Updated as of May 23, 2004

Africa Bureau

Recommended Acceptable Language and Formats (RALF)

to Use in Preparing Requests for Categorical Exclusions and IEEs

**CONTENTS**

[**INTRODUCTION**](#introduction)

-   [Classification Prior to
    IEE](#classification-of-activities-prior-to-iee) (Deferral,
    Exemption, Categorical exclusion, "*a priori"* Positive
    Determination)

```{=html}
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-   [Threshold
    determinations](#classification-of-activities-within-an-initial-environmental-examination-iee)
    within IEE (Negative Determination, Positive Determination,)

[**Monitoring and compliance
assurance**](#monitoring-and-compliance-assurance)

-   [ADS
    references](#ads-references-to-compliance-assurance-esp.-at-end-of-face-sheet-summary-and-other-relevant-places-adapted),
    e.g. regarding SO Team responsibility for IEE compliance monitoring

-   [Sub-grants and other funds
    transfers](#sub-grants-or-other-funds-transfers-by-implementing-partners-made-consistent-with-the-iee)
    made consistent with the IEE

-   Other stipulations for [monitoring and
    compliance](#other-monitoring-and-compliance-assurance-requirements)
    assurance

-   [Micro, Small, and Medium Enterprises (MSE, SME), Business
    Development Services (BDS),](#_Micro,_Small,_and) etc.

-   [Financial Intermediation, Intermediate Credit Institutions (ICI),
    Microfinance Institutions
    (MFI)](#financial-services-financial-intermediation-intermediate-credit-institutions-ici-microfinance-institutions-mfi)

[**Sector-specific conditions**](#sector-specific-conditions)

-   [Biotechnology:](#_Biotechnology:)

-   [Financial Services, Financial Intermediation, Intermediate Credit
    Institutions (ICI), Microfinance Institutions
    (MFI)](#financial-services-financial-intermediation-intermediate-credit-institutions-ici-microfinance-institutions-mfi)

-   [Insecticide Treated Nets](#_[For_programs_involving), Materials for
    Prevention of Malaria Transmission

-   [Livestock production](#livestock-production)

-   [Medical waste](#medical-waste)

-   [Micro, Small, and Medium Enterprises (MSE, SME), Business
    Development Services (BDS), etc.](#_Micro,_Small,_and)

-   [Pesticides:](#_Pesticides:)

-   [Small-scale Construction](#_Small-scale_Construction:)

-   [Studies, research with human subjects and/or
    animals](#research-or-studies-with-human-subjects-andor-animals)

-   [Roads](#Roads)

-   [Sub-grant environmental screening](#Env_Screening)

-   [Water and Sanitation](#_Water_and_Sanitation)

**Africa Bureau's *Environmental Guidelines for Small-scale Activities
in Africa* (EGSSAA)("egg salad")**

-   [General use of environmental
    guidelines](#general-use-of-environmental-guidelines)

**Templates, Guidance Annotations**

-   [Face Sheet for IEE and/or Categorical Exclusion Request -
    template](#face-sheet-template-for-ieece-remove-this-line)

-   [Annotated IEE Outline](#annotated-iee-outline)

-   [Annotated Request for Categorical
    Exclusion](#annotated-outline-for-requests-for-categorical-exclusion)

-   [IEE Narrative Section Examples](#selected-iee-narrative-examples)

> Section 1. Background and Activity/Program Description
>
> [Section 1.1 Purpose and Scope of IEE](#Purpose_Scope_IEE)
>
> Section 1.2 Background
>
> Section 1.3 Description Of Strategic Objective, Results Framework
>
> 1.3.1 Results Framework
>
> 1.3.2 So x IRs And Activities Summarized
>
> Section 2.0 Country & Environmental Information
>
> 2.1 Locations Affected
>
> 2.2 National \[Or Applicable\] Environmental Policies & Procedures
>
> Section 3.0 Evaluation Of Project/Program Issues With Respect To
> Environmental Impact Potential
>
> Section 4.0 Recommended Threshold Decisions & Mitigation Actions
> (Including Monitoring & Evaluation)
>
> 4.1 Recommended Threshold Decisions and Conditions
>
> 4.2 [Mitigation, Monitoring and Evaluation](#Mit_Mon_Responsibilities)

[**Style Tips for IEE Writers**](#style-tips-for-iee-writers)

[**Acceptable Table Formats for Presenting Threshold Decisions and
Mitigation Conditions**](#Threshold_Decisions_Tables)

**[Streamlined IEE Preparation Approaches](#_Streamlined_IEE_Formats:)**
(May 20, 2004)

[**USAID Biosafety Requirements**](#_USAID_Biosafety_\“First)

[**Pesticides: PERSUAP Guidance**](#_USAID/AFR_guidance:_preparing)

### INTRODUCTION

This "[Recommended Acceptable Language and Formats
(RALF)](http://encap.sharepoint.afr-sd.org/envofficers/Shared Documents/Frequently encountered issues and other IEE guidance/AFR Recommended Acceptable Language File for IEEs - RALF.doc)"
is a resource and tool intended for use by IEE drafters, and it is where
"standard" paragraphs, phrases and citations that are commonly employed
and reused in the drafting of IEEs are stored. This content is primarily
useful in the preparation of IEE section *3.0 Evaluation Of
Project/Program Issues With Respect To Environmental Impact Potential*,
and section *4.0 Recommended Threshold Decisions and Mitigation Actions
(Including Monitoring and Evaluation*).

In this document are a few snippets that are unchanging, such as
citations from 22CFR216 (Reg. 216), as well as many paragraphs and
phrases that are subject to periodic revision and refinement, such as
recommended sets of conditions for various types of activities. This
collection is therefore constantly changing, and persons who undertake
to prepare an IEE for a USAID program in Africa should take care to
access the most recent version of this document from the ENCAP website
via the link above.

The objectives of this document are multifold:

1.  Save time and effort for IEE writers, allowing more time for
    analysis and monitoring;

2.  Promote consistency across the region of IEE language used and of
    risk management decisions, which are embodied in the conditions
    proposed;

3.  Increase the likelihood of IEEs being cleared without substantial
    edits or rewriting.

The use of this language is recommended, not required. Its use, in part
or in whole, is up to the discretion of the IEE author. But in the
interest of the above objectives, [IEE authors are strongly encouraged
to start with RALF language]{.underline}, if appropriate to the
situation, and then amend/abridge/add to as needed.

The content of this document is informed by all the Environmental
Officers in the Africa region as well as the General Counsel's office.
Maintenance of the document is primarily the responsibility of
AFR/Office of Sustainable Development, with REDSO/ESA, and questions or
comments should be addressed to [Brian
Hirsch](mailto:bhirsch@usaid.gov), AFR/SD or [Walter
Knausenberger](mailto:waknausenberger@usaid.gov?subject=RALF inquiry),
REDSO/ESA.

### CLASSIFICATION OF ACTIVITIES PRIOR TO IEE:

A **positive determination** is recommended per 22 CFR 216.2(d)(2), and
an Environmental Assessment will be prepared, per 22 CFR 216.6.
**NOTE:** this applies when the classes of action involved are
considered *a priori* to have a high potential for adversely affecting
the environment, and normally would require an EA (as listed in the
section cited above), and no IEE need be prepared.

A **deferral of a threshold determination,** per 22 CFR
216.3(a)(7)(iii), is recommended pending clearer identification of the
activities to be undertaken. The activity(ies) involved may not proceed
until the IEE is amended to remove the deferral, once sufficient detail
about these activities is known, and the appropriate environmental
review of these activities has occurred.

An **exemption from environmental examination** is recommended for these
activities per 22CFR216.2(b)(1)(i) \[international disaster assistance\]
. NOTE: This applies only when an official declaration of emergency has
been made.

**Acceptable format for citing Categorical Exclusions:**

A **categorical exclusion** is recommended for these activities, per...

22CFR216.2(c)(2)(i) \[education, technical assistance, training\]

22CFR216.2(c)(2)(ii) \[controlled experimentation\]

22CFR216.2(c)(2)(iii) \[analyses, studies, workshops and meetings\]

22CFR216.2(c)(2)(v) \[document and information transfer\].

22CFR216.2(c)(2)(viii) \[nutrition, health care or population and family
planning services\], and,

22 CFR 216.2(c)(2)(xiv) \[programs to develop capability of recipient
countries and organizations in development planning\].

**But preferred is the following approach (the most commonly used ones
are listed first, a-g):**

**A** **Categorical Exclusion** is recommended for activities under IRs
x.x, x.x, \..., except to the extent that the activities directly affect
the environment (such as construction of facilities), pursuant to:

a\) 22 CFR 216.2(c)(2)(i), for activities involving education, training,
technical assistance or training programs;

b\) 22 CFR 216.2(c)(2)(ii), for activities involving controlled
experimentation exclusively for the purpose of research and field
evaluation which are confined to small areas (for this IEE, defined as
an area which is smaller than 4 hectares) and carefully monitored;

c\) 22 CFR 216.2(c)(2)(iii), for activities involving analyses, studies,
academic or research workshops and meetings;

d\) 22 CFR 216.2(c)(2)(v), for activities involving document and
information transfers;

e\) 22 CFR 216.2(c)(2)(viii), for programs involving nutrition, health
care, or family planning services except to the extent designed to
include activities directly affecting the environment (such as
construction of facilities, water supply systems, waste water treatment,
etc.);

\(f\) 22 CFR 216.2(c)(2(xi) Programs of maternal or child feeding
conducted under title II of Pub. L. 480; and

\(g\) 22 CFR 216.2(c)(2)(xiv), for studies, projects or programs
intended to develop the capability of recipient countries and
organizations to engage in development planning.

**Categorical Exclusions rarely used \[or appropriate\] in today's
assistance environment:**

\(iv\) Projects in which \[USAID\] is a minor donor to a multidonor
project and there is no potential for significant effects upon the
environment of the United States, areas outside any nation\'s

jurisdiction or endangered or threatened species or their critical
habitat;

\(vi\) Contributions to international, regional or national
organizations by the United States which are not for the purpose of
carrying out a specifically identifiable project or projects;

\(vii\) Institution building grants to research and educational
institutions in the United States such as those provided for under
section 122(d) and title XII of chapter 2 of part I of the FAA (22 USCA

2151 p. (b) 2220a. (1979));

\(ix\) Assistance provided under a Commodity Import Program when, prior
to approval, \[USAID\] does not have knowledge of the specific
commodities to be financed and when the objective in furnishing such
assistance requires neither knowledge, at the time the assistance is
authorized, nor control, during implementation, of the commodities or
their use in the host country.

\(x\) Support for intermediate credit institutions when the objective is
to assist in the capitalization of the institution or part thereof and
when such support does not involve reservation of the right to

review and approve individual loans made by the institution;

\(xii\) Food for development programs conducted by food recipient
countries under title III of Pub. L. 480, when achieving \[USAID\'s\]
objectives in such programs does not require knowledge of or control
over the details of the specific activities conducted by the foreign
country under such program;

\(xiii\) Matching, general support and institutional support grants
provided to private voluntary organizations (PVOs) to assist in
financing programs where \[USAID\]\'s objective in providing such
financing does not require knowledge of or control over the details of
the specific activities conducted by the PVO;

**Categorical Exclusion never appropriately applied, because there have
never been any such design criteria or standards officially approved:**

\(xv\) Activities which involve the application of design criteria or
standards developed and approved by \[USAID\].

### CLASSIFICATION OF ACTIVITIES WITHIN AN INITIAL ENVIRONMENTAL EXAMINATION (IEE) 

For the "grey areas" when it is not obvious that an activity falls into
one of the above categories, it is necessary to prepare an IEE to make
that determination. Mission Environmental Officers and Regional
Environmental Officers can assist in the preparation of the IEE, and
recommending threshold decisions (or determinations). Bureau
Environmental Officers approve the Threshold Decisions based on the IEE.

**22 CFR CITATIONS FOR THRESHOLD DETERMINATIONS**

A **negative determination (with or without conditions)** is recommended
per 22CFR216.3(a)(2)(iii).

Conditions are not specifically cited in Reg. 216. They represent an
adaptation by the Africa Bureau to identify those mitigation conditions
needed to ensure that the risk of environmental harm stay within
acceptable bounds.

With conditions

A **positive determination** is recommended per 22CFR216.3(a)(2)(iii)

A **deferral of a threshold determination,** per 22 CFR
216.3(a)(7)(iii), is recommended pending clearer identification of the
activities to be undertaken. The activity(ies) involved may not proceed
until the IEE is amended to remove the deferral, once the appropriate
environmental review has occurred.

An **exemption from environmental examination** is recommended for these
activities per 22CFR216.2(b)(1)(i) \[international disaster assistance\]

### MONITORING AND COMPLIANCE ASSURANCE

#### [ADS references to compliance assurance \[esp. at end of face sheet summary and other relevant places, adapted\]:]{.underline}

As required by ADS 204.5.4, the SO team will actively monitor ongoing
activities for compliance with approved IEE recommendations, and modify
or end activities that are not in compliance. If additional activities
are added to this program that are not described in this document, an
amended environmental examination must be prepared.

OR...

As required by ADS 204.5.4, the SO team will actively monitor ongoing
activities for compliance with approved IEE recommendations, and modify
or end activities that are not in compliance. If the activities in this
program are materially modified, the SO team is responsible for assuring
that the active environmental documentation is amended appropriately.

Or...

As required by ADS 204.5.4, the SO team and activity implementing
partners will \"actively monitor and evaluate whether the environmental
features designed for the activity resulting from the 22 CFR 216 process
are being implemented effectively and whether there are new or
unforeseen consequences arising during implementation that were not
identified and reviewed in accordance with 22 CFR 216.\" If additional
activities not described in this document are added to this program, an
amended environmental examination must be prepared and approved.

#### [Sub-grants or other funds transfers by implementing partners made consistent with the IEE]{.underline}

Any grants or other fund transfers made organizations receiving USAID
funds to other organizations (e.g., subgrants) to support this program's
activities must incorporate provisions that the activities to be
undertaken will be within the envelope of the environmental
determinations and recommendations of this IEE. This includes assurance
that the activities conducted via those transfers fit within the
description of activities described in an approved IEE or IEE amendment
covering this program, and that any mitigating measures required for
those activities be followed.

#### [Other monitoring and compliance assurance requirements]{.underline}

-   Implementing partners\' annual reports and, as appropriate, progress
    reports shall contain a brief update on mitigation and monitoring
    measures being implemented, results of environmental monitoring, and
    any other major modifications/revisions in the development
    activities, and mitigation and monitoring procedures.

-   USAID/(Country) will report to the REO and the BEO on an annual
    basis on the status of environmental screening and review and the
    implementation of mitigation and monitoring requirements. This
    report should draw upon implementing partners\' progress and annual
    reports, as well as on periodic site visits by the MEO and REO.

-   USAID/(Country) is responsible for monitoring and evaluation of
    activities after implementation with respect to environmental
    effects, a process that should be integrated into the SO\'s
    pertinent Performance Monitoring and Evaluation Plan and which
    should also involve periodic field visits.

-   USAID/(Country) is responsible for assuring that implementing
    partners have the human capacity necessary to incorporate
    environmental considerations into program planning and
    implementation and to take on their role in the Environmental
    Screening Process. Implementing partners should seek training as
    needed, such as through participation in the Africa Bureau's
    regional ENCAP training courses.

#### **[Financial Services, Financial Intermediation, Intermediate Credit Institutions (ICI), Microfinance Institutions (MFI)]{.underline}**

#### [Micro, Small, and Medium Enterprises (MSE, SME), Business Development Services (BDS), etc.]{.underline}

**Loan funds, microfinance, and microenterprise support. A Negative
Determination with Conditions** recommended pursuant to 22 CFR
216.3(a)(2)(iii) for support to microfinance institutions and MSEs (IR
x.x, x.x).

