Tiny Timmy's Healing Journey

            Ever lust after those cool kitty hidey-holes but can't quite make the jump of spending upwards of $60 for them? Ikea Hackers has the perfect high-end solution with a little DIY needle & thread!!! IKEA Hackers: GOSIG cat nest.

This is an email I sent to NBC Philadelphia when they ran a story about the NEED to use flea and tick products through winter and year round. I have a sneaking suspicion since I have now seen several articles echoing the same thing that manufacturers are trying to blitz this talking point.

Here are the facts: In 2008 Spot-On products alone caused over 44,000 adverse reactions with 1600 deaths. In a study of bladder cancer, dogs showed an increased risk of 60% for bladder cancer with the use of a pesticide flea & tick product only once a year. The EPA themselves have said pesticide / chemical flea control should NOT be used year-round and should only be used when you have an outbreak, as a last resort, when all other methods of control have failed.

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To: tips@nbcphiladelphia.com

Hello,

My name is Claudia Tietze and it has recently come to my attention that your station ran a 3 minute piece about the need for flea & tick products year round for pets. I run TinyTimmy.org, an educational forum on harmful flea & tick products that damage and kill literally TENS OF THOUSANDS of companion animals each year. TinyTimmy.org is named after our cat, Tiny Timmy, who we rescued in September of 2009. At the time we were told he had a "muscle disorder", however when we picked him up it was clear that something else was terribly wrong. He now has neurological damage from his exposure to flea & tick products. You can learn more about Timmy's story here http://www.tinytimmy.org/timm

Tiny Timmy has a reach of approximately 50,000 supporters across the globe, primarily in the US. His website receives about 5,000 hits per month and growing. This is a topic that is incredibly important as it not only effects pets but also your family. Many ingredients are already restricted for home use due to the significant dangers to human health, yet they sneak into our homes and near our children in pet products.

Last year, CBS ran a fantastic investigative piece that was picked up in many markets on the dangers of these products. This year, ABC has run an even more in-depth piece that you can find here. http://www.newsnet5.com/dpp/money/consumer/consumer_specialist/flea-and-tick -products-under-fire-from-pet-owners-vets-say-the-pesticides-are-safe

Considering the undeniable evidence of the harm that these products cause and that safer alternatives are readily available I am wondering where you got the information for your news story? In fact, had you relied on any sources other than manufacturer's and industry trade organizations, you would have discovered that even the EPA, who regulates these products as they are PESTICIDES not medications, has stated they SHOULD NOT be used year round due to the risks to pets, people and especially children. The EPA recommends ONLY to use these products WHEN you have an outbreak and ONLY WHEN other forms of control fail.

In the light of this information, I would humbly ask for you to run a piece showing the pain, suffering and cost to the pet owner. What would you think if a human product killed 4 people EACH DAY? Just because you are talking about pets does not mean this is a light topic.

Thank you for your consideration. Please feel free to contact me either via email or phone anytime xxx-xxx-xxxx

Yours,

Claudia Tietze

--

~ Under Secretary for Timmy Affairs, Division of the T.O.Y. Army

As you know, Aundria Arlandson (the owner of Oliver who passed from CRF after use of flea powder), Amy Entz and I headed to Washingon again this year to meet with the EPA, lawmakers, do outreach and talk to anyone who will listen about harmful flea & tick products. Please excuse the delay in publishing these notes of our EPA meeting, but Timmy has not been well and neither have I. The trip to DC was both wonderful and frustrating. Wonderful because we uncovered many things that will help us in the future and frustrating because we did not accomplish all that we wanted to. There is so much ground to cover in sharing with you our DC experiences that I am going to have to break it down into many different posts. Here are some of the notes from the meeting with the EPA. Without your help & support, we would never have been able to accomplish these wonderful things! Thank you for Being The Wave!

