Special Compliance Topics

Speeches Shim


This page summarizes how USAID’s environmental procedures apply to certain activities that pose additional or unique compliance requirements and provides links to further resources for each:

Note: Information on the page is highly summarized and may not be authoritative.

Drinking Water Quality

Generally, Initial Environmental Examinations (IEEs) and EAs for activities that will provide drinking water require Implementing Partners (IPs) to develop, implement, and report on a Water Quality Assurance Plan (WQAP). The WQAP specifies how the IP will assure safe drinking water and meet applicable host country water quality requirements. It specifies requirements for initial testing, long-term monitoring, and, in some cases, exact water standards.

USAID Africa Bureau has developed a WQAP Template for use in Africa Region. This template is also being used and adapted more broadly across the agency.

See also the Water and Sanitation Sector Environmental Guideline.

Ecosystem Services

Ecosystem services are the benefits (such as water supply, carbon sequestration and flood risk reduction) that ecosystems provide to people, projects and activities. As a general principle, the environmental impact assessment (EIA) process should consider ecosystem services impacts; this is particularly critical for activities with clear potential for such impacts. The Environmental Compliance Factsheet: Ecosystem Services in Environmental Impact Assessment briefs key concept and provides guidance on how to incorporate ecosystem services into USAID’s EIA process under 22 CFR 216.

Fumigation of Food Commodities

Fumigation with the pesticide phosphine gas is a critical tool to assure protection of agricultural food commodities from waste and spoilage. It is also an intrinsically dangerous process: phosphine is deadly, flammable and corrosive.

USAID/DCHA Bureau’s Programmatic Environmental Assessment (PEA) for Phosphine Fumigation of Stored Agricultural Commodity establishes environment, health and safety requirements for USAID Food for Peace and other USAID operating units (e.g., Regional and Functional Bureaus, field Missions) that plan to undertake phosphine fumigation in a warehouse setting. 

Access the Fumigation PEA, including key templates guidance and resources here.

Genetically Engineered (GE) Organisms

USAID-funded activities conducted outside the United States that involve the research, testing, or use of GE organisms* must comply with the Agency’s Biosafety Review process and requirements specified by ADS 211. The use of GE organisms must be considered during USAIDs environmental impact assessment process to ensure the modified organism does not pose an adverse impact to the environment (e.g., acts as an invasive species).  

The Biosafegy Review process includes (1) initial consultation with the Agency Biosafety Officer (ABO) to determine if biosafety review is necessary; (2) preparation of an Activity Biosafety Summary and supporting documentation; (3) expert review managed by the ABO; (4) ABO approval of a written USAID Biosafety Risk Determination; (5) incorporation of the Biosafety Risk Determination and partner-country biosafety authorization into the ADS204/22 CFR 216 pre-implementation EIA process**; and (6) potential follow-up technical assistance by the ABO.

*GE organisms are defined by USAID as “living organisms into which scientists have intentionally introduced genetic material, using a range of potential technological approaches.”

**The ADS 211 Biosafety Review process only examines the environmental or health risks specifically posed by GE organisms; it does not examine other potential environmental or health impacts of the activity. The biosafety review is intended to precede and inform environmental review per ADS204 and 22 CFR 216.

See ADS 211 for details.

Global Development Alliance Activities (GDAs)

In a GDA, USAID enters into a formal agreement with two or more parties (at least one of whom must be a private sector entity) to jointly define and address a development problem. USAID’s environmental procedures apply to all GDAs. They apply slightly differently to pooled resources vs. parallel financing. See ADS 204.3.9.a for details.

Montreal Protocol on Substances that Deplete the Ozone Layer

The Montreal Protocol on Substances that Deplete the Ozone Layer (1987) is an international treaty that aims to protect the ozone layer by phasing out the production and use of approximately 100 synthetic chemicals. Specifically, it calls for phasing out certain Ozone Depleting Substances (ODS), including CFCs, halons, methyl bromide, HCFCs, and most recently, HFCs. Universal ratification of the Montreal Protocol and growing ratification of the Kigali Amendment mean that there are existing commitments on ODS and HFC use at the country level. By integrating the Montreal Protocol and its amendments into purchasing decisions for equipment and building materials, USAID will ensure that its projects comply with current and future requirements on ODS and HFC use at the local, regional, and international level. 