**Conditions:** MFI and MSE credit and service providers are urged to
institutionalize their own environmental reviews of credit and service
projects and individual activities. MSE & environment guidelines can be
used to improve the effectiveness, on a case-by-case basis, of reviewing
and mitigating the adverse environmental impacts of MSEs, so there
should be scope for factoring in some screening criteria in the loan
provision process.

It is recommended that for all activities relating to the expansion of
microfinance and or micro enterprise to be subjected to environmental
review. The Environmental Review Form in the EGSSAA can be tailored as
needed, to assist in identifying potential environmental impacts that
are likely to occur as a result of such micro enterprise activities. The
ERF helps to classify such potential impacts into low risk medium risk
and high risk categories. Mitigation measures must be identified for all
medium and high risk categories. Again, the USAID Bureau for Africa's
*[Environmental Guidelines for Small-Scale Activities in
Africa](http://www.encapafrica.org/SmallScaleGuidelines.htm)* (EGSSAA)
Part III, "Guidelines for Micro and Small enterprises." In addition, the
SO team leader shall visit all such projects during implementation to
ensure that they are not likely to cause any adverse environmental
impacts, with a view to correcting and or initiating additional
mitigation measures.

### SECTOR-SPECIFIC CONDITIONS

#### [Pesticides:]{.underline}

This examination does not cover pesticides, including their procurement,
use, transport, storage or disposal. Any pesticide activity considered
under this program would necessitate the preparation of a Pesticide
Evaluation Report and Safer Use Action Plan (PERSUAP), in accordance
with AFR Bureau guidance and fulfilling all analytical elements required
by 22CFR216.3(b), USAID's Pesticide Procedures.

[\[Need to include reference to how one determines what activities must
follow the Pesticide Procedures. Where is that defined? See the
EPTM/EDM.. WIK\]]{.mark}

**Except as provided below, this IEE does not cover the procurement of
pesticides**. Activities that entail the promotion or use of pesticides
for activities involving controlled experimentation exclusively for the
purpose of research and field evaluation which are confined to small
areas (\< 4 ha) and carefully monitored, shall be within the parameters
of 22 CFR 216.3(b)(2)(iii) ((Exceptions to Pesticide Procedures). All
activities that fall outside of the category of controlled
experimentation exclusively for the purpose of research and field
evaluation under 22 CFR 216.2(c )(2)(ii) and entail the procurement or
use, or both, of pesticides shall be analyzed in accordance with USAID
Pesticide Procedures (22 CFR 216.3(b) and no funds shall be obligated or
expended for the procurement or use of pesticides unless they are
specifically approved through an amendment to this IEE in accordance
with 22 CFR 216.3(b).

#### [\[For programs involving support for]{.underline} [insecticide-treated nets...\] [\[this needs beefing up...WIK\]]{.mark}]{.underline}

If the program will include support for the acquisition, distribution or
marketing of insecticide treated bednets (ITNs), the \[Health\] Team and
partner organizations will be required to use reliable brands of
long-lasting treated nets and adhere to all relevant stipulations made
in the USAID Africa Bureau [Programmatic Environmental Assessment for
Insecticide-Treated Materials in USAID Activities in Sub-Saharan
Africa](http://www.afr-sd.org/documents/iee/docs/32AFR2_ITM_PEA.doc)
(ITM PEA). If a need for net treatment or retreatment arises, the Team
will draft and gain approval for a "Pesticide Evaluation Report and
Safer Use Action Plan" (PERSUAP) for the ITN program.

#### [Fertilizers:]{.underline}

Only fertilizers that are approved by both the \[local regulatory
authority, e.g. Ugandan Crop Chemicals Board\] and the USEPA can be
introduced and utilized. Further, because of the environmental risks
inherent in improper handling, storage, use and application,
implementing partners must assure that potential users are trained in
proper handling, storage, use and application techniques.

#### [Biotechnology:]{.underline} 

This examination does not cover genetically-modified organisms (GMOs) or
life-modified organisms (LMOs). Any support for laboratory- or
field-based research, multiplication, or dissemination of GMOs or LMOs
shall be subject to review under the Agency's Biosafety procedures.

OR...

All USAID-funded interventions involving biotechnologies must be
subjected to a USAID biosafety review prior to implementation, under
procedures applicable at that time. (Contact the USAID Biosafety Officer
for current guidance.)

Biotechnology interventions to be carried out will have to follow
existing regulations and guidelines governing recombinant DNA research,
testing and commercialization, and transboundary movement of GMOs as
outlined in the *National Institute of Health (NIH) Guidelines*. These
guidelines, "NIH Guidelines For Research Involving Recombinant DNA
Molecules (NIH Guidelines), April 2002" may be accessed at:

<http://www4.od.nih.gov/oba/rac/guidelines_02/NIH_Guidelines_Apr_02.htm>

A Negative Determination with Conditions, pursuant to 22 CFR
216.3(a)(2)(iii), is recommended for activities involving the use,
experimentation, promotion or distribution of genetically modified
organisms (GMOs) and/or biotechnology products. The conditions are as
follows:

1)  the Mission shall ensure (e.g. through the inclusion of appropriate
    provisions in SO 5 implementation instruments (contracts, grants,
    cooperative agreements, etc. and sub-agreements issued under such
    instruments) that the criteria set forth in the \"Biosafety
    Procedures for Genetic Engineering Research,\" which is included as
    Annex 1 to this IEE are followed. In particular this guidance
    details the required written approval procedures needed before
    transferring or releasing GMO or biotechnology products;

2)  the Mission shall ensure (e.g. through the inclusion of appropriate
    provisions in SO 5 implementation instruments (contracts, grants,
    cooperative agreements, etc. and sub-agreements issued under such
    instruments) that all applicable national laws, regulations and
    guidelines governing recombinant DNA research, testing and
    commercialization, and the use, production or distribution,
    including in research, of GMOs or biotechnology products are
    followed, and no GMO and/or biotechnology testing or release of any
    kind, including planting, shall take in a host country until the
    authorized agency or department of the national government of such
    country have APPROVED, IN WRITING, IN ADVANCE, such testing or
    release based on national laws, regulations or guidelines governing
    GMO and/or biotechnology and biosafety;

3)  the Mission shall ensure (e.g. through the inclusion of appropriate
    provisions in SO 5 implementation instruments (contracts, grants,
    cooperative agreements, etc.) and sub-agreements issued under such
    instruments) that the United States *National Institute of Health
    (NIH)Guidelines for Research Involving Recombinant DNA Molecules*
    guidelines are followed. These guidelines may be located at:
    [**http://www.od.nih.gov/oba/rac/guidelines_02/NIH_Guidelines_Apr_02.htm**](http://www.od.nih.gov/oba/rac/guidelines_02/NIH_Guidelines_Apr_02.htm).
    \[check citation, this link does not work. The correct link may be:
    http://www4.od.nih.gov/oba/rac/guidelines/guidelines.html.\]

4)  the Mission shall ensure (e.g. through the inclusion of appropriate
    provisions in SO 5 implementation instruments (contracts, grants,
    cooperative agreements, etc.) and sub-agreements issued under such
    instruments) that all international laws governing recombinant DNA
    research, testing and commercialization, and the use, production or
    distribution, including in research, of GMOs or biotechnology
    products are followed.

OR...

Conditions precedent to dissemination of GMO products:

\- SO 5 will not support the transfer of bioengineered materials
intended for planting without the host government's explicit advanced
informed consent (indeed REDSO will promote such deliberative review
processes).

-SO 5 must assure that its grantees and contractors comply with national
and international laws applicable to biotechnology research and testing.

\- No biotechnology interventions of any kind are to begin until the
host countries and regional institutions involved have drafted and
approved a regulatory framework governing biotechnology and biosafety;

-All USAID-funded interventions which involve biotechnologies are to be
informed by the ADS 211 series governing \"Biosafety Procedures for
Genetic Engineering Research\". In particular this guidance details the
required written approval procedures needed before transferring or
releasing GE products to the field.

\- Biotechnology interventions to be carried out will have to follow
existing regulations and guidelines governing recombinant DNA research,
testing and commercialization, and transboundary movement of GMOs as
outlined in the *National Institute of Health (NIH) Guidelines*:
<http://www.od.nih.gov/oba/rac/guidelines_02/NIH_Guidelines_Apr_02.htm>.

OR\...

The Africa Regional Agricultural Biotechnology Support activities are
recommended for a Negative Determination, per 22 CFR 216.3(a)(2)(iii),
with the following conditions:

1)  All USAID-funded interventions which involve biotechnologies are to
    be informed by the draft ADS 211 series governing \"Biosafety
    Procedures for Genetic Engineering Research\". In particular this
    guidance details the required written approval procedures needed
    before transferring or releasing GE products to the field.

2)  Biotechnology interventions to be carried out at the institutional
    will have to follow existing host country national regulations and
    guidelines governing recombinant DNA research, testing and
    commercialization, and of GMOs as outlined in the *National
    Institute of Health (NIH) Guidelines*. These guidelines may be
    located at:
    [**http://www.od.nih.gov/oba/rac/guidelines_02/NIH_Guidelines_Apr_02.htm**](http://www.od.nih.gov/oba/rac/guidelines_02/NIH_Guidelines_Apr_02.htm).

3)  No biotechnology testing or release of any kind are to take place
    within an assisted country until the host countries involved
    have made formal decisions to APPROVE such testing or release based
    on national guidelines or regulatory framework governing
    biotechnology and biosafety;

4)  SO 5 must assure that its grantees and contractors comply with
    national and international laws applicable to biotechnology research
    and testing.

5)  SO 5 will not support the transfer of bioengineered materials
    intended for planting without the host government's explicit
    advanced informed consent (indeed REDSO will promote such
    deliberative review processes).

OR...

A **Negative Determination with Conditions** is recommended for all
other program activities. Under section 1.3, numbers 1, 2 and 3, these
activities include development and commercialization of sweet potatoes
resistant to the feathery mottle virus, development of maize resistant
to the maize weevil and the large grain borer, development and
commercialization of animal disease vaccines and diagnostic kits.

The conditions (explained in Section 3 and listed in Section 4 of this
IEE Amendment) are that:

-   The program activities will be required to follow existing
    regulations and guidelines governing recombinant DNA research,
    testing and commercialization of products thereof, and
    trans-boundary movement of GMOs outlined in the *National Institute
    of Health (NIH) Guidelines*[^1], *Regulations and Guidelines for
    Biosafety in Biotechnology for Kenya* of the National Biosafety
    Committee and the USAID ADS 211-*Biosafety Procedures for Genetic
    Engineering Research* (Annex I)[^2].

-   These guidelines require that field trials or any such release into
    the environment is not conducted until both Kenyan and USAID written
    approval is obtained.

-   This will require the submission of a specific proposal for the
    activity to the Kenyan NBC and USAID biosafety officer.

-   Approval cannot be granted for the field release until the specific
    experiments are developed, and documentation is submitted to the
    Agency Biosafety Committee, hence the needs to require this step at
    the later date, according to the procedures of ADS 211 (Annex I).

#### [Small-scale Construction:]{.underline}

[]{#Roads .anchor}*Roads:*

> 1\. **Negative Determinations with Conditions are recommended,** per
> 22 CFR 216.3(a)(2)(iii) for the following ...activities:
>
> **Re-opening and maintenance of existing roads** (IR 1.1) No new road
> construction is planned. Existing tertiary and secondary roads will be
> repaired using established best practices as reflected in Chapter 14
> on Rural Roads in USAID/AFR *Environmental Guidelines for Small Scale
> Activities in Africa* (EGSSAA) located at:
> *(*<http://www.encapafrica.org/SmallScaleGuidelines.htm>). Also useful
> guidance for road construction, maintenance and rehabilitation are
> guidelines given in *Low-Volume Roads Engineering: Best Management
> Practices Field Guide*, by Gordon Keller and James Sherar, by the US
> Forest Service for USAID and in collaboration with USDA. (July 2003)
> (see same ENCAP website, or <http://www.fs.fed.us/global>, or
> [[http://www.zietlow.com/]{.underline}](http://www.zietlow.com/)).
> Further, *a certified roads engineer will be employed* to oversee
> activities and report to the MEO/USAID as necessary.

*Small-scale Construction*

Potential adverse impacts from small scale construction activities can
be summarized as follows:

> *The details of the construction carried out in support of any
> particular development activity or site will have a number of unique
> aspects. Construction activities in general, however, share a set of
> common features and potential adverse environmental impacts.*
>
> *Potential Adverse Impacts of Construction Projects*
>
> *• Damage to ecosystems*
>
> *• Sedimentation of streams and surface water*
>
> *• Contamination of water supplies*
>
> *• Social impacts*
>
> *• Spread of disease*
>
> *• Damage to aesthetics of area*
>
> *EGSSAA [Chapter 3: Small-Scale
> Construction](http://www.encapafrica.org/EGSSAAsectionsJan04/Env Guidelines Chapter 3 Construction.pdf)*

Example 1:

> *Small scale construction conditions \[version of 22 April 2004\]*

-   All construction activities will be conducted following principles
    for environmentally sound construction, as provided in [*Chapter 3:
    Small Scale
    Construction*](http://www.encapafrica.org/EGSSAAsectionsJan04/Env Guidelines Chapter 3 Construction.pdf)
    of the USAID Environmental Guidelines for Small-scale Activities in
    Africa, which can be found at
    [www.encapafrica.org](http://www.encapafrica.org/).

```{=html}
<!-- -->
```
-   For the construction of any facilities exceeding a total surface
    area of 10,000 square feet (1,000 square meters), the program will
    conduct a supplemental environmental review according to guidance
    found in "Attachment to Annex G: Environmental Screening and Report
    Form for NGO/PVO Activities and Grant Proposals," found in [Annex
    G](http://www.encapafrica.org/EPTM/annex_G.pdf) of the Africa Bureau
    Environmental Procedures Training Manual (EPTM). Construction may
    not begin until such a review is completed and approved by the
    Mission Environmental Officer. Alternate reporting and review
    procedures may also be utilized if agreement to do so is reached
    between the Mission and the Regional Environmental Officer.

#### [Water and Sanitation]{.underline}

Potential environmental impacts:

The human health benefits of water and sanitation activities are
enormous, and generally far outweigh any potential negative impacts of
such activities. Still, the potential for adverse environmental impacts
from water and sanitation activities exists, and it is the
responsibility of program designers and implementers to avoid such
impacts to the extent possible. Potential adverse impacts from water and
sanitation activities can be summarized as follows:

> *Potential adverse impacts from water supply activities:*
>
> *1. Depletion of fresh water resources (surface and groundwater)*
>
> *2. Chemical degradation of the quality of potable water sources
> (surface and groundwater)*
>
> *3. Creation of stagnant (standing) water*
>
> *4. Degradation of terrestrial, aquatic, and coastal habitats*
>
> *5. Increased human health risks (e.g. from arsenic content in
> groundwater)*
>
> *Potential adverse impacts from sanitation activities:*
>
> *1. Increased human health risks from contamination of surface water,
> groundwater, soil, and food by excreta, chemicals and pathogens*
>
> *2. Ecological harm from degradation of stream, lake, estuarine and
> marine water quality and degradation of land habitats*

*EGSSAA [Chapter 16: Water Supply and
Sanitation](http://www.encapafrica.org/EGSSAAsectionsJan04/Env Guidelines Chapter 16 Water_Feb25.pdf)*

*Water and Sanitation conditions:*

Both water supply and sanitation activities should be conducted in a
manner consistent with the good design and implementation practices
described in *EGSSAA [Chapter 16: Water Supply and
Sanitation](http://www.encapafrica.org/EGSSAAsectionsJan04/Env Guidelines Chapter 16 Water_Feb25.pdf)*.
The SO Team and implementing partners should closely examine this
chapter, as it provides a thorough discussion of program design and
implementation issues that can help avoid numerous preventable problems.
Another useful reference to consult for good water and sanitation design
and implementation principles is the document, "Guidelines for the
Development of Small Scale Rural Water Supply and Sanitation Projects in
Ethiopia," by Catholic Relief Services and USAID, July 31, 2003.

