BACK-TO-OFFICE REPORT Richard Thompson Date of report: 18 ...

BTOR 19 Thompson- Lebanon

BTOR 74 Ammati- Lebanon

BACK-TO-OFFICE REPORT

Reporting Officers: Mohamed Ammati

Richard Thompson

Country: Lebanon

Dates of visit: 3 – 15 April 2011

Date of report: 18 May 2011

Purpose of visit: 1 Facilitate Pesticide Management Workshop

2 Agree scope of activities for GCP/INT/114/USA

3 Plan PSMS enhancement and roll-out

Brief recommendations and follow-up action:

• New pesticide legislation should be drafted encompassing all sectors including

Agriculture, Animal Health and Public Health

• National Consultants for review of Code of Conduct should finalize report of the

workshop including the national priorities and action plan for strengthening

pesticide management in Lebanon

• Finalize the plans and provide TORs and potential consultants to address the high

priority issues that were agreed with HE the Minister of Agriculture under

GCP/LEB/021/ITA and GCP/INT/114/USA

• With CIOK, finalize plan and develop TORs for the enhancement and roll-out of

PSMS in Lebanon

Distribution:

Pandey, AGP

Kenmore, AGP

Prante, AGP

Hodder, AGP

Davis, AGPMC

Lichaa, FAOLEB

Valat, TCID

Moumen, FAOLEB

Hachem, FAORNE

Ravelomanantsoa, LEGN

Wehling, LEGN

Viparthi, CIOK

Settle, AGPMC

Helps, AGPMC

Van der Wulp, AGPMC

Yang, AGPMC

AG Registry

TC-FPMIS-Data Quality



1 Code of Conduct Review under GCP/LEB/021/ITA

Background and objectives

Food Safety and security is a current priority of the Ministry of Agriculture particularly in

relation to use and misuse of pesticides. On 10 and 11 May 2010 under the patronage of

H.E the Minister of Agriculture the Arab Society for Plant Protection facilitated a

workshop “Crop Health Management and Food Safety”. The focus of the workshop was

improving the sustainability of agriculture in Lebanon while reducing reliance on

pesticides and reducing risks from pesticides. A key recommendation from the workshop

was that the country should review the effectiveness of its implementation of the

International Code of Conduct on the Distribution and Use of Pesticides and strengthen

areas of weakness and gaps.

As a result of this recommendation, AGPM and LEGN provided terms of reference for a

review by national consultants of pesticide legislation and pesticide management

practices under GCP/LEB/021/ITA.

The objectives of the workshop were:

1. Present the findings of the legislation review and Code of conduct review to a

wide range of stakeholders (ministries; research institutions; pesticide importers,

distributors and sellers; farmers; pesticide applicators; and NGOs).

2. To identify the gaps and issues, and agree actions and their priority for

strengthening legislation and pesticide management.

Highlights of the meeting:

The agenda, recommendations of the working groups and participants are shown in the

annexes. The workshop was facilitated by Mohamed Ammati and Richard Thompson

from AGPM; Lalaina Ravelomanantsoa and Philine Wehling from LEGN; Dany Lichaa

Khoury, Project Manager and his team from GCP/LEB/021/ITA ; and the national

consultants Imad Nahhal, Halima Itani and Abdallah Ahmad.

Methodology:

The workshop presented and discussed the findings of the review of pesticide

management and pesticide regulations in relation to the International Code of conduct on

the Distribution and Use of Pesticides.

The participants were organized into 3 work-groups to review different areas of the

pesticide life-cycle and to identify the priority issues and make recommendations for their

resolution. The three work groups were:

Group A: pesticide registration and related legislation;

Group B: pesticide management (import, inspection, storage and

distribution); and

Group C: Marketing, use and empty container and unwanted pesticide

management.



The outcomes and recommendations of the different working groups were discussed and

refined in plenary session.

Key findings

The key findings and high priority recommendations were:

1. Pesticide legislation

a. Elaboration of one legislation covering pesticide and bio-pesticides

used in agriculture, public health (including domestic) and animal

health, with the capability for regional harmonization.

b. Elaboration of separate regulations for:

i. Pesticide registration including field trials

ii. Import

iii. Control

c. Elaboration of a single list of registered pesticides and bio-

pesticides in the above three sectors

d. Upload pesticide registry in PSMS

2. Pesticide Management

a. Capacity building in inspection and quality control

i. Training for sampling and inspection

ii. Evaluation of laboratory capacity in Lebanon for pesticide

quality and residues

iii. Assess the stores (and if possible inventory the stocks) of

the licensed importers, distributors and resellers in PSMS

as is done in routine inspection currently.

3. Use

a. Management of Empty containers should be regulated and a

feasibility study undertaken to review options for a national

management scheme

b. Undertake field studies in relation to pesticides use to evaluate the

condition of use and to evaluate their performance according to the

current regulation.

These priority actions were agreed by the Minister of Agriculture and will be funded by

GCP/INT/114/USA and GCP/LEB/021/ITA .

National Strategy for strengthening pest and pesticide management

The national consultants are preparing their final report which will include a draft

national strategy for strengthening pest and pesticide management. This will include all

the issues and recommendations identified during the workshop. Once agreed by all the

Ministries involved in pesticides, this strategy will form the framework for any future

activities and projects in the sector..



