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 || firstname.lastname@example.org || 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.