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. The routine, repeated, arbitrary spreading and spraying of poisonous chemical insecticides around many parts of the country, is carried out largely without proper control or assessment of the consequences. Added to the innumerable other pesticides used by local authorities and individuals, Our Beautiful Croatia is drowning in poisons!
Programme failures: chemical pesticides, not the answer
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 of writing in 2023, 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.
Targeting arthropods with poisons has proved a failure all round the world. Reasons why:
1. collateral damage to non-target arthropods, as no insecticides are wholly selective;
2. natural predators of the target arthropods are reduced or even eliminated;
3. target organisms invariably develop resistance, becoming stronger and more numerous;
4. the insecticides used can also be harmful to humans and animals.
The laws governing arthropod suppression in Croatia theoretically take account of these problems, but in practice, to date, precautions have not been implemented. Tragically, to date 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 obviously the problems extend nationwide.
Programme failure: more mosquitoes, less biodiversity
Many countries - but apparently not Croatia - have woken up to the fact that insect loss is a major catastrophe for the natural world, and a threat to human food sources. One factor that is never mentioned in this context is the role of mosquitoes in the natural chain, most notably as night-time pollinators. Killing the mosquitoes with poisons has inevitably led to the loss of bees, with increasing consequences for the pollination which is vital for plants.
Several years of the Pest Control Programme have failed to prevent the intrusion and spread of new potentially harmful mosquitoes, as is obvious from the monitoring which has been carried out. 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.
Insect suppression: why?
The purpose of the Programme is questionable. Despite the increased spread of mosquitoes over the years, 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 of the four reported deaths was an elderly gentleman, who also had heart problems and various other medical conditions, who died during the outbreak (article in Croatian). In 2017 there had been just 8, and in 2019 there were no recorded cases of West Nile Fever (Croatian Health Statistics Yearbook 2019, p.175.) also none in 2020. There were no cases of Dengue Fever in 2017, 2 in 2018, 5 (all imported - Yearbook 2019, p.190) in 2019, and 3 in 2020.. For Malaria there were 10 recorded cases in 2017, 2 in 2018, 4 in 2019 and 5 in 2020. The figures for malaria from 2007 to 2019 show a fairly wide variation, making it difficult to argue that the insect suppression programme is influencing the number of cases (Croatian Health Statistics Yearbook 2019, p.175.). To put these figures 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). See also the tables of illnesses in the HZJZ Yearbook for 2020 (in Croatian), where the figures for infectious diseases are given in item 5 'Zarazne bolesti u Hrvatskoj'.
Programme failure: no warnings, no transparency
According to European directives, EU citizens have the right to know which poisons they are exposed to (Regulation (EC) No 1907/2006 Introduction. clause 117).
Widespread warnings 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 over several years, we have been unable to obtain details of the route the 'fogging' vehicle takes round each locality on Hvar every summer. Details of the chemical pesticides used and their possible ill-effects have never been made public. We have found out the names of the pesticides through the legal Right to Information / Pravo na pristup informacijama, law in Croatian). The possible adverse effects of the poisons are not made public by the authorities or the manufacturers and vendors of chemical pesticides.
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.
Programme failure: safety measures inadequate, not implemented
'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 this has hppened routinely. 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.
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 toxic chemical pesticides, apparently without due control either from the local Councils that engage them, or the Regional Health Institute which is responsible for the regulations.
Programme failure: collateral damage risks ignored or underestimated
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, but 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. Bee losses are almost certainly under-reported, but they are equally certainly happening. for instance in 2021, a professional beekeeper on Hvar lost his hives in the aftermath of a fogging action, while in 2023, catastrophic bee losses were reported following aerial spraying, near Osijek in Slavonija.
