eliminating, through clean up and prevention, the risks from stocks of obsolete pesticides to human and environmental health in participating countries affected areas. Furthermore, the project will contribute regional and global benefits through the implementation of the Stockholm Convention on POPs. 37. ASP-P1 will implement various clean up and site remediation measures to mitigate the impacts of the publicly held pesticide stocks on people and the environment, including global environment. At the same time, ASP-P1 will strengthen the regulatory and institutional framework, management practices (including promotion of integrated pest management), and public awareness to prevent an increase of pesticide risks in the future. Achievement of the PDO will be monitored through a set of indicators related to risk reduction (pesticides removed and sites cleanup, as well as improved human and environmental health conditions), capacity building (institutional capacity for pesticide effective management vastly improved), and quality of technical assistance and technology transfer to participating countries. The project design is based on a recognition that the existing level of information on the extend, geographic distribution and characteristics of the obsolete pesticide stockpiles is insufficient for planning and implementing pesticide disposal and site remediation measures. The design, therefore, reflects the need to carry out, in all project countries, extensive preparatory and prevention activities, including detailed pesticide inventories, selection of disposal technologies and preparation of country-specific environmental and social assessments (stage 1 activities). Only following the adequate completion of these activities, the clean up and disposal will take place (stage 2 activities). 9 The choice of Nigeria is based in part by the interest expressed by the country to deal with the problems and the interest of government of Canada to provide support through the ASP. 10 b. Project beneficiaries and project area 38. ASP-PI is designed to eliminate or reduce a major source of risk to human health and environmental resources. Therefore, the benefit flows from the project are mostly in terms of risk reduction, quality of life improvement, and capacity building. While some of these benefits will accrue directly to a large number of communities (once detailed inventories, site assessments, and baseline socio-economic surveys are undertaken as part of project implementation), other benefits will accrue at regional level, in terms of improved management capacity, lower social costs due to ill health, and higher productivity of environmental resources. 39. Project area. Designed as a first phase of a longer term program, the project will pilot the ASP approach in 7 countries, including: Ethiopia, Mali, Morocco, Nigeria, South Africa, Tanzania and Tunisia. The project will target areas-and surrounding communities-- where pesticides stocks are stored, mostly at wholesale or retail location, and in government warehouses and distribution centers. c. Project components 40. The project includes four components: 41. Component 1: Country Obsolete Pesticides Operations (estimated cost $44.13 million). This is the main component of the project, which includes all clean up and prevention activities toward achieving the project objectives in the participating countries. The majority of the services provided by the remaining three components will support this components which include four types of activities: (i) Clean up and disposal activities will be based on a detailed inventory of pesticide stockpiles and contaminated sites, determining the identity of the contaminant, its quantity, proximity to people. Country project management units (PMU) will carry out the inventory immediately after the project launch. The inventory will allow determining the priority of contaminated sites based on the risk to people and environment they represent. Inventories will also feed new data into the design of the clean up and remediation operations for individual contaminated sites. Once the inventory is complete, a plan for clean up and remediation will be developed by the PMU. This plan will be subject to a detailed Environmental and Social Assessment (ESA). The clean up and remediation will include various interventions including removal of pesticides from their storage point, transport to interim storage facility, decontamination of the site, decontamination or disposal of empty containers, repackaging of pesticides and pesticide disposal. Where possible, the disposal will employ in situ approach and involve reuse, recycling or reformulation; otherwise it will employ internationally recognized destruction technologies, including shipping overseas for incineration in specialized facilities'". In exceptional cases, the disposal operations will include contaminated soils. Where health risks from soils are extremely high, (e.g. in Mali where the large spill of POPs and other pesticide threatens important drinking water sources in the Sahara, the contaminated soils will be treated as pesticides and destroyed using appropriate soil disposal technologies. '0 This is not to be interpreted as giving priority ex ante to in-situ re-use, recycling or reformulation (including re-use and recycling of storage drums, containers, etc). If viable, these kind of activities can only be done under strictly controlled conditions once the exact composition and quality of the pesticides have been defined. (ii) Prevention of pesticide accumulation activities include strengthening of pesticide management through improvement of pesticide registration, licensing, enforcement of import controls, stock management, waste management, and formulation of effective procurement strategies; and promotion of alternatives to chemical pesticides through improvement of pest control strategies with particular attention to Integrated Pest Management for agriculture and Integrated Vector Management for health care. Prevention activities will also include development of emergency response plans, awareness and training for pesticide distributors, users and others to encourage safe pesticide handling and alternative pest control. (iii) Capacity building activities will include enhancement of laboratory capacity for reliable analysis, health and safety training, epidemiological and pollution studies, environmental monitoring as well as provision of equipment, vehicles and staff training for effective pesticide management. (iv) Project management and monitoring. The country program management activities will include establishment of a Coordination Unit (CU) in each country with the responsibility to implement the country level activities, solicit external technical support, monitor and evaluate project activities, and coordinate their implementation with the GEF funded National Implementation Plans for the Stockholm Convention (NIPs) and similar initiatives. Country level management will also include establishment of a national steering committee that will represent key stakeholders and oversee the work of the CU. 42. Component 2: Technical Support (estimated cost $3.28 million) . This component will finance technical and specialized expertise required for preparation (including ESA), design, implementation, supervision and monitoring of country level activities outlined under Component 1. The key technical support services that the component will provide will include technical advice requested by the CUs for preparing and implementing country projects, design and delivery of training, production of technical guidelines for clean up and prevention operations, assistance in managing technical aspects of procurement and supervision of specialized contractors, advice on linking countries with other specialized agencies and organizations, enhancement of health and safety, assessment of laboratory capacities and oversight of monitoring and evaluation. FAO will host a Technical Support Unit (TSU) to manage delivery of technical services envisaged under this component and tap into expertise of other ASP partners, e.g., UNIDO, UNEP, WHO, Basel Convention Regional Centers, NGOs and CLI. 43. Component 3: Cross-Cutting Activities (estimated cost $3.64 million). This component will finance knowledge management and outreach services across the entire Africa Stockpiles Programme to capture synergies and cost savings from tackling the problem of obsolete pesticides through a coordinated multi-country, multi-partner. The key component activities will include outreach to promote ratification of the Stockholm convention, raising funds from private and bilateral donors, building NGO capacity, hosting the ASP website, knowledge management and communication. Importantly, the component will include preparation of strategic studies on topics common to the entire ASP, e.g., preferred disposal technologies, IPM for locust control and prevention of pesticide smuggling. WWF International will host a Cross-Cutting Activities Management Entity (CCMEA) responsible for delivery of support services under this component. The CCMEA will mobilize the WWF in-house capacity, engage other ASP partners, procure consultants and award competitive grants to maximize the efficiency of service delivery. 44. Component 4: Project Coordination (estimated $1.41 million). This component will finance: a small unit that will consolidate work programs, budgets, financial and project reports; 12 and serve as a secretariat to the ASP Steering Committee. The World Bank will host the ASP Coordination Unit (ASP-CU) under ASP-P 1. 13 IV. BASELINE CONDITIONS IN AFRICA 1. Lifecycle of Pesticides in Africa 45. Virtually every African country is currently home to obsolete pesticide stockpiles, as well as to tens of thousands of tonnes of contaminated soils. The World Bank estimates that 20% of obsolete pesticides in Africa are POP chemicals, and another 30% are an inseparable mixture of POPs and non-POPs chemicals." The ongoing deterioration of pesticide containers and lack of necessary management of the current storage sites continue to increase the risk of greater contamination of soil, air and water, leading to major risks to human health. 