2 Lebanon Component of GCP/INT/114/USA

Background

The US Department of State through its Chemical Treat Reduction Programme has

agreed to fund FAO’s work to reduce pesticides risks including reducing reliance on

pesticides, strengthening capacity for pesticide management and addressing obsolete

pesticides. The funding is mobilized through a framework agreement with the USDA

GCP/INT/114/USA . During the formulation mission to Lebanon in May 2010, the

project activities in Lebanon were agreed to focus primarily on strengthening pesticide

management capacity with the development and roll-out of PSMS in Lebanon. The

project document was approved and funding received from the USDA in October 2010

In the intervening period the Ministry of Agriculture and FAOLEB agreed to fund the

PSMS activities under GCP/LEB/021/ITA and GTFS/REM/070/ITA , and the project

document remained unsigned by the Ministry of Agriculture.

During Mr Thompson’s mission to Lebanon 22-25 February, it was agreed with the

Ministry of Agriculture that the activities to be undertaken under GCP/INT/114/USA

would be modified to address priority recommendations from the Code of Conduct

Workshop. The project document was signed by the Ministry on this basis.

Objective

The objective of the mission was to reformulate the project to address priority pesticide

management issues and obtain the agreement of the Ministry of Agriculture.

Highlights of the meeting:

The Minister of Agriculture confirmed that Mrs Lama Haydar, Head of Pesticide

Registration at the Plant Pharmacy Department as National project coordinator.

Following the Code of Conduct workshop meetings were held with Dr Samir el Chami,

Acting Director General of Agriculture-Director of Plant Resources; Mrs Lama, Dr Salah

Hajj Hassan, advisor to the Minister and Mr Mohammed Abou Zeid Head of the Plant

Pharmacy Department during which the scope and budget of the Lebanon Component

were agreed. The main elements are:

• Assessment and development of pesticide inspection capacity throughout the

life-cycle

• Training of trainers for inspection bodies

• Training on inspection and sampling of pesticide import

• Procurement of inventory equipment and personal protective clothing

• Feasibility study for a management scheme for empty containers and the

collection of unwanted pesticides from users

• Field studies on pesticide use

An Aide-Memoire was prepared detailing the activities and budget. During the meeting to

sign the Aide Memoire, on the insistence of the Minister with the support of FAOR, an

additional unbudgeted and unscoped activity, “Awareness campaign on pesticide



poisoning” was added. While agreeing that pesticide poisoning is an important issue, the

RO pointed out that, to be effective, communications campaigns require research into the

knowledge, attitudes and practices of the target audiences, careful design and adequate

funds. Unresearched, poorly designed and under-funded communications campaigns can

be counter-productive. The Minister agreed that if project funds did not become

available, the ministry would find its own resources for the awareness raising campaign.

The aide-memoire was signed by Dr Samir el Chami, Acting Director General of

Agriculture-Director of Plant Resources and FAOR on 14th

April and is included as an

Annex to this report.

3 Enhancement and Roll-out of PSMS

Background

The Ministry of Agriculture is keen to strengthen the management and control of

pesticides during their lifecycle in Lebanon. The Plant Pharmacy Department has a stand-

alone database that has been developed for them to manage their pesticides registrations.

The system however has not been put into operation.

FAO has developed the Pesticide Stock Management System (PSMS)as a tool for

countries to use to hold pesticide registration information, control and manage stocks of

pesticides throughout their lifecycle in the country including disposal of unwanted empty

containers and pesticides. There is a component that specifically addresses developing

safeguarding strategies for obsolete pesticides.

The Ministry of Agriculture is interested in utilizing PSMS to improve its lifecycle

control and management of pesticides. This document describes the wishes of the

ministry.

As PSMS is a tool for all FAO member states, it is important that any enhancements will

improve its usefulness and usability to all countries. Where Lebanon has requirements

that are specific solely to its national context, those requirements will have to be

addressed outside the core PSMS.

Objectives of the mission

The objective of the mission was to meet with the Ministry to clarify their requirements

and wishes for a system for managing and controlling pesticides and to canvass views of

other stakeholders that would be required to use the system. Following these meetings to

develop an outline scope for the system to facilitate discussions within AGPMC and

CIOK regarding the need for enhancements in PSMS and stand-alone systems for

Lebanon.

Highlights of Meetings



Meetings were held with the Ministry of Agriculture (Lama Haydar, Salah Hajj Hassan

and Mohammad Abou Zeid) and representatives of pesticide importers, formulators and

distributors (SLAC, Debbane, and Adonis).

The private sector were willing to cooperate with the initiative provided that their

commercially confidential information was protected. They accepted a system which

would manage the processes that are currently controlled by the Ministry, i.e. the import

procedures and the new selling procedures where users are required to produce a

prescription from an Agricultural engineer to procure pesticides. They were reluctant to

use a system which tracked pesticides throughout the distribution chain.

At the final meeting with the ministry a detailed specification document was prepared.

This is shown in the annex.

Recommendations

The RO should follow up with meeting with CIOK to identify the most effective means

of satisfying the requirements for the system in Lebanon.

