For usaid funding of locust or grasshopper pesticide usage




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SUPPLEMENTAL ENVIRONMENTAL ASSESSMENT (SEA)

FOR USAID FUNDING

OF LOCUST OR GRASSHOPPER PESTICIDE USAGE

IN SUDAN

USAID KHARTOUM   OCTOBER 1990
PREFACE
This Supplementary Environmental Assessment (SEA) for Sudan Locust/Grasshopper Control was prepared by USAID/Khartoum in cooperation with AID/OFDA, AID/AFR and the Government of Sudan. Contact persons that contributed information provided herein are listed in Appendix A.
The final draft has been internally reviewed by USAID/Khartoum, AID/AFR/TR, and AID/OFDA. Selected sections were reviewed by agricultural and environmental specialists in the Government of Sudan and the Institute of Environmental Studies. This document reflects the best current description of future directions for locust and grasshopper control in Sudan, estimates of environmental risks and benefits, and human safety. Recommendations are provided to ameliorate control practices and to mitigate potential adverse environmental impacts.

TABLE OF CONTENTS
SECTION PAGE
PREFACE 2
ACRONYMS

ABBREVIATIONS

LOCAL WORDS
1.0 EXECUTIVE SUMMARY 9
2.0 PURPOSE 13
3.0 ENVIRONMENTAL POLICY AND LEGISLATION
3.1 USAID Environmental Policy and Legislation 15