For more information about how the Montreal Protocol and its amendments apply to USAID purchasing decisions, see the Montreal Protocol Factsheet.

Pesticides and PERSUAPs

Support to the procurement and/or use of pesticides on USAID-funded or managed activities requires compliance with the Agency’s pesticide procedures, 22 CFR 216.3(b).  Such support is broadly defined as any direct and indirect support for pesticides, including support for pesticide input value chains. The purpose of these procedures is to ensure safer pesticide use.

In general, the procedures require that each pesticide to be supported must be approved on the basis of 12 evaluation factors:

(a) The USEPA registration status of the requested pesticide;

(b) The basis for selection of the requested pesticide;

(c) The extent to which the proposed pesticide use is part of an integrated pest management (IPM) program;

(d) The proposed method or methods of application, including availability of appropriate application and safety equipment;

(e) Any acute and long-term toxicological hazards, either human or environmental, associated with the proposed use and measures available to minimize such hazards;

(f) The effectiveness of the requested pesticide for the proposed use;

(g) Compatibility of the proposed pesticide with target and nontarget ecosystems;

(h) The conditions under which the pesticide is to be used, including climate, flora, fauna, geography, hydrology, and soils;

(i) The availability and effectiveness of other pesticides or nonchemical control methods;

(j) The requesting country’s ability to regulate or control the distribution, storage, use and disposal of the requested pesticide;

(k) The provisions made for training of users and applicators; and

(l) The provisions made for monitoring the use and effectiveness of the pesticide.

These factors and the procedures overall reference and rely on the US EPA registration status of and registered use for the subject pesticide. More rigorous analytical requirements apply to pesticides designated by US EPA as restricted-use. Additional analysis is required when a pesticide is not approved by US EPA for same or similar uses.

The process and instrument by which these analytical requirements are addressed is sometimes called a Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP). As such, PERSUAPs establish the pesticides for which support to procurement and/or use is approved, and specific, mandatory safer use conditions.  The approval is provided for specified activities, sectors, uses, value chains, geographies, and for specified time limits. Once approved by both the USAID mission or office director and the cognizant BEO, the safer use conditions they establish become binding on activity implementation.

PERSUAPs consist of two parts: the PER, which provides the 12-factor analysis and related background information; and (2) the SUAP which provides the list of approved pesticides, approved uses, and safer use conditions. Some conditions are specific to a single pesticide; others are general. The SUAP flows from the PER analysis. Its safer use conditions typically cover all elements of safer use, including required implementation of IPM in some form. The SUAP commonly includes recommended chemical and non-chemical controls for pests of economic importance affecting the value chains covered by the PERSUAP; these are provided as resources for implementing partners to use in finalizing and implementing their required IPM plans.

Implementation of the SUAP is the responsibility of the implementing partner, who must have both the technical capacity and resources under the activity budget to do so.

  • Discussion of pesticide risks, pesticide safer use and IPM in the Crop Production Sector Environmental Guideline [forthcoming]
  • Pesticide Retailer Handbook. This handbook was produced by the USAID/Afghanistan’s IDEA-NEW project as part of its activities to strengthen agricultural input suppliers. It is a practically oriented, written in accessible language, and can serve as a pesticide safer use training curriculum. (

Scoping Statements and Environmental Assessments (EAs)

EAs are USAID’s version of a full EIA study. They must meet the requirements of 22 CFR 216.6 and are performed when a scoping statement identifies significant environmental issues.

Scoping Statements are developed (1) in response to a Positive Determination in an IEE or (2) when proposed actions are within classes of actions normally having a significant environmental effect per 22 CFR 216.2(d) and the originating project team/OU elects not to first develop an IEE. They determine which of the proposed actions may be significant in their effect (and thus must be redesigned or assessed in an Environmental Assessment) and those that are not significant and may be eliminated from further study. Scoping Statements must meet the requirements of 22 CFR 216.3(a)(4).”

These training slides outline the situations in which a scoping statement leading to EA is required, differences between EAs and Initial Environmental Examinations, and other considerations.

The Environmental Documentation Types and Templates page provides access to Scoping Statement and EA Templates.

Last updated: May 20, 2020

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