46. The lack of comprehensive management strategies over the past 40 years, combined with a number of key factors, including government policy, contributes to the ongoing accumulation of pesticides. These factors include: (i) product bans: banned pesticides that remain unused over time; (ii) inadequate storage and stock management: pesticides have a limited shelf life which is shortened if they are not stored properly, etc.; (iii) unsuitable products or packaging: poor product specifications, unavailability of required application equipment, labels in foreign languages, etc.; (iv) donation or purchase in excess of need: excess products often deteriorate during storage; (v) lack of co-ordination among donor agencies: duplicated, unsolicited or excessive donations; (vi) commercial/entrepreneurial interest: over-assessment of need, inappropriate product supply, corruption; and (vi) government policy: central procurement, heavy subsidies, procurement for special programs like locust control, and lack of record keeping, follow up, especially post deregulation of the sector. 47. Obsolete pesticide stores can be found in numerous locations, and as a result of accumulation at various steps in pesticide distribution and use, as illustrated in the lifecycle diagram in Figure 1. Pesticides are often imported into Africa, although some may be manufactured on continent. Following their manufacture and/or import into Africa, the pesticides are transported to wholesale storage and distribution sites. The pesticides are then sold and distributed to major users, retail stores and individual users. Major users, such as government agencies, major industries, or industrial farms, may then either store or apply the pesticides. Smaller retail stores will resell pesticides in smaller quantities to individual users, or store them for sale at a later date. Individual user may immediately apply the pesticides, or store them for later use. The potential exists at each of these sites (wholesale distributor site, major user, retail store and individual user) for pesticide obsolescence to occur. 48. Pesticides that are not sold prior to their expiration date become obsolete, and may be found within wholesale sites and in smaller stores. Pesticides that were purchased either by major users or by individual users and were not used may also become obsolete. The sources of obsolete pesticides are indicated on Figure I in red and yellow. Although individual users may own and store obsolete pesticides which may pose grave health risks, these sources are outside the scope of the project and the environmental and social assessment. Africa Stockpiles Programme, 2002. Programme Overview. June 2002 (www.africastockpiles.org). 14 Figure 1. Pesticide Life-cycle Issues covered by ASP- Material Extraction Pl's Environmental and Social Assessment Sources of Obsolete Pesticides Included in scope of ASP-P1 Manufacture Sources of Obsolete Pesticides not covered by the Environmental Tapti and Social Assessment Transportation Study Reformulation .Persistence in the Environment 15 2. Overview of Current Country Conditions 49. Although the conditions of pesticide stores vary from country to country, the overall condition of current stores (confirmed by sites visits in several countries) present serious human health and environmental risks. Although some countries have begun inventory, clean-up and disposal activities, many African pesticide stores have yet to be inventoried, let alone stabilized and subjected to remediation. 50. In many cases, pesticide containers have deteriorated and pesticides are able to escape into the surrounding environment. One recent country report stated that "containers have deteriorated, corroded and started leaking, while bags have perished, spilling their contents on floors or directly on the soil"12. The stores themselves are often in poor condition and do not comply with FAO guidelines on pesticide storage13. 51. Storage sites may lack proper ventilation and pose serious health risks due to their proximity to houses and workplaces, their location on flood plains or near areas with high water tables. The risks posed by such stores include the risk of fire, and of contamination of local drinking water from infiltration through contaminated soils. 52. One of the greatest challenges facing ASP programme and project planners is the uncertainty surrounding the quantity and location of obsolete pesticide stores currently in Africa. Although several countries have completed initial and/or detailed inventories, many others have yet to gain a clear idea of the quantities, nature, locations and conditions of pesticide stores within their boundaries. 53. Furthermore, the experience of countries who have already completed detailed inventories has shown that estimated numbers are generally lower than those found upon detailed investigation. The amount of obsolete pesticides stocks within Ethiopia was initially estimated to be approximately 1500 tonnes of obsolete pesticides with 500 tonnes of contaminated soils at 400 sites"4. After a subsequent detailed inventory, the numbers were revised to 2900 tonnes of obsolete pesticides, 1000 tonnes of contaminated soils in 900 sites. The investigation further revealed that 400 tonnes of the stock was still useable, and was re-channeled for later use. Similarly, other countries have revised estimates upward after beginning inventory activities. 54. Much of the difficulty in estimating the total quantity of obsolete pesticides (and the associated heavily contaminated soils and packaging) can be attributed to decades of varying degrees of record keeping and documentation of pesticide imports and stockpiling, as well as little to no detailed inventory assessment. Efforts to gain a detailed understanding of the nature and distribution of obsolete pesticide stores may be hampered by a number of factors, including: damaged, worn containers and leaked pesticides; missing or worn off labels; existence or location of small storage sites not recorded; remote location of some storage sites; and, no inventories at storage sites. "2The United Republic of Tanzania, Obsolete Stockpile Programme, Obsolete Waste Disposal Project country report, February, 2003, p.7. 13 The Federal Democratic Republic of Ethiopia, Africa Stockpiles Programme, Obsolete Pesticides Project, Second Phase Country Report, February 2003, P.7. 14 The Federal Democratic Republic of Ethiopia, Africa Stockpiles Programme, Obsolete Pesticides Project, Second Phase Country Report, February 2003, P. 9. 16 55. An additional difficulty in estimating the quantity of obsolete pesticides in Africa is the potential for fluctuations in the amount of obsolete pesticides within individual storage sites as useable pesticides pass their expiration dates and become obsolete. Where no inventories have yet been undertaken there is an urgent need to begin detailed inventories to help verify the status of the stock and the need for clean up and disposal. Such data is essential to programme and project planners to ensure that the sites that pose the greatest environmental and human health risks are stabilized and cleaned up. 56. Table I below summarizes the status of information on amount of obsolete pesticide and storage sites for countries participating in ASP-Pl. Table 1. Summary of Available Data and Project Activities in ASP-PI Project Countries Country Number of Amount of Amount of Project Project storage sites pesticide contaminated P&P C&D (tons) soils (tons) Activities Activities Ethiopia 900 2,500 1,000 Yes Yes Mali 76 500 40,000 Yes Yes Morocco 225 700 500 Yes Yes Nigeria N/A 50 (incomplete) N/A Yes No S. Africa Na 250 N/A Yes Yes Tanzania 350 1,200 1,300 Yes Yes Tunisia 17 452 & 16,600 N/A Yes Yes Liters P & P = Preparation and Prevention C &D = Pesticide Clean-up and Disposal 17 V. ENVIRONMETAL AND SOCIAL IMPACTS 1. Overview 57. The stockpile of obsolete pesticides in the seven countries participating in ASP-P1`5 is recognized as having potential to generate wide ranging environmental, human health and socio- economic impacts. In the broadest sense these impacts are associated with the high degree of toxicity of the substances involved, their recognized persistence within the environment and the degree of control exercised over their storage. While circumstances vary from country to country, currently many obsolete pesticides are stored in inappropriate facilities that are widely distributed, generally located within or adjacent to human settlements and by extension therefore, close to drinking water supplies. 58. Clearly, the assessment, removal and disposal of obsolete pesticides and the remediation of storage sites in ASP-P1 countries will have considerable positive environmental and social impacts in these countries and globally. However, inherent in this process (that is in the proposed ASP-PI project), are unique environmental and social risks, which are identified and described in details in this section, and which form the basis for the Environmental Management Plan (EMP) presented in section VIII. 59. In the short term, the activities associated with the removal and transport of pesticides may be expected to increase the risk of uncontrolled releases into the environment, while the introduction of technologies to dispose of obsolete pesticides and for the remediation of contaminated storage sites will, in themselves, introduce a new spectrum of potential impacts. 60. The potential environmental and social impacts associated with ASP-P1 can arise from the following sources: > Release of pesticides from project activities involving storage, handling and transportation; > Non-pesticide related project activities, including impacts arising from the construction/ rehabilitation of buildings and facilities, other infrastructure, and institutional capacity building; > Construction and operation of pesticide disposal facilities; > Potential effects associated with the clean-up and remediation of contaminated sites; > Socio-economic impacts on local communities; and, ) Cumulative environnemental impacts. 61. As described in the methodology section (Section 1-3), the analysis and review of the potential environmental and socio impacts of ASP-P1 leads to the distinction between two types of risks associated mostly with the implementation of the component I of the project: i. Risks associated with country specific "preparatory to clean-up activities" (Stage 1 activities); and ii. Risks associated with the development and implementation of country specific clean-up plans (Stage 2 activities). 5 "ASP-P 1 countries" will be used throughout to refer to the seven countries supported through ASP-P1. 