Link to FAQ Primer: BHA COVID Strategic IEE 1

STRATEGIC INITIAL ENVIRONMENTAL EXAMINATION FOR BHA COVID-19 ARPA ESF SUPPLEMENTAL PROJECT/ACTIVITY DATA

Project/Activity Name: BHA COVID-19 American Rescue Plan Act (ARPA) ESF Supplemental Funding

Geographic Location(s) (Country/Region): Global

Implementation Start/End Date (FY or M/D/Y): April 2021 to April 2022

Solicitation/Contract/Award Number(s): Multiple, TBD

Implementing Partner(s): Multiple, TBD

Bureau Tracking ID & Permalink: https://ecd.usaid.gov/document.php?doc_id=53252

Tracking ID of Related BHA IEEs (if any): AFR COVID PIEE, BHA RFA IEEs, Agency IEEs1

ORGANIZATIONAL/ADMINISTRATIVE DATA:

Implementing Operating Unit(s): BHA

Other Affected Operating Unit(s): GH, DDI, Regional Bureaus

Lead BEO Bureau: BHA

Funding Amount & Account(s)2: $1.3B ceiling, Economic Support Funds (ESF)

Prepared by and Date: ECOS; April 2021

ENVIRONMENTAL COMPLIANCE REVIEW DATA:

Analysis Type: IEE & PERSUAP

Environmental Determination(s): Negative Determination

IEE Expiration Date (if applicable): May 2022

Climate Risks Identified (#): 8, Moderate

1 Refer to Annex 3 for a list of permalinks to the other coordinated Agency COVID PIEEs. 2 IDA funding is not included in ARPA’s Supplemental COVID funding, Only ESF and Title II

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SUMMARY OF FINDINGS

PURPOSE AND SCOPE The purpose of this Strategic Initial Environmental Examination (IEE) is to provide a review of the environmental impacts and climate risks of the 2021 American Rescue Plan Act (ARPA) ESF Supplemental funding for the BHA response to the global COVID-19 pandemic. This IEE seeks to raise awareness while motivating action around climate and environmental crises in humanitarian assistance, including how healthy ecosystems help mitigate “spillover” of infectious diseases. See FAQs on this COVID Strategic IEE.

ACTIVITY TYPESBHA will use the COVID-19 supplemental funding to support targeted response programs that address increased humanitarian needs resulting from and exacerbated by the COVID-19 pandemic, as well as make investments to prepare for future outbreaks in humanitarian settings. BHA will prioritize initiatives that focus on new and existing humanitarian emergencies, mitigate severe food insecurity and prevent famine, and/or strengthen humanitarian systems for outbreak response.

ENVIRONMENTAL DETERMINATIONS AND CLIMATE RISK RATINGS All activities receive a 22 CFR 216 Negative Determination and a Climate Risk Rating of moderate. Exemption criteria for non-IDA funded activities does not apply to ESF, given that the emergency criterion of ADS 204.3.10(c)(2) is not met.

BEO SPECIFIED CONDITIONS OF APPROVALCondition 1: Recipients must review the IEE distributed by the C/AOR and must report on environment and climate considerations.

Condition 2: BHA to strategically advance opportunities for inclusive green COVID recovery including grant and contracts, such as Learning Agendas.

Condition 3: Follow existing guidance and procedures in emergency application guidelines for environmental safeguarding for COVID-19 response

Condition 4: PIOs to follow internal environmental and climate policies and procedures.

Condition 5: All BHA programs including pesticides will follow pertinent guidelines per USAID pesticide procedures.

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USAID APPROVAL OF INITIAL ENVIRONMENTAL EXAMINATION

PROJECT/ACTIVITY NAME: BHA COVID-19 American Rescue Plan Act (ARPA) ESF Supplemental Funding

Clearance Clearance by email 4/29/2021

Taylor Stager, Acting Office Director, Humanitarian Business and Management Operations (HBMO), BHA

Date

Concurrence

Erika J. Clesceri, BHA Bureau Environmental Officer (BEO) and Climate Integration Lead (CIL)

Date

DISTRIBUTION:

● BHA A&A Working Group● BHA: ALAC, MENA, OA, G3PC, TPQ, FARO● BHA COVID Council● BHA Leadership● BEOs, REOs● USAID Environmental Compliance Database

5/6/21

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INITIAL ENVIRONMENTAL EXAMINATION

1.0 PROJECT/ACTIVITY DESCRIPTIONThis section 1 broadly describes the proposed activities which will be considered within the environmental and climate contexts and conditions discussed in Section 2.

1.1 PURPOSE OF THE STRATEGIC IEE

The purpose of this Strategic Initial Environmental Examination (IEE) is to provide a review of the environmental impacts and climate risks of the 2021 ESF Supplemental funding for the BHA response to the global COVID-19 pandemic (described herein).

The purpose of a Strategic IEE is to systematically evaluate the environmental implications of a proposed policy, plan or program at a strategic level. To allow for a means for looking at cumulative effects and appropriately address them at the earliest stage of decision making alongside economic and social considerations. The Strategic IEE assesses the extent to which a given policy, plan or program:

● provides an adequate response to environmental and climate change–relatedchallenges;

● may adversely affect the environment and climate resilience, and● offers opportunities to enhance the state of the environment and contribute to climate-

resilience.

Given that the COVID supplemental funding for BHA will support a broad range of global activities, this strategic-level IEE will also identify a system of BHA technical oversight as in the USAID COVID-19 Guidance for Implementing Partners3 which, when applied in the design of the actions in the response, will avoid a significant negative effect on the environment, or subsequent Positive Determination.

This IEE will highlight considerations related to climate and environmental degradation drivers of the pandemic, environmental impacts of COVID (and COVID response).

1. Environmental Degradation Drivers of Pandemics2. Impact of COVID-19 on the Environment3. Impact of COVID-19 Response on the Environment4. Climate Drivers of COVID-19 Pandemic

3 Additional guidance includes BHA COVID-19 Guidance: BHA Resilience Food Security Activity Partners Working in COVID-19 Affected Operating Environments and Interim Guidance for Applicants Engaging in COVID-19 Humanitarian Response

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Responses to global crises present an opportunity to build back better by integrating sustainability and justice into our work. As such, this IEE seeks to raise the profile and early design considerations that healthy ecosystems help mitigate spillover of infectious diseases, while damaged habitat harbors wildlife that are more likely to have “spillover” of infectious disease.

To ensure cross-Agency coordination and a consistent approach, this BHA COVID-19 2021 Supplemental IEE was developed in consultation with BEO teams in the other pillar and regional bureaus across the Agency, with the Agency Environmental Coordinator, and with the General Counsel, E3. The following has been agreed upon:

● Flexible, but compliant: This proactive and flexible approach will permit the Agency torespond in advance of the demand, while remaining compliant.

● Tailored to each: Bureaus will draw from global guidance to tailor IEEs to their needs,without duplicating efforts.

● Exemptions for ESF (non-IDA) Do Not Apply: Invoking an “waiver” from regulations foractivities is an option of last resort. BHA activities (funded with the IDA account) have anautomatic “Exemption” under 22 CFR 216, and, therefore, BHA has honed technicaloversight mechanisms for decades through the Office of Technical and Program Quality(TPQ), and predecessors. While BHA will utilize TPQ expertise, the Exemption criteria ofADS 204 do not apply to these ESF funded activities, as described in detail herein.

