It's now up to governments, national and local responsible authorities and above all individual citizens to take action. These are our suggestions to the Croatian and EU authorities.
IT IS VITAL THAT ALL THE RELEVANT MINISTRIES AND NATIONAL INSTITUTIONS SHOULD ACT ACCORDING TO THE PRECAUTIONARY PRINCIPLE, WHICH IS FUNDAMENTAL TO EUROPEAN UNION LAW and THE HUMAN RIGHT TO A CLEAN, HEALTHY AND SUSTAINABLE ENVIRONMENT ADOPTED BY THE UNITED NATIONS HUMAN RIGHTS COUNCIL ON OCTOBER 21st 2021
WHAT WE ASK OF HVAR’S LOCAL AUTHORITIES
CHEMICAL PESTICIDES ARE CAUSING UNTOLD DAMAGE ON HVAR, HARMING HUMAN HEALTH, WILDLIFE AND THE ENVIRONMENT. THIS IS ALSO HAVING A BAD IMPACT ON TOURISM. A BIG PART OF THE PROBLEM IS THE PEST CONTROL PROGRAMME, WHICH LOCAL AUTHORITIES ARE RESPONSIBLE FOR, FOLLOWING THE DIRECTIVES FROM THE NATIONAL AND REGIONAL HEALTH INSTITUTES. THE ROUTINE COSTS ARE COVERED FROM LOCAL REVENUES. OVER MANY YEARS, THE ACTIONS HAVE PROVED UNSATISFACTORY IN PRACTICE.
Therefore we recommend:
1. environmentally friendly methods of agriculture and pest suppression should be encouraged, chemical pesticide use should be discouraged;
2. ecological measures for pest suppression should be used instead of relying solely on chemical pesticides;
3. there should be more public education about the adverse effects of pesticides and the better, environmentally-friendly methods for protecting people and the environment from unwanted pests such as mosquitoes and unwanted plants / weeds;
4. the Health Institute’s two documents (the Programme and Implementation Plan for Pest Suppression) should cover the whole of Hvar island with the cost shared between each of the four local authorities, instead of each paying separately for the same information;
5. monitoring of the target pests should be the compulsory basis of all pest suppression measures, and the results of the monitoring before and after such measures should be recorded and made available to the public;
6. blanket fogging actions should be avoided because of the risks to bees and people, especially people with certain health problems;
7. if blanket fogging is planned, the exact route and timing should be publicized;
8. biocides which have been banned by the EU as ‘plant protection products’ because they are proven to be dangerous for the environment, especially for aquatic organisms and bees, should not be used for insect suppression outdoors, especially not in blanket fogging actions;
9. all pest suppression actions, especially fogging, should be carried out strictly according to the relevant legal regulations and by-laws;
10. the public should be informed in advance in Croatian and other languages of planned insect suppression measures (larvicide and adulticide), using not only public announcements but also the same channels (post and email) used by local authorities to send out bills;
11. if biocides are to be used, they should be named, together with their possible adverse effects;
12. beekeeping organizations at national and local level should be informed in advance of all insect suppression actions everywhere in Croatia;
13. raticides should only be distributed on request, and a record should be kept of the recipients;
14. raticides should be used within secure applicators with access just big enough for mice or rats, to protect people, especially children, and other non-target animals, especially pets;
15. the raticide applicators should be collected after use by the company which distributes them;
16. all chemical pesticide packaging should be disposed of responsibly at designated collection points.
