Tajikistan Health and Pollution Action Plan

Article 1 of the Law of the Republic of Tajikistan "On Production and Consumption Waste" defines "hazardous waste - waste containing in its composition substances that have some hazardous properties or their combination, in such quantity and form that this waste itself or when coming into contact with other substances can pose an immediate or potential danger of causing harm to the environment, health of citizens, and property due to their harmful effects". The law does not provide a definition for “persistent organic pollutants”, but lists POPs as hazardous waste. According to Article 12 of the Law, any entity producing wastes must determine the degree of hazard and the hazard class of the wastes in accordance with the regulations established by the waste management state body. These regulations are: GOST 30774-2001, Guidelines for establishing the Maximum permissible concentration of chemicals in the soil (M., USSR Ministry of Health, 1982), SanPiN 42-128-4433-87, and SanPiN 42-128-5317-91. According to these regulations, Polychlorinated Biphenyls, Polychlorinated Diphenyls, Dioxins, Furans, etc. are included in the Red List of Wastes - the most dangerous kinds of hazardous wastes. The law has separate requirements for the transportation of waste (Article 13) and transboundary movement. According to Article 14, the import of waste into the Republic of Tajikistan for burial is prohibited. The law does not regulate the prohibition on the use of technologies for the neutralization of wastes that lead to the formation of persistent organic pollutants, while many CIS countries have such provisions in similar laws. The development of technical regulations that include all stages of hazardous waste management could become one of the important steps to achieve positive experience in the legal regulation of waste management. But this is not yet done. According to the Decree No. 205 of the Government of the Republic of Tajikistan (April 30, 2012) the Committee for Environmental Protection under the Government of the Republic of Tajikistan is the responsible state body for the management of wastes. The Code of Administrative Offenses of the Republic of Tajikistan (December 31, 2008) establishes administrative responsibility for the following violations: - damage to the forest by sewage, chemicals, hazardous emissions, wastes and discharges (Article 191), - violation of the rules for the storage of industrial and household waste, non-compliance with the requirements for the protection of atmospheric air when burning wastes (Article 231), - violation of the rules and regulations for the transportation, storage and use of plant protection products and other preparations, which caused or may cause environmental pollution (Article 227), - violation of the rules for the transportation, storage and use of plant protection products, stimulants of their growth, mineral fertilizers and other preparations, causing damage to the animal world (Article 210), etc. 18 The liability for crimes against ecological safety and natural environment is established in Chapter 24 of the Criminal Code of the Republic of Tajikistan (May 21, 1998). In particular,

Article 228 establishes liability for damage; Article 223 - for violation of safety rules for production, storage, use, transportation, disposal or other handling of radioactive, bacteriological, chemical substances or production and consumption waste; article 226 - water pollution; article 227 - air pollution. The Law of the Republic of Tajikistan "On Food Safety" (No. 890, August 1, 2012) among other things regulates concentrations of POPs in food and defines state control over the use of POPs containing agrochemicals. The State Ecological Program for 2009-2019 was approved by the Decree No. 123 of the Government of the Republic of Tajikistan (February 27, 2009). The State Ecological Program is recognized by the Republic of Tajikistan as the main legal basis for maintaining a balance between protection and use of natural resources, through rational use of natural resources and restoration of destroyed landscapes. The need for a special program was dictated by the need to solve existing environmental problems. The program includes sections on clean atmospheric air, water; strengthening control to reduce air emissions; strengthening interagency control for the implementation of environmental programs; creating environmentally friendly space. The State Program Among lists the following actions: • constant monitoring of the water quality in rivers, main canals and reservoirs in order to identify heavy metals, pesticides and others; • strict accounting and regulation of air emissions of pollutants from stationary sources in large cities; • development and implementation of a warning system about the sudden contact of people with high doses of emitted toxic substances; • development of methods for determining harmful substances in the air; • creation of a unified system for the neutralization and deep processing of toxic wastes (industrial, agricultural, medical, household); • analysis of the formation, disposal and utilization of industrial waste, and the development of recommendations for waste disposal; • restoration of pesticide landfills; • increase in payments for exceeding pollution limits 5-10 times; • organization of the environmental customs service that would include state inspectors for environmental protection to control the import and export of equipment, technologies and other materials that may harm the environment; • development of a program for the gradual replacement of environmentally hazardous out (technologies with new, modern and environmentally friendly technologies. The listed measures to improve the environmental quality related to the management of chemicals, hazardous wastes and emissions should be financed both by the state budget and funds from users of natural resources. Some funds for the restoration of the environment may come from the privatization of state property. The program provides that there should be incentives to commercial companies for using zero-waste or low-waste technologies that produce environmentally friendly products. Institutionally, the State Program provides for the creation of a special Environmental Service for interdepartmental coordination to implement the program tasks. At the moment, many provisions of the State Program remain only on paper and require substantial funding in order to be implemented. Despite some achievements in the country in the implementation of the provisions of the Stockholm Convention, there is sufficient reason to believe that many steps to implement the National Plan for the implementation of the obligations of the Stockholm Convention on POPs 19 were not yet implemented. For example, the NIP states that by 2008, a law of the Republic of Tajikistan on persistent organic pollutants should be adopted. This never came to fruition, and The same applies to many other provisions of the NIP. Overall, the legislation of Tajikistan does not contain separate regulatory acts for POPs management. They are not mentioned in waste management legislation, however there are references to POPs in earlier regulatory acts adopted before the ratification of the Stockholm Convention: the definition of POPs is contained in the Decree No. 92 of the Government of the Republic of Tajikistan (March 3, 2003) "On the establishment of the Commission on Chemical Safety of the Republic of Tajikistan". The name of the Stockholm Convention was introduced as the basis for the regulatory framework into the Decree No. 464 of the Government of the Republic of Tajikistan (October 3, 2006) “Procedure for assessing environmental impacts.” Interestingly this happened before the Convention was ratified by Tajikistan. Analysis of other regulatory legal acts shows that POPs are mentioned in relation to program documents. For example, the Concept of Transition of the Republic of Tajikistan to Sustainable Development (October 1, 2007, No. 500) in paragraph 4.5.2 lists international agreements signed or ratified by the country, including the Stockholm Convention on POPs, and also gives a brief list of actions taken to fulfill the obligations under the Convention. 2.2.1 Proposals to improve national legislation on POPs management. The analysis of the current legislation on POPs management reveals a number of gaps. In particular: • There is a need to ratify a number of international agreements, particularly the Rotterdam Convention on the Prior Informed Consent Procedure in the International Trade of Certain Types of Hazardous Chemicals and Pesticides and the Aarhus Convention Pollutant Release and Transfer Registers (PRTR) Protocol. • Within the framework of national legislation, it is necessary to develop and adopt the Law "On persistent organic pollutants." This would become a specialized regulatory legal act on POPs management. • Development of a separate technical regulation for the management of POPs containing wastes will help clarify some provisions of the legislation on waste management. It will also help to unite all the existing rules (GOSTs and Building regulations) into one piece. • It is necessary to make changes, additions and amendments to the environmental legislation of the Republic of Tajikistan to introduce the definition POPs, the need to maintain state statistics on waste generation and disposal, create and maintain the Cadastre of Wastes. There should be separate legal act on the Cadastre of Wastes. • It is necessary to introduce provisions on handling of obsolete pesticides and toxic chemicals in the Law of the Republic of Tajikistan "On Quarantine and Plant Protection". • Development of the "Procedure for stimulating the reduction of air emissions" is listed in the Law of the Republic of Tajikistan "On the protection of atmospheric air". But this procedure was never developed. • It is necessary to introduce the definition of POPs in national legislation. There should be a separate regulation and/or technical procedure adopted for determining the hazard class of produced wastes. • An article prohibiting use of technologies producing POPs should be added to the Law of the Republic of Tajikistan "On Production and Consumption Waste" 20 • The National Implementation Plan includes creation of a United Database on Persistent Organic Pollutants. It is necessary to develop the procedure for creating this database. • There are no legal acts regulating restoration of areas contaminated with POPs. The provisions on cleanup, safety and restoration of contaminated areas should be introduced in national legislation. • The state registration of pesticides and chemicals requires creation of the State Catalogue of pesticides and chemicals. However, this catalogue was never created. It is necessary to assign an agency responsible for creating and maintaining such catalogue. It is also necessary to identify pesticides/chemicals that are officially prohibited/permitted for production and/or restricted use in accordance with the requirements of the Stockholm Convention on POPs. • It is necessary to determine the procedure for implementing the inventory of POPs. Without such written and adopted procedure, inventory it is not possible to implement and finance inventory activities and take further actions on identified stocks of POPs. Further, the Agency on Statistics under the President of the Republic of Tajikistan should adopt the act "On approval of the form of state statistical reporting 1 – waste "Report on production waste management "and instructions for its filling." • It is necessary to develop a technical regulation defining the procedure for monitoring POPs in environment. • It is necessary to adopt a legal act (procedure or regulations) for the import/export of equipment containing POPs. • A technical regulation is necessary to define best available technical methods for reducing unintentional POPs emissions. General institutional framework for the implementation of the Stockholm Convention Interdepartmental coordination As part of the NIP implementation the Republic of Tajikistan managed to make some improvements in the institutional framework of chemicals management. One of the important recommendations of the NIP was the creation of a special body for the Stockholm Convention implementation. On February 27, 2009 the Decree of the Government of the Republic of Tajikistan No. 132 established a State Institution “Center for the Implementation of the Commitments of the Stockholm Convention on Persistent Organic Pollutants”. As per amendments in the Statute of the Committee for Environmental Protection the Center is a non- profit organization within the Committee. The main task of the Center is to implement the provisions of the Stockholm Convention, including inventory of POPs, preparing reports on the progress of the country's implementation of the Stockholm Convention, attracting local and foreign funds to clean up contaminated areas, preparing proposals and providing recommendations on legislation regulating POPs management. Despite the establishment of the Center, its potential at the moment is not great. There are problems due to of the lack of funding. The work of the Center is also complicated because of their status as a non-profit organization. This status was initially established in order to make it easier to seek additional funds for the implementation of programs for inventory of POPs, remediation of contaminated sites, renewal of NIP, etc. 21 The existing state management system is functional despite some problems in interdepartmental coordination and insufficient funding for the country's fulfillment of obligations under international agreements. The leading agencies responsible for supervision and management of POPs are: the Committee for Environmental Protection under the Government of the Republic of Tajikistan, the Ministry of Agriculture, the Ministry of Industry and New Technologies, the Ministry of Health and Social Protection of the Population, the Ministry of Defense, the Ministry of Energy and Water Resources, the Ministry of Foreign Affairs, Ministry of Finance, Ministry of Transport, Ministry of Economic Development and Trade, Ministry of Justice, Ministry of Internal Affairs, State Committee on National Security, State Committee on Investments and State Property Management, Agency on Statistics under the President of the Republic of Tajikistan. The State Attorney's Office of the Republic of Tajikistan and the judicial authorities also play an important role. In the Republic of Tajikistan, there is a gradual weakening of environmental policy, giving way to the economic interests of the state. The conflict between the environmental legislation and economic development reflects upon the status of the environmental agency. Over the past 10 years, the environmental protection state body went through 4 reorganizations and diminished its status from the initial Ministry of Nature Protection to the current Committee for Environmental Protection under the Government of the Republic of Tajikistan. The Committee for Environmental Protection under the Government of the Republic of Tajikistan was established by the Resolution No. 189 of the Government of the Republic of Tajikistan (April 24, 2008). The Committee for Environmental Protection (CEP) is responsible for state environmental policy, monitoring the rational use of natural resources, hydrometeorology, preventing of emergencies that could affect the environment, persistent organic pollutants, climate change, control over the protection and rational use of woodlands, water resources, handling hazardous waste, chemicals, etc. The CEP has the right to verify sources of air emissions, laboratory studies of emissions into nature, transit and import of hazardous materials into the country, create information resources of the state of the environment, develop and submit for approval guidance and methodological documents, environmental standards, national strategic documents, license activities, associated with hazardous emissions, create a register of polluting objects, etc. CEP is the agency responsible for the fulfillment of the obligations of the Republic of Tajikistan under the Stockholm Convention on POPs. In addition to the “Center for the fulfillment of the obligations of the Stockholm Convention on Persistent Organic Pollutants”, the CEP Hazardous Waste and Emissions Management structure includes other departments (Table 4) Table 4. CEP Hazardous Waste and Emissions Management Structure Unit Chemicals and hazardous waste management tasks Monitoring and Organization and implementation of environmental Environmental Policy monitoring, comprehensive assessment of environment, Department weather, glaciers, lakes and reservoirs, analysis of natural emergencies; Coordination of activities for the organization of the integrated system for environmental monitoring and use of natural resources; Implementation of the state environmental policy, persistent organic pollutants policy etc... Department of State Control State control over the protection and rational use of water over the Use and Protection of resources, in particular, control over chemicals and hazardous Water Resources waste pollution; Scientific research and study of water resources protection issues. 