1.2 ACTIVITY CONTEXT

While much has been learned in 2020, COVID-19 is still a new disease that is distinct from other respiratory illnesses. Although coronavirus and influenza infections may present with similar symptoms, the virus responsible for COVID-19 is different with respect to community spread and severity. There is still much to discover about the disease and its impact in different contexts. Preparedness, readiness, and response actions - including physical distancing - will continue to be driven by rapidly accumulating scientific and public health knowledge.

BHA will use the FY 2021 COVID-19 supplemental to address humanitarian needs in countries with existing Declaration of Humanitarian Need (DHN). BHA may target settings and populations where public health emergencies have become wider humanitarian emergencies, in coordination with USAID/Global Health or other relevant bureaus. In such cases, a new COVID-specific DD will be required. To determine when this standard has been met, teams are encouraged to use the Criteria for BHA to Respond to COVID-19 Outside of Existing Complex Humanitarian Emergencies. While BHA has made the strategic decision not to utilize COVID-19 ESF supplemental funds for Early Recovery, Risk Reduction, and Resilience (ER4) programming at the country level, supplemental funds will be prioritized for strengthening global and regional infectious disease preparedness at the sectoral or humanitarian system level. The IEE and subsequent recipient reporting creates a timely and critical data stream to inform BHA’s COVID-19 Learning Agenda.

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1.3 ACTIVITY DESCRIPTION

This IEE analyzes the environmental and social impacts and climate risks associated with the activities planned as part of BHA’s COVID-19 response with supplemental funding.

BHA will use the COVID-19 supplemental funding to support targeted response programs that address increased humanitarian needs resulting from and exacerbated by the COVID-19 pandemic, as well as make investments to prepare for future outbreaks in humanitarian settings. BHA will prioritize initiatives that focus on new and existing humanitarian emergencies, mitigate severe food insecurity and prevent famine, and/or strengthen humanitarian systems for outbreak response.

The intent is that COVID-19 supplemental funding will be programmed in FY 2021 and also in FY 2022 as needed.

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2.0 BASELINE ENVIRONMENTAL INFORMATION This section 2 describes environmental and climate baselines (contexts and conditions) against which potential environmental and climate risks will be discussed in Section 3.

2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT, PHYSICAL, CLIMATE, SOCIAL, THREATENED AND ENDANGERED SPECIES)

Relationship Between Nature and Disease

This pandemic further demonstrates the UN Environment Program (UNEP) Healthy Environment, Healthy People paradigm where the degradation of the environment – the air we breathe, the food we eat, the water we drink, and the ecosystems which sustain us – is estimated to be responsible for at least a quarter of the global total burden of disease.

Global Baselines are Shifting, Environmental Drivers of Pandemics

Experts indicate that COVID-19 is just the latest in a series of zoonotic diseases which will continue to plague society. According to UNEP, diseases passed from animals to humans are on the rise, as the world continues to see unprecedented destruction of wild habitats by human activity. UNEP’s Frontiers 2016 Report on Emerging Issues of Environment Concern shows zoonoses threaten economic development, animal and human well-being, and ecosystem integrity.

Ultimately, together the 1) rapid emergence of zoonotic disease emergence (like COVID-19), 2) biodiversity loss and 3) climate change all share common anthropogenic drivers which are increasing and causing global shifts in ecological baselines. These drivers include land use change, habitat fragmentation, expansion of the agriculture frontier, and wildlife harvest and trade.4567

In addition to other invaluable ecosystem services provided to humans, healthy ecosystems help mitigate spillover of infectious diseases, while damaged habitat harbors wildlife that are more likely to have “spillover” of infectious disease. The following baseline conditions and dynamics have leant themselves to the COVID-19 disease emergence:

● Fragmented ecosystems stress wildlife, while healthy ecosystems provide goodnutrition for wildlife, which enhances immune responses and decreases viralload/shedding in reservoir hosts8 and reduced wildlife roaming close to human-dominated areas for food.9 Humans and their livestock are more likely to contact wildlife

4 Patz et al, 2004. Unhealthy Landscapes: Policy Recommendations on Land Use Change and Infectious Disease Emergence 5 Loh et al, 2015. Targeting Transmission Pathways for Emerging Zoonotic Disease Surveillance and Control 6 Huong et al, 2020. Coronavirus testing indicates transmission risk increases along wildlife supply chains for human consumption in Viet Nam, 2013-2014 7 Plowright et al, 2020. A call to action: Understanding land use-induced zoonotic spillover to protect environmental, animal, and human health 8 Becker et al, 2015. Linking anthropogenic resources to wildlife–pathogendynamics: a review and meta-analysis 9 Plowright et al, 2017. Pathways to zoonotic spillover

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when more than 25% of the original forest cover is lost;10 Fragmentation has placed over 70% of the world’s forests within 1 km of an edge.11

● Food web dynamics are damaged in heavily degraded ecosystem habitats, whilehealthy, intact habitats have strong “trophic cascades” or predator-prey populations thatare in ‘balance’. Human-dominated areas where the remaining wildlife populations aretypically generalist species (i.e., small rodents) have a proportionally high risk of beingzoonotic disease reservoirs.121314 Likewise, threatened or endangered species that arefacing declines in their habitat, (or high pressure from unmanaged wildlifetrade/exploitation) harbor more zoonotic pathogens compared to those threatened forother reasons.15

● Healthy ecosystems minimize anthropogenic stresses to wildlife caused bydeforestation, degradation, fragmentation and pollution (air, water, noise), whichincrease stress hormones and negatively impact immune function in birds andmammals, which can increase viral load/shedding in reservoir hosts.1617

COVID-19 Context in BHA Operating Environment

The global context of this pandemic will create complicating factors, such as insufficient health care facilities and supplies, differing or confusing government guidance and mandates, and limited capacity to address disease spread (e.g., stay-at-home or quarantine orders).

As outbreaks progress, communities may face additional challenges where USAID commonly operates. For example, mandated business closures will result in loss of household income, increased poverty, and food insecurity.

2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER INTERNATIONAL STANDARDS, ENVIRONMENTAL AND SOCIAL LAWS, POLICIES, AND REGULATIONS

This IEE pertains to applicable standards, laws, policies, and regulations for each BHA-affiliated country in relation to the COVID-19 outbreak. During the pandemic, standards can quickly evolve, and therefore, local officials must be consulted to identify applicable laws, policies, and regulations at the time of the intervention.

The USG has issued guidance for the U.S. which, as appropriate, can serve as additional reference for USAID activities. UN and local authorities are developing their own guidance and

10 Faust et al, 2018. Pathogen spillover during land conversion 11 Evans et al, 2020. Links between ecological integrity, emerging infectious diseases originating from wildlife, and other aspects of human health - an overview of the literature 12 Johnson et al, 2020. Global shifts in mammalian population trends reveal key predictors of virus spillover risk 13 Gibb et al, 2020. Zoonotic host diversity increases in human-dominated ecosystems 14 Min et al, 2021. An exploration of the protective effect of rodent species richness on the geographical expansion of Lassa fever in West Africa 15 Johnson et al, 2020. Global shifts in mammalian population trends reveal key predictors of virus spillover risk 16 Messina et al, 2018. Physiological and immunological responses of birds and mammals to forest degradation: A meta-analysis 17 Becker et al, 2020. Macroimmunology: The drivers and consequences of spatial patterns in wildlife immune defence

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protocols. Online information may change as the knowledge about an outbreak evolves, therefore, any references must be regularly consulted for updates.

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3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL IMPACT AND CLIMATE RISK

This section 3 describes the environmental impacts and climate risks of both the COVID-19 pandemic, and the BHA actions in response to the pandemic.

