PANNA: Monitoring the World Bank's Pest Management Policy

Authors
Marcia Ishii-Eiteman, PhD
Jessica Hamburger
Christine Lee

Pesticide Action Network North America
Pesticide Action Network (PAN) is an international coalition of citizens’ groups and individuals who advocate adoption of ecologically sound practices in place of pesticide use. Established in 1982, PAN currently links over 700 organizations in some 60 countries, coordinated by five Regional Centers in Africa, Asia, Europe, Latin America and North America. The PAN North America Regional Center (PANNA) links over 140 affiliated health, consumer, labor, environment, progressive agriculture and public interest groups in Canada, Mexico and the U.S. with thousands of supporters worldwide to promote healthier, more effective pest management through research, policy development, education, media, demonstrations of alternatives and international advocacy campaigns/

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Third Edition
Copyright 2002 by Pesticide Action Network North America (PANNA) Regional Center. Permission is granted to reproduce portions of the report, provided the title and PANNA are acknowledged. Permission is granted to translate this guide into other languages as long as it is clearly noted that the translation is "unofficial" and has been done by a group other than PANNA. PANNA would appreciate receiving copies of any such translations.

Acknowledgments

This guide was created as part of Pesticide Action Network North America's World Bank Accountability Project. The project is funded by the Rockefeller Brothers Fund, Ford Foundation, Public Welfare Foundation and John D. and Catherine T. MacArthur Foundation.

The views and recommendations presented in this report are those of the authors and do not necessarily reflect the views of our funders. The authors alone bear the responsibility for any factual errors.

TABLE OF CONTENTS

Introduction

Why Monitor Operational Policy 4.09?

What is OP 4.09?
Problems with Implementing OP 4.09
The Role of Local Communities in Monitoring OP 4.09

What OP 4.09 Requires

The World Bank’s Definition of IPM
The World Bank’s Strategy to Promote IPM
World Bank Conditions for Pesticides Purchases
World Bank Standards for Pesticide Use

Monitoring Tools

Tools for Evaluation of Project Design
Tools for Evaluation of Project Implementation

Appendix A. Monitoring Tools: Pest Management Indicators
Appendix B. Monitoring Pesticide Use
Appendix C. Monitoring the Storage and Handling of Pesticides and Use of Protective Gear
Appendix D. Information Resources
Appendix E. NGO Contacts

Introduction

Monitoring the World Bank's Pest Management Policy, A Guide for Communities is designed to assist communities in evaluating and improving compliance with the World Bank’s binding policy on pest management, Operational Policy 4.09 (OP 4.09). This mandatory policy on pest management states that the World Bank supports biological or environmental approaches to pest management, promotes the adoption of farmer-driven ecologically sound practices and seeks to reduce reliance on synthetic chemical pesticides. This policy applies to all World Bank projects, regardless of sector. In reality, however, Bank project implementation on the ground frequently fails to comply with these policy requirements and may actually promote increased use of hazardous pesticides. For example, projects may include pesticides in input packages, introduce agricultural systems that lead farmers to become highly dependent on chemical inputs and/or fail to provide effective training in ecological alternatives.

The ultimate goal of monitoring OP 4.09 goes beyond identifying policy violations alone. It includes ensuring reduced reliance on pesticides in rural communities around the world. By using the monitoring tools described in this guide, community members can become actively involved in solving the problems they unearth through the monitoring process. This guide is designed to empower communities to investigate and analyze project impacts themselves. The guide will also enable communities to work with World Bank project managers and local government officials to protect public health and the environment and improve agricultural productivity through ecological pest management. Likewise, by listening to and working constructively with communities, the World Bank can improve the quality and sustainability of its projects. Perhaps most importantly, farmers who switch to ecological pest management save money by buying fewer chemical pesticides, while also reducing direct risks to their own and their children’s health.

It is essential that civil society groups develop tools to monitor and evaluate the impacts of World Bank projects on their communities and environments. Around the world, villagers in World Bank project areas, community groups, local NGOs and other supporters of sustainable development are organizing and documenting their experiences. They are using this information to increase community participation, revise and redirect World Bank projects to meet community goals, improve project implementation or even halt misguided projects entirely, when necessary. These efforts contribute to greater transparency and accountability to civil society of international financial institutions such as the World Bank.

Why Monitor OP 4.09?