22 Department of state control State control over the protection and rational use of ... flora, over the use and protection of including protection from POPs; flora and fauna protection, conservation and restoration of ecosystems plant species. Department of State Control of State control over the protection and rational use of ... the Use and Protection of atmospheric air, including protection from POPs; Atmospheric Air Verification of sources of air emissions; Licensing of activities related to hazardous emissions; Setting standards for maximum permissible air emissions. Department of State Control State control over hazardous wastes and chemical substances, over the Use, Protection of including POPs; Lands and Waste Management Environmental regulation of hazardous waste management, import, export, import and transit; Development of instructive, methodological and normative acts on the establishment and collection of fees for the release of pollutants into the environment, waste disposal, including hazardous emissions. Sector of International Implementation of international cooperation on protection and Relations use of natural resources; Fulfillment of the obligations assumed by the Republic of Tajikistan under the signed international environmental agreements. Legal sector Development and assistance in the implementation of national and regional programs, strategies and plans for environmental protection; Development and approval of regulatory and methodological documents; Development in accordance with the current established procedure draft laws, legal, regulatory, methodological documents for submitting to the Government of the Republic of Tajikistan and other relevant bodies. State ecological expertise Overseeing environmental impact assessment processes. Agency of Hydrometeorology Monitoring and control of air pollution. State Institution Research Analytical, instrumental and laboratory diagnostics of water, Laboratory for Nature soil, air, mineral fertilizers and pesticides. Conservation The Ministry of Agriculture was established by the Decree No. 191 of the Government of the Republic of Tajikistan (April 26, 2008). The Ministry of Agriculture plays an important role as the leading government structure in the management of pesticides and agricultural chemicals. According to the Statute "Of the Ministry of Agriculture of the Republic of Tajikistan" (adopted by the Resolution No. 191 of the Government of the Republic of Tajikistan (April 26, 2008) the Ministry performs the following tasks: • Development of proposals on use of pesticides and other agricultural chemicals; • Fulfillment of obligations assumed by Tajikistan under international conventions, agreements and treaties; • Methodological and organizational assistance to agricultural enterprises ... in introduction of new and effective methods and techniques, usage of pesticides and other methods of plant protection; The Ministry of Agriculture works in close in cooperation with other ministries and departments. 23 The State Inspection Service for Phytosanitary and Plant Quarantine is an important structural subdivision of the Ministry of Agriculture. The State Inspection was created by the Decree of the Government of the Republic of Tajikistan No. 372 (August 1, 2008). The main responsibilities of the Service include: - Purchase of fumigants and other pesticides; - Creation of specialized fumigation teams equipped with machinery and other means of plant protection to eliminate and prevent the spread of quarantine and other pests, plant diseases and weeds. The functions of preventing the spread of quarantine and other pests used to be the responsibility of the Republican Production Association "Tajikselkhozkhimiya". The legislation does not directly mention the liquidation of this legal entity. But the Shahrituz and Bokhtar district divisions of "Selkhozkhimiya" were put on sale by the Decree No. 486 of the Government of the Republic of Tajikistan (November 7, 2003) "On the strategic plan for the privatization of medium and large enterprises and the restructuring of natural monopolies and especially large enterprises for 2003-2013". The property rights of the former "Tajikselkhozkhimiya"are important for determining the rights of ownership of warehouses, premises, airfields and other structures that used to belong to "Tajikselkhozkhimiya" and were intended for storage of pesticides. Most of these objects were privatized after the collapse of the USSR or are in distress and need cleaning up. The Ministry of Industry and New Technologies was created by the Decree No. 147 of the Government of the Republic of Tajikistan (March 3, 2014) to be replaced by the former Ministry of Industry and Energy. This ministry plays a key role in the management of the production of POPs - containing substances, the incineration of hazardous waste, the regulation of the emissions of Polychlorinated dibenzodioxins / polychlorinated dibenzofurans (PCDD/PCDF), and the management of polybrominated diphenyl ethers (PBDE). Despite the existing economic difficulties, the Ministry tries to increase industrial development and outputs, even if it means environmental impacts. Tajikistan's transition to a "green economy" remains a big problem. The latest review prepared by Tajikistan for the Rio + 20 conference received negative feedback from non- government organizations (NGOs). Particularly because the review makes conclusions that do not correspond to reality. For example, switching a refrigeration plant line to ozone friendly substances. But this line doesn’t exist for many years. Also, the review does not discuss the development of coal production and the country's transition to use of coal instead of natural gas. Another difficult is licensing. The Law No. 535 of the Republic of Tajikistan "On licensing certain types of activities" (April 29, 2004) has a collision with the norms of the Law No. 20 of the Republic of Tajikistan "On ecological expertise" (April 22, 2003). According to the Law of the Republic of Tajikistan "On Environmental Expertise" (Article 7), the list of objects for which conducting environmental impact assessment is mandatory includes "... development plans for industries/sectors of national economy...". According to the law, the main objective of the environmental impact assessment is “to assess the effectiveness, validity and sufficiency of measures to protect public health, rational use of natural resources, environmental protection.” According to Article 1 of the law the environmental impact assessment should be implemented for both planned and ongoing activities. According to the Article 17 of the Law of the Republic of Tajikistan "On Licensing Certain Types of Activities" "... procurement, processing and sale of scrap ferrous and non-ferrous metals ..." is included in the list of activities for which a license is required. But the Article 9 of the law (listing documents required licensing) does not list environmental impact statement among required documents. The clause 2 of article 9 of the law says that “additional documents could be provided…” this could mean that the environmental impacts statement could be requested, but it is not directly mentioned in the law. The Statute of Tajikhydromet (Hydro Meteorology Service) was approved by the Government Decree No. 485 (October 1, 2008). Tajikhydromet is the agency with capacity to 24 assess the levels of air pollution with POPs and conduct laboratory assessments of POPs in water resources. The agency has 33 meteorological stations, 6 hydrological stations and 57 hydrological posts in Tajikistan. Significant financial resources are needed to increase the role of the agency to conduct environmental monitoring. The Statute of the Ministry of Health and Social Protection of the Population of the Republic of Tajikistan was approved by the Resolution No. 148 of the Government of the Republic of Tajikistan (March 3, 2014). The main responsibility of the Ministry is to protect public health. The work of the Ministry is regulated by the norms of the Constitution, national laws, and existing sanitary norms and rules. The latter are very important as they contain many standards and detailed technical instructions. The State Sanitary and Epidemiological Surveillance Service (SSESS) is an important subdivision of the Ministry. SSESS is responsible for monitoring the sanitary and epidemiological situation in the republic. SSESS plays an important role in management of hazardous wastes, including POPs. For example, an assessment conducted by SSESS may reveal abandoned stocks or dumpsites of hazardous wastes (according to the Procedure for identifying and accounting for abandoned waste (Government Decree No. 626 of November 2, 2012). Representatives of both SSESS and CEP, according to the Procedure, are included in the work groups on abandoned wastes. These workgroups are not very effective as there are still a lot of unaccounted abandoned warehouses, dumps and burials that contain obsolete pesticides. The State Statistics Committee of the Republic of Tajikistan (Goskomstat) acts according to the Law on State Statistics (No. 588, January 12, 2010). Goskomstat communicates with different ministries and departments to exchange various economic, environmental, and social statistical data. Goskomstat has committees and computing centers at the regional and district levels. Goskomstat collects, stores, analyzes, compiles, presents and publishes environmental data. Goskomstat handles a sheer amount of data, but does not collect information on POPs. Since POPs are not produced in the republic, but only imported, the imports could be traced using customs statistics searching particular customs codes of imported goods. The Statute of the Customs Service under the Government of the Republic of Tajikistan, was approved by the Decree of the Government of the Republic of Tajikistan No. 612 on December 28, 2006. The Customs Service plays an important role in controlling the import and export of substances and wastes containing POPs. In order to comply with the Stockholm Convention, the Customs Service must keep records on each imported/exported chemical, countries of origin and importing/exporting parties. The customs committee is required to collaborate with environmental protecting agencies on issues of chemicals and waste management. It would be helpful to develop detailed instructions for the identification of different chemicals and wastes containing POPs. The instructions should contain methods for identifying POPs prohibited/restricted for import and production. It is also important to equip the national laboratories so that they could conduct analyses to detect POPs. Cross-sectoral collaboration One of the main objectives of the legislative and institutional framework is ensuring interaction and collaboration of different sectors of the society on solving environmental problems. The main sectors include the authorities, business/industry and civil society. But presently in Tajikistan we observe that the development of economy is favored over the needs of environmental protection. And this has a negative effect on the interdepartmental coordination between government structures. The authority and role of the main environmental agency is declining. Over the past 10 years the status of the Ministry of Nature Protection was reduced to a committee. Some control functions are lost. For example, the control of natural protected areas was transferred to the Forestry Agency. The creation of the Center for the implementation of the obligations of the Stockholm Convention on POPs could be considered a success. It is important for the organization of 25 interdepartmental coordination of public authorities on issues of POPs. But lack of funding remains the main obstacle to controlling the circulation of POPs in Tajikistan. The Decree No. 299 of the Government of the Republic of Tajikistan (July 3, 2003) "On Approval of the Statute of the Commission on Chemical Safety in the Republic of Tajikistan" established the Commission on Chemical Safety as state workgroup to coordinate activities of ministries and departments on issues of chemical safety. But the work of the Commission so far is not very effective for the following reasons: According to the Decree of the Government of the Republic of Tajikistan No. 92 of March 3, 2003, the Commission includes the Deputy Chairman of the Government (head) and heads of environmental protection and health authorities as his deputies. The other members of the commission are deputy heads of the ministries and departments. As a result, there are many high- ranking officials in the Commission, but not enough people who could do some actual work. The Commission is not responsive to changes in international legislation on chemicals. This issue could be solved if instead of the Commission there would be a Chemical Control Service supervising all handling of chemicals, including hazardous waste. This Service could oversee the practical implementation of important environmental conventions - the Stockholm Convention on POPs, the Basel and Rotterdam Conventions (if signed), as well as other international agreements on handling hazardous chemicals and wastes. The new Service could include specialists from different ministries and departments. Presently the intersectoral interaction is most effective in the cooperation of state bodies with the civil society organization and less effective with business. This situation may improve as more businesses participate in some non-profit organizations, such as the Association of Small and Medium Business, Unions of Entrepreneurs, etc. Non-governmental non-profit organizations (NGOs) are often invited as experts to participate in the development of some government documents, including those on environmental protection and sustainable development. The list of such recent documents includes the "National Report on Sustainable Development", "National Communications" on the UN RC on Climate Change ", framework documents on biosafety in the Republic of Tajikistan, National Profile on the implementation of the Aarhus Convention, the National Plan for the implementation of the obligations of the Stockholm Convention, and so on. Some NGOs implement projects that help fulfilling the obligations of the UN Stockholm Convention. The national NGO Peshsaf together with the international NGO Blacksmith Institute (USA) and the Center for the fulfillment of the obligations of the Stockholm Convention on POPs in 2014-2020 made an inventory of the warehouses, burials and dumpsites of obsolete pesticides. At the same time in the Republic of Tajikistan, local communities and organizations of users of natural resources are not involved in POPs management. The legislation allows associations of farmers, water users, transport workers, etc. to participate in management of chemicals, but it does not happen. Effective intersectoral interaction is possible under the following conditions: • Real funding from the state budget of the development of national documents on the obligations on environmental conventions with the requirement to involve all stakeholders; • Implementation of joint POPs management projects, including research; • Involvement of all stakeholders in the process of developing national priorities for the Stockholm Convention on POPs; • Organization of real information exchange between government structures and stakeholders. The information exchange could be led by the Center for Implementation of the obligations of the Stockholm Convention on POPs. There are some problems that may compromise the effective intersectoral collaboration on POPs management: At the system level: 26 • Absence of uniform policy on environmental protection, rational use of natural resources and sustainable development. • Low priority of environmental issues for the government. • Lack of coordination between government bodies At the institutional level: • Absence of legal acts regulating social partnership and opportunities of civil society involvement; • Fragmentation of POPs monitoring in between different ministries and departments; • Environmental statistical data are not collected and complied separately from other data; • Some monitoring results are not comparable because different methods were used for data collection; • Low level of digitalization: most of the data are collected using paper and its processing requires more time; • Difficulties in collecting information, because of fragmentation and reorganization of big companies; • Lack of equipment in state laboratories. At the individual level: • Lack of common goals in sustainable development and environmental protection; • Lack of procedures regulating intersectoral interaction; • Weak information exchange; • Low level of environmental education at all levels, including decision-makers; • Ignorance of the different sectors’ representatives of the potential of other stakeholders, social stereotypes; • Lack of trust between sectors prevents combining and exchanging resources (intellectual, material, organizational, etc.) Conclusions: • The existing system of management of chemicals is ineffective. It is necessary to better divide the POPs management responsibilities between ministries and departments. • There is a need for a comprehensive law on chemicals. The existing laws and regulations on POPs are ineffective. • The existing decision-making is not uniform, because it is based on many different laws and regulations implemented by different ministries and departments. • While there are many government agencies involved in POPs management, there are no effective mechanisms for their interaction, collaboration and information exchange. • Several ministries and departments have control functions which causes duplication and inconsistency. • There is no system of POPs data collection from businesses. • There is no information system on POPs. • The government is not doing POPs inventory. • Insufficient financing of environmental monitoring, lack of capacity and certification of the existing laboratories does not help effective management and decision making. 