Environmental Management Plan for the Illicit Crop Eradication Program Using Aerial Spraying with the Herbicide Glyphosate (ICEPG)

While executing aerial spraying operations using the mixture of this herbicide, some quite specific conditions may occur that may generate potential environmental and social impacts, from the very moment the airplane takes off until it lands. During the trajectory, it may even be necessary to dump the herbicide in flight to ensure the lives of the crew, due either to attacks by terrorists or to aircraft failure.

The elimination of illicit crops in Colombia is justified because it hinders the negative impact related to the production and trafficking of narcotics and to the harm of deteriorating the environment. It also enables introducing new plant species aimed at extracting psychoactive substances. There are several available eradication methods (manual, mechanical, burning, biological, and chemical). However, taking into consideration the location of the illicit crop fields, the characteristics of the landscape, the opposition of the farmers who cultivate plants for illegal purposes, and the presence of outlawed armed groups, the most efficient and least dangerous strategy is aerial spraying with herbicides.

To follow the procedures and technical and environmental parameters for aerial spraying, which result in the efficient eradication of illicit crops sown throughout the national territory, pursuant to the responsibilities assigned, in order to protect and preserve the environment.
To identify, characterize, and delimit zones with illicit crops.
To identify and delimit exclusion zones and alert zones.
To verify that environmental management measures are effectively applied during ICEPG operations.

Do maintenance and checks on and calibration of the spraying equipment on the aircraft.
Comply with the technical and operational parameters used for applying the herbicide, as set forth herein.
Comply with the environmental zoning criteria herein.

Before every mission, the technical personnel at the National Police Anti-Narcotics Division (DIRAN is the Colombian acronym) operations base must check the operational condition of the spraying equipment, and if need be, adjust the equipment.

3.2 Technical and Environmental Specifications in the Different ICEPG Phases

The spraying process is carried out in three phases: detecting the illicit crops to be sprayed, spraying, and verification.

The purpose of the detection process is to identify, characterize, and locate the zones with illicit crops and the zones to be excluded from the programs, using geographical coordinates.

Such characterization will be supported by satellite imagery, aerial photography, and cartography. The ARECI-DIRAN personnel will do the field work to carry out this activity and its main objective is to identify how the soil is used, the presence of settlements, and the delimitation of National Protected Area System zones, ecologically fragile zones and environmentally, socially, and economically sensitive zones, in order to create the basic environmental zoning for each operation.

To do so, there must be strict compliance with 1991 Decree 1843 Article 87 referring to security zones and with Article 1, Paragraph 2 in National Anti-narcotics Commission Resolution 0013 dated June 27, 2003.

The environmental zoning will be delivered, in accordance with the available cartography for operations already carried out and with the frequency stipulated by the Ministry of the Environment, Housing, and Territorial Development.

For reasons of security and due to the location of and access to the fields with illicit crops, the spraying must be done using proper aircraft that comply with the parameters in Chart # 1.

During the spraying operations, bear in mind all technical navigation and spraying requirements, in order to mitigate the potential impact of the spraying on vegetation or on neighboring crops not covered by the ICEPG. These parameters include flying altitude, the size of the drops, dosage, wind velocity, and other favorable weather conditions.

The effect of the drift or side movement of some of the mixture being sprayed could be an inconvenience, considering the consequences that it may have on the ecological surroundings of the plants being sprayed; therefore, the ICEPG will be carried out under proper conditions (see Chart # 1).

For this purpose, there must be strict compliance with 1991 Decree 1843 Article 102 that refers to the pilots� obligations. Likewise, all other articles therein applicable to the program must be taken into account.

There are other factors that enable increasing the operational efficiency of aerial spraying using Glyphosate, without exceeding technical and economical thresholds; therefore, we recommend not spraying when:

The fields are plowed or have very limited foliage (only stalks or crops harvested).
There is imminence of rain or there is rain nearby
There is evidence of the phenomenon of inverse currents or clouds near the ground. This phenomenon occurs especially in hilly or mountainous areas and in the wee hours of the morning in rainforest zones.
The pilot has doubts about being able to identify the illicit crop to be sprayed.
The aircraft is attacked, the equipment damaged or the operational personnel is ill.

The Eradication Program using aerial spraying with Glyphosate must be verified in order to evaluate the efficiency and effectiveness of the environmental management measures.

In parallel with the verification activities directly related to the efficacy of the illicit crop spraying, an environmental evaluation must be made, for the purpose of qualitatively estimating its magnitude (light / moderate / severe). This will be done, bearing in mind:

The Verification Program must be carried out using a sample of illicit crop parcels that have been sprayed. The zones are the Putumayo-Caquet�, Guaviare-Meta, Cauca-Nari�o, Antioquia, and Norte de Santander nuclei.

The sampling unit will be the breadth of the passing selected, based on satellite localization records chosen at random. Also factors such as security in the zones to be sampled, operating costs, availability of equipment, and variability of the sample universe will be taken into account.

Also, the Ministry of the Environment, Housing, and Territorial Development, the Ministry of Social Protection, the Colombian Farming and Livestock Institute, the National Attorney General�s Office, the National General Prosecutor�s Office, Plan Colombia, and other institutions that it is deemed relevant to summon may be invited to participate in the verification process, as observers.