3.2 Sudan Environmental Policy and Legislation 16



4.0 SCOPING PROCEDURE 17
5.0 LOCUSTS AND GRASSHOPPERS OF THE SUDAN
5.1 Desert Locusts 18

5.2 Tree Locusts Patterns of Outbreaks; 24

5.3 African Migratory Locusts Migration; 24

5.4 Red Locusts Breeding Patterns 24

5.5 Sudan Plague Locusts 25

5.6 Grasshoppers 25


6.0 AGRICULTURAL PRODUCTS THREATENED BY LOCUSTS/GRASSHOPPERS
6.1 Sudanese Agricultural Products 25

6.2 Assessment of Crop Losses 27


7.0 DESCRIPTION OF THE ENVIRONMENT
7.1 Habitat where Locusts and Grasshopper occur 29

7.2 Characteristics of the Affected Terrain 31

7.3 Human Population and Distribution 45

7.4 Agricultural Resources and Land Use Patterns 47

7.5 Forestry Resources 49

7.6 Parks and Protected Areas 51

7.7 Critical Habitats 54

7.8 Species of Wildlife 56

7.9 Bees 62
8.0 LOCUST AND GRASSHOPPER CONTROL
8.1 Role of PPD in Sudan 61

8.2 Structure and Staffing of PPD 65

8.3 GOS Funding for PPD Activities 68

8.4 Pesticide Selection in Sudan 62


9.0 SURVEY PROCEDURES 72
9.1 Terrestrial Surveys 75

9.2 Aerial Surveys 75

9.3 Satellite Imagery 76

9.4 Forecasting 76


10.0 LOCUST CONTROL PROCEDURES 74
10.1 Present PPD Operational Procedures 76

10.2 Notification of Spraying Operations 80

10.3 Equipment Selection, Training, Calibration and Maintenance 81

10.4 Areas Sprayed in Recent Campaigns 82

10.5 Spray Operation Costs 85
11.0 PESTICIDE HANDLING, SAFETY AND DISPOSAL PROCEDURES
11.1 Transport and Handling 87

11.2 Protective Clothing 87

11.3 Pesticide Storage and Security 88

11.4 Disposal of Unused Pesticides and Emptied Drums 88


12.0 POTENTIAL PESTICIDE HAZARDS TO HUMANS, LIVESTOCK AND WILDLIFE 92
12.1 Extent and Locality of Areas to be Treated 90

12.2 Water Contamination 91

12.3 Contamination of Crops 93

12.4 Contaminated Vegetation 95

12.5 Human Consumption of Locusts 95
13.0 HEALTH ISSUES
13.1 Health Infrastructure and Related Issues 96

13.2 Cholinesterase Testing 97


14.0 MONITORING 103
14.1 Pesticide Monitoring Infrastructure 98

14.2 Monitoring Environmental Impacts 99

14.3 Monitoring Residues 100
15.0 MINIMIZING PESTICIDE USAGE 107
15.1 Timeliness of Interventions 101

15.2 Timing, Method and Efficacy of Surveys 102

15.3 Use of Greenness Maps 104

15.4 Defining Economic Thresholds 104

15.5 Targeting of Sprays 107

15.6 Use of Appropriate Equipment and Pesticides 108

15.7 Integrated Pest Management 108

15.8 Traditional Controls 110

15.9 Non Chemical Control 111
16.0 RISKS AND BENEFITS OF PESTICIDE USE 121
17.0 ALTERNATIVE OPTIONS FOR USAID INVOLVEMENT
17.1 Potential USAID Roles 114

17.2 Past USAID Assistance 115

17.3 Future Funding Options for USAID 116
18.0 SUMMARY OF CONCLUSIONS AND RECOMMENDATIONS 116
19.0 OTHER ENVIRONMENTAL ASSESSMENTS AND BIBLIOGRAPHY 145
APPENDIX A List of Compilers and Persons Consulted
APPENDIX B Comparison of Conclusions with PEA Recommendations
APPENDIX C Administrative and Institutional Infrastructure 50
APPENDIX D Other Major Pesticide Usages in Sudan

LIST OF FIGURES
Fig. 1 Sudan   Towns, Administrative Regions, Railways 14

Fig. 2 Desert Locusts: Summer Breeding Areas 19

Fig. 3 Desert Locusts: Winter Breeding Areas 20

Fig. 4 Desert Locusts: Spring Breeding Areas 21

Fig. 5 Desert Locusts: Recorded Gregarization Sites 23

Fig. 6 Gum Arabic Areas 30

Fig. 7 Geology 33

Fig. 8 Rainfall 35

Fig. 9 Ground Water Basins 39

Fig.10 Soils 41

Fig.11 Vegetation 43

Fig.12 Population Distribution 46

Fig.13 Parks and Reserves 53

Fig.14 PPD Stations, Stores and Radios

Fig.15 Land use Zones

LIST OF TABLES
Table 1. Crops Produced in Sudan 26

Table 2. Locust Damage to Crops 27

Table 3. Livestock Production 28

Table 4. Vegetation Zones of Sudan 42

Table 5. National Parks and Wildlife Reserves 52

Table 6. Rare and Endangered Animals 58

Table 7. Rare and Endangered Birds 59

Table 8. Categories and Numbers of PPD Staff 64

Table 9. Pesticides Used in Sudan for Locust Control 71

Table 10. PPD Pesticide Stocks 77

Table 11. PPD Locust Control Resources 78

Table 12. Resources Used for Locust Control 83

Table 13. Pesticides Usage 84

Table 14. Desert Locust Campaign Costs 85

Table 15. Types of Health Care Facilities 96

Table 16. Minimum Population Thresholds 106



LIST OF CHARTS
PPD Organization and Structure 68
ACRONYMS
AFR/TR USAID Africa Bureau/Technical Resources Section

ARC Agricultural Research Corporation

CFR Code of Federal Regulations (US)

DANIDA Danish Aid Agency

DLCC Desert Locust Coordinating Committee

DLCO EA Desert Locust Control Organization   East Africa

EC Emulsifiable Concentrate

ECLO Emergency Center for Locust Operations (FAO Rome)

EEC European Economic Commission

EPA US Environmental Protection Agency

FAA Foreign Assistance Act

FAO Food and Agriculture Organization of the United Nations

FEWS Famine Early Warning System

FINIDA Finnish Aid Agency

GOS Government of Sudan

GTZ German Aid Agency

IES Institute of Environmental Studies (University of Khartoum)

IPM Integrated Pest Management

IRLCO CSA International Red Locust Control Organization for Central and Southern Africa

ITCZ Intertropical Convergence Zone

LS Sudanese Pounds

MFEP Ministry of Finance and Economic Planning

MOAANR Ministry of Agriculture, Animals, and Natural Resources

MOH Ministry of Health

NGO Non Governmental Organizations

NPC National Pesticides Committee

OCLALAV Organization Commune de Lutte Antiacridienne et de Lutte Antiaviare

ODA Overseas Development Agency (U.K.)