Programme failure: biocides used inappropriately
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 poisons used 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 was listed as not approved by the ECHA in 2023. Neopitroid Premium is not on the list of ECHA approved biocidal products, although, with Prallethrin as one of its active ingredients, Neopitroid Premium Plus is on the August 2022 list compiled by the Croatian Ministry of Health ( Registar biocidnih pripravaka ). Prallethrin was still under review for approval by the ECHA in July 2023. The Technical Safety Document issued by the company Genera for Neopitroid Premium (30.05.2020) states that it "can 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, and for fogging around Grad Glina in 2021.
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, and around the Vukovar region in June 2023, besides the examples already cited. There have even been threats of fines for local authorities which do not carry out insect suppression measures with pesticides. These have almost certainly exacerbated the problerms of excessive poison use.
Some of the biocidal substances used for fogging are banned from being sprayed over crops, to prevent them from entering the food chain. As the blanket spraying of the environment means that fields and kitchen gardens along the fogging routes are dowsed in the poisons, there is a real danger that they can enter the food chain. In particular, Cypermethrin-based insecticides have been used on Hvar in recent years, although the EU only allowed their use as 'plant protection products' on condition that they were not used when plants including weeds are in flower, because of the unacceptable risk to bees. Obviously, pesticides which are banned for use onflowering plants are not to be used for blanket spraying of the environment during the flowering season!
Pest suppression, 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').
Delegated responsibilities
The primary Law has been updated and amended over the years: (NN 79/07, 113/08, 43/09, 130/17, 114/18, 47/20, 134/20, 143/21). The law and its related Directives are set out by the Ministry of Health (Ministarstvo zdravstva). 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 javnozdravstvene važnosti za Republiku Hrvatsku, NN 128/2011). This document was amended and updated in 2018 (NN 62/2018).
Prescribed levels of action
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.
The Bench, a favourite meeting place in Jelsa, in direct line for the 'fogging'
Local authorities: contracts, payments, but limited control
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.
Note: on Hvar and other islands, each local authority pays separately for the two documents from the Health Institute, although much of the text is produced by copy-paste each year and each island could anyway be covered by a single set, reducing the cost to the taxpayers.
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 on Hvar, all these formalities happen by rote, with little change from year to year.
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 visible realistic supervision and no attempt at an evaluation of outcomes. The report each year 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?
Monitoring: a Vital 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 as at July 2023, no information about the proposed database was publicly available. Without local input, the national database cannot come into being and the situation does not look like changing any time soon.
Targets
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.
Intentions
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 was 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 made it clear that monitoring is the basis for establishing effective preventive actions, and for evaluating their results.
Responsibility for monitoring mosquito infestations was delegated to local authorities. For instance, in the Regional Health Institute's 2018 'Programme of Measures' it was recommended that the Jelsa local authority should set up or organize a database detailing mosquito infestation sites - if possible. The database would be owned by the Jelsa authority, which would update the data collected annually and make it available to the Health Institute. As this suggestion was repeated each year up to the 2023 'Programme of Measures', it was obviously not taken up by the Jelsa authority.
Meanwhile, local authorities and organizations in other parts of the country have been undertaking monitoring. For instance, the special Centre for Invasive Species in Poreč and Istria organized monitoring of invasive mosquitoes in June 2018, with the aim of making suppression measures more efficient, also teaching the local population how to prevent infestations. It seems that the project was a one-off, as the information was not updated, according to the 2023 listing of the Institute's projects.
In 2022, various local authorities reported on the need for monitoring, such as the Osijek-Baranja County and the Dubrovnik-Neretva Countty Public Health Authority. Some areas, especially in northern Croatia, have monitored mosquitoes each year, and planned suppression measures accordingly. The Vukovar-Srijem County published the results of its monitoring (in Croatian) during 2022: the report stated that there were very few mosquitoes in the region in that year, and this was put down to the extremely dry weather and the lack of flooding from the Dunav and Sava rivers. In 2023, monitoring was carried out in the Slavonski Brod region, followed by insect suppression measures which were carried out not only on land using a 'fogging' vehicle, but also from the air around Osijek and its surrounding settlements on 22nd and 23rd May 2023. The authorities even claimed that they would be justified in spraying the neighbouring Kopački Rit, although it was outside their boundary.