The results of the verification process must be submitted in a document containing:

DIRAN will be in charge of the follow-up on the different activities herein. Therefore, it must have the records of the results achieved in the spraying operations.

The National Police Anti-narcotics Division is in charge of carrying out the activities indicated herein.

An industrial safety program is related to the proper handling of substances used for spraying illicit crops, fuels, lubricants, equipment, aircrafts, ground vehicles and machinery, as well as the occupational health care and industrial safety measures on the operations bases and in the air, whose improper performance may increase the vulnerability and cause accidents of any nature, including actions by outlawed armed groups, with the subsequent generation of effects on the environment and on people�s health.

Accidents lead to an increase of operation costs, supplementary costs (indemnities, compensations, repairs and replacements) associated with a negative program effect.

In order to carry out aerial spraying operations, it will be necessary to transport, store, load and dispose of farming chemical products, fuel, lubricants, and parts for the usage and maintenance of equipment, aircrafts and vehicles in the ICEPG on the operations bases; as well as the final disposal of debris, waste and packing materials.

Among the risks that may arise on the different operations bases, we name the following:

Contamination of Bodies of Water. This contamination is linked to the spillage of farming chemicals used for illicit crop spraying and their eventual dumping into nearby water sources.
Soil Contamination. It may also be derived from the substances spilled on the base, which may affect the physical, chemical and biological conditions of the soil.
Operations Personnel�s Exposure to Chemicals. Farming chemicals and fuels may enter the human body orally, through the respiratory tract, through the skin or eyes, when the personnel is handling such substances.
Spills. Spills may occur during the storage, handling and transportation of substances (farming chemicals, fuels and lubricants), and they may result in undesired personnel exposure and exposure to the environment.
Fires. They may have different causes (accidents, terrorist attacks, sabotage, natural phenomenon) and they represent an evident risk for the personnel�s health as there are flammable substances among the products used.

In order to ensure a proper total safety program, it is necessary to have the training plans for the operation base personnel.

To prevent, control and mitigate the adverse or undesired events related to the improper handling of farming chemicals, fuels, lubricants, equipment, aircrafts, ground vehicles and machinery.

For the storage, handling, application, transportation and disposal of debris and residues, apply the measures embodied in the norms in force in 1986 Resolution 2309, 1991 Law 430, 1991 Decree 1843 and the regulations that modify them, add to them or substitute them, as well as in applicable environmental standards.

The specific activities are consigned in the National Police Anti-Narcotics Division instructions that address total safety measures for the operations base platforms.

For the storage, handling, application, transportation of fuels, lubricants and disposal of debris and residues, implement the measures embodied in the following Colombian technical standards 1899, 1417, 4643, 5011 and in the 2002 Regulation Decree 1609 and in the standards that modify it, add to it or substitute it and that are applicable to it, given the special characteristics of this program.

For the operation and maintenance of aircrafts, ground vehicles, equipment and machinery available on the operations bases, follow the guidelines available at the National Police Anti-Narcotics Division and especially the instructions contained in the manufacturer�s operating manuals.

Follow the measures embodied in the National Police Occupational Health and Industrial Safety internal regulations, as well as the standards provided for in 1979 Law 9, Heading III � Occupational Health and the decrees that regulate it.

Both the illicit crop eradication area and the police aviation area have their own instructions regarding total industrial safety and occupational health measures.

The Operation Bases will be equipped with signaling for prevention, regulations, and information purposes, following industrial safety guidelines to prevent program-associated risks.

Pursuant to the provisions in 1991 Decree 1843 Article 172 and following, all personnel working with pesticides must be trained once a year to ensure proper farming chemicals product management. DIRAN must keep the corresponding records of such training sessions, including topics covered, attendance sheet, duration, and training entity.

DIRAN will forward a training program, according to the specific activities carried out by the personnel involved in the ICEPG, including the following topics:

Risk evaluation and management
First aid
Use of personal protection items
Air Salvage and Rescue (SAR is the Colombian acronym)
Fire and spillage control
Evacuation and contingency plans (please refer to Specification # 8 � Contingency Plan)

DIRAN will be in charge of the follow-up on the different activities included herein. To do so, DIRAN must have the records of the results of the inspections and verifications, as follows:

Inspection of the farming chemical and fuel storage and pumping systems, to detect possible potential risks and incidents.
Inspection of and follow-up on the following activities:
- Operation and maintenance of the aircrafts used for spraying
- Operation and maintenance of the machinery and equipment used in ICEPG activities
Verification of and follow-up on training programs.
Verification of occupational health and industrial safety measure compliance.

The National Police Anti-Narcotics Division is in charge of carrying out the activities herein.

Solid domestic waste (SDW): due to its condition, nature, composition, and volume, this waste is produced from man�s domestic activities or from his activities in any establishment similar to a home; it consists mainly of organic matter (food waste), paper, cardboard, glass, plastic, etc�.
Solid special waste (SSW): it consists of packing discards, oil, grease, used lubricants, epoxy paint and polyurethane-base paint containers, vinyl paints, solvents, accelerators, rain proofing elements, materials contaminated with used oils, fuel or petroleum derivates, shavings, rubber packings, used packages and wrappings, and electrochemical batteries.
Solid waste linked to farm chemical handling (ASW): it consists of empty plastic containers and other types of plastic and cardboard recipients.