This section will discuss intersectionality between COVID-19, climate and environment:

1. Impact of COVID-19 on the Environment2. Impact of COVID-19 Response on the Environment3. Climate Drivers of COVID-19 Pandemic

3.1 ENVIRONMENTAL IMPACTS OF COVID-19 AND COVID-19 REPONSE

The anticipated environmental impacts of COVID-19 are both direct and indirect. In many cases, existing environmental crises have been exacerbated, of which impacts can be disproportionately felt by women and other historically vulnerable and marginalized communities, summarized and in detail below:

Summary of Environmental Impacts of COVID-19

● Increased waste and reduced waste management capacity due to increasing wastestockpiles as PPE use increases and management capacity decreases in many cases.Use of single-use plastics has also increased as plastic bag bans and recyclinginitiatives are paused.

● Exposure to hazardous substances if increased use of disinfectants is not managedappropriately.

● Increased deforestation18 due to reduced policing of international timber exploitationand community member livelihood coping mechanisms (e.g., charcoal making,firewood).

● Increased non-timber forest products (e.g., wildlife trafficking), and associatedminerals exploitations (e.g., artisanal gold, tantalum, tin, bauxite, mining etc.).

● Impacts to wildlife and conservation due to COVID-19 exposure (in the case of greatapes), loss of tourism revenue, and management challenges in protecting wildlife.

18 As noted by the Brazil Institute: “As the coronavirus spreads, there has been a devastating impact on forested areas in particular. Reports indicate that deforestation is spiking in many regions of the world. COVID-19 hampers enforcement and heightens economic hardship, driving deforestation and threatening the region's indigenous communities. Already, satellite data indicates that deforestation from January to March was 51 percent higher than for the same period in 2019.”

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Disaggregation of Environmental Impacts of COVID-19

Environmental and human health impacts related to:

● Exposure to COVID-19 at gatherings, informational sessions, and during essential work;

● Exposure to disinfectants/germicides, and hazardous wastes (medical waste,pharmaceuticals, electronics) in health facilities, businesses, public spaces, and/orhouseholds; and

● Increased exposure to zoonotic diseases through increased human-wildlife contact andwildlife trafficking.

Direct environmental and ecological impacts of COVID-19 response related to:

● Pollution/contamination from inappropriate use or management of COVID-19disinfectants19;

● Pollution/contamination from inappropriately managed Small and Medium Enterprises(SMEs), such as those producing PPE or sanitizer;

● Increase in infectious waste stockpiles, as PPE use increases, exacerbated my limitedmanagement capacity;

● Increase in the use of single-use plastics, as, in some cases, plastic bag bans are liftedto minimize the spread of the virus on reusable bags.

● Other livelihood support activities such as agriculture, irrigation, ag inputs (fertilizer andpesticides).

Indirect environmental and ecological impacts related to COVID-19 coping mechanisms:

● Increased deforestation due to reduced policing of international timber exploitation andcommunity member livelihood coping mechanisms (e.g., charcoal making, firewood);

● Increased non-timber forest products (e.g., wildlife trafficking), and associated mineralsexploitations (e.g., artisanal gold, tantalum, tin, bauxite, mining etc.).

Additional information on the connection between COVID-19 and the environment:

● Geneva Environment Network COVID-19 and the Environment● UNEP Guidance on COVID-19 and the Environment

19 For example, note that the active ingredients in bleach may be broken down by UV light. Therefore, indiscriminate spraying of bleach outdoors may be ineffective, as well as an environmental hazard. See Science Magazine article: Does disinfecting surfaces really prevent the spread of coronavirus?

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● Working With the Environment to Protect People UNEP’s COVID-19 Response

3.2 CLIMATE RISKS TO COVID-19 RESPONSE INTERVENTIONS & PREVALENCE OF ZOONOTIC DISEASES

The January 27, 2021 Executive Order 14008 “Tackling the Climate Crisis at Home and Abroad emphasizes the need to mainstream climate risks in every aspect of USAID’s work. The following sections describe some of the key climate change risks of the COVID-19 pandemic and pandemic disease transmission in general. To summarize, Section 4.3 presents the Climate Risk Management table for this IEE.

Climate Change and Disease Incidence

Weather conditions, which are influenced by long-term climate patterns, are well-established influencers of human health. Climate change is therefore likely to impact human health in numerous ways via direct or indirect exposure to weather and climate risks.

For instance, it is expected that climate change will have an indirect impact on the future spread of zoonotic diseases. Firstly, climate change will continue to bring wild animals and people into closer contact, especially in areas where food is in short supply. For example, if crops fail due to flooding or drought, hunger will likely force people to hunt and eat more wild animals. The reverse is also true as wild animals' habitats are destroyed by climate change or human activity they may be forced to encroach on human settlements i.e. farms to find food and water sources, raising the risk for exposure.

Further, climate change can both directly and indirectly increase exposure to disease vectors, exacerbating the current and underlying burden of disease. WHO notes that increasing temperatures and changing rainfall patterns can facilitate transmission of food and waterborne diseases as well as vector-borne and zoonotic diseases. For example, mosquito (vector for malaria, dengue) breeding, feeding, survival and distribution are all impacted by weather conditions and extreme weather events, while vibrio is highly sensitive to temperature, precipitation and extreme weather events that can concentrate bacteria in water sources.

Climate and COVID-19

Climate and weather shocks and stressors can cause negative impacts to human health, such as heat waves leading to increased heat related illness, or changing temperatures, humidity and rainfall patterns, all of which change the distribution of infectious diseases. While it is still early, preliminary evidence suggests that the distribution of significant community COVID-19 outbreaks is related in part to temperature and humidity. If this holds true, it may be possible to predict the regions most likely to be at higher risk of significant community spread of COVID-19, allowing for concentration of public health efforts on surveillance and containment. At the same

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time, a direct causation has not been proven between temperature, latitude, and COVID-19, and predictions in the near-term are speculative and have to be considered with extreme caution.20

Furthermore, climate and weather shocks and stressors may also weaken health systems, and these systems' ability to respond to COVID-19. The most vulnerable populations are often the most impacted by climate and weather shocks and stressors, potentially putting more people at risk of serious illness due to COVID-19. These impacts may magnify the severity of COVID-19.

There is also evidence to suggest that climate change can impact the spread of zoonotic diseases by increasing the likelihood of human-wildlife interactions. For example, climate change can impact wildlife species’ ranges as they seek favorable conditions or food sources, bringing them in closer contact with humans. In some cases, species may benefit from changing climate patterns, leading to increased species density which can lead to greater pathogen transmission within the species.21 Inversely, as climate change negatively impacts human’s livelihoods, people are more likely to seek alternative livelihoods or livelihood diversification through monetization of non-timber forest products, including wildlife. Both scenarios increase the likelihood for pathogen transmission between wildlife and humans.22

20 Sajadi, Mohammad M. and Habibzadeh, Parham and Vintzileos, Augustin and Shokouhi, Shervin and Miralles-Wilhelm, Fernando and Amoroso, Anthony, https://ssrn.com/abstract=3550308 or http://dx.doi.org/10.2139/ssrn.3550308Source: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3550308 21 Source: https://kleinmanenergy.upenn.edu/news-insights/storm-surge-wildfires-and-pandemics-how-climate-change-is-increasing-the-risk-of-zoonotic-disease-outbreaks/ 22 Source: https://www.medicalnewstoday.com/articles/how-might-global-warming-influence-the-spread-of-viruses

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4.0 ENVIRONMENTAL DETERMINATIONS AND CLIMATE RISK RATINGS This section 4 describes both the environmental compliance regulatory (22 CFR 216) and Climate Risk Management ADS 201mal risk ratings. Section 5 describes the corrective actions needed to mitigate the risks identified in the proceeding sections.

