Eco Hvar

You can read the replies (in Croatian) from the Minister for Health, the State Secretary at the Ministry of Agriculture, and the Director at the Office for Public Health for the Split-Dalmatian County, alongside other responses. We are told that everything is being done according to Croatian law and Directives from the European Union and World Health Organisation, so why should we worry? Sadly, our experience and researches over the years have shown that there is good cause to worry. Pest control practices are urgently in need of change.

We are very grateful to our Jelsa Mayor, Nikša Peronja, and his Deputy, Vlatka Buj, for taking the trouble to write to the Regional Health Office for the Split-Dalmatia County (Nastavni zavod za javno zdravstvo Splitsko-dalmatinske županije), expressing our concerns. You can find the full text of the original in Croatian here.

It has taken several years to pin down the chain of responsibility for pest control practices, despite many letters to our local Council. Now we have it, more or less. The Law on the Prevention of Transmissible Diseases dictates that there must be a programme for insect suppression. At the top of the chain of responsibility is the Minister for Health (Ministarstvo zdravstva); the National Office for Public Health (Hrvatski zavod za javno zdravstvo) devolves the responsibility to the regional (Županijski) Offices for Public Health (Zavod za javno zdravstvo); each regional Health Office is responsible for issuing the current guidelines for implementing the pest control measures. The Health Office also carries out 'technical control', and subsequently provides a written report assessing the measures undertaken. Health inspectors are responsible for ensuring the rules are adhered to. Local authorities sign a contract with the Health Offices, and pay for their services. Based on the instructions from the Public Health Office, local authorities must agree an Implementation Plan in January each year, stating how they intend to carry out the compulsory programme; and they have to appoint a registered firm to carry out the measures.

In Jelsa, there is a local branch of the Regional Health Office in the Jelsa Clinic, with an epidemiologist who is in charge of the technical side of pest control measures. We have not been informed as to how 'technical control' is applied, in Jelsa or elsewhere. It is not clear to us where the local health inspectors are: in Hvar Town, or maybe Split? We have been told that when the fogging vehicle travels around the Jelsa region on summer nights, the local Town Warden (Komunalni redar) is on board. He informs Jelsa's Mayor directly and immediately, at any time of the night, if any part of the route has not been sprayed with insecticides. Although we have been given a certain amount of information about the practice of adult insect control, we have received none about the larvicidal practices, which officially spread over several months in the year.

In 2008, the Minister for Health, on the basis of the recommendations of the National Public Health Office, issued a 'Programme of Measures to Protect the Population from Transmissible Diseases using Pest Control, from 2008-2013' (Program mjera zaštite pučanstva od zaraznih bolesti -dezinfekcija, dezinsekcija i deratizacija - na području Republike Hrvatske od 2008. do 2013. godine), but it seems no recent update has been published on the internet as yet. Jelsa's 2011 Programme for Pest Control was published in the Council's Official Bulletin of 28th January 2011. Since then the Programme for each year has apparently been held in the Council's Archive. Hvar Town's 2017 Programme for Pest Control and the parallel Implementation Plan were published on the town's official website.  

The internet provides a lot of information about Croatian Laws and institutions. The website for the Ministry of Agriculture has a special search section where one can look up details of pesticides, and there is a separate list of those which are no longer approved in Croatia. However, although the information covers herbicides and raticides, we could not access insecticides. The approval status of pesticides within the European Union can be found on the European Commission database.

This is the English translation of the Mayor's letter, which was dated 8th October 2017:

1. "According to the Directive governing the implementation of compulsory disinfection, insect suppression and rodent elimination measures (NN 33/07), hereafter referred to as 'the Directive', the use of poisons (insecticides) is foreseen as an alternative means of insect suppression, if other methods have not produced positive results. However, in the current practice, poisons have become the FIRST AND ONLY choice.
2. The Directive decrees that poisons should be decreased every second year, in order to reduce collateral damage in the environment. From the information we have received, in this and previous years, we see that the number of poisons has increased each year, not reduced.
3. The insecticides used for 'fogging' are mixed into a cocktail consisting of ever-increasing poisons. The manufacturers of the poisons being used do not prescribe them for mixtures with other poisons, and one of the poisons used was not intended for outdoor use, nor is it permitted in the EU. The possible adverse effects of such cocktails is completely unknown, as they have never been tested.
4. The company which carries out the insect suppression measures does not issue adequate warnings of its actions to the public.
5. 'Fogging' is supposed to take place before dawn, but it is started much before, at 10pm.
6. The names of the substances used for 'fogging' are not made public.
7. Experience tells us and many others that using poisons, no matter how many, is not effective - on the contrary, insects quickly become resistant to the poisons and therefore multiply in ever-increasing numbers.
8. The Law for Protecting the Population Against Transmissible Diseases decrees that preventive measures shuld be taken against insects which TRANSMIT DISEASES. The Directive extended the target list by adding six more categories, including insects which cause allergies and pests which are undesirable for aesthetic or public health reasons. In this way, even bees were included among the target insects. Mass destruction causes imbalances in Nature, with immeasurable consequences for the environment, and ultimately for people."

Furthermore, ECO HVAR states that "it is obvious that the Directive is not formulated in accordance with the intentions of the basic Law, also in practice alternative ecological methods for insect control should be used, such as using natural substances for spraying, or making use of the insects' natural enemies, such as birds and bats."

