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Evaluación de Medio Término del "Programa Nacional para la gestiòn ambientalmente racional y la gestión en el ciclo de vida de sustancias químicas"
Commissioning Unit: Ecuador
Evaluation Plan: 2019-2022
Evaluation Type: Project
Completion Date: 06/2021
Unit Responsible for providing Management Response: Ecuador
Documents Related to overall Management Response:
 
1. Recommendation:

The institutional problems and imposed restrictions by the pandemic have affected the implementation of the project, which is observed in lower than initially estimated disbursements as well as in the delay of some key results and the need to reformulate some of them, so it is possible that they will not be achieved at the end of the project (March 2023). Therefore, it is suggested to evaluate, by the end of 2021, whether the project will be able to achieve its objectives within the deadlines stipulated in Prodoc to make the necessary corrections, if applicable.

Management Response: [Added: 2021/08/04]

The recommendation is welcomed.

In the second half of 2021, the project will evaluate the completion of the objectives within the Prodoc established deadlines. Activities that can be implemented simultaneously will be identified in order to accelerate implementation through a well-defined strategy and prioritization of activities and products.

Within this context, the Program will develop a strategy during the second half of 2021 to achieve the macro goals, and where the prioritized measures and products to reach those goals will be established, accompanied by SMART indicators for internal use for M&E.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Develop the roadmap for implementing and monitoring the new work program.
[Added: 2021/08/04] [Last Updated: 2022/06/28]
UNDP Project Implementation Unit 2022/03 Completed The achievement of the objectives was evaluated. The work program with SMART indicators and the strategy by component were formulated. In the preparation of the POA 2022, the prioritization of activities was carried out. To speed up implementation, follow-up meetings are held fortnightly, supported by a checklist of activities carried out and planned. History
2. Recommendation:

There are indicators that are not adequate to measure the progress of the project, but they cannot be changed due to the extended review process by the GEF. It is suggested to clarify and specify their meaning and scope, and to adjust their targets if necessary, such as, for example, the 35 kg/year reduction of Hg, the 30 ton of "releases of new POPs" or whether the financial enhancement plans for national reports should have permanent budget lines and a follow-up on how the new knowledge acquired is used.

Management Response: [Added: 2021/08/05]

The recommendation is welcomed.

We consider the premise that it is not feasible to change indicators before the GEF. For this reason, a work program with SMART indicators will be developed and implemented with regard to products, to clarify and specify their meaning and scope, which correspond to the performance indicators, as established in Prodoc. In addition to the tool to track their implementation.

It is important to mention that this disaggregation of information by indicator will be useful only to better argue the achievement of each result established before the GEF; therefore, it will enable the internal monitoring of the project and its partners part of the Steering Committee.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Develop the roadmap for implementing and monitoring the new work program.
[Added: 2021/08/05] [Last Updated: 2022/06/28]
MAATE MERNNR UNDP PROJECT IMPLEMENTATION UNIT 2022/03 Completed The achievement of the objectives was evaluated. The work program with SMART indicators and the strategy by component were formulated. In the preparation of the POA 2022, the prioritization of activities was carried out. To speed up implementation, follow-up meetings are held fortnightly, supported by a checklist of activities carried out and planned History
3. Recommendation:

Progress reports do not clearly reveal the project challenges or the level of implementation of some key outcomes; for example, the elimination of Hg in luminaires and other products, remediation of contaminated sites through the Health Care Registry Platform (PRAS), the elimination of new POPs, the adoption of the MCI, loans to ASM, assistance to the 5 processing plants and the laboratories associated with them. Reporting according to progress towards the results based on established partnerships, responsibilities of each partner and, of course, specific indicators associated with products and intermediate results to be defined in a work program is suggested.

Management Response: [Added: 2021/08/05]

The recommendation is not accepted, since the mid-term goals are accomplished based on the indicators established in PRODOC.

