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Just-rescued lab mix "Daisy" romps through spring surf at Jennings Beach in Fairfield, CT
“If a huge skull and crossbones were suspended above the insecticide department,
 the customer might at least enter it with the respect normally accorded death-dealing materials.” 
—Rachel Carson, Silent Spring

German shepherd dog seems as not enjoying himself at Jennings Beach in Fairfield, CT
Rex: beset with the furrowed brow of vex...
PART 1 OF TWO.  Many of today's synthetic insecticides are powerful poisons that had their origin in the development of chemical warfare agents (neurotoxins), and are classified as carcinogens (cancer causing) by the EPA.[1] 

Organophosphates[2] (OPs) and carbamates[3] are common synthetic pesticides found in flea & tick killers.  Both are nerve-paralyzing agents capable of causing convulsions, nausea and respiratory arrest: not only in the insects they are intended to obliterate, but in the host animal (your dog) as well.  Research spanning decades classifies many as mutagents (causing genetic damage), as well as hormone and immune system disrupters. 

The peak flea and tick season invariably results in many cases of pesticide-related poisoning of not only the targeted dog or cat, but also children and other pets who touch them.  Paradoxically, application instructions on certain products direct you to vigorously rub powders deep into your dog’s coat, or soak a flea-infected dog thoroughly with a bottled or spray formula… while in parallel, warning of the hazards to humans, often admonishing: “do not pet” your dog for 24 hours, and even to keep multiple dogs separated during that period.  Under what circumstances would you take your child to a facility for a bath in poison, (such as we do when a "flea dip" is advocated?)  Insecticidal powders (including dispersions from flea or tick collars) can be inhaled or licked off by your dog; and especially in liquid formulations, these chemicals can be absorbed through his skin and taken up by the blood, circulating through his entire system, setting the stage for genetic damage
and vital organ failure. 

Aside from immediate toxicity, many researchers link the rise in cancer seen in companion animals and residual chemical persistence in the environment to the use of chemical pesticides against fleas and ticks.  For that reason, even in the midst of an insect invasion, it's important not to let the urgency of your need to get rid of the pests override the risk factors for your dog, other pets, and the household; nor, to be complacent about the pervasive environmental issues raised by use of these products, which the National Resources Defense Council describes as “rash and unnecessary.”

Lab mix "Mac" is fleet-of-foot nimble on Jennings Beach in Fairfield, CT
Mac: the fleet-of-foot
The myth of “Safety.” 
It is unwise to assume that because a product is available at the grocery store, that it has been tested for safety.  Nor should you take this assumption regarding a “professional” pest control applicator, or even products recommended by your veterinarian. 

The 1947 law regulating pesticides—the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) ( [P.L. 75-717] 7 USC § 136 et.seq.)—is based on a risk-benefit standard, and does not use safety as the fundamental basis for permitting a pesticide on the market.  This allows pesticides to be used even if they pose hazards to humans and the environment,[4] so long as the benefits outweigh the hazards: any health or environmental peril can be acceptable if the estimated economic benefits are large.

FIFRA has been amended many times, most recently through the 1996 Food Quality Protection Act; however, imposed deadlines have not been met, some registered pesticides do not meet current testing standards, and the EPA has little information about the cumulative impact of multiple OPs or of other chemicals that function similarly.

Older golden retriever "Sam" tows in a branch on Jennings Beach in Fairfield, CT
Sam: what purpose is there, in dry?

“Active” vs. “Inert” Ingredients.
 
To evaluate the risks associated with any of these products, it is important to understand that flea & tick pesticides are made up of more than one chemical: composed of “active” ingredient(s), whose identity must be listed on the label (percentage by weight); and “inert” ingredients which do not have to be disclosed. 

FIFRA allows manufacturers confidentiality on issues they claim would otherwise make them vulnerable to market competition.  As such, “inert” ingredients became protected by industry as “trade secrets.”  60 years on, however, it is clear that the act protects commerce, yet impedes the consumer’s awareness of health hazards resulting from exposure to un-named chemicals.  Without full disclosure, the consumer is unable to make educated decisions as to which chemicals to avoid.  Contemplating concepts of consumer rights and manufacturer liability exposure, it is troubling to remember that legally, dogs are considered “property,” and therefore limited in value to "cost of purchase."

