Serbia: Attempt to ‘Punish’ Serbian NGO Animal Shelter ? – Investigation Report Into Vaccination ‘Procedures’ Uncovers Discrepancies

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** Latest 10/09/09 ** :

Today, additional government pressure is being placed on NGO shelters within Serbia.

We refer to our recent post of 31/07/09 (link below) and veterinary inspectors who wrote to EPAR shelter and demanded that 174 dogs at the shelter must immediately be re-vaccinated.  As we declared in the post, “All of the dogs which the inspectors require to be vaccinated were vaccinated on 21/07/2008, almost one year ago to the day”.


On 10/09/09, EPAR shelter have received another letter from the republic veterinary inspection information department declaring that veterinary inspectors will visit EPAR shelter to see if vaccinations of the 174 dogs which were demanded on 24.7.2009 have been undertaken.

The Director of the Veterinary station is one Mr Antun Orcic; he is the husband of veterinary inspector Matilda Orcic. Mr Orcic did not want to do the booster vaccinations of all 174 dogs.

Regardless, Veterinary Inspector Matilda Orcic demanded that booster vaccinations be given, even though the dogs were vaccinated approximately one year ago and according to our investigations (see report below), the duration of the vaccination is 3 YEARS.  According to us, the dogs are still covered by their current vaccination, and will be for around another 2 years.

EPAR shelter have sent a request/letter to the veterinary station today, declaring that any vaccinations on any dogs must be financed from the republic budget, as this is in agreement with the Veterinary law. 

It must be made very clear that EPAR shelter, which is simply an NGO which undertakes the care and protection of stray dogs delivered to the shelter, are not the legal owner of all the strays.  The owners of unmarked, unsterilised stray dogs which often end up at EPAR shelter are in some circumstances the tax paying citizens of Subotica City.  These taxes should contribute to the national budget, which should provide (out of the national budget) for the costs of vaccinating stray dogs at EPAR shelter.  It is not the responsibility of an NGO to suddenly be declared the ‘owner’ of all stray dogs at its shelter, and subsequently have to independently cover the costs of all the vaccinations.

These stray dogs at EPAR shelter may or may not have had a past owner – if they did, the owner would have been a taxpayer.  As the government does not have any system to aid identification of an animals owner, such as a microchip, the past owner of many animals simply cannot be identified.  But, because of this, either the original owner of the animal, or the state (if never owned animals) are responsible for the vaccination costs of dogs at EPAR shelter, not the NGO.  This declaration is clear in Article(s) 140. and 141. of the Veterinary Law. 

It would appear that by declaring EPAR shelter as the ‘owner’ of all strays which come through their front gate, and requesting they (EPAR) pay for animal vaccinations, the government are attempting to punish EPAR shelter in yet another way.

Article 55. of the Veterinary Law allows for shelters to take in the animals, but for official veterinarians to visit the shelter, do any necessary vaccinations, and then forward to the state a monthly reoprt of the number of animals vaccinated.  The vets are subsequently financed for their vaccinations out of the state budget.  See report below for detailed information.

So, EPAR shelter is Not the legal ‘owner’ of the stray dogs at its shelter.  It is simply a haven providing a home and shelter for the animals.  Now the government are attempting to ruin EPAR shelter by forcing costs and fines onto them for failing to cover costs for animal vaccinations which should not financially be their responsibility anyway ! 

The vaccination costs of stray animals living at a shelter is NOT the obligation of the shelter, it IS the obligation of the government.

Is this a Serbian government attempt to destroy EPAR shelter and the animal welfare organisations / shelters of Serbia ?

** Possibly the following investigation which has recently been undertaken may be the reason why there are attempts to destroy EPAR shelter.  We leave you to read the report below into our investigation and decide for yourself if what is happening is pure chance, or if there is a deeper reason why the veterinary profession and the government may wish to silence EPAR shelter. **

Please read on for full details of our investigation.




We have an opinion now that the veterinary profession in Serbia, may be undertaking unnecessary work in relation to routine animal vaccinations, possibly charging both individual Serbian citizens and at the same time, the Serbian state, for the costs of the same (ie. One single) unnecessary vaccine.


Under Serbian law, Article 55 of the Veterinary legislation demands that:

1)      everybody who  is the owner of an animal(s) must contact veterinarians who have a permit for undertaking the program of control for infective animal disease(s).