27 • Poor awareness of general public and non-involvement of residents in POPs management. • It is necessary to improve interagency and intersectoral partnership and communication on POPs management in order to reduce POPs health risks. Recommendations: • Create an agency on management of chemicals to replace the existing Commission on Chemical Safety. The agency would be responsible for the development of state policies, instructions, and regulations on handling hazardous substances and wastes. Include specialists from different ministries and departments presently involved in POPs management in the new agency; • Analyze and integrate activities for the implementation of the Stockholm Convention into short-, mid- and long-term national, sectoral and territorial plans and programs; • Increase funding from the state budget and other sources for the implementation of the Stockholm Convention; • Develop a system at the regional and national levels to record emissions and migration of hazardous pollutants; • Organize exchange of information on the results of the inventory of obsolete pesticides and plans for POPs disposal; • Include in all agencies’ statute mechanisms of stakeholders’ participation in the implementation of the Stockholm Convention; • In the current legislation governing the conclusion of international treaties, introduce (strengthen) the norms of responsibility for non-compliance with procedures when taking appropriate international obligations for responsible officials. • Introduce in national legislation responsibility of senior officials for violations of international conventions in decision making; • Introduce in government agencies’ statutes the responsibility of officials for the condition of managed resources (forest, biodiversity, water, land, air, etc.), including impacts from POPs pollution; • For the agency responsible for the implementation of the Convention to constantly expand contacts with international organizations working on reducing POPs health risks, alternative farming techniques, introduction of environmentally friendly agricultural technologies. Relevant international treaties and obligations Tajikistan became a member of the UN in March 1992, right before the UN Conference on Environment and Development in Rio de Janeiro (Brazil). That conference defined the principles of sustainable development as the basis of the policy of international cooperation and partnership. Tajikistan uses international cooperation and partnership to help implementing national environmental policy and takes an active part in international, regional and bilateral cooperation on environmental issues. Tajikistan has established cooperation with a number of UN bodies, including United Nations Economic Commission for Europe (UNECE), Food and Agriculture Organization (FAO), Economic and Social Commission for Asia and the Pacific (ESCAP), United Nations Environment Programme (UNEP), United Nations Development Programme (UNDP), with international 28 financial institutions – World Bank (WB), International Monetary Fund (IMF), European Bank for Reconstruction and Development (EBRD), Asian Development Bank (ADB), Inter-American Development Bank (IDB), Saudi and Kuwait funds, as well as with other international organizations, such as the European Union (EU), Organization for Security and Co-operation in Europe (OSCE), Organization for Economic Cooperation and Development (OECD), Global Environment Facility (GEF), and others. Tajikistan develops cooperation on environmental issues with Afghanistan, China, Iran, Japan, Armenia, Russia, and Central Asian countries. The Republic of Tajikistan is a member of several regional and sub-regional organizations, including Economic Cooperation Organization (ECO), Shanghai Cooperation Organisation (SCO), Eurasian Economic Community (EurAsEC), IFAS (International Fund for saving the Aral Sea), Interstate Commission for Water Coordination (ICWC) and Interstate Commission on Sustainable Development (ICSD). The Republic of Tajikistan recognizes the priority of the widely accepted principles of international law and ensures the compliance of national legislation. The environmental policy of Tajikistan relates to international activities by: • improving regional and global cooperation on environmental protection; • bringing national legislation in line with international laws and agreements; • developing national programs and introducing mechanisms for the implementation of international conventions; • implementing bilateral and multilateral agreements and participating in regional programs. The Regional Environmental Action Plan for Central Asia was prepared by ICSD with support of ADB, UNEP and UNDP. The Action Plan includes five environmental priorities with short-term (2002-2007) and long-term (2007-2012) implementation. The Republic of Tajikistan has signed several regional agreements: • Agreement on interaction on ecology and environmental protection in CIS (February 8, 1992). The agreement includes: harmonization of adopted environmental legislation, regulations and standards; joint development and implementation of international programs and projects on nature management and environmental protection and safety, including programs on safe destruction and neutralization of chemical and nuclear weapons, highly toxic and radioactive waste (Article 3); • Agreement on information cooperation on ecology and environmental protection (September 11, 1998). The agreement includes cooperation on exchange and dissemination of environmental information among CIS member states; creation of an environmental data bank to collect information on environment, hazardous objects, environmental scientific and technical advances (Article 1); • The Agreement on CIS Environmental Monitoring Cooperation (January 13, 1999); • Memorandum on the development of cooperation between the government of the Republic of Tajikistan and the government of the Kyrgyz Republic on environmental safety (May 26, 2004); • Framework Convention on Environmental Protection for Sustainable Development of Central Asia, signed in Ashqabat (Turkmenistan) on November 22, 2006. • "Agreement between the governments of the Republic of Kazakhstan, the Kyrgyz Republic and the Republic of Uzbekistan on cooperation on environmental protection and rational use of natural resources" (1998). The parties of the Agreement cooperate on neutralization, neutralization, safe destruction and disposal of toxic and radioactive waste (Article 2). The Interstate Environmental Council (IEC) of CIS member states was created in May 1993 to help coordination of environmental policy in CIS. The IEC as part of implementing the 29 Agreement on Cooperation on Environmental Monitoring developed the Interstate Scientific and Technological Program for the Creation and Development of Environmental Monitoring in CIS member states”. The Interstate Center for Environmental Monitoring (ICEM) was created to help integration and development of national and regional environmental monitoring systems. As part of Interstate Scientific and Technological Program work it is necessary for Tajikistan to develop a system of monitoring POPs pollution. The existing legal framework ensures Tajikistan's full participation in international cooperation. 30 Chapter 3. Assessment of POPs problems in Tajikistan Pesticides overview In 2017, The World Health Organization (WHO) defined a pesticide as “a chemical compound that is used to kill pests, including insects, rodents, fungi and unwanted plants (weeds).” The Food and Agriculture Organization (FAO) of the United Nations defined a pesticide as “any substance or mixture of substances intended for preventing, destroying, or controlling any pest, including vectors of human or animal diseases, unwanted species of plants or animals causing harm during, or otherwise interfering with, the production, processing, storage, or marketing of food, agricultural commodities, wood and wood products, or animal feedstuffs, or which may be administered to animals for the control of insects, arachnids or other pests in or on their bodies.” Pesticides can be classified by target groups as acaricides, avicides, bactericides, herbicides, fungicides, insecticides, repellents, virucides, and so on. According to the chemical compositions of the active ingredients, pesticides can be categorized into four main groups: carbamates, organochlorines, organophosphorus, and pyrethrin and pyrethroids. WHO (2009) classified pesticides by hazard as an extremely hazardous pesticide, a highly hazardous pesticide, a moderately hazardous pesticide, a slightly hazardous pesticide, and a pesticide which is unlikely to present an acute hazard. In addition, based on the mode of formulation, pesticides can be classified as emulsifiable concentrates, wettable powders, granules, baits, dust, and fumigants. Organochlorine pesticides are chlorinated hydrocarbons used extensively from the 1940s through the 1960s in agriculture and mosquito control. Representative compounds in this group include DDT, methoxychlor, dieldrin, chlordane, toxaphene, mirex, kepone, lindane, and benzene hexachloride. Due to the complex chemical structures and the chemical complexity of these pesticides and their active ingredients, these pesticides are often regulated by their trade names instead of the chemical nomenclature conventions. For example, the National Institute of Standards and Technology (NIST) (2011)4 listed 120 names for the pesticide “Lindane”, which include 30 chemical nomenclature names and 90 other trade names. Even global jurisdictions have regulated pesticides by their local trade names in foreign languages, which has made it difficult to identify pesticides by their “original names”. The Chemical Abstracts Service Registry Number (CAS No.) developed by the NIST and the common name developed by the International Union of Pure and Applied Chemistry (IUPCA) are commonly used as reference. Unfortunately, the CAS No. is not available for most worldwide jurisdictions beyond Europe and North America. Exposure to Pesticides The impact of pesticide residues on human health is a worldwide problem, as human exposure can occur through ingestion, inhalation, and dermal contact. Regulatory jurisdictions have promulgated the standard values for pesticides in residential soil, air, drinking water, and agricultural commodity for years. Until now, more than 19,400 pesticide soil regulatory guidance values (RGVs) and 5,400 pesticide drinking water maximum concentration levels (MCLs) have been regulated by 54 and 102 nations, respectively. Pesticides are broadly applied in numerous agricultural, commercial, residential, and industrial applications to control and kill pests. They help society fight disease and increase agricultural productivity; however, pesticides can be transported into the air, water, soil, and biomass after numerous applications and can cause risks to the ecosystem and to human health. The impact of pesticide residues on human health is a worldwide problem, as human exposure to pesticides can occur through the ingestion of pesticide-contaminated water, food, or residential surface soil, the inhalation of pesticide-contaminated air, soil dust, or industrial vapor, and dermal contact with pesticide-contaminated water (e.g., swimming, showering, or raining), air, agricultural commodities, or soil. Bioaccumulation, for example, is the gradual accumulation of 31 substances, such as pesticides (e.g., DDT), or other chemicals in an organism. Bioaccumulation occurs when an organism absorbs a substance at a rate faster than that at which the substance is lost by catabolism and excretion. Worldwide jurisdictions have been working on regulating pesticide standard values for residential surface soil, residential air, drinking water, surface water, groundwater, and food for years. Pesticide soil regulatory guidance values (RGVs) are applied by worldwide soil jurisdictions to control pesticide pollution in residential surface soil. Pesticide soil RGVs specified the maximum amount of a pesticide which might be present in the soil without prompting regulatory responses, such as surface or groundwater contamination by the transport of pesticides from surface soil, ecological risk, and adverse human health effects by exposure to soil pesticides. The most concerned and conservative pesticide soil RGVs are provided for residential surface soil, where children can be exposed to soil pesticides by the ingestion of soil, the inhalation of soil dust, or dermal contact. Children are especially vulnerable to pesticides because their bodies are still developing, and their diets and activities - such as playing on pesticide-treated lawns or eating a lot of fruits with pesticide residue - can result in high exposures. Pesticides can exist in residential air by the evaporation of volatile and semi-volatile pesticides, such as organochlorine pesticides, from crops and residential surface soil. In addition, pesticides can be blown away from agricultural fields by the wind, and some fumigants (e.g., bromomethane) are released into the air in a gaseous form. Therefore, the regulation of pesticide standard values in the residential air is necessary to control human health risks through inhalation and dermal contact exposures, especially for volatile and semi-volatile pesticides. However, few worldwide jurisdictions have regulated pesticide air standard values, which means that people around the world are probably not protected by the pesticide air regulations, especially for some farmers and workers who frequently work in the agricultural field. DDT – General Description Organochlorine pesticides are chlorinated hydrocarbons used extensively from the 1940s through the 1960s in agriculture and mosquito control. Representative compounds in this group include DDT, methoxychlor, dieldrin, chlordane, toxaphene, mirex, kepone, lindane, and benzene hexachloride. The term DDT refers to p,p'-DDT, or p,p'-dichlorodiphenyltrichloroethane. DDT, prepared by the reaction of chloral with chlorobenzene in the presence of sulfuric acid, was first made in 1874; and its insecticidal properties were discovered in 1939 by a Swiss chemist, Paul Hermann Müller. DDT (dichloro-diphenyl-trichloroethane) is considered one of the first of the modern synthetic insecticides. DDT is applied as a dust or by spraying its aqueous suspension. The compound’s structure permits several different isomeric forms, such as o,p'-DDT. The term DDT is also applied to commercial products consisting predominantly of p,p'-DDT, but also containing smaller amounts of other compounds, including p,p'- and o,p'-DDD (dichlorodiphenyldichloroethane) and p,p'- and o,p'-DDE (dichlorodiphenyldichloroethene)13. Its CAS No. is 107917-42-0 and has a molecular formula of C14H9Cl5. All DDT isomers are tasteless, almost odorless solids. Its physicochemical properties include: • Physical state White, crystalline solid • Melting point 108.5–109 °C • Vapor pressure 2.53 × 10-5 Pa at 20 °C • Solubility in water Highly insoluble (1 µg/liter) • Log octanol–water partition coefficient 7.48 DDT is a non-systemic contact insecticide with a broad spectrum of activity. Growers used DDT on a variety of food crops in the United States and worldwide. Some of the crops were beans, 32 cotton, soybeans, sweet potatoes, peanuts, cabbage, tomatoes, cauliflower, brussel sprouts, corn, and other crops. DDT was also used in buildings for pest control. It was banned in several countries in the early 1970s because of ecological considerations, and many other countries have more recently restricted or banned its use except when it is needed for the protection of human health. Despite a ban on sales, organochlorines may still be found in storage in many countries such as Tajikistan; thus, exposure is still possible. DDT is still used in some countries for the control of vectors that transmit yellow fever, sleeping sickness, typhus, malaria and other insect-transmitted diseases. DDT was designated as a persistent organic pollutant (POP) in 1997 by the Governing Council of the United Nations Environment Programme14. Pesticide applicators are exposed primarily to p,p'-DDT, whereas it is the p,p'-DDE metabolite to which the general population is exposed in the diet or drinking-water. DDT and its metabolites are persistent in the environment and resistant to complete degradation by microorganisms, although photochemical degradation does occur. The persistence of DDT is substantially lower in tropical climates than in temperate ones (a few months compared with years)13. DDT and its metabolites are readily adsorbed onto sediments and soils, which can act both as sinks and as long-term sources of exposure. Due to its strong tendency to be adsorbed onto surfaces, most DDT that enters water is and remains firmly attached to soil particles. If it does find its way into water, it is gradually lost by adsorption onto surfaces13. In soils, DDT is immobile under aerobic conditions with a mean half-life ranging from 2 to 15 years 15,16,17,18,19. DDT is metabolized by microbial systems in soils and is broken down into DDE and DDD. Significant degradation has been demonstrated in soils under anaerobic conditions, while little or no degradation was observed under aerobic conditions 20. Biodegradation, however, is highly variable and influenced by the populations of required microorganisms. Various amendments to soils such as energy and carbon sources, were shown to increase degradation under anaerobic but not aerobic conditions 20,21. DDT has been shown to readily degrade in certain flooded soils22. DDT is apparently co-metabolized by microorganisms and is not used as a sole carbon source. Products of biodegradation include DDD and DDE and occasionally DBP (4,4'-dichlorobenzophenone). The physical and chemical properties of DDT and its metabolites enable these compounds to be taken up readily by organisms from the surrounding medium and from food. In aquatic organisms, uptake from water is generally more important, whereas food is the major source for terrestrial fauna. High lipid solubility and low water solubility lead to the retention of DDT and its stable metabolites in fatty tissue. In general, organisms at higher trophic levels tend to contain more DDT-type compounds than those at lower ones. These compounds can be transported around the world in the bodies of animals, as well as in ocean and air currents. In the United States, populations of bald eagles and other raptors crashed when DDT thinned their eggs, killing their embryos. The pesticide, known for accumulating in food webs and persisting in soil and river sediment, was banned in the United States in 1972. Studies in animals have also shown that oral exposure to DDT can cause liver cancer. DDT is classified as "moderately toxic" by the US National Toxicology Program (NTP) and "moderately hazardous" by WHO, based on the rat oral LD 50 of 113 mg/kg. Indirect exposure is considered relatively non-toxic for humans. The International Agency for Research on Cancer (IARC) classified DDT as Group 2A “possibly carcinogenic to humans”. EPA has determined that DDT, DDE, and DDD are probable human carcinogens as of January, 2015. 