What is OP 4.09?

Operational Policy 4.09 (OP 4.09) is the official pest management policy for projects financed by the World Bank.¹ Approved in December 1998, OP 4.09 applies to all World Bank funded development projects, regardless of sector. In this legally binding policy, the Bank states that the World Bank "supports a strategy that promotes the use of biological or environmental control methods and reduces reliance on synthetic chemical pesticides."

OP 4.09 states the general principles that World Bank staff must follow in designing and implementing pest management components of projects:

1. In Bank-financed projects, pest populations are normally controlled through integrated pest management (IPM) approaches.

2. The World Bank defines IPM as a farmer driven process that uses ecologically based pest control practices, relies as much as possible on non-chemical measures and seeks to reduce users' reliance on chemical pesticides.

3. The Bank may only finance the purchase of pesticides as a last resort (e.g. after first having explored economically viable non-chemical IPM methods such as biological control and cultural practices), and only when their use is justified within a larger IPM approach.

4. The policy prohibits the Bank from financing highly hazardous formulated pesticide products belonging to World Health Organization (WHO) Classes Ia and Ib.

5. It also prohibits financing hazardous formulated pesticide products (WHO Class II) if they are likely to be used by lay persons or farmers without adequate training, equipment and facilities, a common situation in most countries receiving World Bank loans.

6. Pesticides procured by the Bank must be chosen to minimize adverse effects on human health, nontarget species and the natural environment and must take into account the need to prevent the development of resistance in pest populations.

Problems with Implementing OP 4.09

Although the Bank's current pest management policy contains important commitments to farmers' rights and ecological pest management, project implementation frequently fails to comply with its requirements.

Many poorly designed projects violate OP 4.09 by promoting increased use of pesticides. Project designs often include distribution of pesticides in agricultural input packages or introduce agricultural systems that increase farmers' dependence on synthetic chemical inputs. For the most part, Bank-supported agricultural projects are based on high-input agricultural development models that are not environmentally or economically sustainable for poor farmers with limited income living on marginal land.

Even those projects with good pest management design often fail to achieve the planned outcomes due to inadequate project monitoring and supervision by Bank staff. Implementing agencies often take shortcuts such as eliminating farmer consultation or hiring pesticide industry representatives to provide pest management training. Such violations of OP 4.09 have direct and serious impacts on communities and their environment, and require correction by Bank project managers.

The Role of Local Communities in Monitoring OP 4.09

Communities and local non-governmental organizations can play an important role in ensuring that the design and implementation of World Bank-supported projects meet their needs and comply with OP 4.09. Local groupscan monitor and evaluate the impact of a World Bank project on their community and environment and use this information to improve the project and enhance farmers' lives.

Promoting a shift to ecological pest management can help farmers retain higher profits by spending less money on pesticides. It can also reduce pesticide poisonings of farmers and their families and reduce the risk of chronic health effects of pesticide exposure.

These monitoring efforts not only give control of local resources back to community members, but also contribute to greater transparency and accountability at the World Bank.

What OP 4.09 Requires

The World Bank's Definition of IPM

OP 4.09 defines the World Bank's objective in utilizing IPM as the main approach to pest management. The policy states:

IPM refers to a mix of farmer-driven, ecologically based pest control practices that seeks to reduce reliance on synthetic chemical pesticides. It involves (a) managing pests (keeping them below economically damaging levels) rather than seeking to eradicate them; (b) relying, to the extent possible, on non-chemical measures to keep pest populations low; and (c) selecting and applying pesticides, when they have to be used, in a way that minimizes adverse effects on beneficial organisms, humans, and the environment.

It is the responsibility of World Bank staff to assist the borrowing country in implementing a project that will promote IPM as defined in OP 4.09.

The World Bank's Strategy to Promote IPM

OP 4.09 requires the Bank to support the adoption of IPM in borrowing counties. The Bank's assessment and support for IPM is to be achieved through economic and sector work, project environmental assessments, and participatory IPM assessments.

1. Country Economic and Sector Work
The purpose of country economic and sector work is to help Bank staff gain a better understanding of the country's development strategies. In the case of agricultural development projects, the Bank should assess pest management policies, programs and problems in the larger context of the country's constraints to agricultural development. Independent monitors can examine whether,for example, projects make use of existing in-country IPM programs. If such programs are weak or lacking, monitors can determine whether the Bank has included components aimed at increasing the capacity of the national government to provide IPM training sessions, research and extension, specialists and services. Projects can also include elements that strengthen pesticide policy and facilitate enforcement of existing laws and regulations.

