Pest Control and Responsibility

Published in Poisons Beware

After several years of research, we are still waiting for a responsible reaction to our concerns about the current national policy of pest control in Croatia.

The Teaching Institute for Public Health in the Split-Dalmatia County is responsible for the regulation and implementation of the pest control programme in the whole region. We received no reply to our letter of November 2017 detailing our concerns together with comprehensive evidence of the shortcomings of current practices (Croatian version here). Therefore we wrote again in January 2018, this time asking for answers to specific questions, under the Freedom of Information Law. You can read the original correspondence in Croatian here.
 
TRANSLATION OF OUR LETTER TO THE INSTITUTE OF PUBLIC HEALTH, 19TH JANUARY 2018:
 
Pitve 19.01.2018.
Mr.sc. Jasna Ninčević, dr.med.spec. epidemiolog
Nastavni zavod za javno zdravstvo, Splitsko-dalmatinske županije
21000 Split Vukovarska 46

Subject: Request for information in relation to insect and rat control on Hvar

Dear Madam,

In accordance with Article 18 of the Law on the Right to Information (N.N. 25/13), we request answers to the following questions:

1. Among the substances used for pest control on Hvar in 2017, some poisons were included which are not on the European approved list of pesticides, namely the insecticides permethrin, tetramethrin, azamethiphos, phenothrin, resmethrin, and the raticide brodifacoum.

What action are you taking to ensure that the poisons (pesticides and insecticides) used in the Republic of Croatia this year and in the future are in accordance with EU regulations?

2. In 2017, a cocktail of four poisons was used for the 'fogging' actions, consisting of three pyrethroids and an organophosphate*, of which three are not on the EU approved list. Further, such a combination is not justified by the manufacturers' instructions, nor through any scientific evidence.

Will the Institute ensure that such a cocktail is not used this year or in the future?

3. Among the substances listed for pest suppression on Hvar in 2017 was a raticide which is not on the Croatian list of approved poisons: bromadiolon (Ratimor) was banned in 2013.

Will the Institute ensure that from now on this raticide is not distributed to the general public, as it has been up to 2017?

4. Contrary to the Institute's own regulations, the raticide Ratimor has been delivered up to now in cellophane packages.

Will you ensure that from this year on, if raticide is still to be distributed to households, it is securely packed, and safe from children and pets - which would be in accordance with your own rules?

5. Up to now, the raticide has been distributed with the instructions inside the cellophane packet, and written only in Croatian.

Will you ensure that from this year on, if rat poison is distributed, that the warnings and instructions will not be in contact with the poison, and will be written in foreign languages (especially English and German), given that it is distributed to households belonging to foreigners?

6. Neonicotinoids were among the insecticides named for use on Hvar during 2017.

Were neonicotinoids applied on the island? If so, which ones, when, and where?

As certain neonicotinoids are already limited in the EU, and discussions on a further ban are in train, because of the known ill-effects of these poisons on bees and other beneficial insects, will you ensure that neonicotinoids are removed from the list of poisons used in the programme for pest control?

7. Was hot 'fogging' used on Hvar in 2017? If so, what substances were used, when and where?

8. What are the exact routes used for 'fogging' in Hvar Town and Stari Grad and their environs, and the Council areas of Jelsa and Sućuraj?

Will you ensure that from this year on the 'fogging' routes for each place are published in detail and on time (we recommend at least 7 days before the action)?

9. Where and when were larvicide actions carried out on Hvar in 2017, and which substances were used?

Will you ensure that from this year on the local population is fully informed on time of such actions?

10. Will you ensure that from this year on, warnings about pest control measures, especially the 'fogging' along public highways, will be better publicized through the media and on public noticeboards, and that the warnings will be in foreign languages as well as Croatian?

11. As poisons have been shown to be ineffective in controlling unwanted pests, and are known to cause great collateral damage, will you ensure that from this year on the use of poisons will be reduced, and other, better methods of protecting citizens from transmissible diseases will be investigated? This would be in accordance with the Law, and the Institute's own regulations.

12. For security and transparency, will you ensure that the overseer for pest control measures monitors the practices more efficiently in future, and that the report of the measures undertaken will be published and available for scrutiny?

Yours faithfully,


After some prompting, we received a reply from the Institute dated  April 12th 2018. It was depressingly short, two sentences which had no relevance at all to our two letters:

TRANSLATION OF THE REPLY FROM THE INSTITUTE, 12TH APRIL 2018:

In reply to your request for a response, we can briefly repeat what we said previously in reply to Jelsa Council's query about the Programme and Implementation Measures for the Compulsory Preventive Rat and Insect Suppression in the Jelsa area in 2017, that they were organised in accordance with the law and the current regulations. We have not observed any irregularities in the work of the contractor in the Jelsa area in 2017 which would be contrary to the Law or the Regulations, nor any significant deviation from the designated Plan and Programme in the contractor's implementation.  

Note: The letter which is referred to from the Jelsa Mayor was sent to the Institute on October 9th 2017: you can read the original in Croatian here.


Further correspondence: As the reply dated 12th April was inadequate, we sent a further request to the Institute on 16th April. As this too produced no result, we wrote again to the Institute, and informed the Commissioner of the Right to Information of the situation. The Commissioner wrote to the Institute three times, on May 9th, June 26th and August 9th, each time with a time limit for responding, Further official requests for information were sent on October 3rd 2018 and January 9th 2019.  

* Note: The information we received originally from the Jelsa Local Authority was not quite complete, and led to a misunderstanding on our part. The fogging was carried out in 2017 with a conbination of three pyrethroids, while the organophosphate was used in combination with a pyrethroid around the rubbish bins and dumps.


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