OFDA Office of U.S. Foreign Disaster Assistance

PEA Programmatic Environmental Assessment

PPD Plant Protection Department

PRIFAS Program de Recherches Interdisciplinaire Francois sur les Acridiennes du Sahel

PSI Pounds per Square Inch (pressure)

RRC Relief and Rehabilitation Commission

SEA Supplementary Environmental Assessment

SEPS Sudanese Environmental Protection Society

SRAAD Sudan Reforestation and Anti Desertification Project

UK United Kingdom

ULV Ultra Low Volume

UNDP United Nations Development Program

UNEP United Nations Environmental Program

USAID United States Agency for International Development

AID/W United States Agency for International Development/Washington

USG U.S. Government

USGS U.S. Geological Survey

WP Wettable Powder


ABBREVIATIONS
ha Hectares

km Kilometers

m Meter

mm Millimeters



MT Metric Tons

N/A Not Available


GLOSSARY OF LOCAL WORDS
ANIS (ADAR) Sorghum purpureosericeum (grass)

BATTIKH Melons

BULTI Tilapia (fish)

DAHASSIR Indigofera oblongifolia (legume)

DUKHN Bullrush/Pearl Millet (Pennisetum typhoideum/glaucum)

DUMBARI Local "Magicians" who profess to dispel locust hordes

DURA Sorghum

EJIL Nile Perch

GARDUD Patches of hard impervious sand bound by silts, clays, and mineral deposits

GEBASH (DAMBELAB) Schoenfeldia gracilis (grass)

GOZ Sands of desert origin

HABOOB Dust storm

HAFIR Artificial catchment ponds in gardud and silt soil

HASHAB Acacia senegal (tree)

HEGLIG Balanites aegyptica (tree)

HESKANIT Cenchrus biflorus (grass)

JEBEL Mountain, rocky hill

KARKADEH Hibiscus sabdariffa

KHOR Small dry watercourse

KITR Acacia mellifera (bush)

LAOT Acacia nubica (= A.orfota) (bush)

MARAKH Leptadenia pyrotechnica (bush)

MATAMURA Traditional grain storage pits

MAYAA Marshy natural depression

MOKHET Boscia senegalensis (tree)

NAR (NAAL) Cymbopogon nervatus (grass)

RAHAD Large seasonal water holding natural depression

SIDR Ziziphus spina christi (tree)

SIHA Blepharis persica (herb) (=B. edulis)

SIMSIM Sesame

SUNT Acacia nilotica (tree)

TALH Acacia seyal (tree)

TARFA Tamarix aphylla (bush)

TUMAN Panicum turgidum (grass)

TUNDUB Capparis decidua (bush)

