Ban The Sale Of Harmful Flea and Tick Products

We, The Undersigned support legislation banning the EPA's approval of the sale of over the counter flea and tick pet products that contain ingredients that have harmed, damaged, permanently damaged and/or killed thousands of domestic "companion" pets in the United States.

These ingredients, primarily pyrethrins, permethrin and their derivatives, have been known and stated by the EPA to be carcinogenic to animals and humans. There are numerous studies, not funded by industry, that indicate they are more highly toxic than previously banned substances. It is time for the EPA to take a strong stance against these products and ingredients. By keeping them on the market, manufacturers knowingly are keeping toxic products that maim and kill pets on the market for profit instead of seeking safer non-toxic alternatives.

1. We propose that these products be banned for use on pets and in the home. That instead of registrants providing the EPA with scientific studies they control by their funding, that the same dollar amount spent on these studies goes into a fund that the EPA controls to hire truly independent toxicology studies and that long term health effects are also required to be studied.

2. We propose that the EPA set up guidelines that must be followed to the letter for these studies and that it is no longer acceptable to make specious claims with the way science has been practiced in order to continue to have toxic products on the market. Also, entire formularies, including inert ingredients need to be tested instead of individual active ingredients. The EPA should have access to ALL ingredients, even if they are claimed to be trade secrets, for the purpose of evaluating registrant proposals and products. It is well known that chemicals react with each other and it is important not to ignore this fact. It is also known that often ingredients listed as inert are actually hidden lethal combinations, sometimes containing ingredients previously banned or that would be listed as an active ingredient in another pesticide. The public has a right to make educated decisions about their health care and that of their pet.

3. We propose that the EPA regulate a national reporting system directly to the EPA rather than have the reporting be controlled by manufacturers who have a vested interest in under reporting, not reporting or minimizing incidents. Hartz alone has been fined several times for such practices and they are in a sweetheart deal with the ASPCA toxicology poison control hotline to take all Hartz calls. This gives them an unfair advantage over other registrants. I propose that 1\% of corporate profits from manufacturers and registrants go into a fund, controlled either by the EPA or a body of truly independent researchers, to find non-toxic alternatives to dealing fleas and ticks on pets and inside the home and in the yard. In exchange, manufacturers should have the ability to use this information for the purposes of bringing these alternatives to market. I propose that pyrethrins, pyrethrenoids and permethrin are regulated under the same EPA department, instead of different ones as is currently the practice.

4. We propose rather than hiding that ingredients are a derivative (or structurally the same as a chemical that has been getting bad publicity) that they should be required to state the name of the ingredient and what it is derived from. These steps would go a long way toward protecting public and pet health.

Currently, these registrants prey on our fears and cash in on brand recognition, although many of the companies no longer resemble the trusted family run companies ingrained into our families as pet care partners for generations. The public innocently assumes that if something is on a grocery store shelf or other retail environment that there is some assurance of its safety. Sadly, the truth is this is a billion dollar industry and currently profits are outweighing the public health and our pets health. Subsequently in 2008 alone over 120 incidences PER DAY of death and damage were reported to the EPA from manufacturers. The actual numbers are much higher due to the structure of current reporting. This is an epidemic.

It has been established that incidents from these products have been on an alarming increase year after year. This cannot only be explained by more public awareness and more computer use, particularly when most incidences are reported via phone, not the internet. This can be explained by several studies that show these products are toxic and stored in the central nervous system, where necropsy does not look for toxic build up. It can be explained by the fact that our pets are unable to metabolize these products and so the incidents often occur after months or years of use. It can be explained by toxic ingredients often disguised as inert. It can be explained by the fact that these products are working less and less, so formula need to be stronger and stronger, usually with a combination of ingredients which in turn create a more highly toxic product to our pets.

The undersigned understand that the job of the EPA regulating these products is complex and vast, but swift action needs to be taken. The EPA has requested hundreds of these products over the past five years be voluntarily recalled, however this has not accomplished removing them from the market, often times resulting a re-branding effort instead.

The time for action is now and it is the signers of this petition hope that, with the current administration-- the phenomenal amount of death and damage and suffering, will soon be at an end.