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April 2009
I just found your website and I am upset with myself for using flea controls now.
I had the illusion that if they were sold in grocery stores and over the counter they were just as good as the expensive vet versions. I don't apply or give unknown chemicals to my children, or myself or even to my lawn!
My 5 yr old Husky/Border Collie seemed to have a reaction to Sergeant's Gold and when I read what happened to another posting I am going to bath her right away!
I checked out the chemicals listed on the package and they said they were safer than others but what about the "other ingredients" which make up over 50% of the product and are not listed at all? I feel very foolish and irresponsible.
I am an educated person and should have known better. I certainly have had my eyes opened by reading your site.
Thank you!
Judy 4/6/09
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Weird update on frontline-I think I notified you back last June or July of my two nightmare stories to my poor yorkie abbey and my silky riley from their first exposure to frontline. Right about the time I thought Abbey was doing well and then the hair started falling out by the handfuls, Riley started developing a small lump on his chest (if you would have followed the path around his body from the frontline, that is where it was) This thing
started growing rather fast and we had a biopsy done which was benign and were told to just leave it. Well this thing started growing so fast I swear you could watch it. We had it removed last week-now about three by two inches and it stuck out about 1 1/2 inches. Thankfully it was benign and the stitches should be coming out this week. I asked the vet if it could have had anything to do with the frontline and she stood there for a moment and said that from what she has seen it very possibly could have especially
since it developed so close to the application time. Just one more thing to add to the list. I am keeping my little guys on all natural "Flea Free" available from Judy's Health Cafe online- still not one flea or tick and safe for human consumption-dogs love it just put it on their food.
Debbie, CMA 4/6/09
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I treated my cat with Biospot flea and tick treatment that you place on their back. I treated my cat before I left the house to run some errands. I returned about four hours later to find my cat having seizures and continuous trimmers. I immediately took her to the vet. Luckily, I got home in time before she died. My vet gave her charcol to bind the poison before it moved into her organs. She stayed at the clinic for two days. They flushed her with an IV, and kept her sedated to stop the trimmers. The total cost was
$667.00. This was really scary, and the worst thing is that it is still on the market. I just want other people to know that saving a little money on flea and tick control can kill your pet. Thanks for having this website.
Julie 4/7/09
Did you use Bio Spot for Cats or Bio Spot for Dogs by mistake?
Some people have made the mistake of putting Bio Spot for Dogs on their cat, which can be fatal. However, even if you used Bio Spot for Cats and followed the directions carefully, it can still cause adverse reactions in cats.
James TerBush
I did use the Biospot for dogs on my cat. My mistake unfortunately. I also have a 5 pd. Chihuahua. Luckily I caught it in time.
Julie 4/8/09
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About ten days ago, a veterinarian who writes a column for the Miami Herald received a "cease and desist" order from Hartz. The newspaper received even stronger language and demands. The Vet wrote an outstanding response to Hartz that she published on her personal blog (on the other hand the Miami Herald printed a "correction"...buckling to Hartz's demands). You might be interested in reading this case on HartzVictims.org or several other sites.
It seems like Hartz is getting much more aggressive...even taking the position of intimidating private citizens.
(name withheld) 4/10/09
I read Dr. Khuly's personal blog this morning. She may have implied that Hartz flea control products contain permethrin, but her advice to pet owners concerning these products was excellent. Unfortunately, the Miami Herald was too quick in issuing a retraction, and removed her March 28th column from their website.
I find it deeply disturbing that a corporation would use cease and desist letters to stifle legitimate criticism of their products, especially products which have the potential to harm and kill pets. Dr. Khuly should contact the EPA and let them know about it. I would also contact the ACLU, Public Citizen, the NRDC, and The Center for Public Integrity to see if they can offer any advice or assistance.
James TerBush
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(I sent the following email to the EPA on 4/13/09)
To whom it may concern,
I am writing to urge the EPA to consider revising the precautionary statements on phenothrin-based flea and tick control products for dogs, especially those statements which concern adverse reactions in cats.
These concentrated phenothrin products are currently required to have the following statement, "DO NOT USE ON CATS OR KITTENS." However, to the best of my knowledge, unlike concentrated permethrin products, concentrated phenothrin products are not required to have any statement which warns of the consequences of applying these products to cats, or if cats come into close physical contact with treated dogs.
In an EPA memorandum, dated August 10, 2001, the EPA requested that the labels on concentrated permethrin products be revised to warn of the risk these products pose to cats. Here is a link to the memorandum:
Here is an excerpt from page 21:
"In a December 7, 2000 letter from the Registration Division, OPP, nine registrants of concentrated permethrin products were requested to revise their labeling to make warnings about use on cats more prominent, including adding icons (graphic of cat crossed out). In addition, the statement, "May be toxic and potentially fatal if applied to or ingested by cats" after the warnings to not use on cats was suggested. EPA also asked that labels contain the statement, "Cats which actively groom or engage in close physical contact with treated dogs may be at risk of serious harmful effect. Do not use this product in households with both dogs and cats." This statement was requested because there are no data demonstrating a safe period to reunite cats with dogs after treatment. The registrants were reluctant to add the last statement. In a meeting on December 7, 2000, the Consumer Specialty Products Association representing the registrants agreed they would generate data on the safe period for isolation of cats from treated dogs. To date, no data have been submitted. However, Hartz Mountain has agreed to make the label revisions requested in the December 2000 letter."
The EPA is well aware that concentrated phenothrin products have the potential to cause serious harm and death in cats. In 2005, the EPA insisted that Hartz withdrawal several of its concentrated phenothrin products for cats and kittens due to many reports of adverse incidents in cats (including several deaths). However, the EPA allowed Hartz to continue to market its concentrated phenothrin products for dogs (EPA Reg. # 2596-150).
If the above precautionary statements, which are required to be on the label of concentrated permethrin products, are not currently required to be on the label of concentrated phenothrin products, I urge the EPA to require these statements, effective immediately.
Thank you for your consideration.
Sincerely,
James TerBush
Website Administrator
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I just found your website and I am upset with myself for using flea controls now.
