Several years of observation and research on Hvar and, to a lesser extent, on Brač and elsewhere, have revealed that Croatia's policy of mandatory pest suppression is deeply flawed and an ecological disaster. Many countries - but apparently not Croatia - have woken up to the fact that insect loss is a major disaster for the natural world, and a threat to human food sources. Tragically, at the end of 2019, it is clear that there is no national or local authority willing to accept responsibility and make the necessary changes which are becoming increasingly urgent. Our evidence is based on our experiences on Hvar, but it is clear that the problems extend nationwide.
What's the problem?
Answer in a nutshell: the routine, arbitrary spreading and spraying of insecticides around many parts of the country as a national policy. Added to the innumerable other pesticides used by local authorities and individuals, Our Beautiful Croatia is drowning in poisons! (You can see the extent of the specific pesticides used for the national programme on Hvar in 2017 and 2018 here; those used by individuals specifically on the UNESCO-listed Stari Grad Plain here; and a listing of pesticides, their potential harmful effects and authorization status here.)
Targeting arthropods with poisons has proved a failure all round the world. First, there is the problem of collateral damage to non-target arthropods, as no insecticides are wholly selective; second, natural predators of the target arthropods are reduced or even eliminated; third, target organisms invariably develop resistance, becoming stronger and more numerous. The laws governing arthropod suppression in Croatia theoretically take account of these problems, but in practice, to date, they have been ignored.
What are the laws?
(The laws are, of course, written in Croatian.) The original law, promulgated in 1992 after Croatia became an independent state, focussed on preventing the spread of infectious diseases. Certain arthropods which were known to transmit diseases were named as targets whose numbers needed to be controlled.
However, in the 1998 Directive (Pravilnik) regulating the implementation of the mandatory programme of disease and pest control arthropod suppression (dezinsekcija) was defined as measures to control not only the arthropods which cause diseases, but also those which could cause allergic reactions, could be toxic or which were a nuisance. In the revised Directive of 2007, six categories of unwanted arthropods were formally added in addition to the original criterion of 'disease-carriers'. In effect all insects became targets to be suppressed. Although such criteria as 'allergy-causing' or 'aesthetically unpleasing' obviously are not linked to infectious diseases, the law - confusingly - retained its title as 'The Law to Protect the Nation from Infectious Diseases' ('Zakon o zaštiti pučanstva od zaraznih bolesti').
The primary Law (last updated in 2017, NN 130/2017) and its related Directives are set out by the Ministry of Health (Ministarstvo zdravlja). Responsibility for implementing the law is delegated to the Croatian National Institute of Public Health, which in turn delegates the task to the regional Public Health Institutes. Details of how the Pest Control Programme should be constructed were set out specifically by the Ministry of Health in 2011 in a Programme of Measures (Program mjera - Suzbijanja patogenih mikoroorganizma, štetnih člankonožaca (arthropoda) i štetnih glodavaca čije je planirano, organizirano i sustavno suzbijanje mjerama dezinfekcije, dezinsekcije i deratizacije od javnozdrastvene važnosti za Republiku Hrvatsku, NN 128/2011). This document was amended and updated in 2018 (NN 62/2018).
Four levels of action are identified in the Programme: 'ordinary', 'special', 'safety / anti-epidemic', and 'others'. The last applies in the case of actual epidemics or natural disasters, while 'anti-epidemic' measures are instigated by the Minister of Health if there is a heightened risk of an epidemic according to the epidemiologists. 'Special' measures are used at the recommendation of the Regional Health Institutes, if there is a raised risk of transmissible diseases in buildings, boats or vehicles, and especially where food is prepared or stored. 'Ordinary' measures are applied across the board to include public buildings, schools, sports facilities, restaurants, cafes, shops, public spaces. The pest control measures for 'special' and 'ordinary' actions are essentially the same.
