Monthly Archives: July 2011

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  

----------------------------------------------------------------------------------------------------------------
     EPA registration number            Product name             Active ingredients
----------------------------------------------------------------------------------------------------------------

000432-01454....................  Merit 240 SC             Imidacloprid
                                   Insecticide.

002517-00006....................  Double Duty Cat Flea &   Pyrethrins
                                   Tick Spray.             Piperonyl butoxide
                                                           MGK 264

002517-00034....................  Sergeant's Foam 'N Comb  Pyrethrins
                                   Dry Shampoo for Dogs    Piperonyl butoxide
                                   and Cats.
002517-00099....................  Pyrethroid W.B.          Permethrin
                                   Concentrate.

002517-00104....................  Preventic L.A. Flea and  Permethrin
                                   Tick Spray for Dogs.
002517-00105....................  Natura Flea & Tick       Permethrin
                                   Collar for Dogs and
                                   Cats.
002517-00108.................... Permethrin- IGR 1 Flea and Tick Pyriproxyfen Spray for Dogs. 
002517-00113.................... Permethrin-Pyriproxifen Permethrin Residual Shampoo for Pyriproxyfen Dogs 2.

053853-00002....................  Black Flag Fogging       Permethrin
                                   Insecticide Formula 2.  Piperonyl butoxide
                                                           Tetramethrin

------------------------------------------------------------------------
   EPA registration number        Product name          Chemical name
------------------------------------------------------------------------

005481-00551................  Ambush 4E Insecticide            Permethrin.

009688-00070................  Chemsico Roach        Tralomethrin.
                               Control System I.
009688-00078................  Chemsico              Tralomethrin.
                               Tralomethrin Indoor
                               Fogger.
009688-00080................  Chemsico Home Insect  Tralomethrin.
                               Control A.
009688-00081................  Chemsico Home Insect  Tralomethrin.
                               Control B.
009688-00082................  Chemsico              Tralomethrin.
                               Tralomethrin Flea
                               Killer.
009688-00087................  Chemsico Home Insect  Tralomethrin.
                               Control D.
009688-00091................  Chemsico Home Insect  Tralomethrin.
                               Control Refill.
009688-00098................  Chemsico Home Insect  Tralomethrin.
                               Control E.
009688-00101................  Chemsico Home Insect  Tralomethrin.
                               Control E Refill.
009688-00113................  Chemsico              Tralomethrin.
                               Tralomethrin
                               Insecticide D.
009688-00119................  Green Thumb Home      Tralomethrin.
                               Insect Fogger.

009688-00144................  Dethmor 3.75% EC....  Tralomethrin.
009688-00147................  Chemsico Indoor       Tralomethrin.
                               Fogger G.
009688-00152................  Saga WP Insecticide   Tralomethrin.
                               228.
009688-00153................  Saga Multi-purpose    Tralomethrin.
                               Home Pest Control
                               Insecticide.
009688-00166................  Chemsico Insect       Tralomethrin.
                               Control CP.
009688-00167................  Aerosol Insecticide   Imiprothrin.
                               IT-B.                Tralomethrin.
009688-00170................  Chemsico Aerosol      Imiprothrin.
                               Insecticide IT-D.    Tralomethrin.
009688-00171................  Chemsico Aerosol      Imiprothrin.
                               Insecticide IT-C.    Tralomethrin.
009688-00172................  Chemsico Insect       Tralomethrin.
                               Granules Formula T.

[[Page 40361]]

 
009688-00185................  Chemsico              Prallethrin.
                               Tralomethrin         Tralomethrin.
                               Insecticide C.
009688-00194................  Chemsico Wasp &       Prallethrin.
                               Hornet Killer TE.    Tralomethrin.
009688-00204................  Chemsico Insecticide  Tralomethrin.
                               Concentrate T.
009688-00275................  Chemsico Insecticide  Pyrethrins.
                               RTU OP-M.
047000-00139................  Permethrin Dust       Permethrin.
                               0.25%.