Water quality testing is essential for determining that the water from a
constructed water source is safe to drink and to determine a baseline so
that any future degradation can be detected. Among the water quality
tests which must be performed are tests for the presence of arsenic. Any
USAID-supported activity engaged in the provision of potable water must
adhere to Guidance Cable State 98 108651, which requires arsenic
testing. That 1998 cable also anticipates "practical guidelines on
sampling and testing for arsenic" that were then under development. The
EGAT Bureau completed these guidelines, and the Africa Bureau has
packaged them in a document titled, "[Guidelines for Determining the
Arsenic Content of Ground Water in USAID-Sponsored Well Programs in
Sub-Saharan
Africa](http://www.encapafrica.org/docs/Watsan/Arsenic testing guidelines AFR.doc)."
The SO team must assure that the standards and testing procedures
described in this guideline document are followed for potable water
supply activities under this program.

### General Use of Environmental Guidelines

As noted above, a key resource which should inform the SO and its
implementing partners in their design and implementation of \[these\]
activities is the Africa Bureau *Environmental Guidelines for
Small-Scale Activities in Africa (EGSSAA)
(*<http://www.encapafrica.org/SmallScaleGuidelines.htm>). The SO team
should assure that implementing partners have access to these and other
appropriate Africa Bureau and generic environmental assessment
resources. Such resources will help these partners to determine what
potential impacts to guard against for different types of development
activities in various settings.

EGSSAA chapters of particular relevance to the SO's program are the
following (select or delete rows as appropriate):

**PART II - Sector Specific Guidelines**

+--------+----------------------------------------+-----------+-------+
| C      | Chapter Title                          | PDF       | HTML  |
| hapter |                                        |           |       |
|        |                                        |           |       |
| \#     |                                        |           |       |
+--------+----------------------------------------+-----------+-------+
| 1      | Introduction                           | [p        |       |
|        |                                        | df](../.. |       |
|        |                                        | /../../.. |       |
|        |                                        | /../../.. |       |
|        |                                        | /E:%5CENC |       |
|        |                                        | AP%5Cwww. |       |
|        |                                        | encapafri |       |
|        |                                        | ca.org%5C |       |
|        |                                        | EGSSAAsec |       |
|        |                                        | tionsMarc |       |
|        |                                        | h2003%5CE |       |
|        |                                        | nv%20Guid |       |
|        |                                        | elines%20 |       |
|        |                                        | BW%20Part |       |
|        |                                        | %20II%20I |       |
|        |                                        | ntro.pdf) |       |
|        |                                        | (8K)      |       |
+--------+----------------------------------------+-----------+-------+
| 2      | Agriculture and Irrigation             | [pdf      |       |
|        |                                        | ](javascr |       |
|        |                                        | ipt:if(co |       |
|        |                                        | nfirm('ht |       |
|        |                                        | tp://www. |       |
|        |                                        | encapafri |       |
|        |                                        | ca.org/EG |       |
|        |                                        | SSAAsecti |       |
|        |                                        | onsMarch2 |       |
|        |                                        | 003/agric |       |
|        |                                        | ulture.pd |       |
|        |                                        | f  \n\nTh |       |
|        |                                        | is file w |       |
|        |                                        | as not re |       |
|        |                                        | trieved b |       |
|        |                                        | y Telepor |       |
|        |                                        | t Pro, be |       |
|        |                                        | cause the |       |
|        |                                        |  server r |       |
|        |                                        | eports th |       |
|        |                                        | at this f |       |
|        |                                        | ile canno |       |
|        |                                        | t be foun |       |
|        |                                        | d.  \n\nD |       |
|        |                                        | o you wan |       |
|        |                                        | t to open |       |
|        |                                        |  it from  |       |
|        |                                        | the serve |       |
|        |                                        | r?'))wind |       |
|        |                                        | ow.locati |       |
|        |                                        | on='http: |       |
|        |                                        | //www.enc |       |
|        |                                        | apafrica. |       |
|        |                                        | org/EGSSA |       |
|        |                                        | Asections |       |
|        |                                        | March2003 |       |
|        |                                        | /agricult |       |
|        |                                        | ure.pdf') |       |
|        |                                        | (804K)    |       |
+--------+----------------------------------------+-----------+-------+
| 3      | Community-Based Natural Resource       | [pdf      | [     |
|        | Management (CBNRM)                     | ](../../. | html] |
|        |                                        | ./../../. | (../. |
|        |                                        | ./../../E | ./../ |
|        |                                        | :%5CENCAP | ../.. |
|        |                                        | %5Cwww.en | /../. |
|        |                                        | capafrica | ./../ |
|        |                                        | .org%5CEG | E:%5C |
|        |                                        | SSAAsecti | ENCAP |
|        |                                        | onsMarch2 | %5Cww |
|        |                                        | 003%5CEnv | w.enc |
|        |                                        | %20Guidel | apafr |
|        |                                        | ines%20BW | ica.o |
|        |                                        | %20Chapte | rg%5C |
|        |                                        | r%203%20C | secto |
|        |                                        | BNRM.pdf) | rs%5C |
|        |                                        | (318K)    | CBNRM |
|        |                                        |           | .htm) |
+--------+----------------------------------------+-----------+-------+
| 4      | Construction                           | [p        | [ht   |
|        |                                        | df](../.. | ml](. |
|        |                                        | /../../.. | ./../ |
|        |                                        | /../../.. | ../.. |
|        |                                        | /E:%5CENC | /../. |
|        |                                        | AP%5Cwww. | ./../ |
|        |                                        | encapafri | ../E: |
|        |                                        | ca.org%5C | %5CEN |
|        |                                        | EGSSAAsec | CAP%5 |
|        |                                        | tionsMarc | Cwww. |
|        |                                        | h2003%5CE | encap |
|        |                                        | nv%20Guid | afric |
|        |                                        | elines%20 | a.org |
|        |                                        | BW%20Chap | %5Cse |
|        |                                        | ter%204%2 | ctors |
|        |                                        | 0Construc | %5Cco |
|        |                                        | tion.pdf) | nstru |
|        |                                        | (902K)    | ction |
|        |                                        |           | .htm) |
+--------+----------------------------------------+-----------+-------+
| 5      | Ecotourism                             | [pdf](../ | [     |
|        |                                        | ../../../ | html] |
|        |                                        | ../../../ | (../. |
|        |                                        | ../E:%5CE | ./../ |
|        |                                        | NCAP%5Cww | ../.. |
|        |                                        | w.encapaf | /../. |
|        |                                        | rica.org% | ./../ |
|        |                                        | 5CEGSSAAs | E:%5C |
|        |                                        | ectionsMa | ENCAP |
|        |                                        | rch2003%5 | %5Cww |
|        |                                        | CEnv%20Gu | w.enc |
|        |                                        | idelines% | apafr |
|        |                                        | 20BW%20Ch | ica.o |
|        |                                        | apter%205 | rg%5C |
|        |                                        | %20Ecotou | secto |
|        |                                        | rism.pdf) | rs%5C |
|        |                                        | (5256K)   | ecoto |
|        |                                        |           | urism |
|        |                                        |           | .htm) |
+--------+----------------------------------------+-----------+-------+
| 6      | Energy Sources for Development         | [pdf]     | [ht   |
|        |                                        | (../../.. | ml](. |
|        |                                        | /../../.. | ./../ |
|        |                                        | /../../E: | ../.. |
|        |                                        | %5CENCAP% | /../. |
|        |                                        | 5Cwww.enc | ./../ |
|        |                                        | apafrica. | ../E: |
|        |                                        | org%5CEGS | %5CEN |
|        |                                        | SAAsectio | CAP%5 |
|        |                                        | nsMarch20 | Cwww. |
|        |                                        | 03%5CEnv% | encap |
|        |                                        | 20Guideli | afric |
|        |                                        | nes%20BW% | a.org |
|        |                                        | 20Chapter | %5Cse |
|        |                                        | %206%20En | ctors |
|        |                                        | ergy.pdf) | %5Cbi |
|        |                                        | (170K)    | omass |
|        |                                        |           | .htm) |
+--------+----------------------------------------+-----------+-------+
| 7      | Fisheries and Aquaculture              | [pdf](..  |       |
|        |                                        | /../../.. |       |
|        |                                        | /../../.. |       |
|        |                                        | /../E:%5C |       |
|        |                                        | ENCAP%5Cw |       |
|        |                                        | ww.encapa |       |
|        |                                        | frica.org |       |
|        |                                        | %5CEGSSAA |       |
|        |                                        | sectionsM |       |
|        |                                        | arch2003% |       |
|        |                                        | 5CEnv%20G |       |
|        |                                        | uidelines |       |
|        |                                        | %20BW%20C |       |
|        |                                        | hapter%20 |       |
|        |                                        | 7%20Fishe |       |
|        |                                        | ries.pdf) |       |
|        |                                        | (203K)    |       |
+--------+----------------------------------------+-----------+-------+
| 8      | Forestry: Including Forest Management, | [pdf]     |       |
|        | Plantations, and Agroforestry          | (../../.. |       |
|        |                                        | /../../.. |       |
|        |                                        | /../../E: |       |
|        |                                        | %5CENCAP% |       |
|        |                                        | 5Cwww.enc |       |
|        |                                        | apafrica. |       |
|        |                                        | org%5CEGS |       |
|        |                                        | SAAsectio |       |
|        |                                        | nsMarch20 |       |
|        |                                        | 03%5Cfore |       |
|        |                                        | stry.pdf) |       |
|        |                                        | (444K)    |       |
+--------+----------------------------------------+-----------+-------+
| 9      | Healthcare Waste: Generation,          | [pdf](../ | [htm  |
|        | Handling, Treatment and Disposal       | ../../../ | l](.. |
|        |                                        | ../../../ | /../. |
|        |                                        | ../E:%5CE | ./../ |
|        |                                        | NCAP%5Cww | ../.. |
|        |                                        | w.encapaf | /../. |
|        |                                        | rica.org% | ./E:% |
|        |                                        | 5CEGSSAAs | 5CENC |
|        |                                        | ectionsMa | AP%5C |
|        |                                        | rch2003%5 | www.e |
|        |                                        | CEnv%20Gu | ncapa |
|        |                                        | idelines% | frica |
|        |                                        | 20BW%20Ch | .org% |
|        |                                        | apter%209 | 5Csec |
|        |                                        | %20Health | tors% |
|        |                                        | care.pdf) | 5Cmed |
|        |                                        | (4422K)   | waste |
|        |                                        |           | .htm) |
+--------+----------------------------------------+-----------+-------+
| 10     | Housing                                | [zip]     |       |
|        |                                        | (../../.. |       |
|        |                                        | /../../.. |       |
|        |                                        | /../../E: |       |
|        |                                        | %5CENCAP% |       |
|        |                                        | 5Cwww.enc |       |
|        |                                        | apafrica. |       |
|        |                                        | org%5CEGS |       |
|        |                                        | SAAsectio |       |
|        |                                        | nsMarch20 |       |
|        |                                        | 03%5CEGGS |       |
|        |                                        | SA%20Hous |       |
|        |                                        | ing%20Cha |       |
|        |                                        | pter.zip) |       |
|        |                                        | (1858K)   |       |
+--------+----------------------------------------+-----------+-------+
| 11     | Humanitarian Response Programs and the | [p        |       |
|        | Environment                            | df](../.. |       |
|        |                                        | /../../.. |       |
|        |                                        | /../../.. |       |
|        |                                        | /E:%5CENC |       |
|        |                                        | AP%5Cwww. |       |
|        |                                        | encapafri |       |
|        |                                        | ca.org%5C |       |
|        |                                        | EGSSAAsec |       |
|        |                                        | tionsMarc |       |
|        |                                        | h2003%5CE |       |
|        |                                        | GSSAA%20h |       |
|        |                                        | umanitari |       |
|        |                                        | an%20resp |       |
|        |                                        | onse.pdf) |       |
|        |                                        | (514K)    |       |
+--------+----------------------------------------+-----------+-------+
| 12     | Pest & Pesticide Management I:         |           |       |
|        | Integrated Pest Management (IPM)       |           |       |
+--------+----------------------------------------+-----------+-------+
| 13     | Pest & Pesticide Management II: Safer  |           |       |
|        | Pesticide Use                          |           |       |
+--------+----------------------------------------+-----------+-------+
| 14     | Livestock                              | [pdf]     |       |
|        |                                        | (../../.. |       |
|        |                                        | /../../.. |       |
|        |                                        | /../../E: |       |
|        |                                        | %5CENCAP% |       |
|        |                                        | 5Cwww.enc |       |
|        |                                        | apafrica. |       |
|        |                                        | org%5CEGS |       |
|        |                                        | SAAsectio |       |
|        |                                        | nsMarch20 |       |
|        |                                        | 03%5CEnv% |       |
|        |                                        | 20Guideli |       |
|        |                                        | nes%2013% |       |
|        |                                        | 20Livesto |       |
|        |                                        | ck%20Grap |       |
|        |                                        | hics%20JR |       |
|        |                                        | %201.pdf) |       |
|        |                                        | (2069K)   |       |
+--------+----------------------------------------+-----------+-------+
| 15     | Rural Roads                            | [pdf](..  | [     |
|        |                                        | /../../.. | html] |
|        |                                        | /../../.. | (../. |
|        |                                        | /../E:%5C | ./../ |
|        |                                        | ENCAP%5Cw | ../.. |
|        |                                        | ww.encapa | /../. |
|        |                                        | frica.org | ./../ |
|        |                                        | %5CEGSSAA | E:%5C |
|        |                                        | sectionsM | ENCAP |
|        |                                        | arch2003% | %5Cww |
|        |                                        | 5CEnv%20G | w.enc |
|        |                                        | uidelines | apafr |
|        |                                        | %2014%20R | ica.o |
|        |                                        | ural%20Ro | rg%5C |
|        |                                        | ads%20Gra | secto |
|        |                                        | phic%20JR | rs%5C |
|        |                                        | %202.pdf) | roads |
|        |                                        | (7345K)   | .htm) |
+--------+----------------------------------------+-----------+-------+
| 16     | Safer Pesticide Use                    |           |       |
+--------+----------------------------------------+-----------+-------+
| 17     | Solid Waste                            | [pdf      |       |
|        |                                        | ](../../. |       |
|        |                                        | ./../../. |       |
|        |                                        | ./../../E |       |
|        |                                        | :%5CENCAP |       |
|        |                                        | %5Cwww.en |       |
|        |                                        | capafrica |       |
|        |                                        | .org%5CEG |       |
|        |                                        | SSAAsecti |       |
|        |                                        | onsMarch2 |       |
|        |                                        | 003%5CEnv |       |
|        |                                        | %20Guidel |       |
|        |                                        | ines%2015 |       |
|        |                                        | %20MSW%20 |       |
|        |                                        | Graphics% |       |
|        |                                        | 20JR.pdf) |       |
|        |                                        | (357K)    |       |
+--------+----------------------------------------+-----------+-------+
| 18     | Water Supply and Sanitation            | [pdf]     | [h    |
|        |                                        | (../../.. | tml]( |
|        |                                        | /../../.. | ../.. |
|        |                                        | /../../E: | /../. |
|        |                                        | %5CENCAP% | ./../ |
|        |                                        | 5Cwww.enc | ../.. |
|        |                                        | apafrica. | /../E |
|        |                                        | org%5CEGS | :%5CE |
|        |                                        | SAAsectio | NCAP% |
|        |                                        | nsMarch20 | 5Cwww |
|        |                                        | 03%5CEnv% | .enca |
|        |                                        | 20Guideli | pafri |
|        |                                        | nes%20BW% | ca.or |
|        |                                        | 20Chapter | g%5Cs |
|        |                                        | %2016%20W | ector |
|        |                                        | ater.pdf) | s%5Cw |
|        |                                        | (4803K)   | atsan |
|        |                                        |           | .htm) |
+--------+----------------------------------------+-----------+-------+

PART III - Guidelines for Micro and Small Enterprises (MSEs)

  --- --------------------------------------------- -----------------------------------------------------------------------------------------------------------------------------------------------------------
      Title                                         Download English Version

  1   Introduction - MSEs & the Environment         [pdf](../../../../../../../../E:%5CENCAP%5Cwww.encapafrica.org%5CEGSSAAsectionsMarch2003%5CEnv%20Guidelines%20MSE%20Chapter%201.pdf) (314K)

  2   Mechanisms for MSEs to Control Environmental  [pdf](../../../../../../../../E:%5CENCAP%5Cwww.encapafrica.org%5CEGSSAAsectionsMarch2003%5CEnv%20Guidelines%20MSE%20Chapter%202.pdf) (316K)
      Impact                                        

  3   Integrating Environmental Considerations into [pdf](../../../../../../../../E:%5CENCAP%5Cwww.encapafrica.org%5CEGSSAAsectionsMarch2003%5CEnv%20Guidelines%20MSE%20Chapter%203.pdf) (599K)
      MSE Assistance Activities                     

  4   Sub-Sector Specific CP Briefings              [pdf](../../../../../../../../E:%5CENCAP%5Cwww.encapafrica.org%5CEGSSAAsectionsMarch2003%5CEnv%20Guidelines%20MSE%20Chapter%204%20main.pdf) (392K)

      4.1 Brick & Tile Production                   [pdf](../../../../../../../../E:%5CENCAP%5Cwww.encapafrica.org%5CEGSSAAsectionsMarch2003%5CEnv%20Guidelines%20MSE%20Chapter%204%20Brick%20and%20Tile.pdf)
                                                    (493K)

      4.2 Food Processing                           [pdf](../../../../../../../../E:%5CENCAP%5Cwww.encapafrica.org%5CEGSSAAsectionsMarch2003%5CEnv%20Guidelines%20MSE%20Chapter%204%20Food%20Processing.pdf)
                                                    (518K)

      4.3 Leather Processing                        [pdf](../../../../../../../../E:%5CENCAP%5Cwww.encapafrica.org%5CEGSSAAsectionsMarch2003%5CEnv%20Guidelines%20MSE%20Chapter%204%20Leather.pdf) (483K)

      4.4 Metal Finishing                           [pdf](../../../../../../../../E:%5CENCAP%5Cwww.encapafrica.org%5CEGSSAAsectionsMarch2003%5CEnvGuidelines%203.4G%20Metal%20Finishing.pdf) (322K)

      4.5 Small-Scale Mining                        [pdf](../../../../../../../../E:%5CENCAP%5Cwww.encapafrica.org%5CEGSSAAsectionsMarch2003%5CEnv%20Guidelines%20MSE%20Chapter%204%20Mining.pdf) (509K)

      4.6 Wet Textile Operations                    [pdf](../../../../../../../../E:%5CENCAP%5Cwww.encapafrica.org%5CEGSSAAsectionsMarch2003%5CEnv%20Guidelines%20MSE%20Chapter%204%20Wet%20Textile.pdf) (500K)

      4.7 Wood Processing and Furniture Making      [pdf](../../../../../../../../E:%5CENCAP%5Cwww.encapafrica.org%5CEGSSAAsectionsMarch2003%5CEnv%20Guidelines%203.4F%20Wood%20and%20Furniture.pdf) (291K)

  5   References                                    [pdf](../../../../../../../../E:%5CENCAP%5Cwww.encapafrica.org%5CEGSSAAsectionsMarch2003%5CEnv%20Guidelines%20MSE%20Chapter%205.pdf) (148K)

  6   Annexes                                       [pdf](../../../../../../../../E:%5CENCAP%5Cwww.encapafrica.org%5CEGSSAAsectionsMarch2003%5CMSE%20Chapter%206.pdf) (472K)
  --- --------------------------------------------- -----------------------------------------------------------------------------------------------------------------------------------------------------------

### ENVIRONMENTAL SCREENING

[]{#Env_Screening .anchor}

> [\[NOTE: include alternative of Environmental Review Report (ERR)
> format, as now in the EGSSAA Part III
> ([www.encapafrica/SmallScaleGuidelines](http://www.encapafrica/SmallScaleGuidelines)/.