Local authorities sign a contract annually with the Regional Health Institute for their expert supervision of the pest control programme (Ugovor o stručnom nadzoru nad provedbom mjera obvezatne (preventivne) dezinsekcije i deratizacije), after which the Health Institute prepares two documents, a 'Programme of Measures' (Program mjera obvezatne preventivne dezinfekcije, dezinsekcije i deratizacije) and a 'Directive for Implementation' (Provedbeni plan obvezatne preventivne dezinfekcije, dezinsekcije i deratizacije) which are approved by the County Governor (Župan) and sent to local authorities as mandatory guidelines for implementing the pest control programme.
Once the documents and financial commitments are accepted by the local Councils (Vijeća), the local authorities have to select a firm by tender to carry out the measures, and a contract is signed between them. In practice, in many places, including Hvar, all these formalities happen by rote. There is little change from year to year, and the implementation of the pest control programme has been totally unsatisfactory, as you can read here.
Monitoring: a Vital Missing Factor
In its Strategic Programme for 2008 - 2013 the Ministry of Health set out details for nationwide monitoring of mosquitoes, and the need to monitor the results of pest control measures was included in Article 3 in the 2007 and 2012 Directives (NN 35/2007, NN 76/2012). Responsibility for monitoring was devolved to the Regional Health Institutes, which were required to submit their findings to the National Institute of Health. However, it took until 2016 for a national programme of monitoring invasive species of mosquitoes to be initiated by the National Institute of Health. The stated intention was to put all the collected data into a national database, but at the end of 2019, no information about the database was available.
Of the 50-odd species of mosquito identified in Croatia, the main target for suppression is the Asian tiger mosquito (aedes albopictus), which is a known potential vector for Dengue fever, chikungunya virus and dirofilariasis. The monitoring carried out in 2017 in Zagreb, Pula, Split, Rijeka and Osijek revealed that tiger mosquitoes were present in all counties except Požega-Slavonia (which did not participate in the investigation) and Virovitica-Podravina (which did). In the initial report from 2016 (in Croatian), a second invasive species of mosquito was recorded, the East Asian bush or rock pool mosquito (aedes japonicus japonicus), which is not considered a definite vector for disease transmission. By the time of the 2017 report (in Croatian), this mosquito had spread across a wider territory.
In the 2018 Amendments to the National Programme (NN 62/2018), in Section III under the sub-clause 'Current situation and priorities' (2.1.4), the three existing items were amended in the light of the 2016 and 2017 monitoring reports, and eight new items were added, emphasizing in particular the importance of detailed national monitoring and recording of mosquito types, numbers and their associated risks of spreading diseases. The National Institute of Health has to draw up a Protocol each year detailing the materials and methods needed for the monitoring, including a list of entomological centres specialized in mosquito identification and another of laboratories specialized in identifying any viruses present in the mosquitoes. The new Programme makes it clear that monitoring is the basis for establishing effective preventive actions, and for evaluating their results.
Distorted, mistaken practices
The Law and all the Directives have always stated clearly that pesticide use has limited value, and that other methods of prevention should be used in preference. In practice, up to the present time at the end of 2019, pesticides have been the first and only means used to carry out the annual arthropod suppression programme. Educating the population about preventive methods was and is a legal requirement, but it hasn't happened at a realistic level, certainly not on Hvar. Widespread warnings were and are supposed to be given via all the public media channels before the general street spraying ('fogging'), but they haven't happened either. Despite repeated requests, we have been unable to obtain details of the route the 'fogging' vehicle takes round each locality on Hvar every summer. Details of the pesticides used and their possible ill-effects have never been advertised.
'Fogging' is done several times during the summer season: this should happen only around dawn according to the Directives. In the 2018 Amended National Programme ((NN 62/2018) the optimum times are given as an hour or two at dawn and the same at twilight (Heading III, item 4.3.2.). In practice it has run throughout the night in most places. Fields and kitchen gardens with ripening fruits and vegetables are not supposed to be sprayed, but on Hvar they have been. People have been sprayed too: those sleeping in bedrooms or on terraces alongside alleyways and roads; those out and about enjoying the warm night air, for instance sitting on the benches outside Jelsa's Town Hall; and those driving behind the 'fogging' vehicle. Without due warnings of the route and timing of the spraying, people are easily caught up in it.