33 Current concerns surrounding DDT are due to it being an endocrine disruptor. Endocrine disruptors are chemicals that can interfere with endocrine (or hormone) systems at certain doses. These disruptions can cause cancerous tumors, birth defects, and other developmental disorders. Any system in the body controlled by hormones can be derailed by hormone disruptors. A wide and varied range of substances are thought to cause endocrine disruption. Chemicals that are known endocrine disruptors include diethylstilbestrol (the synthetic estrogen DES), dioxin and dioxin-like compounds, polychlorinated biphenyls (PCBs), DDT, and some other pesticides. DDT in Breastmilk in Tajikistan In 2015, the International Agency for Research on Cancer classified DDT as Group 2A "probably carcinogenic to humans". Previous assessments by the U.S. National Toxicology Program classified it as "reasonably anticipated to be a carcinogen" and by the EPA classified DDT, DDE and DDD as class B2 "probable" carcinogens. The health risks of DDT and related compounds (DDE, DDD) were not studied in detail in Tajikistan. But there were studies measuring DDT in breastmilk – this is the best way to assess human exposure to fat soluble substances. The WHO/UNEP human milk global surveys showed that breastmilk DDT levels in Tajikistan were the highest in the world and nearly a factor of three higher than in India where the breastmilk DDT levels are second highest. Figure 4 shows 9000 8502 8000 7000 6000 DDT (ng/g lipids) 5000 4000 3000 2000 1000 773 438 376 160 131 0 Eastern Europe Western Europe Northern Europe Southern Europe Western Asia Tajikistan Figure 4. DDT levels in breastmilk in Tajikistan and other countries (data from WHO & UNEP 2013) 34 Assessment of chemical substances listed in Annex A, Part I (POPs – pesticides): production, use, import and export in the past present and future According to Article 3 of the Stockholm Convention: “1. Each Party shall: Prohibit and/or take the legal and administrative measures necessary to eliminate: (i) Its production and use of the chemicals listed in Annex A; and (ii) Its import and export of the chemicals listed in Annex A Any Party that has a specifi c exemption in accordance with Annex A or a specific exemption or an acceptable purpose in accordance with Annex B shall take appropriate measures to ensure that any production or use under such exemption or purpose is carried out in a manner that prevents or minimizes human exposure and release into the environment. For exempted uses or acceptable purposes that involve intentional release into the environment under conditions of normal use, such release shall be to the minimum extent necessary, taking into account any applicable standards and guidelines.” This means that the following POPs listed in Annex A must be eliminated: aldrin, alpha-hexachlorocyclohexane, beta-hexachlorocyclohexane, chlordecone, dieldrin, endrin, heprachlor, gamma-hexachlorocyclohexane (lindane), pentachlorobenzene, toxaphene and endosulfan The following substances could be produced under certain circumstances and if registered as exemptions: chlordane, hexachlorobenzene and mirex The following substances could be used under certain circumstances and if registered as exemptions: aldrin, chlordane, heptachlor, hexachlorobenzene, lindane, mirex and dieldrin may be included in the register of use for a specific exemption Tajikistan is an agrarian republic. The area of cultivated crops is about 1.1 million hectares, including about 200 thousand hectares used for growing cotton. In most fields, crops are harvested twice a year. Pesticides are widely used in Tajikistan to combat pests, plant diseases and weeds. The agro-climatic conditions of the republic favor rapid reproduction and dissemination of many pests on agricultural crops. Many crops in Tajikistan are susceptible to various diseases. In most fields irrigation water is used every year and the irrigation water brings seeds of weeds. Pesticides were widely used in the past and will be still used in the foreseeable future to combat these threats. In the Soviet times Tajikistan used big volumes of various agricultural chemicals, including pesticides. The excessive use of pesticides without proper observation application rules, safety precautions and without proper consideration of the climatic conditions, creates serious problems, including: - poisoning; - reduction of biodiversity; - death of wild and domestic animals; - interference with natural pest control; - water pollution; - accumulation of pesticides in the food chain; - decrease of the soil quality as the result of pesticides contamination; - accumulation of stocks of obsolete pesticides. Large-scale use of pesticides, particularly POPs, led to environmental pollution and disruption of the dynamic balance of the biosphere. 35 Tajikistan does not produce pesticides, so the industry is fully composed of imports. From 2005-2007, the Favz commercial agriculture company started a small production (formulation) of some pesticides. The company installed two production lines imported from China in the Vahdat district. which were One line produced powdered pesticides, the other line produced suspensions and concentration emulsions. The produced analogues of pesticides were inferior in quality to original products of well-known companies such as Sengenta, DuPont and others. , which kept Favz’s sales low and ultimately limited its operation to two years. In the Republic of Tajikistan, pesticides and their mixtures listed in the "List of chemical and biological preparations permitted for use in the Republic of Tajikistan", approved by the Interdepartmental Commission on Chemical Safety of the Republic of Tajikistan (June 11, 2004) are permitted. According to the State Service for Plant Protection and Chemicalization of Agriculture of the Ministry of Agriculture, the import of pesticides is permitted for companies that win special tender. The companies must have manufacturers’ certificates for all imported pesticides. It is also necessary to obtain "Certificate of Analysis" from the Institute of Chemistry of the Academy of Sciences of the Republic of Tajikistan for each imported pesticide. Using those documents the Agency for Standardization, Metrology, Certification and Trade Inspection issues a Certificate of Conformity for the imported pesticide. Only after this procedure, the State Institution for Plant Protection and Chemicalization of Agriculture registers imported pesticides. All imported pesticides have labels in Russian with pictograms, written information, the country of origin and the address of the manufacturer. However, the pesticides do not necessarily have a technical safety manuals. OJSC "SUGHDAGROSERV" is one of the largest companies importing and selling pesticides in Tajikistan. The company has direct contracts with big foreign companies: "Sengenta" "DuPont" and others. OJSC "SUGHDAGROSERV" receives the documents from manufacturers, including safety technical manuals, labels and marks. OJSC “SUGHDAGROSERV” receives pesticides packaged by manufacturers and protected by trademarks. The pesticides are transported by special vehicles marked with hazard signs. There are also many small firms in Tajikistan that import pesticides. Their activities are insufficiently controlled. Some of these companies may import pesticides of poor quality or expired. Some smaller quantities of pesticides could be brought to Tajikistan illegally such as cases of dichlorodiphenyltrichloroethane dust smuggled from China and Uzbekistan and sold in the local markets in small bags. The Republic of Tajikistan became a member of the World Trade Organization (WTO) in 2012. In the same year the Law of the Republic of Tajikistan "On Food Safety" (July 19, 2012, No. 389) was adopted. According to the rules of WTO and the requirements of the Law on Food Safety all agricultural products sold in the domestic and foreign markets must undergo laboratory analyses for pesticides content. The toxicological laboratory assigned to conduct such analyses belongs to the State Service for Plant Protection and Chemicalization of Agriculture. But the laboratory has very old equipment and presently does not function. It is necessary to create and equip a modern toxicological laboratory and train laboratory personnel. The list of formerly used pesticides includes the following POPs: aldrin, dieldrin, heptachlor, endrin, hexachlorobenzene, toxaphene, chlordane, dichlorodiphenyltrichloroethane (DDT), lindane and endosulfan. In the past DDT comprised up to 90% of all used pesticides. Another popular insecticide was endosulfan (thiodan). Regrettably now Thiodan 35% and Thiodan 50% are included in the "List of chemicals and biological products approved for use in the Republic of Tajikistan." It is legal to import and use endosulfan (thiodan). Therefore, it is allowed to be imported into the republic and used to protect agricultural crops from pests. Chlordecone was never used in Tajikistan. The gamma isomer of hexachlorocyclohexane (lindane) was used in the 1960s, e.g. 10.7 tons were used in 1967. The inventories of 2005 and 2014 did not identify any stocks of this insecticide. In 1970 the order of the Minister of Health of the Union of Soviet Socialist Republics (USSR) use of DDT in agriculture was prohibited, and in 1987 it was prohibited to use for vector disease control. In 1980s and early 1990s, the use of other POPs 36 pesticides was banned, but some stocks of obsolete pesticides (mainly DDT) remained and were used for a long time. Inventory results Obsolete pesticides are still used in agriculture and it remains a big health risk problem. Many old warehouses still contain some remaining obsolete pesticides. The warehouses and surrounding soil are often contaminated with pesticides. In many cases pesticides were buried near the warehouses and some local residents dig up the pesticides for use in the fields and sale. This problem was particularly big for the specially designated landfills storing big volumes of obsolete pesticides. In 1991-2004 there was practically no information about the condition of those landfills and the remaining volumes of pesticides. An inventory of those landfills and storage areas was done as part of the implementation of the GEF / UNEP project No. GFL -23-27-4708 "Implementation of activities for the preparation of the National Implementation Plan for the Stockholm Convention on POPs in the Republic of Tajikistan" in 2004-2005. The inventory data were used for the development of the NIP approved by the Government of the Republic of Tajikistan on October 01, 2007. The efforts on inventory of pesticides storages and contaminates areas were continued with support of the European Union, FAO and United States Agency for International Development (USAID). As the result more than 150 sites were assessed in all regions of the country. The inventory showed that most of the former warehouses of pesticides are privatized and actively used. In only about 10% of assessed sites the remaining stocks of obsolete pesticides were preserved and require clean up action. The Fourth and Fifth Conferences of the Parties to the Stockholm POPs Convention agreed to amend the Convention by adding 10 new POPs to Annexes A, B, and C, including pesticides: Chlordecone, Lindane and Endosulfan. Methodology for conducting an inventory of pesticides The purpose of the inventory was: • comparative assessment of the use of pesticides from 2005 until present; • identification of obsolete pesticides (POPs) on farms; • assessment of existing volumes of obsolete pesticides (OP); • assessment of existing mixed pesticides; • assessment of the soil contamination with OP; • comparative assessment of condition of the pesticide warehouses since 2005; • comparative assessment of the condition of agricultural airfields since 2005; • assessment of the technical condition of the Vakhsh Polygon and the Kanibadam Polygon storage areas for pesticides. The inventory of pesticides was implemented under supervision of the Work Group, which included specialists from the State Institution for Plant Protection and Chemicalization of Agriculture of the Ministry of Agriculture of the Republic of Tajikistan and the Service of State Sanitary and Epidemiological Surveillance of the Ministry of Health and Social Protection of the Population of the Republic of Tajikistan. 37 The pesticide inventory was conducted using Toxic Site Identification Protocol (TSIP) developed by the Blacksmith Institute (USA) and entered into the database https://www.contaminatedsites.org/. Results of Pesticides Inventory In the Soviet time pesticides were supplied in large quantities. The import of pesticides in the republic was 1.5-2 times higher than the actual demand. As a result, pesticides were accumulating in warehouses and distribution centers of "Tajikselkhozkhimiya". Other factors also contributed to the accumulation of pesticides, including: • prohibition by health authorities to use some previously acquired chemicals because of health concerns; • insufficient effectiveness of chemicals against the pests; • expiration of shelf life of pesticides; • improper containers and packaging materials; • improper formulation; • improper storage conditions; • mistakes and poor organization of accounting of pesticide stocks. The accumulated obsolete pesticides were supposed to be transported to specially designated hazardous storage areas, such as Vakhsh Polygon. However, many stocks were not transported. Instead the pesticides were distributed to farmers; secretly buried or dumped; disposed at municipal solid waste landfills. After the collapse of the Soviet Union the import of pesticides in Tajikistan has decreased. People responded by starting to use remaining stocks of obsolete pesticides. The main sources of pesticide health and environmental risks are: • warehouses of pesticides with remaining OP stocks, contaminated packaging, equipment and materials; • soil contaminated with pesticides; • former agricultural airfields; • Vakhsh landfill for burial of pesticides; • unauthorized burials of pesticides. Pesticide warehouses. The initial inventory identified 143 warehouses located in Khatlon and Sughd regions and RRS. The next inventory showed that only 40% of those warehouses remained intact. Most of the warehouses were partially or completely demolished for the purposes of using the land or parts of the warehouses as construction materials. In many cases the warehouse buildings do not have roofs, doors, windows, etc. Very often there is only a wall or two standing. These warehouses could not be repaired but remain to be the sources of contamination and health risks. 38 Figure 5. Typical former warehouses for storing pesticides 39 Figure 6. Food for animals is stored in former pesticide warehouses The inventory conducted with the support of the EU, USAID and FAO in 2014-2020 identified 160 former warehouses of pesticides. Only 10% of the buildings were in good condition. Most of the former warehouses were privatized and used as commercial properties or for construction of residential houses. Most warehouses are located in Khatlon region (Figure 6.). 40 Figure 7. Locations of warehouses of obsolete pesticides in Tajikistan In most cases people live and work right near or in the former warehouses of pesticides. Some obsolete pesticides remained dumped or buried near the warehouses and people are exposed to contaminated dust, vapors and through consumption of local foods. Agricultural airfields. In the Soviet time there are 96 agricultural airfields in Tajikistan. None of them are presently operating. Presently most former airfields are used for growing crops or grazing livestock. If the airstrip is paved or made of concrete local residents used it for organizing local markets to sell raw and processed food (meat, cottage cheese, milk, dairy products), cattle, different goods. Very often the food is cooked right within the area contaminated with pesticides. For example, the Bagara site is located in the Vakhsh region, Jamoat Oq-Gaza. There used to be an airfield with paved airstip, two warehouses, pesticide solutions preparing area, access roads, a weighing ramp and ramps for unloading / loading pesticides. Now there it has become an open air market (Figure 8 and 9). 41 Figure 8. A market at the Bagara site located on the former agricultural airfield. 42 Pesticide containers. There is a problem with disposal of pesticide containers and packaging materials (Figure 10). In the past when pesticides were supplied in big volumes, the pesticides were packed in steel 100-200 liters drums or aluminum 20-40 liters cans. Most empty container were returned to the suppliers. Today pesticides are supplied mainly in small plastic containers 1, 5 or 10 liter volumes. Such containers are never returned to suppliers of pesticides and are used by rural residents for storing liquids or just dumped with other solid household waste. There are cases of using the population using these same containers for storing water, milk, vegetable oil and other food products. High transportation costs have kept suppliers from shipping used containers back to the manufacturers, and they do not have any obligation to do so. The inventory revealed that there are about 7.45 tons of various containers for pesticides piled in different locations. Figure 9. Pesticide container in Ziraki Illegal Burials of Obsolete Pesticides In 1970-80s the supply of pesticides in Tajikistan was 1.5-2 times higher than the actual demand, which led to accumulation of pesticides in the warehouses of "Tajikselkhozkhimiya". Over the years, Tajikistan has accumulated thousands of tons of obsolete pesticides, often not safeguarded properly. Before the hazardous waste storages in Vakhsh and Kanibadam were constructed many farms got rid of their obsolete pesticides by burying them somewhere near the warehouses. Sometimes after a fire the remaining agricultural chemicals including pesticides were buried. After the warehouses were privatized in 1990 the new owners either used the remaining stored pesticides 43 or dumped or buried them. Now there are many unauthorized burials of pesticides across the country. The exact locations of the burials are often unknown. 