4.1 ENVIRONMENTAL DETERMINATION OF INTERVENTIONS

All activities receive a Negative Determination with Conditions.

Most activities that previously qualified as a Categorical Exclusion (training, capacity building, meetings, etc.) now present a risk of transmission through workplace exposure, and hence are re-classified as a Negative Determination. This determination will remain in place until further notice from the BEO, contingent on approved vaccines and testing being widely-available and accessible.

The low environmental risk or Categorical Exclusion determination (per 22 CFR 216.2(c)) no longer applies to Education, Training, or any social gatherings and meetings within current BHA activities, unless they are virtual.

The Exemption criteria for non-IDA funded activities does not apply to supplemental ESF funding, given that the emergency criterion of ADS 204.3.10(c)(2) is not met, since the Agency is conducting “advanced planning.” Likewise, the COVID-19 supplemental funded activities covered herein do not qualify for the Exemption of “Other Emergency Circumstances” pursuant to 22 CFR 216.2(b)(1)(ii), as the Assistant Administrator and Administrator indicated in writing and the White House Council on Environmental Quality has not formally been consulted.

ESF funds that are blended or “comingled” with other funding sources (such as IDA) are required to abide by the more restrictive authority. Therefore, this COVID Strategic IEE continues to apply for awards with blended funding.

4.2 CLIMATE RISK RATINGS OF COVID-19 RESPONSE INTERVENTIONS

Climate Risk Management (CRM) screening is required for all USAID awards, per ADS 201mal. CRM is the process of assessing and adaptively managing climate risks that may impact the ability of USAID programs to achieve objectives. Climate risks that cause negative consequences to programming are reduced through climate change adaptation (CCA) measures to changing climatic conditions.

Climate Risk Ratings for the activity types in this IEE are moderate.

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4.3 CLIMATE RISK MANAGEMENT TABLE

The Climate Risk Management (CRM) table assesses climate risks from BHA COVID-19 response activities, as well as climate risks related to COVID-19 transmission.

Table X. Climate Risk Management Screening DEFINED OR ANTICIPATED

PROGRAM INTERVENTION

TIME- FRAME GEOGRAPH

Y CLIMATE RISKS RISK

RATING CLIMATE RISK MANAGEMENT OPTIONS

HOW ARE RISKS

ADDRESSED

OPPORTUNITIES TO STRENGTHEN

CLIMATE RESILIENCE23

BHA COVID-19 Supplemental ESF funding Response Activities

Risks Related to COVID-19 Response Activities, Specific to COVID-19 Elements

Life of Award

Areas of BHA COVID-19 Response (multiple

countries)

Supply chain disruption (including disinfectants and

PPE) due to extreme climate or weather events

Moderate

Logistic and supply chain delivery plans and teams

should consider alternative routes, be adaptive, and both plan ahead and be

prepared for extreme climate and weather events

both increasing demand, and interrupting supply

chain delivery.

To be determined by

recipient based on local

context.

Consider working with host country

government to improve climate risk planning

and resilience of supply chains.

Locations hosting meetings or trainings and associated

access routes may be impacted by extreme

weather events or power availability.

When planning trainings and similar activities,

recipients must consider seasonal forecasts and

rainy seasons when choosing dates. Recipients

should use contingency planning and consider

virtual trainings as options.

Consider integrating how climate contributes

to pandemics and infectious disease occurrence during

trainings.

Improper disposal and waste of PPE, clogging

drainage and waterways, increasing risk of flooding

due to heavy rainfall events.

Ensure sufficient waste management collection and

disposal systems are in place to accommodate

increased PPE waste, away

Consider working with local waste

management authorities to plan for and minimize waste

runoff associated with

23 Recipients should expand on opportunities based on local context and initiatives.

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from known at-risk flooding zones.

extreme weather events and flooding.

Effectiveness of disinfectants/ germicides

could be impacted by changing temperature

ranges. Sunlight may also breakdown the active ingredients in bleach

Disinfectants with published temperature ranges

appropriate for use should be prioritized. Consider UV

ray exposure before spraying bleach outdoors, as it may be ineffective.

Consider raising awareness of climate

risk’s impacts to efficacy of disinfectants.

Risks to COVID-19 and Increased Risk of Zoonotic Disease Transfer

Life of Award

Areas of BHA COVID-19 Response (multiple

countries)

Temperature extremes can make it more difficult to

social distance, as outdoor activity may be limited.

Moderate

Recipients must plan ahead and manage projects adaptively in order to

minimize exposure to and transmission of COVID-19,

following USAID, BHA, WHO and local COVID

guidelines.

To be determined by

recipient based on local

context.

Consider integrating how climate contributes

to pandemics and infectious disease occurrence during

trainings.

While it is still early, preliminary evidence

suggests that the distribution of significant community COVID-19

outbreaks is related in part to temperature and humidity Climate change can impact

species ‘ranges bringing them in closer contact to human settlements and

increasing the risk of zoonotic disease transfer.

Recipients should minimize impacts to wildlife habitats

to the greatest extent possible and consider

indirect impacts of programming, such as

increasing human-wildlife interaction.

Recipients should raise awareness of the risks of

zoonotic diseases amongst beneficiary communities.

Consider working with host country

governments to build capacity in monitoring

and surveillance of climate change

impacts to species’ ranges and

distributions.

Climate change impacts can disrupt livelihood

activities, leading communities to cope by encroaching into wildlife areas to make additional income through timber or

non-timber forest products. This brings humans and

wildlife into closer contact, increasing the risk of

zoonotic disease transfer.

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4.3 ENVIRONMENTAL THRESHOLD DETERMINATIONS AND CLIMATE RISK RATINGS

Table 2. Summary of Environmental Threshold Determinations and Climate Risk Ratings Illustrative Interventions

22 CFR 216 Environmental Determination Climate Risk Rating

BHA COVID-19 Supplemental ESF funding Response Activities

Negative Determination with Conditions Moderate

Negative Determination with Conditions Moderate

Negative Determination with Conditions Moderate

Negative Determination with Conditions Moderate

Negative Determination with Conditions Moderate

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5.0 CONDITIONS AND MITIGATION MEASURES This section 5 describes the required BEO Conditions (or actions) associated with those determinations and ratings. The previous section 4.0 issued Environmental Threshold Determinations and Climate Risk Ratings for the activities included in this IEE.

5.1. BEO CONDITIONS, APPLICABLE TO ALL ACTIVITIES

Inclusive Green COVID Recovery

Every crisis presents an opportunity to build back in a more effective and efficient manner. It is not advised to “return to normal” when normal is part of the problem. Rather, increased calls to build back better and safer, to avoid ramifications of continuing “business as usual.” A recent report from UNEP and Oxford University titled “Are We Building Back Better? Evidence from 2020 and Pathways for Inclusive Green Recovery Spending” found that only 2.5% of the trillions of dollars marked for COVID-19 recovery spending will have “positive green characteristics.”

As noted in this study, “Early findings suggest that global green spending is so far incommensurate with the scale of ongoing environmental crises and that associated economic and social gains are not being fully captured.”

There are practical actions that can substantially reduce these emerging disease risks. To be effective, these actions require interdisciplinary collaboration across the human, environmental, and animal health sectors, a best practice approach known as One Health.