Annex - Recommendations of Code of Conduct Workshop

Issues Recommendation Priority Classification

Evaluation of alternative

pest management options Not discussed

Identification and

Removal of highly

hazardous pesticides

Not discussed

Nee

ds

Ass

essm

ent

Incorporating needs

assessment in registration

process

Not discussed

Single Registration Body

for all Pesticides

• Need to establish a single registration body and the

details regarding its competencies in addition to

the stakeholders involved will be discussed later.

Reg

istr

atio

n

Definitions of Pesticides

• Adopt a law that will act as an umbrella for

chemical pesticides and bio-pesticides.

• The definition of the chemical pesticide will be

inspired by the code of conduct while the

definition of the biological pesticide will be agreed

upon pursuant to FAO recommendations.

• As for the details, regarding agricultural

pesticides, public health pesticides and veterinary

pesticides, they will be mentioned in special

decrees.



Improvement of the

Registration System

• All pesticides, active ingredients and technical

ingredients should be registered.

• In order to import all kind of pesticides, licenses

for both registration and use should be given.

• While for technical and active ingredients, only a

license for registration is given.

• The registration process requires an importer

license.

• Agricultural professions licenses are subject to a

symbolic fee.

• Each pesticide to be registered shall also be

subject to a symbolic fee.

• After registering the pesticides in the relevant

tables, a time frame shall be determined for field

trials in order to ensure that the pesticide does not

have any harmful impact on the environment and

the public health. Following those trials, the

license of use will be issued.

Transparency and

Availability of

information on Registered

pesticides.

• A unified list of pesticides shall be developed on

national level.



Regional Collaboration

and Harmonization

• The draft law shall stipulate the need to take all the

necessary procedures in order to ensure a proper use

and transportation of the pesticide and guarantee its

alignment with public health and environment safety.

• Information exchange and commercial exchange

between the countries of the region.


Lack of data to base

decisions for needs

assessment

Prepare and publish detailed statistics of pesticide

registry, pesticide imports, stocks, use, types, package

sizes,

Cropping calendar for forthcoming season for use in

public and private sector decisions

H 1

Legislation,

regulations

and

institutional

structures

Nee

ds

Ass

essm

ent,

Imp

ort

/form

ula

tio

n

Effective needs

assessment

Undertake an agricultural census,( crops, pests, uses),

Field history and bookkeeping,

Needs of new areas to be developed

Training on needs assessment for import for public and

private sectors

H 2

Pesticide

Management

capacity

building



Requirement for import

and export licences,

control and data

Further study and consultation required for reconciling the

requirements for the ministry to control imports and

ensure fair competition in the private sector

(Updating the legislations, reduce bureaucracy,

notification to replace license of export until procedures

are well defined, gathering correct data)

Important to have an import Licence, and work on speed

up procedures and transparency.

L 3

Legislation,

regulations

and

institutional

structures

Compliance with

Rotterdam

Review the mechanisms for compliance with Rotterdam

and determine the needs for export permits

M 2

Legislation,

regulations

and

institutional

structures

Sampling procedure at

entry point -

Staff do not have capacity

and equipment to sample

effectively at entry point

Large pack sizes should be customs sealed and the

samples taken at the facility of the importer or formulator.

Capacity building in safe sampling to avoid cross

contamination and correct sampling procedures

For consignments of small bottles should be sent directly

to Kfarsima

H 1

Pesticide

Management

capacity

building

Capacity and number of

Ministry staff

Review needs for staff numbers and capacity and

undertake Training for Ministry staff L 2

Pesticide

Management

capacity

building



Emphasis of IPM IPM should be encouraged with the users to reduce

pesticides needs

Awareness Raising, Training of Farmers,

Alternatives to chemical pesticides H 1

Pest

management

capacity

building (e.g.

lower risk

alternatives)

Inspection can be seen as

over bureaucratic

Inspection regimes should not restrict private sector (not

too burdensome) yet fulfilling proper level of security and

quality H 1

Legislation,

regulations

and

institutional

structures

Quality control issues FAO pesticide specifications should apply as “good

quality pesticides”

Private sector would like to be able to use Kfarshima for

pesticide testing

Split samples and recourse to third party accredited lab in

event of dispute

Agreed methodologies should be used by Kfarshima

(accreditation)

Capacity building for laboratory staff in methodologies

and GLP

H 1

Legislation,

regulations

and

institutional

structures

insp

ecti

on

/qu

alit

y c

ontr

ol

Standard of inspection Assess inspection regimes in Lebanon with regard to the

code of conduct and identify gaps and plan for their

improvement H 1

Pesticide

Management

capacity

building



Traceability Implement PSMS in Lebanon – step by step

H 1-3

Pesticide

Management

capacity

building

Low capacity of the staff

in the regional

inspectorates

Review the options for outsourcing the inspections to

private inspection companies or

Build capacity through the regional inspectorates with

Training and systems

H 2

Pesticide

Management

capacity

building

No standardised procedure

for inspection

Develop inspection procedures and checklists for stores

and pesticide quality

H 2

Legislation,

regulations

and

institutional

structures

MoA only accepts

analytical standards from

third party organisations –

for new AIs these are not

available

This problem should be addressed by the pesticides board

rather than just Kfarshima

H 1

Legislation,

regulations

and

institutional

structures

No transport rules for

hazardous materials

With the ministry of transport investigate options for

developing regulations for transport of hazardous

materials

Vehicle standards

Driver training

H 3

Legislation,

regulations

and

institutional

structures

Sto

rage

and

Dis

trib

uti

on

Low capacity of store

keepers

Training programme for storekeepers in private and public

sector stores - M 1

Pesticide

Management

capacity

building



Stores are located in

residential areas

Review and update the regulations for pesticide stores to

meet international standards

Municipality grants approval for location of the store. The

Municipality staffs are not aware of the risks. The MoA

grants a licence on the basis of this approval. The

regulations should be amended to ensure adequate

assessment of the risks.