2)      it is the responsibility of the animal(s) owner to  keep vaccination documentation for a period of at least 2 years.

But owners of animals do not have any more obligations with regard Rabies vaccination(s). This is specifically a vaccination which must be performed / undertaken by a qualified veterinarian.

As far as we see, the term ‘vaccination’ means both 1)  the physical vaccine (vial) itself and 2)  the administration (application) of that vaccine to any animal.

A ‘vaccinator’, ie. the veterinarian, is one who vaccinates.

Important:  Veterinarians do not have a legal permit for the distribution of vaccines, but only for the administration (giving) of a vaccine to an animal.

The vets receive (via a distribution network) doses of the vaccine for Rabies which is called ‘Nobivac Rabies’. 

For 2007, the veterinarians within Subotica city alone were given 15,000 doses of the Nobivac Rabies vaccine. 

In 2008, 35,980 doses of the Nobivac Rabies vaccine have been allocated in Subotica.

NOBIVAC RABIES :  An inactivated vaccine for the immunization of dogs, cats, cattle, sheep, goats, foxes, ferrets and horses, and in principle all healthy mammals against Rabies.

Source –

SAV contacts / Serbian campaigners have previously requested, and now actually have documented evidence of the numbers of vaccines provided (distributed) to veterinarians in all major cities within Serbia.  It is understood that the Republic of Serbia has paid a Dutch company named ‘Intervet’ for the legitimate, legal supply of all vaccines used in the Republic of Serbia.

‘Marlo Pharma’  of Belgrade were the organisation responsible for the importation (into Serbia) and distribution within Serbia of the vaccine (including needles etc) to all the specific veterinary institutes around the country.  The other organisation is called ‘Net Vet’, also of Belgrade; who have a permit for the importation of ‘Rabdomun’, a very similar Rabies vacine.   The registration of both vaccines detailed is undertaken by a state organisation named ‘Agencija za lekove’ – a public agency with responsibilities for both human and veterinary medicines.

The veterinary institutes around the country were then responsible for forwarding on – allocating / distributing the vaccine doses to the regional / local veterinary facilities, who would then be responsible for the vaccination of any animals requiring innoculation within their specific region.

The current arrangement is that all the veterinary stations involved in this programme, being those which are located throughout Serbia, each send a monthly report to the National Veterinary Institute and the Veterinary Department of Serbia, detailing specifically how many doses of the (Nobivac Rabies) vaccine they have given in their individual national region (municipality) for that (1 month) period.

As a result, once they have been supplied with the monthly information from the individual (municipal) regions, the Republic of Serbia (government) then finances (pays back) the individual regional / municipal  veterinary stations for undertaking their monthly vaccination work – ie. the administration of the dose of vaccine to animals by the vaccinator.

But, now, following campaigners investigations, the vaccination rules seem to have changed a little.

The alleged situation now is that Mr. Micovic, the Director of the government Veterinary Department, is personally demanding that veterinary stations undertaking the application of antirabies vaccines can now ask the individual animal(s) owner to pay for theapplication’ of the (Nobivac) Rabies ‘vaccination’ to their animal !

A conflict of terms it would appear to be, between ‘application’ and ‘vaccination’.

Individual animal owners are being told to finance a Rabies ‘application’ of the vaccine, whilst a Rabies ‘vaccination’ can be paid for directly from the national budget, without any cost to the animal owner.

This alleged ‘demand’ by Mr. Micovic is simply that, nothing more than a demand by him; it is not Serbian law / legislation, and is completely in opposition to the Serbian Veterinary law, Articles 140 and 141, which specifically state that antirabies vaccinations MUST BE FUNDED from the Republic of Serbia’s budget !

So, if the public are all specifically being asked (demanded via Mr. Micovic) to individually fund the ‘APPLICATION’ of the antirabies vaccination out of their own pocket for their own animal(s), where is all the money going which has been allocated and should be provided free of charge to Serbian animal owners by the Serbian Republic for exactly this same thing – in this case termed a ‘VACCINATION’ ?