1. The EPA has agreed to allow us to meet yearly (or more often).
2. They will be looking into implementing a self-reporting portal much like the veterinarian portal. HUGE WIN. This means that the EPA would not receive “filtered” data from manufacturers who have been fined for under-reporting or mis-reporting the severity of incidences. The information would come directly from you, the consumer and end user.
3. We brought up Assurity for Cats because we got the studies from a Freedom of Information Act Request and they were horrifying. The studies for cats and kittens had to be stopped early due to too many of them dying. As far as I know, they have not had to submit new studies with the whole formulary. The EPA is doing a data call in (where the manufacturer has to submit information when it is requested) for Assurity and will pay extra close attention to the reported incidences. If they seem miniscule, they will ask for more information. There is reason to suspect under-reporting/no-reporting based on the number of complaints I have gotten on TT's website. (Mostly skin lessions and hair loss.) As a side note – Assurity for Cats is sold only through veterinarians and we also discussed how the sales representatives portray it to vets. I've heard numerous reports of Assurity being billed by reps as "the only totally safe all natural" flea & tick treatment for cats.
4. The EPA will also follow up on whether or not the entire formulary of Assurity  has been tested and what those results were (if it was done). If it has not been done, they will mandate it to be expedited. They were very concerned over this product and the feed back they have gotten from TT's site - although they seemed to think that the EPA has not seen any higher-than-expected reports. This might be because it is a fairly new product.
5. They will provide us with aggregate numbers of adverse incidences for 2008, 2009, 2010 and 2011 to date. I explained the 39,000 figure for adverse incidences from 2009 was not calculated the same way as the 44,000 from 2008 and so they really in all honestly can't claim the reports are lower. This way we can compare before it has been filtered and altered. These alterations have been an issue in an accurate view of the vastness of the adverse incidences that are reported by manufacturers and their agents to the EPA who then compiles it all. For example, I learned early on to take screen shots of anything important. The first time I found the information on adverse reactions for 2008, the EPA stated 1600 deaths. The second time it was 1200 and now it is 600. That’s a huge difference and the only way to get a clearer picture of the patterns is to have this data.
6. We discussed the conflict of interest of the ASPCA (again). The ASPCA runs the Pet Poison Control Hotline, but they are paid by flea & tick manufacturers (registrants in EPA lingo) for a variety of services, including handling the incident reporting. They also regularly testify in court on behalf of manufacturers against the people who have issues with their products. Now with their backing of Pet Armor and the $6 million + they earn from registrants and manufacturers each year it has become a ridiculous situation. I got the impression that based on my report of it on TT's site that they already were looking into this - but this why they were so receptive to the idea of an EPA based reporting portal. I also stated it would save them money and scrutiny from the public. (They would no longer have to pay the ASPCA for reports of results and people would feel that they were treated better as far as their voice being honestly heard.)
7. I also brought up that they would be able to truly assess the pros and cons of flea & tick products with a public reporting portal and would be able to see a pattern of any manufacturer or registrant under-reporting or failing to report. Legally manufacturers have to report all adverse incidences quarterly to the EPA.
8. We followed up from last year’s meeting, of course.
9. The EPA are looking into making it straight across the board of a cat product saying not for dog use and vice versa. They said this is in the works, but it "takes time". This is what they said last year too, so I asked how much time is reasonable in EPA-land. There were reports of a dog product not carrying such a warning and when it was followed up on, the EPA product manager said it was “not necessary”. This is a conflict to their 2008/2009 mitigation plan and was brought to their attention.
10. We brought up the experience pet owners whose pets have suffered adverse reactions having their claims dismissed straight away, with registrants (or their agents) insisting either their product doesn't cause adverse reactions or that it must be something the dog/cat ate, yada yada.