WADI Seasonal river bed




1.0 EXECUTIVE SUMMARY
This Supplementary Environmental Assessment (SEA) provides information that is in addition to the content of the Programmatic Environmental Assessment on Locust/Grasshopper Control in Africa/Asia (PEA) (TAMS/CICP 1989). It examines potentially adverse environmental consequences from various factors which are involved in the selection and use of pesticides for locust and grasshopper control in Sudan, discusses the risks and benefits of such control operations, lists the options for USAID involvement, and makes recommendations for optimizing safe application of pesticides.
Sudan is the largest country in Africa, with an area of approximately 2.5 million sq. km., being 1800 km long and 1500 km wide. It has rainfall varying from less than 50 mm in the north to 1200 mm in the southern mountains. Locusts and grasshoppers, such as desert locusts in particular, have been periodic pests occurring in plague numbers at irregular intervals, primarily in the northern half of Sudan above latitude 10 degrees North, causing damage to the agricultural production and economy of Sudan. Sudan is at the hub of the overall range of desert locust and is of special importance in the population dynamics of this locust. This is because summer and winter rainfall regions can alternatively harbor a succession of generations.
At present, successful control strategies require the use of some chemical pesticides. Though the pesticides selected for use are ones that are optimal for reducing the risk to human health and the environment, some risk remains. Therefore, to minimize risk, the following recommendations will be implemented in connection with any USAID-supported control program.
PPD, DONOR, AND REGIONAL COOPERATION
1. Donor committee meetings will be convened weekly during major campaigns, and twice a year during recession. The Plant Protection Department (PPD) will be encouraged to exchange information directly with the crop protection services in neighboring countries, to work with the Customs Department to expedite the importation of equipment and pesticides, to obtain international overflight agreements through the Ministry of Foreign Affairs, to support the coordinating efforts of DLCO-EA and to appoint headquarters/field liaison officers.
SURVEY
2. Strategic control will be used to prevent plague conditions. This will be supported through the use of greenness maps, egg pod surveys, monitoring diseases and parasites, standardized survey forms, properly trained and equipped field scouts, and the encouragement of nomads' and local villagers' reporting.
PESTICIDE SELECTION
3. The pesticides to be used will be limited to the currently PEA approved chemicals--malathion, diazinon, carbaryl, fenitrothion, chlorpyrofos, propoxur, bendiocarb and lambda cyhalothrin--until others are approved by AID/W. Others, such as deltamethrin and acephate, should be screened for possible inclusion on the approved list. No pesticides will be accepted unless labeled according to USEPA standards in Arabic and English.
4. A pesticide bank will be used to provide a choice among pesticides and to avoid overstocking at any given location.
5. Farmer brigades will be used but will only be supplied with dusts and baits, unless they are properly trained for application of liquid formulations.
PESTICIDE STORAGE AND HANDLING
6. All PPD pesticide storage sites will be securely fenced, guarded, posted with "NO UNAUTHORIZED ENTRY" and "HAZARDOUS MATERIALS" signs in Arabic and English and periodically inspected. All pesticides will be kept in a sheltered, well ventilated enclosure with a cement floor, and stacked on wooden pallets. Storage facilities will have first aid kits, showers, soap, a means of washing safety clothing, and lime for neutralizing organophosphate pesticide spills.
7. A system for regular inventory of pesticide stocks will be put into practice to minimize pesticides becoming obsolete. Pesticides types will be kept separate from each other and from non-pesticide stores, used on a first-in/first-out basis, and analyzed if of dubious quality. Liquid carbaryl formulations will be rolled monthly to prevent excessive viscosity.