------------------------------------------------------------------------
   EPA registration number        Product name          Chemical name
------------------------------------------------------------------------
003377-00009................  Methyl Bromide        Methyl bromide.
                               Technical.
005785-00023................  Terr-O-Gas 45.......  Chloropicrin.
                                                    Methyl bromide.
008622-00040................  57-43 Preplant Soil   Methyl bromide.
                               Fumigant.            Chloropicrin.
008622-00044................  80-20 Preplant Soil   Methyl bromide.
                               Fumigant.            Chloropicrin.
------------------------------------------------------------------------

073049-00459................  Ultra TEC DS Yard     S-Bioallethrin.
                               and Patio Spray.     Deltamethrin.

The T.O.Y. Army, a group of dedicated volunteers in the US and globally, has contacted the Dollar Tree chain of stores after finding Bansect propoxur flea collars in most of the stores visited. We followed up with two letters, the second one is in the post Letter to Dollar Tree. We began this journey last year and had over 100 dedicated volunteers visit Dollar Tree Stores all over the country. They took pictures of the flea products on the shelves and filled out forms, including the brand, how many and the ingredients. We were surprised to find that Bansect collars, and made by Sergeant's Pet Car, were on the shelves in almost every Dollar Tree Store. This collar contains propoxur, which is a known carcinogen and has already been banned for residential use due to health concerns. To learn more about propoxur and the open comment period (to July 15) for EPA consideration visit this post Help Get Propoxur Flea Collars Banned and Off the Shelves. This is a GREAT VICTORY! We are trying to confirm this information since it was so short, however it bodes well. Aundria followed up with another letter and found her follow up letter was bounced back from all the contacts formerly emailed. However, she got this response when she sent it again to the general email. OPEN LETTER:

From <ithinkimoliver@yahoo.com> To: <customerinquiries@dollartree.com> Name: Aundria Arlandson In December of last year, I submitted a letter to Mr. Bob Sasser explaining my concern with the Bansect line of Flea and Tick Collars sold in some of your stores. Since sending that letter, I have received no response from your company, but did receive a threat from Sergeants Pet Products regarding a cease and desist order against further contacting you about my concerns of carrying the Bansect Line of Flea and Tick Collars that you carry in some of your Dollar Tree Stores. The Bansect Line flea collars that Dollar Tree sold in some of your stores contain propoxur. California has already determined that propoxur causes cancer and that consumer warnings are required. NRDC is suing major manufacturers and retailers of flea collars containing propoxur. Last year, I traveled to Washington DC to meet with the EPA Office of Pesticide Programs regarding their on-going support of the sale of harmful over the counter flea and tick products. This year, I am returning to Washington and intend to further discuss my concerns about the pesticides in over the counter flea and tick products that harm, damage, permanently damage and kill companion animals with the EPA, government agencies, state representatives, print and televised media and partake in a tentatively scheduled rally that will inform hundreds, if not thousands of people about the dangers of flea and tick products that contain harmful pesticides, including Dollar Trees sale of the Bansect line that contains propoxur in some of your stores. If you have any questions, I can be reached at ithinkimoliver@yahoo.com Please see the docket at Regulations.gov #EPA-HQ-OPP-2009-0207 PETS AND PEOPLES LIVES ARE WORTH MORE THAN ONE DOLLAR. PLEASE PULL THESE PRODUCTS FROM YOUR SHELVES! Thank you. Not One More Like Him. Ever.

DOLLAR TREE RESPONSE:

From: customerinquiries@dollartree.com <customerinquiries@dollartree.com> Subject: Fw: Concerns about a Dollar Tree Product To: ithinkimoliver@yahoo.com Date: Thursday, June 30, 2011, 6:14 PM Dear Mrs. Arlandson, Thank you for your comments and your concern. We no longer carry that product. Thank you, Customer Service