18 62. It is important to note that the nature and scope of risks associated with Stage I activities is qualitatively and quantitatively different from those raised at Stage 2. In particular, Stage I risks relate to preparatory activities that will have limited adverse environmental and socio- economic impacts, or where mitigation measures can be developed based on generically available information (e.g., conducting inventories using FAO standards). By contrast, risks associated with Stage 2 activities are potentially greater and will require country specific clean-up plan details in order for mitigation measures to be developed. While a more detailed description of the nature and scope of each stage's risks is presented in subsequent section, the interrelationship between the key activities is shown in Figure 2, and the main potential environmental social impacts and risks associated with project activities are summarized in Table 2. Figure 2. Project Activity Sequence and Stage National Conduct institutional Prevention Inventory and Legal Public Assessment Consultations Pro Emergency 4 F Draft Stage 2 Plan (Country Plan) Environmental and Social Assessment Public Consultations Staae I Activitv Pesticide Removal and Site Prevention Action Stae 2 Activi Remediation tivit7v71 19 Table 2. Summary of Key Impacts Stage 1 Activities Project Key environmental and social impacts (all ASP-Pl coiftries) Component a) Inventory and I (i) Increased risk of exposure to workers and local emergency repackaging community Increased risk of contamination of environment, especially land and surface/ground water Disturbance of local communities through inventory process b) National legal and I (iii), 2, 3 Potential positive benefits in terms of education and institutional capacity capacity building building c) Identification of priority I (i) No direct impacts - however will influence the sites effectiveness of Stage 2 activities through d) Development of I (ii), 2,3 No direct impacts - however will influence the emergency response plans effectiveness of Stage 2 activities e) Public consultation and I (ii), 2,3 Potential positive benefits in terms of avoiding education exposure and prevention of build up of additional stocks of obsolete pesticides f) Development of I (ii), 2,3 Potential positive benefits in terms of prevention of prevention plans build up of additional stocks of obsolete pesticide stocks g) Development of draft 1 (i) No direct impacts - however key step in ensuring country specific country specific issues are addressed (including implementation plans choice of disposal method(s), infrastructure requirements and extent of site remediation required) h) ESA of draft country 1(i) No direct impacts - provides for development of specific plans mitigation measures Stage 2 Activities Project Key environmental and social impacts (all ASP-Pi countries Component except Nigeria) a) Review and 1 (i) Highest risk of contamination of environment, implementation country especially land and surface/ground water from specific clean up movements of obsolete stocks b) Prevention plans Disposal of hazardous wastes (both obsolete pesticides and contaminated materials or soils), potentially including international waste transfers and shipments Potential for disruption of communities and socio- economic issues associated with project activities Potential environmental and socio-economic impacts from construction of in country facilities and infrastructure 2. Stage 1 Activities and Risks 63. The principal source of direct environmental and socio-economic impacts during conduct of Stage I activities is related to: (i) planning and conducting a country inventory, and (ii) any 20 emergency repackaging arising from poor/dangerous storage conditions discovered during the inventory phase and requiring immediate attention. 64. The types of hazards involved are site specific and include pesticide exposure to both the workforce and the surrounding inhabitants and their environment from airborne exposure (dusts etc), contamination of water sources, and accidental ingestion. In addition, the impact on communities may include temporary restrictions on access during the inventory process, and community fears and concerns over the nature of the process being undertaken. 65. While the above issues are significant (including the potential loss of human life, in a worst case scenario) the current--internationally established and used--controls and processes are sufficiently developed to manage and mitigate these risks to an acceptable level. These mitigation measures, involving the use FAO Worker Training and Equipment Guidelines supervised by international experts, are outlined in Section I of the ESMF.16 66. Other activities that will be undertaken as part of this Stage 1 (planning and program building stage) are: (i) identification of priority sites; (ii) national institutional/legal capacity assessment; (iii) development of an emergency response plan; (iv) public consultation and education; and (v) prevention planning (including activities such as IPM plans). These activities, which are essential for the development and assessment of country specific plans, will have low or negligible environmental and socio-economic impact. 3. Stage 2 Activities and Risks 67. Stage 2 activities and risks are by comparison to those covered under Stage 1 greater both in magnitude and scope, and require in depth country and site specific information and analysis for their adequate assessment and for development of mitigation measures. They include the physical clean-up of obsolete pesticide stocks and the development and implementation of prevention programs that fall outside the scope of those delineated as Stage I activities. In addition, Stage 2 prevention programs would include development and implementation of country specific programs for reduction in reliance of pesticides, involving for example, introduction of biological controls. 68. Stage 2 activities may include the building and operation of physical storage and treatment/disposal facilities; bulk transport of obsolete pesticide stocks; and assessment and clean-up (to an extent limited by the scope of the Africa Stockpiles Programme) of contaminated soils and groundwater. 69. The biophysical and socio-economic risks associated with such activities are highly significant and program activities related to this stage should not be undertaken without the prior completion of a country level environmental assessment. Therefore, the preparation of a country specific ESA'7 4. Socio-Economic Impacts 16 The ESMF is described in details in Part 2 of the Consultant Report. '7 Given the nature and scope of risks involved, country ESAs will need to meet the requirements of World Bank's category "A" projects, and will include a resettlement Policy Framework to deal with potential social impacts. 21 70. Human health and the well-being of communities, socially and economically, are of special concern in the development and implementation of ASP-PI. Many of the burdens of obsolete pesticide stocks are bome disproportionately by poorer communities. A number of factors influence this. Many obsolete stockpiles are located within poorer communities, increasing the risk of exposure on a day to day basis. This exposure can arise through a number of pathways. Direct exposure can arise through simple proximity to the store or through the scavenging of materials (such as containers) to be reused for other purposes. The dangers associated with such scavenging are exacerbated by the low levels of literacy amongst the poor, who are often unable to read warning labels or to follow printed instructions. Indirectly, human populations may also be effected by contamination of water sources or of agricultural land arising from run off from unprotected stockpiles. 71. A key objective of ASP-PI is the alleviation of such burdens and the protection of communities from the reoccurrence of the problems created through effective prevention measures, including public education and outreach. In doing so, however, it is also important to ensure that that additional socio-economic burdens are not created or imposed through the development and implementation of the project activities themselves. 72. To a certain degree, socio-economic impacts may be generated by almost any project activity, however, their potential incidence of occurrence and severity is greatest during the conduct of inventories and associated emergency repackaging and during Stage 2 activities of clean up and prevention. In the case of Stage I activities (inventory and repackaging) socio- economic impacts are likely to be restricted in nature to those associated with human health (through increased risk of exposure), potential temporary restriction of access and community fears and concerns over the nature and reason for the process being undertaken. These may be significant issues at the local level and the inventory process should be conducted in a manner that is sensitive to these factors. Section I of the ESMF sets out mitigation measures to be followed in this respect. 73. Stage 2 activities, by contrast, have the potential for more wide reaching impact. The precise nature of these impacts will vary on a case by case basis, however, it can be anticipated that Stage 2 activities may create potential concerns over such issues as: > Human health; > Property rights and divisions, including under exceptional cases, resettlement; > Land values; > Agricultural quality of land and associated yields and production; > Economic opportunities, including employment and other sources of income; > Education and skills/technology transfer; > Accessibility to important resources; > Cultural heritage and its links to a specific geographical location; and > Traditional knowledge, as embedded in the members of the community. 74. Examples of Stage 2 activities that may create such concerns include: 0 Construction and/or operation of physical infrastructure required to implement the project at the country level such as transport infrastructure, storage facilities; treatment and disposal facilities; > Where carried out under the scope of the project, the remediation of contaminated soils and waters; and > The development and implementation of country specific pest management strategies. 22 75. The above activities may have both positive and negative socio-economic consequences, for example the construction of a new storage facility may have adverse implications for property rights and land values for specific individuals while creating new economic opportunities for the wider community. 