44 Chapter 4. Plan Implementation Strategy Political statement in support of Tajikistan's obligations under the Stockholm Convention on Persistent Organic Pollutants Along with the approval of the Stockholm Convention on POPs National Implementation Plan the Government of the Republic of Tajikistan issued at political statement to declare support of the NIP activities and fulfillment of Tajikistan's obligations under the Stockholm Convention (Decree No. 502, October 01, 2007). “As part of this implementation plan, Tajikistan, in addition to the first statement, accepts the following: • Participation in international environmental agreements is essential for the nation aiming to achieve Millennium Goals in 21st century. • Sharing the concern of the international community on the use of POPs, on December 6, 2006, the Republic of Tajikistan ratified the Stockholm Convention on POPs. The Government of the Republic of Tajikistan approved the National Implementation Plan for the United Nations Stockholm Convention on Persistent Organic Pollutants on October 01, 2007. In the NIP the Government of the Republic of Tajikistan assumed the responsibility to properly implement and comply with all provisions of the Convention. The Government would take actions to implement the NIP and current Health and Pollution Action Plan to reduce the health impacts of POPs and protect the rights of citizens of the republic to a healthy environment. • This policy statement supports the Health and Pollution Action Plan, which will be implemented with active participation of ministries, departments, agencies, research and educational institutions, society and media. The action plan would help coordinating all activities. • In order to achieve the NIP goals and implement the HPAP, the Committee for Environmental Protection under the Government of the Republic of Tajikistan will collaborate with international partners and use all available national expertise and technical resources. It is important to provide appropriate technical and financial assistance to the Republic of Tajikistan, as a Party with an economy in transition, considering the country's needs in building capacity to fulfill obligations under the Stockholm Convention on POPs for the successful and timely implementation of the HPAP. • Participation of Tajikistan in the Stockholm Convention on POPs is a real step forward on the road to integrating the country into the process of international cooperation to eliminate hazardous chemical compounds. Implementation strategy This section contains a description of Stockholm Convention NIP activities, including coordination of actions, reporting, assessments and updating inventory of contaminated areas (Table 5) Table 5. Proposals and priorities for implementing the strategy and capacity building Proposals and priorities for the implementation of the Management and Capacity Responsible parties Building Plan Creation of the coordination center based on the National Center for the Committee for Nature implementation of the Stockholm Convention on POPs and the public Protection Building technological capacity for disposal of POPs (obsolete pesticides), wastes and Committee for Nature soils contaminated with POPs Protection Assessment of POPs health and environmental impacts using international standards Committee for Nature Protection Revision and update of the current Plan. Committee for Nature Protection Distribution of responsibilities of national partners Committee for Nature Protection Implementation principles The implementation of NIP and HPAP activities will be based on the following principles: • Community involvement. Effective implementation of the Stockholm Convention on POPs needs effective coordination between the government, industry and non- governmental organizations and communities. • Transparency and providing general public information about POPs issues. • Compliance with international criteria, standards and regulations, updates of existing national standards. • Support to research on chemicals - alternatives to POPs. • Clear distribution of responsibilities between national partners reflected in a separate detailed agreement. • Timely compliance with undertaken obligations to avoid having exemptions on POPs. • Cost-effectiveness of the action plan. • Consideration of the real economic capacity of enterprises. • Compliance with Best Available Techniques (BAT) / Best Environmental Practices (BEP) principles. Approval of national priorities Initially an inventory of POPs was done and the NIP of the Convention was prepared with international support. The creation of the Center for the Implementation of the Stockholm Convention on POPs helped coordination of the implementation of the Stockholm Convention on POPs. The situation has changed significantly since the adoption of NIP. New substances were added to the list of POPs. This may require changes in national priorities. According to Article 7.1 of the Stockholm 46 Convention on POPs regular updates and revision of NIP is the obligation of all Parties of the Convention. HPAP contains summary of the work done until now and the analysis of possible changes in priorities based on the most recent inventory. Selection and justification of priority criteria The criteria for assessing the priority of tasks in NIP (2007) could be used in HPAP. Presently there is no need to revise the main national priorities as they are consistent with long-term National Programs. But it is necessary to analyze the effectiveness of the implemented actions. The main criteria for prioritizing activities could include: 1. The environmental and health impacts, including short term and long term impacts, the potential of exposure of people and impacts on vulnerable ecosystems. 2. Compliance with the conditions of the Stockholm Convention on POPs. Any planned activity must comply with the requirements and priorities of the Convention. 3. Cost-efficiency is important considering the economic situation of the country. 4. Cross-cutting effect on all categories of POPs. The HPAP implementation should have an effect on as many POPs as possible. For example, building analytical capacity of laboratories or adopting/amending legislation and regulations. 5. The influence on the economic development of the country. It is necessary to assess the economic effect of planned activities. Some may cause an increase of prices or stop some production. Or some actions may stimulate the economic development (introduction of new and better technologies); 6. The feasibility of monitoring. It is necessary to be able to monitor the progress and obtain tangible and measurable results. For example, it is much easier to control the concentrations of pesticides in soils or food products compared to measuring concentrations of dioxins and furans. These criteria correspond to the main priorities of the National Environmental Policy of the Republic of Tajikistan. Priority directions Development and adoption of the Law "On persistent organic pollutants in the Republic of Tajikistan". This law was included in the list of priorities but never adopted. Adoption of the law would have a significant impact on the development of the legislative and regulatory framework for new POPs. There are two main options: either adopt the law, or modify relevant existing laws and regulations. Repackaging and disposal of obsolete and banned pesticides. According to the latest inventory there are significant stocks obsolete pesticides in warehouses and buried underground The previously planned projects on repackaging and destruction of pesticides were not implemented. The problem remains one of the main priorities requiring urgent actions. The 47 list of obsolete pesticides needed to be repackaged and destroyed now would include one more substance (endosulfan). Elimination of potential health and environmental threats by improving Kanibadam and Vakhsh landfills. The Kanibadam landfill was improved which reduced potential health and environmental risks by isolating and securing obsolete pesticides. Several research projects were implemented at the Vakhsh landfill, but the general condition of the landfill did not see much improvement. More work is needed, particularly at the Vakhsh landfill. Eliminate sources of malaria using methods alternative to DDT. There are plans to destroy stocks of DDT in Vakhsh as part of the UNEP-GEF project. Creation of POPs Monitoring System including a certified chemical analytical laboratory. Proper multilevel monitoring of POPs requires creation of an internationally accredited chemical analytical laboratory equipped with modern equipment and staffed with qualified personnel. It would take significant funding but it is a high priority. New pesticides. The conducted inventories identified only endosulfan as one of the newly listed POPs in Tajikistan. It is important to register new pesticides, create a list of chemicals prohibited or permitted for import and use. Implementation Strategy Review The implementation strategy includes mechanisms for reporting and progress monitoring. It is also necessary to determine the relationship between NIP results and the HPAP. There should be a timeframe established for the implementation of activities under the Stockholm Convention. Activity: Strengthening legal and institutional mechanisms for the implementation of the Stockholm Convention on POPs. According to the analysis of the current legislation of the Republic of Tajikistan, it is proposed to improve the regulatory framework on chemical safety. It will involve introducing changes in national legislation, development of new laws. A number of international agreements supplementing the Stockholm Convention Considerable should be ratified to ensure safe and effective hazardous waste management. Since the ratification of the Stockholm Convention till the present moment, a tremendous amount of work was done to amend the national legislation. However, the reality requires from government agencies to work constantly on updating the legal framework reacting to changing situation and particularly the addition of new POPs in the Convention. The work on the legal framework should be actively supported by political decisions. Undoubtedly the Republic of Tajikistan should actively participate in international processes on circulation of chemicals and hazardous waste and respond by adopting important international legal agreements. These include the Rotterdam Convention and the PRTR Protocol. 48 The implementation of the Convention and the inventory of POPs at the national level should be based on national legislation reflecting the responsibilities of private and public institutions and businesses to provide necessary information and data. It is necessary to introduce the amendments to the legislation of the Republic of Tajikistan to require mandatory tests to assess the potential threat of produced or imported chemicals to human health. The following priorities are proposed: 1. Within the framework of national legislation, it is necessary to develop and adopt the law "On persistent organic pollutants", which will become a specialized regulatory legal act on management and handling POPs. 2. Development of a separate technical regulation on the management of wastes containing POPs would help clarify the legislation on waste management. It would also help to unify the rules scattered in GOSTs and Building regulations into a single piece. 3. It is necessary to make changes, additions and amendments in the environmental legislation of the Republic of Tajikistan regarding the introduction of the definition of the term POPs, collection of statistical data on waste generation and disposal, creating and maintaining the Unified Waste Cadastre. 4. It is necessary to make additions and amendments in the Law of the Republic of Tajikistan "On quarantine and plant protection" in order to introduce provisions on handling obsolete pesticides and toxic chemicals. It will be necessary to develop a regulation on such procedures. According to the Law of the Republic of Tajikistan "On the protection of atmospheric air" it is also necessary to develop the "Procedure for stimulating the reduction of atmospheric emissions. " 5. It is necessary to make additions and amendments in the legislation of the Republic of Tajikistan on waste management. It is necessary to introduce a definition for the term "persistent organic pollutants" in Article 1. To determine the hazard class, it is necessary to introduce an entire article, and for detailed regulation - development of a separate Procedure for determining the hazard class of wastes or refer to special technical regulations. It is necessary to add a separate article prohibiting the use of waste disposal technologies that result in producing POPs; 6. As part of NIP it is planned to create a Unified Database on POPs. But the procedure for creating and maintaining such database was not yet developed. So it is necessary to adopt a legal act on such procedure. 7. There are no normative legal acts regulating the procedures of restoration of the areas contaminated with POPs. It is proposed to introduce additions and amendments to the legislation on hazardous waste management, to establish and regulate activities of restoration of the territories contaminated with POPs. 8. The state registration of pesticides and toxic chemicals requires creation of the State Catalogue of pesticides and toxic chemicals. But the Catalogue was never created. It is necessary to develop the "Procedure for maintaining the State Catalogue of Pesticides and Toxic Chemicals." This document should define which government agency would establish and maintain the Catalogue and define which pesticides and toxic chemicals are officially banned for production and/or restricted in use in accordance with the requirements of the Stockholm Convention on POPs, including the list of new POPs; 49 9. The regulation on POPs inventory was not yet developed. The development of such regulation, including a methodology, is extremely necessary for financing the work related to the identification, description, inventory, and management of POPs. 10. A special procedure for registration, import, storage, use, and disposal of new pesticides and agrochemicals on the territory of Tajikistan does not exist and must be developed. 11. The Agency on Statistics under the President of the Republic of Tajikistan should adopt the normative act "On approval of the form of state statistical reporting 1-waste "Report on production waste management "and instructions for filling it out." 12. It is necessary to develop a technical normative act defining the procedure for monitoring the concentrations of POPs in natural environment. 13. It is necessary to adopt a normative legislative act (provision or regulations) for import and (or) export of equipment containing POPs through the customs border of the Republic of Tajikistan. 14. It is necessary to adopt a technical normative document defining the procedures of sampling and measuring concentrations of new POPs in natural environment. 15. A separate Resolution of the Government of the Republic of Tajikistan should establish the authorized state body for control over the circulation of pesticides and agrochemicals. The body should replace the existing Commission on Chemical Safety. Include specialists from different ministries and agencies institutions in the new state body. Use the Center for the implementation of the provisions of the Stockholm Convention on POPs to coordinate this work. 16. Introduce appropriate amendments and changes in the Customs Code of the Republic of Tajikistan on the control over the import and export of hazardous waste, on the identification and responsibility of individuals for customs violations. It is necessary to include experts from environmental protection institutions and the Ministry of Health and Social Protection of the Population in the commissions on POPs identification. 17. Amendments in the Tax legislation to stimulate activities to reduce use of POPs in all sectors of the economy; 18. Ensure that the planned actions fulfill the obligations under all environmental conventions on hazardous substances and wastes. This would allow uniting the efforts and reduce the impact of hazardous chemicals/waste on environment and human health. 19. Seek an increase in budgetary/extrabudgetary resources to implement the Convention 20. Develop a system to register the emissions and migrations of hazardous pollutants at the regional and national levels; 21. Organize the information exchange on the results of inventory of stocks of prohibited and obsolete pesticides, plans for their disposal and elimination, based on the results of monitoring and control between government agencies and non-governmental organizations participating in activities to identify unauthorized storage of obsolete pesticides. 22. Include mechanisms of stakeholders’ participation in the statutes of government agencies. 23. Introduce (strengthen) the norms of responsibility for officials for non-compliance with procedures of international agreements; 24. Ensure personal responsibility (administrative, criminal) for senior officials for their decisions, implementation and consequences. 50 25. Introduce into the statutes of the relevant ministries and departments a clause on the responsibility of officials for the condition of the regulated resources (forest, biodiversity, water, land, air, etc.), including pollution of the resources with POPs; 26. The specially authorized body for the implementation of the Convention should constantly expand contacts with international organizations working on the impact of pesticides on health, alternative farming, and the introduction of environmentally friendly agricultural technologies. Table 6. Action plan for legislative, institutional and regulatory capacity building. Activities Responsible Deadlines Indicators Costs, parties USD 1 2 3 4 5 Ratification of international CEP, Customs 2020-2025 Ratification of an 500.000,00 agreements Committee, international agreement Ministry of Health and bringing national and Social legislation in line with Protection of the the requirements of the Population Convention Development and adoption of CEP, the Ministry 2020-2026 Adoption of the Law of 200.000,00 a package of regulatory legal of Agriculture, the the Republic of acts, including the Law of the Ministry of Health, Tajikistan "On Persistent Republic of Tajikistan "On the Ministry of Organic Pollutants" Persistent Organic Pollutants" Industry and A package of normative Innovation legal acts, including changes and additions to the current legislation Creation of a state catalog of CEP, Ministry of 2020-2023 State catalog of 500.000,00 pesticides and pesticides, Agriculture pesticides and toxic including NLA chemicals, Government Decree and the Procedure for catalog maintaining Development of a technical CEP 2020-2023 Technical documentation 100.000,00 regulatory document on on POPs inventory and inventory and monitoring of monitoring POPs in the Republic of Tajikistan Development of regulations CEP, Customs 2020-2026 Regulation (instruction) 50.000,00 (instructions) for the detection Committee for the detection of POPs of POPs in goods passing the customs. Establishment of an Government of the 2020-2025 Abolition of the 100.000,00 interdepartmental coordinating Republic of Chemical Commission body under the Government of Tajikistan, CEP and the creation of a new the Republic of Tajikistan for interdepartmental body the organization of environmental conventions regulating the handling of chemicals and hazardous wastes on the basis of the Center for the implementation of the Stockholm Convention obligations on POPs 51 Revision and implementation Center for the 2020-2026 Integration of POPs 150.000,00 of concepts, legal regulation Implementation of management issues into of POPs circulation in the Commitments of environmental environmental strategies the Stockholm documents Convention on POPs TOTAL: 1.600.000,00 Activities: Production, import, export, use, stocks and wastes of POPs listed in Annex A (chemicals listed in Annex A, Part I) The Stockholm Convention on POPs prohibits import and export of all pesticides listed in Annex A, except for environmentally sound disposal purposes and purposes that are listed as exceptions.

