BACKGROUND:

Deadline extended – Draft indicators for America’s Children and the Environment, Third Edition (ACE3) available for public review and comment

EPA is preparing a third edition of America’s Children and the Environment (ACE), following the previous editions published in December 2000 and February 2003. ACE is EPA’s compilation of children’s environmental health indicators and related information, drawing on the best national data sources available for characterizing important aspects of the relationship between environmental contaminants and children’s health.

EPA has prepared draft indicator documents for ACE3 representing 23 children’s environmental health topics and presenting a total of 42 proposed children’s environmental health indicators.  Several new topics of importance to children’s environmental health have been added to ACE3, and topics included in the previous editions have been extensively revised and updated.

EPA is interested in your comments on the draft indicator documents for ACE3. These draft documents are being circulated only for purpose of obtaining comments, and should not be construed to represent any agency determination or policy.  EPA will consider the comments and other information provided to EPA through this public review and a simultaneous peer review by technical experts in deciding whether to make revisions to the indicators or other elements of the draft indicator documents. EPA intends to publish the final ACE3 report in 2011.

The deadline for submitting comments has been extended by 15 days.  Comments will be accepted through April 21, 2011.

You may view the draft indicator documents, instructions for submitting comments, and further information about the ACE3 process at:
www.epa.gov/ace – please follow the link at the top of the page for ACE3 Draft Indicators.  Or you may go directly to the ACE3 page at:  www.epa.gov/ace/ace3draft.

TinyTimmy.org Comments:

To Whom It May Concern:

My name is Claudia Tietze and I represent approximately 50,000 supporters who include concerned citizens, parents and pet owners. TinyTimmy.org is an ambitious effort to help educate pet owners on harmful flea and tick products and advocate for use of safer alternatives. Thank you for allowing TinyTimmy.org to respond with suggestions to ACE3.

Sadly, labels do little to educate pet owners on the true dangers of these products, brought intimately into our homes, and particularly the risks to children, especially toddlers, from these products.

This is a message I recieved on our website, which has a page that allows people to light virtual candles for those harmed by flea and tick products. “We would like to light a candle on behalf of our daughter, Reeses Marie Meyer, who is currently struggling to overcome Sentry products. We would like to light this in hope that our family can find strength to help her fight a good fight and stay strong like mom and dad tell her every day. She is our light and a blessing. Mr & Mrs. Meyer” Reeses Marie is not alone. There are numerous accounts of children being harmed  by flea and tick products designed for use on companion animals. Most of these adverse reactions are settled privately and so little comes to public light. This should never happen. These parents should have been informed, prior to use of the Sentry companion animal product, of any and all risks to children.

I believe that ACE3 is a step in the right direction, however was incredibly saddened to see that companion animal flea and tick products were minimally addressed.

Considering that these products, in the form of collars, sprays, spot-on/drops/squeeze on, shampoos, mousse, powders and dips leave residue that is widely unmeasured in the home environment to date and due to the habits of children, particularly toddlers, the exposure to these pesticides is very intimate and has been shown to be incredibly high. For example, the NRDC has submitted a petition to the EPA requesting immediate cancellation of certain flea collars. They were incredibly concerned about the use of flea collars on companion animals, particularly those containing propuxor and tetrachlorvinphos in their active ingredients. These are both considered neurotoxins to mammals and known to be carcinogentic. These collars and their active ingredient chemicals pose risk of damaging the brain and nervous system of humans, especially toddlers, as well as the pets that they are used on.

You can read the NRDC press release from April 23, 2009 http://www.nrdc.org/media/2009/090423a.asp

Here is an excerpt (my highlights):

…tested the fur of dogs and cats wearing flea collars to measure the invisible pesticide residues left on the pets from these collars. This analysis, which was the first study of propoxur residues on pet’s fur, found that propoxur levels are so high in some products that they pose a cancer risk in children that is up to 1,000 times higher than the EPA’s acceptable levels, and up to 500 times higher for adults. The study also showed that after three days, 100 percent of the pets wearing collars containing propoxur and 50 percent of the pets wearing collars with TCVP posed a significant neurological risk to toddlers. Testing also revealed that unsafe levels of pesticide residue remain on a dog’s or cat’s fur two weeks after a collar is put on an animal. Families with multiple pets that wear flea collars have even greater exposure risks.

Many flea and tick products for companion animals contain heavily restricted pesticides or those cancelled for other household uses, yet remain in the home environment through the application on our companion animals, in our homes and in our yards. Often the carriers are more of a concern, such as the use of benzene, which is not required to be disclosed by claiming an entire formularly is CBI.