2. Project Environmental Assessments
Environmental assessments are critical to any project that contains a pest management component. Independent monitors should not only confirm that an environmental assessment has been performed by the Bank, but also check to see that the findings and recommendations of the environmental assessment report have been incorporated into the final project design before the onset of project implementation.

3. Participatory IPM assessments
The third method used by Bank staff to assess country capacities is participatory IPM assessments. This approach requires field visits and community and farmer input. From these field visits, Bank staff can gain valuable information on local ecology, agricultural practices and community needs that should then be incorporated into the project design. The lack of participatory IPM assessment indicates poor planning by the Bank Task Team and missed opportunities to design a better program adapted to local knowledge and conditions. The Bank project should always conduct participatory IPM assessments.

World Bank Conditions for Pesticide Purchases

In order to authorize the purchase of pesticides for Bank projects, Bank staff must ensure that their use is justified under an IPM approach. The use of pesticides alone without the context of a broader IPM plan would be a violation of Bank policy.

OP 4.09 includes criteria for the selection and use of pesticides:

1. (The proposed pesticides) must have negligible adverse human health effects.

2. They must be shown to be effective against the target species.

3. They must have minimal effect on nontarget species and the natural environment. The methods, timing and frequency of pesticide application are aimed to minimize damage to natural enemies. Pesticides use in public health programs must be demonstrated to be safe for inhabitants and domestic animals in the treated areas, as well as for personnel applying them.

4. Their use must take into account the need to prevent the development of resistance in pests.

If the criteria above are not fulfilled, then the Bank must not approve the selection and use of the proposed pesticides. For example, pesticides which can cause health problems for farmers or which can harm beneficial insects, domestic animals or wildlife must not be used. Also, any WB project using pesticides must include a clear strategy for how the project will decrease the likelihood that pests would develop resistance to the pesticides.

Furthermore, OP 4.09 restricts the purchase of particularly hazardous pesticides:

The Bank does not finance formulated products that fall in WHO Classes Ia and Ib, or formulations of products in Class II, if

• the country lacks restrictions on their distribution and use; or
• they are likely to be used by, or accessible to, lay personnel, farmers, or others without training, equipment, and facilities to handle, store, and apply these pesticide products properly.

In practice, these conditions are almost never met in borrower countries, since poor farmers rarely have access to proper training, equipment or facilities for safe use and disposal. When these conditions are not met, WHO Class Ia (extremely hazardous), Ib (highly hazardous) or II (moderately hazardous) pesticides must not be purchased.²

World Bank Standards for Pesticide Use

The World Bank's pest management policy includes strict requirements for proper handling of pesticides financed by the Bank:

The Bank requires that any pesticides it finances be manufactured, packaged, labeled, handled, stored, disposed of, and applied according to standards acceptable to the Bank.

The Bank identifies that its required minimum standards are those described by the United Nations Food and Agriculture Organization (FAO) in three documents published in 1985.³ The FAO's International Code of Conduct on the Distribution and Use of Pesticides can also provide guidance.

Monitoring Tools

This section provides a number of tools for evaluating compliance with the World Bank's pest management policy in two stages of the Bank's project cycle: design and implementation. We strongly encourage communities to tailor these tools to their specific project according to their local needs and conditions.

The tools presented in this section address four main principles of pest management required in Bank-financed projects:

• Promoting farmer-led ecologically based IPM in communities and nationally.
• Reducing reliance on pesticides.
• Ensuring that any pesticide use occurs only as a last resort and is integrated within a larger non-chemical IPM framework.
• Minimizing the impacts of pesticide use on human health, nontarget species and the natural environment.

Tools for Evaluation of Project Design

The following questions can be used as a framework to evaluate project design and can be answered by studying World Bank Project Information Documents (PIDs), Project Appraisal Documents (PADs), Environmental Assessments (EAs) and by conducting interviews with World Bank staff and project managers.⁴ It is also possible to cross-check information from World Bank sources by interviewing a subset of farmers to confirm whether they were consulted or not during the project design stage.