HEALTH PROTECTION
8. PPD, the Ministry of Health, and the Agricultural Extension Administration, with donor assistance, will design and issue posters and bulletins on pesticide safety and poisoning to all field stations, rural clinics and hospitals. All spray operations will be preceded by local public radio notification.
9. All applicators and handlers will have two sets of light weight, long-sleeved, tight weave cotton coveralls suited to Sudan's climate, a respirator (with replacement filter cartridges), durable plastic or rubber gloves with forearm length gauntlets, a face shield, hard hat, and rubber boots (not to be cut to ankle length). Employees displaying pesticide toxicity symptoms will be reassigned to other duties and will not be laid off.
10. Each spray team will have a water tanker to provide adequate water for washing of persons, clothes and equipment; instruction posters and guidance manuals; and at least one person trained in health procedures, and equipped with cholinesterase test kits and antidote (atropine). Cholinesterase testing should be done routinely for handlers and applicators.
11. Post spray harvest delay intervals will be closely observed when crops are sprayed and the public will be forbidden to market and consume locusts during campaigns. Livestock will be removed prior to treatment and kept out for at least two days after treatment.
12. Specific actions and prohibitions will be followed to minimize pesticide use, for example, a favorable cost/benefit ratio will be the basis for all decisions to treat (and MOAANR and PPD must make every possible effort to improve data collection so that more credible cost/benefit estimates can be made in the future), no blanket spraying will occur in marginal pastures and croplands on a prophylactic basis, all spraying will be targeted and be based on economic and biological considerations (e.g., spraying will not take place after grain crops have passed the "hard dough" stage of maturity, nor after females have laid their eggs), and smaller aircraft will be favored to facilitate precision applications. Large scale application will be forbidden in areas with vulneralbe groundwater and restrictions will be applied to treatment near wadis and river beds even when they are dry. In addition, limits will be placed on total proportion of locust and grasshopper populations that are treated in order to allow the building of natural diseases and parasites.
13. Pesticide application will be conducted in early morning with no more than light winds to treat swarms before flight, to minimize volatilization of spray droplets in warmer temperatures, and to avoid excessive drift.
DISPOSAL OF UNUSABLE PESTICIDES AND EMPTY CONTAINERS
14. Empty pesticide drums will be stored in securely fenced and guarded areas until punctured and crushed or reconditioned technology becomes available.
15. Unusable pesticide stocks will be concentrated at a single, secure location until they can be destroyed. In view of a recent USAID efforts in northern Pakistan and in Niger, options for incineration of Sudan's obsolete pesticides will be vigorously explored.
16. Each PPD field station, pesticide/equipment storage facility, and airstrip will be equipped with a concrete apron around a sump for washing equipment and flushing spray tanks, and a means of puncturing and crushing empty drums.

ENVIRONMENTAL PROTECTION
17. The appropriate GOS Ministries will be encouraged to delegate overall environmental responsibility to one Ministry and to establish a central environmental monitoring function. Appropriate staff will monitor pesticide impacts on fauna and flora. Guideline protocols for monitoring will be developed and used.
18. Existing National Parks will be clearly defined and protected from spraying. Pesticide use also will not occur in the remaining patches of natural vegetation on Jebel Mara, in other fragile or limited ecosystems, or within 2.5 km of riverine and other aquatic habitats.

PPD spray and survey teams will file reports with Wildlife Research and Wildlife Conservation Forces on the presence or absence of rare species in remote areas and surveys of endangered species and critical habitats will be conducted.


19. Fenitrothion and diazinon will not be used for spraying tree locusts or other species in Forest Reserves and in riverine habitats because of the danger to birds and aquatic life. Pesticides that require mixers, loaders and applicators to wash after use will not be used in desert areas unless a means to wash is also provided.
20. Five per cent of the value of all pesticide donations and purchases will be put into a fund devoted to environmental monitoring and research within Sudan. This will be in addition to research conducted elsewhere that may have relevance in Sudan.
21. PPD will map the localities and record the areas of crops and rangeland sprayed each year and note the types and quantities of each pesticide applied to provide supportive data for long term monitoring.
TRAINING
22. PPD will require in service refresher training needs for all categories of staff and will arrange this on a regular and systematic basis. Administrative management training will be incorporated into the training program. PPD will be encouraged to create a training organization to ensure that appropriate training occurs.
23. Farmers will receive extension education on pesticide safety, selection, calibration, locust and grasshopper identification, band/swarm size estimation, IPM principles, and environmental concerns.
24. Wildlife Research and/or Wildlife Conservation Forces will train PPD staff on identification of birds, animals and plants, with special reference to rare species. Wildlife field guides, environmental literature, and video tapes, will be obtained for training PPD staff.

25. Farmers in areas subject to heavy Senegalese grasshopper infestations will be encouraged to replace part or all of their millet plantings with sorghum because of the greater resistance to damage.