76. Because of the widespread and high potential for such impacts arising from Stage 2 activities, these will form an important component of the country level ESA required prior to the commencement of this stage. Given the nature and scope of risks involved, country EASs need to meet the requirements of World Bank's category "A" projects, and will include a resettlement Policy Framework to deal with the potential social impacts described above. Further guidance on this matter is provides in Section 7 of the ESMF and Annex B of the Consultant Report. 5. Cumulative Impacts 77. Potential cumulative environmental or social impacts of ASP-P1 are those impacts that will continue beyond the project, and which are essentially linked: (i) on the negative side, to the type of obsolete pesticide disposal option selected at the country level,'8 and (ii) on the positive side, to the institutional capacity building developed by the project. 78. Potential negative cumulative impacts. Where local disposal options are chosen for lower risk material the operation of such facilities will generate cumulative impacts. The operation of landfills will generate a continued risk of contamination arising from improper design/operation or closure. Such risk will increase over time as the quantity of landfill increases and the landfill site ages. In order to manage this risk effectively, all such disposal sites should be sited to accepted standards and should be operated according to an agreed "Operating Plan". This plan should include: (i) the nature of waste(s) to be accepted; (ii) how waste is to be filled; (iii) inspection and monitoring requirements; and (iv)instructions on steps to be taken in the event of an accident. 79. In addition to operational concems for such facilities, consideration must also be given to their continued financial viability and responsibility for the maintenance and/or safe closure of the site should the operator go out of business. This is often handled through the form of a financial bond or guarantee. 80. The addition of waste generated through ASP-P1 and the longer term program to European incineration volumes may be a potential cumulative impact, however, information collected from a number of European waste companies indicates that the industry is technically and commercially capable of handling the nature and volume of waste streams expected to be generated by the ASP program as a whole. 81. Potential positive cumulative impacts. The positive consequence of infrastructure and institutional capacity building should be a key benefit of the project This will include: > The development of new regulations and frameworks, which may then be applied to address issues other than obsolete pesticides; > The development of human capital through training and experience; and 18 A detailed discussion of these options together with advantages and disadvantages is given in Annex F of the Consultant Report. 23 The provision of new physical infrastructure, where required, such as roads, bridges and port facilities. 6. Compliance with World Bank/IDA Safeguard Policies 82. This section briefly summarizes the conditions under which the World Bank Safeguard Policies may be triggered by project activities involving storage, transportation, disposal and site remediation, and which are detailed in the Environmental and Social Management Framework (ESMF). 83. As indicated in Table 3, two of the Safeguard Policies are certain to be triggered by ASP- P1 implementation activities, while several others may be triggered in certain circumstances, to be determined during the preparation of country specific clean-up plans and associated ESAs. Table 3: World Bank Safeguard Policies Safeguard Policy Triggered Nature of Activities and timing by ASP-P 1 Activities Environmental Assessment (OP Yes Pesticide Removal and Site Remediation 4.01, BP 4.01, GP 4.01) Pest Management (OP 4.09) Yes Pesticide Removal and Site Remediation Prevention Naturel Habitats (OP 4.04, BP Possibly Pesticide Removal and Site Remediation 4.04, GP 4.04) Identification of Priority Sites Indigenous Peoples (OD 4.20) Possibly Pesticide Removal and Site Remediation Identification of Priority Sites Involuntary Resettlement Possibly Pesticide Removal and Site Remediation (OP/BP 4.12) Identification of Priority Sites Cultural Property (OP 4.11) Possibly - Forestry (OP 4.36, GP 4.36) No - Safety of Dams (OP 4.37, BP No - 4.37) Projects in International Waters No - (OP 7.50, BP 7.50, GP 7.50) Projects in Disputed Areas (OP No - 7.60, BP 7.60, GP 7.60) 7. Overall Programme and Reputational Risks 84. The successful implementation of the Africa Stockpiles Programme in general (starting with ASP-PI) is based in a number of explicit and implicit assumption. This section briefly 24 reviews the risks associated with the potential failure of these assumptions, as distinct from the risks associated with specific project activities and described previously. 85. There are at least seven major types of Programme risks (summarized in Table 4) two of which may be considered "high risk:" (i) international public opposition to off-continent disposal option (in case this option is selected); and (ii) damage to the reputation of World Bank Group, GEF and other partners arising from potential problems with implementation of program civilities. 86. Sources of reputational risk. The nature of the programme activities, their potential to attract attention from diverse groups (including NGOs and the media, both at national and international levels) and the potential "downside" if there is a major programme failure despite all the controls, implies that ASP is a source of "reputational risk" both to the Bank and to major programme partners. Perhaps the most significant source of such risk is the global attention that would follow a single catastrophic programme failure (such as a major accidental release of POP pesticides from a bulk transport operation, or failure to follow international conventions leading to a shipment being refused landing at the destination port). As the implementing agency for the ASP the Bank would, under such circumstances, likely be judged as "guilty by association" even when it may have taken all reasonable measures to prevent the event. This would not only adversely impact the Bank's public image but would also cast doubt on the Bank's "corporate management" competency with existing and future programme partners and stakeholders. This issue is considered further as a separate element in the overall Environmental Management Plan for the ASP. 87. Mitigation of repuational Risk Important measures to reduce or eliminate these high risks focus on: i. maintaining an open and transparent approach to implementing the ASP; ii. relying on multi-sectoral approaches to build understanding, commitment and public trust; iii. maintaining strict adherence to the World Bank's Safeguard Policies; and iv. ensuring that all participating countries have signed or ratified the Stockholm Basel, and Rotterdam Conventions. 88. These same measures are highly effective in addressing other Programme risks that may not be ranked as high, such as the risk that a participating African country may reduce its commitment to the Programme, or that the Programme may need to operate in an area of conflict. 89. It is important to note that the above approach to reputational and programme risk mitigation is relies to a significant degree on the capacity and willingness of participating countries to develop, implement, operationalize and enforce environmental legislation that meets the requirements of relevant international conventions (in particular the Basel Convention and Stockholm Convention). Therefore, the importance of proper completion of Stage 1 planning activities cannot be underestimated - and in particular those activities that relate to the legislative and environmental management capacity within each participating country. Where such capacity does not exist or is not adequate, building and establishing this capacity will be an essential element in the management of this risk.'9 19 The case of Nigeria which proposes to focus exclusively on prevention and capacity building activities as part of ASP-PI, is a pilot case to watch in this regard. 25 90. In order to maintain an open and transparent approach to the implementation of the programme it is recommended that: i. The partnership and consensus based approach used to date in the development of the programme (and in particular in the resolution of specific programme issues, such as the inclusion of contaminated soils in the scope of the ASP) be maintained; ii. All major programme decisions be taken in a participatory manner, where all stakeholders are given the opportunity to make input to the decision making process; iii. Clear communications are maintained with all programme partners and stakeholders and that the rationale for key decisions is clearly stated and explained both to programme partners and (to the wider audience) through public communications; iv. Issues and lessons arising from the implementation of ASP-P1 in specific countries are used to inform key programme decisions and that such issues and lessons are made readily available to all partners and stakeholders; v. No one organization or sub-set of programme partners may make significant changes in programme scope or direction without consultation with all partners in the ASP; and vi. Finally, that an independent audit of programme activities be conducted on a minimum of an annual basis, with the audit scope addressing the extent to which the above factors are being maintained as well as the progress of the ASP towards its overall goals and objectives. Table 4: Summary of Assessments of Key Programme Risks Programme Risks Likely Level Risk Mitigation Measures of Risk Reduced commitment by Low * All participating countries have signed or ratified a participating African Stockholm , Basel and Rotterdam Conventions government at * Country programme to be based on multi-sectoral implementation stage national steering committees * Close liaison with technical support unit Poor interagency Medium to * Country programme to be based on multi-sectoral cooperation in country High national steering committees * Public awareness, as well as capacity building activities Need to carry out ASP Low * All participating countries have signed or ratified activities in an area of Stockholm and Basel Conventions conflict * Country