Further, note that BHA is engaging with IFRC and ICRC, members of the Environment in Humanitarian Action (EHA) Network led by the Joint UNEP/OCHA Environmental Unit (JEU) as part of a stakeholder consultation process on their Climate and Environment Charter. This charter targets humanitarian organizations to pledge their commitment to support climate change mitigation and adaptation as well as environmental sustainability in humanitarian interventions. While USAID has not signed onto the charter as of yet, BHA is supportive of these commitments and the message of the charter.

BHA aims to foster regional and country-level adaptations for specific contexts and draw on the current evidence base and lessons learned from the initial COVID-19 supplemental response, while ensuring global funding allocations are balanced, transparent, and informed by consistent criteria.

Additional information on green and inclusive response can be found at the following sites: ● COVID-19 and Planetary Health: How a Pandemic Could Pave the Way for a Green

Recovery● African Ministers of the Environment commit to support a green COVID-19 recovery plan● Collaborative Partnership on Forests urges to turn the historic challenge of COVID-19

into an opportunity for forestry and sustainability

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The following five (5) conditions present both recommendations and existing robust procedures to integrate green and inclusive approaches into COVID-19 response activities. This IEE is included in Award language for recipients and is publicly available at USAID.gov.

Condition 1: Recipients must review the IEE distributed by the A/COR and report on environment and climate considerations, as described within.

Recipient are to include responses to these core climate and environmental questions which are based on the 8+3 template of the “Grand Bargain” commitments of humanitarian actors towards harmonized reporting24. Recipients are to include responses in their regular semi-annual and/or annual reports (similar to how gender considerations are integrated into regular reporting):

1. Describe how environmental or climate issues were addressed. What did you do toensure that the environment was protected and to manage risks to the environment?What environmental guidelines or policies did you follow?

2. If the project produced positive outcomes for the environment, for climate sustainability,or better future resilience against natural disasters, write about them here.

A/CORs must verify that IEE reporting is included in the required reports as outlined in the award. The IEE and subsequent recipient reporting creates a timely and critical data stream to inform BHA’s COVID-19 Learning Agenda.

Condition 2: BHA to strategically advance opportunities for inclusive green COVID recovery.

Recipients are encouraged to share ideas on COVID-19 response activities that are Greener and More Inclusive with the listserv (BHA-BEO-Support@icf.com). For example:

● BHA recipients could include infectious disease transmission risks of ecologicaldisruption that can occur in irrigation activities.

● BHA recipients may consider how issues of environmental and climate justice impacttargeted communities in the COVID response.

● BHA recipients may consider how digital innovation tools like the Nexus EnvironmentalAssessment Tool (NEAT+) app can improve COVID-19 responses.

● BHA recipients may increase coordination with multilateral organizations and otherDonors to address issues of environmental safeguarding and climate resilience inCOVID-19 humanitarian response activities.

● BHA recipients may look for opportunities to improve supply chain sustainability, as inthe Joint Initiative for the Preliminary Scoping Study of Improving Sustainability ofHumanitarian Supply Chains, and newsletter.

24 See harmonizedreporting.com

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Recipients could consider the following questions:

• Can COVID-19 response activities exacerbate environmental impacts or climate risksdisproportionately felt by historically marginalized communities?

• How can response activities both meet the needs and hear the voices of vulnerable andmarginalized communities that are the embodiment of climate and environmentalinjustice?

• How can BHA recipients encourage global policy discussions around improving thesustainability of humanitarian response activities related to COVID-19?

Condition 3: Follow existing guidance and procedures in emergency application guidelines for environmental safeguarding for COVID-19 response.

Recipients implementing food security activities as part of COVID-19 response must follow the existing Emergency Application Guidelines (EAG) and Annex A: Technical Information and Sector Requirements, which includes environmental safeguarding measures, per regular procedures. The EAG covers environmental concerns such as appropriate waste management of PPE and appropriate infection prevention and control (IPC) practices.

As noted above, BHA has also developed COVID-19 Emergency Application Supplemental Guidance.

Condition 4: PIOs to follow internal environmental procedures.

For sound investment of US taxpayer dollars, USAID supports PIOs to adhere to their own climate and environmental policies, e.g., UN Greening the Blue. If PIO climate and environmental policies do not appear to fulfill “the purpose and intent of USAID requirements” then USAID (with the Bureau Environmental Officer and Climate Integration Lead) may recommend climate and environment strategies to improve project design and implementation. See Condition 5 for Pesticide Procedures

Condition 5: All BHA programs including pesticide support/use will follow pertinent guidelines per USAID pesticide procedures.

BHA recipients must take note that pursuant to 22 CFR 216.3(b), in the event that any interventions include the promotion, procurement, transport, storage or disposal of pesticides for agricultural or livestock interventions, vector control interventions, or construction material treatment, a PERSUAP for proposed pesticides must be approved by the BHA/BEO prior to the commencement of these interventions. BHA encourages its recipients to tier off existing USAID analyses when possible, thereby reducing the need to carry out new and potentially redundant analyses, yet allowing for the appropriate consideration of the specific needs and context of each resilience food security activities. Several existing PERSUAPs and Programmatic Environmental Assessments (PEAs) for pesticide use can be found on the Environmental Procedures- Emergency page. Please reach out to the BEO with any questions on PERSUAP development and/or use.

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Regarding COVID-19 response specifically, there are a range of environmental health concerns related to increased disinfectant and germicide25 use. While the EAG covers IPC, some non-medical-use germicides utilized for cleaning inanimate objects and surfaces (environmental surfaces) are classified by the US Environmental Protection Agency (USEPA) as pesticides. This definitional distinction does not suggest that non-medical disinfectants are more toxic than medical use disinfectants. For purposes of USAID environmental review, however, this USEPA definition triggers the Pesticide Procedures analysis found at 22 CFR 216.3(B)(1)A-L.

For any PIO awards involving pesticides with cost-type agreements, (as defined under ADS 308.3.9.1, and in line with ADS 308.3.10c), are to coordinate with the BEO to abide by 22 CFR 216.3 Pesticide Procedures. PIO activities that include fumigation of commodities have been assessed in advance by the USAID Phosphine Fumigation of Stored Agricultural Commodity Programmatic Environmental Assessment (PEA), which is recommended to be included in PIO awards documentation.

Please note that any use of a private cost-share by a USAID recipient for pesticide support, requires compliance with USAID Pesticide Procedures26 to reduce potential harm to communities.

For disinfectant use recipients must abide by the Pesticide evaluation Report (PER) found in Annex 1 and the Safer Use Action Plan (SUAP) found in Annex 2.

Annex 1: Pesticide Evaluation Report (PER) for Approved Disinfectants Annex 2: Safer Use Action Plan (SUAP) for Use of Disinfectants

For the purposes of disinfectant use for COVID-19 response activities, Annexes 1 and 2 satisfy the pesticide analysis requirements of 22 CFR 216.3.

Note that disinfectants/germicides are generally less dangerous than pesticides used for agriculture, fumigation/warehouse protection, construction or other health. The negative impacts of disinfectants are widely understood and well-controlled globally (e.g., the use of aquatabs in humanitarian assistance activities).

However, given the extreme behaviors some have taken for COVID-19 eradication (i.e., ingesting disinfectants), guidance on safe disinfectant use is extremely important for recipients and must be taken seriously.