Because the program generates domestic solid waste on the bases where spraying is done, the regulation embodied in Decree 2104 dated July 26, 1983, through which solid waste management is regulated, will be applied.
In addition to the above, instructions must be given to the personnel on the operations base for them to classify solid waste in its place of origin, in order to facilitate its management.

3.2. Management of Special Solid Waste (SSW) and Solid Waste linked to Farming Chemical Management (ASW)

Because the program generates special solid waste on the bases where spraying is done, including farming chemical containers, the regulation embodied in 1991 Act 430, in Decree 2104 dated July 26, 1983, in 1986 Resolution 2309 and in 1991 Decree 1843 issued by the Ministry of Health, through which solid waste management is regulated, must be obeyed.

In addition to the above, instructions must be given to the personnel on the operations base for them to classify solid waste in its place of origin, in order to facilitate its management. An instructions booklet and environmental education workshops will complement the solid waste management program for the operators on the bases.

Due to the low toxicity of the mixture used for the ICEPG, the empty recipients of the mixture can be used to collect garbage or for building barriers (trenches) on the military bases, provided they are completely washed and perforated, to avoid their being used to transport water or other materials for human consumption.

With the above exceptions, they can be re-used by the same farming chemical manufacturing company.

DIRAN will be in charge of the follow-up on the different activities included herein. To do so, it must have the records for each one of the activities:

Inspections of the temporary solid waste storage sites
Inspection of, follow-up on, and verification of the collection, separation, and disposal of solid waste.
Verification of and follow-up on the training programs.
Verification of compliance with occupational health and industrial safety measures
Preparation of a six-month report on the results of such inspections.

The National Police Anti-narcotics Division will be in charge of carrying out the activates described herein.

There are three (3) types of wastewater produced on a National Police Anti-narcotics Division operations base:

Industrial Wastewater: the product of washing the spraying devices of the aircraft, machinery, filling equipment, and of mixing and storing farming chemicals. This also includes water used to wash the facilities. In the wastewater from the general maintenance and washing of the facilities, we foresee a greater content of solids in suspension, detergents and, possibly, emulsified grease and oils.

Rainwater: This goes to a collecting system and is evacuated from the operations base or is infiltrated into the ground. Rainwater full of sediments that it drags on the ground may contain total solids as well as solids in suspension.

Some ICEPG areas of operation are located in airports or next to them; the airports are equipped with their own sewer system or the sewer systems are part of the municipal sewer systems. The measures for collecting and treating the wastewater established below only apply to the bases that do not have connections to public sewer system networks for emptying purposes.

Wastewater management will be handled, taking where the wastewater is produced into account:

On the fixed bases where there is no connection to the public sewer system, connection may be made to an alternate wastewater treatment system or at least to a septic tank with a grease trap or a membrane, which meets minimum waste disposal standards.

The bases will have a fixed or mobile system for collecting and re-using industrial wastewater. See Annex.

Precipitate solids produced in sewage treatment processes will be managed as domestic solid waste (DSW) and special solid waste (SSW), pursuant to the provisions in Specification # 3 regarding solid waste management.

The bases that produce sewage directly related to spraying operations will have treatment systems according to need; they will obey the allowable limits set forth in the regulations in force, and will ensure proper, permanent maintenance.

The industrial wastewater produced from washing the aircraft used to apply the mixture will be re-used in the spraying process.

Once the wastewater meets the conditions required at the emptying site, based on the use of the water in the receiving trench, it can be dumped, pursuant to the provisions in 1978 Decree 1541 and to 1984 Decree 1594.

In order to establish basic sanitary parameters (DBO, DQO, total solids and solids in suspension, pH, total coliforms and faecal coliforms), a characterization aimed at proving the efficiency of the domestic wastewater treatment system and compliance with regulations must be made.

A wastewater dumping analysis must be made once every six (6) months or at least once during the operation on bases that operate for less than six months, in order to establish that the emptying was limited to the provisions set forth in 1984 Decree 1594 regarding the use of wastewater and liquid waste.

The wastewater treatment system will be located where it will not lead to the contamination of any well, spring or other source of water supply. In addition, it will be located in a place that has the slope specified for evacuating the treated wastewater. The location must have the proper terrain and must be easily accessible.

The bases where wastewater is emptied into systems other than municipal sewer systems will obtain permits and keep them effective.

Training and educational programs will be given to those who operate the treatment system for the wastewater plants and for the re-use of industrial wastewater, in order to guarantee their proper maintenance and operation.

DIRAN will be in charge of the follow-up on the different activities included herein. To do so, it must have the records of the results achieved in each one of these activities, as follows:

Inspections of the bases, to verify the proper functioning of the wastewater treatment systems: collection system, treatment, and disposal of domestic wastewater and of water from washing the spraying equipment and the filling and storage equipment.
Verification of and follow-up on training programs.

Implementing the measures included in this program will be subject to the budget assignments that the National Government allots for this purpose.

The National Police Anti-narcotics Division is in charge of carrying out the activities indicated herein.