I had the illusion that if they were sold in pet store and over the counter they were just as good as the expensive vet versions. I should not have put this Bio Spot or any other unknown chemicals to my one year old Maltese. After a trip to my Vet and a comprehensive physical exam, heartworm/Lyme/Erlichia/Anaplaso test she told me it had to be a reaction to the Bio spot.
So I brought him home gave him a bath and it helped some but he had a very rough night up at two in the morning could not settle down at all. So I gave him another bath which seems to have helped again. He is getting a long a little better now but I am keeping a close eye on him.
I checked out the chemicals listed on the package and they said they were safer than others but what about the "other ingredients" which make up over 50% of the product and are not listed at all? I feel very foolish and irresponsible.
I'll let my Vet educated me on what should be used and what should not be used from now on. If you love your pet as I do don't trust any product until your Vet tells you it's OK!
Thank you for this web site!
Jerry 4/13/09
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Here's a link that your readers may be interested in:
The EPA announced today, April 16, that they are stepping up their scrutiny of these flea and tick spot-on pesticide products because of a sharp increase in reported adverse incidents involving dogs and cats. The EPA reported 44,000 potential incidents in 2008 alone! How high does the body count have to rise before this government agency steps up to its responsibilities? This is sickening--44,000 reported incidents. And how many incidents go unreported--75%--90%? A ground swell of negativity towards these products is building. Enough is enough. There are a lot of people all over the web making strong comments and expressing anger over these products, and rightfully so. However, it's about time people who are sincerely concerned start writing to Debra Edwards, director of the Office of Pesticide Programs at the EPA and let her know what's going on. Keep getting the media involved as well. Some media have more courage and backbone than the Miami Herald--there have been some great investigative reports aired/written lately (NBC Los Angeles is one recent example) and in spite of intimidation tactics by a manufacturer they have not buckled. And ask your congressman/woman and Senators to get off their rear ends and take some action--particularly if they sit on the right committees (environmental, human services, etc.). Most politicians are looking for an opportunity to make themselves look good and they would certainly get much support from the public on this issue. My point is this--take action. Don't just write a few lines of inane comments on blogs. These manufacturers are harming thousands of our pets and animal friends and leaving families devastated. Who knows what damage is being done to toddlers and children that have more fragile neurosystems. The EPA has expressed concern about that as well. Let's keep the momentum growing--we have the ability to stop this insanity.
Anonymous 4/16/09
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Dear Madam/Sir:
(Please forgive the length of this email. I wanted to provide as much information as possible to help you evaluate this matter.)
I maintain a website called www.BioSpotVictims.org, which seeks to educate pet owners about the risks of dangerous flea control products, and help them find safer alternatives (the GreenPaws website has a link going to my website, and my website has a link going to GreenPaws.org). I am writing to urge the NRDC to consider filing a federal lawsuit against the EPA for allowing several phenothrin-based flea and tick control products to remain on the market.
The products in question are: Hartz UltraGuard Flea & Tick Drops for Dogs and Puppies, Hartz UltraGuard Plus Flea & Tick Drops for Dogs and Puppies, and Hartz UltraGuard Pro Flea & Tick Drops for Dogs and Puppies. These products contain 85.7% d-Phenothrin as their active ingredient. D-Phenothrin is a synthetic pyrethroid pesticide, and is not considered to be acutely toxic to humans or animals. However, no other brand of flea and tick control product contains a concentration of active ingredient as high as the Hartz products.
In 2005, the EPA forced Hartz to withdrawal several of their flea and tick control products for cats and kittens, which also contained 85.7% d-Phenothrin, after receiving thousands of incident reports detailing cases of serious illness and deaths in cats
and kittens resulting from the use of phenothrin-based flea and tick control products. At the time, the EPA was aware of several reports of neurological symptoms in dogs treated with phenothrin-based flea and tick control products, but allowed Hartz to
continue to sell their phenothrin-based flea and tick control products for dogs.
Despite the danger to cats and kittens, the EPA did not require Hartz to revise the precautionary statements concerning cats on the label of their phenothrin-based flea and tick control product for dogs, which would have warned cat owners of the consequences of using the "for dogs only" product on cats (such statements are required on the label of highly concentrated permethrin-based flea and tick control products for dogs).
In 2006, the NRDC warned pet owners of the potential risk of phenothrin-based flea and tick control products in this brochure:
Last May, the EPA re-evaluated the health risks of d-Phenothrin as part of a reregistration process. They discovered that they had originally failed to consider the risks of toddler incidental ingestion of residues on pets via hand-to-mouth after pet treatment. The EPA determined that the target Margin of Exposure (MOE) for the residential exposure assessment for d-Phenothrin is 1000. Any number lower than 1000 would be considered a "risk of concern." The EPA's risk assessment found that the estimated MOE for risks to toddlers from incidental ingestion of residues on pets via hand-to-mouth after pet treatment is 46 (forty-six)!
Here is the EPA's memorandum:
Last September, the EPA issued their Reregistration Eligibility Decision for d-Phenothrin. It can be found here:
Here are excerpts (please read carefully):
"...As a result of this review, EPA has determined that all products containing the active ingredient phenothrin are eligible for reregistration provided that the risk mitigation measures indicated in this document are adopted."
"It is currently unknown whether the pyrethroids as a class have similar effects on all nerve channels or whether modifications of different types would have cumulative effect. The Agency also does not have a clear understanding of effects on key downstream
neuronal function, e.g. nerve excitability, or how these key events interact to produce their specific patterns of neurotoxicity. Without such understanding, there is no basis to make a common mechanism of toxicity finding. Therefore, EPA is not currently
following a cumulative risk approach based on a common mechanism of toxicity for the pyrethroids because the Agency has determined further study is needed...."
"Phenothrin is often formulated with piperonyl butoxide (or PBO), a synergist which increases the effectiveness of phenothrin as an
insect knockdown agent."
"The Agency currently lacks statistics on the estimated nationwide use (in pounds) of phenothrin. In all likelihood, the nationwide use of phenothrin has greatly increased over the past five years as pyrethroid insecticide alternatives have emerged to take the
place of the several organophosphate pesticide residential uses that are no longer available."
"In the case of phenothrin, the toxicity database is incomplete for a full hazard evaluation, but is considered partially adequate to evaluate risk to infants and children. The uncertainties with respect to risks to infants and children are accounted for with
the addition of the 10X FQPA uncertainty factor."