programme to be based on multi-sectoral national steering committees * Close liaison with technical support unit * If risks are high, consideration will be given to preclude ASP activities in area of potential conflict 26 Programme Risks Likely Level Risk Mitigation Measures of Risk Catastrophic accident Low * Ensure highest standards of vessel safety and (e.g., breakup of security container vessel * Close liaison with technical support unit containing hazardous * Compliance with international maritime materials) conventions such as MARPOL Annex III and the International Maritime Dangerous Goods (IMDG) Code Country public Medium * Open and transparent development of ASP opposition to ASP * National and local awareness/ education/ activities outreach International public High * All participating countries have signed or ratified opposition to off- Stockholm and Basel Conventions continent disposal option * Open and transparent development of ASP * Involvement of NGOs during implementation Problems with ASP High All participating countries have signed or ratified implementation damage Stockholm and Basel Conventions reputation of World Rigorous enforcement of Safeguard Policies Bank, GEF and other Open process partners Multi-sectoral advisory committee 27 VI. PARTICIPATORY APPROACH 1. Project Preparation Phase 91. Since its inception in December 2000, the Africa Stockpiles Programme has evolved as a partnership initiative based on the involvement and participation of all stakeholders, expressed through both formal and informal communications and consultations. In addition to partners meetings involving country representatives20, international NGOs, the private sector, and international development institutions, in the course of preparing their individual projects, participating countries have also conducted consultative workshop among key internal stakeholders. 92. The most recent formal consultation was the "Partner's Meeting and Country Workshop" held in Midrand, South Africa, between September 9 and 19, 2003. This was attended by key partners in the ASP and by representatives from seven countries involved in Phase 1 of the ASP. The workshop presented country updates for Ethiopia, Tanzania, South Africa Nigeria, Mali, Morrocco and Tunisia. Key issues emerging from this workshop were: * Ratification of the Stockholm Convention on POPs - Ethiopia, South Africa and Mali have already ratified the convention, while the process is almost complete for Tanzania and Nigeria, and well underway in Morocco and Tunisia. Ratification of the Stockholm Convention is seen as a key pre-cursor to participation in the ASP; * The concept of dividing each country project into two or three stages was discussed and generally agreed. There was consensus that a two stage approach would provide the degree of monitoring and control required and that detailed triggers for release of Stage 2 funding should be identified. Stage 1 would cover some activities for the life of the project (project management and some prevention activities) while Stage 2 would cover clean-up of sites. This has implications for project funding and for the timing of country level environmental assessments; and * The responsibility of the ASP for remediation of contaminated soils remains an issue. There was consensus that soils would be dealt with only when there is evidence that soils contamination results in very high risks for public health and the environment. Mali is quoted as an example where this is expected to be the case, while Morocco and Tunisia are quoted as more contentious examples. The view of the meeting was that the scope and magnitude of soil remediation activities under the ASP should be addressed on a case by case basis and can only be fully defined at the time of appraisal of Stage 2 activities. 93. It is important to note that the consultative process during the preparation phase of ASP- P1, has been critical in influencing project design and shaping the analysis and conclusions of the environmental and social assessment. 2. Project Implementation Phase 94. The consultative process started during programme preparation is expected to continue and intensify all through the implementation of ASP-PI and beyond, and particularly through two key stage I activities, as part of the preparation of country clean-up plans (see Figure 2): 20 Meetings were held in Paris (February 2003), Rome (April 2003) and Washington (February 2004). 28 Public consultation and education activity (part of project component 2), focused on: * Developing and implementing a comprehensive and integrated public awareness, education and consultations programme to support implementation of the ASP-P1 at the national and local levels, as well as efforts aimed at prevention (reducing the stream of obsolete pesticides); and * build longer term capacity in the country for engaging citizens and communities in addressing national and local environmental challenges. Public consultation, as an integral part of the preparation of country ESAs. 29 VII. ANALYSIS OF ALTERNATIVES 95. Because ASP-Pt is fundamentally about environmental and social sustainability, the analysis of alternatives considered as part of the preparation of the environmental and social assessment has significantly influenced the final design of the project. While the main design alternative--to the current design- considered is to continue "business as usual," the assessment also focused on the analysis of disposal options. 96. The "Without project" alternative, represented the current or moderately enhanced individual effort of FAO and other donors in separate country initiatives. This alternative was rejected because it did not offer any of the economies of scale, synergies and visibility captured by the current ASP-PI design. In addition, the unique set of risks posed by stocks of obsolete pesticides across the continent, despite differences in scale and spatial distribution, requires that an overall common approach, consistent with international standards and experience, be used in order to marshal a critical mass of technical know-how, political visibility and support, and sufficient financial resources, to provide a viable and sustainable solution to the problem. Although the actual social and environmental cost of the "business as usual" scenario has never been attempted-partly because of the paucity of reliable data-all assessments point to the fact that project benefits significantly outweigh its cost. The willingness of the international community to provide grant resources through GEF is an indication of "willingness to pay" for a risk perceived to be substantial. Moreover, the expected project benefits in the areas of institutional capacity building are also expected to have a multiplier effect in terms of the capacity of the participating countries to mainstream environment into national development plans. 97. Alternatives disposal options. As part of the ASP mandate, on-site obsolete stores will be identified and inventoried, repackaging for transport and site remediation will take place. Obsolete pesticides will be repackaged and should then be removed to centralized storage to be stored until a disposal method is available. Several options are open to the project for the disposal of obsolete pesticides and pesticide wastes. The suitability of disposal options will depend on the obsolete pesticide formulations in need of disposal, the quantity of obsolete pesticides, the infrastructure in existence to support the disposal facility, and the technical and scientific capacity of the region. Disposal options range from relatively simple methods to technologically and logistically complex options. Prices vary according to the options and the necessary infrastructure. 98. The options reviewed at length as part of this assessment2" have been grouped into three main categories: i. Off-continent disposal (export to a disposal facility in a non-African country); ii. Long term storage; and, iii. African disposal, including thermal neutralization techniques, chemical treatment and landfill. x. Although the technical option of reformulating obsolete pesticides does exist, it is not permitted within the Stockholm Convention. The Convention states that pesticides deemed obsolete are "not permitted to be subjected to disposal operations that may lead to recovery, 2i See Annex B of Consultant Report 30 recycling, reclamation, direct reuse or alternative uses of persistent organic pollutants".22 Reformulation of useable pesticides may be permitted under the Convention, but falls outside the FEA mandate and will not be discussed. 22 Stockholm Convention on persistent organic pollutants, Article 6, 1 d). 31 VIII. ENVIRONMENTAL MANAGEMENT PLAN (EMP) 1. Overall Design of the EMP for ASP-Pl 99. The Environmental Management Plan (EMP) describes the actions (including mitigation measures, cost, and institutional arrangements) that must be taken in order to ensure that ASP-P I implementation is undertaken in an environmentally sound manner and without adverse socio- economic impacts. The structure of the EMP is linked to the "staging" of project activities and is driven by the following three issues: i. The importance of ensuring that the "inventory activity" is conducted in a manner that minimizes risks to the environment, to inventory workers and to local communities; ii. The importance of successful completion of Stage 1 activities as a precursor to starting Stage 2 within any country; and iii. The need to conduct a country project environmental and social assessment (referred to "CP-ESA") prior to commencing Stage 2. 100. A key element of the EMP is the ESMF, which seeks to guide implementation of the ASP at the country level by detailing: (a) the mitigation measures required to eliminate or reduce to an acceptable level the environmental and socio-economic impacts associated with the conduct of Stage I activities (describes in section V above); and (b) the issues to be considered in the conduct of a CP-ESA for Stage 2 activities. 101. The role of the EMP is to provide an overall programme for the management of the environmental and social impacts associated with ASP-PI, while the ESMF is to provide practical guidance to those responsible for the planning and implementation of ASP-P1 at the country level. The ESMF (Figure 2) therefore provides more detailed information on mitigation measures and is an integral part of in EMP. In addition, it is important to note that country level CP-ESAs which will guide the design and implementation of stage 2 activities (i.e., essentially disposal) in each country will have their own detailed EPMs (called CP-EMPs). 