Although the scientific studies available show that there are is no significant impact from applying Glyphosate on the soil, water, and plant components that surround the illicit crops being sprayed, it is necessary to carry out follow-up and verification actions regarding the effectiveness of the spraying operations and the estimation of the possible impact on the environmental components.

This technical follow-up will be done on parcels that meet the following criteria:

The soil and the vegetation correspond to types common to the region or nucleus.
The weather corresponds to the weather predominant in the nucleus.
It is possible to do the proposed measuring (access and security). Consequently, this activity will only be carried out on parcels with coca crops because it is impossible to descend into the zones with poppy crops.
In order to guarantee efficient resource and security management, selecting the parcels and sampling and monitoring will be implemented based on the spraying operations carried out as established in the National police Anti-narcotics Division work schedule.

To become familiar with the plant succession process, a qualitative regeneration characterization (percentage of vegetation layers) will be done before and after each spraying, using videos, digital photography, and satellite imagery.

In zones where there is no access either due to public order problems or to topographical conditions, available images will be used in order to determine any change in the vegetation layers.

The parcel to be evaluated will be geo-referenced and will have a minimum area of one hectare.

A total of two (2) parcels will be analyzed regarding vegetation layers, for each ICEPG target nucleus:

Verification must be done before the spraying, immediately thereafter, at 60 days and, if justified, at 90 and at 180 days.

To forward the environmental monitoring of the spraying operations on poppy crops, aerial monitoring will be done, given the topographical, meteorological, public order, and typical logistic support conditions in these zones.

To determine the behavior of the Glyphosate and its metabolite MPAA residues, samples will be taken from the same parcels, in compliance with the ICA-approved protocol for soil and water sample-taking, in accordance with the studies required to obey the provisions in 2003 Resolution # 0099.

The parcel to be evaluated will be geo-referenced and will have a minimum area of one hectare.

A total of two (2) parcels will be analyzed regarding vegetation layers, for each ICEPG target nucleus. For soils, a compound sample will be made up of minimum three (3) samples taken from each parcel. For bodies of water, a compound sample will be made up of minimum two (2) samples taken from each parcel.

In each parcel selected, a compound sampling will be used taken from the first 20 cm. of horizon A, before the spraying, immediately thereafter, at 60 days and, if justified, at 90 and at 180 days.

For the purpose of understanding the dynamics of Glyphosate and its metabolite MPAA and their effect on the physiochemical and biological properties of soil and water, we intend to evaluate the impact that the application has, by comparing the parcels from which the samples were taken, sprayed and not sprayed. The following parameters will be measured through laboratory analysis:

Soil: pH, Cationic Interchange Capacity (CIC), relation of interchangeable bases, nitrification (nitrates, ammonia and nitrites), percentage of organic matter, texture, concentration of Glyphosate and AMPA, new count of bacteria, actinomycetic fungus and nitrogen fixative, phosphate solubilizers, total phosphorous and available phosphorous.

Water: Concentration of Glyphosate and AMPA, pH, electrical conductivity, temperature, dissolved oxygen, chemical oxygen demand, nitrification (nitrates, nitrites and ammonia), dissolved phosphate, magnesium, and calcium.

Vegetation Layer. The indicator will be a percentage estimate of the area with new vegetation.

In coordination with the entities involved, DIRAN will ensure compliance of the work schedule established to carry out the proposed activities and to send the samples to the Agust�n Codazzi Geographical Institute (IGAC is the Colombian acronym) Soil Laboratory and to the National Health Institute (INS is the Colombian acronym) National Referencing Laboratory .

Montioring Planning will be done with the intervention of the National Police Anti-narcotics Division, the National Health Institute, and the Agust�n Codazzi Geographical Institute.
IGAC technicians will take soil samples and pack them and the INS or whomever the INS trains to do so, will take water samples and pack them.
The technicians who take the samples will send them to the labs.
IGAC and INS will do the lab analysis and supply the results, for soil and water, respectively.
The National Anti-narcotics Agency (DNE is the Colombian acronym) will compile the results for the nuclei and periodicity indicated herein and will send them to the Ministry of the Environment, Housing, and Territorial Development.

The development of a program of the nature of the ICEPG implies a series of interactions with the communities in the program target zones, either to inform them of its characteristics, results or progress or to solve the concerns that they may have regarding said program.

To develop a set of prevention, training and information activities aimed at the national, regional and local environment, as well as to the communities regarding the ICEPG nature and scope, its results and its risks, and regarding the environmental protection measures involved in the EMP.

Through a communication strategy, keep the society and the community at large informed nationally, regionally and locally, especially the communities located in the areas of influence of the Glyphosate spraying nuclei, regarding aspects, such as:

The training will be aimed at institutional officials involved in the program, ICEPG technical and operational personnel, health care authorities, among others, and will be related to the Environmental Management Plan. See training aspects in Specifications # 1, 2, 3, 4, 7, and 8.

To develop this strategy, prepare a Training Plan with the different topics to be addressed in the EMP, the workshop date, the technical, financial and human resources required, the entities in charge, the number of persons to be trained, the workshop evaluation and follow-up. The DNE will require this Plan in order to consolidate it into one sole document.

