At own initiative, the Slovenian Human Rights Ombudsman (HRO) tackled the issue of the use of phyto-pharmaceutical products (PPPs) as early as in March 2009. In this context, the HRO highlighted the potential detrimental effects of the adopted Decision on the Restriction of Trade in and the Use of Certain Phyto-pharmaceutical Products on the Territory of the Republic of Slovenia (Official Gazette of the Republic of Slovenia, No 12/2009), by way of which the 2008 Order on the Prohibition of Trade in and Use of Certain Phyto-pharmaceutical Products on the Territory of the Republic of Slovenia ceased to apply. Through the decision quoted, the Ministry of Agriculture, Forestry and Food (MAFF) adopted a decision on the exception that allows the use of certain PPPs. This apparently took place on the basis of tests carried out at the Agricultural Institute of Slovenia, and according to the risk assessment for bees at the EU level. Moreover, the MAFF took into account the relevant EU legislation, which sets out free movement of seeds and other agricultural products in the EU internal market.

In the light of the above considerations, the HRO at that time expressed doubts whether the MAFF's decision had really been thoroughly deliberated and informed the then minister of its view that the uncontrolled or insufficiently controlled use of PPPs could threaten the rights of individuals to health, healthy nutrition and healthy and safe living environment. Therefore, the HRO demanded certain explanations from the Minister.

In its reply, the MAFF took the view that the HRO's doubts are unfounded and that the free circulation and use of certain PPPs on Slovenian territory did not constitute a risk to the health of people, animals and the environment. However, this statement does not correlate with the recent mass bee deaths.