25 A germicide is an agent that can kill microorganisms, and includes antiseptics and disinfectants. Antiseptics are germicides applied to living tissue and skin and disinfectants are antimicrobials applied only to inanimate objects. Source: https://www.cdc.gov/infectioncontrol/guidelines/disinfection/introduction.html 26 22 CFR § 216.3(b)(1)(Project Assistance) states that the procedures in 22 CFR § 216.3 (b)(1)(i)-(v) apply to all proposed projects involving use of pesticides, assistance for their procurement, or both, unless one of the exceptions to the pesticide procedures identified in (b)(2) apply. 22 CFR § 216 does not make a distinction based on cost share.

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6.0 LIMITATIONS OF THE STRATEGIC IEE

This BHA Strategic IEE fulfills the narrow task of helping to meet the environmental impact screening expectations of the Agency’s Environmental Procedures. It does not provide official guidance on how BHA programs and operating units must respond to COVID-19. The Strategic Framework for USAID’s BHA Programming for FY2021 COVID-19 Supplemental is the source of such official guidance.

Please note that the circumstances surrounding the COVID-19 pandemic continue to evolve rapidly. Given the dynamic nature of this situation and response efforts, this BHA COVID-19 IEE may be revisited and updated prior to its expiration date, must the need arise.

ANNEXES 1. Pesticide Evaluation Report (PER) for Approved Disinfectants2. Safer Use Action Plan (SUAP) for Use of Disinfectants3. Links to other Bureau COVID-19 PIEEs4. BHA COVID Strategic IEE Primer for 2021 American Rescue Plan Act (ARPA)

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ANNEX 1. PESTICIDE EVALUATION REPORT (PER) FOR APPROVEDDISINFECTANTS

For the purpose of this document, uses of disinfectants (germicides) are divided into non-medical and medical uses. Some non-medical-use germicides utilized for cleaning inanimate objects and surfaces (environmental surfaces) are classified by the US Environmental Protection Agency (USEPA) as pesticides. This definitional distinction does not suggest that non-medical disinfectants are more toxic than medical use disinfectants. For purposes of USAID environmental review, however, this USEPA definition triggers the Pesticide Procedures analysis found at 22 CFR 216.3(B)(1)A-L.

Note that disinfectants/germicides are generally less dangerous than pesticides used for agriculture, fumigation, or construction. The negative impacts of disinfectants used for health are widely understood and well-controlled globally (e.g., the use of aquatabs in humanitarian assistance activities).

However, given the extreme behaviors some have taken for COVID-19 eradication (i.e., ingesting disinfectants), guidance on safe disinfectant use is extremely important for recipients and must be taken seriously.

CATEGORIZATIONS OF DISINFECTANTS/GERMICIDES

USAID programs seeking to provide guidance to businesses, institutions and individuals in the procurement and use of disinfectants and sterilants on environmental surfaces (i.e., are not providing guidance on their use for medical purposes) must comply with conditions for non-medical Use of Disinfectants (see Part a) and seek guidance primarily from local authorities. USAID programs seeking to provide guidance for use of pesticides to medical facilities must comply with conditions for Medical Use of Disinfectants (see Part b).

Please note that any use of a private cost-share by a USAID recipient for pesticide support, requires compliance with USAID Pesticide Procedures27 to reduce potential harm to communities.

a) Conditions for Non-Medical Use of Disinfectants/Germicides

For activities described below, use of disinfectants/germicides constitutes use of pesticides:

● Procurement and distribution of disinfectant/germicides by recipients to all facilities,community health workers, businesses, public institutions, and households for cleaningand disinfection.

● ULV fogging and community-wide surface cleaning in non-medical facilities.

27 22 CFR § 216.3(b)(1)(Project Assistance) states that the procedures in 22 CFR § 216.3 (b)(1)(i)-(v) apply to all proposed projects involving use of pesticides, assistance for their procurement, or both, unless one of the exceptions to the pesticide procedures identified in (b)(2) apply. 22 CFR § 216 does not make a distinction based on cost share.

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● Training and demonstration of disinfectant/germicide preparation and use as well assolid and liquid waste management.

This is because disinfectant/germicide use on non-medical surfaces is considered use of a pesticide and regulated by USEPA and therefore under 22 CFR 216.3(b)(1)(i) requires USAID Pesticide Procedures’ “12-factor analysis.”

As such, for these activities the following conditions will apply:

● Use only the following AIs as a sole ingredient and/or in combination of ingredients, thatare registered and approved by USEPA and per the BHA COVID-19 PIEE for use ofcleaning and disinfecting surfaces:

● Alcohols: Ethanol, Isopropanol, Triethylene Glycol● Salts: Ammonium Carbonate, Ammonium Bicarbonate, Sodium Carbonate,

Sodium Chlorite, Sodium Dichloro-S-Triazinetrione, SodiumDischloroisocyanurate Dihydrate, Sodium Hypochlorite

● Acids: Citric, Hypochlorous, Glycolic, L-Lactic, Octanoic, Peracetic,Peroxyacetic, Peroxyoctanoic, Phenolics

● Peroxides: Hydrogen Peroxide, Peroxyhydrate● Quaternary Ammonium compounds● Other ingredients: Silver ions, botanical oil thymol

● Select products that contain active ingredients or mixture of active ingredients that areapproved by this BHA COVID-19 PIEE listed above. For selecting which concentrationsare effective, it is best to consult the USEPA-approved list of products and identify sameor similar products.

● Consult local authorities and follow host country established channels of communicationwhen providing recommendations and procedures for use of disinfectants/germicides.

b) Conditions for Medical Use of Disinfectants/Germicides

For activities described below, use of disinfectants/germicides constitutes use of pesticides:

● Use of antiseptics/disinfectants/sterilant germicides on human body and medicaldevices and in medical facilities on medical equipment.

Best management practices, health and safety and environmental mitigation measures specified by lead health organizations, such as CDC, must be applied to these uses and detailed in the EMMP. Recently developed references for COVID-19 in healthcare settings can be found at:

● CDC’s Information for HealthCare Professionals● CDC’s Information for Laboratories● CDC’s Rationale and Considerations for Chlorine Use in Infection Control for

Non- U.S. General Healthcare Settings

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MANDATORY 22 CFR 216.3(B)(1) - 12-FACTOR ANALYSIS FOR PESTICIDES

The following 12-factor analysis meets the requirements mandated by 22 CFR 216.3(b)(1) for pesticide analysis.

A. U.S. Environmental Protection Agency (US USEPA) registration status of the proposed pesticides

Active ingredients (AIs) and combinations of AIs listed above are registered by USEPA.

B. Basis for selection of pesticides

These pesticides were recommended by USEPA as effective for treatment ofenvironmental surfaces and are based on full product list provided by USEPA at:

https://www.epa.gov/pesticide-registration/list-n-disinfectants-use-against-sars-cov-2

C. Extent to which the proposed pesticide use is part of an IPM program

These AIs are recommended in combination with handwashing measures andrecommendations to avoid touching face, eyes and mouth with unwashed hands. Thefollowing site provides links to both CDC recommended hand cleaning procedures:https://www.cdc.gov/coronavirus/2019-ncov/prepare/prevention.html

D. Proposed method or methods of application, including the availability ofapplication and safety equipment

Methods of application of products are in accordance with the label and manufacturerinstructions. For home made products follow strictly dosage instructions provided byrelevant authorities.