As previously mentioned, the Program will be developed and implemented with SMART indicators at the product level that respond to the outcome indicators, based on Prodoc. It will be possible to measure progress, more objectively towards the result.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Actions detailed in previous recommendations 1 and 2.
[Added: 2021/08/05] [Last Updated: 2022/01/31]
MAATEC MERNNR UNDP Project Implementation Unit 2021/12 Completed In the PIR 2020-2021, achievements and challenges were drafted in a balanced manner. Progress was reported based on indicators and intermediate results. Now that the work program is in place, the same will apply to the upcoming reports. The knowledge management strategy has been developed, and in the next few days it will be sent to the partners for validation. History
4. Recommendation:

For the second stage of implementation, the project must have a strategy of approaching its partners in terms of involving those officials with more opportunities of institutional continuity, in the design, planning and review of consulting reports that are relevant to them. This approach should be based on a mutually agreed work agenda, with specific activities, responsibilities and results, so that officials are committed and directly involved with the results of the project.

Management Response: [Added: 2021/08/05]

The project  partially accepts this recommendation because it has no way of knowing whether or not the delegates will stay in their jobs.

However, a knowledge management strategy will be developed and implemented that includes working with multilevel actors and with a focus on their own characteristics.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Achieve the knowledge management strategy.
[Added: 2021/08/05] [Last Updated: 2022/06/28]
MAATEC MERNNR UNDP MSP Executing unit of the project. 2022/12 Initiated The knowledge management strategy is in a process of design and development. It will be sent to the partners for validation when ready. History
5. Recommendation:

Establish a new approach based on priorities, focused on products and services that have a clear relationship with the expected results, without dispersing efforts to other proposals, while ensuring the adoption of current ones, eliminating non-fundamental products and activities. It is suggested to focus on approving the already proposed  regulatory instruments, Hg elimination strategy and new POPs in products, identify and analyze at least two additional contaminated sites before ending this activity, increase in the collection of empty pesticide containers, MAPE credits, exit strategy; please see the regulation of surface water pollution in ASM.

Management Response: [Added: 2021/08/05]

The recommendation is partially accepted, because most of the activities indicated are carried out in accordance with the provisions of Prodoc.

However, the work program development process, mentioned in recommendations No.1 and 2, will also include an analysis of outputs and activities with a priority approach, identifying those that directly add value to the project results, those that are supportive and those that do not add value. 

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Actions detailed in previous recommendations 1 and 2.
[Added: 2021/08/05] [Last Updated: 2022/06/28]
MAATEC MERNNR UNDP Executing unit of the project. 2022/03 Completed Please see the status in recommendations 1, 2 and 3 above History
6. Recommendation:

The above-mentioned  approach should be associated with a new structure of the work team, aimed at advising and supporting the partners rather than directly implementing the actions. It is suggested to reformulate the working strategy with the project partners and decentralize the execution of certain key results, based on an analysis of the needs of the partners to meet established goals. Specifically, there is a proposal  to enable the  integration of a consultant in the MERNNR and another in the MSP that respond to the executing team and the institution that hosts them, so that he or she can directly interact with them.

Management Response: [Added: 2021/08/05]

The suggestion is partially accepted, because it can be implemented only with the approval of the steering committee and the consent of the state ministries involved.

The proposal will be to hire three (3) professionals as individual consultants, at the advisory level, to join MERNNR MAATEC, and MSP, respectively.

The objective of these recruitments will be to have a point of support within these institutions so that the processes of the project (product approvals, officialization of ministerial agreements, viability of new processes, sustainability, among others) are streamlined.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
-Present this suggestion to the Steering Committee.
[Added: 2021/08/05] [Last Updated: 2022/06/28]
MAATEC MERNNR UNDP. 2022/03 Completed The Steering Committee approved the hiring of 3 individual consultants (IC), two for MAATE and one for MERNNR. MAATE: The CI for support to Pesticides is already working. The CI to support chemical substance procedures is working as well. MERNNR: the IC is selected, is working. MSP: this entity is not working with the PNGQ. Therefore, in the steering committee in December, it was approved to replace this partner with the IESS, with whom various activities are being developed. There will be no hiring of support personnel for this entity History
-Coordinate this action with the focal points of MERNNR, MAATEC and MSP, and obtaining their approval.
[Added: 2021/08/05] [Last Updated: 2022/06/28]
MAATEC MERNNR UNDP 2022/03 Completed The Steering Committee approved the hiring of 3 individual consultants (IC), two for MAATE and one for MERNNR. MAATE: The CI for support to Pesticides is already working. The CI to support chemical substance procedures is working as well. MERNNR: the IC is selected, is working. MSP: this entity is not working with the PNGQ. Therefore, in the steering committee in December, it was approved to replace this partner with the IESS, with whom various activities are being developed. There will be no hiring of support personnel for this entity History
7. Recommendation:

It is suggested to perform an analysis on how to integrate the CDP and /or other participatory instances of the project to other institutions that are considered relevant for the second stage of implementation of the project, such as the MSP, Customs or COMEX, and improve the balance between MAATEC and MERNNR, either as permanent members or as guests.

Management Response: [Added: 2021/08/05]

The suggestion is partially accepted, because it can be implemented only with the approval of the steering committee.

The decision to invite the members of the technical working groups as advisors, with a voice without a vote, will be submitted to the steering committee for approval, considering that the structure of the steering committee is established in Prodoc.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Include the motion in the next steering committee (possibly August 2021).
[Added: 2021/08/05] [Last Updated: 2022/06/28]
UNDP, MAATEC, MERNNR. Project implementation unit 2022/04 Completed The steering committee did not approve the integration of other entities into this committee, because in this way the objective of leveraging the PNGQ is not achieved. This would be achieved by activating the Environmental Quality Committee, for which the recommendation of the CD is that the PNGQ motivates the first meeting of the committee and the approval of its regulations. This was achieved on December 8. History
8. Recommendation:

It is suggested that the working groups be formalized and that they have their own representatives to accompany the project team in the meetings of the CDP or other instances to be defined. In this regard, the performance of the current working groups and the formation of ad-hoc groups (at least until the MCI is approved) should be evaluated to define the credit mechanisms for ASM and jancheras (BCE, BanEcuador, Min of Production, for example) and the legal and administrative mechanisms necessary to implement them. The members of these groups should be designated by the institutions as technical working groups with a limited mandate to agree on a work agenda with specific results, deadlines and responsibilities.

Management Response: [Added: 2021/08/05]

The suggestion is partially accepted.

This activity will be included in the work program  development process, referred to in recommendation No. 1 and 7.

In addition, the Program is taking up the Environmental Quality Committee with the new MAATEC authorities, which will also provide with sustainability to the working groups, beyond just the CDP meetings.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
-Actions detailed in previous recommendations No. 1 and No. 7.
[Added: 2021/08/05] [Last Updated: 2022/02/01]
MAATEC, MERNNR, UNDP. Executing unit of the project. 2023/04 Initiated There are 5 working groups: Pesticides, COPNIS, Products with Hg, Products with POPs, MAPE. The POA 2022 was prepared in a participatory manner with the presence of the working groups. It is pending to send the document formalizing the working groups and the agendas developed as a result of this process. Regarding the environmental quality committee, the first meeting and the approval of the operating regulations were held on December 8. The next steps are to keep said committee active and promote the approval of the proposals generated from the PNGQ History
9. Recommendation:

For the annual financial reports, it is suggested to incorporate comparisons with what was planned in the Prodoc with the original expenses approved in January of each year, rather than presenting the expenses with respect to the adjusted budgets, which are always online. The purpose is to identify gaps and modalities of adjustments in strategies.

Management Response: [Added: 2021/08/05]

Recommendation is welcomed.

The project will include in its financial reports, the result of implementation compared to the original yearly planning.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Include the budget execution result, compared to the original yearly planning in the financial reports.
[Added: 2021/08/05] [Last Updated: 2022/06/28]
MAATEC, UNDP. Project implementation unit 2022/06 Completed This recommendation was accepted in the semi-annual progress report (July to December 2021). The same will apply to future reports. History
10. Recommendation:

It is also suggested that annual audits, or at least two audits, be carried out during the implementation of the project for the purpose of controlling its operations: one at mid-term of the project implementation period to make necessary adjustments and one at the end.

Management Response: [Added: 2021/08/05]

The suggestion is not welcomed, according to UNDP financial policies, priority is given to the execution of audits on projects with an annual budget execution of more than two million dollars. Because the project has not been executed in this manner, no audits have been performed. This information has been confirmed with the Country Office.