> Use the most recently revised version of the , which WIK revised in
> April 2004...\]]{.mark} -- How to deal with this, link to where?

(Adapted from 33Rwanda2_SO1_DG_amend.doc)

Given that \[the nature of the activities is not well know\] \[details
about the proposed activities are not yet fully developed, e.g.
siting\], the grantee or sub-grantee will be required to subject \[the
referenced activities\] to an environmental screening process intended
to identify potential environmental problems, appropriate mitigation
measures, and to trigger supplemental environmental review if
appropriate. The SO team has the responsibility to ensure that the
environmental screening and review process is applied in conformity with
the procedures described below:

-   Implementing partners will screen proposed activities according to
    ***the Africa Bureau Screening and Environmental Review Process***,
    which is described in the Bureau's Environmental Procedures Training
    Manual, "[Annex G: Umbrella IEEs and Subgrant Environmental
    Screening](http://www.encapafrica.org/EPTM/annex_G.pdf)." As
    described in that chapter, screening categories include the
    following: **Category 1**. Activities that would normally qualify
    for a categorical exclusion under Reg. 216; **Category 2**.
    Activities that would normally qualify for a negative determination
    under Reg. 216; **Category 3**. Activities that have a clear
    potential for undesirable environmental impacts and typically under
    Reg. 216 require an Environmental Assessment; **Category 4**.
    Activities that either USAID cannot fund or for which specific
    findings must be made in an Environmental Assessment prior to
    funding.

> The MEO shall be responsible, first, for clearing the implementing
> partner's category determination. Further, the MEO must approve all
> Category 2 Environmental Reviews individually or in groups. The MEO
> will review and pass on to the REO and BEO any Category 3 reviews and,
> as he/she determines the need, Category 2 documentation. All Category
> 3 Environmental Reviews must be approved by the BEO. Any activities
> that fall within Category 4 will be immediately referred to the REO
> and BEO, unless the MEO rejects them and thereby denies implementation
> of the subject activities.

#### [Medical Waste]{.underline}

*Potential impacts*

Although small-scale healthcare activities provide many important
benefits to communities, they can also unintentionally do great harm
through poor design and management of waste management systems.
Healthcare waste is dangerous. If handled, treated, disposed of
incorrectly it can spread disease, poisoning people, livestock, wild
animals, plants and whole ecosystems.

Currently, little or no management of healthcare wastes typically occurs
in small-scale facilities in Africa. Training and supplies are minimal.
Common practice in urban areas is to dispose of healthcare waste along
with the general solid waste or, in peri-urban and rural areas, to bury
waste, without treatment, in an unlined pit. In some cities small
hospitals may incinerate waste in dedicated on-site incinerators, but
often they fail to operate them properly. Unwanted pharmaceuticals and
chemicals may be dumped into the local sanitation outlet, be it a sewage
system, septic tank or latrine.

*Conditions*

For \[identify affected activities -- involving the potential for
generation of medical waste\], the SO team must work with its
implementing partners to assure, to the extent possible, that the
medical facilities and operations involved have adequate procedures and
capacities in place to properly handle, label, treat, store, transport
and properly dispose of blood, sharps and other medical waste. The USAID
Bureau for Africa's Environmental Guidelines for Small Scale Activities
in Africa (EGSSAA) Chapter 8, "Healthcare Waste: Generation, Handling,
Treatment and Disposal" (found at this URL:
<http://encapafrica.org/SmallScaleGuidelines.htm>) contains guidance
which should inform the Team's activities to promote proper handling and
disposal of medical waste, particularly in the section titled, "Minimum
elements of a complete waste management program." Other important
references to consult in establishing a waste management program are
"WHO's Safe Management of Wastes from Healthcare Activities"
<http://www.who.int/water_sanitation_health/medicalwaste/wastemanag/en/>
and the State Department cable "1993 State 264038: Model Guidance on
Health Projects Involving HIV Screening and Handling of Blood." The
ability of the Team to assure such procedures and capacity is understood
to be limited by its level of control over the management of the
facilities and operations that USAID/\[country\] is supporting.

[\[Also consider including a "Minimal Program Checklist and Action Plan"
with the IEE and adding this text...WIK\]]{.mark}

**Annex A** was adapted from the above EGSSAA chapter. It presents a
representative and appropriate "Minimal Program Checklist and Action
Plan" for handling healthcare waste, and should be further adapted for
use in USAID/Sudan programs.

#### [Livestock production]{.underline}

*Potential impacts*

Properly managed, livestock production can enhance land and water
quality, biodiversity, and social and economic well-being. However, when
improperly managed, livestock production may cause significant economic,
social and environmental damage. As described in the [Livestock
Production
chapter](http://www.encapafrica.org/EGSSAAsectionsJan04/Env Guidelines Chapter 11 Livestock.pdf)
of the EGSSAA, following are the types of environmental problems often
associated with livestock production:

-   Land degradation;

-   Habitat damage and reduced biodiversity;

-   Harm to vegetation.

Livestock product processing can also have negative impacts on the
environment. Leather processing, for example, is a particularly
problematic activity associated with livestock production, as described
in EGSSAA "*[Chapter 4.3 Leather Processing: Cleaner Production Fact
Sheet and Resource
Guide](http://www.encapafrica.org/EGSSAAsectionsMarch2003/Env Guidelines MSE Chapter 4 Leather.pdf)."*
Environmental problems commonly associated with leather processing
include the introduction of toxic chemicals into the environment through
the waste stream, use of large quantities of water, worker health
hazards, odor, and overproduction and inappropriate management of waste.

*Conditions*

For increased livestock production and processing a **Negative
Determination** is recommended per 22 CFR 216.3 (a)(2)(iii) **with
conditions** that include:

The SO team must work with implementing partners to assure that the
livestock production activities are designed and implemented in such a
way as to avoid potential harmful impacts as much as possible. The above
EGSSAA chapters should be used as guides to this analysis. Of particular
utility for such an analysis is the Livestock chapter's table titled,
*Mitigation and Monitoring Issues Environmental Mitigation and
Monitoring Issues for Livestock Projects*. Implementing partners should
monitor for and report on adverse impacts, particularly land and habitat
degradation.

#### [Research or Studies with human subjects and/or animals]{.underline}

To the extent this involves carefully controlled research, but and thus
poses risk factors with respect to human and animal subjects, the
following conditions apply:

-   Any issues concerning human research subjects will follow NIH
    requirements in consultation with CDC advisors. Procedures must be
    consistent U.S. National Institutes for Health (NIH) guidelines for
    research involving human subjects. See 45 CFR Part 45. Protection of
    Human Subjects. See the URL:
    http://ohrp.osophs.dhhs.gov/humansubjects/guidance/45cfr46.htm

-   Also, recommend following U.S. National Institutes for Health (NIH)
    guidelines for research involving live animals. The use of animals
    in research is a privilege that carries with it the responsibilities
    of proper care and humane treatment of animals. To biomedical
    scientists, proper care is in the best interest of the laboratory
    animals and is essential to ensure quality research. Consider Public
    Law 99-158:Animals in Research:
    <http://grants.nih.gov/grants/olaw/references/hrea1985.htm>.

### ANNOTATED IEE OUTLINE

[]{#Annotated_IEE_Outline .anchor}

# INITIAL ENVIRONMENTAL EXAMINATION

**PROGRAM/ACTIVITY DATA**:

[\[For Title II DRP IEEs\]]{.mark}

DRP Program/Activity:

CS Name, Country/Region:

[\[For non-Title II IEEs\]]{.mark}

Program/Activity Number:

Country/Region:

Program/Activity Title:

**1.0 BACKGROUND AND ACTIVITY/PROGRAM DESCRIPTION**

1.  **Purpose and Scope of IEE**

What does the IEE cover, why is it needed, is it an amendment, and if
so, why? What other IEEs cover the sector, or SO, if any? .

2.  **Background**

Describe why the activity is desired and appropriate, with some relevant
context..

3.  **Description of Activities**

Outline the key activities proposed for funding. A current activity
description should be provided, paraphrasing and shortening as much as
needed. Some suggested subheadings:

**1.2.1 Results Framework**

**1.2.2 SO... Activities Results Framework**

2.  **COUNTRY AND ENVIRONMENTAL INFORMATION (BASELINE INFORMATION)**

Recommended subheadings:

**2.1 Locations Affected**

**2.2 National \[or applicable\] Environmental Policies and Procedures
\[of host country both for environmental assessment and pertaining to
the sector\]**

This section is critical and should briefly assess the current physical
environment that might be affected by the activity. It should draw on
the Country Strategy and supportive analysis (such as the Environmental
Threats and Opportunities Assessment, Conflict Vulnerability Assessment,
etc.). While we are seeking to streamline IEEs, we also need to try to
maintain the integrity of relevant analysis that sheds light on the
interventions in the SO. This may be a standard we cannot always meet.

Our objective should be to add analysis which has a bearing upon the
substance of the sector involved, we don't want irrelevant "fill"
material in here. Ideally some thoughtful analysis should be there, or
at least compact, up-to-date, relevant info to the sector, e.g., on the
environment-conflict links. It is worth drawing attention, in the IEE
(which seeks to ensure that we avoid harm, in the most basic biophysical
sense), to the SO's opportunities for improving environmental management
and governance.

Depending upon the activities proposed, this could include an
examination of land use, geology, topography, soil, climate, groundwater
resources, surface water resources, terrestrial communities, aquatic
communities, environmentally sensitive areas (e.g., wetlands or
protected species), agricultural cropping patterns and practices,
infrastructure and transport services, air quality, demography
(including population trends/projections), cultural resources, and the
social and economic characteristics of the target communities.

The information obtained through this process should serve as an
environmental baseline for future environmental monitoring and
evaluation. Be selective in the country and environmental information
you provide, as it should be specific to the activity being proposed and
more information is not necessarily better.

Finally, indicate the status and applicability of host country, Mission,
and CS policies, programs and procedures in addressing natural
resources, the environment, food security, and other related issues.

*Cross-referencing*. One approach which might be an appropriate
expedient is to refer to an earlier IEE's write-up for this Section, as
long as it is in the same strategy period, and reasonably recent and
relevant (say, less than 3-5 years old). If one were to use this
approach, here's how it should be done, so the file can be found online:
"See IEE for SO1 \-- Increased rule of law and transparency in
governance, 27rwand4.iee, at
<http://www.afr-sd.org/documents/iee/docs/27rwand4.doc>. "

The [BEO Actions Tracker](http://www.afr-sd.org/IEE/) is a reliable
resource, typically kept current within at least six months.

3.  **EVALUATION OF PROJECT/PROGRAM ISSUES WITH RESPECT TO ENVIRONMENTAL
    IMPACT POTENTIAL**

> This section of the IEE is intended to define all potential
> environmental impacts of the activity or project, whether they be
> considered direct, indirect, beneficial, undesired, short-term,
> long-term, or cumulative.

**4.0 RECOMMENDED THRESHOLD DECISIONS & MITIGATION ACTIONS (INCLUDING
MONITORING AND EVALUATION)**

**4.1 Recommended Threshold Decisions and Conditions**

**4.2 Mitigation, Monitoring and Evaluation**

*[FOR UMBRELLA IEE, THE FOLLOWING MIGHT BE USED:]{.mark}*

**4.1 Recommended Threshold Decisions and Conditions**

**4.2 Recommended Planning Approach**

**4.3 Environmental Screening and Review Process**

**4.3 Promotion of Environmental Review and Capacity Building
Procedures**

**4.4 Environmental Responsibilities**

**4.5 Mitigation, Monitoring, and Evaluation**

> For each proposed activity or major component recommend whether a
> specific intervention included in the activity should receive a
> categorical exclusion, negative determination (with or without
> conditions), positive determination, etc., as well as cite which
> sections of Reg. 216 support the requested determinations.
>
> Recommend what is to be done to avoid, minimize, eliminate or
> compensate for environmental impacts. For activities where there are
> expected environmental consequences, appropriate environmental
> monitoring and impact indicators should be incorporated in the
> activity's monitoring and evaluation plan.

### SELECTED IEE NARRATIVE EXAMPLES:

**1.1** []{#Purpose_Scope_IEE .anchor}**Purpose and Scope of IEE**

The purpose of this IEE is to update the threshold decisions made for
the former SO 3 "*Increased use of essential PHC & HIV/AIDS services and
practices*" and supercedes the IEE formulated for this SO, covered in
29saf1 (6/17/1999). The latter IEE included the HIV/AIDS/STD HIV/AIDS
Capacity Building Project (CAPACITY) in 28saf2.iee, and the EQUITY
project.