Municipality staff should be trained.

M 2

Legislation,

regulations

and

institutional

structures

Environmental risks posed

by storage locations and

conditions

Use PSMS to evaluate the risks of stores

The Ministries of Environment and Health should be

involved in the assessments M 2

Legislation,

regulations

and

institutional

structures


Misleading publicities Prior technical control by MOH, MOA in collaboration

with MOI when needed

M-2 Legislation-

regulations

Unavailability of

information

MOA to continuously publish the list of registered and

banned products and their crop use (Label + MSDS)

H-1 Communicatio

n

Solvents of toxicological

concern

MOA to enforce naming of these solvents in the label

under “notes to physicians”

M-3 Legislation

Difficulty in custom

clearance of biological

pesticides alternatives

MOA in collaboration with customs to facilitate faster

clearance in the ports of entry

H-2 Regulations

Ma

rket

ing

Unsuitability of some

pesticides containers

MOA to enforce the fabricators/Importers to provide

suitable quality containers and to repack the pesticides of

inadequate containers

H-3 Legislation



Transfer of pesticides to

smaller packs

Promote the use of soluble small packs when applicable M-3 Pesticide

Management

capacity

building

Scarcity of measuring

cups

MOA to enforce the inclusion /distribution of measuring

cups in adequate numbers

M-2 Pesticide

Management +

Legislation

Lack of proper application

equipment

New technology transfer program on equipment and their

proper use

H-1 Pesticide

Management

Capacity

building-

Communicatio

ns &

Awareness

raising

No use & Lack of PPE

(Personal Protective

Equipment)

Awareness program on the importance of using PPE to

users

H-1 Communicatio

ns &

Awareness

raising

Use

Misuse of pesticides and

spraying equipment

Training of MOA staff on proper pesticides and equipment

use

Extension program and demonstrations

H-1 Communicatio

n and

awareness

raising/

Pesticide

Management

Capacity

building



Weak advisory system for

pest management

Support IPM research

Continuous training of MOA extension staff

Initiate IPM programs on greenhouses, citrus, grapes and

other major crops (Public -Private- Research centres and

universities and NGOs partnership)

H-1 Pest

management

capacity

building

Farmers don’t read labels Awareness campaign by extension services H-1 Communicatio

n and

awareness

raising

No follow up of pesticide

efficacy and mixture

compatibility at end user

level

Extension services in cooperation with private sector to

monitor and report efficacy and compatibility of mixtures

M-1 Pesticide

management

capacity

building

Health monitoring Activate existing legislations

MOH to request from hospitals and medical centres to

report cases of pesticide poisoning

MOA to enforce the inclusion of poisoning centre phone

(toll free)

H-1 Legislation

and

communicatio

n

Ma

nag

emen

t o

f em

pty

con

tain

ers

an

d

un

wa

nte

d p

esti

cid

es Weak mechanism of

disposal of empty

containers

Awareness on triple-rinse, puncturing of containers and

proper disposal

Waste collecting services to include specific bins for

empty pesticides containers in agricultural areas

Farmers to return empty containers to resellers, resellers to

collecting services

Collection and recycling (non food grade)/ disposal by the

plastic recycling industries

MOI to control the recycling into non food grade

Cost of services to be charged as a levy on quantity of

imports

M-2 Pesticide

management

building

capacity +

Legislation +

Communicatio

n and

awareness

raising



No mechanism for

disposal of unwanted

pesticides (obsolete,

expired or unused)

MOA to enforce importers to assess the quantity of

pesticides needed

Expired pesticides are considered obsolete unless proved

to be properly stored in the importers stores and

complemented by chemical and physical validation tests in

locally and internationally accredited labs

MOA-MOH-MOE to make yearly circular requesting all

whole sale and retail pesticides stores to declare the

amount of obsolete pesticides available with a clear note

that the disposal will be at the expense of the Lebanese

government and it doesn’t involve any penalty for small

quantities

H-2 Legislation

1

Participants

Strengthening Production and Marketing of the Lebanese Agricultural Products (GCP/LEB/021/ITA)

Name Position Institution Email Phone Signature

Samir el-Chami

Acting Director General of

Agriculture-Director of Plant

Resources

Ministry of

Agriculture

[email protected]

Salah Hajj Hassan Advisor to The Minister Ministry of

Agriculture

[email protected]