In addition, according to Prodoc and the results matrix, the Program must submit zero audits at the Medium Term and one audit at the End of the Project.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
In the case of compliance with the 2M rule, the financial audit for the project will be contracted before the mandatory one at the end.
[Added: 2021/08/05] [Last Updated: 2022/01/31]
UNDP 2023/12 Initiated Financial audits have not yet been carried out in 2022, this depends on UNDP policies. History
11. Recommendation:

In the case of the Annual Operating Plans, it is suggested to accompany them with a concise implementation strategy document for the corresponding period,  but that explains the reasons why the activities are carried out, their dependencies with others and whether they are parallel and can be advanced.

Management Response: [Added: 2021/08/05]

The recommendation is welcomed.

The annual implementation strategy paper will be prepared as part of the AOP construction process. This process will be repeated every year until 2023.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
-Elaborate the POA 2022 and develop the detailed strategy. Put up for consideration by the steering committee.
[Added: 2021/08/05] [Last Updated: 2022/02/01]
MAATEC UNDP MERNNR Project implementation unit 2022/12 Initiated AWP 2022 has an annual implementation strategy document. This is consistent with the working group agendas. Regarding the environmental quality committee, the first meeting and the approval of the operating regulations were held on December 8. The next steps are to keep said committee active and promote the approval of the proposals generated from the PNGQ. History
-Repeat the process in each year until 2023.
[Added: 2021/08/05] [Last Updated: 2022/01/31]
MAATEC UNDP MERNNR Project implementation unit 2023/12 Initiated the process will be applied until the end of the project History
12. Recommendation:

For the administrative function, it is suggested to review the processes of awarding and implementing MFC projects and other acquisitions to verify bottlenecks and information gaps that beneficiaries may have.

Management Response: [Added: 2021/08/05]

The recommendation is welcomed.

A mapping of the bottlenecks in the administrative processes of awarding and implementing will send to UNDP to implement improvements in the processes.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
-Carry out a mapping of bottlenecks in UNDP on the administrative adjudication processes.
[Added: 2021/08/05] [Last Updated: 2022/01/31]
UNDP. Project implementation unit 2022/12 Initiated There is a mapping of procurement processes and bottlenecks. It is pending to socialize the results with the PNGQ and UNDP team. History
-Deliver this information to UNDP
[Added: 2021/08/05] [Last Updated: 2022/06/28]
UNDP. Project implementation unit 2022/03 Completed There is a mapping of procurement processes and bottlenecks. It has already been socialized with UNDP and the PNGQ team. The team is following a strategy to comply the with deadlines and do not affect the proceses. History
13. Recommendation:

It is very likely that the priorities of the new authorities in the country will be related to the recovery of the economy and the fight against the pandemic, so activities such as waste and chemical management could be secondary. It is recommended that the project team make an analysis of the new actors and implement a communication strategy with a specific discourse according to the primary interests of each of them, where - for example - the discourse has greater emphasis on the project facilitating and structuring economic recovery, beyond mere environmental issues. In the case of artisanal gold mining, it will be helped with regulatory and financial instruments that encourage legal production and that also establish clear rules for investments in the sector, ensuring an orderly and transparent work for the actors involved. In the case of Health, it is important to emphasize that regulatory activities for the management of hospital waste (including Hg) is in line with the cutting of disease transmission and the emergence of diseases among health workers. This communication strategy should also include continuity in contacts, work agenda and information, including the progress in project activities.

Management Response: [Added: 2021/08/05]

The comment is welcomed.

A communication and knowledge management strategy will be developed and implemented to approach partners. In this strategy, staff turnover should be analyzed. In addition, the tool to monitor its implementation, as well as the sustainability of the prioritized products should also be analyzed.

They will be complemented by the survey of good practices and/or lessons learned.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
-Procedure included in previous recommendation 3.
[Added: 2021/08/05] [Last Updated: 2022/06/28]
Executing unit of the project, UNDP. 2022/12 Initiated The knowledge management strategy is in a process of design and development. It will be sent to the partners for validation when ready. History

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