1. Does the project’s design promote the use of biological or environmental control methods?
Biological control methods include the use of natural enemies or beneficial organisms, such as predators, insect pathogens, and parasites. Environmental control methods include many techniques, such as cultural practices, crop rotation, and the use of pest resistant crops. The first checklist in Appendix A can be used to determine if a project is promoting biological or environmental pest management methods.

2. Does the project plan include processes or mechanisms aimed at reducing reliance on pesticides?
Paragraph 1 of OP 4.09 identifies the primary strategy for pest management in Bank projects as the use of biological or environmental control methods, and reducing reliance on chemical pesticides. The second checklist in Appendix A provides examples of different methods that local Bank projects can use to reduce farmer reliance on chemical inputs. (Determining whether those methods are actually adopted and successful is the subject of a later section, "Tools for Evaluation of Project Implementation.")

3. Do the project's processes and mechanisms promote the use of pesticides?
Bank-financed projects can be monitored and evaluated by not only looking at activities which directly promote biological and environmental control methods, but also by examining processes that might promote the use of pesticides (for example by supplying free or low cost pesticide packages to project farmers). The third checklist in Appendix A can be used to gather information on activities which promote the use of pesticides, a violation of Bank policy.

4. What is the project’s proposed method of pest management? Project Information Documents (PIDs) should identify the main pest management method. Project Appraisal Documents (PADs) should elaborate on the details of the project’s pest management approach. OP 4.09 requires the main method of pest management to be IPM—defined as "farmer-driven" and consisting of a "mix" of several control techniques, emphasizing non-chemical approaches. The provision of local/regional IPM specialists, farmer training in pest-predator population monitoring, and other IPM techniques are good indicators that the project has been designed with IPM in mind.

5. Does the project design include plans to integrate existing national IPM policies and programs?
Many countries are beginning to develop and adopt national policies and strategies for IPM. If your country has developed a National IPM Policy and/or program, be sure that the World Bank has consulted and collaborated with national offices to support and reinforce national work in IPM through the World Bank sponsored project.

6. Does the project help the national government build capacity to implement pesticide legislation and regulations and promote IPM?
World Bank projects should include elements that support national efforts to strengthen pesticide policy and regulations. They can enhance the capacity of the national government to provide IPM training sessions, research and extension, specialists and services.

7. What proportion of project costs go towards IPM and its development versus pesticides or pesticide-dependent practices?
The project budget makes up the final section of the Project Appraisal Document and provides an itemized list of what money has been allocated to various project components, including pest management training and inputs. The data included in these budgets can sometimes give monitors an idea of the proportion of Bank resources dedicated to pesticides versus IPM.

It is also helpful to check the budget for evidence that adequate resources for IPM training have been provided. If a project refers to farmer training in the text, but provides no financing for that training in the budget, monitors should ask WB staff who or what agency will provide the training and at what cost.

Note: Project budgets vary greatly from project to project and, as a result, it is not always easy to determine where funds are going and whether appropriate amounts are being allocated. Most project budgets refer to pesticides as agricultural inputs, with no clarification as to what proportion is allocated to pesticides and what portion may consist of seeds, fertilizer or other inputs. Monitors should ask WB staff to clarify how much exactly is going towards pesticides.

Tools for Evaluation of Project Implementation

The following questions can used as a framework to evaluate project implementation and can be answered through community-based monitoring and farmer surveys of both farmers participating in the WB project. It is also helpful to ask the same questions of farmers who are not participating in the World Bank project, to see whether their pest management practices are different.

1. How do farmers manage pest problems?
To determine whether the project addresses the components of IPM (defined in Footnote 4 of OP 4.09, cited on page 8 of this guide), a survey of project farmers can be conducted asking how farmers manage pests. There are several formats that can be used for this survey, but it is usually best to ask farmers open-ended questions about their practices (rather than multiple choice for example) in order to avoid influencing farmers’ responses. After the interview, farmers’ responses can then be organized into several categories for easier data analysis.

Below are examples of some questions that could be included in this type of farmer survey of pest management practices.