102. It is important to note that except for Nigeria, which will be involved in stage 1 (prevention) activities only, the other six countries participating in ASP-Pt will be subjected to a condition of disbursement in their Grant Agreements, reflecting the requirement and the need to prepare a CP-ESA which meets the World Bank requirements for category "A" projects, before they can proceed to stage 2 activities. 103. Because of the intrinsically environmental nature of ASP, there is an important overlap between key program activities and mitigation measures which are part of the EMP. Therefore, the EMP is presented below on the basis of the total estimated costs of seven key program activities, as well as incremental costs associated with these activities. 104. Moreover, it is important to note that the EMP is designed on a "per country" basis. Given the wide range of individual country circumstances, it is by its nature a "generic" EMP which should be used for guidance purposes and will need to be adapted the EMP are in the order of $1.75 per country23 to individual country circumstances. This implies that the need for setting 23 This estimate includes includes an "offset" figure which relates to an estimate of the potential to reduce the "per country" cost by the use of centralized management planning or programme development. This 32 aside some resources at the program level in a "unallocated" cost category in order to adjust to specific country needs as the implementation of the EMP gets underway. 105. While there will be variation on a country by country basis, the EMP is typically expected to take up to 3 years to implement (when starting from scratch) and costs associated with It should be noted that this cost and time-scale includes only those factors that ensure sound environmental management of the programme and that can be reasonably estimated at this time. Costs and time-scale associated with construction of ASP-PI related infrastructure and the operational implementation of Stage 2 activities are therefore excluded These will be provided under the operational planning activities for ASP-P1I. Summary EMP Activity Costs and Estimated Estimated Estimated Timeline date of Total Cost of Incremental Completion Activity Cost of (from start) Activity 1.0 Conduct Inventory Month 18 $0.75-$1.5 $0.375 2.0 National Institutional/Legal Capacity Month 6 $0.5 $0.1 3.0 Identification of Priority Sites Month 24 $0.25-$0.5 0 4.0 Emergency Response Plan Month 24 $0.25 $0.125 5.0 Public Consultation and Education Month 24 $0.25-$0.75 $0.3 6.0 Prevention (stage 1) Month 24 $1.0 0 7.0 Pesticide removal and site remediation Month 36 $1.0 $0.85 (stage 2) Total Cost Estimate $4.0-$5.5 $1.75 *** Month of completion assuming activities conducted concurrently (as indicated in Figure 2). 2. Key elements of the Environmental Management Plan24 may be achieved through existing resources (the ASP team) or by expansion of resources to facilitate such "central development" of program elements. 24 Information contained in summary EMP tables Mitigation measure - shows summary of action to be taken Responsibility: Proj = Responsibility of the country project team Proj/Prog = Principle responsibility is country project team - support from programme Prog/Proj = Programme team to provide co-ordination - project team to implement locally Need for measure - shows reasons that measure required Cost - shows estimated costs for sub-activities plus overall estimate for total activity Time required - shows estimated time for sub-activities plus overall estimate for total activity ESMF reference - identifies element of ESMF providing more detailed mitigation measure Cost assumptions * Costs are for indicative purposes only and may vary from country to country as a result of specific circumstances ** Time required is for indicative purposes. Total time required assumes that some sub-activities may be planned to be completed concurrently- 33 106. The following sections provide a breakdown of the key elements of the EMP. *The tables at the end of each section provide details on the costs, and timeframe associated with each activity. a. Inventory of Obsolete Pesticides (Stage 1 Activity) 107. The first essential step required for establishment of an ASP programme in a specific country is the conduct of an accurate inventory. This inventory provides the country project manager with the baseline information required to plan and implement the later steps of the project. At the same time the data collected during this process will provide the quantitative and qualitative information needed for the conduct of the country environmental assessment required prior to commencement of any Stage 2 activities. This information will include the location of obsolete pesticide stores, types and quantities of obsolete pesticides contained in each store and a review of storage conditions (state of pesticide containers and storage structures). It is also recommended that during the course of the inventory, a preliminary assessment of sensitivity of the surrounding environment to impacts from the project is conducted. This initial scan should encompass such issues as proximity of obsolete pesticide stores to human dwellings, places of work, schools, areas of agriculture, drinking water sources and biophysical features, such as wetlands and rivers and an initial assessment of potential for wider contamination. This preliminary assessment will provide information to be used in later Stage 1 activities and specifically in the prioritization of sites. 108. The conduct of the inventory also provides an opportunity for immediate action that will reduce the threat to the environment and human health posed by obsolete pesticides stored in deteriorated packaging or containers. While this action increases the risk of exposure to pesticides, particularly to the workforce (through handling and repackaging activities), these risks can be mitigated through following the recommended steps contained in the ESMF. By contrast, the potential gains to be made in terms of human and environmental protection are significant and should not, without due cause, be delayed. Table 5. EMP for Conduct of Inventory Mitigation Measure Responsibility Need for measure Cost* Time required- ESMF ref: 1.0 Conduct Inventory $0.75 to $1.5 M 12 to 18 months ESMF #1 1.1 Training Prog/Proj To ensure inventory staff < $0.25 M 3 to 6 months are aware of and able to follow safe working and environmental practices. 1.2 Equipment and PPE Prog/Proj To protect inventory staff < $0.25 M <3 months from human health hazards (assumes no need and protect the environment to construct new and local communities from safe storage contamination during the fadlities) inventory process. 1.3 Conduct of inventory Proj Define scope of problem in $0.5 - $1.0 M 6 to 12 months the country with respect to volume, type, location of obsolete pesticides as well storage conditions. 1.4 Analysis of results Proj To provide information < $0.1 M I to 3 months required to develop pestidde rerno4al and dean up plan. b. National Institutional/Legal Capacity Assessment (Stage 1 Activity) 109. The second element of the EMP, development of legal and institutional capacity, is a complex area that in many instances (for example, the state of development of the national environmental legislative framework) is impacted by factors substantially outside the control of ASP-P1. A key step in implementing the ASP at the country level will, however, be a gap analysis of the existing legal and institutional framework and the subsequent delineation of how any significant gaps (for example, lack of environmental assessment regulations) are to be filled. An understanding of national regulations and institutions should be a formative step completed prior to the commencement of any project activities in a given country, however, the task of gap analysis and subsequent actions is likely to continue throughout the life of the country project. The ESMF provides guidance to the country project manager on how to manage the above processes and indicates their importance to the preparation of the environmental assessment required prior to commencement of any Stage 2 activities. Table 6. EMP for National Institutional/Legal Capacity Mitigation Measure Responsibility Need for measure Cost* Time required** ESMF ref: 2.0 National Institutional/Legal Capacity $0.5 M 6 months ESMF #2 2.1 Legislative Gap Analysis Proj To establish the state of < $0.1 M 1 to 3 months development and enforcement of national legislation. 2.2 Develop/Apply Prog/Proj Where legislation and < $0.25 M 3 to 6 months Standards standards are not to the level required to support implementation of ASP at the country level, develop and apply suitable standards. 2.3 Management Regime Proj To establish the effectivess < $0.1 M 1 to 3 months Gap Analysis of the existing regulatory management process. 2.4 Develop Management Proj Where the existing < $0.25 M 3 to 6 months Regime regulatory process is not suffcient to support implementation of ASP at the country level, develop suitable management regime. c. Identification of Priority Sites (Stage 1 Activity) 110. For any programme such as the ASP, identification of priority sites is a natural step in program planning. For ASP-PI, identification of priorities should be carried out using the data collected from the inventory process, including that relating to site sensitivity. Therefore, it is important to use a process for prioritizing sites that is simple, transparent and readily understood. To this end, a simple risk assessment tool is provided as part of this element of the ESMF. In addition, it is recommended that the country project manager must be able to conduct this assessment in a timely fashion, following the conduct of the inventory. For countries with a large number of sites the potential for changes in the inventory, through for example, additional stocks of pesticide becoming obsolete, need to be borne in mind throughout the ASP process. 35 Table 7. EMP for identification of priority sites Mitigation Measure Responsibility Need for measure Cost* Time required* ESMF ref: 3.0 Identification of priority sites $0.25 to $0.5 M 3 to 6 months ESMF #3 3.1 Establish risk Prog/Proj To ensure that risk < $0.1 M I to 3 months assessment team and assessment is conducted in guidelines a defined and consistent manner. 