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Terminal Evaluation of Comprehensive reduction and elimination of Persistent Organic Pollutants in Pakistan
Commissioning Unit: Pakistan
Evaluation Plan: 2018-2022
Evaluation Type: Project
Completion Date: 06/2021
Unit Responsible for providing Management Response: Pakistan
Documents Related to overall Management Response:
 
1. Recommendation:

To ensure the sustainability of POP's pesticide free environment, the federal and provincial EPAs should remain vigilant about any illegal import or sale of POPs pesticides in the country. If any stock is found, the MOCC should take over the stock, contain it securely to avoid immediate risks, and get it disposed of as quickly as possible following guidelines and SOPs established by the project

Management Response: [Added: 2021/07/08]

The POPs project has successfully eliminated/disposed of POPs pesticides from across Pakistan. The leftover stockpiles with the Sindh Agriculture department amounting to 70MT is the only stockpile present in the country. The Sindh Agriculture department did not hand over these stockpiles to the project due to their internal differences despite repeated follow-up by the project through the Ministry of Climate Change.

The project has also imparted training to various government departments including the Customs departments to control the illegal trading of POPs pesticides at various border points. It may be pertinent to mention here that Clause 3 of the proposed SRO under the Pakistan Environmental Protection Act which is developed under the project and deals with the Prohibition of Import, Manufacture, and Use of POPs; Clause 4 deals with the Storage of POPs and Clause 6 relates to the Environmentally Disposal of POPs also provide provision to exercise its powers to enforce the same. The Federal, as well as provincial EPAs, were technically capacitated through the provision of GCMS equipment and necessary training to check any illegal practice of the use of obsoleted chemicals in the country. Since the Federal EPA administratively falls under the Ministry of Climate Change therefore as per the recommendation, the MoCC will be reached out to take appropriate measures in collaboration with the federal EPA and necessary coordination with the provincial EPAs. Additionally, the MoCC will also be requested to pursue the Sindh Agriculture Department to either dispose-off the leftover stockpiles from their possession through internal arrangements under the established SOPs or contain these stockpiles in a secure manner to mitigate the risk of its release into the environment as occurred in floods of 2010. 

Key Actions:

Key Action Responsible DueDate Status Comments Documents
As the project has been operationally closed So UNDP will consider this in the next phase if launched depending on funds availability
[Added: 2021/07/08]
N/A 2021/05 No Longer Applicable [Justification: As the project has been operationally closed So UNDP will consider this in the next phase if launched depending on funds availability]
2. Recommendation:

UNDP should work closely with the MoCC and ensure that the rules developed under the POPs projects is formally approved and enacted by the concerned government department

Management Response: [Added: 2021/07/08]

We agree with the proposed recommendation and follow-up actions will be considered in new phase of the project based on funds availability

Key Actions:

Key Action Responsible DueDate Status Comments Documents
No Key action is required at this stage as the project is operationally closed.
[Added: 2021/07/08]
N/A 2021/05 No Longer Applicable [Justification: No Key action is required at this stage as the project is operationally closed. However, the recommendations will be considered if a new phase of the project is launched. ]
3. Recommendation:

The EPAs should undertake an inventory of all the electric/transformer companies engaged in the business of manufacturing and repair of equipment containing mobile oil and enforce to provide the PCB contaminated oil to the designated factory such as Bestway Cement for disposal.  EPAs should serve as a bridge between the industry and the Bestway Cement. Since the oil has a calorific value, it will cut the fuel cost of cement plant, which will be an incentive for it.  It is a win-win situation for both the parties. Likewise, the EPAs should strictly monitor and ensure that no used mobile oil, plastic or used tyres are used as fuel in the brick kilns

Management Response: [Added: 2021/07/08]

As per the project document, the project had a target to collect 5,000 samples of oil from various power departments across Pakistan and after carrying out necessary laboratory tests, should identify PCB contaminated oils from the transformer oils being used by these power departments. When the project started this activity, the project team found that there is no PCB inventory existed in Pakistan. After carrying out the sampling process and laboratory tests of 5000 samples, the project developed an inventory and shared with the respective power departments. The PCB contaminated oil was marked and kept separately in the respective locations. 