The Illicit Crop Eradication Program using Aerial Spraying with Glyphosate (ICEPG) is a strategy that the Colombian State uses to reduce the supply of illicit drugs.

To carry out the activities included in the ICEPG and in its Environmental Management Plan, we boast, at a national level, the participation and commitment of the different institutions involved in the ICEPG, which have direct responsibility, pursuant to the provisions in the National Narcotics Council Resolution 0013 dated June 27, 2003, and to the specifications in this plan.

In order to carry out these actions, we may establish inter-institutional covenants with technical, public and private organizations who can support the ICEPG.

Complaints of affectations that may have been caused by working with legal crops not mixed with or that are rotated with illicit crops will be handled pursuant to the provisions in Resolution 0017 dated October 4, 2001 or in any other regulation that modifies it, adds to it or substitutes it.

Should there be possible damage to zones in the National Natural Park Systems or other forest zones or State-owned natural zones, the Environmental Authority (Regional Autonomous Corporations) or the Natural National Park Special Administrative Unit (UAESPNN is the Colombian acronym) will present the complaints to DIRAN, who must handle said complaints pursuant to the standards in force regarding administrative actions.

The possible complaints that may arise for alleged health affectations will be handled pursuant to the mechanisms set forth in the General Health Social Security System described in Specification # 7.

On a monthly basis, DNE will verify the progress status of the scheduled activities vs. the activities carried out for each strategy defined herein.

Each entity committed to the implementation of strategies will appoint one delegate who will be in charge of all coordination with DNE.

DNE is responsible for coordinating the implementation of the strategies provided for herein.

This program describes the set of activities and procedures aimed at the prevention, mitigation, correction, and compensation of risk situations for the health of the population in the ICEPG application zones.

To develop risk management measures for the prevention, mitigation, correction, and compensation of the effects on health that may be associated with spraying using Glyphosate in the ICEPG operations zones.

To carry out community information activities aimed at reducing the risks of exposure to pesticides and at inducing the demand for timely medical care to diagnose and manage possible accidents with these substances.

To strengthen the institutional capacity of health services and environmental sanitation at a local level, in order to ensure timely, proper attention to possible risk situations that may affect the population�s health.

The strategies to be developed are related to information, care, and evaluation regarding health complaints.

The Ministry of Social Protection will create the Panorama for Risks to Human Health, which may be caused by exposure to the mixture used in the ICEPG. Based on medical and scientific literature, medical histories and risk levels as well as foreseeable adverse effects can be described.

Using that panorama, the scope and development of the other activities included herein based on the occurrence of each risk will be established and specific measures to eliminate or effectively control the provoked adverse effect will be prepared.

3.2. INFORMATION FOR PREVENTING EXPOSURE AND ACCIDENTS CAUSED BY ILLICIT CROPS AND THEIR ERADICATION

Within the general framework to develop the information, education, and communication strategy, there will be workshops and training sessions on the contents of the ICEPG Environmental Management Plan and its components. The training will be aimed at institutional officials who participate in the program, ICEPG technical and operational personnel, and administration, health, and environmental authorities in the municipalities involved.

The specific information actions to which this component refers are aimed at the communities in the areas of influence of the zones in which the ICEPG intervenes, in order to reduce risks of exposure to pesticides and to induce the demand for timely medical care for the diagnosis and management of possible accidents with pesticides. Such activities will be permanently carried out in all of the zones scheduled in the ICEPG, with certain priority before the spraying occurs and during the period immediately after the spraying. The activities include the following:

Designing and developing informational messages aimed at the community regarding prevention measures and management of possible situations of exposure to pesticides, which will be permanently broadcast in the zones scheduled for spraying in the ICEPG. The massive media will broadcast these messages, thus ensuring that this information will be of public domain.

Designing and developing informational bulletins of a technical nature aimed at health and environmental authorities that direct prevention and control actions for possible situations associated with the spraying.

The local health and environmental authorities will be in charge of carrying out the above-mentioned activities, using the guidelines and technical assistance of provincial department and national level authorities.

3.3. HEALTH CARE FOR AFFECTATIONS RELATED TO ILLICIT CROPS AND THEIR ERADICATION

The actions aimed at guaranteeing timely, proper attention to possible risk situations or affectations effects to the population�s health include:

Preparing and strengthening health care services in the service network that exists in the areas of influence of the zones scheduled for spraying in the ICEPG. Each Territorial Health Division will define in its area of influence the health establishments where sufficient institutional development will be done to be able to respond and manage such cases.

Carrying out activities to induce the demand of services to provide the diagnosis and management of possible cases of exposure to pesticides among the population in the areas of influence of the sprayed zones, by actively seeking to develop health brigades and by performing channeling actions with community leaders.

Carrying out training programs aimed at community leaders and health professionals and technicians involved in the service network that exists in the areas of influence of the zones to be sprayed, and aimed at the health authorities and other officials involved in performing the ICEPG. In the areas of influence, the local health authorities will replicate training programs every time there is a turnover of the assigned health personnel. On the bases where the spraying is done, these programs must be set up every time a new operation starts, keeping a record of each activity.