Follow up on your concerns:

•    The EPA is working on the new labeling (still) and they are voluntarily asking registrants to add inert/inactive ingredients. What I have found is that instead of calling the “invisible” inert ingredients “inert” that many packages now say “other ingredients” and still do not list them. Legally they can claim these are a “trade secret” and so protected information. •    Part of their review will be of font size so that important information will not be in ant print that hardly anyone can read or if they can read it, it’s a struggle. •    I have had 4 reports from vets stating that Assurity for Cats is being marketed to them as “the only totally safe” product against fleas for cats. We discussed this and it was the EPA’s belief that unless this statement is made in writing as part of their marketing material, there is not much that can be done with it, although it is clearly illegal. •    We asked if there was anything that could be done about manufacturers regularly claiming their product is “safe when used as directed”. They are not allowed to make this claim, yet regularly do in the form of public statements and responses to news stories. Again, it falls into the whole “is it part of their printed marketing materials” for the EPA. I made the point that if someone is charged with being a public mouthpiece for a corporation that their statements become a de facto part of their marketing, just as those who speak for the EPA are also help accountable for their statements. •    Q: I would be interested in why they have not educated the public about the dangers of these chemicals and components and investigating and studying alternatives to using these chemicals so that they are safe  A: The EPA has added a short list of alternatives (vacuuming, flea combing, washing bedding, etc.) on their website. They have a Green Chemistry initiative to find safer alternatives to the old and more toxic chemicals and pesticides on the market. •    When are the comments to the EPA’s Mitigation Plan going to be addressed. (The answer then was by the end of the month, and now is that they have been released, but are disappointing.) •    The packaging on the Frontline generic, Pet Armor, looks deceptively like the Frontline packaging using similar coloring, layout and fonts. A: They will look into it. •    Q: An observation about how important these issues are to people who do not 'own' their pet, but regard them as a valued member of their family and health support network brings in the... human factor. The impacts of these problems can also adversely impact the service animals (as defined in the ADA) and their partners if the toxicity levels exceed a changed threshold due to issues with the person's immunity, neurological health, etc. [Relating to the impacts of the Body of Burden calculations, other pets in the household, children, senior citizens, etc.]  A: Sadly we were not able to go into this much detail with this point. It’s an excellent point and perhaps a tactic we need to pursue in the future. We did talk about health risks, but sadly that point seemed to be dismissed with the statement that they have set calculations for that measurement. The issue with their “set calculations” are they are woefully inadequate and change from product to product.  

Thank Yous

Without you, supporters and friends, this trip could not have happened. It happened because we all pulled together, donated items, time, air miles, hotel points, gift cards, sharing and tweeting and told your friends. This is about YOU and without you, we would just be one ripple. With you we are a giant wave, gaining momentum. Also, I would like to thank all those who helped us in DC, including the EPA who agreed to meet with us again this year, Melissa Jo who helped us decorate Timmy Stones all over the Capital, William Lee who is filming a documentary about our Journey and Karma Hurworth who went to great lengths to have Tiny Timmy Cookies sent in time for our meeting with the EPA. (Sadly, the meeting was moved up and so we missed the cookies!) Rebecca Slattery-Kavanagh for EVERYTHING and running the Timmy Stones Project. Mimi Pipino of Catching Lizards and Denyse Romero of Crafting for Critters for ongoing support of profits, moral and emotional support. Deb Lavoie of Crafting for Critters whose heart always amazes me. . Maike and the Milty Project for making Timmy a Milty Pet and helping his Healing Journey. Ana from Meow.com who would not quit sharing the word until she knew we were set for our fundraising goal. Tamar from IHaveCat.com who always amazes me! Chitari Foundation for their support and sponsorship. Pam & Robin who donated a large amount of items for fundraising auctions.  There are far too many people and organizations to thank everyone. Just know that you are all amazing and appreciated even if I have not mentioned you by name!

Many thanks to the Emmy Award winning investigative journalist, Jenn Stratham at WEWS in Ohio. She covered the issue of harmful flea & tick products with incredible finess. See for yourself! If you are a Twit - and by that I mean one who Tweets - join the conversation on Twitter by using hashtag #wewspets [If the video below does not work, you can see the article & video here as well.] .  