"There is qualitative and quantitative evidence of increased susceptibility to infants and children from exposure to phenothrin. The studies assessing developmental neurotoxicty in rabbits indicated the presence of spina bifida at mid-dosage treatment levels, as well as the presence of hydrocephaly at the highest dose used...."
"Phenothrin is not known to be acutely toxic at high exposure levels to humans or mammals. Phenothrin exhibits low acute toxicity by oral (Category III), dermal (Category III) and inhalation (Category IV) routes of exposure. Phenothrin is mild eye irritant (Category III) but is not a skin irritant or a skin sensitizer."
"The toxicity database for phenothrin is currently incomplete. The toxicity database lacks acute, chronic, and developmental neurotoxicity studies that are required to fully evaluate risks to infants and children. Due to the incompleteness of the toxicity
database, the Agency has added the ten-fold (10X) database uncertainty factor (UFdb) to the margin of exposure level (MOE) used to assess concerns for all exposures. The addition of this 10X database uncertainty factor brings the total uncertainty factor for
this assessment to 1,000 (including 10X to account for interspecies variation and 10X to account for intraspecies extrapolation)."
"Although phenothrin is lacking in acute, subchronic, and developmental neurotoxicity studies, neurotoxic effects were observed in the developmental toxicity studies that were submitted. Neurotoxic effects were not observed in other acute, chronic, and subchronic toxicity studies in rats and dogs up to the limit dose of 20,000 mg/kg/day."
"The Agency notes, however, that cats in particular may be especially sensitive to pyrethroid flea and tick treatments. In the year 2005, flea and tick spot-on products with phenothrin as the active ingredient were cancelled for use on cats and kittens due to
incident reports and companion animal studies which indicated apparent neurotoxicity symptoms resulting from treatment, including excessive salivation, tremors, and/or seizures."
"The phenothrin registrant, Sumitomo Chemical Company, Ltd., is currently in the process of conducting an acute neurotoxicity study for phenothrin. The Agency will review these data when they are submitted by the registrant."
"There are no studies of dermal absorption available specifically for phenothrin. Dermal absorption amounts were conservatively estimated to be 2.0% based on dermal absorption studies available for other pyrethroids and pyrethroid-like compounds. A previous study (2004) of the dermal absorption of pyrethrins in humans showed absorption at a 0.22% rate (MRID 46382501)."
"The Agency has made the finding that phenothrin is "not likely to be carcinogenic to humans....""
"Residential exposure estimates are expressed in terms of Margins of Exposure (MOE). In numerical terms, the MOE is the NOAEL divided by a numerical measure of the expected amount of exposure. A target level of concern (LOC) or MOE of 1000 is considered safe for inhalation, incidental oral, and residential exposures and risks. Deterministic modeling estimated that several residential exposure scenarios would result in exposures of concern (MOE < or = 1000): the incidental ingestion of residues on pets via hand-to-mouth after pet spot-on or spray treatment by toddlers (children 1-2 years of age) and the incidental ingestion of residues on carpet or vinyl flooring by toddlers after fogger or carpet powder treatment (without vacuuming). The results of the
deterministic assessments for residential use products are detailed in Table 5 below. Assessments were further refined for the MOEs which are bolded."
SEE TABLE 5 - "Todders Playing with Pets, Incidental Ingestion - Post Application - Spot On - MOE = 46 "
(NOTE: THIS IS THE HIGHEST RISK ESTIMATE OF ANY RESIDENTIAL EXPOSURE SCENARIO CONSIDERED IN THE ASSESSMENT)
"The Agency has typically used deterministic methods (otherwise known as point estimates) to determine exposure amounts. The Agency has begun to explore probabilistic approaches to estimate exposure amounts in the past few years, and such approaches are considered to be refinements over deterministic assessments. Probabilistic assessments provide more information regarding the possible variety
of exposure routes and the probability of receiving a range of doses during an exposure event. Probabilistic approaches provide a distribution of exposure assessments, rather than a single, (perhaps high-end), point estimate of exposure."
"The Agency used the CARES (Cumulative and Aggregate Risk Evaluation System) modeling tool to assess residential post-application risks....The CARES assessment focused on those MOEs of concern first identified by the deterministic residential assessment. These scenarios included post-application incidental oral exposure from pet care products, and exposure from indoor foggers and carpet powders."
"The probabilistic CARES assessment was conducted only for those post-application exposure scenarios identified in the deterministic assessment which presented risks of concern (MOE < or = 1000)...."
"The results of the CARES assessment for residential use products are detailed in Table 6 below."
SEE TABLE 6 - "Phenothrin MOEs for Children 1-2 years, Incidental Oral Exposure - LOC/MOE = 1000. Pet Care Spot-On - MOE = 674 "
(NOTE: MOE = 674 IS A MUCH LOWER RISK ESTIMATE THAN MOE = 46, BUT IS STILL THE HIGHEST RISK ESTIMATE OF ANY RESIDENTIAL EXPOSURE
SCENARIO CONSIDERED IN THE ASSESSMENT, AND IS STILL CONSIDERED TO BE A RISK OF CONCERN.)
"Since the incidental oral exposure from the CARES assessment using a NOAEL resulted in assessed risks above the Agency's LOC, the Agency used a benchmark dose analysis to further refine the assessment of risks to toddlers from exposure to pet spot on products."
"There are adequate data on which to base a benchmark dose for phenothrin and the Agency conducted an analysis using the effect of organ weight gain to set the appropriate BMDL of 100 mg/kg/day."
"The benchmark dose used and the MOE values calculated from the CARES assessment for toddler hand to mouth exposures are presented in Tables 7 and 8 below."
SEE TABLE 8: "Incidental Oral MOEs for Pet Care Spot-On Target MOE = 1000. Estimated LOC/MOE = 1350 "
"Aggregate risk assessments consider the possibility that certain members of a population will be exposed to a pesticide through multiple routes and that the effects of these multiple exposures will be additive. With the addition of a food use tolerance,
phenothrin exposure can occur through the food, water, and residential pathways. Generally, the estimated average exposure from food and drinking water is added to the risks from incidental oral and inhalation exposure to arrive at an estimate for the
short-term aggregate risk from all possible exposure pathways. For phenothrin, however, the risks were not aggregated because the dietary, incidental oral, dermal, and inhalation endpoints are all based on differing effects. Therefore, an aggregate risk assessment is not possible for phenothrin."