The purpose of the health division personnel training contents and methodologies will be to contribute to strengthening the capacity of municipal and provincial department management for the prevention, supervision, and control of problems caused by pesticides, including those that may be produced as a result of spraying in the ICEPG.

The objective here is to improve the capacity to detect, diagnose, and clinically manage cases of exposure and intoxications caused by pesticides. To do so, the Ministry of Social Protection will prepare health care manuals and guidebooks.

The purpose of training this type of personnel is to develop their skills in identifying, monitoring, and controlling circumstances of risk to the population, associated with the use and management of pesticides, as well as to develop their abilities to investigate cases within the public health supervision process and community education for preventing and controlling risks at a domestic level. To do so, the Ministry of Social Protection will prepare care manuals and guidebooks.

The Territorial Health Divisions will carry out information and education activities aimed at personnel in other sectors and the community at large, regarding the risks and potential effects of pesticides, as well as general prevention, supervision, and control measures. To do so, the Ministry of Social Protection will design proper educational material.

The objective of this activity will be to encourage the participation and integration of persons and institutions to supervise and control problems related to the use and handling of and management of pesticides. Special emphasis will be given to coordination with the ICA Regional Offices, the Regional Autonomous Corporations, SENA, the UMATAS, and Municipal Ombudsmen�s Offices.

e) Training the Operational Personnel Who Work with the Mixture Being Sprayed

Regarding this topic, the Territorial Health Divisions will support the training processes carried out by the entities in charge of guaranteeing the safety and industrial hygiene of the operations base operators, pilots, and personnel. In all cases, the provisions set forth in 1991 Decree 1843 regarding the use and handling of pesticides, especially those in Chapters IX, X, XIII, and XIV (see reference in the contents of Specification # 2) will be obeyed.

The General Health Social Security System will attend alleged events of exposure in accordance with its normal procedures and it will determine if there is a cause and effect relationship between the exposure to the sprayed mixture and the condition of the patient under study, pursuant to the protocol set forth by the Ministry of Social Protection.

To do so, a standardized protocol will be established and institutionalized to attend patients who have symptoms that make us suspect exposure or who have symptoms compatible with intoxication caused by pesticides. The protocol will include the following procedures:

Preparing a complete medical chart including occupational background.
Filling out the specific form for evaluation of exposure to pesticides and other chemical substances.
Doing a physical exam seeking signs compatible with intoxication caused by pesticides.
Taking samples to determine pesticides, pursuant to the criteria in the public health supervision protocol.
Giving medical care as required based on the established diagnosis.
In the event of the death of a patient where there is suspicion of intoxication caused by pesticides, performing a legal medical autopsy, pursuant to the procedures set forth by the Institute of Legal Medicine and Forensic Sciences.
Filling out the Notification Form for Intoxication Caused by Pesticides, if such is the diagnosis, and sending the notification to the Local Public Health Supervision Unit.

Health entities are responsible for establishing a possible cause and effect relationship between affected health and the Glyphosate used in the ICEPG. To do so, they have medical professionals duly trained to evaluate each case and pronounce a decision, pursuant to the protocol that the national health authority defines to evaluate and determine the possible damage to people�s health related to Glyphosate. The evaluation will be made maximum ten (10) days after the alleged exposure to the herbicide.

All health complaints received or remitted to entities other than health care service centers or to public health supervision units will be immediately referred to the above-mentioned health agencies set up in each territorial agency, to proceed with the medical evaluation and determine possible relations between the medical situation that motivated the consultation and exposure to Glyphosate and other related substances. Along those lines, information must be given to the persons involved as well as to the authorities and officials of the distinct agencies, for said evaluation to be done in a timely manner.

At any time, both entities that receive health complaints and the population at large may demand that health organizations make an evaluation of the health condition of persons who file complaints or who accede to services for consultation when they suspect the existence of physical signs and symptoms that they believe are associated with pesticides.

Follow-up will be done on a monthly basis to check scheduled activities against activities carried out. The Ministry of Social Protection General Director�s Office will be the entity that will do the plan follow-up and monitoring.

At the national level, the Ministry of Social Protection and the National Health Institute will be in charge of the health component; at the provincial department, district and municipal levels, the Territorial Health Divisions will be in charge.

Given the fact that the illicit crop eradication program sprays using Glyphosate, a broad spectrum herbicide, and, although the environmental risk evaluation reported the high degradability of Glyphosate in the different environmental surroundings, the operation of the program itself is subjected to several risk factors (outlawed armed groups, aircraft mechanical failures, environmental aspects, to name a few), which endanger human lives and the natural environment when, due to these facts, it is necessary to immediately dump all of spraying product.

The Contingency Plan (CP) is a document that provides response strategies to attend the emergencies that may arise during the different stages of Glyphosate handling, for the purpose of illicit crop eradication (transportation, storage, handling and spraying). Among the possible events that may occur, we include dumping (immediately dumping all of the Glyphosate from the aircraft), which action, in the oil sector, would correspond to spillage. For all events analyzed, we have established the responsible parties to be in charge of the CP operation as well as the mechanisms to supply basic information on the possibly affected areas. Likewise, we have established action procedures that must be followed when facing each type of situation, the parties to whom to request support, the equipment and production factors that would be required for each action.