3.2 Conduct risk assesment Proj Process by which priorities < $0.25 M 3 to 6 months will be assigned for clean up of sites at Stage 2. d. Emergency Response Plan (Stage 1 Activity) 111. Data gathered from the first three elements of ASP-PI will form key inputs to the fourth element of the ESMF, that of emergency response planning. The assessment recognizes that, particularly during Stage 2 of a country project, significant risks to the biophysical and human environments may be presented. The explicit recognition of such risks and the development of mitigation measures are indeed a key role of the present study, however, it is prudent to recognize that even with such planning unforeseen emergencies (such as accidental releases during transport) may still occur. This fourth element of the ESMF therefore seeks to ensure the necessary responsibilities, decision processes, communication channels and resources (including trained personnel and equipment) are in place to respond to any such emergencies in a rapid and effective manner, such that their impacts may be best contained and minimized. The development of an emergency response plan for each country project will form a key part of the mitigation measures contained in the country environmental assessment required prior to moving to Stage 2 activities in any given country. Table 8. EMP for Emergency Response Plan Mitigation Measure Responsibility Need for measure Cost* Time required* ESMF ref: 4.0 Emergency Response Plan $0.25 M 3 to 6 months ESMF #4 4.1 Set up ER planning Prog/Proj To establish the process for < $0.25 M 1 to 3 months team and guidelines ER planning and ensure particpation in the process by appropriate national/regional bodies and authorities. 4.2 Establish ER Team and Proj To resource the ER plan < $0.25 M 3 to 6 months equipment. with personnel and equipment. 4.3 Establish ER Prog/Proj To ensure ER is < $0.1 M 1 to 3 months Management Regime coordinated and controlled, including reporting regimes, ongoing training and testing of response capability. 36 e. Public Consultation and Education (Stage 1 Activity) 112. The ASP is recognized as a significant project both in terms of the African continent and in terms of the involvement of the international community. The need to consider and balance a wide range of stakeholder interests and viewpoints will therefore be a key factor in the overall success of the program. As the GEF Implementing Agency of the ASP it is the Bank's role to facilitate the synthesis of those interests and views to form a cogent plan for the program as a whole. In a similar fashion, it will be the role of the executing agency and project manager at the country level to ensure that public participation and education is undertaken such that the country process mimics the participative nature of the program overall. This element of the EMP provides guidance for the country project manager with regard to the planning and conduct of such processes. The information and knowledge gathered during this Stage I activity will be used to meet the public consultation requirements of the environmental assessment required before moving to Stage 2 of any country project. Table 9. EMP for Public Consultation and Education Mitigation Measure Responsibility Need for measure Cost* Time required* ESMF ref: 5.0 Public Consultation and Education $0.25 to $0.75M 6 to 12 months ESMF #5 5.1 Set up PCE planning Prog/Proj To ensure that PCE is < $0.25 M 1 to 3 months team and guidelines conducted in a planned and consistent manner and that all groups are identified. 5.2 Conduct PCE with ProJ/Prog To ensure that local $0.25 to $0.5 M 6 to 12 months appropriate groups communities have a say in (identified from 5.1 the development of the ASP above) and that the education objectives of the programme are achieved. f. Prevention (Stage 1 Activities only) 113. A recognized aim of ASP-PI is to seek to stop the future build up of obsolete pesticide stocks, thereby preventing the reoccurrence of the issues now faced. This study recognizes that such prevention activities divide into those that can be conducted under Stage I of the program and those for which a further environmental assessment would be required. Broadly speaking, Stage I prevention activities are those where the focus is on better management of pesticide stocks or on policy review. These include generic reviews of available options for reduction of reliance on pesticides, training on storage and management of pesticides and the development of actions to better track pesticide stocks. Stage 2 activities would represent a significant change in pest management strategies and approaches, such as the planned introduction on targeted biological controls. Stage 2 Prevention activities should be considered under the country ESA. 37 TablelO. EMP for Prevention Mitigation Measure Responsibility Need for measure Cost* Time required* ESMF ref: 6.0 Prevention (Stage 1) $1.0 M up to 18 months ESMF #6 6.1 Set up Prevention Prog/Proj To establish prevention < $0.25 M 3 to 6 months Planning team and planning activites within the guidelines country. 6.2 Enforce regulations, Proj/Prog To implement Stage 1 $0.25 to $1.0 M up to 18 months implement pesticide prevention activities and (excludes any management practices, stop the build up of further costs of new implement pest obsolete pesticide stocks. physical management practices, infrastructure, conduct education and such as safe outreach. storage) g. Pesticide Removal and Site Remediation (Core Stage 2 Activity) 114. This activity represents the core project activity, and has the greatest potential to create adverse environmental and socio-economic impacts both on the African continent and - depending on transport and disposal routes and methods chosen, elsewhere on the globe. The environmental and social assessment clearly recognizes the potential significance of these impacts and identifies that the nature of such impacts will be highly dependent on the individual circumstances and conditions specific to each country. These factors are outside the scope of an environmental assessment conducted at the project level, and therefore a country level environmental and social assessment is required prior to starting this activity within any country participating in ASP-PI. This country level ESA will be the principle mitigation measure required for the country level Stage 2 project. It is important, however, that each country level ESA is conducted under a common framework. 115. To ensure this the ESMF provides the country project manager with guidance as to issues to be considered in the conduct of the country environmental assessment. This guidance deals with the following key issues: 116. Defining scope of activities - a key decision in any country project will be the definition of scope of activities to be covered. To this end the ESMF provides clear guidance to the country project manager on the activities that are to be within the scope of ASP-P1. Such activities include all operations relating to handling, transport and treatment or disposal of obsolete pesticides and pesticide associated wastes (such as contaminated structures and packaging). 117. Reviewing information from Stage I activities - the program has been designed such that much of the information required to conduct the country specific environmental assessment will flow from undertaking Stage I activities. Review of this information and the filling of data gaps will, however, be required prior to the completion of the country environmental assessment. The ESMF provides guidance to the country project manager on this process. 118. Potential environmental and socio-economic impacts - the detailed nature of these impacts will vary on a country by country basis and potentially over time (for example, as technology or infrastructure changes and evolves). Therefore, the ESMF seeks to provide guidance to the project manager on the impacts associated with major project decisions. This guidance can be used in considering the consequences of project decisions and in reviewing and 38 developing the project strategy for any given country. Through this guidance environmental assessments conducted under the project will operate within a similar frame of reference helping to ensure consistency and continuity throughout. Table 11. EMP for Stage 2 Activities Mitigation Measure Responsibility Need for measure Cost* Time required** ESMF ref: 7.0 Pesticide removal and site remediation $1.0 M up to 18 months ESMF #7 7.1 Prepare Draft Stage 2 Proj/Prog Required to develop $0.5 M 6 to 12 months Plan country specific strategy for clean up of pesticides and stage 2 prevention 7.2 Conduct Project EA of Proj/Prog Process by which country $0.25 to $0.5 M 6 to 12 months Draft Stage 2 Plan specific impacts are assessed and mitigation measures are developed. 7.3 Finalize Stage 2 Plan Proj/Prog Formal adoption of Stage 2 < $0.1 M 1 to 3 months plan and mitigation measures. 7.4 Implement Stage 2 Plan Proj/Prog During this step monitor Costs dependent Time required Stage 2 activities and on country setting dependent on enforce mitigation and scope and nature measures identified in the circumstances. of issues Stage 2 EA. Determined as identified in Stage part of Stage 2 2 Plan. Plan. N.B. Costs and time estimates for above exclude those associated with conduct of 7.4 (including building of any infrastructure required as part of implementation of the program. Such costs can only be determined on completion of the Stage 2 plan. 3. Program and Reputational Risk 119. While this issue is not strictly an environmental or social impact, subject to mitigation in the normal manner, the following steps should be considered in seeking to mitigate this risk. i. Seek to ensure the effective implementation of all other steps of the EMP, thereby seeking to minimize the risk of crystallization of this issue, through avoiding significant program failures. Of particular importance here is ensuring that all legal safeguards and best management practices are followed, including use of authorized and approved contractors for handling and transport of hazardous wastes. ii. Continue to build the ASP in a consultative and open manner, obtaining the "buy in" to key program decisions from all program and country partners. iii. In the event of a programme failure likely to result in potential exposure to reputational risk: > Through ASP planning be prepared to rapidly mobilize emergency response teams; > Have established and be able to rapidly implement a public communications process, to ensure that factual issues are treated in an open manner and reducing the potential for distortion or misrepresentation; > Have established and be able to rapidly implement a communications process with key stakeholders (including stakeholders not involved with the ASP); and 39 Have established and be able to call upon a "contingency" fund to assist in the mitigation of the biophysical and socio-economic impacts caused by the programme failure. 