EPA Meeting Notes from September 2011

As you know, Aundria Arlandson (the owner of Oliver who passed from CRF after use of flea powder), Amy Entz and I headed to Washingon again this year to meet with the EPA, lawmakers, do outreach and talk to anyone who will listen about harmful flea & tick products.

Please excuse the delay in publishing these notes of our EPA meeting, but Timmy has not been well and neither have I. The trip to DC was both wonderful and frustrating. Wonderful because we uncovered many things that will help us in the future and frustrating because we did not accomplish all that we wanted to.

MLK Jr. Monument in Washington DC

There is so much ground to cover in sharing with you our DC experiences that I am going to have to break it down into many different posts. Here are some of the notes from the meeting with the EPA. Without your help & support, we would never have been able to accomplish these wonderful things! Thank you for Being The Wave!

  1. The EPA has agreed to allow us to meet yearly (or more often).
  2. They will be looking into implementing a self-reporting portal much like the veterinarian portal. HUGE WIN. This means that the EPA would not receive “filtered” data from manufacturers who have been fined for under-reporting or mis-reporting the severity of incidences. The information would come directly from you, the consumer and end user.
  3. We brought up Assurity for Cats because we got the studies from a Freedom of Information Act Request and they were horrifying. The studies for cats and kittens had to be stopped early due to too many of them dying. As far as I know, they have not had to submit new studies with the whole formulary. The EPA is doing a data call in (where the manufacturer has to submit information when it is requested) for Assurity and will pay extra close attention to the reported incidences. If they seem miniscule, they will ask for more information. There is reason to suspect under-reporting/no-reporting based on the number of complaints I have gotten on TT’s website. (Mostly skin lessions and hair loss.) As a side note – Assurity for Cats is sold only through veterinarians and we also discussed how the sales representatives portray it to vets. I’ve heard numerous reports of Assurity being billed by reps as “the only totally safe all natural” flea & tick treatment for cats.
  4. The EPA will also follow up on whether or not the entire formulary of Assurity  has been tested and what those results were (if it was done). If it has not been done, they will mandate it to be expedited. They were very concerned over this product and the feed back they have gotten from TT’s site – although they seemed to think that the EPA has not seen any higher-than-expected reports. This might be because it is a fairly new product.
  5. They will provide us with aggregate numbers of adverse incidences for 2008, 2009, 2010 and 2011 to date. I explained the 39,000 figure for adverse incidences from 2009 was not calculated the same way as the 44,000 from 2008 and so they really in all honestly can’t claim the reports are lower. This way we can compare before it has been filtered and altered. These alterations have been an issue in an accurate view of the vastness of the adverse incidences that are reported by manufacturers and their agents to the EPA who then compiles it all. For example, I learned early on to take screen shots of anything important. The first time I found the information on adverse reactions for 2008, the EPA stated 1600 deaths. The second time it was 1200 and now it is 600. That’s a huge difference and the only way to get a clearer picture of the patterns is to have this data.
  6. We discussed the conflict of interest of the ASPCA (again). The ASPCA runs the Pet Poison Control Hotline, but they are paid by flea & tick manufacturers (registrants in EPA lingo) for a variety of services, including handling the incident reporting. They also regularly testify in court on behalf of manufacturers against the people who have issues with their products. Now with their backing of Pet Armor and the $6 million + they earn from registrants and manufacturers each year it has become a ridiculous situation. I got the impression that based on my report of it on TT’s site that they already were looking into this – but this why they were so receptive to the idea of an EPA based reporting portal. I also stated it would save them money and scrutiny from the public. (They would no longer have to pay the ASPCA for reports of results and people would feel that they were treated better as far as their voice being honestly heard.)
  7. I also brought up that they would be able to truly assess the pros and cons of flea & tick products with a public reporting portal and would be able to see a pattern of any manufacturer or registrant under-reporting or failing to report. Legally manufacturers have to report all adverse incidences quarterly to the EPA.
  8. We followed up from last year’s meeting, of course.
  9. The EPA are looking into making it straight across the board of a cat product saying not for dog use and vice versa. They said this is in the works, but it “takes time”. This is what they said last year too, so I asked how much time is reasonable in EPA-land. There were reports of a dog product not carrying such a warning and when it was followed up on, the EPA product manager said it was “not necessary”. This is a conflict to their 2008/2009 mitigation plan and was brought to their attention.
  10. We brought up the experience pet owners whose pets have suffered adverse reactions having their claims dismissed straight away, with registrants (or their agents) insisting either their product doesn’t cause adverse reactions or that it must be something the dog/cat ate, yada yada.