Article 3 of the Convention, Annex A, forbids production of aldrin, dieldrin, endrin, heptachlor and toxaphene. The production of chlordane, hexachlorobenzene and mirex could be permitted as an exception. Aldrin, Chlordane, Dieldrin, Heptachlor, Hexachlorobenzene and Mirex could be included in the “Registry for a Specific Exception”. The specific exemptions for these chemicals expired on 17 May 2009 but could be extended upon request of an interested Party at the Conference of Parties. There are no exceptions for toxaphene and endrin, which means that those substances could only be disposed of in an environmentally safe manner. DDT is included in a separate Annex B of the Convention and deserves special attention. If a Party of the Convention intends to use DDT for vector disease control, it must: • register an acceptable target; • develop and implement an action plan to: ensure use only for vector disease control; introduce alternative products, methods and strategies for disease control; reduce the incidence of disease. The specific exemptions for DDT expired on 17 May 2009, but they can be extended upon request of interested Parties at the Conference of the Parties. In 2014- 2020, international organizations and donors (GEF, EU, UNIDO, UN FAO, UNDP, OSCE, UNEP) supported inventory of obsolete pesticides in Tajikistan. As a result of this work 218 warehouses were assessed. The inventory identified more than 14 097 tons of obsolete pesticides in different locations, including 4 022.74 tons of DDT and 7.0 tons of thiodane (endosulfan). The amount of soil mixed with pesticides – 55 720.1 tons. In Vakhsh Polygon TAUW company identified over 33.3 thousand tons of pesticides, including at least 3.3 thousand tons of DDT. The main reasons for the accumulation of obsolete pesticides include: - ineffective system of purchasing and supplying pesticides; - long-term storage of pesticides with short shelf life; - unsatisfactory organization of storage and accounting; - improper packaging; During the latest inventory in 2014, 202 soil samples were collected in Khatlon region and RRS. The analyses of those samples were conducted in a certified laboratory of Analitfaktor LLC in St. Petersburg, Russia. The analyses had to be done abroad because there are no internationally accredited laboratories in Tajikistan capable of analyzing soil for concentrations of substances listed in the Stockholm Convention. The inventory was also conducted in the Sughd region with support of FAO, but soil analyses were not done because of lack of funding. 52 The issue of disposal of containers from pesticides requires a solution. According to the preliminary data from the national inventory, there are over 130 thousand pieces of used pesticide containers in Tajikistan. These containers are a real health threat, as they are often used for household purposes, including storage of food and water. The general population health risk awareness of pesticides is very low. The number of used pesticide containers is growing every year, especially plastic containers. Simple burning is an undesired disposal method because of emissions of combustion products into the air. Table 7. Action Plan for the Elimination of POPs Stocks and Wastes (Appendix A, Part 1) Activities Responsible Indicators Deadlines Total cost in Potential sources parties $USD of funding Training for CEP, NCSK, Training 2020-2022 40,0 GEF, international members of the public program. donor assistance, working groups of organizations Certificates of republican budget Sughd and Khatlon training regions and RRS completion (40 people from plant protection specialists) in methods of conducting a detailed inventory, using the latest FAO standard forms Detailed CEP, NCSK, Working group 2021- 2023 216,0 GEF, international assessments of public reports donor assistance, contaminated sites organizations republican budget Identification of CEP, Ministry of Analytical data 2021-2023 432,0 GEF, international pesticide samples Agriculture, donor assistance, taken at pesticides NCSK republican budget warehouses and AS landfills Construction of new CEP, NCSK, Warehouse 2022-2024 250,0 International donor warehouses for public acceptance assistance, temporary storage organizations certificates republican budget of pesticides to be destroyed Cleaning, CEP, NCSK, Acceptance 2022- 2023 4125,0 International donor repackaging of public certificates for assistance, obsolete and organizations cleaning, republican budget prohibited repackaging pesticides, pesticides. provision of safe storage until the commencement of destruction activities Ensuring safety of CEP, NCSK, Instruction Constantly in 150,0 International donor repackaging and public approved by the process of assistance, transportation of organizations specially work. republican budget obsolete and 53 prohibited authorized pesticides and their bodies. mixtures, including those containing POPs Development of a CEP, NCSK Program 2023- 2025 40,0 GEF, international program for the approved by donor assistance, destruction of specially republican budget obsolete and banned authorized pesticides, the bodies. program would include the timeframe, locations and methods of destruction Transportation of CEP, NCSK Acts of 2020- 2027 340,0 GEF, international repackaged acceptance of donor assistance, pesticides to the pesticide waste republican budget place of destruction by the on the territory of destruction the Republic of organization. Tajikistan or beyond Total: 5593,0 Comprehensive environmental studies include: • Study of the geological and hydrological conditions of the sites; • Justification and construction of a regime network of observation wells for groundwater; • Identification of possible routes of migration of pesticides in the environment; • Analytical studies of pesticides in natural ecosystems; • Public health risk assessment; • Justification and organization of monitoring at each disposal site. Based on the results of the studies, develop a monitoring program for burial grounds. a) Transportation of repackaged pesticides to the place of destruction; b) Construction/acquisition of an enterprise for the destruction of obsolete and banned pesticides; c) Cleanup, restoration, destruction of warehouses / storages, soils contaminated with pesticides, including the territory of landfills. Activity: Facilitation of information exchange and stakeholder engagement It is necessary to develop a specially organized system for collection, storage, processing, analyzing and presenting the data to decision-makers. This system would benefit from the involvement of national and local non-governmental organizations of the coalition of NGOs "Tajikistan without toxic waste". The effective management of chemicals needs a system of information exchange, which would allow all partners involved in the process of chemicals management and issues of chemical safety to have access to all necessary information. One of the steps in the process of creating such information 54 system is creation of a database (electronic) that would supply and exchange information for all stakeholders in all regions of the country. The following steps are proposed: - Create an Information Exchange National Agency as part of the NCSC; - Develop and use networking strategies for exchange, collection and dissemination of information; - Subscribe to online resources containing data on national inventories; - Support the existing information mechanisms of the NCSK; - Attract stakeholders in the discussion of chemical management problems; - Appoint a National Coordinator on information exchange; - Define what information is needed; - Provide information to government agencies, academia, businesses and NGOs using the Internet, printed publications, emails, etc.; - Purchase and install necessary equipment: computers, communication devices, etc.; - Train the personnel to work with information – collection, dissemination, stakeholders’ involvement; - Build national capacity in collection and use of multi-sectoral information; - Develop educational materials and programs; - Organize trainings. Defining partners’ obligations: - Identification of relevant partners and partner organizations; - Establishment of relationships with partners; - Exchange of information with partners; - Involvement of partners in the programmatic activities. It is possible to exchange information with other Parties of the Convention if an effective international network is created. There should be a system in place including software and hardware systems for storing, processing and maintaining primary databases, including automatic quality control and increase of technical potential of information and analytical centers. Table 8. Facilitating communication and stakeholder engagement Activities Responsible Deadlines Total costs Potential sources of parties $USD funding Establishment of the Exchange CEP, NCSC 2020-2023 55,0 International donor of Information National Agency assistance, state budget as part of the NCSC Train personnel CEP, NCSC, 2020-2022 15,0 International donor NGOs assistance, state budget Increase the national capacity in CEP, NCSC, 2021-2024 20,0 International donor collection and use of NGOs assistance, state budget information from various sectors Define responsibilities of CEP, NCSC 2021 No funds partners required Discussion of health issues MAF, NCSK 2022- 2024 10,0 International donor MH assistance, state budget Total: 100,0 55 Activity: Public awareness, information and training (Article 10) According to Article 10 of the Convention, “Each Party shall, within its capabilities, ensure that the public has access to information on POPs; raises awareness on POPs among the policymakers and governing bodies.” Successful implementation of the Stockholm Convention on POPs in Tajikistan can only be achieved if the society knows about the problem of POPs and understands the impacts of POPs on environment and human health. It is necessary to raise the public awareness by providing information on POPs and conducting trainings. For this purpose, the following must be done: • Prepare and implement a program to increase public awareness of POPs; • Develop and publish educational materials (brochures, posters, newsletters) about POPs; • Prepare TV and radio materials; • Prepare articles and brochures; • Organize workshops for vulnerable groups. The policy and decision-making to increase the awareness of managers of POPs: • Identify the managers/decision-makers. Implementation of education programs for general public: • Feeding information through media; • Identifying backup people for the implementation of the public education process (ministries, local governments and NGOs); • Training of backup people; • Liaising with educational institutions dealing with POPs issues. Support of educational activities: • Highlighting the benefits of using alternatives to POPs; • Organization of TV and radio programs; • Development of a mini grant program for NGOs. Compilation of information on POPs: • Establishment of information centers; • Development of mechanisms for POPs data collection. Support for the dissemination of information: • Updating the website and issuing newsletters; • Support of the process of preparation and dissemination of information on POPs by ministries, institutions and other stakeholders. Training of workers, teachers, technical and management staff in the relevant institutions: • Organization of trainings for trainers; • Production of training materials; • Organization of practical seminars. 56 Table 9. Action plan on education and public awareness Activities Responsible Deadlines Indicators of Total cost Potential sources of parties fulfilment in $USD funding Development of a program CEP, NCSC, 2021 Program approved 25,0 GEF, international to raise public awareness NGOs by a specially donor assistance, authorized body state budget Implementation of CEP, NCSC, 2022-2025 Public education 240,0 International donor education programs for NGOs plan assistance, state general public budget Raising public awareness CEP, NCSK, Constantly Special information 50,0 International donor about the effects of POPs on NGOs in the media assistance, state environment and human (printed, electronic), budget health seminars, trainings, etc. Collection and analysis of CEP, NCSK, Constantly Aggregated 300,0 International donor data on POPs. Creation of a NGOs information assistance, state data collection team presented to the budget public and stakeholders. Establishing a process for CEP, NCSK, 2016-2017 Seminars, round 280,0 GEF, International dissemination of NGOs tables, information donor assistance, information in printed and state budget electronic media. Trainings for workers, CEP, NCSK, According Training schedule. 150,0 GEF, state budget teachers, technical and NGOs to the Reports on the management staff in the approved conducted trainings. respective institutions. schedule Total: 1045,0 Activities: research, development and monitoring (Article 11)