Mohamad Abu

Zeid Head of Plant Protection Service

Ministry of

Agriculture

[email protected] 03 315 180

Lama Haidar Head of Plant Pharmacy

Department

Ministry of

Agriculture


Imad NAHHAL Head of Plant Protection

Department

Ministry of

Agriculture

[email protected]

b

03 894 679

Salem Hayar Head of Kfarshima Lab for

Pesticides Analysis

Ministry of

Agriculture


Najwa Khansa Plant Pharmacy Department Ministry of

Agriculture

Najwa-

[email protected]

03 216 972

Rima El Shihne Plant Pharmacy Department Ministry of

Agriculture

Rima-el-

[email protected]

70 476 177

1

List of Participants of the Workshop Pesticide Management in Lebanon


Desire El Dayyeh Plant Pharmacy Department Ministry of

Agriculture

Desiree-

[email protected]

03 730 268

Carole Najjar Plant Pharmacy Department Ministry of

Agriculture


Abdallah Ahmad Legal dept Ministry of

Agriculture



Abir Abou El-

Khoudoud

Head of extension and

education department

Ministry of

Agriculture

[email protected]

v.lb

Did not come

Dr. Elias Chaaban Veterinary Drugs Office Ministry of

Agriculture [email protected]

70 068 797

Charles Zazour Head of plant Quarantine

Service

Ministry of


009615952510

Dr. Obeida

Mdawar

Head of Animal quarantine

Department

Ministry of


03 469 019

Youssef Abou

Jawde

Member of Pesticides

Committee

American University

of Beirut- [email protected]

03 01 03 44

1




Aziz El Ammar Member of Pesticides

Committee Debbane Freres [email protected]

03 300 598

Fabienne Jbara Member of Pesticides

Committee SLAC [email protected]

03 699522

Nadine Antar Member of Pesticides

Committee ANTAGRO

Did not come

Samir ASSI Member of Pesticides

Committee ADONIS [email protected]

03 300 345

Kozhaya El

ZOUKI

Member of Pesticides

Committee INSECTA

Did not come

Fatima EL Ali Member of Pesticides

Committee

Lebanese

Agricultural Research

Institute

Did not come


Mhamad Kabbara Observer- Pesticides Committee Order of Engineers Did not come

1



Dr. Fakher

Dakroub Observer- Pesticides Committee Order of Engineers

03 652 363

Adel Yacoub Head of Protection of Natural

Resources Service

Ministry of

Environment [email protected]

01 976 555

Ext:456

Did not come

Olfat Hamdan Head of Chemical Safety

Department

Ministry of


01 976 555

Ext:408

Did not come

Farid Karam Head of Service of Sanitary

Engineering Ministry of Health

[email protected]

m

03 643 155

Ms Hayat Azouri

Health issue person -

Toxicologist

03-332246

St Joseph University

Anti poisoning centre

– toxicology

department

[email protected]

03 332 246

Eng Mohammad

Naja

Registration Officer in the

company Agricultural Materials

m.naja@agrimatco-

me.com

03 386 127

Eng Ziad Zughaib Registration Officer in the

company

Akiki

Did not come

Fouad Diab Large farmer of Citrus in South

of Lebanon Commercial farmer

Did not come


1

Eng. Ibrahim Al

Hariri

Large farmer and act as a leader

to farmers in his region (Saida)

Al Hariri Foundation -

Agricultural Section &

Commercial farmer

[email protected]

Did not come

Eng Ali Fiad Al

Tarshishi

Large farmer and sprayer to

farmers in his region (Bekaa –

Baalbeck)

Worker &

Commercial farmer [email protected]

Did not come

Eng. Mohammad

Al-Hajj

General Manager- Agriculture

Section

Jihad-al- Binaa

Development

Association

[email protected];

[email protected]

Did not come

Eng. Patricia R.

Sfeir

Agriculture & Environment

Department Manager

Young Men's

Christian Association

(YMCA)

[email protected]

Did not come

Ms Maya Dao Legal dept Ministry of


01 976555

ext:463

Did not come

Mr. Bashir Eid Customs Service Ministry of Finance [email protected]

b

03 675089

Louai Hajj

Chehadeh Directeur des douanes Ministry of Finance

01 429 003 Did not come

Eng. Ramzi

Shasha Chemical Engineer Ministry of Industry

[email protected]

m

71 79 45 22

Dr. Fadi Salhani

Head of Department for

Applying of public health

pesticides

Municipality of Beirut

01 580 122

03 87 55 53

1




Eng Adnan Katerji Responsible for applying public

health pesticides Municipality of Beirut

Ammar El kaak Small farmer of vegetables in the

Bekaa - Baalbeck Commercial farmer

03 038540 Did not come

Nihal El Homsi WHO Did not come

Solange

MattaSaade Field programme Officer FAO Lebanon

Solange.mattasaade@fao.

org

03 950206

Did not come

Halima Itani National pesticides management

consultant [email protected]

03 620 952

Eng. Georges

Kaddisi Marketing coordinator

Comptoir Agricole du

levant [email protected]

01 890 811

Moussa Kfoury Agriculture business master 70 836 157

Sarah Ezzedine Agriculture Engineer YMCA [email protected]

m

03 260 388

1



Dr. Hanna Bou

Habib MoE [email protected]