"The following data bases were consulted for poisoning incident data on the active ingredient phenothrin: OPP Incident Data System (IDS), Poison Control Centers (PCC), California Department of Pesticide Regulation (CDPR), and the National Institute of Occupational Safety and Health's (NIOSH) Sentinel Event Notification System for Occupational Risks (SENSOR)."
"Flea and tick uses for phenothrin products on cats and kittens have been cancelled since the year 2005. These products were cancelled in response to the number of incident reports the Agency received detailing cases of serious illness or deaths among cats and kittens resulting from the use of phenothrin flea and tick products. In addition to the companion animal incidents reported for cats and kittens prior to 2005, the Agency has received, over the past ten years, a handful of reported incidents of the appearance of apparent neurological symptoms and other various complications following phenothrin flea and tick treatment on dogs."
"Section 4(g)(2)(A) of FIFRA calls for the Agency to determine, after submission of relevant data concerning an active ingredient, whether or not products containing the active ingredient are eligible for reregistration. The Agency has previously indentified and required the submission of generic (i.e., active ingredient-specific) data required to support reregistration of products containing the active ingredient phenothrin. The Agency has completed its review of these generic data, and has determined that the data are sufficient to support reregistration of all products containing phenothrin."
Given the fact that the toxicity database for phenothrin lacks acute, chronic, and developmental neurotoxicity studies, I believe that it was inappropriate for the EPA to use a probabilistic approach (also known as Monte Carlo simulations) to evaluate the risks to toddlers from exposure to pet spot-on products.
Here is an excellent article on probabilistic analytical tools, written by Prof. Susan R. Poulter in 1997:
Here is an excerpt:
"Paradoxically, since quantitative risk assessment can only address risks that have to some degree been anticipated and investigated, increased focus on the quantitative aspects of risk assessment may further obscure the fact that for many substances
there are little or no hazard data and quantitative risk assessment is therefore infeasible."
Prof. Poulter aptly pointed out that Monte Carlo simulations "require more data, otherwise, uncertainties in the input parameters may result in large uncertainties in the resulting risk estimates." She also pointed out that checking the accuracy of Monte Carlo simulations is difficult, and that the results are only as good as the assumptions.
I truly hope the NRDC will take time to evaluate this deception by the EPA, which puts children who are exposed to these highly concentrated pet pesticide products at unacceptable risks. You don't need a Monte Carlo simulator to know that pets are an integral part of the family, and that children face risks of pesticide exposure every time they touch their pet.
If you have any questions, please do not hesitate to contact me. Thank you for your consideration.
Sincerely,
James TerBush
Website Administrator
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I wish I was able to find your site a long time ago and did some research on TriForce Canine squeeze-on before I bought and applied it to my 3 y/o Black Lab named Gunner. I have never used any flea/tick med before, so when I moved to a wooded area and pulled 3 ticks off Gunner in 2 days, I thought it was time to try. I subscribe to a magazine called Gun Dog magazine and saw an add for TriForce. I loved how it said it kills fleas, ticks, and mosquitoes!! I applied it per the enclosed directions (back of neck to a point midway between the neck and tail) on Wednesday, April 15 2009. Within two hours, he started acting weird. Biting at his side, shaking his head violently (which I thought to be his chronic ear infection returning). I kind of ignored it and started treating his ears. Other than that he was normal. Eating, running around, and getting into Lab trouble. Yesterday, Monday, April 20 2009, he started licking at the small area he was able to reach where the TriForce was applied. I tried stopping him but he was extremely persistent. Two hours later he started shaking, was unsteady on his feet, and his eyes were fully dilated. I rushed him to the vet and was administered Atropine via an IV injection. When I returned home, I bathed him with twice with dishwashing soap. All night long he was jumpy, barking at the wall, snapping his head as if you were standing behind him without him knowing and calling to him. He even vomited after he ate. He's a little better this morning, but still acting a little jumpy. I'll be calling the vet soon to see if this is a side effect I need to deal with. I will email you in a few days to let you know how Gunner is doing. Thanks for the website, I'm glad I found this today. Hopefully more people will find this site before they go out and buy over-the-counter flea/tick meds. No one needs to go through the nightmare I and other pet owners have had to endure.
Rob 4/21/09
Western Massachusetts
Just wanted to give you an update on Gunner. Well, he's back to his old troublesome healthy self. I noticed an almost immediate recovery after his second bath. About 3 days after the initial incident with TriForce, he was causing trouble again. I'll keep you informed after I contact the contacts you gave me. Thanks.
Rob 5/19/09
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Our four-year old, much loved Lab/Sharpei cross, a rescue dog, had four grand mal seizures this morning, two days after we gave her a dose of Biospot. We had administered other does to her in previous months, at first with no problems. Last month she seemed uneasy and uncomfortable after the dose--I wish we had paid attention to our gut feelings then.
She is back from the vet's now and is doing well. The Biospot should be out of her system in another 3 days; her blood tests all indicated no visible lasting damage at present. She is on Valium for the next couple of days and phenobarbitol for the next month.
We thought we could save some money with this cheaper alternative to Frontline. We are very, very sorry now and hoping that we have not inadvertently caused lasting damage to our good friend and beloved family member. Oh--and by "saving" on Biospot, we ended up with a $240 vet bill. Not that we hold that against the vet--my point is that sometimes what looks like a savings is far from it!
Clair 4/21/09
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Happy Earth Day, everyone!
It's not easy being green, especially for the manufacturers of toxic flea and tick products. But just because these products pose harm to people, pets, and the environment doesn't mean they can't cloak themselves in green.
Sincerely,
James TerBush
Website Administrator
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My vet just switched our 10 1/2 yr old Chow from Frontline to Vectra 3D. Used the first dose 2 1/2 weeks ago and my dog had a seizure on Apr 18, 2009. I will not be using this product again. My healthy dog has never had a seizure before. The only thing we did diff was give her Vectra instead of Frontline.
Deb 4/23/09
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I gave half dose of advantix 25kg to my two australian cattle dogs. The male weighs 18Kg, the female is around 14[kg]. So I definitely gave them less than the suggested dose. I spread it along the back rim.