While the word “inert” suggests benign effect (and likely connotes safety to the consumer), this is misleading, because these undisclosed ingredients are neither biologically, chemically, nor toxicologically inactive.  Legally, “inert” merely means those substances are not the “active” ingredient.  From a marketing perspective, consumers may feel comforted by the concept that a product contains only a minuscule amount of an “active” ingredient, and up to 99.9 percent “inert” ingredients;  suggesting they are inactive: probably only carriers, conditioners, etc.  The reality should be opposite: because testing required for Environmental Protection Agency (EPA) registration is rigorous only for the “active” ingredients, whose toxicological profiles must be disclosed on inserts and packaging.  Not so, for the “inert” ingredients, generally tested in short-term studies for acute (immediate) toxicity only: the cumulative and synergistic effects of these chemicals are not required to be tested for safety.  In actuality, many “inert” ingredients are as toxic, or more toxic, than the registered “active” ingredients.[5]  In 1987, EPA “requested” registrants of pesticide products to voluntarily substitute the term “other ingredients” in lieu of the term
“inert ingredients” on the label.[6]

Bulldog "Cooper" is nonpareil, the most excellent fellow along Jennings Beach in Fairfield, CT
Cooper: the most nonpareil fellow

The price of safety.
 

US consumers expect that products on store shelves have been vetted (registered) by the EPA’s Pesticide Division for safety before marketing.  But how (or if?) is this accomplished? 

Laboratory toxicological (poison) testing is done on healthy “domestic animals” (mice, rats, dogs and cats) to confirm the median lethal dose or LD50: the oral dose at which the product would kill 50 percent of a of a test population after a specified test duration, in order to determine acute (not chronic) effects.  Similar measures include LC50 (Lethal Concentration, 50%) or LCt50 (Lethal Concentration & Time, 50%), also known as Haber's Law: a mathematical statement of the relationship between the concentration of a poisonous gas and how long the gas must be breathed to produce death, or other toxic effect. 

The dose level found to not lead to adverse effect, called the No Observed Adverse Effect Level (NOAEL), serves as the basis for EPA safety level, or “reference dose.”  The results are mathematically extrapolated to make judgments regarding general consumer application, adjusted for weight of the dog, although the very generalized nature of the process may make that figure unreliable.  During and following the study, certain surviving animals are killed in order to review identifiable system damage to vital organs (lungs, kidneys, etc.). 

Australian shepherd/cattle dog mix, "Kinn," warily eyes the camera on Jennings Beach in Fairfield, CT
Lulu: a courser's gaze
Acute disease tests (skin reactions, nervous system effects) can reveal issues in a comparatively short time period.  These studies are conducted for 3 to 52-week intervals, using exaggerated dosages to compensate for the short testing periods.  While health effects resulting from high doses[7] of the chemicals are relevant, they do not reveal possible chronic effects (examples: cancer, developmental or reproductive damage, DNA damage, immune system suppression) that may take months or years to manifest.  Commonly also unaccounted for, is individual, sex, and breed sensitivity: a minimal “impact dose” for one animal could be lethal to another, even adjusted for weight; small and other so-called high-strung breeds or females are particularly susceptible to neurotoxin adverse side-effects.

Long-term testing is not generally undertaken, and as such, the cumulative effect of pesticide use over the lifetime of the dog is simply not known.  Further, the EPA does not require testing for the synergistic effect of the combined influence of chemical exposure and outdoor environments (not replicable in the laboratory).  In the final analysis, we are failing to acknowledge and question that, essentially, it is the dog himself who becomes a living chemical research vessel of insecticide over his lifetime.

Remember that pursuant to FIFRA, the EPA registers pesticides on a cost-benefit basis: weighing health and environmental concerns against the economic gain/benefit to the manufacturer and the end user of the product.  As such, this “risk-benefit balancing analysis” represents an especially significant relationship to “over the counter” (OTC) treatments, which may cost less than half of a veterinary supplied product. 

Currently, no pre-market clinical trials (studies on pets in a “real world” environment, before the product goes on the market) are required for EPA approval, and the confined, short-term tests are often only on one breed of dog, limiting the veracity of predicted effects across a broader population of users.  According to the National Research Defense Council, the EPA’s “risk assessments have been handicapped by flawed and inconsistent assumptions that understate the risk from pet products,”[8] and which do not adequately account for environmental issues of pesticide bio-accumulation, bioconcentration and pesticide biomagnification.  In fact, in the summary of meetings between the EPA and manufacturers (click here for PDF), EPA investigators found that the data the EPA now requires for registration do not accurately predict the toxicity when the product is approved and being widely used by consumers.