03 175 022


Mustafa Antar Marketing Coordinator Antagro [email protected] 01 311 603

Nayla Maalouf Agriculture engineer Robinson Agri [email protected] 09 796 144

Talar Babikian Agriculture engineer Robison Agri [email protected] 70 862 465

Dr. Abed Rahman

Saghir Consultant Ex AUB [email protected]

03 728 819

Marwan Akkary Technical and Development

manager Debbane [email protected]

03 370 310

Nabil Kaissi Engineer ESIB [email protected] 01 864 876

Mohammad

Darwish Saab Foundation

Hsaab-

[email protected]

03 80 94 97

Hanadi Jaafar MoA [email protected]

m

Dr. Faten Raad Researcher LARI [email protected] 03 73 84 32

Annex

25

Aide-Memoire

FAO Lead Technical Unit

Pesticide Risk Reduction in Middle East and Asia (GCP/INT/114/USA)

Reformulation of the Project Component for Lebanon

April 4 - 15, 2011

1 Introduction

The component for Lebanon in Pesticide Risk Reduction in Middle East and Asia

(GCP/INT/114/USA) was originally formulated during a mission in May 2010 by the Lead

Technical Officer, Richard Thompson. It was agreed that the focus of the component should

be implementation of the Pesticide Stock Management System (PSMS) in the country while

the project “Lebanese Observatory for Agricultural Development” (GCP/LEB/020/ITA)

would include an initial survey of obsolete pesticides from agricultural input suppliers. The

project framework agreement was signed between the United States Department of

Agriculture and FAO in October 2010.

During the intervening period, the priority for the implementation of PSMS was raised and it

was agreed between the Ministry of Agriculture and FAO Lebanon that it should be included

in the project “Strengthening Production and Marketing of Lebanese Agricultural Products”

(GCP/LEB/021/ITA) with additional support from the Regional IPM Project

(GTFS/REM/070/ITA).

GCP/LEB/021/ITA has also funded a review of the “pesticide life cycle” and an evaluation of

the country’s implementation of the Code of Conduct on the Distribution and Use of

Pesticides (the Code). A stakeholder workshop was held between 5th

and 7th

April 2011, at

which the gaps in the implementation of the Code were reviewed and activities to address

them identified.

The Ministry of Agriculture (MoA) has requested that FAO reformulate the Lebanon

component of GCP/INT/114/USA to address the highest priority activities. This aide

memoire describes the activities, the revised budget and new work plan that have been agreed

by the Ministry.

2 Reformulated Activities

The priority activities that will be addressed under the Lebanon component of

GCP/INT/114/USA are described below:

2.1 Legislation and pesticide management workshops

The development of the national pesticide legislation and the national pesticide management

strategy will require two further stakeholder workshops in October 2011 and January 2012.

The workshops and the participation of other FAO experts will be funded by

GCP/LEB/021/ITA. The LTO of GCP/INT/114/USA will participate in both workshops to

assist in the formulation of the legislation and the development of the national pesticide

management strategy. His participation will be funded by GCP/INT/114/USA.

26

2.2 Assessment and development of pesticide inspection capacity throughout the

life-cycle

The capacity and inspection roles of the regional MoA services responsible for inspection of

pesticides, customs inspectors, quarantine officers and other inspection staff will be assessed

in a review undertaken by a national consultant under the support of an international expert.

If there is a potential need for the use of private sector inspection agencies, their capacity will

also be assessed. The international consultant will develop a report detailing

recommendations in the improvement of the inspection strategy for Lebanon. The report will

include recommendations for the roles of each of the groups involved in inspection; their

training requirements; the development of standard inspection methodologies and checklists;

and the equipment required for sampling, sample storage and personal protection. All

methodologies and checklists will be prepared with Arabic versions.

2.3 Training of trainers for inspection bodies

The national and international consultants employed under section � will be engaged to

undertake a five-day training of trainers for up to 20 staff selected from each of the central

and regional bodies designated for undertaking pesticide inspections. The training will be

based on the methodologies and checklists developed in section �.

2.4 Training on inspection and sampling of pesticide import

The national and international consultant employed under section � will be engaged to

undertake a five-day training for up to 25 staff selected from the inspectors of imports and for

identification of pesticide products and inspection and sampling methodologies. The staff will

undertake a full medical check (including cholinesterase inhibition to check for previous

pesticide poisoning) prior to the training. The project will procure sampling equipment

(samplers and sample storage equipment) and personal protective clothing that will be

demonstrated during the training. The specification and quantity for the sampling equipment

will be determined by the consultants during the assessment outlined in section �.

2.5 Procurement of inventory equipment and personal protective clothing

The project will procure equipment to be used for the evaluation of pesticide stores and the

inventory of their stocks. The equipment will be available for use by the regional inspectors

when they inspect pesticide stores and complete inventories of stores of the importers,

distributors and resellers as part of the roll-out of PSMS.

2.6 Feasibility study for a management scheme for empty containers and the

collection of unwanted pesticides from users

A national consultant will be engaged to undertake an assessment of the pesticides entering

the market/used in Lebanon and their pattern of distribution and use in order to:

• estimate the quantities, sizes, types and materials of construction of containers that are

required to be recycled annually;

• estimate the patterns of arising of empty containers including seasonality and

geographical concentrations;

• estimate the current level of practice of “triple rinsing”;

• identify the options for collecting the empty containers and small quantities of

unwanted pesticides from users including the local waste management services,

dedicated collection points, reverse distribution through the resellers; and

• assess the national and regional recycling industry to identify recycling/disposal

options for each of the container materials.