Both male and female had itchiness and scratched a lot. But especially the female developed in the next 48-72 hrs a really bad dermatitis which also got infected. I'll send you a picture if you like. It's circular and roughly 4 cm wide. It is exactly were most of the
product was applied. I am a vet by the way.
Vincenzo 4/24/09
Italy
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Hi, I'm a victim of a biospot death.
I like ever year give my little yorkies a hair cut and bath them and then treat them with the biospot flea [and] tick treatment. I gave my little biewers a treatment of the biospot and ever one was fine. I had to go to town and a few hours later come home to a 8 month old biewer puppy dieing because of the biospot treatment. None of my other dogs had any reactions to it. I hurried up and gave all a bath with dawn dish soap.
The dog was as fine as could be before I put the biospot on him. I have no proof that this happened - only that now my dog is dead and I know this was the cause.
Biospot should be pulled from the shelves. I'm so devastated by this. My kids are, too, and you know the saddest part, this little guy was a member of the family. How can I be sure someone else won't go through this.
Patty 4/26/09
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(Below is email that Jan sent to John Hebert at the EPA in regards to their decision on 4/24/09 to remove the list of flea and tick products that were originally published in the EPA Advisory : Increased Scrutiny of Flea and Tick Control Products for Pets)
Dear Mr. Hebert:
Many consumers whose pets suffered catastrophic effects from spot-on products are very disappointed that the recent Bulletin issued by the EPA entitled "Increased Scrutiny of Flea and Tick Control Products" was revised to remove the listing of the 7 products. Are the pharmaceutical companies so powerful to influence the EPA to change the originally published release showing the very dangerous products listed by name?
Pet health and big-pharma profit is an area that has needed the EPA's attention for many years. Consumers have felt incredibly frustrated in attempting to bring this issue to the attention of the EPA inclusive of your requirements of pharmas accountability and follow-through in requiring review and revision of product ingredients, clinical study trial reports and audits and truth in marketing/ advertising campaigns.
My particular case focuses on a family pet as the injured party. I am a pet owner whose dog had an adverse reaction to the flea control product, Frontline Plus. Perhaps you already know that Frontline (made by Merial Limited), is the best-selling flea and tick product in the world. Frontline contains the pesticide fipronil and I believe that it is responsible for causing hundreds of thousands of severe adverse reactions in pets each year. It also has the potential to cause harm in humans, especially young children who play or sleep with treated pets. Merial promotes Frontline as being "gentle" and "non systemic" to animals, but there are many scientific studies which show that fipronil has adverse effects on the nervous systems of people and animals.
Here is the address for a website that features consumer letters reflecting pets' adverse reactions from flea control products:
Here is the webmaster's contact information. He is very involved in the collection of scientific data revealing the harmful effects of these products. His name is James Terbush. He has assisted me in a great deal in research and pertinent information.
I have also completed significant research in the area of fipronil's toxic effects on mammals and have been in touch with many other pet owners whose animals have suffered as well. I initiated a class-action case which was under the guidance of a law firm who had it for almost one year and then decided not to file. They felt that individual cases would be difficult and expensive to `prove' requiring witnesses who could testify in research areas pertaining to chemical analysis and the effect of the chemicals on the body. Pets are also designated in the legal world as `property' and their `worth' reduced in monetary value.
Veterinarians sell/recommend these products via the pharma reps and apparently have not done much research themselves on the adverse reaction outcome. The homeopathic vets do not recommend this treatment, but the allopathic vets do a thriving business. If/when your pet has a reaction after being administered this product, you bring them back. You pay dearly for all services rendered by the vet.
I've spent over $10,000, inclusive of four blood transfusions and hospitalizations as my pet continues to be treated almost three years after his initial reaction, for severe, life-threatening anemia. Merial was less than helpful when I requested on two occasions, in writing, to a Dr. Dixon, a veterinarian on their staff to send me information on clinical study trials to prove the safety and efficacy of the product. She refused and informed me Merial takes no responsibility for my pet's illness and he could have been made ill by any number of circumstances during the course of his very lengthy illness. They actually informed me my case was "unique", natch minimizing the truth in revealing the thousands of other reports they received. It is a clever (and deceitful) way to create doubt in the consumer's mind as to the underlying reason or their pet's illness. Very conveniently also they are aware there is no gas chromatography study for the chemical fipronil - nowhere in the entire country is a lab available that will accept a blood sample and test it to learn if indeed the pesticide has infiltrated the blood and system. One of the largest vet hospitals on the east coast, VHUP and the chief of internal medicine (Dr. Rondeau) informed me this was indeed the case after I requested a lab analysis of my pet's blood. (Merial advertises that the spot-on product remains on the outer-layer (sebaceous glands) and does not penetrate the pets' system). This, of course is not truthful.
Would like to see you hold the pharmas accountable for these dangerous treatment consumers continue to give to their pets on the advise of vets. The EPA, for years remained silent and had little direct response for consumers in analyzing adverse reaction claims. Your recent bulletin was a MAJOR ADMISSION OF REGULATORY SLACKING. How much longer will it take the EPA to complete the investigation while consumers wait? During the waiting phase how many thousands of pets will needlessly be stricken with serious health problems?
Now that there finally is an admission of grave concern by the EPA, please give this immediate attention Place the products you removed back on the page and provide consumers a time-line of direct action. Your Chief Officers should be sending a clear message and insist regulatory processes be met. Until that time they need to issue a directive to the respective veterinary pharmas to take these poisons off the shelves until proper clinical testing has been approved by your bio-chemists not the pharmas chosen biochemists. There are 44,000 pet owners in 2008 alone, by your admission whose names and stories are real and who have spent millions of dollars collectively making the pharmas and the vets quite wealthy while attempting to bring their pet back to wellness after using flea-control, pesticide based spot-products. Please, do the right thing and advocate for the consumer.