USAID/South Africa has undertaken a technical adjustment of its health
strategy for the period 2003-2010. It addresses the need to adjust the
current health strategy to better account for the expanding HIV/AIDS
epidemic and its impact on the other health challenges facing South
Africa such as TB, ensuring the quality and availability of
reproductive, maternal and child health services to all South Africans.

The adjusted Strategic Objective (now referred to as SO 8) "*Increased
Use of HIV/AIDS and Other PHC Services*" reflects only a minor revision
of the previous SO, but introduces significant scaling up of HIV/AIDS
activities and their integration into primary health care services. The
SO focuses on high-impact prevention, care and support activities that
can be taken to scale and that promote effective public-private
partnerships especially at the community level. The SO also builds on
significant progress made thus far, and expands successful elements of
the existing program and the previous program focus on Primary Health
Care (PHC) and HIV/AIDS. This includes activities implemented with
HIV/AIDS funding under the President's Emergency Plan for AIDS Relief
(PEPFAR). These activities will be implemented under the SO3/8 Strategic
Objective Agreement (SOAG) with the Government of the Republic of South
Africa (674-008).

This situation provides the opportunity to update the IEE for all of SO
3 to the somewhat revised but greatly expanded SO 8. The 1999 SO 3 IEE
(June 1999), with Categorical Exclusions and a Negative Determination
with Conditions, effectively replaced the two prior IEEs (Table 1) and
provided one vehicle for Reg. 216 monitoring and amendment should new
activities be added in the future.

Table 1. Former IEEs now amended or superceded.x

  ----------------------- ------------------------------- ----- ---------------- --------- ----------
  **SO 8 (SO 3):                                                                           
  Increased Use of                                                                         
  Primary Healthy                                                                          
  Services and HIV/AIDS                                                                    
  Prevention/Mitigation                                                                    
  Practices**                                                                              

  674-0320                SO3 \-- Increased use of        CE,   1995&1998-2003   29saf1    06/17/99
                          essential primary health care   NDC                              
                          and HIV/AIDS services and                                        
                          practices (EQUITY). Provided                                     
                          umbrella ND for all SO 3                                         
                          activities. Present IEE amends                                   
                          this one.                                                        

  674-0324                HIV/AIDS/STD Capacity-Building  CE    1998-2003        28saf2    02/09/98
                          Project (CAPACITY Project)                                       
  ----------------------- ------------------------------- ----- ---------------- --------- ----------

This amended IEE covers only Phase I, for the period 2003-2006, which
corresponds to the current approved USAID/SA CSP. This IEE does not
address construction, or water and sanitation-related health activities
nor use of pesticides, support for any of which would require amendment
of this IEE.

**4.2** []{#Mit_Mon_Responsibilities .anchor}**Mitigation and Monitoring
Responsibilities \[ & Compliance Assurance\] -- cf. Sect. 4.2, etc.**

\[also see end of Face Sheet Summary\]:

**Caveat:**

In accordance with USAID/SA Mission Order 405 (as amended June 9, 1999)
and ADS 204.5.4, the SO2 team, with assistance from the MEO and REO,
must actively monitor ongoing activities for compliance with approved
IEE recommendations, and modify or end activities that are not in
compliance. If there are any changes which affect the basis on which
these threshold decisions were made, an IEE amendment will be prepared.
The SO team will also ensure that provisions of the IEE concerning
mitigation measures and the conditions specified herein along with the
requirement to monitor be incorporated in all contracts, cooperative
agreements, grants and subgrants.

### ANNOTATED OUTLINE FOR REQUESTS FOR CATEGORICAL EXCLUSION

[\[alternative format if requesting only a Categorical Exclusion, no
extensive narrative needed, normally need not exceed 1-2 pages\]]{.mark}

**Annex 1**

**\[JUSTIFICATION\] REQUEST FOR CATEGORICAL EXCLUSION**

**[SO \# & program / activity title]{.mark}**

1\. **Background and Activity Description**

> More in-depth information than what was provided on the cover sheet,
> especially if activities are relatively diverse, complex, and likely
> to operate for several years. This will allow the environmental
> recommendation to be more self-explanatory and free-standing,
> especially for the BEO's record keeping and tracking purposes.

2\. **Justification for Categorical Exclusion Request**

Refer to appropriate guidance from Reg. 216, especially 22 CFR
216.2(c)...

### [FACE SHEET TEMPLATE FOR IEE/CE -- Remove this line]{.mark}

**INITIAL ENVIRONMENTAL EXAMINATION**

**OR**

**CATEGORICAL EXCLUSION**

**[PROGRAM/ACTIVITY DATA]{.underline}:**

**Program/Activity Number:** ( - [)]{.underline}

**Country/Region:**

**Program/Activity Title:**

**Funding Begin:** **Funding End:** **LOP Amount:** \$

**Sub-Activity Amount:** \$

**IEE Prepared By:** **Current Date:**

**IEE Amendment (Y/N):** If \"yes\", Filename & date of original IEE ;

**[ENVIRONMENTAL ACTION RECOMMENDED:]{.underline}** (Place X where
applicable)

Categorical Exclusion: Negative Determination:

Positive Determination: Deferral:

**[ADDITIONAL ELEMENTS:]{.underline}** (Place X where applicable)

CONDITIONS PVO/NGO:

**[SUMMARY OF FINDINGS:]{.underline}** (please limit to this page
whenever possible, but at most three pages without clearances)

**[APPROVAL OF ENVIRONMENTAL ACTION RECOMMENDED:]{.underline}** (Type
name under signature line)

**CLEARANCE:**

Mission Director: Date:

**CONCURRENCE:**

Bureau Environmental

Officer: Date:

Paul des Rosiers (Acting) Approved:

Disapproved:

**Filename:** (USAID/AFR BEO)

**[ADDITIONAL CLEARANCES]{.underline}:** [(Add as appropriate; type name
under signature line)]{.mark}

Mission Environmental Officer: Date:

Activity Manager: Date:

(Cognizant Technical Officer, etc.)

SO Team Leader: Date:

Regional Environmental Officer

[(RCSA,REDSO, WARP):]{.mark} Date:

[Rob Clausen, Walter Knausenberger or Jean Saint-Cyr]{.mark}

Regional Environmental Advisor

(AFR/SD): Date:

[Brian Hirsch]{.mark}

General Counsel

(Africa Bureau): Date:

Regional Legal Advisor: Date:

May 20, 2004

### Streamlined IEE Formats: Experimenting

Some experimentation is underway with streamlining preparation and
review of Reg. 216 documentation.

1.  Some preparers contend that Section 2 does not add sufficiently to
    the IEEs' substance (very rarely do they achieve "baseline info"
    quality), so why not curtail or drop it unless there is a persuasive
    reason to include details?   But see the annotations to Section 2 in
    the [Annotated Template](#Annotated_IEE_Outline) bove.

2.  Further, some believe that it is feasible to combine all analysis of
    impacts, mitigation conditions and threshold determinations in one
    place, a new section 2 or 3, or "the Table."   

3.  Length: Keep entire length to max. 15 pages (but not to be slavish
    about this).

4.  Agreement was reached on May 11, 2004 that GC will no longer need to
    receive IEEs for review routinely, but only when special or new
    issues arise, or Positive Determinations are involved.

So, by ...

·        Streamlining Sect. 1 to only essentials to characterize the
program, down to at IR level.

·        curtailing Sect. 2, to cover essentials for sector only, with
some info on relevant host country procedures and regulatory system,
application of environmental laws.  

·        combining Sect. 3-4, and

·        dropping Sect. 5, the Summary...

·        summarizing the essential decisions and conditions in the
Summary of Findings,

·        hyperlinking to EGSSAA resources (mainly, but not only),

·        otherwise eliminating anything unnecessarily repeated,

·        tightening up the threshold determination language using (an
ever-enhanced) RALF, and

·        making resources available on Africa Bureau EOKX,

...the process of preparing IEE can be significantly simplified and
streamlined.

### ACCEPTABLE TABLE FORMATS FOR PRESENTING THRESHOLD DECISIONS AND MITIGATION CONDITIONS

-   []{#Threshold_Decisions_Tables .anchor}A single Table, not several
    short ones close together

-   Landscape or Portrait format, in narrative body or as Annex.

-   Table header rows repeated automatically at top of each page (Table
    Properties, Row, check box)

ANNEX 1:

Summary Of Threshold Decisions, by IR, for Sudan SO 8: Foundation
Established For Economic Recovery. Refer to Section 4 for Expanded
mitigation and monitoring measures by key issue area.

+--------------------+---------------------+---------------------------+
| **Pr               | **Impact Issues &   | **Recommended Threshold   |
| ogram/Activities** | conditions,         | Determination & 22 CFR    |
|                    | mitigation or       | Part 216 (Reg. 216)       |
|                    | proactive           | citation**                |
|                    | interventions**     |                           |
+====================+=====================+===========================+
| **SO8: Foundation  |                     |                           |
| Established for    |                     |                           |
| Economic           |                     |                           |
| Recovery.**        |                     |                           |
+--------------------+---------------------+---------------------------+
| **Intermediate     | a\) Will not have a | a\) Categorical Exclusion |
| Result 8.1: Food   | direct effect on    | 22 CFR 216.2 (c)(2)(i),   |
| security needs of  | the environment.    | education, technical      |
| vulnerable         |                     | assistance or training;   |
| communities met.** | b\) See Sect. 3.2.1 | 216.2 (c)(2)(iii):        |
|                    | and Section 4.2.1   | analyses, studies,        |
| a\) The activities | regarding a PEA,    | academic or research      |
| for: (1) Food aid  | and the discussion  | workshops and meetings;   |
| distributions;     | under IR 8.3 below. | 216.2 (c)(2)(v): document |
| supplementary      |                     | and information           |
| feeding; training  | As apt, activities  | transfers; and, 216.2     |
| of agricultural    | will be subjected   | (c)(2)(viii) for programs |
| extension workers  | to a screening      | involving nutrition,      |
| and community      | process to identify | health care or population |
| animal health      | appropriate adverse | and family planning       |
| workers; and       | impact mitigation   | services.                 |
| providing support  | and monitoring      |                           |
| for disaster early | measures.           | b\) Positive              |
| warning systems.   |                     | Determination, per 22 CFR |
|                    |                     | 216.2(d)(viii) for road   |
| b\) Rehabilitation |                     | improvement. OFDA funded  |
| of roads, except   |                     | activities would not be   |
| where this is      |                     | directly implicated.      |
| exempted as per 22 |                     |                           |
| CFR 216.2 (b) (1)  |                     | Negative Determination    |
| ;                  |                     | with Conditions, 22 CFR   |
|                    |                     | 216.3 (a)(2)(iii). See    |
| Distributions of   |                     | Section 4.1 for details   |
| improved seeds;    |                     | on ND with conditions     |
| establishment of   |                     | regarding seed supply.    |
| community food     |                     | Conditions:               |
| stores and seed    |                     |                           |
| banks; and,        |                     | Application of            |
| encouragement of   |                     | appropriate guidelines as |
| change in crop     |                     | in                        |
| production choices |                     | <htt                      |
| and cultivation    |                     | p://www.encapafrica.org/S |
| techniques.        |                     | mallScaleGuidelines.htm>. |
+--------------------+---------------------+---------------------------+
| **IR 8.2: Market   | Will not have a     | Categorical Exclusion, 22 |
| support            | direct effect on    | CFR 216.2 (c)(2)(i),      |
| institutions       | the environment.    | education, technical      |
| created and        |                     | assistance or training;   |
| strengthened.**    | See Sect. 3.2.1 and | 216.2(c)(2)(ii): research |
|                    | Section 4.2.1       | and experimentation;      |
| Technical          | regarding a PEA,    | 216.2 (c)(2)(iii):        |
| assistance,        | and the discussion  | analyses, studies,        |
| training           | under IR 8.3 below. | academic or research      |
| workshops,         |                     | workshops and meetings;   |
| meetings, market   | Conditions:         | 216.2 (c)(2)(v): document |
| research,          |                     | and information           |
| information        | Application of      | transfers.                |
| documentation and  | appropriate         |                           |
| analysis, exchange | guidelines as in    | Negative Determination    |
| of skills and      | <http://www.enca    | with Conditions, 22 CFR   |
| market             | pafrica.org/SmallSc | 216.3 (a)(2)(iii)         |
| information;       | aleGuidelines.htm>. |                           |
| equipment supply,  |                     |                           |
| commodities, and,  | As apt, activities  |                           |
| establishment of   | will be subjected   |                           |
| links and networks | to a screening      |                           |
|                    | process to identify |                           |
| Rehabilitation and | appropriate adverse |                           |
| development of     | impact mitigation   |                           |
| buildings          | and monitoring      |                           |
| involving          | measures.           |                           |
| constructions,     |                     |                           |
| water and          |                     |                           |
| sanitation         |                     |                           |
| facilities and     |                     |                           |
| establishment of   |                     |                           |
| agribusiness       |                     |                           |
| training centers.  |                     |                           |
| Provision of       |                     |                           |
| sub-grants         |                     |                           |
+--------------------+---------------------+---------------------------+
| **IR 8.3 : Market  | a\. No impacts      | a\. Categorical           |
| support programs   | expected;           | Exclusion, 22 CFR 216.2   |
| and services**     | commodities will    | (c)(2)(i), education,     |
|                    | have no biophysical | technical assistance or   |
| **Introduced and   | actions on the      | training; 216.2           |
| expanded.**        | environment         | (c)(2)(iii): analyses,    |
|                    |                     | studies, academic or      |
| a\. Technical      | b\. A programmatic  | research workshops and    |
| assistance,        | or sectoral EA      | meetings; 216.2           |
| training           | approach is         | (c)(2)(v): document and   |
| workshops;         | recommended. See    | information transfers.    |
| equipment supply,  | Section 4.2.1.      |                           |
| commodities,       |                     | b\. A **Positive          |
| establishment of   | c\. An              | Determination** is        |
| links and          | Environmental       | recommended per 22 CFR    |
| networks; and;     | Assessment on the   | 216.2(d)(viii) and 22 CFR |
| information        | suite of actions    | 216.3 (a)(2)(iii), for    |
| documentation,     | planned is          | road improvement.         |
| analysis and       | recommended. See    | Specifically, a           |
| transfer.          | Sect. 4.2.1.        | **Programmatic (or        |
|                    |                     | sectoral) Environmental   |
| b\. Rehabilitation | d\. These           | Assessment (PEA)          |
| of roads in        | activities must     | approach** is             |
| southern Sudan     | follow established  | recommended, per 22 CFR   |
| under SIP and      | environmental       | 216.6(d).                 |
| WFP/GTZ programs,  | guidelines, or be   |                           |
| and associated     | subjected to a      | c\. Positive              |
| culverts, bridges, | screening process   | Determination, per 22 CFR |
| etc.               | to identify         | 216.2(d)(i) for river     |
|                    | appropriate adverse | basin development, (ii)   |
| c\. Rehabilitation | impact mitigation   | irrigation or water       |
| of dikes in North  | and monitoring      | management; and (iv)      |
| and South Bor, and | measures.           | drainage projects.        |
| associated water   |                     |                           |
| management         | e\. An appropriate  | d\. Negative              |
| infrastructure,    | screening process   | Determination with        |
| incl. pilot        | to be designed to   | Conditions, per 22 CFR    |
| drainage- and      | identify            | 216.3 (a)(2)(iii)         |
| irrigation works.  | appropriate adverse |                           |
|                    | impact mitigation   | e\. Negative              |
| d\. Rehabilitation | and monitoring      | Determination with        |
| and development of | measures.           | Conditions, per 22 CFR    |
| buildings and      |                     | 216.3 (a)(2)(iii)         |
| minor roads and    |                     |                           |
| other key          |                     |                           |
| infrastructure     |                     |                           |
| (telephone and     |                     |                           |
| power supply       |                     |                           |
| networks),         |                     |                           |
| building           |                     |                           |
| constructions and, |                     |                           |
| water and          |                     |                           |
| sanitation         |                     |                           |
| facilities for     |                     |                           |
| agribusiness       |                     |                           |
| training centers.  |                     |                           |
|                    |                     |                           |
| e\. Provision of a |                     |                           |
| subgrants, loan    |                     |                           |
| fund for           |                     |                           |
| microfinance       |                     |                           |
| institutions; and  |                     |                           |
| technical          |                     |                           |
| assistance and     |                     |                           |
| sub-grants for     |                     |                           |
| HIV/AIDS programs  |                     |                           |
+--------------------+---------------------+---------------------------+
| **IR 8.4:          | No potential for    | Categorical Exclusion, 22 |
| Transparent        | direct impact on    | CFR 216.2 (c)(2)(i),      |
| policymaking       | the environment.    | education, technical      |
| processes          |                     | assistance or training;   |
| encouraged.**      |                     | 216.2 (c)(2)(iii):        |
|                    |                     | analyses, studies,        |
| Technical          |                     | academic or research      |
| assistance,        |                     | workshops and meetings;   |
| training           |                     | 216.2 (c)(2)(v): document |
| workshops;         |                     | and information           |
| meetings, making   |                     | transfers; and            |
| policies,          |                     | 216.2(c)(2)(xiv), for     |
| regulations and    |                     | studies, projects or      |
| laws affecting     |                     | programs intended to      |
| ownership and      |                     | develop the capability of |
| utilization of     |                     | recipient countries and   |
| natural resources, |                     | organizations to engage   |
| agricultural       |                     | in development planning.  |
| production and     |                     |                           |
| marketing,         |                     |                           |
| enterprise         |                     |                           |
| creation and       |                     |                           |
| profitability, and |                     |                           |
| macroeconomic      |                     |                           |
| policy; funding    |                     |                           |
| and research and   |                     |                           |
| analysis in        |                     |                           |
| economic and       |                     |                           |
| natural resources  |                     |                           |
| policy.            |                     |                           |
+--------------------+---------------------+---------------------------+

TABLE 1: SUMMARY OF RECOMMENDED THRESHOLD DETEMINATIONS FOR SUDAN SO 7:
INCREASED USE OF HEALTH, WATER AND SANITATION SERVICES.