Question 1: When do you apply pesticides?
Answers might include:

1. by calendar (by age of crop);
2. whenever I see insects;
3. when the extensionist or pesticide salesperson says to;
4. when I think the number of pests is "too high,"
   (If this is the answer, a monitor can ask how the farmer knows when pest numbers are "too high?");
5. after observing the proportion of pests to natural enemies;
6. after using field studies to decide whether natural enemies and other ecological factors are sufficient to keep pest numbers down;
7. other

Question 2: Have you tried any non-chemical measures?
If yes, what measures are used? Were they successful? Were only short term/immediate impact measures tried (e.g. applying botanical pesticides or releasing natural enemies), or were longer term practices also used (eg. mixed cropping, crop rotations, planting food sources for natural enemies)?

2. Are farmers learning how to conduct ecologically-based integrated pest management (IPM)?
Community monitors can interview project farmers' to assess their understanding of pest ecology, IPM and local agro-ecosystems. A survey can include questions regarding the behavior of local pests, including how and when they cause damage, the existence and role of natural enemies, the effect of weather and crop plant age on pest activity, the relationship between pest numbers at different crop stages and any actual yield loss, etc.

3. Do IPM-trained farmers have increased capacity to make informed pest management decisions?
It is important to assess whether farmers apply their understanding of ecological IPM and their knowledge of the environmental and health effects of pesticides when making decisions about pest management. For example, have farmers changed their agricultural practices after participating in IPM training? If and when applying pesticides, do farmers and extensionists choose the type of pesticide and method of application (e.g., timing, frequency, etc.) that will minimize adverse health and environmental effects?

4. Do trends in pesticide use indicate that the project is reducing reliance on pesticides?
Collecting pesticide use data from both project farmers and non-project farmers is an essential step in monitoring whether or not a Bank project is reducing reliance on pesticides (as required in paragraph 1 of OP 4.09). Analyzing data on pesticide types and quantities used before and after Bank projects, and between project farmers and non-project farmers, can help clarify whether a particular Bank project is reducing or increasing farmers' reliance on pesticides.

Tables 1 and 2 in Appendix B have been developed to guide community monitors in collecting information on pesticide use.

Note: To measure "reliance," it is useful to:

• measure the increase or decrease in pesticide use (e.g. by volume, number of products, frequency of application, etc.);
• measure the increase or decrease in the proportion of farm costs going to pesticides;
• measure the increase or decrease in land area that is pesticide free.

5. Are pesticides used only as a last resort?

Use of pesticides should be strongly discouraged in Bank projects. Before introducing pesticides into agricultural projects, Bank project managers should consult with local farmers to assess the possibility of non-chemical and traditional approaches to pest problems. Long term, preventatives practices should also be incorporated into pest management strategies from the start of the project. Examples of these methods include mixed cropping, crop rotations and planting food sources for natural enemies.

If pesticides are being used in a WB project, monitors should ask farmers what effort was made by the World Bank to develop and implement non-chemical measures first. If no significant efforts to implement IPM were made, and the WB project led to increased pesticide use (whether directly, by providing pesticides, or indirectly, by allowing pesticide company representatives to promote their products through demonstrations or trainings), then the project would violate WB policy OP 4.09.

6. Is pesticide selection based on efforts to minimize impacts on human health, nontarget species and the natural environment?
Paragraph 6 of OP 4.09 outlines four criteria that must be met by any pesticides procured for any Bank project:

1. They must have negligible adverse human health effects.
2. They must be shown to be effective against the target species.
3. They must have minimal effect on nontarget species and the environment. The methods, timing, and frequency of pesticide application should minimize damage to natural enemies.
4. Their use must take into account the need to prevent the development of resistance in pests.

Additionally, OP 4.09 requires the inclusion of a list of pesticide products authorized for procurement, or an indication of how and when this list will be developed, in project documents. We strongly encourage community monitors to request this list from project managers and Bank staff as it is an essential piece of information that should be made available for public review.

Monitors should also request a written report from Bank project managers that provides justification for the selection and purchase of each pesticide, addressing the four criteria above.⁵

Finally, annual WB project reporting by government agencies (often at the provincial offices) should include the exact cost and type of any pesticides purchased for the project. Monitors should ask both WB staff and relevant government agencies for these reports and for detailed information about pesticide purchases.

7. Are pesticides being used by people without access to proper training, equipment and facilities to store, handle, and apply them safely?
Chemical pesticides should only be used by trained personnel, with protective equipment and detailed instructions for "safe" application. When supplying pesticides to project farmers, Bank staff are required by OP 4.09 to follow the standards set forth by the United Nations Food and Agriculture Organization (FAO).⁶ These FAO guidelines specify standards for pesticide product manufacturing, packaging and storage, handling and application, disposal and labeling.