Accordingly, a schedule was developed to collect and dispose of it. A private sector firm was engaged to collect the oil and transport it to another private firm which was responsible to dispose of it. Bestway cement was selected to dispose-off the PCB contaminated oil.

A total of 300MT of oil was earmarked as a result of the sampling process. The same quantity of oil was collected and disposed of under this project.

We agree with the recommendation of the project and propose that EPA should liaise with the concerned power departments to check and develop another inventory of any left-out PCB contaminated oil which might be underuse of the power departments and then partner with Bestway cement to receive the oil and dispose of it without charging any cost of disposal and use the same oil for fuel purpose in the cement plant for operational use. 

UNDP believes that there will still be a requirement of certain resources for the transportation of the PCB oil after it is identified through a sampling process. EPA could use its own GCMS equipment and develop an inventory after necessary sampling

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Key action not applicable
[Added: 2021/07/08]
N/A 2021/05 No Longer Applicable [Justification: the project is operationally closed so the recommendations will be taken care of if a new phase is launched in the future based on funds availability. ]
4. Recommendation:

 Being a member of the Project Board and the regulatory body for the import of pesticides, the Ministry of National Food Security and Research should collect data about the illegal trade of POPs pesticides in the country and take measures to curb it.  It should also initiate a “Programme on Certified Pesticides Applicators” and provide training and issue license to farmers for the use of pesticides and proper disposal of empty containers

Management Response: [Added: 2021/07/08]

The Ministry of National Food Security and Research claims that no obsoleted pesticides are imported to Pakistan. However, the recommendation proposes to collect data regarding the illegal trade of POPs pesticides therefore this could be checked if the Ministry has such mechanism or if they intend to develop such mechanism in collaboration with other relevant government entities such as Customs department.It is pertinent to mention here that under this project, necessary trainings were already imparted to the Customs department to curb the illegal trading.

The second part of the recommendation is to propose to the Ministry to develop a programme on certified pesticides applicators for the farmers. UNDP may follow up on the same to check if any such plan exists and if not, the Ministry could be encouraged to include such initiative in their future planning that may ensure safety and well being of the farmer community

Key Actions:

Key Action Responsible DueDate Status Comments Documents
No Key action is applicable
[Added: 2021/07/08]
N/A 2021/05 No Longer Applicable [Justification: the project is operationally closed so no key action is applicable at this stage. However, the recommendations will be considered if there is a next phase of the project]
5. Recommendation:

To ensure long term sustainability of the project, it is proposed that UNDP may advocate to the government to submit a bill to the Parliament to establish a central “Hazardous Waste Management Authority” on the pattern of “Food Authority” in the country under the umbrella of MOCC. This authority should be established in the spirit of public-private partnership

Management Response: [Added: 2021/07/08]

This needs to be ascertained that whether such authority could be established under the MoCC or it falls under the mandate of the provincial environment departments. However, the proposed recommendation will be discussed with the concerned Ministry officials

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Key action not applicable as the project is operationally closed
[Added: 2021/07/08]
N/A 2021/05 No Longer Applicable [Justification: Key action not applicable as the project is operationally closed. The recommendations will be considered if UNDP secured funding for the next phase of the project.]
6. Recommendation:

MOCC should work closely with UNDP on the formulation of a successor project to reduce/eliminate hazardous chemicals wastes, other unintended POPs especially in the ship breaking industry in the Gadani area, Balochistan. The project may consolidate the successes of this project and ensure implementation and enforcement of laws/rules developed under the project

Management Response: [Added: 2021/07/08]

The Ministry of Climate Change, as well as the Government of Balochistan, are equal stakeholders in the proposed project.  UNDP will discuss with the Government for exploring suitable resources.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Key actions not applicable
[Added: 2021/07/08]
N/A 2021/05 No Longer Applicable [Justification: as the project is closed operationally so the recommendations will be taken care of if UNDP managed to secure further funding for a new phase of the project.]

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