27

Together with the national consultant, the international consultant will undertake a two day

stakeholder workshop to present the findings of the review and develop recommendations for

the national container management scheme. The international consultant will prepare a costed

proposal for establishing and running the scheme including awareness raising and

infrastructure. The proposal will also include options for funding the scheme.

2.7 Field studies on pesticide use

The current data available to the Ministry of Agriculture on the patterns and practices of use

of pesticides is very limited. A national consultant will be engaged to undertake field studies

to gather information on the storage, use and disposal practices of pesticide users. The study

will primarily focus on farmers involved in agriculture, horticulture, livestock husbandry but

will also include public health pesticides by municipal authorities and the public. The study

will assess the knowledge, attitudes and practices of farmers with respect to: sources of

advice on pest management; needs assessment; pesticide use; alternative pest management

practices; pesticide risks; personal protection; and awareness poisoning symptoms and signs.

The report of the study will include an assessment of the gaps and recommendations for

priority actions.

2.8 Awareness campaign on pesticide poisoning

The Ministry of Agriculture will develop an awareness campaign on pesticide poisoning to be

designed after the beginning of the project.

3 Terms of Reference

Outline terms of reference are included in the main project document. Detailed terms of

reference will be developed from these for each of the consultancies.

4 Duration

The duration of the project is 12 months from the date of signature of this Aide Memoire.

5 Budget

The total budget for this component is USD 180 000. The budget breakdown by activity and

oracle code is shown in Annex 1.

6 Work plan

The work plan is shown in Annex 2.

28

7 Signature

This Aide-Memoire has been signed on 14th

April 2011 by the Government of Lebanon,

represented by the Director General of the Ministry of Agriculture, Eng Samir El Chami

and the Food and Agriculture Organization of the United Nations, represented by the FAO

Representative in Lebanon, Dr Ali Moumen.

For the Food and Agriculture

Organization of the United Nations

Ali Moumen

FAO Representative

For the Government of Lebanon

Eng Samir El Chami

Director General of the Ministry of Agriculture

Annex 1 Budget

Budget

line Component Description Sub Comps Main Comp.

5013 Consultants USD 39,755

5542 Consultants - International USD 18,800

5543 Consultants – National USD 20,955

5014 Contracts USD 0

5650 Contracts Budget USD 0

5020 Locally Contracted Labour USD 4,800

5652

Casual Labour - Temporary

Assistance USD 4,800

5021 Travel USD 30,015

5661 Duty travel others (FAO staff only) USD 4,492

5684 Consultants - International USD 12,753

5685 Consultants – National USD 12,770

5023 Training USD 18,800

5920 Training Budget USD 18,800

5024 Expendable Equipment USD 30,000

6000 Expendable Equipment USD 30,000

5025 Non Expendable Equipment USD 0

6100 Non Expendable Equipment Budget

5027 Technical Support Services USD 28,080

6120 Honorarium TSS USD 28,080

5028 General Operating Expenses USD 7,842

6300 General Operating Expenses Budget USD 7,842

5029 Support Cost USD 20,708

6118 Project Support Costs (13%) USD 20,708

Grand Total USD 180,000

Pesticide Management US Dollar

Evaluation of stores of importers and resellers 15,000

Training of inspection protocols throughout life-cycle 10,716

Training in sampling and inspection at borders 39,488 Assessment of inspection capacity throughout life-cycle and development of inspection protocols 13,490

Use

Field Studies 27,240

Feasibility study for container management and collection of small quantities 15,986

Legislation

Facilitation of stakeholder workshops on national pesticide legislation and pesticide management strategy 18,892

Management

Management of Lebanon Component 13,680

PSC 20,708

National Project coordinator 4,800

Grand Total 180,000

2011 2012

Activity J F M A M J J A S O N D J F M A M J J A S O N D

1 workshops

2 Assess and develop inspection capacity

3 Training of Trainers for inspection

4 Training of trainers for sampling

5 Procurement for inventory

6 Feasibility study for Container Management

7 Field studies on pesticide use

Pesticide Stock Management System Implementation in Lebanon

1 Introduction

The Ministry of Agriculture is keen to strengthen the management and control of pesticides

during their lifecycle in Lebanon. The Plant Pharmacy Department has a stand-alone database

that has been developed for them to manage their pesticides registrations. The system

however has not been put into operation.

FAO has developed the Pesticide Stock Management System (PSMS)as a tool for countries

to use to hold pesticide registration information, control and manage stocks of pesticides

throughout their lifecycle in the country including disposal of unwanted empty containers and

pesticides. There is a component that specifically addresses developing safeguarding

strategies for obsolete pesticides.

The Ministry of Agriculture is interested in utilizing PSMS to improve its lifecycle control

and management of pesticides. This document describes the wishes of the ministry.

As PSMS is a tool for all FAO member states, it is important that any enhancements will

improve its usefulness and usability to all countries. Where Lebanon has requirements that

are specific solely to its national context, those requirements will have to be addressed

outside the core PSMS.