However, these requirements are often overlooked when pesticides are given to farmers through Bank projects. Conditions common in developing countries often make it unlikely that farmers can follow FAO guidelines. (For example, most poor farmers cannot afford protective equipment and extreme tropical heat makes their use impractical.) It is important that Bank staff understand actual conditions in the field, avoid introducing pesticides when the FAO standards cannot be met and take steps to reduce farmers’ exposure to pesticides.

Monitors should investigate whether those who are applying pesticides have had training in their use, storage and disposal, and whether they possess and use protective equipment. Monitors can also observe storage conditions and farmers’ practices in the field. The checklist in Appendix C can be used to evaluate WB efforts to reduce farmers' exposure to pesticides.

8. Are any WHO Ia, Ib or II products included in the project pesticide packages?
OP 4.09 prohibits the Bank from financing pesticides that are classified as WHO Class Ia, Ib, or II if (a) the country lacks restrictions on their distribution and use; or (b) they are likely to be used by or be accessible to lay personnel, farmers, or others without training, equipment, and facilities to handle, store, and apply these products properly. Therefore, if project pesticides are easily available to farmers and anyone else from local markets, then the conditions for financing these pesticides have not been met.⁷

Monitors will likely find that pesticides used in a Bank project contain active ingredients that are listed as Class Ia, Ib or II. However, the final WHO classification depends upon the formulation of the product, which may result in a lower rating (if, for example, the product formulation is weak). Nevertheless, the pesticide product could still be extremely harmful, particularly if mixed with other pesticides (a common practice by farmers which often results in the creation of new dangerous by-products) and used without protective equipment. Regardless of the final classification, communities can legitimately advocate for the removal of dangerous pesticides from WB projects and the implementation of ecological alternatives.

Conclusion
Farmers, communities and local NGOs that have monitored pesticide use in World Bank projects have been able to transform harmful projects into beneficial ones. Pesticide use has been reduced in these projects and communities have lobbied for and obtained training in ecologically-based integrated pest management. As a result of their active involvement in the monitoring process, many farmers have become leaders in their communities and some have established their own NGOs advocating farmers’ rights.⁸ Communities, government officials and World Bank staff are increasingly recognizing the value of independent community-based monitoring and its potential to transform World Bank projects for the better.

Notes
1 Operational Policy 4.09, Pest Management, World Bank, Washington, DC, 1998.

2 The final classification of the toxicity of a pesticide (active ingredient) depends upon its formulation. International Program on Chemical Safety (IPCS). The WHO recommended classification of pesticides by hazard and guidelines to classification 1996-1997.

3 FAO’s Guidelines for Packaging and Storage of Pesticides (Rome 1985), Guidelines on Good Labeling Practice for Pesticides (Rome 1985) and Guidelines for the Disposal of Waste Pesticide and pesticide Containers on the Farm (Rome 1985). See Appendix D for information on how to download or order a copy of the FAO Guidelines.

4 See Appendix D for information about how to obtain these documents.

5 For information on pesticide toxicity, human health hazards, effects on nontarget species, etc, see PANNA’s pesticide database, available at http://www.panna.org

6 See Appendix D for information on how to download or order a copy of the FAO Guidelines.

7 For information about which pesticides are classified as WHO Ia, Ib and II, contact the World Health Organization or see www.pesticideinfo.org.

8 For example, see Ishii-Eiteman, M & J. Hamburger. 2001. Taking the World Bank to Task: a case study of successful community-based monitoring in Indonesia. Global Pesticide Campaigner April 2001, vol. 11, no. 1.

Appendix A. Monitoring Tools: Pest Management Indicators

Appendix B. Monitoring Pesticide Use

Table 1. Pesticide Use Averages by Pesticide Type (eg. insecticides, fungicides, herbicides

Table 2. How many times do farmers spray their fields?
Project Farmers

Non-Project Farmers

_____________________________
Tables adapted from the community based monitoring surveys conducted by Yayasan Duta Awam (Indonesia, 1997-1998).

Appendix C. Monitoring the Storage and Handling of Pesticides and Use of Protective Gear

Packaging & Storage Requirements