Yelllow labrador retriever, "Honey," awaits a tossed ball on Jennings Beach in Fairfield, CT
Honey: locked onto a gull, beckoning overhead

Traveling protection: “Spot-ons.”

As a profitable sales strategy, manufacturers drive the concept of insect killer/repellants that “travel” with the dog as a convenient response to the busy lifestyle of the modern consumer.  These “spot-applied” synthetic, chemical-based insecticides bear names (developed through market research) that suggest protection and safety (Guardian®, Advantage®, Frontline®, Advantix®, Interceptor®, and others).  But few consumers have a reasonable understanding of how these products work, that the toxic ingredients enter their dog’s internal filtering organs (liver and kidneys), move through his intestinal tract (where 80% of his immune system resides), and are eventually eliminated in his feces and urine into the environment.
 
The oil-based drops are placed between the dog’s shoulder-blades to prevent him from licking it off.  A common (off patent) ingredient is imidacloprid (Bayer’s Advantage®), a nicotine-based insecticide, belonging to a class of chemicals called neonicotinoids.  These chemicals act as a neurotoxin and interfere with the transmission of nerve impulses in insects by binding to certain nicotinic acetylcholine receptors, causing paralysis and death.  Neonicotinoids are selectively more toxic to insects than warm-blooded mammals, because they block a specific neural pathway that is more abundant in insects; hence their efficacy as synthetic broad-use insecticides, particularly in lage-scale agricultural applications.  However, the French Minister of Agriculture suspended the use of imidacloprid as a treatment for sunflower seeds (1999) and corn (2004) owing to studies linking it to collapse of honeybee populations.  Other European regulatory agencies have likewise suspended use of similar systemic neonicotinoid
pesticides for this reason.

Chihuahua "Marcey" turns a smart foot on Penfield Beach in Fairfield, CT
Marcey: turning an elegant shoe
Using seemingly contradictory terminology, manufacturers seem to imply that these chemicals are not absorbed into the dog’s system, but remain on the surface of the skin.  As an example, Merial Limited states that Frontline® is “not systemically active,” but describes translocation (a change in location): that Frontline® is “gradually dispersed by the pet's natural oils, collecting in the oil glands in the skin… then wicked onto the hair over the next 30 days” (diffusion and capillary action; transfer from hair to hair as the dog moves); and “Frontline® will not go into the bloodstream and hence very safe...” But this suggests an illogical conclusion: that fipronil (the “active” ingredient) remains in the sebaceous (oil) glands beneath the skin— and then leaves through the same entry point (to the hair) without moving into any other part
of the dog’s body.

However, a 1996 EPA memorandum, “Review of Domestic Animal Safety Studies,” cites a study: “in which radio-labeled fipronil was administered to dogs… demonstrat(ing) that the chemical is absorbed systemically.  Plasma (intravascular fluid containing blood cells) levels of radioactivity were detected from day 2 to day 30 post-treatment.”  Regarding packaging, the EPA concluded: “These statements (that “Fipronil is not absorbed into the body”) should be deleted from the label”
(click to view PDF). 

When fipronil is exposed to light it can break down (photo-degeneration) into a smaller molecule called MB4651324 or fipronil-desulfinyl, which because of its size, can penetrate skin more readily.  Based on acute toxicity testing sponsored by the manufacturer, a 1998 EPA Health Effects Division risk assessment estimated that MB4651324 is nearly 10 times more toxic than fipronil itself.  EPA identifies fipronil as highly toxic to certain birds and fish (1996), and UK researchers (2003) identified its “half life” persistence in soils up to 7 months.  Scientists at Murray State University (KY: 2002)  found that during the first month after treatment, petting an animal transferred fipronil from the animal to the person.  And remember, the chemicals in Frontline are supposedly among the “more safe group of spot-ons.”[9]

The active ingredients in Frontline Plus®[10] are Fipronil (9.8%) and S-methoprene (8.8%).  Fipronil is a synthetic broad use insecticide that disrupts the normal nervous system functioning of insects by blocking the passage of chloride ions through the GABA receptor and glutamate-gated chloride (GluCl) channels, leading to hyper-excitation, paralysis, and death.  This is how nerve gas works.  In laboratory tests, finopril was shown to cause kidney damage, and altered levels of sex and thyroid hormones.[11]  S-methoprene is a biochemical insecticide and insect growth regulator that mimicks natural juvenile hormone of insects. Juvenile hormone must be absent for a pupa to molt to an adult, so methoprene treated larvae will be unable to successfully change from a pupa to the adult insect. This breaks the biological life cycle of the insect preventing recurring infestations.[12]  81.4% of the ingredients in this product are captioned as “inert” and as such, neither the consumer or his veterinarian has means to gain knowledge about what they are, or what their toxicological effects might be.

