A PLATFORM FOR A NATIONAL STRATEGY AGAINST

WILDLIFE POISONING IN BOSNIA AND HERZEGOVINA

NATIONALN ANTI-POISONING WORKING GROUP

Sarajevo, 2018.

VCF/J. Andevski
A platform for a National Strategy Against Wildlife Poisoning in Bosnia and Herzegovina has
been prepared within the framework, as part of the Balkan Anti-Poisoning Project (BAPP), which
represents an integral part of the Mediterranean Anti-Poisoning Project (MAPP: Fighting
Poisoning — Reducing Vulture (and Other Scavengers’ and Predators’) Mortality due to the Use
of Poison Baits and Lead Ammunition Across the Mediterranean) financed by the Mava
Foundation and coordinated by the Vulture Conservation Foundation (VCF). This document shall
serve as a platform for building a National Strategy Against Poisoning, aimed at easing the battle
against the illegal use of poison baits in the natural environment and animal poisoning, thus
corresponding to Activity 4.5 of MAPP.

Prepared by: Dražen Kotrošan, Tarik Dervović (Ornithological Society “Naše ptice”)

Associates:

Date of completion: December, 2018

Project time frame: 8 years

1
Table of Contents

Acronyms and abbreviations.......................................................................................................

Introduction.................................................................................................................................

1. Background..............................................................................................................................

1.1 Vultures in Bosnia and Herzegovina..........................................................................

1.2 History of Bird Poisoning in Bosnia and Herzegovina................................................

1.3 Aim and objectives.....................................................................................................

1.4 Methods......................................................................................................................

2. Legal framework........................................................................................................................

2.1 Domestic legislation......................................................................................................

2.2 International legislation...............................................................................................

3. The status quo regarding the use of poison and poison baits in the natural environment of
B&H – Current situation.................................................................................................................

3.1 Types of Poisoning Recorded in Bosnia and Herzegovina...........................................

3.2 Stakeholder analysis.....................................................................................................

3.3 GAP analysis..................................................................................................................

4. Conclusions.................................................................................................................................

5. Framework of actions.................................................................................................................

References......................................................................................................................................

2
ACRONYMS AND ABBREVATIONS

3
INTRODUCTION

The use of poisonous bait in the natural environment is one of the most commonly used
methods for destroying vermin (Márquez et al., 2012), yet is also one of the biggest threats to
biodiversity. The illegal use of poisonous substances is considered one of the leading causes of
the decline in the populations of various bird species — vultures in particular — which feed
primarily on the carcasses of dead animals (BirdLife, 2011; Bodega Zugasti, 2014; Brochet et al.,
2015). High mortality rates, brought about by the misuse of poison bait, can seriously affect the
status of vulnerable species, including those protected by state law and international directives.
Additionally, poison baits pose a grave threat to some carnivorous animals (Virgós & Travaini
2005), and have historically caused declines in the populations and/or regional or national
extinctions of certain species such as bear, lynx, wolf, weasel, and the wildcat (Council of
Europe, 1993; Breitenmosser, 1998; Lozano & Malo, 2012). The non-selective use of such bait
represents a risk factor for other wild animals, as well as domestic animals and pets, and can
also negatively affect the health of humans, with potentially fatal consequences.

Most commonly, wild animal poisoning in the Balkans is caused by the intentional placement of
poison bait with the goal of exterminating wild, and in some cases even domesticated animals.
The use of poison bait usually consists of mixing food with various poisonous substances, many
of which are easily obtained through retail as phytosanitary products, such as insecticides,
rodenticides, fungicides, herbicides, and molluscicides. These bait units are then placed in spots
that are known to be accessible to the target animals, which can have an unfortunate side-
effect of harming numerous other species.

Using poison bait, as well as the outright poisoning of animals, was outlawed in all of the
Balkans during the 1980s, yet is still commonly seen and practiced as a quick and relatively easy
solution to the frequent conflicts with predators such as wolves and jackals and other wild
animals, mad and stray dogs, and to the damages they cause to ranchers, farmers, and animals
found in commercial hunting areas. Their widespread use is eased by the relatively lax
enforcement of existing laws and the market ubiquity of poisonous substances used to make
them.

4
1. Background

1.1 Vultures in Bosnia and Herzegovina

In his 1889 paper on vultures in Bosnia and Herzegovina, Otmar Reiser noted that Bosnia and
Herzegovina, along with Greece and Spain, was the only European country in the late 19th
century to have hosted all four species of vulture: the bearded vulture — Gypaetus barbatus,
the cinereous vulture — Aegypius monachus, the griffon vulture — Gyps fulvus, and the
egyptian vulture — Neophron percnopterus (Kotrošan 2009). But even then Reiser was issuing
warnings about the possibilities of these species going extinct, only to see their populations
continue to decline throughout the entire 20th century.