Article 11 of the Stockholm Convention on POPs “Obliges the Parties, to promote and / or undertake appropriate research on POPs (their alternatives and potential POPs), development, monitoring and cooperation at the national and international levels.” The inventory revealed that the infrastructure and institutional capacity for conducting research, development and monitoring of POPs is not sufficiently developed in Tajikistan. This section presents the planned activities on research, development and monitoring of POPs in Tajikistan. • Building capacity of the institutional structure of POPs research. • Identification of institutions with potential for POPs research. • Building the national capacity for scientific and technical research and infrastructure for exchange of data and analytical results. • Establishing cooperation between research institutions. • Development of procedures for public awareness about research and development results. • Conducting research to identify alternatives to POPs. • Inventory of appropriate laboratories to monitor all activities related to POPs. • List the existing laboratories. 57 • Develop the criteria for assessing laboratory capacity for analyzing POPs. • Assessment and selection of laboratories • Modernization of laboratory / laboratories that are able to test chemicals. • Research of POPs effects on human health • Monitoring and evaluation of POPs effects on pregnant women, milk of lactating mothers and other human tissues. • Research to assess the potential exposure to POPs and human health risks related to consumption of food consumed, early development, mothers’ nutrition. • Research of reducing reproductive health risks of POPs. • Environmental protection studies. • Research of POPs life cycle and migration in the environment. • Development of new, improved technologies for the detection of POPs in components of natural environment. • Identification of POPs concentrations in components of natural environment. • Determine sampling and analysis methods. • Sampling. • Tests of soil, air, water, breast milk and media for POPs concentrations. • Establishing a data management process. • Data collection and monitoring, considering the necessity to minimize duplication of activities. • Establishment of procedures for management test results. • Development of guidelines for analysis of monitoring results and reporting in accordance with international standards. • Creation of a mechanism to ensure monitoring quality. • Creation of an effective system of quality control and assurance. • Creation of a committee to evaluate the obtained data. Table 10. Research, development and monitoring Activities Responsible Deadlines Indicators Cost, $USD Potential sources parties of funding Creation of a mechanism to CEP, 2021-2023 National POPs 100,0 International donor ensure the quality of POPs MAF, NCSK monitoring assistance, state monitoring. system approved budget by a special authorized body Identification of appropriate CEP 2020-2021 Conclusion of the 20,0 International donor laboratories. Creation of a working group assistance, state working group. budget Modernization of CEP, 2021-2025 Obtaining a 1000,0 International donor toxicological analytical NCSC certificate for assistance laboratories for testing for laboratory chemicals classified as accreditation from POPs the Agency for Standardization, Metrology, Certification and Trade Inspection 58 Detection of levels of POPs CEP, Constantly Research 500,0 International donor in environmental media and NCSC program. assistance, GEF, biosubstrates. Sampling state budget schedule. Documented data. Establishment of proper CEP, Every three Data Management 250,0 GEF, international data management. NCSC years Guide (Results donor assistance, and Reporting) state budget National registries. Total: 1870,0 59 APPENDIX A: Toxic Site Identification Program in Tajikistan Prepared by: Umidjon Ulugov, Petr Sharov, Alena Temnikova Date: October 2020 60 Acknowledgements The activities described in this report were supported by the European Commission and the United Nations Industrial Development Organization project "Mitigating Toxic Health Exposures in Low-and Middle-Income Countries: Global Alliance on Health and Pollution” (DCI-ENV/2015/371157). Introduction Pure Earth/ Blacksmith Institute (BI) is an international non-profit organization dedicated to solving pollution problems in low- and middle-income countries. Pure Earth has been implementing the Toxic Sites Identification Program (TSIP), which is an effort to identify and screen contaminated sites in low- and middle-income countries where public health is at risk. TSIP has been supported by The United Nations Industrial Development Organization (UNIDO), European Commission, Asian Development Bank (ADB), World Bank and Green Cross Switzerland. The contaminated sites are identified by trained consultants/investigators drawn from universities in respective countries using the Initial Site Screening (ISS) protocol. The ISS helps to understand the risks posed by pollution, types of pollutants, size of the polluted site, population at risk, magnitude of health risk and possible remediation measurers. In Tajikistan, Pure Earth’s main partner has been the NGO Peshsaf, and its staff member Umidjon Ulugov, who also serves as Pure Earth’s country coordinator. Pure Earth’s New York and regional staff have trained Peshsaf staff in conducting various types of assessments, which has allowed them to collect samples, and investigate various types of toxic sites across Tajikistan. Project Background The Toxic sites identification program (TSIP) is designed to identify contaminated sites all over the world and to assess their potential impact on human health. To the date over 4600 sites in 99 countries have already been identified and downloaded into the database. This is probably only a small part of all contaminated sites in the world. Therefore, it is very important to continue studying toxic pollution and its impact on health. Specifically, 61 trained investigators work for Pure Earth/Blacksmith Institute in low- and middle income countries using the Initial Site Screening (ISS protocol) to implement this task. A special program developed by Pure Earth/ Blacksmith Institute called the ISS protocol helps stakeholders and governments to understand the risks associated with contamination, to identify types of contaminates, to estimate the size of contaminated area, to count the number of people at risk, and to develop a preliminary plan for rehabilitation and clean-up of sites. The main result of this work is creating an exhaustive list of toxic sites that pose a risk to human health in each country. Toxic Site Identification Program (TSIP) The Toxic Sites Identification Program aims to assess sites that have: • Toxic pollution from a “point-source” (a fixed location, not air pollution from cars and trucks), • In concentrations or levels that can cause adverse human health impact • Where there is a migration route and exposure pathway to humans • In low- and middle-income countries as designated by the World Bank Mostly obsolete pesticide sites have been inspected in Tajikistan during the TSIP process, Central to Pure Earth’s approach is the model of Pollution-Migration-Pathway-People as the basis for understanding and assessing risks at a particular site. This model is consistent with risk screening approaches used internationally (by U.S. EPA, WHO and others) but is simplified for the purpose of conducting rapid risk screenings. Pure Earth is focused on people’s health. However, many health impacts from pollution are chronic and are difficult to attribute directly to one source. In the context of an Initial Site Screening (ISS) it is unusual to be able to demonstrate clearly the health consequences of a particular site. What can be done is to show that there is a credible risk attached to the site and that this risk deserves further investigation, as part of the design of an intervention. In simple terms, the health impact of a compound on an individual is a function of its toxicity and the dose received by people. The dose is a function of the concentration of the toxic compound, the time that people are exposed, and the pathway into the body. There are three basic pathways: inhalation – entry into the body through breathing; 62 ingestion – entry through eating or drinking; and dermal – entry through skin contact and absorption. The existence of a public health risk at a site depends on three components: 1) There must be a source of pollution with a severe enough toxicity and a high enough level or concentration to be hazardous; 2) There must be a migration route for the pollution get to an area used or occupied by people; and 3) There must be a pathway into the body whereby people have the contaminant in their bodies for a long enough time for a significant dose to occur. The ISS is the process by which these components are identified and assessed at a site. TSIP Training in Tajikistan A number of both TSIP and safety trainings had been held in Tajikistan, the first being a TSIP training in 2012. A seminar was held on March 30, 2012 in Dushanbe. At that date 17 people were trained in TSIP methods (which have since been updated). Four of the 17 were government representatives. The next series of trainings were held in the years 2016-2018. On May 2-3, 2016 a safety training of 8 members of a cleanup crew was held on the territory of Yakkatut Jamoat, Jami, Tajikistan. The training program included safety issues, collection of pesticides, transportation and storage of them to the Vakhsh landfill. This is the standard safety course for all workers who work with Peshsaf—Pure Earth’s partner in Tajikistan. On May 4, 2016 Pure Earth and Peshsaf conducted an outreach program for the population of the Yakkatut Jamoat of the Jamiy region. This project reached up to 500 people. Among these persons are the staff of the mahalla council - 3 people and the jamoat - 8 people. Also 1 representative of the Khukumat district. The main task of this program was to explain the danger of obsolete pesticides on the human body, including to children. The goal was ultimately to prevent the use of building materials from the warehouse, and show local residents the methods for preventing toxic chemicals from entering the body. This initiative was meant to protect the health of the local population. As part of the project supported by the European Union, Pure Earth and Peshsaf co- hosted an educational seminar on improving the capacity of public organizations of Tajikistan in the field of environmental protection and human health. This took place on July 17 to July 22 2018. In all 22 Tajik NGO representatives, 5 staff from Peshsaf, 4 people from Pure Earth and 1 person from USAID attended. (Agenda and draft are attached in 63 annex). This seminar also included a TSIP training, showed participants how to use the TSIP online database, and ended with a site visit. On October 16, 2018, a safety training was held for 5 cleanup workers in Southern Kyrgyzstan (Vakshsh). One safety expert from Peshaf, and 4 other Peshsaf staff and 3 Pure Earth staff including one Technical Advisory Board member were present. In attendance was also the head of the Vakhsh landfill, as well as the head of the environmental protection department of the Vakhsh district. The main task as in all training workshops was an emphasis on worker is safety, proper PPE use, behavior during the action, first-aid kit, procedures for cleaning, transportation and temporary storage of obsolete pesticides at the Vakhsh landfill. Peshsaf hosted a seminar on the TSIP Database from November 12 to November 28, 2018. A total of 20 people attended as well as 3 Peshsaf staff. All NGO representatives from the July 2018 meeting were present. The main objective of this seminar was to further familiarize participants with Pure Earth’s new TSIP database. Country Background - Tajikistan Tajikistan is a small country located in Central Asia. Tajikistan shares borders with Afghanistan and China in the south and east, and with Kyrgyzstan and Uzbekistan in the north and west. The climate of Tajikistan is dry continental, with significant fluctuations in temperature and precipitation, depending on the absolute height of the terrain, and seasons. The country suffers from a number of legacy and contemporary environmental problems. Clean, surface waters are polluted by human activity. The Varzob River, which supplies drinking water to the capital of the country, Dushanbe, is polluted upstream by household and industrial wastewater. The Kafirnigan River is another important source of drinking water, but it receives drainage water, and industrial and domestic wastewater, which leads to pollution. The Vakhsh River, which crosses all of Tajikistan is polluted with industrial wastewater containing mainly salts and organic fertilizers, toxic chemicals and pesticides that are washed away from the fields. The Syr Darya River (one of the rivers which went into the Aral sea) is so polluted with irrigation water that the water in it is practically unsuitable for drinking. Groundwater is also polluted after human activities (industrial, agricultural and domestic wastewater). Waste management issues are also very prominent in Tajikistan. Currently, there is no reliable information on the volumes and types of waste, including toxic waste (such as 64 pesticides). Wastewater treatment in the country does not follow the international rules of transfer and storage of toxic goods and chemicals intended for use in agriculture and industrial facilities. Air pollution is another serious pollution issue in Tajikistan. The main sources of air pollution in urban areas are metallurgical plants, chemical production plants, and cotton processing plants. Many of the pollutants in the air are suspended solids. Thus, the anthropogenic causes that have a negative impact on the health of the population in the Republic of Tajikistan are: • Air pollution in major cities of the country; • Low provision of the population with drinking water • Low water quality where water is present • The storage of household and industrial waste in water protection zones • Unsatisfactory storage of all types of waste, including toxic and radioactive waste The environmental monitoring system at the state level is poorly developed for a number of reasons, including lack of funding. This makes it impossible to know the scope of the problem across the country, as well as the full variety of environmental issues. No state centralized system of information is available to the government which makes it possible to make management decisions to reduce health risks for people living in polluted areas. All of these issues contribute to the continued problems related to health risks from pollution in Tajikistan. Implementation Strategy Coordination with the government Joint work was carried out by Pure Earth and Peshsaf with the Committee for Environmental Protection under the Government of the Republic of Tajikistan (Chairman of the Committee - Ibodzoda Khairullo), as well as the Center for the Implementation of the Stockholm Convention on POPs (Head of the Center - Khairullayev Rakhmatullo). In their work, coordinators and researchers work closely with government agencies, and begin by considering the sites from afar, and ending with a trip to the sites. 65 The Committee on Nature protection is interested in clearing the sites investigated, but because of a lack of funding it cannot do it on its own. Pollution Sources and Key Pollutants Total Sites Surveyed in Tajikistan Since 2009 217 contaminated sites in Tajikistan have been investigated and entered into the database. The main source of pollution in the surveyed areas is agriculture (stores of obsolete pesticides). About 87% of all sites are polluted with toxins from the agriculture industry. The remaining sites are polluted from mining, landfills, chemical manufacturing, heavy industries. The distribution of plots by type of industry is shown in Table 1 and Figure 1. Table 11. The number of sites as categorized by pollution source assessed by Pure Earth’s investigators in the TSIP Database Number of Industry Sites Agriculture 188 Industrial/Municipal Dump Site 6 Mining and Ore Processing 5 Chemical Manufacturing (acids, organics, base chemicals) 2 Petrochemical Industries (refineries) 2 Lead - Battery Recycling 2 Heavy Industry (casting, rolling, stamping) 1 Nuclear Fuel Processing 1 Product Manufacturing (electronics, equipment, clothing) 1 Industrial Estate (mixed industries) 1 Lead Smelting (with ingot production) 1 Unknown 7 Total 217 66 Industry Agriculture (86.6%) Industrial/Municipal Dump Site (2.8%) Mining and Ore Processing (2.3%) Chemical Manufacturing (0.9%) Petrochemical Industries - refineries (0.9%) Lead - Battery Recycling (0.9%) Heavy Industry - casting, rolling, stamping (0.5%) Nuclear Fuel Processing (0.5%) Product Manufacturing - electronics, equipment, clothing (0.5%) Industrial Estate - mixed industries (0.5%) Lead Smelting with ingot production - (0.5%) Unknown - (3.2%) Figure 1. Segmentation of sites as categorized by pollution source assessed by Pure Earth’s investigators in the TSIP Database Based on the analysis of the obtained data, it was found that the vast majority of sites (87.1%) of the estimated sites were contaminated with pesticides (including DDT, lindane, aldrin, heptachlor). Figure 2 shows the geographical distribution of pollution sources in Tajikistan. The types of pollutants that were found at the sites are shown in Table 2 and Figure 3. Figure 4 shows the geographical distribution of sites ranked by type of pollutants in Tajikistan. 67 Figure 2. Geographical Distribution of pollution sources in Tajikistan Table 2: The number of sites as categorized by contaminant assessed by Pure Earth’s investigators in the TSIP Database Key Pollutant # of sites DDT 156 Pesticides (unidentified) 16 Lindane (Hexachlorocyclohexane all forms) 13 Unknown 10 Uranium 5 Radiation 4 Aldrin 2 Asbestos 2 Heptachlor 2 Other 2 Bromacil 1 Chromium (Hex) 1 68 Mercury - elemental 1 PCBs (PolyChlorinated Biphenyls) 1 Phenol (0.5%) 1 Total 217 DDT (71.9%) Pesticides (unidentified) (7.4%) Lindane (Hexachlorocyclohexane all forms) (6.0%) Unknown (4.6%) Uranium (2.3%) Radiation (1.8%) Aldrin (0.9%) Asbestos (0.9%) Heptachlor (0.9%) Other (0.9%) Bromacil (0.5%) Chromium (Hex) (0.5%) Mercury - elemental (0.5%) PCBs (PolyChlorinated Biphenyls) (0.5%) Phenol (0.5%) Figure 3. Polluted sites in Tajikistan broken down by type of pollutant 69 Figure 4. Map of contaminated sites in Tajikistan 70