E. Any acute and long-term toxicological issues with the proposed use, andmeasures available to minimize such hazards

All chemical disinfectants are, by their very nature, potentially harmful or toxic to livingorganisms. Like other toxic substances, the chemical disinfectants can enter the bodythrough several routes, including absorption through skin or mucous membrane,inhalation and ingestion. Sometimes a chemical substance can enter through more thanone of the routes. However, chemical disinfectants would be effective and safe toolswhen handled properly with the safety measures in place. If misused, they can behazardous and harmful to people and the environment.28

Accidental exposure in high doses may result in acute toxic reactions such as skinirritation, dizziness or nausea, or they may be permanent: blindness, scars from acidburns, mental impairment and other adverse health effects. Acute toxicity is often seen

28 Source: https://www.labour.gov.hk/eng/public/os/C/Disinfectants.pdf

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within minutes or hours after a sudden, high exposure to a chemical. However, there are a few instances where a one-time high-level exposure causes delayed effects. Symptoms of exposures may not appear for several days.

As a general rule, chronic toxicity appears many years after exposure first began. The health effects may occur where exposure has taken place repeatedly over many years. For this activity, repeated exposure over the long term is not anticipated.

Disinfectants can pose physical/chemical risks and can be flammable or explosive. Products must be stored at temperatures designated by their labels/Safety Data Sheets.

All AIs and products must be accompanied by the label and, where available, a Safety Data Sheet. First aid instructions must be available to users and health workers.

All disinfecting products/AIs and their containers must be properly triple rinsed away from all water sources, punctured and properly recycled or disposed of, never reused.

F. Effectiveness of the requested pesticide for the proposed use

The AI approved by this IEE are contained in USEPA approved/recommended productsfor disinfection of environmental surfaces against COVID-19.

G. Compatibility of the proposed pesticide use with target and non-targetecosystems

Disinfectants contribute to air and water pollution during their manufacture and use.Cleaning, sanitizing and disinfecting products can increase indoor air pollution. However,AIs identified by USEPA as effective against COVID-19 are recommended by this IEE.

H. Conditions under which the pesticide is to be used, including climate, geography,hydrology, and soils

AIs in products recommended will be used mostly indoors and surfaces aroundstructures. These AIs/products must be used away from ambient environmental watersources and in a manner that prevents runoff.

I. Availability of other pesticides or non-chemical control methods

Only AIs/Products registered by USEPA are recommended. Other AIs, such asaldehydes that are approved by the European Union for disinfection, are not covered bythis IEE.

J. Host country’s ability to regulate or control the distribution, storage, use, anddisposal of the requested pesticide

Many BHA-affiliated host countries have limited frameworks for regulation of pesticidesand most do not satisfactorily regulate disinfectants for use on environmental surfaces.

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Regulation of disinfectants is a joint effort between Ministries of Health (MoH) and Ministries of Environment (MoE). Many BHA program regions have a network of health clinics and environmental quality directorates that can be instrumental for Training of Trainers (TOT) and promulgation of guidelines for use of disinfectants.

K. Provision for training of users and applicator

Guidelines, training materials and awareness built through Social Behavior ChangeCommunication (SBCC) messaging must be developed for each country, translated tolocal languages, and distributed through MoH networks. These must also include a list ofAIs, labels, Safety Data Sheets (SDSs), and instructions for first aid and environmentalcontrols.

L. Provision made for monitoring the use and effectiveness of each pesticide

Use and effectiveness will be tracked through regular reporting by the recipientssupporting the actions involving germicides. Overall, monitoring effectiveness in limitingspread of COVID-19 will depend on numerous factors that are likely to be monitored aspart of disease surveillance by host countries’ Ministries of Health and their internationaldonors.

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ANNEX 2: SAFER USE ACTION PLAN (SUAP) FOR USE OFDISINFECTANTS

This annex flows from the Pesticide Evaluation Report (PER) analysis to provide conditions for safe use of disinfectants, including specific practices related to COVID-19. Together with Annex 3, the PER and SUAP satisfy the requirements of 22 CFR 216.3(b)(1)(i). Since information and best practices are still evolving, users must frequently visit websites for updates and maintain contact with their local health authorities.

DISINFECTION PROCEDURES29

Disinfection at a household with a suspect or confirmed case of COVID-19:

A complete guide to disinfecting households with suspected or confirmed COVID-19 cases is available at: https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/cleaning-disinfection.html

When using manufactured product for disinfection of inanimate objects:

a) Select products that contain active ingredients or mixture of active ingredients that areapproved by this IEE. For selecting which concentrations are effective, it is best to consult theUSEPA-approved list of products and identify the same or similar products. A full list ofproducts approved is available at: https://www.epa.gov/pesticide-registration/list-n-disinfectants-use-against-sars-cov-2

b) Always ensure that the product has a proper label. Labels of disinfectants must include thefollowing information:

● Product name● Company name and address● Net contents● Manufacturing/host country registration detail● Active ingredients statement● Child hazard warning● Hazard signal word● First aid instructions● Precautionary statements and requirements for use of PPE● Environmental hazards statements● Physical/chemical hazards statements● Directions for use and misuse statement● Storage and disposal instructions

c) Always use products in accordance with the label. Strict attention must be given to the properuse of a product with regard to its application, effectiveness, and associated hazards (human,

29 Under no circumstances should disinfectants be ingested. All disinfectant use must strictly follow the guidelines on the label.

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animal, and environment). Where possible, obtain the Safety Data Sheet that provides more extensive product detail.

Directions for use must specify:

• The surfaces, objects or inanimate environments intended for treatment (floors, walls,bathroom surfaces, etc.)

• The major areas in which the product is intended for use (hospitals, restaurants, homes,schools).

• The level of activity (e.g., Sanitizer, Disinfectant, Sporicide)• Pathogens against which product is effective• How the product must be applied• Pre--cleaning steps• Recommended use dilution and provide instructions for preparing it including the units of

measure (milliliters, liters, ounces, quarts).• Method of application• Contact time• How to remove the product from the surface after the recommended exposure time[1]

When using homemade products for disinfection of inanimate objects:

Natural household disinfectants may be less effective than commercial household disinfectants. It is important to be informed on hazards of AI(s) used for homemade product preparations. Where possible, SDS sheets must be obtained for AI(s) used in preparing homemade products. The SDS information and risk assessment will help determine, the PPE requirements, describe health hazards of unprotected exposure to people and animals, describe physical hazards such as flammability and explosion, and environmental hazards such as toxicity to aquatic organisms, provide hazard statements and first aid instructions and instructions for use, storage and disposal of chemical used in making of a disinfectant.

COVID-19 CATEGORIES OF DISINFECTANTS – CONSIDERATIONS FOR SAFE USE

Bleach30

Homemade disinfectants are most commonly made from household bleach. Chlorine containing bleach is a common household disinfectant.

Household bleach is usually a mixture of chemicals, its main active ingredient is a solution of ~3-6% sodium hypochlorite (NaOCl), which is mixed with small amounts of sodium hydroxide, hydrogen peroxide, and calcium hypochlorite. Unexpired household bleach will be effective against coronaviruses when properly diluted.

30 Note that bleach and vinegar must NOT be mixed, as they release chlorine gas. The bleach decomposes to form hydrochloric acid, which reacts with ammonia to form toxic chloramine fumes. If ammonia is present in excess (which it may or may not be, depending on your mixture), toxic and potentially explosive liquid hydrazine may be formed.

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Bleach solution preparation recommended by CDC31:

Diluted household bleach solutions can be used if appropriate for the surface. ● Prepare a bleach solution by mixing:

o 5 tablespoons (1/3rd cup) bleach per gallon of water oro 4 teaspoons bleach per quart of water

● Follow manufacturer’s instructions for application and proper ventilation.● Check to ensure the product is not past its expiration date.● Never mix household bleach with ammonia or any other cleanser.