The response from the Split-Dalmatian County Public Health Office you can find here (in Croatian). Dated 18th October 2017, it failed to address any of our concerns adequately. We at Eco Hvar therefore took the trouble to write again, this time directly, pointing out precisely and in detail the discrepancies between what the Law, Directive and the Public Health Office's own instructions say, and what happens in practice. You can read the full text of our letter (in Croatian) here. In support of the letter, which was dated and posted on 16th November 2017, we enclosed four of our articles in Croatian which provide yet more details of the law and directives governing pest control measures, and the way pest control is implemented on Hvar, especially in the Jelsa region. The English versions of those articles are: 'Insect spraying: pros and cons' 'Insect spraying: save the bees!', 'Insect spraying: the 'fogging' practice' and 'Insect spraying on Hvar 2017', which is included here.

Our letter itemized six major areas of concern:

1. Collateral damage caused by pesticides. The Croatian National Public Health Office has admitted that collateral damage to non-target insects is inevitable when adult insects are targeted with non-selective pest control measures, and that the damage undermines biodiversity. In practice, there has been a noticeable reduction in bird, bat and insect numbers over the years on Hvar.
2. Inefficacy of the system. The Split-Dalmatian Public Health Office has admitted that, although insect suppression measures have been used for some 20 years, the virulent tiger mosquitoes only appeared in the region some nine years ago, in 2008. It has also been admitted that measures such as 'fogging' against adult insect pests have a limited effect. Clearly, in our view, the measures are ineffective and have failed. This is not surprising, as it is well known that target insects can quickly become resistant to poisons. In several countries around the world researchers are reducing the use of chemical poisons and seeking alternative methods for controlling unwanted insects.
3. The substances used. The Split-Dalmatian Public Health Office has stated that the number of permitted insecticides is reduced each year, but that the substances used for 'fogging' are all authorized for use in Croatia. The law states that every second year the quantity of insecticides should be reduced for health reasons and to lessen the release of harmful substances in the environment. In practice, in our area the quantity of poisons used for 'fogging' has increased year on year. In 2017, a cocktail of three pyrethroids and an organophosphate was applied in the Jelsa area. Of the four poisons, three are no longer on the list of pesticides approved for use in the European Union. Of five pyrethroid poisons listed on the 'fogging' programme for Hvar Town, three were not allowable in the European Union. Who decides on poison mixtures and on what basis? Why are pesticides which are not approved in the EU allowed in Croatia?
4. The method of carrying out insect control. The Directives state that 'fogging' should be carried out for just a couple of hours at a time, around dawn, and that spraying should be suspended if the 'fogging' vehicle passes close to vegetable plots and beehives. In practice, the spraying is done overnight, usually between 10 pm and 6am, and is continuous, regardless of people, crops or property in the vicinity.
5. Education. Officially, by law, educating the population about measures which limit the rising numbers of unwanted insects such as mosquitoes is an important part of the insect control programme. In practice, there is very little evidence of this, at least on Hvar.
6. Illness prevention. According to the Split-Dalmatia County Public Health Office, the Croatian Ministry of Health and the National Public Health Office have decreed that there should be increased measures to suppress insects, in view of an increase in vector-borne diseases over the last few years. However, 0fficial figures fail to confirm any increase in these illnesses, which are much less significant than the major killers, namely cardiovascular, heart and lung problems, which in many cases are linked to poor lifestyle choices such as tobacco, alcohol abuse and an unhealthy diet. This raises the question of whether the current insect suppression measures are really necessary, especially given that they are both ineffective and harmful.

OUR CONCLUSIONS. We are calling for changes which are absolutely in keeping with the Law on the Protection of the Population Against Transmissible Diseases:

1. The reduction and eventual elimination of the use of chemical poisons: officials, whether individuals or groups, should be examining on a regular basis possible alternative means of insect control in the scientific literature and from the experiences of other countries.

2. Responsibility and transparency:

1. those who are responsible for overseeing the insect control measures as they happen should be fully informed about these measures, so that they can explain the details - and particularly the risks of any poisons used - to the authorities and citizens;
2. officials should check whether pesticides which are considered for use are on the approved lists of the European Union and the Republic of Croatia;
3. information relating to the substances approved for use should be given not just to institutions but to the public;
4. the official reports which follow the pest control measures should be made public;
5. warnings about impending insect control measures (both larvicide and adulticide) should be spread widely through all the available media, including the websites of the local authorities, social networks and local registered charities;
6. the warnings should give all the details of the substances to be used, the timing and locations of the actions, and the vehicle route in the case of 'fogging';
7. the warnings should be in foreign languages, not just Croatian.

3. Correction of the Directive: the Directive (NN 35/2007) should be revised to exclude from the compulsory programme some of the categories of target insects (which were not included within the original Law), namely 'those which transmit micro-organisms mechanically', 'body parasites', 'those which cause allergic reactions', 'those which are poisonous', and 'harmful insects significant for aesthetic or public health reasons'.

In view of the difficulty in obtaining positive responses at national and regional levels to our requests for information, we are all the more grateful to our local officials at the Jelsa Town Hall who have helped as much as they can over the years, especially Ivica Keršić, Director of the Jelsa Council Office, Ivan Grgičević, formerly Deputy Mayor, now Leader of the local Council, Vlatka Buj, current Deputy Mayor, and Mayor Nikša Peronja. Mayor Peronja has supported our other projects for protecting the environment, notably our campaign against chemical agricultural pesticides. We believe that Jelsa can set a strong example for improving environmental practices, which will benefit the community immeasurably, as well as enhancing the attractions of Hvar Island for visitors.

Humans are weaving a tangled web of problems arising from the overuse and careless use of synthetic pesticides of all kinds, regardless of the effects on human health and the environment. Nature will provide everything we need, if we let it, and use our natural resources wisely. We cannot better Nature: Nature does it best!

© Vivian Grisogono MA(Oxon) 2017