+-------------------------+----------------------+---------------------+
| **Key Elements of       | **Threshold          | **Impact Issues &   |
| Program/Activities**    | Determination &**    | Mitigation          |
|                         |                      | Conditions and/or   |
|                         | **22 CFR 216         | Proactive           |
|                         | Citation**           | Interventions**     |
+=========================+======================+=====================+
| **SO 7: Increased Use   |                      |                     |
| of Health, Water and    |                      |                     |
| Sanitation Services**   |                      |                     |
+-------------------------+----------------------+---------------------+
| **Intermediate Result   | Categorical          | No biophysical      |
| 7.1: Increased access   | Exclusion:           | interventions       |
| to high-impact          |                      | involved            |
| services.**             | 22 CFR 216.2         |                     |
|                         | (c)(2)(i),           | CE applies except   |
| Technical assistance,   | education, technical | to the extent that  |
| education and training  | assistance or        | activities might    |
| workshops, meetings,    | training; 216.2      | directly affect the |
| information             | (c)(2)(iii):         | environment (such   |
| documentation, analysis | analyses, studies,   | as construction of  |
| and transfer for        | academic or research | facilities, water   |
| equipment supply,       | workshops and        | supply systems,     |
| community-based health  | meetings; 216.2      | waste water         |
| care, child survival;   | (c)(2)(v): document  | treatment extent    |
| maternal and child      | and information      | designed to include |
| health care; improved   | transfer;            | activities, etc.)   |
| nutrition; and          |                      |                     |
| improvement drugs       | 216.2 (c)(2)(viii)   |                     |
| availability            | for programs         |                     |
|                         | involving nutrition, |                     |
|                         | health care or       |                     |
|                         | population and       |                     |
|                         | family planning      |                     |
|                         | services; and        |                     |
|                         | 216.2(c)(xiv)        |                     |
|                         | programs intended to |                     |
|                         | develop capability   |                     |
|                         | of recipient         |                     |
|                         | countries to engage  |                     |
|                         | in development       |                     |
|                         | planning.            |                     |
+-------------------------+----------------------+---------------------+
| **Intermediate Result   | Negative             | For activities that |
| 7.1:** cont'd.          | Determination with   | will increase       |
|                         |                      | access to quality   |
| To the extent they      | Conditions           | immunization        |
| involve health care     |                      | services, the       |
| waste management:       | 22 CFR 216.3         | program must make   |
| vaccinations;           | (a)(2)(iii)          | reasonable efforts  |
| community-based health  |                      | to assure           |
| care, child survival;   |                      | development and     |
| maternal and child      |                      | implementation of   |
| health care             |                      | an adequate medical |
|                         |                      | waste management    |
|                         |                      | program. Consult    |
|                         |                      | EGSSA               |
|                         |                      | ([www.encapafr      |
|                         |                      | ica.org](http://www |
|                         |                      | .encapafrica.org/)) |
|                         |                      | and utilize the     |
|                         |                      | Minimal Program     |
|                         |                      | Checklist (Annex    |
|                         |                      | A).                 |
|                         |                      |                     |
|                         |                      | (Further details    |
|                         |                      | re: medical waste   |
|                         |                      | management          |
|                         |                      | conditions are      |
|                         |                      | given following     |
|                         |                      | this table.)        |
+-------------------------+----------------------+---------------------+
| **Intermediate Result   | Negative             | Team responsible    |
| 7.1:** cont'd.          | Determination with   | for the             |
|                         |                      | construction and    |
| Construction of primary | Conditions           | related activities  |
| health centre units     |                      | is expected to      |
| with FFW                | 22 CFR 216.3         | apply the Africa    |
|                         | (a)(2)(iii)          | Bureau              |
|                         |                      | *Environmental      |
|                         |                      | Guidelines for      |
|                         |                      | Small-scale         |
|                         |                      | Activities in       |
|                         |                      | Africa (EGSSAA).*   |
|                         |                      | The URL is:         |
|                         |                      | (<http://www.enc    |
|                         |                      | apafrica.org/SmallS |
|                         |                      | caleGuidelines.htm> |
|                         |                      |                     |
|                         |                      | (Further details    |
|                         |                      | re: small scale     |
|                         |                      | construction        |
|                         |                      | conditions are      |
|                         |                      | given following     |
|                         |                      | this table.)        |
+-------------------------+----------------------+---------------------+
| **IR 7.1 cont'd.**      | Negative             | See conditions      |
|                         | Determination with   | under IR 7.3, for   |
| Malaria control (using  |                      | increased use of    |
| anti-malarial           | Conditions           | ITNs                |
| medications and         |                      |                     |
| increased use of        | 22 CFR 216.3         |                     |
| insecticide-treated     | (a)(2)(iii)          |                     |
| nets).                  |                      |                     |
+-------------------------+----------------------+---------------------+
| **IR 7.2: Increased     | Categorical          | No biophysical      |
| Sudanese capacity,      | Exclusion:           | interventions       |
| particularly women's,   |                      | involved            |
| to deliver and manage   | 22 CFR 216.2         |                     |
| health services.**      | (c)(2)(i),           | CE applies except   |
|                         | education, technical | to the extent that  |
| Providing technical     | assistance or        | activities might    |
| assistance; education   | training; 216.2      | directly affect the |
| and training workshops  | (c)(2)(iii):         | environment (such   |
| for health workers;     | analyses, studies,   | as construction of  |
| information analysis,   | academic or research | facilities, water   |
| documentation and       | workshops and        | supply systems,     |
| transfer for            | meetings; 216.2      | waste water         |
| distribution of         | (c)(2)(v): document  | treatment extent    |
| training materials,     | and information      | designed to include |
| development of          | transfer;            | activities, etc.)   |
| cost-sharing policy     |                      |                     |
| modules, acceleration   | 216.2 (c)(2)(viii)   |                     |
| of community training,  | for programs         |                     |
| establishment of basic  | involving nutrition, |                     |
| public health systems;  | health care or       |                     |
| and formulation of      | population and       |                     |
| health policies (e.g.   | family planning      |                     |
| treatment and control   | services; and        |                     |
| of malaria and          | 216.2(c)(xiv)        |                     |
| tuberculosis);          | programs intended to |                     |
|                         | develop capability   |                     |
|                         | of recipient         |                     |
|                         | countries to engage  |                     |
|                         | in development       |                     |
|                         | planning.            |                     |
+-------------------------+----------------------+---------------------+
| **IR 7.2, cont'd.**     | Negative             | Must be subjected   |
|                         | Determination with   | to a screening      |
| Providing sub-grants    |                      | process to identify |
|                         | Conditions- 22 CFR   | appropriate adverse |
|                         | 216.3 (a)(2)(iii)    | impact mitigation   |
|                         |                      | and monitoring      |
|                         |                      | measures.           |
|                         |                      |                     |
|                         |                      | (Further details    |
|                         |                      | regarding the       |
|                         |                      | environmental       |
|                         |                      | screening process   |
|                         |                      | are given following |
|                         |                      | this table.)        |
+-------------------------+----------------------+---------------------+
| **IR 7.2, cont'd.**     | Negative             | Team responsible    |
|                         | Determination with   | for the             |
| Construction of or      |                      | construction and    |
| rehabilitation of       | Conditions- 22 CFR   | related activities  |
| community health worker | 216.3 (a)(2)(iii),   | is expected to      |
| training institutes     | as these will have a | consult the Africa  |
|                         | direct effect on the | Bureau              |
|                         | environment          | *Environmental      |
|                         |                      | Guidelines for      |
|                         |                      | Small-scale         |
|                         |                      | Activities in       |
|                         |                      | Africa (EGSSAA).*   |
|                         |                      | The URL is:         |
|                         |                      | (<http://www.enc    |
|                         |                      | apafrica.org/SmallS |
|                         |                      | caleGuidelines.htm> |
|                         |                      |                     |
|                         |                      | (Further details    |
|                         |                      | regarding small     |
|                         |                      | scale construction  |
|                         |                      | conditions are      |
|                         |                      | given following     |
|                         |                      | this table.)        |
+-------------------------+----------------------+---------------------+
| **IR 7.3: Increased     | Categorical          | No biophysical      |
| demand for health       | Exclusion:           | interventions       |
| services and            |                      | involved            |
| practices.**            | 22 CFR 216.2         |                     |
|                         | (c)(2)(i),           | .                   |
| Technical assistance;   | education, technical |                     |
| education and training  | assistance or        |                     |
| workshops; development  | training; 216.2      |                     |
| of radio communication  | (c)(2)(iii):         |                     |
| programs; meetings;     | analyses, studies,   |                     |
| and, information        | academic or research |                     |
| documentation analysis  | workshops and        |                     |
| and transfer for        | meetings; 216.2      |                     |
| dissemination of health | (c)(2)(v): document  |                     |
| information, support    | and information      |                     |
| for primary health care | transfer; and        |                     |
| centers.                |                      |                     |
|                         | 216.2 (c)(2)(viii)   |                     |
|                         | for programs         |                     |
|                         | involving nutrition, |                     |
|                         | health care or       |                     |
|                         | population and       |                     |
|                         | family planning      |                     |
|                         | services.            |                     |
+-------------------------+----------------------+---------------------+
| **IR 7.3, cont'd.**     | Negative             | Must be subjected   |
|                         | Determination with   | to a screening      |
| Providing sub-grants    |                      | process to identify |
|                         | Conditions, 22 CFR   | appropriate adverse |
|                         | 216.3 (a)(2)(iii)    | impact mitigation   |
|                         |                      | and monitoring      |
|                         |                      | measures.           |
|                         |                      |                     |
|                         |                      | (Further details    |
|                         |                      | regarding the       |
|                         |                      | environmental       |
|                         |                      | screening process   |
|                         |                      | are given following |
|                         |                      | this table.)        |
+-------------------------+----------------------+---------------------+
| **IR 7.3 cont'd.**      | Negative             | If provision of     |
|                         | Determination with   | supplies will       |
| Malaria control,        |                      | include insecticide |
| through increased use   | Conditions, 22 CFR   | treated bednets     |
| of insecticide-treated  | 216.3 (a)(2)(iii)    | (ITNs), the         |
| nets.                   |                      | USAID/SFO Health    |
|                         | **Deferred:**        | Team and partner    |
| Activities to increase  | Treatment or         | organizations will  |
| access and use of       | retreatment of nets  | be required to use  |
| long-lasting            |                      | reliable brands of  |
| insecticide treated     |                      | long-lasting        |
| bednets (LLITN).        |                      | treated nets and    |
|                         |                      | adhere to other the |
| Insecticidal treatment  |                      | stipulations made   |
| or re-treatment of ITNs |                      | in the USAID Africa |
|                         |                      | Bureau              |
|                         |                      | [Programmatic       |
|                         |                      | Environmental       |
|                         |                      | Assessment for      |
|                         |                      | Insecticide-Treated |
|                         |                      | Materials in USAID  |
|                         |                      | Activities in       |
|                         |                      | Sub-Saharan         |
|                         |                      | Africa](htt         |
|                         |                      | p://www.afr-sd.org/ |
|                         |                      | documents/iee/docs/ |
|                         |                      | 32AFR2_ITM_PEA.doc) |
|                         |                      | (ITM PEA).          |
|                         |                      |                     |
|                         |                      | If a need for net   |
|                         |                      | treatment or        |
|                         |                      | retreatment arises, |
|                         |                      | USAID/SFO will      |
|                         |                      | draft and gain      |
|                         |                      | approval for a      |
|                         |                      | "Pesticide          |
|                         |                      | Evaluation Report   |
|                         |                      | and Safer Use       |
|                         |                      | Action Plan"        |
|                         |                      | (PERSUAP) for the   |
|                         |                      | ITN program. If any |
|                         |                      | vector control      |
|                         |                      | measures involving  |
|                         |                      | pesticides are      |
|                         |                      | recommended, these  |
|                         |                      | pesticides must be  |
|                         |                      | approved by the     |
|                         |                      | USEPA and the       |
|                         |                      | GFDRC, and a        |
|                         |                      | PERSUAP covering    |
|                         |                      | safe use of these   |
|                         |                      | pesticides          |
|                         |                      | prepared.           |
+-------------------------+----------------------+---------------------+
| **IR 7.3 cont'd**.      | Negative             | Mitigating Actions: |
|                         | Determination with   |                     |
| Establishment of        |                      | For activities that |
| HIV/AIDS voluntary      | Conditions, 22 CFR   | will involve        |
| counseling and testing  | 216.3 (a)(2)(iii)    | expanded provision  |
| (VCT)                   |                      | of the VCT          |
|                         |                      | services, the       |
|                         |                      | development and     |
|                         |                      | implementation of a |
|                         |                      | medical waste       |
|                         |                      | management program  |
|                         |                      | is advised. Consult |
|                         |                      | EGSSA               |
|                         |                      | ([www.encapafr      |
|                         |                      | ica.org](http://www |
|                         |                      | .encapafrica.org/)) |
|                         |                      | and utilize the     |
|                         |                      | Minimal Program     |
|                         |                      | Checklist (Annex    |
|                         |                      | A).                 |
|                         |                      |                     |
|                         |                      | (Further details    |
|                         |                      | re: medical waste   |
|                         |                      | management          |
|                         |                      | conditions are      |
|                         |                      | given following     |
|                         |                      | this table.)        |
+-------------------------+----------------------+---------------------+
| **IR 7.4: Improved      | Categorical          | No biophysical      |
| access to safe water    | Exclusion:           | interventions       |
| and sanitation.**       |                      | involved, per se.   |
|                         | 22 CFR 216.2         |                     |
| Technical assistance    | (c)(2)(i),           |                     |
| for water and           | education, technical |                     |
| sanitation maintenance; | assistance or        |                     |
| education and training  | training; 216.2      |                     |
| workshops for public    | (c)(2)(iii):         |                     |
| health and hygiene      | analyses, studies,   |                     |
| promotion and hand pump | academic or research |                     |
| maintenance; meetings;  | workshops and        |                     |
| dissemination of health | meetings; 216.2      |                     |
| information, and        | (c)(2)(v): document  |                     |
| community               | and information      |                     |
| sensitization.          | transfer; and        |                     |
|                         |                      |                     |
|                         | 216.2 (c)(2)(viii)   |                     |
|                         | for programs         |                     |
|                         | involving nutrition, |                     |
|                         | health care or       |                     |
|                         | population and       |                     |
|                         | family planning      |                     |
|                         | services.            |                     |
+-------------------------+----------------------+---------------------+
| **IR 7.4 cont'd.**      | Negative             | Must be subjected   |
|                         | Determination with   | to a screening      |
| Providing grants, and   |                      | process to identify |
| food for work programs  | Conditions, 22 CFR   | appropriate adverse |
|                         | 216.3 (a)(2)(iii)    | impact mitigation   |
|                         |                      | and monitoring      |
|                         | .                    | measures            |
+-------------------------+----------------------+---------------------+
| **IR 7.4 cont'd.**      | Negative             | Will have a direct  |
|                         | Determination with   | effect on the       |
| **Small-scale           |                      | environment.        |
| construction, Water &   | Conditions, 22 CFR   | Mitigation: The     |
| Sanitation              | 216.3 (a)(2)(iii)    | team responsible    |
| infrastructure:**       |                      | for the             |
| Drilling new boreholes  | .                    | construction and    |
| and rehabilitation of   |                      | related activities  |
| old boreholes;          |                      | is expected to      |
| development of          |                      | consult and apply   |
| traditional hand-dug    |                      | the best practices  |
| shallow wells;          |                      | and principles in   |
| protection of water     |                      | the Africa Bureau   |
| catchments areas        |                      | *Environmental      |
| (forests); and,         |                      | Guidelines for      |
| construction of new     |                      | Small-scale         |
| latrines and            |                      | Activities in       |
| rehabilitation of old   |                      | Africa (EGSSAA).*   |
| latrines                |                      | The URL is:         |
|                         |                      | (<http://www.enc    |
|                         |                      | apafrica.org/SmallS |
|                         |                      | caleGuidelines.htm> |
|                         |                      |                     |
|                         |                      | (Further details    |
|                         |                      | regarding small     |
|                         |                      | scale construction  |
|                         |                      | and water and       |
|                         |                      | sanitation          |
|                         |                      | conditions are      |
|                         |                      | given following     |
|                         |                      | this table.)        |
+-------------------------+----------------------+---------------------+

### Style Tips for IEE Writers[^3]

Last Updated: April 28, 2004

Simple, clear writing helps improve the quality of analysis, and speeds
the review and approval of environmental reviews. The Africa Bureau
Environmental Officer therefore asks that you follow these style tips
for writers preparing IEEs and other environmental documentation that
covers Africa Bureau activities:

-   In general, IEEs and/or Requests for Categorical Exclusion should be
    prepared at the Strategic Objective or otherwise most inclusive
    level possible (e.g., IR). The basic organization of each IEE should
    be as given in the attached templates.