The trip to Washington, DC to help educate government officials and the general public went very well despite many frustrations. I will post a few updates since there is a lot to catch you all up on. I have been sorely absent here and on Facebook & Twitter for a while post-DC. As many of you know I have a chronic illness that effects my energy. Even after such a short trip and all the preparations prior, I crashed upon returning home. I am slowly starting to come back out of it and so hope to be more visible again soon. The plus is I have best kitty, in Timmy, on Cuddle Patrol when I spend days on end in bed, unable to move or to move very little. In my absence and the days leading up to the trip to Washington, DC, much has happened. Some important deadlines were missed, such as the open comment period over at the Federal Register for the EPA review of permethrin. Permethrin is one of the ingredients found in the flea spray FOR CATS that was used on Timmy and in the flea powder used on Oliver. Permethrin and derivatives in many different names are found in the majority of flea & tick products. Usually they are listed as pyrethrins or have complex names primarily ending in -in or -rin on the packaging. Here are a few more up-to-date things happening in the world: The EPA's Human Studies Review Board is hosting a two day on-line Internet TV webcast of their October 2011 meeting which is open to the public. Here are the details if you wish to attend: October 19-20, 2011, live from the EPA in Washington D.C.  This live video webcast event is free, open to the public, and will be accessible at this URL. The agenda for this two-day event is also available at this site. The event will go from 10:30 AM to 5:00 PM ET on Wednesday, Oct. 19 and 9:00 AM to 3:45 PM ET on Thursday Oct. 20. Personally, I will be interested to see who is going to be there from industry. Usually these "boards" have more industry representation than environmental groups. And yes, the government does track human studies, although this includes exposure to things like pesticides sprayed on crops and monitoring farm workers and their health concerns. The most exciting thing is an online database on inert ingredients from the EPA. KUDOS! ... Well sort of. The database does not associate inerts with the products that carry them, so it doesn't help you as a consumer make educated decisions. But, you could pop the EPA a comment on this "flagship" project and ask them to list intert ingredients for pet products, particularly flea and tick products,  and tell the EPA that this is necessary for you as an educated consumer. These products are not just on your pet, but expose yourself and your family to potentially dangerous amounts of toxic, carcinogenic and endocrine disrupting chemicals and pesticides. Here is the info on the new database: Office of Pesticide Programs Launches Online Searchable Database of Inert Ingredients Approved for Use in Pesticides EPA's Pesticide Program has released a new online searchable database, called Inert Finder. This database allows pesticide formulators and other interested parties to easily identify chemicals approved for use as inert ingredients in pesticide products.  It will allow registrants developing new products or new product formulations to readily determine which inert ingredients may be acceptable for use as well as making this same information more readily available to the public.  Users can search for inert ingredients by chemical name or Chemical Abstract Service (CAS) Registry Number to determine whether inert ingredients are approved for products that have food or nonfood uses.  Search results will also provide any applicable use limitations and will flag inert ingredients for which companies have asserted data compensation rights. Inert Finder was developed in response to a longstanding need expressed by the regulated community and others for a resource that consolidates the several lists of approved inert ingredients into a readily searchable format.  For food use inert ingredients, Inert Finder includes links to the Code of Federal Regulations, which is the legal record regarding inert ingredients that have exemptions from the requirement of a tolerance for residues on food.  The system does not include information about ingredients in individual pesticide products. You may access inert finder at http://www.epa.gov/pesticides/inertfinder.  EPA welcomes your questions or comments about this new tool.  Please email them to the Inert Ingredient Assessment Branch: inertsbranch@epa.gov. The home page for InertFinder includes a link to another online searchable database called the Chemical Data Access Tool, which allows users to find health and safety information submitted to EPA under the Toxic Substances Control Act (TSCA) at http://java.epa.gov/oppt_chemical_search/.