By creating the illicit crop eradication program contingency plan, the Anti-Narcotics Police aims not only to respond in a timely manner to the contingencies that arise from the operation, but also to follow the National Total Emergency Attention Policy, with the support and participation of the different government entities and institutions, each one handling its portion, based on its mission and objectives.

The Contingency Plan (CP) is a set of activities and operations that must be planned and carried out, in order to anticipate, prevent and / or correct any eventuality that may arise due to operating, natural or exogenous failures, and that may cause some type of negative impact on people, their assets or on the environment.

The Contingency Plan is basically comprised of a Strategic Plan, an Operating Plan and a Database, with the following basic components:

The purpose of the strategic plan is for each responsible person or entity to clearly know its functions and responsibilities within the plan, to perform the functions assigned and to efficiently use the resources available to take care of emergencies.

The Contingency Plan covers the spraying program operations zones. Therefore, the National Police Anti-narcotics Division bases will have the equipment, mechanisms and personnel trained to handle possible incidents or accidents related to the aerial spraying processes.

Within the specific ICEPG implementation zones, the following have been defined as priority action zones within the Contingency Plan:

National Police Anti-narcotics Division bases and surrounding areas
Zones in which the aircraft used for spraying flies and routes between the bases and the application zones
Areas neighboring illicit crops

The CP structure is mainly based on the creation of a Permanent Emergency Committee (PCE is the Colombian acronym) for each base, responsible for the following activities:

Planning the actions to follow in the case of any eventuality
Establishing and organizing reactions in order of importance
Assigning pertinent functions
Directing and coordinating the actions to be followed
Evaluating the CP application results

The Coordination Centers for activating the Contingency Plan will be the National Police Anti-Narcotics Division spraying bases, where the required equipment is available for communication between the disaster attention team and the operations center.

The purpose of this plan is to establish the basic procedures of the Contingency Plan operation. It also defines notification, organization and operation principles and mechanisms.

Prevention and control measures
Communication with the internal support team
Communication with external support entities
Alarm activation
Contingency Plan activation
Evacuation during emergencies
Post-evacuation measures
Fire control in the storage area
Explosion control in the storage area
Spillage control in the storage area
Fire control in the spraying area
Explosion control in the spraying area
Spillage control in the spraying area
Contingency Plan evaluation
Training programs

Below we list the procedures or protocols to be followed in each Operating Plan component:

The Spraying Operations Commander will take the necessary steps to acquire the required materials and equipment for the Contingency Plan implementation, such as communications equipment, fire extinguishers, and first aid kits; and will order their installation in the corresponding sites. Fire extinguishers will be placed in the areas that are most vulnerable to fire.

The technician responsible for the Environmental Management Plan will be responsible for installing the fire and explosion signaling equipment and for their periodical checks, for the signaling in all areas on base: NO SMOKING, RESTRICTED AREA, AUTHORIZED PERSONNEL ONLY, USE SAFETY PROTECTION ELEMENTS, EMERGENCY EXIT, EVACUATION ROUTE, HIGH TENSION AREA, FIRE EXTINGUISHER, ETC... . That person will also manage the communications equipment maintenance.

The existing communication systems must be used to inform all personnel on the base of the emergency at hand for them to immediately arrive and give the pertinent recommendations.

When the internal groups cannot control the contingency, the Spraying Operations Commander will contact the existing external entities specialized in emergency attention to inform them of the type of emergency at hand, and to request their immediate arrival and support.

The Spraying Operations Commander will coordinate the actions with the internal and external support groups to respond to the emergency.

In the case of dumping, the Spraying Operations Commander will report and coordinate the necessary support with the different pertinent entities.

The Spraying Operations Commander will prepare an initial dumping report that will contain the basic information regarding the specific circumstances (where, when, and how), in order to preliminary estimate the magnitude and severity of the event.

For initial notification purposes, Form # 1 �INITIAL REPORT� will be used, (see Annex), taken from the National Contingency Plan and customized to the spraying program operation conditions.

In case of emergency, the Spraying Operations Commander must trigger the emergency alarm.

If there is any other person in the emergency room, this person must immediately inform the Spraying Operations Commander for him / her to trigger the alarm.

Once the corrective actions are initiated, the Spraying Operations Commander may order the alarm deactivation.

To activate the CP, we will take the customized levels from the National Contingencies Plan.

Once the emergency is reported, the Spraying Operations Commander will proceed to:

The CP activation may have different levels, according to the characteristics of the emergency:

In this type of event, the Program will take measures aimed at controlling the situation, by activating its maximum operating response level for attending the event, maximum three (3) hours after activation.

Level 2: Program CP Activation by Requesting Support to the Operating Committees

This occurs in remote zones within the program operation coverage, and is coordinated with the internal support groups and external support entities. This level will be activated 24 hours after the event.