Excessive use of bleach indoors, especially when mixed with some other cleaning agents, can release harmful chlorine gas. Inhalation and long term exposure can cause lung damage and respiratory illnesses.

Chlorine compounds found in bleach are unstable and react with a variety of chemicals and water when it is released into the environment. Because chlorine is so reactive, it is not normally detected in the environment except for very low levels. Bleach spilled into surface water may adversely affect aquatic organisms. Inhaling bleach fumes may cause eye, nose, throat irritation depending on dosage. The effects will depend also on exposure duration. In general, people who suffer from respiratory conditions such as allergies or hay fever, or who are heavy smokers, tend to experience more severe effects than healthy subjects or nonsmokers. Spilling hypochlorite solution on the skin can produce irritation. The severity of the effects depends on the concentration of sodium hypochlorite in the bleach. Drinking small amounts of hypochlorite solution (less than a cup) can produce irritation of the esophagus. Drinking concentrated hypochlorite solution can produce severe damage to the upper digestive tract and even death. These effects are most likely caused by the caustic nature of the hypochlorite solution and not from exposure to molecular chlorine. Long-term exposure to small amounts of sodium hypochlorite has not shown to have significant impacts on human health.3233

Alcohols

Alcohols that are components of drinking beverages and rubbing alcohols are recommended for sanitizing, not for drinking. Alcohol products must be at least 70%. Most drinking beverages are below 48% alcohol and not appropriate for sanitizing.

Rubbing alcohol products that are at least 70 percent alcohol reportedly will kill viruses. When using rubbing alcohol, do not dilute it below 70%. Alcohol higher than 70% is not always better, and 70% alcohol is better than 91% because water plays a key role in protein denaturation. Consumer Reports says rubbing alcohol is safe for all surfaces but can discolor some plastics.

31CDC, 2019, Rationale and Considerations for Chlorine Use in Infection Control for Non-U.S. General Healthcare Settings 32 CDC, 2018, Facts about Chlorine 33 Lenntech, Chlorine - Cl

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Although it has the word alcohol in its name, rubbing alcohol is completely different from the ethyl alcohol found in alcoholic beverages. Isopropyl alcohol, also referred to as isopropanol and IPA, is twice as toxic as ethanol. Swallowing just 8 ounces, or 240 milliliters, of rubbing alcohol can be fatal — but as little as 20 milliliters mixed with water can make a person sick.

Inhaling rubbing alcohol can also cause serious side effects, including headache, nausea, vomiting and irritation of the nasal passages and lungs. Inhaling isopropanol fumes can cause a loss of consciousness.34

Hydrogen Peroxide

Hydrogen peroxide is typically sold in concentrations of about 3%. Hydrogen peroxide at this concentration must be able to neutralize the coronavirus. It is recommended to be left on surfaces for at least 1 minute. Hydrogen peroxide is not corrosive and can be used on metal surfaces. Similar to bleach, it can discolor fabrics. Hydrogen peroxide has minimal impact on the environment as it decomposes into oxygen and water.

Acids

Commercial products effective against Covid-19 often contain acids. Acids range from weak to very strong. Weak acids such as household vinegar are not likely to be effective against coronavirus (NOTE: Household vinegar (5% acetic acid) combined with hydrogen peroxide creates peroxyacetic acid. It's an EPA approved, environmentally friendly, disinfectant for coronavirus).

Concentrated industrial strength acids are not recommended as they can be extremely corrosive and can cause dangerous burns when not handled properly. Only acids approved by this IEE can be used in preparation of homemade products.35

Quaternary ammonium compounds

The quaternary ammonium compounds (QAC) are widely used as surface disinfectants and are an active ingredient in household cleaning products. Health hazards of QACs include contact dermatitis, triggering of asthma symptoms in people who already have asthma or new onset of asthma in people with no prior asthma, eye and mucous membrane injuries from splashes or contact with mists, and oral and gastrointestinal injuries from swallowing solutions containing QACs.36 Some household products can be diluted with water but the correct dosage effective against Covid-19 must be established. 37

34 Advanced Recovery Systems, DrugRehab.com, Drinking Rubbing Alcohol Can Prove Dangerous 35 Koukel, Sonja, 2017, Selection and Use of Home Cleaning Products 36 Mount Sinai, 2018, Quaternary Ammonium Compounds in Cleaning Products: Health & Safety Information for Health Professionals 37 Pinandita, Apriza, 2020, Want to Disinfect Your Home? LIPI Recommends Cleaning Products as Alternative Disinfectants

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Oils

Botanical oil thymol is an ingredient in some USEPA approved products effective against Covid-19. There is no evidence that other oils such as tea tree oil are effective.

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ANNEX 3: LINKS TO OTHER BUREAU COVID-19 IEES

E&E: https://ecd.usaid.gov/document.php?doc_id=52766 (DCN: 2020-EE-005)

ME: https://ecd.usaid.gov/document.php?doc_id=52765 (DCN: 2020-ME-024)

Africa: https://ecd.usaid.gov/document.php?doc_id=52763

Asia: https://ecd.usaid.gov/document.php?doc_id=52764

LAC: https://ecd.usaid.gov/document.php?doc_id=52767

E3: https://ecd.usaid.gov/document.php?doc_id=52768

RFS: https://ecd.usaid.gov/document.php?doc_id=52769 (DCN: RFS-20-04-004)

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ANNEX 4: BHA COVID STRATEGIC INITIAL ENVIRONMENTALEXAMINATION (IEE) PRIMER FOR 2021 AMERICAN RESCUE PLANACT (ARPA)

Why the COVID Strategic IEE? The climate and environment crisis is exacerbating risks in all dimensions of people’s lives, and is a high priority of the Biden-Harris Administration. Of global pandemic responses, only 2.5% of funding marked for COVID-19 recovery, will have “positive green characteristics” (UNEP/Oxford, 2021). We have an opportunity to better reduce environment and climate risks in humanitarian assistance with COVID ESF supplemental.

What is the purpose? The purpose of this Strategic Initial Environmental Examination (IEE) and Climate Risk Management (CRM) is to provide a review of the environmental impacts and climate risks of the 2021 American Rescue Plan Act (ARPA) ESF funding response activities.

How do I use it? If you have ESF funding to program, this is your required IEE. It is only nineteen (19) pages, with ten (10) pages of Annexes. Be sure to look at Section 5, which provides a list of climate and environmental risk actions needed from you as the A/COR.

Why no Environmental Compliance Exemption? Last year, BHA received IDA funding to address emergency situations brought about by the global COVID-19 pandemic. ESF Supplemental funding does not have the same exemption as IDA under USAID Environmental Procedures, 22 Code of Federal Regulations 216 (22 CFR 216).

What are the climate and environmental actions required as C/AOR?

• Pre-award: C/AORs must distribute this IEE to potential awardees to ensurerequirements are understood.

• Post-Award: PIOs to follow internal environmental procedures.

• Post-Award: Partners must add climate and environmental considerations into regularproject reports (similar to gender reporting) and in alignment with the 8+3 template of the“Grand Bargain” commitments of humanitarian actors towards harmonized reporting.

• Post Award: Partners indicate how they can advance Green Inclusive COVID recoverytargeting humanitarian needs, under the Administration’s priority of “Build Back Better.”

• Post-Award: In responding to COVID, there may be an increased use of certainpesticides, which require the environmental approval described within this BHA COVIDIEE.

Where can I get more information? Refer to the BHA Strategic COVID IEE or please feel free to reach out to BHA’s Bureau Environmental Officer and Climate Integration Lead (BEO-CIL) for more information.

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