Vultures have all but disappeared in Bosnia and Herzegovina due to being killed, poisoned,
having their habitat ruined, or experiencing shortages of food caused by cuts in extensive
livestock farming. Following the poisoning of griffon vultures in Blagaj on June 26, 1991, not a
single species of vulture has been laying eggs in Bosnia and Herzegovina, rendering them all
officially extinct (Kotrošan et al., 2009).

The bearded vulture was a highly common nesting bird in the late 19th and early 20th century in
Bosnia and Herzegovina (Kotrošan et al., 2009). It was last seen in the areas surrounding the
mountains Prenj in 1985 and Čvrsnica in 1989. The appearance of a bearded vulture chick flying
off of its nest at a feeding site near Blagaj seems to indicate the bearded vulture was breeding in
Bosnia and Herzegovina in as late as 1986 (Marinković et al., 2007). Since the year 2000 there
has been only a single sighting near the mountain Vlašić (Drocić & Drocić, 2013).

The egyptian vulture, or the white scavenger, was a lesser known species of vulture in Bosnia
and Herzegovina known to have nested in Herzegovina and seen on occasion in Bosnia.
Although in small numbers, the bearded vulture managed to survive right up until the armed
conflicts started in 1992. From 1980 to 1992, a total of 6 nests and 10 cases of nesting were
identified in Herzegovina. According to the latest estimate from 1990, there were a total of 3
nesting pairs native to Bosnia and Herzegovina (Marinković et al., 2007). The bearded vulture
was last seen in the early 2000s in the Dabar field (Kotrošan et al., 2009).

Of all these species, the first to go extinct in Bosnia and Herzegovina was the cinereous vulture,
also known as the black vulture, or the monk vulture, having last been identified in the early
20th century. It has been seen several times in northern and central Bosnia and western and
eastern Herzegovina, though yielding no conclusive evidence of nesting (Kotrošan et al., 2009).

Arguably the most common and widespread species of vulture in Bosnia and Herzegovina was
the griffon vulture, with populations seen all across the country, and a large number of nesting
sites found in relevant literature. Towards the late 20th century, however, it has seen its range
constantly reduce to a handful of areas in Herzegovina. There were an estimated 20—40 nesting
5
pairs from 1980 to 1991, with 252 successful nestings identified in the same period (Marinković
et al., 2007). Following the 1991 Blagaj poisoning event and by the time the 1990s armed
conflict was over, the griffon vulture had already disappeared as a nesting species from Bosnia
and Herzegovina, with only a small number of flyovers seen since 2000 (Grubač & Gašić, 2001,
Gašić, 2007; Kulijer, 2007; Bešo, 2011/2012;). According to telemetric data collected by Saša
Marinković and Goran Sušić, the griffon vulture has been for the last several decades flying over
parts of Herzegovina, reaching the city of Mostar from the directions of the river Uvac in Serbia
and Croatian island of Cres.

Since 2005 there have been several — albeit unsuccessful — efforts to reintroduce the griffon
vulture to Herzegovina (Kotrošan et al., 2009), with the birds brought in from Spain dying in
both spells. In 2016, there were two cases of famished birds getting caught and later being
moved to cages in Blagaj and the Popovo field, with the one in the Popovo field dying shortly
thereafter.

1.2 History of Bird Poisoning in Bosnia and Herzegovina

Bird poisoning using strychnine, normally used against wolves, has been a serious problem from
as early as the late 19th and early 20th century, and has been marked as one of the largest
contributors to the extinction of vultures in Bosnia and Herzegovina (Reiser, 1889).
Unfortunately, there remains no concrete evidence of cases of poisoning from this period.

The very first systematic data on vulture poisoning in Bosnia and Herzegovina were collected in
the post-WWII period. It is at this time that hunting groups began conducting systematic efforts
to tackle vermin by planting poisoned baits for wolves, jackals, foxes, and dogs — most notably
using strychnine and potassium cyanide. These efforts lasted two decades; in the year 1959
alone there were a whopping 220 cases of griffon vultures falling victim to these poisonings
(Kotrošan et al. 2009).

And even though later on strychnine and potassium cyanide were officially outlawed, poisoning
as a practice continued due to the availability of alternative substances such as carbofuran and
Kreozan.

According to Marinković and associates (2007), a total of 97 poisoned griffon vultures were
identified in Herzegovina from 1980 to 1991, with room left for those who have gone unnoticed
(Kotrošan, 2009).

The last recorded case of griffon vulture poisoning occurred in Blagaj in 1991, when a total of 30
of mostly adult, nesting birds identifying with this species were affected (Kotrošan et al. 2009).

