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(Below is email that I sent to Kelly Sherman at the EPA on 3/2/11)

Dear Ms. Sherman,

I am writing in regards to a fipronil (Frontline) pet treatment post-application exposure study that you reviewed for ethics on August 10, 2009:

I would like to bring to your attention a conflict of interest that ought to preclude reliance on
that study in EPA actions taken under FIFRA.  As you stated in your review, the study was funded by Merial, the Frontline registrant.  You also stated that the study did not report any independent ethics oversight or review of the protocol or of the conduct of the research.

In case you were not aware, the above study was submitted by Merial in response to an
EPA risk assessment, which had determined that exposure estimates were unacceptable:

In other words, the registration of the fipronil pet treatment was dependent upon the submission of an acceptable exposure study.  The fact that the study was not only funded
by, but conducted in part by Merial, was a serious conflict of interest.

I would also like to bring to your attention another disturbing fact.  One of the study’s authors (Andre Weil) also happened to be one of the inventors of the fipronil pet treatment:

Clearly, Merial and Mr. Weil had a significant financial interest in the outcome of the study,
but that was never mentioned in the EPA’s technical review of the study:
In fact, it states, “The study author stated that there were no influences, impacts or circumstances which might have impaired the integrity of the study.”

In light of these revelations, and the fact that the EPA still relies upon that study in actions
taken under FIFRA, I hope that you will seriously consider reevaluating the study for ethical conduct.

Thank you for your consideration.


James TerBush
Website Administrator

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