Reports supplied by the Split-Dalmatia Institute of Public Health reveal that the surface areas sprayed with pesticides in the 2017 and 2018 'fogging' actions on Hvar often amounted to more than 2 litres per hectare, whereas the 2018 Amended National Programme states the amount should be between 0.5 and 1litre per hectare (NN 62/2018, Heading VII, 1.4.8.2.).
All the insecticides used for larvicide and adulticide actions are harmful. Some of the insecticides used are not approved for use in the European Union, for instance Tetramethrin, one of the active ingredients in the product Permex 22E which is commonly used for 'fogging' on Hvar. Muhomor (active ingredient Azamethiphos) is not even approved in Croatia, yet it has been used routinely against flies on Hvar over these last few years. Some of the poisons used, apart from being banned, are known to pose the risk of cancers in humans, especially Permethrin, which has been used for aerial spraying as well as from road vehicles. For instance, Neopitroid Premium, a toxic cocktail of Permethrin, d-Allethrin and Piperonyl Butoxide mixed in diesel, was used in 2014 for aerial insecticide spraying over three localities in the Vukovar-Srijem County. In the 2018 Amended National Programme the use of fuel as a mixer was banned, with only mineral oil or 'some other ecologically acceptable' alternative being allowed ((NN 62/2018, Heading VII 1.4.8.2.). D-allethrin is not on the ECHA list of approved substances, although it is under review in 2019; Neopitroid Premium is not on the lists of ECHA or Croatian approved products. The Technical Safety Document issued by the company Genera for the product states that it "could be fatal if ingested or inhaled" (in Croatian). Yet Neopitroid Premium was used in 2019 around Osijek and surrounding areas, including Đakovo (articles in Croatian) from aeroplanes and road vehicles. In the Osijek-Baranja County, detailed monitoring was in effect by 2019, with results at the end of October 2019 showing that suppression measures were not needed at this time. Obviously the poison spraying had achieved the aim of suppressing the mosquitoes, but it is well known that this is only a temporary effect, and that it will have done nothing to prevent the spread and increase of the target insects.
Aerial spraying is only allowed as an exceptional measure under the law (NN 76/2012, Article 14), but it has been carried out relatively frequently in the northern regions of Croatia, for instance in the Borovo Council region in the Vukovar-Srijem County (article in Croatian) in 2016, besides the example already cited. There have been threats of fines for local authorities which do not carry out insect suppression measures. These have almost certainly exacerbated the problerms of excessive poison use.
Apart from the risks to human health, there are the animals which might be roaming at night, such as cats, for whom these insecticides can be fatal, and dogs, which are probably also at risk. Bacillus Thuringiensis Israelensis (Bti) has been used on a large scale as a larvicide, and has been sprayed annually over 3 hectares of woodland around Hvar Town against the pine processionary moth caterpillar. It was thought to be harmless, and is still described as such in the annual Health Institute Directives, despite the fact that research has shown that it may cause loss of biodiversity (2000) and can interfere with bird reproduction (2010). Larvicides also do away with natural predators, such as dragonfly larvae which are voracious devourers of mosquito larvae.
The annual contract for 'expert supervision' on the part of the Health Institute has always included a commitment to supervise the practice of the pest control measures and produce an evaluation of the completed measures in the form of a written report. In practice, on Hvar at least, there has been no realistic supervision and no attempt at an evaluation of outcomes. The report has been just a rubber-stamped reiteration of the account submitted by the commercial firms engaged to carry out the measures. Every report has invariably concluded that the measures have been carried out 'in accordance with the important regulations'. So, are some of the rules in the copious regulatory documents unimportant?
Is there hope for the future?