In 2004, there was a case in Sarajevo of 20 common buzzards (Buteo buteo) being poisoned
after biting on poisoned bait intended for rat population control (Kunovac, 2004).
6
There were also two recorded cases of poisoned adult storks in the village of Vrbaška near
Gradiška in 2017, most likely due to deratisation efforts amid the rat-bite fever crisis (Topić &
Topić 2018).

Other than the aforementioned sporadic cases of poisonings, there remain no data on large-
scale efforts to these ends; there are also profuse reports of stray dogs being poisoned via the
same means, but no official data. Dog poisoning is especially frequent in urban areas, thus
posing a threat to the health of the human population.

1.3. Aims and objectives of the Strategy Against Animal Poisoning in Bosnia and Herzegovina

The basic goal of this document is to serve as a platform to work on a Strategy Against Animal
Poisoning in Bosnia and Herzegovina, and to define the guidelines for drafting a comprehensive
and integrated framework of activities geared towards eliminating the illegal use of poison and
poisoned bait in the natural environment.

An evaluation of the status quo, in order to gain an insight as to the extent of the dangers of
animal poisoning in Bosnia and Herzegovina, shall be one of the principal tasks of the work
outlined in this document.

Objective 1. Raising awareness and collecting more systematic data on the illegal use of
poisoned bait and its consequences.

1.1 Evaluating the status quo and raising the level of knowledge about the use and
effects of poison and poisoned bait in Bosnia and Herzegovina
1.1.1 Conducting a detailed study on the frequency and volume of the illegal use
of poison and poisoned bait in the natural environment, and their effects on biodiversity,
particularly inflicted on the protected species.
1.1.2 Accruing greater knowledge on the motives and causes of using poison in
the natural environment.

1.2 Setting up a database of known cases of animal poisoning

1.2.1 Designing a standard protocol for recording cases of animal poisoning —
each to contain information on the location and date of the incident, the species of animal
affected, the type of bait and poison used, as well as the motivation.
1.2.2 Creating a database to serve as a collection of information on all cases of
poisoning in Bosnia and Herzegovina, following a predefined protocol, and collecting data on all
such known cases in the last 5 years.
1.2.3 Creating a map of high activity areas, i.e. places that are known to host the
lionshare of animal poisoning activities.

7
 1.3 Setting up efficient and uninhibited communication channels for exchanging relevant
data between all stakeholders.
1.3.1 Identifying all authorities relevant to the cause and providing easy access to
valuable data for the sake of improving cooperation and knowledge exchange.
1.3.2 Creating procedures for fast data exchange and the encouragement of
cooperation between inspection and law enforcement agencies on tackling illegal poisoning,
with the help of ecological societies and various other organizations with relevant experience.
1.3.3 Making publicly available the data on all recorded cases of poisoning (with
the exception of those currently under investigation), as well as the penalties and sentences
issued to the perpetrators.

Objective 2. Strengthening institutional intervention efforts in coordination with solutions

proposed by existing law.

2.1 Coordinating a Strategy Against Wild Animal Poisoning in Bosnia and Herzegovina.
2.1.1 Forming a task force for the battle against animal poisoning comprised of
representatives for all the relevant state- and entity-level ministries and institutions, as well as
non-government organizations.
2.1.2 Adopting operational protocols for the bodies responsible for litigating
cases of wild animal poisoning, and also for the responsibilities and authorities of all the
administering state-level institutions.

2.2 Expanding the capacities of the administering bodies by applying educational and
training programs.
2.2.1 Educating, through specialized seminars, officers with various state- and
entity-level bodies involved in handling cases of poisoning.
2.2.2 Raising awareness within the judicial system of the negative effects of using
poisoned baits.

2.3 Expanding the capacities of the administering bodies for examining samples of
poisoned animals and conducting toxicological analyses.
2.3.1 Naming the laboratories authorized to conduct sampling of poisoned
animals and toxicological analyses.
2.3.2 Educating officials at authorized laboratories through specialized seminars.

Objective 3. Raising awareness among the general public, and all the stakeholders, of the
problems of illegal wild animal poisoning.

3.1 Raising awareness among all the stakeholders through targeted educational
programs.
3.1.1 Informing and raising awareness among all kinds of agricultural workers,
and hunters, through meetings with representatives from authorities about the effects of using
8
poison and poisoned bait on public health and biodiversity, and about the prescribed
administrative and criminal sanctions.
3.1.2 Conducting an awareness-raising campaign about the environment
targeted at farmers, ranchers, hunters, and other groups that can be tied to using poison and
poisoned bait. These campaigns ought to provide information about the effects of using poison
and poisoned bait on endangered species, the risks they pose to the health of humans, the
prescribed administrative and criminal sanctions associated with them, and the critical role that
vultures play in the correct functioning of our ecosystem.
3.1.3 Conducting an awareness-raising campaign in stores retailing pesticides
about the risks that come with their inadequate use on the environment and public health.