The flea and tick products regulated by the EPA do not have adequate aftermarket surveillance in place. Pet products are only required to submit fairly short term studies regarding acute toxicity and the potential for long term issues often goes disregarded by the registrants when reports are submitted to the EPA regarding adverse reactions. For example, there is no way to currently measure the increases in certain cancers or other health issues to humans, toddlers and companion animals from the use of such products. There have been no submitted tests or statistics that I am aware of submitted to the EPA from manufacturers, although there are such studies showing an increase of bladder cancers among dogs who are treated as little as once per year with such topical flea and tick products from non-industry sources.

Many of these companion animal flea and tick products contain ingredients that are known endocrine disruptors, particulatly to children whose systems are still developing and due to their habits, increase their exposure risk. TEDX – The Endocrine Disruptor Exchange, has compiled a large number of studies on permethrin, for example, and it’s effects found in scientific studies. Permethrin is a very common ingredient found in many pet products as well as house sprays, foggers and similar products to fight insects in general, particularly fleas and ticks. You can find the link to download the raw data and charts here http://www.endocrinedisruption.com/pesticides.permethrin.spreadsheets.php

It is, of course, alarming that children are exposed in schools and day care centers to potentially high levels of pesticides, however it is more alarming to me that parents, believing they are being responsible and good pet owners, bring such intimate contact to these potentially devastating pesticides into their homes. Labeling of these products does not allow a pet owner to make educated decisions as they do not include a complete list of known adverse reactions, nor the dangers that may be caused to humans and children, let alone to their companion animals. Owners mistakenly believe that if these products are available on store shelves that they must  have a high margin of safety. This is completely untrue and, again, long term testing is inadequate.

Registrants have a vested interest in not completing more thorough studies, particularly to the exposure risk that children and especially toddlers face from their products. In order for the EPA to get accurate information regarding the risks to children and toddlers, the EPA must implement other measures of acquiring such studies. I recommend that registrants pay into a pool either a small percentage of their profits, or what they would normally invest in such studies, and that the pool is governed by an independent organization with no relations to the pesticide or chemical industry. The purpose of such a pool would be to stimulate studies that are more impartial and still take the burden of the cost of studies out of the budget of the EPA.

It is naive and reckless for the EPA to continue to rely solely on industry backed studies for toxicology and environmental information. This has been shown over and over to harm the environment, human health, and wild life. I understand that the EPA must follow certain guidelines and legalities put in place since the 70’s that benefit industry and protect profits. However, human life, particularly that of our legacy in the form of our children, is more precious than another million here or there. The EPA should create an incentive program for registrants to explore and market known safer alternatives in the fight of fleas and ticks (and other pests found in agriculture and in schools and daycare centers) such as diatomaceous earth. Patents could be given in the form of novel and new application methods of such safer alternatives.

It is my opinion that ACE3 is a step in the right direction, but that pet products for use on companion animals have not been given the attention they ought to have, particularly the exposure these products bring to our toddlers and children.

My recommendations are as follows and none require “re-inventing the wheel” – meaning all pertinent resources are already present:

  1. The use of now available computer models that accurately predict long term toxicity in humans, children, toddlers, companion animals, wild life, the environment.
  2. Clear labels on pet products that state, much as prescriptions for humans do, known health risks from both acute and chronic exposure, to companion animals, human adults, children and toddlers from active and inert/inactive ingredients and entire formularies of pet pesticide products registered by the EPA.
  3. A fund, seeded by industry by either a small percentage of profits or what industry has traditionally paid for studies in one year, administered by a non-industry panel which includes concerns citizens, to allow the EPA to carry out scientific toxicology studies showing both acute and chronic exposure risks from the use of pesticide pet products used on companion animals.
  4. The inclusion of data already statistically assessed of studies reviewed by TedX – The Endocrine Disruptor Exchange when evaluating exposure risks to humans, children and toddlers.
  5. More thorough examination of the exposure risks to children and toddlers from the use of pesticide pet products, which includes adequate estimates of hand-to-mouth transmission as well as sleeping arrangements with treated pets and the number of pets and type treated in a household.
  6. The public discloser of inert/inactive ingredients of all products containing pesticide products in the home and strict regulation and discloser of entire formularies including synergists and their mode of action in making active ingredients even more harmful to mammals, including children and toddlers.

It is my belief and that of the 50,000 supporters I represent, that not including a more thorough study of pet flea and tick product residue and risks in the home that ACE 3 will be sadly flawed an incomplete.

Yours,

Claudia Tietze

TinyTimmy.org

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Visit me at http://www.tinytimmy.org

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