RESEARCH NEEDS
26. An international field research station, run in conjunction with PPD, will be established at an appropriate location for the study of locusts and grasshoppers. Studies could include locust and grasshopper biology, dynamics of diseases and parasites, effects on crops (including yields of gum arabic and tree browse), control measures (such as a selective barrier spray, improving the use of crop residues in bait formulations, Neem extract as an anti feedant), environmental impacts of various pesticides (including effects on soil microorganisms, nitrogen fixing bacteria and phytotoxicity), environmental fate (persistence, breakdown rates, and metabolites). USAID will participate in the support of such a field research station at such a time as current USG restrictions are lifted.
ADMINISTRATIVE
27. The Africa Emergency Locust/Grasshopper Assistance program (AELGA) has been extended by AID/W in order to have a continuing program. Research on microbial and chemical detoxification of pesticides, including banned organochlorine compounds, will be encouraged.
Other detailed recommendations on operations and on research for disposal of undesirable pesticides and empty drums appear in section 20 of this document.

2.0 PURPOSE


Because locusts and grasshoppers are an integral part of the Sudan- Sahelian biota, the Sudan (Fig. 1) will likely always require management of locusts and grasshoppers to prevent losses to agriculture. Periodic control operations will be required during plague episodes with probable need for USAID sponsored technical assistance, pesticides, survey and application equipment and services, and/or greenness maps.
For the near future, the use of anti locust-and-grasshopper pesticides will likely be required. The environmental procedures in the Code of Federal Regulations (22 CFR 216) must be followed to permit USAID assistance. This document reports the steps that have been, and need to be, followed to fulfill the requirements of 22 CFR 216 environmental procedures. For the present, USG pesticide donations will require technical assistance at the storage, transport, application, and disposal phases where U.S. contributions are concerned, in order to adhere to the recommendations herein.
Dummy page for Fig. 1. Admin areas of Sudan
3.0 ENVIRONMENTAL POLICY AND LEGISLATION
3.1 USAID Environmental Policy and Legislation
As a response to the increasing world wide concern about environmental issues, USAID funding is contingent on adhering to stringent environmental procedures. The disbursal of USAID funds for any activity is conditional upon the completion of a satisfactory Environmental Assessment prior to pesticide procurement or use and on the implementation during procurement or use of any safeguards and mitigation outlined in the Environmental Assessment. The regulations also require that host government regulations and procedures be followed.
These requirements are to ensure that environmental consequences of USAID financed activities are identified and considered by USAID and the host government prior to implementation. Possible environmental impacts are considered during USAID project planning and are used to design environmental safeguards and mitigation.
As the injudicious use of pesticides can have serious environmental consequences, USAID funding for pesticides, or their application, is particularly subject to scrutiny and approval. This document indicates how environmental impacts were evaluated to assess the desirability of future support for pesticide use, while maintaining the commitment to preventing environmental degradation as required by title 22 of the Code of Federal Regulations, Part 216, "AID Environmental Procedures." Regulation 216 sets out in detail the required procedures for environmentally sensitive AID assistance for pesticide procurement or use and is the basis for the environmental assessment.
Initially, potential environmental impact was assessed in a Programmatic Environmental Assessment (PEA) for Locust and Grasshopper Control in Africa/Asia (TAMS/CICP 1989) which covered locusts and grasshoppers control in Africa and the Middle East but which is not country specific. USAID Environmental Procedures require "subsequent Environmental Assessments" for individual actions when there may be significant environmental impacts in specific countries not adequately addressed in a programmatic assessment. The PEA's general breadth precluded an individual assessment of conditions in the Sudan. A determination was made that supplementary environmental assessments are necessary for all countries with significant locusts and grasshoppers control programs prior to pesticide related USG financed assistance. It is expected that the Sudan will be a recipient of USG contributions for locusts and grasshoppers operations in the future. This document is designed to fulfill the need for a "subsequent environmental assessment" for the Sudan. It is a supplement to the PEA, specific to the Sudan.
