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

THE FACTS:

  • 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.

Dollar Tree Sells Sergeant's Bansect Collars with Propoxur for one Dollar...

Dollar Tree - One of MANY stores across the country to continue to sell Bansect collars by Sergeant's Pet Care despite knowing the dangers.


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  • http://twitter.com/fleem fleem

    Hi, Timmy. I sent them a comment. Let’s win!  :)

    • Anonymous

      YAY!!! Thank yous Fleem!!!

  • Lechatboote

    We pet owners need safe pet products.  Our pets are valuable why jeopardize their  health or their lives.  Please remove ALL unsafe products.

    • Anonymous

      Hi Lechatboote! Can you leave this on the link for comments to the Federal Register so the EPA can see your comment? I know it’s a confusing system, but it’s the only one we have right now to get your voice heard!

  • Sue from Australia

    Please remove all pet products containing Propoxur. The Americans always seem to consider themselves a world leader and I really think in this instance you should take the lead and show other countries you really care about your animals, children and the environment.

  • Sue from Australia

    Timmy I misread the instructions:(   Really sorry but I am leaving the comment below on the right site now

    • Anonymous

      No worries! You might get a message that the site is down. It should be up again on the 4th.

  • meowmanor

    Success…finally!!!  Comment Tracking Number: 80eb9fc9

    • Anonymous

      YOU ROCK!

  • Aladdin-diane

    OH boy Timmy…I have been having troubles navigating the American Government site..as you know I am not the most computer savvy person in the world… Anyway I founda place to leave a comment but didn’t know where I added my name and details so I added it to my comment….hope that is ok, my tracking number is 80 ebd 5e8….boy I hope I did it right!!! Love you guys so much and I hope we make this  happen…love Di and AladdinXXXXX

    • http://www.tinytimmy.org Tiny Timmy<span class="comment-author-location"> from Portland, OR, United States</span>

      No worries! It’s a VERY confusing site. I always have to re-learn it when I go there too. You did GREAT!!! Thank you!!!

  • Lechatboote

    Here’s da comments twakings numbers Comment Tracking Number: 80ebd5eb

  • Lechatboote

    Heys Timmies I dids its’ I posteds da comments in da wites placcies MOL

    • http://www.tinytimmy.org Tiny Timmy<span class="comment-author-location"> from Portland, OR, United States</span>

      MOL!

  • Jeddygirl

    Its hard for me to believe that such toxic items have been on sale for so long, endangering animals lives as well as children and adults, who while playing with their animal companions are in close contact with the toxins. There are alternatives which make more sense and aren’t dangerous.

    • http://www.tinytimmy.org Tiny Timmy<span class="comment-author-location"> from Portland, OR, United States</span>

      This is true! You should leave that on the Federal Register Public comment! There is a link in the post above!

      WE LOVE YOU!!!

  • Michelle

    Submitted comment with tracking number 80ebfd60. Thank you for all that you are doing to help ban these harmful products!

  • http://www.facebook.com/profile.php?id=822877901 Janice Holladay

    Do I put myself where it says organization on the form or what? Any suggestions as to what to put on the comments? Do they need a recounting of facts or do they need more of just an appeal from the heart? I know they don’t want stock letters, but I’d love a bit of guidance, please. Thanks!

    • Anonymous

      You don’t need to fill out that part. Just let em have it!!!