3.2 Raising public awareness

3.2.1 Conducting an awareness-raising campaign among the general public about
the problem of animal poisoning, through mass and social media, in cooperation with non-
governmental organizations and various other groups dedicated to environmental protection.
The end-goal of the campaign should be to instill an attitude of zero tolerance towards the
crime of animal poisoning.
3.2.2 Carrying out educational programs in schools about the illegal use of poison
and poisoned bait, and the indispensable role of predators in our ecosystem, with a
concentration on areas high in these criminal activities.

Objective 4. Instituting measures of control against toxic substances used to make poisoned
bait.

4.1 Increasing measures of control over the retailing and using of toxic substances
usually used to make poisoned bait.
4.1.1 Carrying out regular audits at agricultural pharmacies and stores retailing
tools and compounds used for crop protection.
4.1.2 Carrying out controls over the adequate use of tools and compounds for
crop protection, especially with agricultural workers in high-activity areas.

4.2 Putting an end to the illegal trade of pesticides forbidden by law.

4.2.1 Carrying out regular audits, in cooperation with customs enforcement, of
the availability of illegal pesticides on the market.
4.2.2 Intensifying customs controls against illegal imports of pesticides from
other countries.
4.2.3. Clarifying and hiking up administrative and criminal sanctions.

1.4. Methods

An Introductory Meeting of all the Stakeholders

9
Meetings with all the stakeholders have been held in Sarajevo on May 31 and June 1, 2018, as
part of phase one of BAPP. The meeting’s principal goal was to collect information about vulture
poisoning and animal poisoning in general and to get the governmental bodies involved in the
project with support through assembling a task force to address this issue.

The attendees included representatives from the Ministry of Foreign Trade and Economic
Relations of Bosnia and Herzegovina, the Ministry of Agriculture, Water Management and
Forestry of the Federation of Bosnia and Herzegovina, the Federal Department for Inspection
Affairs, the Republika Srpska Inspectorate, the Hunters Association of Republika Srpska, the non-
governmental organization Čaplja from Čapljina, Naša baština from Tomislavgrad, Novi val from
Blagaj, the Center for Sustainable Development and Ecology from Trebinje, as well as
representatives of the aforementioned VCF, and the meeting organizers — the Ornithological
Society Naše ptice (Our Birds).

The National Anti-Poisoning Working Group in Bosnia and Herzegovina

The national anti-poisoning working group shall consist of representatives from the most
notable institutions (e.g. ministries, inspection agencies, customs enforcement agencies), who
shall be authorised by their respective institutions to participate in creating the National
Strategy against wildlife poisoning in Bosnia and Herzegovina.
An invitation to name representatives into the working group, along with a presentation of the
Platform, shall be sent out to all the stakeholders by the Ministry of Foreign Trade and
Economic Relations of Bosnia and Herzegovina.

Coordination

The Ornithological Society Naše ptice, in cooperation with Nada Mlinar and Vanda Medić at the
Sector for Water Resources, Tourism, and Environmental Protection of the Ministry of Foreign
Trade and Economic Relations of Bosnia and Herzegovina, shall be tasked with coordinating the
Working Group through joint meetings. The Working Group shall, if necessary, seek consult
and/or advice from VCF. The Working Group shall carry out work via direct correspondence, i.e.
live meetings. Any decision or official document shall seek approval from entity-level ministries
and the Ministry of Foreign Trade and Economic Relations of Bosnia and Herzegovina as project
coordinators.

10
2. LEGAL FRAMEWORK

2.1 Domestic legislation

Bosnia and Herzegovina is a complex country; it is comprised of two entities — the Federation
of Bosnia and Herzegovina and Republika Srpska — and the District of Brčko. The Federation of
Bosnia of Bosnia and Herzegovina consists of 10 cantons, and the local authorities are
comprised of towns and municipalities. Republika Srpska has the same structure for local
authorities. The District of Brčko, on the other hand, has a specific legal and constitutional
status. A territorial organization this complex carries with it a complex legal frame reflecting
multiple levels of authority when it comes to legislating and enforcing the law. The Ministry of
Foreign Trade and Economic Relations of Bosnia and Herzegovina is the executive branch body
authorized to make decisions at the state-level regarding policy, basic principles, work
coordination, and managing the work of entity-level ministries, for areas such as agriculture,
environmental protection, and natural resources management. The entities, along with the
District of Brčko, as distinct territories, hold the majority of authorities. In the Federation of
Bosnia and Herzegovina, the cantons themselves have their own legal frame, which frequently
brings up the issue of legal texts at different levels not being in sync with one another.