2 Objectives for use of PSMS in Lebanon

The Ministry of Agriculture wishes to monitor and control the import, distribution and use of

pesticides in Lebanon with the following objectives:

• Manage Pesticide Registrations

• Investigated sources of pesticides where crops are found with excessive residue

levels.

• Monitoring lifecycle of pesticides

• Limit smuggling

• Limit inappropriate use of pesticides

• Monitoring expiry of pesticide stocks

3 Vision for PSMS implementation mechanism

3.1 Registration

PSMS has been developed to HOLD pesticide registration information that would be

common to all countries using the system. It was not intended to replace pesticide registration

systems that been designed to meet the specific requirements of a country for evaluating

dossiers etc.

As part of the enhancement process, the FAO CIOK team will investigate the options that

will allow MoA to manage all the datasets that have been built into the Ministry’s standalone

registration database. These options will include:

• Adapting PSMS to hold all the information

• Linking PSMS automatically with the Lebanese standalone registration database

system

• Exporting from Lebanese standalone registration database system and importing to

PSMS

• Splitting the functions between the two systems such that registrations are handled in

PSMS and other data (e.g. list of engineers) is held in the Lebanese standalone

registration database

3.2 Import

Importers do not want to divulge their imports until immediately before they arrive.

• Issue a series of barcode numbers for each importer

• Importer gives to his supplier sufficient of these the bar code numbers for the

containers in the consignment. The supplier puts barcodes onto each container prior

to shipment.

• Prior to the arrival of the load, the importer should enter the details of the pesticides in

the consignment into PSMS together with the barcode numbers.

• When the product arrives in Lebanon, the following steps are taken

Ministry of Agriculture Plant Quarantine at Entry

Point

Customs

Importer submits to MOA PP:

request for taking samples of

shipment along with copy

shipping documents

Importer puts the information

of the consignment into psms

Examine the shipping

documents to determine

whether the shipment contains

pesticides

MOA checks to see product is

registered and PSMS record is

complete issue a Laissez

Passer for taking samples plus

a paper copy of PSMS record

to the plant Quarantine

Issue a provisional declaration

which is sent to plant

quarantine

When both documents are

received, plant quarantine

take a sample and check

that the psms information

is correct and send sample

to Kfarshima

Kfarshima checks analysis

certificate and other info

and import statement and

if OK undertakes analysis

If analysis is fine,

Kfarshima send a copy of

the analysis to MOAPP,

this should be done

electronically

If analysis is not ok,

MOAPP check the analysis

and informs the Importer to

collect analysis from MOA.

Importer signs the analysis for

receipt.

If the analysis is not ok the

importer has a right to do the

analysis again in an

independent laboratory

this should be done

electronically – to importer

and plant quarantine

Importer takes analysis to

plant quarantine who then

release the pesticides and

sign the Customs

Provisional declaration

authorizing customs to

release the goods

PSMS record is updated to

show it has entered the

Ministry of Agriculture Plant Quarantine at Entry

Point

Customs

country and arrived at the

importer

3.3 Sale process at retailer

• Retailers must all be licenced and Stores should be recorded in PSMS

• Farmers must be registered. (registered farmers could be input in PSMS)

• Farmer obtains a prescription (5 copy) from an Agricultural Engineer

• Farmer goes to reseller with the prescription and buys the prescribed pesticides

• The reseller puts the barcode numbers of the pesticides onto the prescription

there are two options for this:

• A double barcode label that has a peelable sticky top label (in one colour) that can

be stuck to the prescription and a permanent under label (in another colour) with

the same number

• Write the bar code number on the prescription. (issue with mistakes in writing the

number)

• The reseller transfers the details of the prescription, sale and barcodes to MoA. There

are two options:

• The reseller enters the information into PSMS directly

• The reseller delivers monthly the prescription with the receipt and barcodes to the

local inspector. The local inspector transmits the documents to the MoA for data

entry.

4 Enhancements and integration with local systems

The ministry of Agriculture wishes to use PSMS

• All reports should be generated in Arabic

• The system should include an automatic registration numbering (start with the last

registered number) (could be just a test to check for uniqueness – currently the number

sequential number concatenated with the date dd

• Usage details page: add more fields including dosage, Pre-Harvest Interval (PHI), Maximum

Residue Limit (MRL)

• Include a database of engineers or technical responsible per business

• Scanning of all related documents (should be further investigated specially in relation to

confidentiality issues)

• The system should popup warning alerts in relation to the expiry of registration

• The system should be able to generate a Certificate of Registration(template specific to

Lebanon e.g. with logos and in Arabic)

• Review the design of Excel export form in registration

• Expand the search to single page covering all the fields, including the newly requested ones

• The system should not allow the registration of banned active ingredients

• Reproduce all the forms in Arabic

• The system should distinguish between importers, retailers and formulators

• Add the prescription records for every movement from retailer to user

• The system should include a sample tracking component of imported pesticide

• Automatic and printable confirmation to the importing companies module

• Movement tracking: add quantity and barcode series fields in order to cater with the small

bottles

Add a repacking component

BACK-TO-OFFICE REPORT Richard Thompson Date of report: 18 ...

Documents

Transcript of BACK-TO-OFFICE REPORT Richard Thompson Date of report: 18 ...