The search for better alternatives
The monitoring figures are proof that the annual use of chemical pesticides against 'flying insects', which began years before those reports, is failing to prevent the spread of existing mosquito species or the influx of new invasive species across the country. Claims that the insect suppression programme is keeping mosquito-borne diseases at bay in the country are unfounded.
Introducing the 'SIT' programme to Croatia
In July 2022, the Croatian National Institute for Health announced a pilot project to introduce sterile male mosquitoes into the environment in the village of Premantura (Medulin Municipality), in association with the Teaching Institute for Public Health (Istria County) and the Biology Department of the J.J.Strossmayer University, Osijek. The concept is known as 'Sterile Insect Technique'. The International Atomic Energy Agency, which helped to finance the project, describes the technique as "an environmentally-friendly insect pest control method involving the mass-rearing and sterilization, using radiation, of a target pest, followed by the systematic area-wide release of the sterile males by air over defined areas, where they mate with wild females resulting in no offspring and a declining pest population." In June 2023, Zagreb announced it was releasing 100,000 sterile mosquitoes into the environment, with an accompanying video showing the release operation. The mosquitoes were released in the Cvjetno naselje, near the River Sava . In Pula, 1,200,000 sterile mosquitoes were to be released over a three-month period. The plan in June 2023 was for Pula to set up its own factory producing sterile mosquitoes, after two years of importing them from Bologna in Italy (report in Croatian).
Still experimental
Although the Sterile Insect Technique has been in use on different targets since the 1950s, the details for targeting each type of insect are not the same. Sterilization of mosquitoes is done by gamma-ray or X-ray irradiation. According to research being done in the United States, the sterilization techniques were still being improved in 2023 (Entomology Today, July 2023; article in the Journal of Medical Entomology, published 21 June 2023).
Possible 'flies in the ointment'?
It is said the irradiated mosquitoes, like the normal males, will not bite humans. However, the impregnated females presumably will. Do we know what changes there might be within the females as a result of the irradiated sterilization process? Could there be a harmful knock-on effect when a human gets bitten?
Will SIT achieve the aims and solve the problem of disease-carrying mosquitoes? Time will tell.
MEANWHILE, 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 made all insects possible targets for suppression; this would revert to the intentions of the original Law (NN 60/92); [Note: the law on protecting the population from infectious illnesses was revised at the end of 2021 (NN143/21 - in Croatian), in force from 25.12.2021]
2. identify, promote and use better, environmentally acceptable methods of suppressing unwanted 'pests', in particular by restoring and encouraging their natural predators;
3. enforce adequate monitoring of the presence of mosquitoes, in accordance with the provisions of the Health Authority's Action Plan for Insect Suppression;
4. end non-selective, blanket spraying of the environment with insecticides of any kind;
5. reduce chemical pesticide use to a minimum;
6. publish the details of any poisons which are to be used across public areas, together with their possible ill-effects, based on independent current scientific knowledge;
7. advertise any 'fogging' and larvicide land-based or aerial actions openly, clearly and transparently, with proper warnings in other languages besides Croatian;
8. publish the exact routes of the 'fogging' vehicles or aeroplanes, and their timing;
9. identify all chemical poisons authorized and recommended for use in Croatia together with their possible ill-effects in every type of information service and in all places where they are sold;
10. the Ministry of Health should create an accessible updatable database of biocides approved for use in Croatia.
Is there hope for the future?
A sustainable future depends on change.
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 once provided the public and media with accessible educational material about dealing with mosquitoes, emphasiting alternative methods to poisons (all links in Croatian).
It's a pity not to put this into practice. The emphasis on disease prevention through adequate precautionary measures which do not depend on poisons is the model that needs to be followed - as a matter of URGENCY! because once beneficial species of insects or any other creatures are lost, it's too late.
© Vivian Grisogono MA(Oxon) 2019, updated July 2023