Table 1. An overview of the local and regional legislative directives relevant to the issue of
animal poisoning

LAW/CODE
The Nature Protection Code
of the Federation of Bosnia
and Herzegovina
The Nature Protection Code
of Republika Srpska
The Nature Protection Code
of the District of Brčko
SCALE OF
EXECUTIVE BODY IMPLEMENTATIO
N
- Government of the Federation of Bosnia and Herzegovina,
- Federal Ministry for the Environment and Tourism,
- Cantonal ministries in charge of the environment,
Entity,
- Federal Department for environmental protection,
canton
- Cantonal dpts. for environmental protection,
- Federal Administration for Inspection Affairs,
- Cantonal authorities for inspection affairs,
- Cross-entity body for the environment (state-level)
- Government of Republika Srpska,
- Ministry for Spatial Planning, Construction and Ecology,
- Environmental protection fund of Republika Srpska
- Local authorities, Entity,
- Protected areas management, local
- Inspectors from Republic Administration for Inspection
Affairs,
- Inspectors from local authorities
- Cross-entity body for the environment (state-level)
- Department for Spatial Planning, Subdepartment for
Spatial Planning, Urbanism and Environmental Protection, District
— The Inspectorate, Department for Inspection of Health
and Environmental Protection, Inspection of Environmental

11

The Environmental Protection
Code of the Federation of
Bosnia and Herzegovina
The Environmental Protection
Code of Republika Srpska
The Environmental Protection
Code of the District of Brčko
The Hunting Code of the
Federation of Bosnia of
Herzegovina
The Hunting Code of
Republika Srpska
The Hunting Code of the
District of Brčko
The Criminal Code of the
Federation of Bosnia and
Herzegovina
The Criminal Code of
Republika Srpska
The Criminal Code of the
Protection,
- Cross-entity body
- Government of the Federation of Bosnia and Herzegovina,
- Advisory Council for the Environment (named by the Govt)
- Federal Ministry for the Environment and Tourism, Entity,
- Cantonal ministries in charge of the environment, canton
- Federal environmental protection fund,
- Cantonal funds for the environment,
- Cross-entity body for the environment (state-level)
- Government of Republika Srpska,
- Advisory Council,
- Ministry for Spatial Planning, Construction and Ecology,
- Advisor with the Ministry on Questions of Environmental
Protection, Entity,
- Local authorities, local
- Public prosecutor,
- Inspection conducted by municipal/town and republic
bodies in charge of environmental protection,
- Cross-entity body for the environment(state-level)
- Mayor,
- Advisory Council for the Environment,
- Department for the Environment,
- Advisor on questions of environmental protection, District
- Public prosecutor,
- Department for Public Safety,
- Inspectorate — the inspector for environmental
protection
- Ministry of Agriculture, Water Management and Forestry,
- Cantonal ministries,
Entity,
- Federal hunting inspector,
canton
- Cantonal inspectors,
- Hunting ground user – hunters/keepers office
- Ministry of Agriculture, Forestry, and Water Management,
- Inspection for Forestry and Hunting with the Republic Entity
Administration for Inspection Affairs,
- Hunting ground user – hunters/keepers office
- Government of the District of Brčko
- Department for Agriculture, Forestry and Water
Management,
District
- Inspectorate, Department for Inspection of Health and
Environmental Protection, forest inspector,
- Hunters/keepers office
- Cantonal prosecutors,
- Courts in the Federation (municipal, cantonal, and the Entity
Supreme)
- Republic public prosecutors,
- County prosecutors,
Entity
- Courts in Republika Srpska (municipal, county, and the
Supreme)
- Prosecutors office, District
12
 District of Brčko - Courts in the District (the Basic and the Court of Appeals)

2.2 International legislation

Bosnia and Herzegovina has thus far signed the majority of international conventions and
directives related to the natural environment, which, by the same token, are relevant to the
issue of animal poisoning. The biggest obstacle remains a difficulty in implementing some of the
elements within certain directives, as well as adapting local legislative texts against certain
directives and other international documents.

Table 2. An overview of the international documents relevant to the issue of animal poisoning

Convention Source

Decision to ratify the Convention on biodiversity (Rio de Janeiro, Službeni glasnik BiH No. 13/02 –
June 5, 1992) 467 – addendum

Decision to ratify the Convention on the conservation of European

Službeni glasnik BiH No. 8/08 –
wild species and their natural habitats (Bern, September
47 – addendum
19, 1979)

Decision to ratify the Convention on safety and health in

agriculture, No. 184 from 2001, and the Službeni glasnik BiH No. 9/09 –
Recommendations on safety and health in agriculture, No. 279 – addendum
192 from 2001, International Labour Organization

Decision to ratify the Convention on the conservation of migrating Službeni glasnik BiH No. 8/17 –
wild species of animal (Bonn, June 23, 1979) 141 - addendum