120. Developing a fully integrated management programme to address the above issues, including the identification of financial mechanisms to fund such activities (such as insurance, performance bonds, fund retention) as well as administrative plans and tools should be an activity conducted in conjunction with (if not prior to) the move of the first phase of countries into Stage 2 activates. Funding requirements for such a management programme is likely to be in the region of $<0. I M and the programme may be expected to take approximately three to six months to develop. 40 IX. MONITORING AND EVALUATION 121. The ASP-PI project design includes a number of operational indicators to measure the progress of the project against objectives and to evaluate operational and financial performance. The environmental and social assessment does not seek to duplicate this process, but rather provides a monitoring and evaluation framework for follow up on the mitigation measures that are contained in the EMP (for Stage I activities) and those that will be required under country level environmental assessments (for Stage 2 activities). The proposed indicators are qualitative and quantitative in nature and are divided into three broad categories: i. Indicators to monitor that Stage I mitigation measures are being followed during the conduct of inventories and emergency repackaging (including the audit of selected site inventory exercises against the mitigation criteria referenced in the ESMF); ii. Indicators and conditions that must be met (from an environmental and socio-economic safeguard point of view) in order for the country project to move to Stage 2; and iii. A framework of environmental and socio-economic indicators that can be used to guide monitoring of impacts and their mitigation under the Stage 2 environmental assessment. 1. Assessing effectiveness of mitigation measures under Stage 1 122. Mitigation measures for Stage I activities are contained in the ESMF and it is essential, from a project management perspective, that the application and effectiveness of such measures are monitored and assessed. Especially important in this regard are those measures surrounding the conduct of inventory and emergency repackaging. 123. The following indicators for effectiveness of inventory and emergency repackaging are proposed: (1) Numbers of inventory personnel trained in FAO guidelines for inventory taking, as compared with numbers required; (2) Quantitative and qualitative review of incident and near miss reports; and (3) Quantitative and qualitative review of complaints or communications received. (4) In addition to the above it is recommended that, given the importance of following the proper procedures during the inventory taking process, periodic audits are conducted of specific site inventories using the FAO guidelines as audit criteria. 124. The following additional indicators for measuring the capability to move from Stage I to Stage 2 are proposed: (5) Number and % (of total) completion of site inventories; (6) Number and % (of total) of sites requiring emergency repackaging; (7) Completion of legislative and institutional gap analysis; (8) Completion of a plan to address gaps in above (using relevant international standards where required); (9) Number and % (of total) sites risk assessed; (10) Completion of a prioritized site clean-up plan; (11) Completion of development of emergency response plan (including a test scenario); (12) Completion of the development of the public consultation and education plan; and (13) Completion of the Stage I prevention plan. 41 2. Trigger for progressing to Stage 2 125. In order to move to Stage 2 activities the ASP country project must be able to demonstrate that 100% of planned sites have been inventoried and risk assessed and that items 8, 9, 11, 12, 13, and 14 above have been completed. These items will form a key part of the draft Stage 2 plan required prior to implementing Stage 2 activities. 3. Measures for measuring effectiveness of mitigation measures under Stage 2 126. For Stage 2 activities the indicators required to monitor the effectiveness of mitigation measures will be set at the country specific level through the process of the environmental assessment of the draft Stage 2 plan. The following should be considered during the country specific environmental assessment. (15) Economic value of land used for the development of ASP facilities and structures and related infrastructure, together with value of compensation paid (including land made inaccessible by project related activities); (16) Net increase/reduction in agricultural production arising from use of land for ASP related activities and structures (including land made inaccessible by project activities); (17) Net increase/reduction in natural resources areas (such as wetlands, fisheries, subsistence food sources, forests) arising from use of land for ASP related activities and structures (including land made inaccessible by project related activities); (18) Net increase/reduction in potable water supplies arising from ASP related activities; (19) Net job gains/losses arising from ASP activities (identified by unskilled, traditional skilled, technology skilled, and managerial); (20) Numbers of people trained in pesticide management skills, including handling and storage practices; (21) Loss of cultural heritage sites (or restriction in access to same) as a result of ASP related activities; (22) Net increase/reduction in quality of the natural environment, including biophysical parameters (such as water quality) and biodiversity of flora and fauna, (through remediation, development or through deterioration) arising from ASP related activities; and (23) Net increase/reduction in obsolete pesticide related human health impacts as a result of ASP related activities. Conclusion 127. The effective execution and mainstreaming the EMP into project activities, and adherence to the principles and framework outlined throughout this document, implementation of ASP-PI and the overall program will allow the considerable potential social and environmental benefits of the project to be realized. Through direct clean up activities the project can make a significant contribution to environmental and human health issues, while consultation, education and outreach will play a pivotal role in ensuring that the problem of obsolete pesticide stocks does not reoccur. The potential risks represented by Stage 2 clean up activities are significant, especially if improperly or ineffectively managed, as is the potential for reputational risk to the World Bank and key partners should there be a major failure. The need to comply with international conventions and national legislation on hazardous wastes and to follow best management practices is therefore paramount in ensuring safe and diligent implementation. For any country project, the capacity to achieve this management capability must therefore first be developed (and clearly demonstrated) through preparation activities identified under Stage I of 42 the programme - before this capability is critically assessed through the conduct of a country specific ESA. It is essential that no project moves to commence Stage 2 activities without first gaining Bank approval for the country specific EA The effective implementation of measures contained in the EA and the compliance with international and national conventions, legislation and codes must then be monitored and enforced, both through internal management regimes and through the auspices of the Bank's own programme review capacity. 43 References Environmental Media Services. 2003. 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Guidelines for the management of small quantities of unwanted and obsolete pesticides. Rome. FAO. 2000. Assessing soil contamination, A reference manual. Rome. FAO. 2001a. Baseline study on the problem of obsolete pesticide stocks. Rome. FAO. 2001b. Country Guidelines. Rome. FAO. 2001c. FAO training manual for inventory taking of obsolete pesticides. Rome. IMO. 1994. International maritime dangerous goods code, 27th ed. London. Ontario College of Family Physicians. 1998. Pesticides and Human Health. Environmental health committee newsletter for family physician. Toronto. PAN-UK. 2003. Disposal of obsolete pesticides. Pest management notes No. 3. London. UN. 1995. Recommendations on the transport of dangerous goods, 9th revised ed. New York and Geneva. UNEP/SBC. 1994a. Basel Convention on the control of transboundary movements of hazardous wastes and their disposal, 1989, and decisions adopted by the first (1992) and second (1994) meetings of the conference of parties. UNEP Secretariat of the Basel Convention. Geneva. 44 World Bank. 1991. Environmental assessment handbook. Washington. World Bank. 2002. Programme Overview. Africa Stockpiles Programme. Washington. Can be viewed at www. africastockpiles.org World Bank/WHO/UNEP. 1989. The safe disposal of hazardous wastes: the special needs and problems of developing countries, Vols. 1-111. World Bank Technical Paper No. 93. R. Batstone, J.E. Smith Jr. and D. Wilson. Washington. WHO. 1994. Recommended classification of pesticide by hazard. Document WHO/PCS/94.2. Geneva WHO. 1990. Public health impact of pesticides used in agriculture. Geneva. WHO. 1994. Recommended classification of pesticide by hazard. Document WHO/PCS/94.2, Geneva. WWF. 2001. International Toxics Programme, Incineration and other waste disposal technologies. Washington. 45 ANNEX 1. Available estimated distribution of pesticides in Africa (2001) (Need to change colors for better B&W readability) Inventory of obsolete, unwanted and banned pesticide stocks Oty. in metric tonnes = 500- 1,000 t X 50-500 - 5-50 % @ f t - Not quantified . Further full Inventory is necessary All require revised Inventory from time to time Martin Fodor L:\-AFTES\ASP\ASP-Env&Social Assessemnt-Final draft-h.doc March 18, 2004 12:17 PM 46