WHAT WE ASK OF THE CROATIAN NATIONAL AND REGIONAL HEALTH INSTITUTES
THE NATIONAL AND REGIONAL HEALTH INSTITUTES ARE RESPONSIBLE FOR THE PLANNING AND IMPLEMENTATION OF MEASURES RELATING TO THE LAW CONCERNING PROTECTING THE POPULATION AGAINST TRANSMISSIBLE DISEASES (NN 143/21 čl.5, law in Croatian). MEASURES LAID DOWN BY THE HEALTH INSTITUTES ARE PROVING UNSATISFACTORY IN PRACTICE. THEREFORE WE RECOMMEND:
1. risk assessments should be the basis for instigating preventive measures such as pest suppression, in particular the actual risk of specific diseases, as well as the risk of collateral damage if chemical pesticides are to be used;
2. all pest suppression actions, especially fogging, should be carried out strictly according to the relevant legal regulations and by-laws:
3. monitoring of target pests should be the compulsory basis of all pest suppression measures, and the results of the monitoring before and after such measures should be recorded and made available to the public;
4. ecological measures for pest suppression should be used instead of relying solely on chemical pesticides;
5. biocides which have been banned by the EU as ‘plant protection products’ because they are proven to be dangerous for the environment, especially for aquatic organisms and bees, should not be used for insect suppression, especially not in fogging actions;
6. the public should be informed in advance of planned insect suppression measures, using public announcements and also the same channels used by local authorities to send out bills;
7. the biocides to be used should be named, together with their possible adverse effects;
8. beekeeping organizations at national and local level should be informed in advance of all insect suppression actions everywhere in Croatia;
9. blanket fogging actions should be avoided because of the risks to bees and people, especially people with certain health problems;
10. if blanket fogging is planned, the exact route and timing should be publicized;
11. if people complain about mosquitoes, they should be given educational leaflets about how to protect themselves and their environment, also about the collateral damage caused by chemical pesticides;
12. raticides should only be distributed on request, and a record should be kept of the recipients;
13. raticides should be used within secure containers, which should be collected after use;
14. all pest suppression actions should be closely controlled by the Health Institutes;
15. the Health Institute reports following the actions should not just rubber-stamp information from the implementing companies, but should be based on observation on the ground.
WHAT WE ASK OF THE CROATIAN MINISTRY OF HEALTH
IN RELATION TO THE LAW CONCERNING PROTECTING THE POPULATION AGAINST TRANSMISSIBLE DISEASES (NN 143/21 law in Croatian) WE RECOMMEND:
1. consistent coordination between the Ministry of Health and the Ministry of Agriculture, in particular in order to avoid using biocides for insect suppression which have been banned by the EU as ‘plant protection products’ because they are proven to be dangerous for the environment, especially for aquatic organisms and bees;
2. the list of approved biocides on the Ministry website should be a detailed database which is updated regularly, like the Phytosanitary Information System list of approved pesticides on the Ministry of Agriculture website;
3. that all insect suppression actions, especially fogging, should be carried out strictly according to the relevant legal regulations and by-laws;
4. that the results of monitoring should be the sole basis of any and all actions for suppressing mosquitoes;
5. that publicizing all the possible adverse effects of biocidal products should be made compulsory;
6. that testing for the presence of pesticides should be an integral part of all systematic preventive health check-ups.
WHAT WE ASK OF THE CROATIAN MINISTRY OF AGRICULTURE
We recommend:
1. the Ministry should press for risks to bees to be added to the primary hazard warnings for pesticide labelling in the listings issued by the United Nations and the European Union;
2. all information and recommendations regarding chemical 'plant protection products' should always list in full the possible adverse effects and collateral damage they can cause:
3. possible adverse effects of so-called 'plant protection products' should be the first part of the information given on the Phytosanitary Information System (FIS) listing of approved substances and products;
4. organic agricultural methods should be given priority in the Ministry's regular expert technical advice bulletins for farmers;
5. agriculture based on alternative methods other than chemical pesticide and fertilizer use should be a major focus in the education of agronomists;
6. organic agricultural methods should be prioritized and promoted with a raft of incentives, as the best way to preserve Croatia's natural environment and improve public health;
7. chemical pesticides should not be the primary recommendation issued by the Ministry for dealing with pests or other hazards in agriculture;
8. controlled disposal of chemical pesticide packaging and obsolete pesticides should be made more publicly accessible in all parts of Croatia and should be subject to stricter monitoring;
9. the Ministry of Agriculture in collaboration with the Ministry of Health should initiate and support more research into the possible ill-effects of combinations of chemical pesticides on the environment and human health;
10. chemical substances used at each stage of agricultural production, from seed to finished produce, should be logged and listed when the produce is placed on the market, in accordance with the European Commission's stated safety aims;
11. the Ministry should help to ensure that any advertisements for pesticide products in any media should conform to the rules laid down in Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008, Title VII, Article 48:
12. the Ministry of Agriculture in collaboration with the Ministry of Health should press the European Commission to end the distinction between 'plant protection products' and biocides, in order to put an end to the unacceptable use of biocides for general outdoor insect suppression which have been banned by the EU as ‘plant protection products’ because they are too dangerous for the environment, especially for aquatic organisms and bees.