We have concerns that the system now in place can allegedly lead to TWO individual charges and payments being made for every SINGLE (individual)  Rabies vaccine administered to animals; ie: we try to inform that:

1)                  The animal owner is individually charged by the regional veterinary station for the ‘APPLICATION’ of the vaccination; one payment made directly by the animal(s) owner;

2)                  Using the parallel system available, veterinary stations involved in the ‘VACCINATION’ programme, continue to send a monthly report to the national Veterinary Institute and the Veterinary Department of Serbia, detailing specifically how many doses of the vaccine they have administered to animals (ie. vaccinated) in their specific region / municipality for the latest (1 month) period. 

In each of the 135 cities within Serbia the prices being charged by veterinarians for the ‘APPLICATION’  of a vaccine to individual animals varies considerably.  It is 800 dinar in Belgrade, 500 dinar in Subotica, and 800 dinar per animal in Novi Sad, for example.

On 31/07/09, various telephone calls were made by SAV and Serbian campaigners to the European manufacturer of the anti Rabies vaccination at their contacts in both the Uk and Serbia.  In both cases, we were verbally informed that the re-vaccination (ie. Booster) times for animal species depended largely on the Rabies situation within individual nations. 

Reference to the vaccination manufacturers web site Data Sheet  states that the duration of immunity is 3 years, and that for dogs and cats, booster vaccinations only need to be given every 3 years after the primary vaccination. 

SOURCE – Nobivac Rabies – Data Sheet information detailed below:



Company name: Intervet / Schering-Plough Animal Health 

Address: xxxxxxxxx

Milton Keynes, England, Uk.


Telephone: 01908 xxxxxxx (Customer Support Centre)

Telephone: 01908 xxxxxxxx (Switchboard)

Fax: 01908 xxxxxxxx



Inactivated vaccine containing > 2 I.U. Rabies virus strain Pasteur RIV per dose. Also contains Aluminium phosphate as an adjuvant. 0.1 ml Thiomersal are added as a preservative.


For the active immunisation against rabies to reduce clinical signs and mortality.

Onset of immunity: an adequate serological response (> 0.5 I.U.) has been demonstrated 2 to 3 weeks after vaccination.

*** Duration of immunity: ***   3 years.    ***

Dosage and administration

A single dose inoculation of 1 ml is sufficient irrespective of size, species or breed of animal. Sterile equipment should be used for administration. Avoid contamination of vaccine with traces of chemical sterilising agents. Do not use chemicals such as disinfectant or spirit to disinfect the skin prior to inoculation.

Primary course and booster vaccination:

Dogs & cats

Primary vaccination age* 3 months or older
*** Booster vaccination every 3 years ***

————————————————————– Data sheet End ————–

As well as checks in the Uk, checks within Serbia undertaken on 31/07/09 can reveal that the national Serbian policy for Rabies re-vaccination is in accordance with the manufacturers guidance; ie. every 3 years

This 3 year re-vaccination period was verified by a very distinguished authority at the Serbian Faculty of Veterinary  Medicine via e mail on Thursday, September 03, 2009.  SAV and also Serbian contacts have copies of this mail as evidence should it be required in future.

Taking the individual Subotica ‘application’ charges of 500 dinar being demanded from each animal owner, and with almost 36,000 vaccine doses being provided to Subotica in 2008, does this not mean that there is a maximum potential of

500 dinar x 36,000 doses = 18,000,000 dinar to be made for ‘applications’.

The current exchange rate is approximately 1 Euro = 92 Serbian dinar.

500 dinar (Subotica charge) divided by 92 dinar/Euro = approximately 5.4 Euros per ‘application’ in Subotica.

=>    5.4 Euros per ‘application x 35,980 doses (2008) in Subotica = 194,400 Euros

 These are additional finances to the ‘vaccination’ funding being provided out of the state budget.

So, if the monthly paperwork is being submitted for the (state funded) ‘vaccination’ of animals in any region, whilst at the same time veterinarians are charging individual animal owners for the ‘application of a vaccine, one has to ask

So where is all the ‘application’ money going ?

– money which is being taken directly from the public for a procedure which, according to our information regarding Serbian animal welfare legislation, should be provided to veterinarians indirectly via the state budget ?

 To date, the Serbian government have declined to provide any responses.

This report and post is now being provided to Members of the European Parliament who have responsibilites with the EU Animal Welfare Intergroup –