As some of you know, I suffer from a chronic illness. Why do I mention this? Well, because it means I cannot dedicate as much time sometimes to this site as I would like to do. It means that I post not-so-frequently. I hope when I do post, however, that it is valuable to you. Here is some "mews" and updates: In an effort to come up with a viral way of sharing Timmy's story and tens of thousands of other dogs & cats in the US (and across the globe) we have come up with the idea of Timmy Stones. These stones are decorated by the volunteers of the T.O.Y. Army (Timmy, Oliver & YOU), who live around the globe. We decorate the stones and send them to anyone who wants one. These stones are placed all over the place. When they are placed, we log the stone location on our map. When others find them, we hope they will follow the TimmyStones.com written on the back and let us know where they found them, also placing the location on our map. Why Timmy Stones? The idea is that Timmy Stones, shared in this Viral Social Geo-Caching way will open the conversation about harmful flea & tick products in a fun, interactive way with people who we would normally not have contact with. Also, we can better evaluate our reach this way. We have VERY EXCITING NEWS about our trip to Washington DC this year!!! We have confirmation that we have a documentary film maker who will be interviewing and filming us while there. We have a news crew (hopefully). Aundria has an interview next week sometime. We have several other supporters joining us this year. We have a meeting already scheduled with the EPA to continue last year's discussion. And we will find out next week about other meetings, including the White House. We still need your help to get there. If you can spare $5 to help, please do so. We have a ChipIn here. Also a special thank you to Anna at Meow.com for donating 5% of all profits from this weekend's sales to get us to DC! The trip to our Nation's Capital is coming up so quickly! There is much preparation. One thing for certain, we will get there and make a difference! Leave a comment with any issues you would like specifically addressed. We have been very fortunate to have this open communication with the EPA. These people do not have an easy job and change takes a long time. However, there genuinely seem to be people within the ranks who understand the issues or who find our input as "people on the streets" valuable to their decision making process and understanding of the issues and how the public views the situation. We are very blessed that they have spent so much time with us in last year's meeting, have accepted another meeting this year and have spent quite a bit of time with us answering questions and having conference calls where necessary throughout this past year. A small bit of mews... We have new soap packaging, which I will be posting as soon as it's finalized. In the past it often has taken quite a while to get soaps out in some cases. This is because we do not do this as a business and make no money from it. However, we understand that people who order soap for their pets usually wants it yesterday, so we are streamlining our process so we can be more nimble getting them out. I saved the BIGGEST MEWS for last! I am proud to tell you that the Chitari Foundation has taken Timmy Tour and our educational efforts under its wing! Chitari means "meeting place". The Foundation is in the process of creating a truly integrative, health-centered approach to healthcare and plan to build a hospital to heal people based on an inter-disciplinary and integrative team approach. One of the focuses of Chitari is to minimize toxins in the home. Since flea & tick products used on our companion animals also effect people, and deposit "unacceptable" levels of harmful toxins into the home environment, this was a wonderful fit!

Last year Aundria Arlandson and I went to Washington DC to discuss harmful flea & tick products and their dangers to pets and people with those who can make changes to the laws. We met with Directors at the Office of Pesticide Products at the EPA who regulates these products. We did outreach on the streets, speaking to people one-on-one. We visited politicians. We were heard. This year we are returning to Washington DC for a longer time, from September 4th through the 10th. Please help us get there. One dollar makes a huge difference. If you can't contribute money, then please share with your trusted circle of friends and ask them to do so. This year all your contributions are tax-deductible due to 501(c)(3) status. Help us be your voice.


 

All great things start with the first step. How many times have you heard this? I believe that we all can make small effective changes, in the form of ripples, with very little effort all around us. That once we have enough ripples, a Tipping Point is reached and we create a wave from sheer critical mass. BE THE WAVE.