Sincerely,
Jan [deleted] 4/25/09
Philadelphia, PA
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Just over the weekend my 8 month old female cat became the victim of Bio Spot. I gave her the recommended dose Saturday night and by Sunday morning I noticed her walking funny and having tremors I didn't piece it together at first and while I was trying to research her symptoms on line, she started convulsing more and drooling. I took her to the emergency vet right away and they confirmed that it was due to the poison from this product. They took her in, gave her a bath and started her on an IV along with medication for the tremors. She was critical but the vet said that her outcome would be good once they cleanse her of much of the toxins. I am happy to report that so far she is doing a lot better. I dropped her off at my regular vet this morning for further monitoring and fluids. Both vets warned me about the use of Bio Spot and other brands that contain permethrin. Even Hartz over the counter products were not recommended. I was told that they only recommend Frontline or Advantage because it doesn't contain that product. While even these have some risk, it is far less than trying to save a few dollars to get something more lethal. I am disgusted that this product is still on the market.
BTW, I found your site very helpful when I was trying to figure out what was going on with her. Thank you very much!!
Lucy 4/27/09
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(Below is email that I sent to John Hebert hebert.john@epa.gov at the EPA in regards to their decision on 4/24/09 to remove the list of flea and tick products that were originally published in the EPA Advisory : Increased Scrutiny of Flea and Tick Control Products for Pets)
Dear Mr. Hebert,
Can you please provide me with details (where, when) of your upcoming meeting with the manufacturers of pet pesticide products concerning the sharp increase in the number of reported incidents from these products? Will the meeting be open to the public? Who has been invited besides the manufacturers of these products? How can I obtain a transcript of the meeting?
Sincerely,
James TerBush
Website Administrator
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I've come across your website when I was actually looking to price out flea and tick products. We have - unfortunately - used biospot for many years. It's really all starting to come together for me. I am a Nurse Practitioner and am starting to realize that some of the problems we have been having with our animals may definately be related to biospot.
About 2 years ago, shortly after applying biospot to our Australian Shepher, Annie she was found unresponsive in the driveway. She later suffered seizures at the vets office and died. We did not really link it. About 8 months ago, our miniature dachshund, Allie, started to go blind. We had used biospot for many years. Now our other miniature dachshund, Gretchen is also going blind. I have to think these are all linked to the biospot.
I would just caution people to not take the chance - it's not worth risking your babies lives and well being to save a couple of bucks.
Karen 4/27/09
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(Below is email that Jan sent to Natasha Joseph at Merial in regards to her press release concerning the EPA Advisory on flea and tick products)
Congratulations for being a loyal Merial employee, Ms. Joseph. However, coupled with the deceptive advertising and false information your company produces regarding the product Frontline, I am surprised you can sleep well at night.
Posted on your recent statement responding to the EPA Bulletin re: Adverse Reaction Reports to Spot-On Flea Products, "The number of adverse events reported per volume of sales has remained consistently low since the introduction of FRONTLINE in 1996. Over one
billion doses of FRONTLINE have been sold, so there is extensive experience with the product in marketed use."
The consumer should believe this? Why? Where is the proof? Reveal the numbers! Bring out the clinical study trials regarding the safety and efficacy of the product. Your customer service reps tell all who call to report an adverse reaction that their pet is a "unique" case. And natch they hardly ever receive calls regarding adverse reactions. Of course then one steps back and becomes curious and begins researching a venue to learn more about consumer response to adverse reaction from Frontline, There are hundreds of letters written electronically and on-line, the pain and frustration palpable regarding the unnecessary illness their beloved pet is experiencing. Your Dr. Dixon refused to release clinical study trial data for review following two requests. She did respond to my letters but only to provide a basic template of verbiage stating my pet could not have become so terribly ill from the application of Frontline Plus. However, I knew that is precisely why he, (and many others) had fallen ill. Very conveniently also Merial is aware there is no gas chromatography study for the chemical fipronil - nowhere in the entire country is a lab available that will accept a blood sample and test it to learn if indeed the pesticide has infiltrated the blood and system. One of the largest vet hospitals on the east coast, VHUP and the chief of internal medicine (Dr. Rondeau) informed me this was indeed the case after I requested a lab analysis of my pet's blood. (Merial advertises that the spot-on product remains on the outer-layer (sebaceous glands) and does not penetrate the pets' system). This pseudo "fact" of course is effective branding for the product, but woefully not truthful.
As you might have surmised, I am a pet owner whose dog had a life threatening adverse reaction to Frontline Plus. I have spent $10,000 attempting to keep my pet alive. After three years of continuous medical treatment and multiple blood transfusions for severe anemia he is just starting to once again become normal regarding his red blood cell count. I have
experienced much guilt, grief and total bemusement about the circumstances of events that encouraged me to give my pet a treatment advertised as innocuous that ended up being a true poison.
Your company has dishonestly advertised the safety of the chemical pesticide fipronil and no regulatory agency has held you accountable. Fipronil is responsible for causing hundreds of thousands of severe adverse reactions in pets each year. It also has the potential to cause harm in humans, especially young children who play or sleep with treated pets. Merial
promotes Frontline as being "gentle" and "non systemic" to animals, but there are many scientific studies which show that fipronil has adverse effects on the nervous systems of people and animals.
Here is the address for a website that features hundreds of consumer letters reflecting pets' adverse reactions from flea control products:
Here is the webmaster's contact information. He is very involved in the collection of scientific data revealing the harmful effects of these products. His name is James Terbush.
If you are really interested in collecting data ask him to provide you the actual letters/consumers names and addresses's and cause and effect circumstance that have been reported due to Frontline Plus. The numbers are rising; and hardly "consistently low."
Consumers have very little power against big Parma. Pet loving owners are hoping that the EPA takes action and finally holds Merial accountable for more complete testing protocols and honest reporting practices. So far your company has done a disgraceful job in both areas.
Jan 4/27/09
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On April 24, 2009, ABC News posted an excellent article, titled, "Injuries from Flea and Tick Prevention on the Rise : Is your Pet Safe? by Sarah Netter," but hours later they had removed it from their website! I am providing excerpts (below) for nonprofit educational purposes, and for the purpose of archiving this article to prevent plagiarism.
Are Your Pets' Flea, Tick Meds Safe?