The most significant other environmental assessments, as well as other relevant literature, are listed in section 19.0. In addition, during the three years that AID Khartoum has been closely involved with desert locusts control campaigns in Sudan, this office has acquired a considerable store of literature and data covering all aspects of locust biology, control procedures, and pesticide data. It has also had the benefit of the knowledge and expertise of various international consultants who have been contracted to provide advice, and whose reports are on permanent file in the Mission office.
3.2 Sudan Environmental Policy and Legislation
Deterioration of the environment (desertification, deforestation, drying of wells, soil salinity, river siltation, elimination of larger forms of wildlife, etc.) in the northern half of Sudan is widespread and widely recognized. It has touched the lives of the entire population in one way or another. The appropriate Government of Sudan (GOS) officials are fully aware of these serious environmental problems.
The Ministry of Agriculture, Animals and Natural Resources (MOAANR), is the relevant GOS Ministry with responsibility for land use and natural resources, but not specifically for environmental issues. This Ministry deals with these policy issues at the national level. In the early 1980's a start was made (principally in Kordofan and Darfur), to decentralize administration of these functions to the local Regional Governments. Successive GOS regimes have made token attempts to address the desertification and degradation issue, most notably by the establishment of the Desertification and Rehabilitation Administration in the MOAANR, and later upgrading it to Commission status in response to greater urgencies at the time of the 1984/85 drought and the resultant mass population displacement, as well as displacement caused by the civil war. These issues currently appear to be of rather limited concern to the Relief and Rehabilitation Commission (RRC), as it is now termed, as their attention is presently focussed on war related relief measures.
In addition, within the MOAANR there also exists the Land Use, Soil Conservation and Water Programming Administration (now largely inactive), the Range and Pasture Administration, and the Forestry Administration (currently being converted into a parastatal corporation), all of which have land use and environmental responsibilities. The majority of senior staff in these organizations are reasonably well qualified. Most of the GOS administrations have been effectively grounded for some years due to the appalling state of Sudan's economy, the run down infrastructure, and the vastness of the country.
The Sudanese National Council for Research formerly had a National Committee for the Environment during the period that the United Nations Environmental Program (UNEP) had an office in Khartoum. This was an informal advisory committee, and its functions ceased when the UNEP office closed; the functions were subsequently taken over by the RRC in 1986. At about that time, a proposal to form a Ministerial Council to deal with environmental issues was made but it was unsuccessful.
Sudan does not have a specific Environmental Act, and there is no legal requirement for Environmental Assessments to be undertaken for proposed new projects or for environmental monitoring. The Sudan Environmental Protection Society (SEPS), an NGO active in Sudan, organized a seminar in June 1988 on legislation and environmental issues, and drafted an environmental policy act, but due to frequent Ministerial shuffling in the previous regime, and the over riding concerns of the civil war and the economic crisis, there was no official follow up. The coup in June 1989 installed a new set of Ministers and officials in senior posts, but with the previous crises still unresolved, and with a continuing purge of staff in all Ministries, it is unlikely that any new environmental legislation will be enacted in the near future.
Apart from the Sudanese Pesticides Act, the legislation that most closely addresses environmental issues in Sudan is the Environmental Health Act 1975 (Vol.9, P.273), and to a lesser extent, the Public Health Act, (Vol.9, P.220). The latter deals with routine human health matters. The former is more oriented to general environmental concerns, with an emphasis on human health safeguards, such as protecting water supplies from contamination, air pollution prevention, garbage disposal, siting of industries, etc. It could, with amendments, be extended to cover additional forms of environmental degradation. The Act imposes obligations on People's Councils to issue regulations and instructions for the implementation and enforcement of the Act's objectives, but without guidelines as to how this should be done. However, their enforcement is not really feasible given the prevailing situation in Sudan, and the lack of trained personnel to ensure compliance.
With respect to pesticides, it therefore remains largely with senior staff in PPD and the National Pesticides Committee (NPC) to ensure that steps are taken to avoid any associated environmental contamination. As the Director General of PPD is the Registrar for the Pesticides Act, the responsibility for ensuring compliance by members of PPD, in addition to other pesticide users, is vested very firmly with the incumbent of that office. SEPS acts as a useful watchdog insofar as it has the capacity to monitor various activities in Sudan.

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