Please keep in mind that even if a pesticide product (yes, flea & tick treatments are pesticides, not "medicine") is cancelled, often manufacturers are allowed to sell through their existing stock, or have a cut-off day for a halt to production in the future. This means some of these products might still be available sometimes for years. Table 1--Registrations With Pending Requests for Cancellation EPA Reg. No.                            Product name                                                          Active ingredients -------------------------------------------------------------------------------------------------------------------------------------------------------- 002596-00132                 Hartz Sumithrin Carpet Powder.                                    . MGK-264 Sumithrin. 002724-00697............................ Permanone H&G Insect Control... Permethrin. 004822-00531............................ Raid 1000...................... Triethylene glycol. 006959-00082............................ Cessco Accudose Aerosol Pyrethrins Piperonyl butoxide. Insecticide. 047000-00171............................ SMCP Pyrethrum Dust 1%......... Pyrethrins. 061483-00086............................ 10% Permectrin Pour-On Permethrin. Insecticide. 080490-00002............................ Promeris Spot on for Dogs...... Amitraz 4-{(2Z)-2-({[4-(Trifluoromethoxy)Anilino]Carbonyl{time} Hydrazono)-2- [3-(Trifluoromethyl)Phenyl]Ethyl{time} Benzonitrile Metaflumizone. 080490-00003............................ Promeris Spot on for Cats...... 4-{(2Z)-2-({[4-(Trifluoromethoxy)Anilino]Carbonyl{time} Hydrazono)-2-[3- (Trifluoromethyl)Phenyl]Ethyl{time} Benzonitrile Metaflumizone. 080490-00004............................ Promeris for Dogs--Flea Control 4-{(2Z)-2-({[4-(Trifluoromethoxy)Anilino]Carbonyl{time} Hydrazono)-2-[3- (Trifluoromethyl)Phenyl]Ethyl{time} Benzonitrile Metaflumizone. 087650-00001............................ Fipronil Technical............. Fipronil CA ***NOTE: Fipronil is the active ingredient in Frontline & a host of "new" generics - use the search feature to find out more about Fipronil*** COMPANY CONTACT INFORMATION This unit includes the names and addresses of record for all registrants of the products in Tables 1, 2, and 3 of this unit, in sequence by EPA company number. This number corresponds to the first part of the EPA registration numbers of the products listed in this unit. Table 4--Registrants Requesting Voluntary Cancellation EPA Co. No.        Company name           address 2596             The Hartz Mountain Corp., 400 Plaza Dr., Secaucus, NJ 07094. 2724 2724             Wellmark International, 1501 E. Woodfield Rd., Suite 200 West, Schaumburg, IL 60173. 4822             Fort Dodge Animal Health, 7000 Portage Rd., KZO 300-403 SW., Kalamazoo, MI 49001. 81598           Fipronex Solutions, Inc., AGENT: Technology Sciences Group, Inc., 1150 18th St., NW., Suite 1000, Washington, DC 20036.

Here's the first teaser for this year's DC trip where we will meet with the EPA and other decision makers! The date says in the video August 2011, but it's been moved to September.  

Timmy's new widget that shows his YouTube Channel. Help spread the word!  

Below is my full letter, submitted to the EPA during the Open Comment Period regarding a petition from the NRDC requesting the ban on retail sales of flea collars containing propoxur. Thank you everyone who took the time to comment to the EPA on the Federal Register. They use these comments to make regulatory decisions, so it is very important that they hear from us, even if it is only a few lines.

Portland, Oregon || t.timmykitty@gmail.com || Phone (503)ITZ-TIM1

June 25, 2011

  Re: Docket EPA-HQ-OPP-2009-0207; FRL-8875-1 - Petition Supplement Requesting Cancellation of Propoxur Pet Collar Uses

  Dear Lisa Jackson, the EPA Office of Pesticide Products and EPA Staff:

I am writing to you today as a concerned citizen and pet owner.  I am also writing in representation of over 50,000 supporters across the nation, including over 100 dedicated volunteers, and TinyTimmy.org. TinyTimmy.org is an ambitious effort to educate pet owners on harmful flea and tick products and an advocate for safer alternatives. In the past 30-day period, TinyTimmy.org has received 4,767 hits from other concerned pet owners and veterinarians looking for accurate information on flea and tick products. The site is named in honor of my cat, Tiny Timmy, whom my partner and I rescued in September 2009 while he was in the throes of a toxic reaction to flea spray designed for use on cats. Despite the use of the flea spray on Timmy, we still pulled over 350 fleas off of his tiny body through flea combing and bathing him. We rushed him to the vet who believed he would not live 48 hours due the severity of this reaction to his exposure. Thankfully, he survived, however he is left with neurological damage. Our experience with Timmy, watching his struggles and triumphs, led us to educate ourselves, and tens of thousands of pet parents, about these harmful products and safer alternatives.