"A number of animals have suffered adverse reactions to common flea and tick prevention, according to the Environmental Protection Agency. The EPA is now preparing to take a closer look at the chemicals in several popular brands of flea and tick products after reports of injuries and side effects increasing more than 50 percent last year. Worcester said she applied Bio Spot brand flea and tick prevention to Ellie's back as directed and when bumps started appearing on her back a day later, they didn't initially make the connection. But when the bumps spread down her entire back and began leaking pus and blood, the Worcestors took Ellie to their veterinarian, who deduced that the medication had burned her skin. The wounds, Worcester said, were so severe, Ellie had to be put under general anesthesia to remove the rotting skin, a procedure she had done more than once, the other times fully awake. At home, Ellie stopped eating and drinking as Worcester's husband took time off work to change her bandages every three hours. "That was the least of her problems, actually," she said. "We were dealing with huge wounds." After a month of treatments, Ellie began to heal. She's now a year old, but the Worcester's once-perfect puppy has massive scars on her back where her fur has not regrown. "I try to tell everybody not to use this stuff," Worcester, a mom of three, said. "They don't listen." Worcester said she filed reports that included Ellie's veterinary records with Bio Spot and the EPA. Bio Spot, she said, paid for Ellie's vet bills. Dale Kemery, a spokesman for the EPA's pesticides and toxic substances division, said the new evaluation is a "fact-finding effort" to determine the causes of some of the more severe side effects reported by pet owners. Kemery said the EPA got 44,263 reports from animal owners last year, up from 28,905 in 2007. Of those more than 44,000 reports, he said, only 1,200, or 2.7 percent, were considered to be "major incidents" like severe injuries or death. Among the more common adverse reactions the EPA saw were rashes, tremors and seizures, Kemery said. "
OTC Brands 'Not as Good?' "The Washington, D.C.-based Center for Public Integrity released a report last year called the "Perils of the New Pesticides"
(http://www.publicintegrity.org/investigations/pesticides) that detailed adverse reactions to pyrethrins and pyrethroids, chemicals commonly found in many of the flea and tick control products found on store shelves. Looking at numbers provided by the EPA, the center reported that those chemicals were responsible for more moderate to severe injuries than any other class of insecticide from 2003 to 2007. "Good Morning America" resident veterinarian Dr. Marty Becker, who has a practice in Idaho, said the adverse reactions to flea and tick control products are typically caused by two things -- owners not using the products properly and [deleted]. Becker noted that certain breeds such as collies and Rottweilers have an innate sensitivity to any tick and flea product. Hartz, Bio Spot and Sergeant's are three of several companies listed by the EPA as products named in 80 percent of their reports in 2008 (http://www.epa.gov/pesticides/health/flea-tick-control.html). The others were Zodiac, Promeris, TriForce, Sentry and Adams. There were also two Frontline products -- Frontline Plus for Dogs and Frontline Plus for Cats -- that were added to the list. Sergeant's released a statement to ABCNews.com that read, in part, "As the EPA continues to update its list of scrutinized flea and tick control products, it's clear this is an industry-wide issue that affects both over-the-counter products and products sold through veterinarians as well. Sergeant's works with the EPA on a continuous basis and welcomes the EPA's increased evaluation of the use of spot-on pesticides to better protect pets. The health and safety of pets is Sergeant's number one priority." And Central Life Sciences, a division of Farnam Companies, which distributes Bio Spot, said adverse reactions to its products are extremely rare, only in about 1 percent of all applications. "Through our investigations, we have found that in many cases, the reaction is the result of a pre-existing medical condition or misapplication of the product," the statement read, in part. "We urge all pet owners to carefully follow all recommended application guidelines." Central Life Sciences also puts out the Adams and Zodiac brands of flea and tick prevention. Hartz also released a statement saying it supported the EPA's latest evaluation of the chemicals and defended its products as safe and effective when used properly. "Flea and tick products make an important contribution to the health of pets and families, since fleas and ticks can transmit disease," the statement read in part. "
One Owner Staying Away From Flea and Tick Products "Cari Becker, no relation to the doctor, said she no longer uses any flea or tick control on her Italian greyhounds since two of her dogs were sickened after she applied it to their backs in 2001. Becker, who lives in Batavia, Ill., said she had moved into a house in the country and wanted to make sure fleas and ticks didn't find their way into Mia's and Skye's fur. "I was careful to make sure they didn't touch each other," she said. "But in a very short amount of time they were shaking, they were vomiting." As her dogs were seized by tremors, Becker said she immediately scrubbed them with soap and water to get the medication off, and the effects wore off. Though Mia and Skye have since died, Becker said she refuses to use any flea or tick prevention on the two dogs she has now or any of the rescue Italian greyhounds she fosters before placing them into permanent homes. "I don't recommend it to anyone," she said. "I'm not a believer in it at all." Instead, Becker said she's diligent about checking her dogs' short coats to make sure nothing is crawling on them and, so far, there never has been. "When we're sitting with them and stuff, we just check," she said. The Humane Society offers several other remedies to flea and tick prevention on its Web site, including regular vacuuming and grooming with a flea comb as well as frequently lawn mowing and washing of pet beds and blankets. But Kemery and doctor Becker advised against foregoing flea and tick control all together, pointing out that there are insects that can spread to humans as well and cause a hard-to-control infestation. Owners just need to be smart about their use, they said. Becker said it's not uncommon for owners to use products meant for other animals as they try to save a few bucks by buying one product and using it on all animals in the household or buying a product meant for a larger animal and dispersing it among several smaller animals. Because each product is formulated for each species' biology and size, using one product for all animals can cause severe reactions. Cats, for example, often can't process the pyrethrins found in many dog products. "It's not apples and apples," he said. "You can't use a dog product on a cat, you can't use a horse product on a dog." Going to the vet to buy flea and tick medication not only ensures owners are getting the proper dosage and instructions for use, Becker said, the products are usually [deleted]. Vets, he said, are also becoming more sensitive to the economic crunch and will often match prices if pet owners find the same products cheaper online. And the products, even those listed by the EPA, he said, have vastly improved from even just 20 years ago when vets were prescribing baths in pesticides known as "dips" and owners were bombing their house with heavy chemicals to treat infestations. As for Worcester, they now give Ellie a combination medication for heart worm and flea and tick prevention, something that has been decidedly less toxic for her. "The companies do not care," she said. "They're just making their money.""
