I cannot tell you enough how important it is that you join in this decision making process by taking a little bit of time to write a comment on the Federal Register.
For several years, the NRDC (National Resources Defense Council) has been trying to get retailers to remove harmful flea collars from the market. As part of that effort, they filed (and won) a lawsuit in California under the Proposition 65 terms that states any product sold in California containing a known carcinogen must state the product causes cancer. The NRDC took on major retailers such as PetSmart, PetCo, Ralphs, and more as well as the companies that make these collars. The NRDC won their case.
The NRDC submitted a petition several years ago to the EPA requesting the ban of these collars based on studies the NRDC conducted which shows these collars exposes humans and children to a higher than allowed amount of propoxur through the use of the flea collars “when used as directed”. They now need your help to see their mission through.
As part of this process, the EPA is required to have an open comment period. This is where manufacturers, distributors and other members of the industry can comment on important key issues and be part of the decision making process. YOU can also be part of the decision making process.
Here is the notice. It’s a little confusing as you then need to go to the Federal Register and put in the docket number EPA-HQ-OPP-2009-0207 Now you have access to the whole docket, including the comments from others, the text of the petition and other supporting materials. You can submit your comment here. It’s important to keep in mind that the EPA wants to hear YOUR views not a standard stock letter that hundreds submit. The NRDC has already submitted over 8,000 letters from their email campaign.
Please be sure to put your name, and if you are comfortable, contact information, on the letter. These should have been off the shelves the moment they hit the shelves.
Here are a few points to include in your comments, if you wish. You can either use their comment form or attach a Word or PDF file for longer letters. COMMENTS MUST BE RECEIVED ON OR BEFORE JULY 15, 2011
- According to the land-breaking NRDC study, Poison on Pets II: “The April 2009 paper Poison on Pets II details a first-of-its-kind study by NRDC showing 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. Residue levels produced by some flea collars are so high that they pose a risk of cancer and damage to the neurological system of children up to 1,000 times higher than the EPA’s acceptable levels.”
- “California has already determined that one of these pesticides, propoxur, causes cancer and that consumer warnings are required. NRDC is suing major manufacturers and retailers of flea collars with propoxur to make them comply with this requirement or pull the products from California shelves. However, California’s laws are not enough—the Environmental Protection Agency (EPA) should step in to ban these dangerous products nationwide. Retailers should help keep pets and families safe by pulling products that contain tetrachlorvinphos and propoxur from their shelves.”
- From Volume 111, Number 4, April 2003 copy of Environmental Health Perspectives. An article entitled Cancer and Developmental Exposure to Endocrine Disruptors by Linda S Birnbaum and Suzanne E Fenton (both members of the National Health and Environmental Research Laboratory under the EPA : “The carbamate pesticide propoxur is one environmental chemical identified where exposure was highly correlated with leukemia in the offspring… All of these studies have demonstrated that prenatal exposure to EDCs can alter the hormonal milieu, reproductive tissue development, and susceptibility to potential carcinogen exposure in the adult. These compounds are not genotoxic, yet can have significant adverse health outcomes.”
- In 2007 the EPA was so concerned about risks to children from propoxur that they restricted the home/residential use of it in 2007. Now these flea collars allow it into your home anyway, at levels considered very dangerous by the EPA.
- Propoxur is listed by the EPA as a probably human carcinogen (in Group B2) and a cholinesterase inhibitor. It is also assumed to be an endocrine disruptor. Endocrine disruptors have a significant effect on the endocrine system and they are unique in that minimal exposure levels still disrupts the endocrine system.
- Propoxur shares similar features with other members of the same pesticide family, which includes the ability to inhibit acetylcholinesterase (AChE), an enzyme which is functional in the transmission of nerve impulses. When AChE is inhibited, cholinergic toxicity results, eventually leading to the overstimulation of neurotransmitters. 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.
- Children and toddlers are especially susceptible to these effects as their systems are developing and their unique habits, such as hand to mouth contact and playing on floors and intimate proximity to pets.
- In the study conducted by the National Cancer Institute, propoxur is thought to increase the likelihood of developing non-Hodgkin’s Lymphoma and highly indicated in generational leukemia.
- Propoxur has been identified as one of hundreds pesticides that now can be measured in our drinking water, so it persists in the environment.
The arguments that the industry makes:
- The testing review of studies submitted by industry to the EPA did not show the same high levels. – Counter Argument: This study minimized the exposure to children and toddlers, using one incident of hand-to-mouth contact PER DAY. This is not only against the EPA standard assumptions of such contact, but anyone with children, or has been around children, especially toddlers KNOWS that the hand-to-mouth contact is much more than once per day. It also does not take into account children crawling on floors with their pets or sleeping with their pets while wearing these collars.
- The EPA must take financial loss of the “registrants” (manufacturers) into account when making a decision: Counter Argument: This shows a blatant disregard for human and companion animal health. Also, the cost to society in terms of health care costs, treatments, medications and long term illnesses is much greater than the loss of revenue to registrants.
- Registrants (manufacturers) claim their products are “safe when used as directed”: Counter Argument: As always, this claim takes responsibility for safe products away from the registrant/manufacturer and puts the onus on the pet owner, who is expected to make good sound purchasing decisions based on a distinct lack of information available.
- The proposed “alternatives” suggested by the NRDC are not enough to combat a severe flea issue (regular vacuuming, washing of pet bedding, flea combing and bathing): Counter Argument: This is simply false. A Harvard study showed vacuuming to be the single most important way to mechanically kill fleas and larvae. Also, there are other products that can be used that are safer and effective. The bonus to these products and methods is that fleas and ticks do not build a resistance to them. This includes the use of diatomaceous earth (food grade), beneficial nematodes and flea traps.
- The NRDC Study wasn’t a “real” study and so should be discounted. Counter Argument: The NRDC created this study to actually measure the true values from actual real-life contact and use of these flea collars. Industry, on the other hand has had since 1963, which propoxur was first introduced to do a study that was valid and honest, measuring the same exposure and health risks and has failed to do so in the past 38 years. It’s a blatant disregard for human and companion animal health and an honoring of their profits from continuing to sell products that they know are harmful.
For more information, please see the letter to Dollar Tree Stores, who sell these collars for $1, the price put on human and pet health by Sergeant’s Pet Care and the Dollar Tree Stores.
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