TABLE 1. CP ACTIVATION LEVELS, OBTAINED AND EDITED FROM THE NATIONAL CONTINGENCY PLAN

LEVEL
HIGH VALUE This occurs in zones of human settlements, National Natural Park System zones, water supply sources			N3

MEDIUM VALUE It is developed in wooded zones with high drainage density.		N2

LOW VALUE Partial or total dumping on pastures or legal crops, in areas far from sensitive ecosystems	N1
	IMMEDIATE	LOCAL	REGIONAL

Level 3: Instantaneous Total CP Activation. Disaster � Highest Volume and Severity, within the Local CP Coverage Area

The event is totally out of the program operation area control, and exceeds the capacity of the requested local or regional assistance systems. National level agencies are required to organize the actions. This level will be developed if the event exceeds the level 2 operations capacities 48 hours after its occurrence, for which it will have the support of national level agencies.

The highest priority is to protect and preserve the lives of persons threatened by the incident.

When there are resource and time limitations, it will be necessary to first protect the resources that are most valuable and important for the security and welfare of the base personnel and of the population in the surrounding area. Next, we will protect resources with a high ecological value and the greatest sensitivity, such as primary and secondary woodlands with native vegetation, in order to ensure sustainability of the ecosystems. And last, we will protect socio-economically and ecologically threatened resources that have a risk indicator of medium or low, such as legal crops or brush.

If we have to select between protecting two threatened resources of high value to the community, but with different risk indicators, priority will be given to the most sensitive one. If there are two resources with equal risk value, we will opt to protect the resource that, if affected, would cause greater socioeconomic impact on the human population at a short or mid term.

If any of the above-mentioned measures cannot be applied, we will proceed to do emergency dumping at an altitude of 5,000 feet, and to do follow-up on the area if the public order conditions so permit; otherwise, we will notify the pertinent entities to do follow-up on the possible effects.

2.2.7.1 Evacuation and Assistance in the Event of Fire or Explosion on the Base due to Failures of an Operational Nature

The Spraying Operations Commander will direct the area evacuation in a rapid, organized manner, will stop people from returning to the evacuated areas, will make sure that all of the personnel has been evacuated; otherwise, he/she will do a rapid inspection of the area.

The Spraying Operations Commander will check to make sure that all personnel is unharmed, report missing persons, and prevent personnel from re-entering the hazardous area, except for the internal support group personnel.

The following procedure will be delivered to the transportation entity contracted for transporting farming chemicals.

Verify the condition of the driver and of other accompanying personnel, in order to protect human lives, providing first aid services to those who so require, staying away from the vehicle in case of a possible fire or explosion

When the spillage has occurred in bodies of water, the company must inform such situation as soon as possible to the personnel who operate intakes downstream; absorbent barriers must be installed around the intakes located downstream once the emergency has been declared. It is necessary to go along the edge of the affected body of water to identify the spots affected, and proceed to isolating and cleaning them; then, inform the local authorities and experienced external groups, if the spill exceeds the transportation company�s possibility to clean it.

When the spillage has occurred on the ground, the transportation company will isolate the area with security bands, will proceed to do the cleaning, and will isolate the existing sewers or drains so that the affected area does not expand.

The Spraying Operations Commander must order the personnel responsible for farming chemicals and fuel to suspend their activities, and to prepare to deploy the corresponding procedure in response to the emergency.

The fire protection group will isolate the area where the fire is, evaluate the type of fire to select the most appropriate fire extinguishing equipment. Small fires may be put out by using extinguishers nearby. Recharge or replace the equipment used after the fire is controlled.

The Spraying Operations Commander will notify the civilian personnel on the base, for them to occupy their assigned places in order to ensure their safety; if security conditions so permit, civilian personnel must be evacuated immediately.

a. Primary Incident Report. The aircraft pilot must report the events right after they occur.

It is possible that the pilot not report the incident immediately after the event occurs, due to damages that may affect the aircraft communication systems or to the pilot�s not detecting the incident in a timely manner or if the incident ended up in a fatality (aircraft accident).

When the incident is detected and the communication systems have not been affected, the pilot must immediately report to the base, specifically to the Spraying Operations Commander, who verifies the pilot�s integrity and, along with him/her, makes a primary or initial evaluation of the damage.

When the aircraft has suffered an incident, no matter if the incident is of low, medium or high severity, it must return to the base. Prior to returning to the base, the pilot and the Spraying Operations Commander, after having evaluated the incident, establish the need to dump the product, based on the following order of importance:

Low Severity Incident. We include incidents where the safety of the aircraft and, therefore, the pilot�s safety are not seriously endangered. In this type of incident, no product dumping is considered. In this case, the aircraft suspends the operation and immediately returns to the base.

Medium Severity Incident. The pilot has operational and airworthiness capacity that enables him / her to evaluate the zone for product dumping. Priority is given to pre-established zones in the spraying zone characterization. The pilot immediately returns to the base after dumping the product.

High Severity Incident. This is an event of great risk, where the pilot lacks sufficient airworthiness to select the spot to dump in, thus he/she has to dump the product immediately and return to the base.

Fatal Severity Incident. These are incidents where the final result is fatal; they usually end up in the aircraft being shot down.

The follow-up on the operation as described in the CP is established within the environmental monitoring program.

b. Response Team Activation. This operating level relates to all activities carried out to activate the emergency attention group during the spraying process. Among them is the reconfirmation of the exact place of the incident, the security study of the area in which the incident occurred, going to the area, the evaluation of the need of taking corrective measures or not, and dumping, if required.