Conclusion about the ratification of the Report on the

Public record from the 12th
implementation of the Rotterdam Convention on the
Session of the Council
procedures of prior consent for certain dangerous
of Ministers of Bosnia
chemicals and pesticides in international trade, from July
and Herzegovina
4, 2012

The Rulebook on maximum levels of pesticide remains in food for

Službeni glasnik BiH 89/2012
animals of both plant and animal origin

13
3. THE STATUS QUO REGARDING THE USE OF POISON AND POISON BAITS IN THE NATURAL
ENVIRONMENT IN BOSNIA AND HERZEGOVINA – CURRENT SITUATION

At this time, there is no available data from the authorities in Bosnia and Herzegovina to provide
any indication of the actual status quo regarding this issue. This is largely due to non-existent
monitoring, protocols, or databases to store the data in. There is the general consensus that
bird poisoning is occurring, which is mostly implied from known cases of dog poisoning.
However, even with dog poisoning cases there are no reports documenting any additional
animals being poisoned.

The last recorded mass poisoning event is the 2004 Sarajevo poisoning of 20 common buzzards
(Buteo buteo). This was a case of unintentional poisoning, as the goal was rat population
control.

Table 3. An overview of poisoning cases in Bosnia and Herzegovina from 1990 to 2018

No. of
Date/ Toxic Cause of
Species poisoned Location
period substance poisoning
birds
Griffon vulture
30 1991 Blagaj Furadan Dog poisoning
(Gyps fulvus)
Common buzzard Rat population
20 2004 Sarajevo /
(Buteo buteo) control
Vrbaška, Deratization
White stork
2 2017 Municipality / amid rat-bite
(Cicionia ciconia)
of Gradiška fever

3.1 Types of Poisoning Recorded in Bosnia and Herzegovina

At this time, it is safe to say there are intentional mass poisoning efforts targeted at stray dogs,
while with birds these poisonings occur on an individual basis and unintentionally, either when
the poisoned baits are prepared for another kind of animal, or in agriculture, through the
inadequate overuse of crop protection substances.
Out of all the toxic substances, Furadan is the only one known to be in use illegally, while for all
the others there are extensive prescribed licensing procedures.

3.2 Stakeholder analysis

14
The issue of animal poisoning is seeing involvement — direct or indirect — from ministries at all
levels, inspection agencies, entity- and canton-level law enforcement, customs enforcement,
university departments, institutes and non-governmental organizations.

Table 4. An overview of the most significant stakeholders

Institution/Organization Level of authority

Ministry of Foreign Trade and Economic Relations Bosnia and
Herzegovina
Federal Ministry of Environment and Tourism Federation of
Bosnia and
Herzegovina
Federal Ministry of Agriculture, Water Management and Forestry Federation of
Bosnia and
Herzegovina
Federal Department for Inspection Affairs Federation of
Bosnia and
Herzegovina
Ministry of Spatial Planning, Construction and Ecology Republika Srpska
Republic Administration for Inspection Activities Republika Srpska
Ministry of Agriculture, Forestry and Water Management Republika Srpska
Department for Spatial Planning, The District of
Subdepartment for Spatial Planning, Urbanism, and Environmental Brčko
Protection
The Inspectorate, The District of
Department for Inspection of Health and Environmental Protection, Brčko
Inspection of Environmental Protection
Federal Police Administration Federation of
Bosnia and
Herzegovina
Police Administration Republika Srpska
Border Police of Bosnia and Herzegovina Bosnia and
Herzegovina
Veterinary Faculty, University of Sarajevo Federation of
Bosnia and
Herzegovina

3.3 GAP Analysis

● Tracking down and reporting

15
 - An unclear procedure for reporting poisoning cases to the authorities. Citizens are
unclear as to whom they are supposed to report such incidents.
- A lack of publicly available data necessary to ascertain the types of poisoning present in
the country. Data provided by the media are often inaccurate but mostly referring to instances
of dog or cat poisonings unintentionally affecting other animals.
- A low level of public awareness about the importance of the issue. In general, there is
very little information out there about poisoning cases, or the consequences of inadequate toxic
substance use. There are no workshops, and the media’s approach is weak.
- Illegal substances are easily accessible and there are insufficient trade controls. These
substances are easily obtainable and they are imported from other countries.
- Uncertainties in the designated authorities of the judiciary, the inspectorates, and the
police; in the Federation, these uncertainties occur between the entity and the cantons. The
system is highly complex, and laws frequently cause confusion as to the authorities of certain
levels of government.