We recommend that the following factors should be taken into account, honoured and enacted:
1. Pesticide authorizations should be based on independent research published in peer-reviewed journals, not just on industry-funded unpublished studies as at present;
2. substances already in use which have been proven to be harmful to humans, animals, wildlife and/or the environment should be banned without delay, i.e. withdrawn from the market with immediate effect without any grace period for using up stocks, and any stocks held by end-users should be collected for appropriate safe disposal;
3. risks to bees should be included among the primary hazard warnings in pesticide labelling;
4. all the possible adverse effects of individual pesticides should be clearly stated and prioritized over suggested uses for the substances, a) on the pesticide product packaging, b) in any related product advertising, c) on treated end-products to include every part of the production process (eg from seed treatments to treated packaging);
5. the distinction between biocides and ‘plant protection products’ should be abolished: at the least substances banned or limited in one category should also be banned or limited in the other;
6. the policy of allowing ‘candidates for substitution’ to continue to be used despite having been shown to be harmful should be abolished and replaced by an immediate ban;
7. re-evaluation of authorized pesticide substances should begin long enough before the expiry date to be completed in time: the practice of granting automatic extensions if the Member State rapporteur fails to conclude the process by the due date should be abolished: substances should be banned until the re-evaluation processes are concluded;
8. the will of EU citizens regarding pesticide use as expressed in European Citizen Initiatives such as ‘Ban glyphosate and protect people and the environment from toxic pesticides’ (2017) and ‘Save Bees and Farmers’ (2023) should be taken into account, fully respected and enacted;
9. regular testing of people and the environment for chemical pesticide contamination in Member States, together with publication of the results, should be a mandatory component underpinning the award and retraction of authorizations.
WHAT WE ASK OF THE EUROPEAN DECISION-MAKERS
We recommend that the following factors should be taken into account, honoured and enacted:
1. Pesticide authorizations should be based on independent research published in peer-reviewed journals, not just on industry-funded unpublished studies as at present;
2. substances already in use which have been proven to be harmful to humans, animals, wildlife and/or the environment should be banned without delay, i.e. withdrawn from the market with immediate effect without any grace period for using up stocks, and any stocks held by end-users should be collected for appropriate safe disposal;
3. risks to bees should be included among the primary hazard warnings in pesticide labelling;
4. all the possible adverse effects of individual pesticides should be clearly stated and prioritized over suggested uses for the substances, a) on the pesticide product packaging, b) in any related product advertising, c) on treated end-products to include every part of the production process (eg from seed treatments to treated packaging);
5. the distinction between biocides and ‘plant protection products’ should be abolished: at the least substances banned or limited in one category should also be banned or limited in the other;
6. the policy of allowing ‘candidates for substitution’ to continue to be used despite having been shown to be harmful should be abolished and replaced by an immediate ban;
7. re-evaluation of authorized pesticide substances should begin long enough before the expiry date to be completed in time: the practice of granting automatic extensions if the Member State rapporteur fails to conclude the process by the due date should be abolished: substances should be banned until the re-evaluation processes are concluded;
8. the will of EU citizens regarding pesticide use as expressed in European Citizen Initiatives such as ‘Ban glyphosate and protect people and the environment from toxic pesticides’ (2017) and ‘Save Bees and Farmers’ (2023) should be taken into account, fully respected and enacted;
9. regular testing of people and the environment for chemical pesticide contamination in Member States, together with publication of the results, should be a mandatory component underpinning the award and retraction of authorizations.
November 2023.