It is all too clear that the legal provisions for safeguarding people, animals, wildlife and the environment with all its trillions of essential organisms have been ignored in favour of the simple solution of delegating the job of arthropod suppression to commercial firms. They have been let loose with pesticides, some of which are banned in Europe, apparently without due control either from the local Councils that engage them, or the Regional Health Institute which is responsible for the regulations. It is disheartening that our warnings that the programme is being implemented in a way which is potentially damaging to humans and disastrous for the environment have fallen on deaf ears.
Several years of the Pest Control Programme have failed to prevent the intrusion and spread of new potentially harmful mosquitoes, as is obvious even from the limited monitoring carried out in 2016 and 2017. Not only has the Programme failed to achieve its stated purpose, but it is causing untold collateral damage, especially in Dalmatia, notably in the visible reduction in beneficial insects, pollinators, bats and birds. Nature lovers have already noticed the damage and are turning away from visiting Croatia. This does not bode well for Croatia's aspirations to 'quality tourism', in which 'unspoilt natural beauty' plays a big part.
The purpose of the Programme is questionable. Despite the increased spread of mosquitoes, there has been no major outbreak of mosquito-borne diseases, the worst being in 2018, with 63 or 64 cases of West Nile Fever. One elderly gentleman, who also had heart problems and various other medical conditions, died during the outbreak (article in Croatian). To put this into perspective, circulatory problems caused the most deaths (23,048) in Croatia in 2018, as in previous years, and, together with 14,210 deaths from neoplasms (cancers), accounted for three quarters of Croatian deaths in that year (Croatian Health Statistics Year Book 2018, web edition in English and Croatian, p.30).
The Croatian public has been kept largely in ignorance of the Pest Control Programme, which in its current form is a project of mass destruction. All residents in Croatia who pay local taxes and dues provide the finance for it, but very few people have any understanding about what is done and what it means for Croatia's environment. Such information as is put into the public domain is misleadingly reassuring. Being told that mosquitoes are being sprayed with pesticides which are 'harmless to warm-blooded creatures' sounds reasonable and even desirable. The reality is neither reassuring nor appealing. The stark truth is that every year, especially on the Croatian coast, local people, thousands of visitors, and the exquisite environment are showered with highly toxic substances without due warning or explanation, and with little, if any information about the possible dangers to the health of humans, animals, wildlife and the environment. This is hardly material for the tourist brochures, neither is it acceptable to local populations. Public health is arguably at much greater risk from the accumulation of poisons in the environment than from insects.
A sustainable future depends on change.
What needs to happen?
The solution to the current problems is not to keep hiding the truth in the hope that people won't notice, but to change the practices:
1. revise Directive (NN 76/12) Clause 2 Article 10, to exclude items 2-7, which make allinsects possible targets for suppression; this would revert to the intentions of the original Law (NN 60/92);
2. reduce pesticide use to a minimum, and advertise any 'fogging' and larvicide actions openly, clearly and transparently, with proper warnings in other languages besides Croatian;
3. publish the details of which poisons are to be used across public areas, together with their possible ill-effects, based on current scientific knowledge;
4. publish the exact route of the 'fogging' vehicle;
5. all chemical poisons authorized and recommended for use in Croatia should be clearly identified together with their possible ill-effects in every type of information service and in all places where they are sold;
6. identify, promote and use better, environmentally acceptable methods of suppressing unwanted 'pests'.
Change is possible.
In accordance with the 2018 Amended National Programme, the Department responsible for infection and pest control within the Osijek-Baranja County Institute of Public Health provides the public and media with accessible educational material about dealing with mosquitoes, including alternative methods to poisons (all in Croatian).
The emphasis is on disease prevention through adequate precautionary measures which do not depend on poisons. Sadly it is obvious from the examples cited above that the Osijek-Baranja County still relies on poisons to solve the ever-increasing problem of troublesome mosquitoes, despite the fine words and apparent good intentions published by the Regional Institute of Health. Let's hope that the alternatives really are put into practice, and that other Counties follow this example - as a matter of URGENCY! because once beneficial species of insects or any other creatures are lost, it's too late.
© Vivian Grisogono 2019.