```{=html}
<!-- -->
```
-   The key organizing principle for the entire document should be a
    listing of the activities and/or intermediate results covered by the
    SO. Each section, to the extent relevant (mainly Section 1, 3, 4,
    and the summary), should refer to the IRs and activities. Use this
    organization scheme in 1) describing the activities; 2) analyzing
    the potential environmental impact of each activity, 3) recommending
    threshold decisions for each IR/activity, and 4) proposing
    mitigation measures for each IR's/activity's potential impacts.

-   Keep writing simple & clear. Use short sentences. ~~The passive
    voice should be avoided~~...Avoid the passive voice.

-   For amendments, include the following information in the [first
    paragraph]{.underline} of the Summary:

> \-- Identify the IEE being amended;
>
> \-- state the reason for the amendment;
>
> \-- summarize the differences between the amendment & the original in
> terms of activities & environmental determinations.
>
> \-- when some parts of the determinations in the previous IEE are
> being carried forward without amendment, be sure to summarize what
> those parts indicated, and particularly any conditions which must
> still be followed.

-   Be brief. Tell what the activity involves, what impact it may have,
    & what you propose be done about that. If supporting documents are
    needed, attach them &/or refer to them, but there is no need to copy
    huge passages into the IEE.

```{=html}
<!-- -->
```
-   Use bullets, tables & other formatting devices to best organize
    information & to reduce verbiage. For example, a table is most often
    the best way to present the findings in Section 4, Recommended
    Threshold Decisions & Mitigation Actions.

```{=html}
<!-- -->
```
-   Limit the Summary of Findings section on the face sheets to one page
    if at all possible, two pages at a maximum. The Summary of Findings
    must include all Threshold Determinations and applicable Conditions,
    if any. The Section 5 Summary of Findings may be longer.

-   Refer to other IEEs as models when drafting an IEE...but do so
    carefully. Look for similar IEEs when harvesting technical
    suggestions, but take care to also look for good style examples that
    meet the above recommendations.

-   Send the IEE to the REO for review and editing before submitting to
    the Africa Bureau BEO in Washington for clearance. See Figure 3.3 in
    the [EPTM](http://www.encapafrica.org/EPTM.htm) for Africa, IEE
    Submission Process.

### USAID Biosafety "First Review, Proposal and Reporting" Requirements

The draft ADS chapter 211 "Biosafety Procedures for Genetic Engineering
Research" is not yet widely available. Summarized here is ADS Section
211.3.1, regarding mandatory procedures for the transfer to, testing of,
or use outside of contained facilities in developing countries of all GE
products (e.g., plants, microorganisms, livestock vaccines, animals, or
insects). Laboratory research involving GE products in both the U.S. and
developing countries is covered under current USAID provisions
referencing National Institutes of Health (NIH) guidelines. The
mandatory procedures apply to:

-   All USAID-funded transfers of GE products from the U.S. to
    developing countries for testing or use outside a contained
    facility;

-   The testing of GE products in the developing country in which they
    were developed; and

-   The transfer of GE products from one developing country to another.

USAID-funded GE-product development and implementation partners are
prohibited from transferring or releasing GE products prior to obtaining
the required written approval from USAID, as detailed in ADS 211.3.1. In
addition, applicable national laws (e.g., biosafety, shipping/packaging,
sanitary, or phytosanitary standards) must be adhered to.

**Regarding the first review of initial transfer, testing, or use** (ADS
211.3.1), the responsible actors (grantee /contractor, etc.), shall
follow the USAID biosafety review process:

**Proposal.** The implementing parties must: provide a proposal
containing required information on the proposed transfer, testing, or
use that the grantee/contractor. The goes to the USAID Cognizant
Technical Officer (CTO) or Strategic Objective (SO) Team, before
supporting GE products for testing or use. , the grantee/contractor must
submit a proposal for approval by USAID.

**External Review for USAID**. This proposal will be forwarded by the
CTO to the USAID Biosafety Officer for external review. The Biosafety
Officer will arrange for an external biosafety review of the proposal.

**Certification of Host Country Approval**. Documentation must be
provided demonstrating approval by the host country authorities of the
proposed transfer, testing, or use that the grantee/contractor must
provide to the USAID CTO or SO Team. If the country has a national
biosafety authority or focal point (e.g., as required by Parties to the
Cartagena Protocol on Biosafety), the letter of approval must come from
this designated authority.

These procedures in this section apply to the first transfer, testing,
or use of a particular GE product under a particular set of conditions.
Streamlined procedures for the subsequent transfer, testing, or use of
the same GE product under the same set of conditions are stated in
211.3.2.

The grantee/contractor or host country collaborator must submit to the
USAID CTO or SO Team a letter or letters from the relevant authority in
the host country approving the transfer and/or release of the GE
product, including any specific conditions imposed by the host country.

USAID will not grant approval of the transfer or testing in the absence
of this letter or letters of approval.

# February 22, 2002

# 

### USAID/AFR guidance: preparing PERSUAPs for pesticide programs in Africa

#### [Overview of review requirements]{.underline}

All USAID activities are subject to evaluation via, at minimum, an
Initial Environmental Examination (IEE). And because of risk concerns
presented by pesticides, the USAID environmental regulations require
that at least the 12 factors outlined in the Pesticide Procedures
described in 22 CFR 216.3 (b)(1)(i) (a through l) be addressed in the
IEE for any program that includes assistance for the procurement or use
of pesticides. The Africa Bureau asks that these factors be examined in
a particular type of document, termed a "Pesticide Evaluation Report and
Safer Use Action Plan" (PERSUAP), which is submitted as an attachment to
the IEE. (Note: the IEE itself can be very brief, with the analytical
work contained in the attached PERSUAP.) The PERSUAP focuses on the
particular circumstances of the program in question, the risk management
choices available, and how a risk management plan would be implemented
in the field. Further details about what to include in a PERSUAP are
given below.

Why is a local-level assessment such as a PERSUAP needed for USAID
pesticide programs? To help in understanding the utility, consider the
U.S. system for promoting pesticide safety. When the USEPA registers
pesticides for use in the United States, it specifies the manner in
which the product can be "safely" used (i.e., with an acceptably small
risk), including safety equipment needed when applying the pesticide,
how to apply it, the allowed uses, etc. But the context in which EPA
makes these registration decisions is important to note. An extensive
system of capabilities and resources exist in this country that help
give EPA confidence these specifications will be followed and the
product will be used appropriately. These include a 97% literacy rate
meaning most of the population can read labels; close control by EPA
over the content of the label; training requirements and programs for
those pesticide products that require applicator certification; worker
protection requirements; occupational safety regulations; and relatively
effective federal, state and local enforcement mechanisms. In allowing
the use of certain pesticides in its African programs, USAID cannot rely
on the same societal capabilities and resources that the USEPA does to
assure appropriate use of the product. The preparation of a PERSUAP
gives a program manager the opportunity to consider practical actions by
which to reduce the risks of using pesticide products in a program,
taking into consideration the context in which the products will be
used, the particular elements of the program, and the different
capacities of the partners involved.

#### [Who prepares a PERSUAP?]{.underline}

Program managers are generally responsible for assuring that
environmental review requirements for their programs are met, including
PERSUAPs. As for all environmental reviews, guidance and assistance for
PERSUAPs is available from the the appropriate Mission Environmental
Officer (MEO), Regional Environmental Officer (REO), the Africa Bureau
Environmental Officer (BEO), or the BEO/DCHA if Title II (PL 480) funds
are involved.. Considerable reference materials, as well as examples of
other PERSUAPs, are available through these contacts, or directly from
the Africa Bureau's ENCAP program website, www.encapafrica.org.

#### [Components of an activity-level PERSUAP]{.underline}

A PERSUAP basically consists of two parts, a "PER" and a "SUAP." The
Pesticide Evaluation Report (PER) section addresses the 12 informational
elements required in the Agency's Pesticide Procedures. The Safer Use
Action Plan (SUAP) puts the conclusions reached in the PER into a plan
of action, including assignment of responsibility to appropriate parties
connected with the pesticide program.

Below are three annexes which further elaborate the content needed in a
PERSUAP:

*1. Detailed guidance for developing a Pesticide Evaluation Report:*
provides detailed guidance on the information that should be provided in
the Pesticide Evaluation Report, following the 12 informational elements
required by the Pesticide Procedures section of USAID's environmental
regulations.

2\. *Representative Elements for a Safer Use Action Plan*: Describes the
elements needed in a plan that takes action to assure issues resolved in
the Pesticide Evaluation Report are resolved in the implementation of
the development program being reviewed.

***3. "A Practical Guide To Reducing Pesticide Risks in Development
Projects":*** This brief guide was prepared by staff of the UNFAO, and
provides a useful list of problems to watch for as well as practical
responses. USAID programs using pesticides would do well to use this
guide as a checklist to look for problems and as a source of inspiration
for ways to deal with those problems.