● Sampling, research, and analysis

- Laboratories are ill-equipped (in the Federation, there are no laboratories for blood
sample analysis). Problems arise when it is necessary to run tests (e.g. test the blood for poison)
and the results come back only partially useful (e.g. they show that the cause of death was
poisoning, but can’t identify the poison).
- A shortage of well-trained toxicologists. Underfinanced jobs carry with them a shortage
of experts.
- A lack of clearly devised protocols. Although protocols exist within legislative texts, in
the field they are routinely broken due to lack of knowledge.
- A lack of a financing solution for institutions who would do the analyses. Instead, they
are done by underfinanced university laboratories.

● Applying the law and judicial processes

- Overlaps and ambiguities within the existing legislature (a number of laws deal with
toxic substances). A number of laws deal with various questions regarding the use of toxic
substances, and the sanctions imposed for illegal and inadequate use (e.g. the criminal code,
the hunting code).
- Lax enforcement of existing law. In most cases, filing criminal charges and litigation is
avoided.
- Judicial processes are complicated and take very long; at certain levels, they can take
years.
- A low number of solved cases — ones that resulted in criminal charges. Not one case of
animal poisoning has been treated as a criminal offense.
- A tendency to commute sentences/penalties. Even if judicial processes are set in
motion, the penalties are usually mild.

16
4. CONCLUSIONS

The main takeaways for the preparation of the Strategy are:

Conclusion 1: It is necessary to determine the scale and gravity of wild animal poisoning in
Bosnia and Herzegovina.

Conclusion 2: Education and awareness raising ought to be conducted toward the general public
and to authorities at all levels.

Conclusion 3: The legislative foundation is solid, but needs better enforcement.

Conclusion 4: It is necessary to develop more efficient and straightforward legislative protocols

for defining responsibilities in reporting, researching, and examining cases of animal poisoning.
Once developed, these protocols ought to be distributed to all authorities so as to clearly
designate responsibilities for each level and thus avoid overlaps.

Conclusion 5: The Working Group ought to be officially formalized and the best methods must
be found to ratify and accept the Strategy Against Animal Poisoning in Bosnia and Herzegovina.

Conclusion 6: Much effort is to be invested in on-site research, reporting and documenting

cases of poisoning.

Conclusion 7: The tentative new sanitary regulations dealing with toxic waste disposal could
result in decreased numbers of poisoning cases.

Conclusion 8: Protocols for dealing with wild animal poisonings are defined within the
Veterinary Inspectorate. If the inspector suspects poisoning, there are funds at the Federal level
that will cover the costs of a toxicological analysis.

Conclusion 9: It is necessary to dramatically expand the existing capacities of laboratories to

conduct efficient toxicological analyses. Without them, a death cannot be positively tied to
poisoning.

17
 5. FRAMEWORK OF ACTIONS

The Strategy brought forward here would pan out over 8 years; the activities and the budget are
presented below in Table 5.

Table 5. The recommended activities to combat animal poisoning in Bosnia and Herzegovina

Time
period Authorized Budget
Priority Users
body (EUR)
(yrs)

140,800.0
PROJECT MANAGEMENT 0

Coordination 8 High Naše ptice 76,800.00

Office costs 8 Medium Naše ptice 48,000.00

Tools & equipment 8 Low Naše ptice 16,000.00

Raising awareness about cases of

Goal 1
poisoning in Bosnia and Herzegovina 10,000.00

Naše ptice &

Conducting a study on the initial state
Activity 1.1 associates
(data collection)
1 High (networking) Ministries, police, NGO 8,000.00

Activity 1.2 Creating a preliminary public database

1 Medium Naše ptice Ministries, police, NGO 2,000.00

Strengthening institutional intervention

Goal 2 efforts in coordination with solutions
proposed by existing law. 80,000,00

Adapting the Strategy for Bosnia and Working

Activity 2.1
Herzegovina document 1 High Group/VCF Ministries, police 6,000.00

State evaluation — meetings with local Working Ministries, police, local

Activity 2.2
stakeholders 1 Medium Group/VCF communities, NGO 4,000.00

Training sessions for establishing

Activity 2.3 Police, inspectors, labs,
protocols
2 Low Naše ptice/VCF NGO 6,000.00

Activity 2.4 Expanding laboratory capacities Police, inspectors, labs,

8 Low Naše ptice/VCF NGO 64,000.00

Raising awareness among the general

Goal 3 public, and all the stakeholders, of the 224,000.0
problems of illegal wild animal poisoning. 0

The Stop trovanju divljih životinja Naše ptice and

Activity 3.1 campaign (Let’s Put an End to Wild associates
Animal Poisoning) 8 High (networking) General public, NGO 80,000.00

18
 Workshops for farmers, hunters, and Naše ptice & Schools, universities,
Activity 3.2
students 8 Low NGO Novi Val hunting orgs 80,000.00