Timmy Stones in Honor of Lilli & Ozzie

Follow up on your concerns:

•    The EPA is working on the new labeling (still) and they are voluntarily asking registrants to add inert/inactive ingredients. What I have found is that instead of calling the “invisible” inert ingredients “inert” that many packages now say “other ingredients” and still do not list them. Legally they can claim these are a “trade secret” and so protected information.
•    Part of their review will be of font size so that important information will not be in ant print that hardly anyone can read or if they can read it, it’s a struggle.

•    I have had 4 reports from vets stating that Assurity for Cats is being marketed to them as “the only totally safe” product against fleas for cats. We discussed this and it was the EPA’s belief that unless this statement is made in writing as part of their marketing material, there is not much that can be done with it, although it is clearly illegal.

•    We asked if there was anything that could be done about manufacturers regularly claiming their product is “safe when used as directed”. They are not allowed to make this claim, yet regularly do in the form of public statements and responses to news stories. Again, it falls into the whole “is it part of their printed marketing materials” for the EPA. I made the point that if someone is charged with being a public mouthpiece for a corporation that their statements become a de facto part of their marketing, just as those who speak for the EPA are also help accountable for their statements.

•    Q: I would be interested in why they have not educated the public about the dangers of these chemicals and components and investigating and studying alternatives to using these chemicals so that they are safe  A: The EPA has added a short list of alternatives (vacuuming, flea combing, washing bedding, etc.) on their website. They have a Green Chemistry initiative to find safer alternatives to the old and more toxic chemicals and pesticides on the market.

•    When are the comments to the EPA’s Mitigation Plan going to be addressed. (The answer then was by the end of the month, and now is that they have been released, but are disappointing.)

•    The packaging on the Frontline generic, Pet Armor, looks deceptively like the Frontline packaging using similar coloring, layout and fonts. A: They will look into it.

•    Q: An observation about how important these issues are to people who do not ‘own’ their pet, but regard them as a valued member of their family and health support network brings in the… human factor. The impacts of these problems can also adversely impact the service animals (as defined in the ADA) and their partners if the toxicity levels exceed a changed threshold due to issues with the person’s immunity, neurological health, etc. [Relating to the impacts of the Body of Burden calculations, other pets in the household, children, senior citizens, etc.]  A: Sadly we were not able to go into this much detail with this point. It’s an excellent point and perhaps a tactic we need to pursue in the future. We did talk about health risks, but sadly that point seemed to be dismissed with the statement that they have set calculations for that measurement. The issue with their “set calculations” are they are woefully inadequate and change from product to product.


Thank Yous

Without you, supporters and friends, this trip could not have happened. It happened because we all pulled together, donated items, time, air miles, hotel points, gift cards, sharing and tweeting and told your friends. This is about YOU and without you, we would just be one ripple. With you we are a giant wave, gaining momentum.

Also, I would like to thank all those who helped us in DC, including the EPA who agreed to meet with us again this year, Melissa Jo who helped us decorate Timmy Stones all over the Capital, William Lee who is filming a documentary about our Journey and Karma Hurworth who went to great lengths to have Tiny Timmy Cookies sent in time for our meeting with the EPA. (Sadly, the meeting was moved up and so we missed the cookies!) Rebecca Slattery-Kavanagh for EVERYTHING and running the Timmy Stones Project. Mimi Pipino of Catching Lizards and Denyse Romero of Crafting for Critters for ongoing support of profits, moral and emotional support. Deb Lavoie of Crafting for Critters whose heart always amazes me. . Maike and the Milty Project for making Timmy a Milty Pet and helping his Healing Journey. Ana from Meow.com who would not quit sharing the word until she knew we were set for our fundraising goal. Tamar from IHaveCat.com who always amazes me! Chitari Foundation for their support and sponsorship. Pam & Robin who donated a large amount of items for fundraising auctions.  There are far too many people and organizations to thank everyone. Just know that you are all amazing and appreciated even if I have not mentioned you by name!

Tiny Timmy Cookies sent to DC from Hot Lava Bakery and Karma!

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