03/07/13 Poisonings in Zagreb

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Ministry of Health
Sanitary Inspection Directorate
c/o Ivo Afric, assistant minister
Ksaver 200a
10000 Zagreb

March 7, 2013

Dear Mr. Afric,

We are writing to you on account of the recent cases of intentional placement of rat poison and snail poison, concentrated bromadiolone, and other types of poison in public places in Zagreb, Split, and other parts of Croatia, where dogs, cats, birds, and other animals are poisoned throughout the year.

Regarding the alarming frequency of poison placement in all districts of Zagreb within the past months, we have been alerted by a considerable number of citizens fearing for the health of their companion animals and their children, as well as those worried about the pollution of soil, water, and other ecological problems related to the uncontrolled dissipation of poisonous chemicals. We believe that this should lead to the introduction of a far stricter control and/or prohibition of free and uncontrolled access to chemicals that are threatening the lives and health of humans and other animals in Croatia.

According to the Law on Chemicals (Official Gazette 150/05), anyone selling dangerous chemicals must have his or her trade listed in the court register (Article 38) and have a permit issued by the Ministry of Health (Article 43); all employees in contact with dangerous chemicals must have special certificates issued by the Croatian Institute for Toxicology and Anti-Doping (hereafter abbreviated as HZTA), stating that they have passed a basic course (Article 47); rooms where dangerous chemicals are kept and/or sold must contain instructions on the proper procedure in case of exposure (Article 48); logs must be kept on dangerous chemicals sold in retail (Article 54), and the total data for the previous year must be sent to HZTA; and eventually, there is a list of chemicals that are not to be sold in retail at all (Article 53).

The Rule Book on special conditions that must be met by all legal subjects engaged in the production, sale, or use of dangerous chemicals, and on the conditions to be met by all legal subjects or private persons who sell dangerous chemicals in retails or use them (Official Gazette 68/07), includes a detailed list of conditions regarding the preservation, storage, use, and distribution, both wholesale and retail, of all dangerous chemicals.

Control over the proper observation of all these regulations regarding dangerous chemicals is in the hands of the Sanitary Inspection, which should strictly control the work of private persons and legal subjects buying or selling dangerous chemicals. Does the Sanitary Inspection Directorate keep lists of all private persons and legal subjects who have been issued a permit to produce, sell, or use dangerous chemicals, does it control such subjects after the permit has been issued, and in which way does it prevent local stores from selling dangerous chemicals without the permit?

The Rule Book on keeping logs about dangerous chemicals, as well as methods and deadlines regarding the submission of data from these logs (Official Gazette 113/06), includes forms that must be filled in when selling or buying dangerous chemicals in retail, and these logs are to be submitted to HZTA. Supposing that all stores selling dangerous chemicals keep these logs regularly, HZTA should presently have the information of all legal subjects and private persons who have sold and bought chemicals within the last year or longer. Does HZTA have data about the quantities of imported and sold dangerous chemicals, and how can these logs help in identifying the perpetrator? Does the inspection in charge check whether all merchants have sent in their data and whether these data are complete, and how does it deal with those stores who violate the legal regulations?

What measures in controlling the implementation of the Law on Chemicals and the corresponding Rule Books have the sanitary inspections in Zagreb, Split, and other cities undertaken after the dramatic increase in poison occurrence in urban/residential districts and public spaces, and after the cases of poisoned animals were reported? Can your work and the work of other relevant institutions in charge prevent the uncontrolled acquisition of dangerous chemicals that cause death in animals and can also cause human deaths?

We are raising these questions as we are aware of the fact that it is not the Croatian laws that are deficient, but that, judging from the frequent occurrences of poison in public spaces, dangerous chemicals are obviously not as difficult to obtain as they should be on the basis of the aforementioned legal regulations.

We are requesting your cooperation in solving these issues, both in relation to the citizens, who keep reporting the discovery of poisonous substances, and in relation to the police, regarding the measures undertaken after the increased number of cases of poisoned animals. We would appreciate a prompt answer so that we may forward the information to the public and the mass media.

Best regards,

Luka Oman
President of Animal Friends Croatia

CCd:

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