ANNEX 1. List of TSIP sites in Tajikisan Site Site name Source of Industry Key Maximum Units ID Pollutant test result TJ- Chkalovsk hydrometallurgical Mining and Ore mg/kg 437 plant tailing pond Processing Radiation 0,00048 or ppm Degmai (or Degmay) TJ- Radioactive Storage Site, Mining and Ore mg/kg 754 Degmai Village, Sughd Region Processing Radiation 0,0025 or ppm TJ- Taboshar Uranium Tailing Mining and Ore 786 Dump Processing Radiation 950 TJ- Anzob Mining and Mining and Ore 2086 Beneficiation Complex Processing Mercury - elemental 0 TJ- mg/kg 2889 Kanibadamsky POPs Landfill Agriculture DDT 1074 or ppm TJ- Industrial/Municipal mg/kg 2904 Vahsh pesticide burial ground Dump Site DDT 1074 or ppm TJ- Landfill of solid domestic Industrial/Municipal PCBs (PolyChlorinated mg/kg 2957 waste in Rudaki Dump Site Biphenyls) 0 or ppm Chemical Manufacturing TJ- (acids, organics, 2964 Javanese Chemical Plant - JSC base chemicals) Other 0 TJ- Solid domestic waste ground Industrial/Municipal 2966 in Khudjand Dump Site Chemical Manufacturing TJ- (acids, organics, 2986 JSC base chemicals) Bromacil TJ- Mini Lead Processing 3148 Workshop in Dushanbe TJ- Lead processing company, 3149 Sino Dushanbe TJ- Pesticides Burial Site, Village mg/kg 3208 1, Kumsangir Region Agriculture DDT 107,41 or ppm Village Bagara of Vahsh region TJ- (Ïîñåëîê Áàãàðà Âàõøñêîãî mg/kg 3240 ðàéîíà) Agriculture DDT 8,7 or ppm Village Oikamar of Khuroson TJ- region (Ïîñåëîê Îéêàìàð mg/kg 3241 Õóðîñîíñêîãî ðàéîíà) Agriculture DDT 6,13 or ppm TJ- POPs Landfill in djamoat Industrial/Municipal 3242 Kirov, Vahsh region Dump Site DDT 0 71 TJ- Kishlak Sogdiana, Vahsh mg/kg 3248 region Agriculture DDT 5,93 or ppm Petrochemical TJ- Industries 3272 Bitumen Plant of Rumi Region (refineries) Heavy Industry TJ- (casting, rolling, mg/kg 3328 LLC stamping) Asbestos 0 or ppm TJ- Landfill of solid domestic Industrial/Municipal mg/kg 3329 waste in Dushanbe Dump Site Asbestos 0 or ppm TJ- Industrial/Municipal 3424 School ¹ 5, Istiklol (Taboshar) Dump Site Uranium 0,003287 ug/m3 Former Building of KIP Automatics (uranium TJ- production adit), Sarymsakli, mg/kg 3451 Istiklol (Taboshar) Radiation 0,00084 or ppm TJ- Gozien Settlement near Nuclear Fuel mg/kg 3452 Digmay Tailings Processing Uranium 0,00272 or ppm TJ- mg/kg 3462 Chkalovsk Tailing Dump Uranium 0,00048 or ppm A Former Garment Factory, TJ- village Old Taboshar, Istiklol mg/kg 3466 town (Taboshar) Uranium 0,00098 or ppm TJ- Former uranium mine ¹ 3, mg/kg 3469 Khujand Uranium 0,00049 or ppm Product Manufacturing TJ- Tannery - Tojik Intikol LLC, (electronics, ug/l or 3609 Firdavsi District, Dushanbe equipment, clothing) Chromium (Hex) 140 ppb TJ- Private Enterprise for the Industrial Estate 3640 Production of Lime (mixed industries) Petrochemical TJ- Industries 3651 Petroleum Refinery LLC (refineries) Phenol 0 Ìàëîå ïðåäïðèÿòèå ïî TJ- ïåðåðàáîòêå ñâèíöîâûõ Lead Smelting (with 4067 àêêóìóëÿòîðîâ ingot production) TJ- Ïóíêò ïðèåìà ñâèíöîâûõ Lead - Battery 4068 àêêóìóëÿòîðîâ ãîðîäà Äóøàíáå Recycling TJ- Êàáåëüíûé çàâîä ãîðîäà Lead - Battery 4139 Äóøàíáå Recycling TJ- Mining and Ore 4154 Öåìåíòíûé çàâîä íà Âàðçîáå Processing TJ- Ïðåäïðèÿòèå ïî äîáû÷å çîëîòà 4420 "Ïàêðóò" TJ- mg/kg 4690 Ziratkor Agriculture DDT 7 or ppm TJ- mg/kg 4691 Kalinin Agriculture Pesticides (Total) 7 or ppm 72 TJ- mg/kg 4692 Moscow Agriculture Pesticides (Total) 8 or ppm TJ- mg/kg 4693 Storage Khaidar Mirov Agriculture Pesticides (Total) 5,5 or ppm TJ- mg/kg 4694 Sumbula Agriculture Pesticides (Total) 8 or ppm TJ- mg/kg 4695 Jdanov Agriculture Pesticides (Total) 6,5 or ppm TJ- mg/kg 4696 Dzerjinskiy Agriculture DDT 7,5 or ppm Lindane TJ- (Hexachlorocyclohexane mg/kg 4698 Marks Agriculture all forms) 8 or ppm TJ- mg/kg 4699 Selknozkhimiya Agriculture Pesticides (Total) 7 or ppm TJ- mg/kg 4700 Latif Murodov Agriculture Pesticides (Total) 5 or ppm Lindane TJ- (Hexachlorocyclohexane mg/kg 4940 Bakhor, Djami Agriculture all forms) 0,087 or ppm Lindane TJ- (Hexachlorocyclohexane mg/kg 4956 Zarnissor (former Engels) Agriculture all forms) 0,067 or ppm Lindane TJ- (Hexachlorocyclohexane mg/kg 4958 Djovidon, F. Saidov Agriculture all forms) 82,51 or ppm Lindane TJ- Tursunzoda or Tursunzade, (Hexachlorocyclohexane mg/kg 4963 Djami Agriculture all forms) 1,373 or ppm Lindane TJ- (Hexachlorocyclohexane mg/kg 4971 Ozodii Sharq (former Lenin) Agriculture all forms) 0,125 or ppm Lindane TJ- State Farm 6, (Sovhoz 6) (Hexachlorocyclohexane mg/kg 4972 Yavan Agriculture all forms) 6,94 or ppm TJ- mg/kg 4973 Davlatobod, Khamadoni Agriculture DDT 0,263 or ppm Lindane TJ- (Hexachlorocyclohexane mg/kg 4981 Vakhdat, Khamadoni Agriculture all forms) 0,106 or ppm TJ- mg/kg 4982 Turdyev, Khamadoni Agriculture Aldrin 0,358 or ppm TJ- State Farm 5, (Sovhoz 5) mg/kg 4984 Yavan Agriculture Heptachlor 5,291 or ppm Lindane TJ- (Hexachlorocyclohexane mg/kg 4985 State farm 4, (Sovhoz 4)Yavan Agriculture all forms) 0,359 or ppm TJ- mg/kg 4986 Imomberdyev, Yavan Agriculture Other 0,499 or ppm 73 Lindane TJ- (Hexachlorocyclohexane mg/kg 4987 50 years of USSR, Yavan Agriculture all forms) 0,066 or ppm TJ- State Farm 1, (Sovhoz 1) mg/kg 4988 Yavan Agriculture Aldrin 0,073 or ppm Lindane TJ- 10 years of Independence, (Hexachlorocyclohexane mg/kg 4989 Khamadoni Agriculture all forms) 18,89 or ppm Lindane TJ- Dekhkan and Farming Entity (Hexachlorocyclohexane mg/kg 4990 Saidov, Khamadoni Agriculture all forms) 13,75 or ppm Lindane TJ- (Hexachlorocyclohexane mg/kg 4991 Khamidov, Khamadoni Agriculture all forms) 0,099 or ppm TJ- mg/kg 4992 Ittifoq, Khamadoni Agriculture DDT 30,074 or ppm TJ- mg/kg 4993 Sarhadchi, Khamadoni Agriculture Heptachlor 0,214 or ppm TJ- Pesticide Warehouse, Darkat, mg/kg 5404 Muhojirobod, Farhor Agriculture DDT 12,66 or ppm TJ- Pesticide Storage Ziraki, mg/kg 5413 Kulyab Agriculture DDT 13,82 or ppm Former Pesticides TJ- Warehouse, Bulbul Chashma mg/kg 7309 jamoat Agriculture DDT 5,29 or ppm Former pesticides warehouse TJ- named after Dzerzhinsky, mg/kg 7310 jamoat Durbat Agriculture DDT 4,38 or ppm TJ- Former pesticides warehouse, 7395 "Agriculture", Sharora jamoat Agriculture DDT TJ- Former pesticides warehouse, 7398 "Moscow", jamoat Mirzo Rizo Agriculture Pesticides Former pesticides warehouse TJ- "Sambula" jamoat Dehati mg/kg 7400 Gissor Agriculture DDT 7,3 or ppm TJ- Former pesticides warehouse, mg/kg 7414 Jamoat G. Gulmurodov Agriculture DDT 373 or ppm TJ- Warehouse in Khatlon-1, mg/kg 7417 Jamoat Zarbdor Agriculture DDT 14,6 or ppm TJ- Warehouse of obsolete mg/kg 7420 pesticides in Lagmon, Kulyab Agriculture DDT 34,4 or ppm TJ- Former pesticides warehouse, 7423 Jamoat Mirzo Tursunzoda Agriculture DDT Former pesticides warehouse, TJ- Sayod village, Jamoat named mg/kg 7425 after T. Sadriddinov Agriculture DDT 0,88 or ppm Former pesticides warehouse, TJ- Takhti Sangin jamoat, Farogat mg/kg 7426 area Agriculture DDT 437 or ppm 74 Former warehouse of pesticides of the former state farm "Komsomol", jamoat TJ- "Navzamin", village mg/kg 7427 Pakhtakor Agriculture DDT 0,44 or ppm Former pesticides warehouse, TJ- Yangiabad village (Navabad), mg/kg 7432 Nuri Vakhsh jamoat Agriculture DDT 0,15 or ppm Warehouse of the former collective farm "Umed" in the TJ- village of "Umed", jamoat mg/kg 7434 "Navzamin" Agriculture DDT 0,24 or ppm Burial of pesticides at former TJ- airfield, jamoat Navobod, mg/kg 7436 deha Navobod Agriculture DDT 309 or ppm Burial of pesticides, jamobat TJ- Navobod, Navobod site, mg/kg 7437 Dehkan Farm "Ibod" Agriculture DDT 34,5 or ppm Former pesticides warehouse, regional agricultural TJ- chemistry, Seshanbe jamoat mg/kg 7438 Tursunzade Agriculture DDT 29,7 or ppm TJ- Burial of pesticides, jamoat mg/kg 7440 Navobod, Navobod area Agriculture DDT 5,55 or ppm Warehouse of obsolete TJ- pesticides in Vatan Jamoat, mg/kg 7441 Farkhor District Agriculture DDT 18,5 or ppm Buriev Former Pesticides TJ- Warehouse, Regar Jamoat, mg/kg 7442 Tursunzade Agriculture DDT 2,63 or ppm Former pesticide warehouse TJ- in the Namuna Village, G. mg/kg 7443 Gulmurodova Jamoat Agriculture DDT 6,21 or ppm Former pesticides warehouse, TJ- Mekhnatobod village, Jamoat mg/kg 7445 20 years of Independence Agriculture DDT 73 or ppm Pesticides warehouse in TJ- Farhor District, Chorgul mg/kg 7447 Village Agriculture DDT 1,83 or ppm Former warehouse of TJ- pesticides, Bolshevik-1, mg/kg 7448 jamoat Zargar Agriculture DDT 1051 or ppm Former central pesticide warehouse of the Margedar TJ- state farm in the village of mg/kg 7481 Bahor Jamoat Loik Sherali Agriculture DDT 8,54 or ppm TJ- Former Pesticides mg/kg 7483 Warehouse, Jamoat Agriculture DDT 6,94 or ppm 75 Pahtaobod, Vakhdat area (former Pervomaiskii) Former Pesticides TJ- Warehouse, Dusti collective mg/kg 7484 farm, jamoat Karatog Agriculture DDT 2,04 or ppm Former Pesticides TJ- Warehouse, Kumshok area, mg/kg 7485 jamoat H. Kholmatov Agriculture DDT 2731 or ppm TJ- Burial of pesticides, Aini mg/kg 7486 Village, Navbahor Jamoat Agriculture DDT 433 or ppm TJ- Former warehouse of mg/kg 7487 pesticides, Jamoat Bokhtarien Agriculture DDT 3,65 or ppm Former warehouse of TJ- pesticides, village of Rohi mg/kg 7488 socialism, jamoat Kalinin Agriculture DDT 5,91 or ppm Former pesticides warehouse, TJ- Khuramzamin vVllage, mg/kg 7490 Farohor Jamoat Agriculture DDT 0,58 or ppm Former Pesticides Warehouse, Jamoat Istiklol, TJ- the village of Beshkent mg/kg 7522 (Komsomol) Agriculture DDT 599 or ppm Бывший склад ядохимикатов село Бешкапа TJ- , джамоат "Навруз" Носири 7523 Хусравский район. Agriculture Pesticides Старый аэропорт для химической обработки хлопковых полей. Село Чупон кишлок, джамоата TJ- "Истиклол" Носири 7524 Хусравского района Agriculture DDT Former Pesticides Warehouse, Rakhmonov, TJ- Chuibor Village, Kumsangir mg/kg 7527 Jamoat Agriculture DDT 1664 or ppm Former Pesticides TJ- Warehouse, Emamadov, mg/kg 7528 Vahdati Milli Jamoat Agriculture DDT 190 or ppm FFormer Pesticides TJ- Warehouse, Khasanov, mg/kg 7529 Telman Village, Istiklol Jamoat Agriculture DDT 0,73 or ppm Former Pesticides Warehouse, Eshkhonov, the TJ- village of Kirov, jamoat mg/kg 7530 Yakkodin Agriculture DDT 3,07 or ppm Former Pesticides TJ- Warehouse, Geranium, mg/kg 7531 Zarnisor village, Jamoat Dusti Agriculture DDT 0,73 or ppm 76 Former Pesticides Warehouse, Esankulova, the TJ- village of Kizil-October, mg/kg 7533 jamoat Madaniyat Agriculture DDT 1,46 or ppm Former Pesticides Warehouse, 40 Solag, TJ- Michurin village, Jamoat mg/kg 7534 Frunze Agriculture DDT 1,53 or ppm Former Pesticides Warehouse, Yangiturmush, TJ- the village of Yangiturmush, mg/kg 7536 jamoat Frunze Agriculture DDT 1,83 or ppm Former Pesticides TJ- Warehouse, Jamoat Overpass mg/kg 7538 Deha Vatan Agriculture DDT 0,73 or ppm Former warehouse of TJ- pesticides, Surkhob Village, mg/kg 7539 Jamoat Galaba Agriculture DDT 0,26 or ppm Former pesticide warehouse, TJ- Sinov Street, center of Farhor mg/kg 7545 District Agriculture DDT 2,34 or ppm Former Pesticides Warehouse, Jamoat U. TJ- Nazarov, Mehnatobod area, mg/kg 7547 Dekhan farm Shermat Bobo Agriculture DDT 4,02 or ppm Former pesticide warehouse, TJ- Archa Village, Dekhkon Aryk mg/kg 7551 Jamoat Agriculture DDT 36,5 or ppm Former Pesticides Warehouse, Eshmurod TJ- Niyozov Jamoat, Ziraki, mg/kg 7553 dekhan farm Tour Sohib Agriculture DDT 0,52 or ppm Former warehouse of pesticides of the agricultural TJ- airfield of Jamoat Takhti mg/kg 7554 Sangin, Navobod site No. 2 Agriculture DDT 0,93 or ppm Former pesticide warehouse, TJ- the village of Pravda, Uzun mg/kg 7556 jamoat Agriculture DDT 3,36 or ppm Former Pesticides Warehouse TJ- in Pushkin Village, Navobod mg/kg 7558 Jamoat Agriculture DDT 2,92 or ppm Former warehouse of TJ- pesticides, Khaidarova Street, mg/kg 7559 Balkh Village Agriculture DDT 2,92 or ppm Former Pesticides Warehouse, 20 years of TJ- Independence Jamoat, mg/kg 7561 Sangoba area Agriculture DDT 1580 or ppm 77 Former pesticides warehouse TJ- in Gulshan Jamoat, Farkhor mg/kg 7562 District Agriculture DDT 8,76 or ppm Former Pesticides Warehouse, Jamoat "U. TJ- Nazarov", the village of mg/kg 7563 Guliston (Bugama) Agriculture DDT 0,44 or ppm Former Pesticides Warehouse, Jamoat "20 of TJ- the Istikloliyat", the village of mg/kg 7567 Doki (former Kalinin) Agriculture DDT 47,3 or ppm Burial of pesticides on the TJ- bank of Mazor Creek, Bahor mg/kg 7575 Village, Jamoat of L. Sherali Agriculture DDT 0,22 or ppm Field camp of the brigade No. 4 of the former state farm TJ- "Margedar" of the Gusar mg/kg 7576 Village, L. Sherali Jamoat Agriculture DDT 0 or ppm Burial of pesticide residues TJ- near Ogilak Creek, Navobod mg/kg 7577 Village, L. Sheral Jamoat Agriculture DDT 3,94 or ppm Former Pesticide Warehouse, TJ- Kalinin State Farm, mg/kg 7579 Kuibyshevsky District Agriculture DDT 2,56 or ppm TJ- Former Pesticide Warehouse, mg/kg 7580 Hovaling Jamoat Agriculture DDT 8,76 or ppm Burial of pesticides in the TJ- village of Sherobod, Dusti mg/kg 7582 jamoat Agriculture DDT 2245 or ppm Former pesticides warehouse in the village of Chorsad, TJ- Lolazor jamoat, Dangara mg/kg 7583 District Agriculture DDT 1,9 or ppm Former pesticides warehouse, TJ- Nurali Mirali street, center of mg/kg 7584 Dangara District Agriculture DDT 0,07 or ppm Former pesticide warehouse, TJ- Dilnishin village, Pushing mg/kg 7586 Jamaat, Dangary District Agriculture DDT 2,92 or ppm Burial of pesticides in the TJ- village of Ozodia Shark, mg/kg 7587 Jamoat K. Giyosov Agriculture DDT 29,2 or ppm Former Pesticide Warehouse, TJ- Khovaling state farm, mg/kg 7588 Khovaling Jamoat Agriculture DDT 0,88 or ppm Former Pesticide Warehouse, TJ- jamoat Khudoyor Rajabova, mg/kg 7592 Pakhtakor Village Agriculture DDT 10,3 or ppm 78 The former pesticide TJ- warehouse in Navobod mg/kg 7594 Village, Sherali Jamoat Agriculture DDT 9,86 or ppm The former warehouse of pesticides in Navobod Village, TJ- Loik Sharoli Jamoat, Pejikent mg/kg 7595 District Agriculture DDT 1545 or ppm The former pesticide warehouse, LLC Resanda in TJ- Khatlon Region, Kushoniyon mg/kg 7596 District Agriculture DDT 5,11 or ppm A former pesticides TJ- warehouse in Bakhor Jamoat, mg/kg 7597 Nosiri-Khursav District Agriculture DDT 634 or ppm Burial place of pesticides in TJ- the farm "E. Sultonov", Jilikul mg/kg 7598 Jamoat Agriculture DDT 129 or ppm TJ- Former Pesticide Warehouse, 7599 Sadam LLC, A. Jami District Agriculture Pesticides Former agricultural TJ- aerodrome pesticide mg/kg 7606 warehouse, Jilikul jamoat Agriculture DDT 18 or ppm Former pesticides warehouse of Agricultural chemistry of TJ- the Dusti district, Garauti mg/kg 7607 jamoat Agriculture DDT 449 or ppm Former agricultural airport TJ- and pesticides burial site, mg/kg 7616 Lolazor 4 Agriculture DDT 62 or ppm Household of Dustov Khujamurod, a resident of TJ- Kishlak Navobod, Jamoat L. mg/kg 7625 Sherali Agriculture DDT 1,61 or ppm Warehouse of pesticides and a garage of dekhkan farm TJ- "Zarafshon", village Ruknobod mg/kg 7626 jamoat Voru Agriculture DDT 0,37 or ppm Field camp of the brigade No. TJ- 1 of the farm Margidar, mg/kg 7627 Jamoat L. Sherali Agriculture DDT 0,51 or ppm Former pesticides warehouse of the collective farm named TJ- after Lenin, the village of mg/kg 7632 Ohchar Agriculture DDT 513 or ppm Former pesticides warehouse, collective farm Tomin, TJ- Sulkhobod village, jamoat mg/kg 7634 Tugarak Agriculture DDT 234 or ppm 79 Former pesticides warehouse, collective farm of TJ- Communism, Kaduchi village, mg/kg 7635 Vaysov jamoat Agriculture DDT 62,8 or ppm Former pesticides warehouse, TJ- Halevard jamoat, Yesleninchi mg/kg 7650 village Agriculture DDT 46,6 or ppm Склад селение "АНОРЗОР" TJ- ХДФ Рахмонова района mg/kg 7765 Кумсангир (Джайхун) Agriculture DDT 1,9 or ppm Склад типовая ХДФ Рахмонов селение Чуйбор- TJ- 1(ИСМОИЛ) джамоат 7767 Кумсангир район Джайхун Agriculture Pesticides Склад типовая, ДХФ имени TJ- Мехвар (СЕЛЬХОЗХИМИЯ)- mg/kg 7768 район Пяндж Agriculture DDT 1,39 or ppm Склад типовая, ДХФ имени TJ- Мехвар ДЕХИ БАЛАНД- mg/kg 7769 район Пяндж Agriculture DDT 4,89 or ppm Склад типовая, ДХФ имени "НАМУНА" селение TJ- ПЕШКАДАМ -1 -район 7770 Пяндж Agriculture Pesticides Склад типовой, ДХФ имени TJ- "НУРИ ВАХДАТ", район mg/kg 7771 Пяндж Agriculture DDT 16,5 or ppm Склад типовая, ДХФ имени TJ- ОЗОДАГОН совхоз ПАНЧ- mg/kg 7772 район Пяндж Agriculture Pesticides 6,57 or ppm Склад типовая, ДХФ имени ОЗОДАГОН TJ- (ЭМОММАШРАБ)-район mg/kg 7773 Пяндж. Agriculture Pesticides 7,15 or ppm Склад типовая ХДФ Намуна TJ- селение ПЕШКАДАМ-2 7774 район Пяндж Agriculture Pesticides Pesticide Warehouse HDF TJ- Kabud Sayfiddin in the village mg/kg 7775 Rohi Lenin, Pyanj district Agriculture DDT 4,16 or ppm Склад типовая ХДФ НАМУНА TJ- селение ПЕШКАДАМ-1 mg/kg 7776 РАЙОН ПЯНДЖ Agriculture Pesticides 2,92 or ppm Pesticide Warehouse HDF TJ- Sayfidin Kabud in the village mg/kg 7777 of Pravda Agriculture DDT 123,1 or ppm TJ- АО им. Назарова - AS name 8176 of Nazarova Agriculture DDT 80 TJ- АО "Таджикистан" - AS 8178 "Tajikistan" Agriculture DDT TJ- 8179 АО "Дусти" - AS " Dusti" Agriculture DDT TJ- 8180 АО "Асор" - AS " Asor" Agriculture DDT TJ- АО им " Бойматова" - AS " 8181 Boymatova" Agriculture DDT TJ- АО " Сельхозхимия" - AS " 8182 Selhozhimiya" Agriculture DDT TJ- ДФХ им " Карабаева" - 8183 "Karabayeva" Agriculture DDT TJ- Пр. КООП "Таджикистан" - 8184 "Tajikistan" Agriculture DDT TJ- 8185 АО "Ирам" - " Iram" Agriculture DDT TJ- 8186 АО "Андарсой" - "Andarsoy" Agriculture DDT TJ- 8187 ПКООП "Бобоев" - "Boboev" Agriculture DDT TJ- 8188 АО "Сатторов" - "Satorov" Agriculture DDT TJ- 8189 АО "Улчабоев" - "Uljaboev" Agriculture DDT TJ- Хозяйство им Р. Набиев - 8190 Hothiaystvo im R. Nabiev Agriculture DDT TJ- АО "Саидкургон" - 8191 "Saidkurgon" Agriculture DDT TJ- 8192 АПК "Гулистон" - "Guliston" Agriculture DDT TJ- ПК им П. Бобокалонова - PK 8193 im P. Bobokalonova Agriculture DDT TJ- 8194 ДХ им. "Алиева" - "Alieva" Agriculture DDT TJ- АДХ "Узбекистан" - 8195 "Uzbekistan" Agriculture DDT TJ- Хозяйство им Дж. Расулова 8196 - Hothiaystvo im J. Rasulova Agriculture DDT TJ- АО им А. Джумаева - AO in 8197 A. Jumaiva Agriculture DDT TJ- АО им "Урунходжаев" - 8198 "Urunhojaev" Agriculture DDT TJ- АХД "Сомониен" - AHD 8199 "Smonien" Agriculture DDT TJ- 8200 АО им Кушатова - Kushatov Agriculture DDT TJ- АО Убайдуллоев - 8201 Ubayduloev Agriculture DDT 81 TJ- ДФХ "Таджикистан" - 8202 "Tajikistan" Agriculture DDT TJ- 8203 АДХ им Д. Азизов - D. Azizov Agriculture DDT TJ- Хозяйство им А. Самадова - 8204 Hoziaistvo im. A. Samadova Agriculture DDT TJ- АО им Б. Турдыбаева - 8205 Turdieva Agriculture DDT TJ- АДХ им. О. Нозирбоева - O. 8206 Nozirboeva Agriculture DDT TJ- ПК "Ленинград" - 8207 "Leningrad" Agriculture DDT TJ- ДХ им Д. Хамдамова - DH im 8208 D. Hamdamova Agriculture DDT TJ- 8209 АДХ "Дусти" - "Dusti" Agriculture DDT TJ- АХД "Фирдавси" - AHD 8210 "Firdavsi" Agriculture DDT TJ- АДХ "Юсуф - Вафо" - ADH 8211 "Usuf - Vafo" Agriculture DDT TJ- АХД "Хакикат" - AHD 8212 "Hakikat" Agriculture DDT TJ- АДХ им "Хочи Амиров" - 8213 ADH im "Hochi Amirov" Agriculture DDT TJ- АХД "Заравшон" - AHD 8214 "Zaravshon" Agriculture DDT TJ- АХД им "Рудаки" - AHD im 8215 "Rudaki" Agriculture DDT TJ- АХД "Файзи Султон" - AHD 8217 "Payzi Sulton" Agriculture DDT TJ- АХД "У. Хайом" - AHD "U. 8218 Hayom" Agriculture DDT TJ- АХД "Ч. Эргашев" - AHD "C. 8219 Ergashev" Agriculture DDT Сельхозхимия и хозяйство TJ- им. Каленина - Selhozhimiya 8220 i hoziaystvo im Kalenina Agriculture DDT TJ- Хозяйство им Х. Назарова - 8221 Hoziystvo im H. Nazarova Agriculture DDT TJ- Хозяйство им. К. Назарова - 8222 Hoziystvo im. K. Nazarova Agriculture DDT TJ- 8223 ЧП "Иттифок" - CP "Ittifok" Agriculture DDT Хозяйство им. TJ- Хубайдуллоева - hoziystvo 8256 im Hubaydulloeva Agriculture DDT TJ- Хозяйство им Мирзоматова 8257 - Hoziystvo im Mirzomatova Agriculture DDT 82 TJ- Хозяйство им. Р. Ходжиева - 8258 Hoziaystvo im R. Hojieva Agriculture DDT TJ- Хозяйство им. С. Айни - 8259 Hozaystvo im. A. Ayni Agriculture DDT TJ- 8260 АХД "Дусти" - AHD "Dusti" Agriculture DDT TJ- 8261 АХД Шухрат - AHD Shuhrat Agriculture DDT TJ- КАНЗ "Навруз" - KANZ 8262 "Navruz" Agriculture DDT TJ- 8263 АХД "Логин" - AHD "Login" Agriculture DDT TJ- 8264 АХД "Шарк" - AHD "Shark" Agriculture DDT 83 84