*Annex 1: Detailed guidance for the development of a Pesticide
Evaluation Report*

+-------------------------+--------------------------------------------+
| USAID "Pesticide        | Specific Guidance for Pesticide PERSUAP    |
| Procedures" Element and |                                            |
| Description             |                                            |
|                         |                                            |
| (from USAID Pest        |                                            |
| Management Guidelines,  |                                            |
| 1991)                   |                                            |
+-------------------------+--------------------------------------------+
| a.  **USEPA             | In the PERSUAP: *Identify the registration |
|     registration status | status in the U.S. and in the host         |
|     of the proposed     | country. Identify the formulated pesticide |
|     pesticide**.        | product to be used*.                       |
|     Pesticides are      |                                            |
|     registered in the   | USAID is effectively limited to using      |
|     U.S. by active      | pesticide active ingredients registered in |
|     ingredient and by   | the U.S. by the U.S. Environmental         |
|     formulation.        | Protection Agency for the same or similar  |
|     "Registration       | uses. Other pesticides not registered in   |
|     status"             | the U.S. may be authorized, but only if    |
|     possibilities of    | the USAID program can show that no         |
|     the active          | alternatives are not available, as         |
|     ingredients and the | required under USAID Pest Management       |
|     formulated products | Guidelines for the use on non-U.S.         |
|     include registered, | registered pesticides. Host country        |
|     never registered,   | pesticide registration procedures must     |
|     and cancelled.      | also be identified and followed.           |
+-------------------------+--------------------------------------------+
| b.  **Basis for         | In the PERSUAP: *Explain the basis for     |
|     selection of the    | selection of the pesticide product to be   |
|     pesticide**: This   | used, including active ingredient and      |
|     refers to the       | formulation.*                              |
|     economic and        |                                            |
|     environmental       | Pesticide product selection may be driven  |
|     rationale for       | by a number of factors, including          |
|     choosing a          | efficacy, price, availability, safety,     |
|     particular          | etc. All things being equal, a program     |
|     pesticide. In       | should choose the pesticide active         |
|     general, the least  | ingredient and formulation that presents   |
|     toxic pesticide     | the least overall risk.                    |
|     that is effective   |                                            |
|     is selected.        | Formulation is a key determinant of        |
|                         | toxicity, and should be considered in      |
|                         | selecting a particular pesticide product.  |
|                         | Formulation can also have an impact on     |
|                         | exposure; for example, solid formulations  |
|                         | can eliminate the potential for poisoning  |
|                         | through accidental exposure to             |
|                         | concentrated liquid product.               |
|                         |                                            |
|                         | Packaging can have a significant impact on |
|                         | exposure potential. Large containers       |
|                         | necessarily introduce hazardous product    |
|                         | transfer steps, as well as the possibility |
|                         | that the product will end up in a smaller, |
|                         | poorly labeled container. Smaller          |
|                         | containers are generally better for use in |
|                         | USAID programs.                            |
+-------------------------+--------------------------------------------+
| c.  **Extent to which   | In the PERSUAP: *Describe the extent to    |
|     the proposed        | which the proposed product(s) is/are or    |
|     pesticide use is,   | could be a part of an IPM program.         |
|     or could be, part   | Describe the connection between the USAID  |
|     of an IPM           | activity and regional, national and local  |
|     program**: USAID    | control programs (as appropriate).*        |
|     policy promotes the |                                            |
|     development and use | Integrated pest management, and its public |
|     of integrated       | health counterpart, integrated vector      |
|     approaches to pest  | management, is USAID policy because it is  |
|     management whenever | the most effective, economical, and safest |
|     possible. This      | approach to pest control. "Integrated pest |
|     section discusses   | management attempts to control pests in an |
|     the extent to which | economically and environmentally rational  |
|     the proposed        | manner; it emphasizes non-chemical tactics |
|     pesticide use is    | which cause minimal disruption to the      |
|     incorporated into   | ecosystem."[^4] USAID programs should      |
|     an overall IPM      | assure that the choice of pesticides was   |
|     strategy.           | made after consideration of other pest     |
|                         | management options available, and that     |
|                         | this is the most effective and             |
|                         | environmentally sound option available.    |
+-------------------------+--------------------------------------------+
| d.  **Proposed method   | In the PERSUAP: *As stated, describe in    |
|     or methods of       | detail how the pesticide is to be applied  |
|     application,        | and the measures to be taken to ensure its |
|     including the       | safe use.*                                 |
|     availability of     |                                            |
|     application and     |                                            |
|     safety equipment**: |                                            |
|     This section        |                                            |
|     examines in detail  |                                            |
|     how the pesticide   |                                            |
|     is to be applied    |                                            |
|     and the measures to |                                            |
|     be taken to ensure  |                                            |
|     its safe use.       |                                            |
+-------------------------+--------------------------------------------+
| e.  **Any acute and     | In the PERSUAP: *Describe measures the     |
|     long-term           | program will take to reduce the potential  |
|     toxicological       | for exposing humans or nontarget organisms |
|     hazards, either     | to selected pesticides. Also describe      |
|     human or            | monitoring measures that will allow the    |
|     environmental,      | program to identify problems with users    |
|     associated with the | applying other pesticides.*                |
|     proposed use, and   |                                            |
|     measures available  | **It is recommended that this be the key   |
|     to minimize such    | section of the PERSUAP, in which the       |
|     hazards**: This     | majority, or perhaps all, of the planned   |
|     section of the IEE  | mitigation measures are described.** To    |
|     examines the acute  | address this element, the PERSUAP should   |
|     and chronic         | summarize the toxicity to humans and other |
|     toxicological data  | non-target organisms of the pesticide      |
|     associated with the | products chosen for the program in         |
|     proposed pesticide. | question, the potential exposure           |
|     In addition to      | opportunities presented by those products, |
|     hazards, this       | and the risk reduction actions the program |
|     section of the IEE  | will take to minimize such exposure        |
|     also discusses      | opportunities. The risk reduction actions  |
|     measures designed   | should be described in sufficient detail   |
|     to mitigate any     | to show that they are indeed workable      |
|     identified          | solutions. If protective clothing is       |
|     toxicological       | recommended, for example, assurance should |
|     hazards, such as    | be provided that a sustainable source of   |
|     training of         | such protective clothing has been          |
|     applicators, use of | identified, a schedule for its             |
|     protective          | replacement, training in its use, etc.     |
|     clothing, and       |                                            |
|     proper storage.     |                                            |
+-------------------------+--------------------------------------------+
| f.  **Effectiveness of  | In the PERSUAP: *Explain what              |
|     the requested       | recommendations or evidence suggests that  |
|     pesticide for the   | the ITM products proposed are effective in |
|     proposed use**:     | the program area.*                         |
|     This section of the |                                            |
|     PERSUAP requires    |                                            |
|     information similar |                                            |
|     to that provided in |                                            |
|     item b, but more    |                                            |
|     specific to the     |                                            |
|     actual conditions   |                                            |
|     of application.     |                                            |
|     This section also   |                                            |
|     considers the       |                                            |
|     potential for the   |                                            |
|     development of pest |                                            |
|     resistance to the   |                                            |
|     proposed            |                                            |
|     insecticide.        |                                            |
+-------------------------+--------------------------------------------+
| g.  **Compatibility of  | In the PERSUAP: *Describe efforts that are |
|     the proposed        | being made to minimize environmental       |
|     pesticide use with  | exposure to pesticide products.*           |
|     target and          |                                            |
|     non-target          | This section should address the toxicity   |
|     ecosystems**: This  | of the products and the environmental risk |
|     section examines    | mitigation measures that the program will  |
|     the potential       | take. The key options for environmental    |
|     effect of the       | risk mitigation are product choice and     |
|     pesticide on        | exposure reduction. In this section,       |
|     organisms other     | therefore, describe the relative           |
|     than the target     | environmental risk of the product chosen   |
|     pest (for example,  | versus the other options. Also describe    |
|     the effect on bee   | efforts the program will make to reduce    |
|     colonies kept in    | exposure of the environment, through       |
|     the area).          | choice of pesticide product and packaging, |
|     Non-target species  | preparation of educational materials,      |
|     of concern also     | training, etc.                             |
|     include birds and   |                                            |
|     fish. The potential | This question might also be covered in     |
|     for negative impact | response to question (e), and if so,       |
|     on non-target       | simply reference that section without      |
|     species should be   | repeating it.                              |
|     assessed and        |                                            |
|     appropriate steps   |                                            |
|     should be           |                                            |
|     identified to       |                                            |
|     mitigate adverse    |                                            |
|     impacts.            |                                            |
+-------------------------+--------------------------------------------+
| h.  **Conditions under  | In the PERSUAP: *Describe the              |
|     which the pesticide | environmental conditions under which the   |
|     is to be used,      | pesticide is to be used, identifying any   |
|     including climate,  | environmental factors that might be        |
|     flora, fauna,       | particularly sensitive or subject to       |
|     geography,          | contamination from re-treatment            |
|     hydrology, and      | operations.*                               |
|     soils**: This       |                                            |
|     section examines    | This item refers to particular             |
|     issues such as the  | environmental factors that might           |
|     potential for       | accentuate the effects of exposure to      |
|     contamination of    | pesticides, and the potential need for     |
|     surface and         | measures to reduce those risks. Examples   |
|     groundwater         | of special conditions that need to be      |
|     sources.            | noted here include sensitive ecosystems in |
|                         | the project area and superficial           |
|                         | groundwater tables.                        |
+-------------------------+--------------------------------------------+
| i.  **Availability of   | In the PERSUAP*: Describe other pest       |
|     other pesticides or | management options being pursued in the    |
|     non-chemical        | geographic area of the activity, either as |
|     control methods**:  | part of the USAID activity or otherwise,   |
|     This section        | and explain why this particular vector     |
|     identifies other    | control method was chosen over other       |
|     options for control | available options.*                        |
|     of pests and their  |                                            |
|     relative advantages |                                            |
|     and disadvantages.  |                                            |
+-------------------------+--------------------------------------------+
| j.  **Host country's    | In the PERSUAP: *Summarize the host        |
|     ability to regulate | country's capacity and structure for the   |
|     or control the      | regulation of public health and            |
|     distribution,       | agricultural pesticides. Identify the      |
|     storage, use, and   | approval/registration status of the        |
|     disposal of the     | pesticide product in the host country.*    |
|     requested           |                                            |
|     pesticide**: This   | The host country's capacity and structure  |
|     section examines    | for the regulation of public health and    |
|     the host country's  | agricultural pesticides should be          |
|     existing            | summarized. A critical issue for a         |
|     infrastructure and  | pesticide activity supported by the Agency |
|     human resources for | is the extent to which the host country's  |
|     managing the use of | regulatory oversight will help to control  |
|     the proposed        | distribution, storage, use and disposal of |
|     pesticide. If the   | the pesticide products in question. USAID  |
|     host country's      | activities should always be in compliance  |
|     ability to regulate | with local environmental and public laws   |
|     pesticides is       | and regulations, but that is not           |
|     inadequate, the     | necessarily enough. If host country        |
|     proposed action     | regulatory systems and institutions are    |
|     could result in     | not sufficient to give a reasonable        |
|     greater harm to the | expectation that environmentally sound     |
|     environment.        | practices will be enforced, USAID still    |
|                         | bears responsibility for assuring          |
|                         | environmental protection at each of these  |
|                         | steps in the pesticide life cycle.         |
|                         |                                            |
|                         | Government oversight over pesticides is    |
|                         | important for controlling the quality of   |
|                         | products as well as their                  |
|                         | environmentally-sound use and disposal.    |
|                         | USAID programs of substantial size should  |
|                         | generally include an element of            |
|                         | capacity-building work with host country   |
|                         | institutions that govern public health     |
|                         | pesticide use. These measures should be    |
|                         | identified in this chapter of the PERSUAP. |
+-------------------------+--------------------------------------------+
| k.  **Provision for     | In the PERSUAP: *Describe the provisions   |
|     training of users   | made to train and educate those who will   |
|     and applicators**:  | be using the pesticides.*                  |
|     USAID recognizes    |                                            |
|     that safety         |                                            |
|     training is an      |                                            |
|     essential component |                                            |
|     in programs         |                                            |
|     involving the use   |                                            |
|     of pesticides. The  |                                            |
|     need for thorough   |                                            |
|     training is         |                                            |
|     particularly acute  |                                            |
|     in developing       |                                            |
|     countries, where    |                                            |
|     the level of        |                                            |
|     education of        |                                            |
|     applicators may     |                                            |
|     typically be lower  |                                            |
|     than in developed   |                                            |
|     countries.          |                                            |
+-------------------------+--------------------------------------------+
| l.  **Provision made    | In the PERSUAP: *Describe monitoring and   |
|     for monitoring the  | evaluation programs for pesticide use      |
|     use and             | activities, and the health and             |
|     effectiveness of    | environmental safety-related information   |
|     this pesticide**:   | that is collected via this M and E         |
|     Evaluating the      | capacity.*                                 |
|     risks and benefits  |                                            |
|     of pesticide use    | Monitoring programs should actively        |
|     should be an        | investigate, to the extent possible, the   |
|     ongoing, dynamic    | following issues:                          |
|     process.            |                                            |
|                         | -   Effectiveness of Information,          |
|                         |     Education and Communication materials  |
|                         |     and activities in promoting safe       |
|                         |     handling, use and disposal of          |
|                         |     pesticide products.                    |
|                         |                                            |
|                         | -   Adverse health and environmental       |
|                         |     effects and the frequency and severity |
|                         |     with which they occur.                 |
|                         |                                            |
|                         | -   Quality control of pesticide products. |
|                         |                                            |
|                         | -   Effectiveness of the chosen products   |
|                         |     and their alternatives, including      |
|                         |     whether or not resistance is           |
|                         |     developing.                            |
|                         |                                            |
|                         | -   Safe and effective pesticide use and   |
|                         |     handling practices by program staff    |
|                         |     and end users.                         |
+-------------------------+--------------------------------------------+

# 

#### *Annex 1: Representative Elements for Pesticide Safer Use Action Plan*

A pesticide safe use action plan should:

-   **Be programmatically linked to national pesticide registration and
    pest management programs**

-   **Ensure formal national registration of pesticides**

    -   Establish pesticide quality standards and control procedures

    -   Provide for enforcement

    -   Require good packaging and clear and adequate labeling

-   **Define and assure safe use practices**

    -   Identify pesticides appropriate for use, selecting the least
        toxic insecticides and formulations possible, and considering
        non-pesticide alternatives.

    -   Define appropriate methods of pesticide handling, storage,
        transport, use and disposal.

-   Assure accessibility of protective clothing and equipment needed.

    -   Training, development and distribution of appropriate
        information, education and communication

    -   Specific IEC messages, along with sale and treatment, regarding
        the proper handling, use, disposal of pesticides, and related
        waste, at the distribution, storage, handling, use, disposal
        stages, at all levels, but especially at the village and
        household levels.

-   **Emphasize operational research & monitoring & evaluation**: Roles
    of key actors

    -   Quality control of insecticide(s)

    -   Research on alternative insecticides and effectiveness under
        local conditions

    -   Mosquito susceptibility to insecticide(s) of choice

    -   Safe and effective use of insecticide by parties at all levels

-   **Identify Roles and Responsibilities**:

    -   Public Sector: coordination, regulatory oversight and
        management, defining environmental responsibilities, and others

    -   Commercial Private Sector

    -   Non-profit private sector, PVOs, NGOs

-   **Integrate Mitigation Measures**, for example:

    -   Choice of USEPA-recommended pesticides

    -   Avoid disposal of treatment solution in bodies of water

    -   Avoid washing application equipment where the residues would
        impinge on bodies of water

    -   For bulk pesticides, provisions for spill prevention and
        clean-up

-   **Disposal provisions for used pesticide containers**

## Annex 2: A Practical Guide To Reducing Pesticide Risks in Development Projects[^5]

**Basic principle of risk reduction**: risk must be evaluated in the
local conditions of the project or activity.

1)  **Some common errors**

-   Pesticide not registered in the host country

-   Pesticide not evaluated/registered in the country of origin (OECD)

-   Pesticide not efficacious for the planned use

-   Formulation is not stable in tropical conditions

-   Formulation not adapted for the available application equipment

-   Quantities exceed the real need

-   Pesticide is too dangerous for the users

-   No label / in a foreign language

-   Packaging of an inappropriate volume

-   Packaging not strong enough

2)  **Basic principles**

-   Promote IPM as the preferred approach for pest control

-   Reinforce the management of pesticides by the host country

-   Use good practices in the provision of pesticides

3)  **Constraints to IPM \-- pesticides**

-   Aggressive marketing of pesticides

-   Policies of government/donors

-   Governmental policies / donors promote the use of pesticides

-   Economic/financial

-   Institutional

-   Centralized decision-making in favor of pesticides

4)  **Possible responses**

-   Put in place a project/program for plant protection/vector control

-   Put in place IPM/IVM projects/programs

-   Donation/purchase of pesticides

5)  **Use of pesticides in development projects \-- some recommendations
    if one is obliged to use pesticides.**

**Stage 1 -- phytosanitary problem analysis**

-   Is the pest biology known?

-   Is the environment and are the farmer practices known?

-   Is the pest impact known (financial loss)?

**Stage 2 -- analysis of management options.**

-   Has the pesticide efficacy been evaluated for the crop/pest and
    locality in question?

-   Are agronomic/cultural measures known and applied?

-   Is biological control possible?

-   Has an IPM system been developed?

**Stage 3 -- risk reduction**

-   Risk = toxicity x exposure

-   Minimize the risk of the pesticides used by:

-   Reducing toxicity of choices

-   Reducing the duration of exposure

-   Reducing the degree of exposure

6)  **Risk reduction measures:**

##### Avoid use

-   Avoid pesticide use, if possible.

-   Avoid pesticide use as the only control option, if possible.

-   Integrate pesticide use into an IPM system \-- minimize the
    frequency and dose of applications

-   Use pesticides as a last resort

###### Toxicity reduction

-   Use the least toxic commercial products available -- basic
    principles:

-   Products authorized? \-- regulation.

-   Products efficacious? \-- regulation / research

-   Products acceptables to users? \-- extension / farmers' groups

-   WHO acute toxicity classes:

> Ia Extremely hazardous
>
> Ib Highly hazardous
>
> II Moderately hazardous
>
> III Slightly hazardous
>
> U Unlikely to present any acute hazard in normal use

-   Lists of concern :

    -   Products in WHO toxicity classes Ia, Ib (and II)

    -   Products not registered in OECD countries

    -   « PIC » or « POP » chemicals

(FAO: will not use Ia/Ib in development projects. World Bank / OECD:
will not finance Ia/Ib/(II) if use is directly by or accessible to small
farmers or in countries without good regulatory programs.)

####### **Exposure reduction**

-   Prior to use

    -   Transport, Packaging, Storage

-   During use (« safer use »)

    -   Training

    -   Formulation

    -   Equipment

    -   Protective material

    -   Buffer zones

-   After use

    -   Waiting period

    -   Cleaning / bathing

    -   Storage

    -   Disposal

    -   Monitoring

[^1]: U.S. NIH Guidelines:
    <http://www4.od.nih.gov/oba/rac/guidelines_02/NIH_Guidelines_Apr_02.htm>

[^2]: ADS 211- Biosafety Procedures for Genetic Engineering Research.

[^3]: Refer to the [Environmental Procedures Training
    Manual](http://www.encapafrica.org/EPTM.htm) (EPTM) (AFR Edition),
    Chapters 3 & 4 for comprehensive guidance on the choices and
    approaches for preparing environmental documentation. See the
    attached annotated templates.

    Note that the EPTM Annex C presents two IEE formats, one for Title
    II (Food for Peace) activities, another for non-Title II activities.
    The difference is only in the Face Sheets formats. For historical
    reasons, we continue to use two different formats in the Africa
    Bureau., thus present both. But the Request for Categorical
    Exclusion and the narrative formats are the same for both.

[^4]: USAID. 1990. Integrated Pest Management: A.I.D Policy and
    Implementation.

[^5]: Translated from Oct. 2000 presentation at IPM workshop by H. van
    der Walk, UNFAO Sahel Regional Program, Bamako, Mali.