It is my belief that flea collars for dogs and cats containing propoxur, and other companion animal products containing carbamate pesticides, pose an exceptionally high risk to companion animals and their human owners. These propoxur collars should be banned for companion animal use to protect the health of our pets, their owners (especially children) and the environment. The EPA can no longer look at regulation as a calculation of adverse incidents (which do not take into account long term health consequences) vs. economic damage to registrants. This type of regulatory enforcement allows manufacturer interests and profits to be protected with little to no attention to the true and accurate danger to companion animals, human health and environmental long-term impact. The EPA must also look at the economic cost of the extreme health effects to companion animals and humans. The cost of the endocrine disruption and carcinogenic properties of propoxur is much higher than the profits lost over flea collars sales benefitting registrants, retailers and distributors. There are safer, more effective alternatives to propoxur collars.

According to a global study performed by the American Cancer Society and LIVESTRONG released in August of 2010, the global cost of cancer surpasses all other conditions and illnesses in economic loss. Cancer had the greatest economic impact from premature death and disability of all causes of death worldwide. The study found that cancer has a 20% higher economic toll than the second leading cause of economic loss – heart disease. The economic loss from cancer globally is $895 billion, which does not include direct medical costs such as prescriptions and cancer treatments.

It’s estimated that the cost of endocrine disruptors to the US and Canada, taking into account only four environmentally related diseases (Parkinson’s Disease, neurodevelopmental effects, hypothyroidism and deficits in IQ) is an estimated $392 billion per year.

Industry has taken offense to the first-of-its-kind study performed by the NRDC, documented in the April 2009 paper, Poison on Pets II. This study showed that “high levels of pesticide residue can remain on a dog's or cat's fur for weeks after a flea collar is put on an animal.” After three days of use, propoxur collars had deposited higher than acceptable levels into the home environment. Residue levels from some flea collars were 1,000 times higher than the EPA's acceptable levels, specifically for tolerances set for the burden of chemicals for developing children. There was no accounting for the burden put on our companion animals, whom these collars supposedly “protect”, however due to their size and grooming habits, it can be assumed to also be incredibly higher than the amount the EPA has calculated as “acceptable”.

Whether or not registrants are offended by the NRDC study or its methods is irrelevant. The EPA has known of the danger of propoxur for at least 16 years. This long-held knowledge by both industry and the EPA led to the cancellation in 2007 for residential uses that exposed children to propoxur. In May 2010, EPA Administrator Lisa Jackson wrote to Governor Ted Strickland stating:

… the pesticide Propoxur could pose health risks for children, harming their nervous systems.

To allow propoxur to then continue to come into our homes via the route of flea collars on our pets is counter to the intent of the original cancellation and a severe breach of public trust.

Further, in a study conducted by the National Cancer Institute, propoxur is thought to increase the likelihood of developing non-Hodgkin’s Lymphoma and highly indicated in leukemia of offspring. In Volume 111, Number 4 of the April 2003 issue of Environmental Health Perspectives, in the article Cancer and Developmental Exposure to Endocrine Disruptors, it was clearly stated:

The carbamate pesticide propoxur is one environmental chemical identified where exposure was highly correlated with leukemia in offspring.

This article was co-authored by Linda S Birnbaum and Suzanne E Fenton from the Experimental Toxicology and Reproductive Toxicology Divisions, National Health and Environmental Effects Research Laboratory, Office of Research and Development of the U.S. Environmental Protection Agency. Thus, the EPA has been well aware of this harmful tendency of propoxur for years, yet has continued to allow its use in flea collars which are marketed by registrants as “safe when used as directed” and as a “public health” service.