Establishing control mechanisms at the Naše ptice &

Activity 3.3
feeding site in Blagaj 8 Low NGO Novi Val NGO 64,000.00

Instituting measures of control against

Goal 4 toxic substances used to make poisoned
67,000.00
bait.
Entity admins
Setting up a public database on
Activity 4.1 for inspection
substances imported into the country
2 Low affairs Ministries, police, NGO 3,000.00

Training sessions for inspectors and

Activity 4.2
customs enforcement officers 8 Low Naše ptice/VCF Ministries, police, NGO 64,000.00

320,200.0
TOTAL 0

19
REFERENCES

● Bešo, A., 2011/2012: Posmatranje bjeloglavog supa (Gyps fulvus) iznad Nevesinja. Bilten
Mreže posmatrača ptica u Bosni i Hercegovini, 7-8(7-8): 91.
● Bodega Zugasti, D. de la (Ed.). 2014, Illegal use of poisoned-baits. Legal analysis and
investigation. SEO/BirdLife-Proyecto Life+ VENENO project. Madrid
● Breitenmoser, U., 1998. Large predators in the alps: the fall and rise of man's
competitors. Biol. Conserv. 83, 278–289.
● Brochet, A., Van Den Bossche, W., Jbour, S., Ndang’ang’a, P. K., Jones, V. R., Abdou, I., Al-
Hmoud, A., Asswad, N., Atienza, J., Atrash, I., Barbara, N., Bensusan, K., Bino, T., Celada,
C., Cherkaoui, S., Costa, J., Deceuninck, B., Etayeb, K., Feltrup-Azafzaf, C., Figelj, J.,
Gustin, M., Kmecl, P., Kocevski, V., Korbeti, M., Kotrošan, D., Mula Laguna, J., Lattuada,
M., Leitão, D., Lopes, P., López-Jiménez, N., Lucić, V., Micol, T., Moali, A., Perlman, Y.,
Piludu, N., Portolou, D., Putilin, K., Quaintenne, G., Ramadan-Jaradi, G., Ružić, M.,
Sandor, A., Sarajlić, N., Saveljić, D., Sheldon, R. D., Shialis, T., Tsiopelas, N., Vargas, F.,
Thompson, C., Brunner, A., Grimmett, R., Butchart, S., 2016: Preliminary Assessment of
the Scope and Scale of Illegal Killing and Taking of Birds in the Mediterranean. Bird
Conservation International 26 (1): pp 1-28
● Drocić, N., Drocić, S., 2013: Opažanje kostoberine, Gypaetus barbatus (Linnaeus, 1758), u
srednjoj Bosni maja 2013. godine. Bilten Mreže posmatrača ptica u Bosni i Hercegovini,
9(9): 107-108.
● Gašić, B., 2007: Prilog za faunu ptica Jahorine (Bosna i Hercegovina). Ciconia. 15: 46-53.
● Grubač, B. & Gašić, B., 2001: Savremeni podaci o fauni ptica istočne Hercegovine i
susjednih područja (Bosna i Hercegovina). Ciconia. 13: 59-76.
● Kotrošan, D, 2009: “Balkanski akcioni plan za zaštitu lešinara” – Novi pokušaj obnavljanja
populacije bjeloglavog supa u Hercegovini. Naše šume, 8(16-17): 22-26.
● Kotrošan, D., Marinković, S., Šimić, E., Viada, C., 2009: Lešinari – priručnik za edukaciju
posmatrača ptica u Bosni i Hercegovini
● Kulijer, D., 2007: Bjeloglavi sup (Gyps fulvus) zabilježen iznad čvrsnice. Bilten Mreže
posmatrača ptica u Bosni i Hercegovini. 3(3): 53.
● Kunovac, S., 2004: Pomor škanjaca, Čovjekova nebriga ili … Lovački list, NS 79: 15.
● Lozano, J., Malo, A. F. 2012: Conservation of European wildcat (Felis silvestris) in
Mediterranean environments: a reassessment of current threats. In: Williams GS (ed)
Mediterranean Ecosystems: Dynamics, Management and Conservation. Nova Science
Publishers Inc., Hauppauge, pp 1-31
● Márquez, C., Vargas, J. M., Villafuerte, R., Fa, J. E., Gompper, M., Fritz, H., 2012:
Understanding the propensity of wild predators to illegal poison baiting, Animal
Conservation, 16 (1): 118-129
● Virgós, E., Travaini, A. 2005: Relationship Between Small-game Hunting and Carnivore
Diversity in Central Spain. Biodivers Conserv 14
http://novovrijeme.ba/u-blagaju-predstavljen-bjeloglavi-sup-jablan/
http://mojahercegovina.com/savo-gavrilovic-i-ovako-ruznu-pticu-mozes-mnogo-zavoljeti/
20