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(Below is email that I received on 4/29/09 from Doug Parsons at the EPA concerning their upcoming meeting with the manufacturers of spot-on flea and tick products)
Dear Mr. Terbush:
Thank you for your inquiry. EPA expects to meet with manufacturers of spot-on flea and tick products the week of May 4, 2009. This is not a public meeting; however, it is standard practice to prepare a summary of the meeting and place it and meeting materials in the docket for the public to view. This meeting is to discuss the registrants' product licenses and what measures might be necessary to better protect pets. EPA is committed to keeping the public informed as this evaluation proceeds. The FOIA Web site is available at
Doug Parsons
Communications Director
Office of Prevention, Pesticides and Toxic Substances
U.S. Environmental Protection Agency
202-564-0341
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(Below is email that I sent on 4/29/09 to Doug Parsons at the EPA in response to his message above )
Dear Mr. Parsons,
Thank you for the information. I urge the EPA to consider including all of the "stakeholders" in your upcoming meeting with the manufacturers of spot-on flea and tick products - including members of the veterinary community and other advocates for safer pet
pesticide products, such as the NRDC and The Center for Public Integrity. I also urge the EPA to republish the list of flea and tick products which was removed from your Advisory on 4/24/09, effective immediately.
Sincerely,
James TerBush
Website Administrator
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Hello,
I am writing on behalf of CBS 3 in Philadelphia in light of the EPA increased scrutiny of spot on flea and tick products.
We are doing a story about the dangers of spot-on flea and tick treatments.
We would like to find a dog owner and a cat owner to tell us their stories as part of this story.
We are in Philadelphia and looking for a dog owner and a cat owner in our Philly area including New Jersey and Delaware.
If you can help please give me a call or send an email at your earliest convenience.
My condolences to those who have lost their friends.
Thank you so much,
Joan Sill
CBS3
Philadelphia
215-977-5381
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(Below is email that I sent on 4/29/09 to Doug Parsons at the EPA)
Dear Mr. Parsons,
I would like to bring to your attention this press release, which was issued today by Summit VetPharm in regards to Vectra 3D, an EPA-registered flea and tick spot-on product for dogs:
Here is an excerpt:
"Don't let nasty parasites prevent you from enjoying the outdoors with the family dog this summer. As the weather warms, pet owners need to protect their pets against parasites such as ticks, fleas, mosquitoes, sand flies, mites and lice that can transmit vector-borne diseases. Vectra 3D(R) for Dogs is an advanced monthly topical vectoricide that goes beyond traditional flea and tick products."
Could you please tell me what is the EPA's position on "vectoricides"? I admit that I have never heard of vectoricides before, but surely the EPA must be aware of them since this is an EPA-registered product.
Here is Summit VetPharm's website:
Here is an excerpt:
"A new dimension in protection against fleas, ticks and mosquitos"
"Our Vectra 3D® line of products contains a distinctive triple-action formula fleas, ticks and mosquitos have never encountered:"
Here is an additional Summit VetPharm webpage:
Here are excerpts:
"Flea infestations may lead to significant skin disease, tapeworm disease, anemia (especially in very young, ill, or older dogs), or even death. The longer your dog is infested with fleas, the greater risk your dog has of developing these severe signs and consequential diseases."
"How does Vectra 3D reduce the risk of disease?"
"Fleas, ticks and mosquitoes are vectors that can transmit diseases to your dog. The longer they remain on your dog, the greater the chance your dog could get sick. Vectra 3D helps prevent disease transmission by repelling and killing fleas, ticks, and mosquitoes."
Here is the EPA Label Review Manual:
Here are excerpts:
"EPA's regulation, at 40 CFR 156.10(a)(5), provides examples of statements that are considered to be misbranded; such as:"
"A false or misleading statement concerning the effectiveness of the product as a pesticide or device (EPA may review and approve or disapprove non-pesticidal claims appearing on a pesticide label);"
"A false or misleading statement about the value of the product for purposes other than as a pesticide or device;"
"III. Some Examples of Unacceptable Claims"
"Statements that imply or suggest that the product can or will prevent or control disease or offer health protection."
"Claims Such as "Prevents Infection," "Controls Infection", or "Prevents Cross Infection" or that the product will control or mitigate any disease, infection or pathological conditions constitute public health claims and are not acceptable."
"VII. Efficacy Related Claims"
"Implied claims (e.g., any statement, design, graphic representation or brand name) of heightened efficacy of a pesticide product by itself or as compared with another product or device are false and misleading. Examples of such claims include, but are not limited to: "professional strength," "extermination strength," "hospital strength," "industrial strength," "institutional strength," "super strength," "ultra strength," "maximum strength," "maximum efficacy," "extra strength," "double-strength," "triple-strength," "hospital grade," "high potency," and "high-powered" PR Notice 93-6."
"Claims that are inconsistent with efficacy established by testing are unacceptable. For example, a claim of 30-second efficacy is not acceptable if testing and/or use directions require two-minute contact time for efficacy."
"Claims of efficacy based on an unsubstantiated, or improbable site/pest relationship are unacceptable. A claim for control of Legionnaire's disease in cooling tower water is unacceptable."
"X. Claims Made in Advertising"
"Advertising and collateral literature or verbal claims for the product must not substantially differ from any claims made on the label or labeling. See FIFRA § 12(a)(1)(B). In other words, if a claim is not on the label or substantially differs from what appears on the label (or any part of its distribution or sale which for example appears on a brochure), it cannot be made in advertising. Although OPP does not routinely review advertising in connection with the registration, the Agency may require advertising used in the marketing of the product to be submitted upon request and then reviewed it to see that it is in compliance with FIFRA section 12(a)(1)(B)."
Based on the statements made on Summit VetPharm's website, and in their press release, dated 4/29/09, it is apparent that Vectra 3D is in violation of FIFRA and should be considered to be misbranded. Even the name, Vectra 3D, implies efficacy against vector-borne diseases.
I urge the EPA to take immediate action to resolve this matter.
Sincerely,
James TerBush
Website Administrator
Copyright © 2002-2009 BioSpotVictims.org All rights reserved.
DISCLAIMER: Below are messages that I have received from others whose dogs and cats experienced adverse reactions after using flea control products. I have no way of knowing if the information in these messages is factual, or if the products they used were the actual cause of the adverse reactions.