Propoxur is classified by the EPA as a probable human carcinogen (in Group B2) and a cholinesterase inhibitor. The State of California classifies it as a known human carcinogen and the EPA ought to follow suit. Propoxur is believed to be an endocrine disruptor, which have significant effects on the health of humans and our pets. Endocrine disruptors are unique in that minimal exposure levels cause long-term problems with the hormone-producing endocrine system in mammals. Children and toddlers are especially susceptible to these effects as their systems are still growing and developing and their unique habits, such as hand-to-mouth contact, playing on floors, hugging pets and sleeping with pets.

Exposure to propoxur-type chemicals is cumulative and although acute exposure might resolve in a few hours, there are considerable studies that links exposure to long term neurological damage. Carbamates, including propoxur, are known to block acetyl cholinesterase production, which is an enzyme that allows nerves to transmit impulses. Manufacturers continue to staunchly claim that pet products containing pesticides are “safe when used as directed”. That is simply untrue and it is universally known to be untrue. The EPA has not stopped this practice of deceitful marketing by registrants of pet products.

Since propoxur was first introduced into the US market in 1963 by Bayer, registrants have had ample time to complete long term and short term exposure studies for flea collars used in the home environment on companion animals using realistic real-life exposure scenarios, particularly for children and toddlers. Perhaps if industry had used the past 38 years to carry out similar studies to the one the NRDC undertook, they would not be moaning about the NRDC study now. Things need to change in order for citizens to rely and trust in the regulatory process again.

It is our belief that for the healthy life of both companion animals and their owners, that fleas and ticks must be treated against. However, continuing to use carcinogenic and endocrine disrupting chemicals is not the answer. Fleas especially are building immunity to these chemicals. There are safer alternatives to these harmful products and the NRDC mentioned a few of them: Flea combing, washing bedding, bathing your pet and vacuuming. Registrants, with an economic interest, not a health-interest, in these products will tell you that these “alternatives” do little to nothing in order to fight a “bad outbreak” (please see the letter included in public comments on this docket from manufacturers). This is simply not true. Registrants do not market flea and tick products to combat an occasional “bad outbreak”. They are marketed to consumers and veterinarians to be used year-round regardless of where the pet resides or their habits (indoor/outdoor).

The best alternatives are those that are not chemical in nature, but mechanical. Other alternatives include the use of diatomaceous earth in yards and in the home, which is extremely effective as the microscopic diatoms scratch the waxy surface of fleas and ticks and they become desiccated. Beneficial nematodes in the garden and yard eat flea larvae and thus stop the cycle of reproduction. Flea traps lure fleas using heat and light, and sometimes pheromones, onto a sticky pad from which they cannot escape. The others were already mentioned by the NRDC.

I humbly request, on behalf of over 50,000 concerned pet owners, that the EPA step in and put an end to these abuses by industry and cancel all pet applications using propoxur immediately. Administrator Lisa Jackson thought this topic important enough to list as her number three priority on her Top Seven Priorities:

One of my highest priorities is to make significant and long overdue progress in assuring the safety of chemicals in our products, our environment and our bodies.

In order to see that priority become a true reality, the EPA needs a dedicated department solely created to assess companion animal products and their unique and intimate residential use. As of today, there is still no one sole contact for this position. Last year the position was blank, and this year it has disappeared altogether from the EPA OPP contact list posted on the EPA website.

Reviewing the prior knowledge of the EPA regarding the dangers to humans, children and companion animals of the use of propoxur products, I am left with one question. How can a regulatory agency not take action in the face of the knowledge they have had, and made public, for over a decade? Based on your own knowledge and the vast volume of legitimate studies, the EPA has no choice but to ban these harmful pet products from the consumer market.

Yours,

Claudia Tietze
TinyTimmy.org
(503)ITZ-TIM1