Shepherd-mix "Bonnie" stolls toward the water's edge on Jennings Beach in Fairfield, CT
Bonnie: the eyes as windows to a gentle soul

Remedies that lead to illness and death.
 
Over a recent 5-year period, at least 1,600 pet deaths related to spot-on treatments were reported to the EPA.  In 2008 alone, the EPA recorded 600 deaths and 44,263 non-lethal complaints about spot-on flea & tick killing products.  It’s not clear how many more consumers experienced issues, but did not file complaints with the federal agency.[13]

In April of 2009, the EPA announced they were increasing investigations of these pesticides, widely advertised as “safe when applied as directed.”  It’s also not clear why the agency did not reveal what they knew or provided warning, while pets were sickened or killed.  No recalls were issued, and the EPA concluded that incidents were primarily the result of improper application by consumers.  It has been suggested that this increase may coincide with the timeframe that some of these
products began to be offered in retail outlets and through online vendors, and as such, those sales would lack traditional veterinary advice.  EPA-registered spot-on products are available as “non-restricted use” products that are commercially available through many sellers— the EPA does not establish who can sell these products, and there is no prescription vs. “over the counter” (OTC) classification of pesticide products— the manufacturer determines how they want
to distribute their product.

After revisiting the safety of these products the agency had previously approved, in March of 2010, EPA announced it will pursue changes in labeling to reduce consumer confusion, establish narrower weight ranges for per-vial dose of spot-ons, and “develop more stringent testing and evaluation requirements for both existing and new products.”  The EPA also indicated that a review of “inert (undisclosed) ingredients” (regarded as industry trade secrets) was important, owing to the “toxic properties” and potential for interaction of some ingredients; (view PDF).

Unfortunately, these actions don't address the larger concerns about the roles of economics and politics play in cost/benefit evaluation and registration (pre-market approval) of these chemicals.  Based on EPA's analysis, not all of the pet poisonings can be explained by consumers misusing the products, and this brings into question the safety of the products themselves.  Moreover, the review was narrow: other organophosphate and carbamate chemicals used in flea and tick collars, powders, sprays, and other products aren’t covered by the new protocols.[14]

Boxer-pit mix "Marty" posesses an infectious cheer on Jennings Beach in Fairfield, CT
Marty: antennae up, "tuned in" to frolic
The concentrations of pyrethroids (synthetic pesticides) in OTC spot-on products (example: Farnam Bio-Spot®, Hartz Ultraguard®) range from a 40% to an 85% solution: up to 17 times stronger than the toughest pyrethroid product currently approved for use on humans.  Neither the Food and Drug Administration (FDA: regulating orally administered pet products), or the EPA, (regulating topically applied products), has registered a product for human application containing a pyrethroid concentration above 5%— and that FDA-approved product requires a doctor's prescription.  EPA’s registration branch assumes that these high concentrations may be necessary because dogs (and cats) are more likely to come in contact with fleas and ticks. 

While the application instructions for Sergeant's Squeeze-on for Dogs directs the consumer to apply the treatment “to the dog's skin,” the warning section of that same label cautions: “Harmful if swallowed or absorbed through skin,” (presumably human).  According to a 2008 study published in The Veterinary Journal, dermal exposure by application to the skin or coat is the most common route of toxic exposure, potentially causing seizures leading to brain damage and death.  The label of Hartz Ultraguard® Flea & Tick Dip for Dogs, a liquid intended for literally soaking a dog or cat in, cautions: “Environmental Hazards: Toxic to fish. Do not contaminate any body of water with this concentrate or dip.”  Other Hartz spray-on products are labeled as toxic to aquatic invertebrates (animals without a backbone, such as insects, worms, mollusks, sea stars, jellyfish and others), and which represent food sources for avaian and coastal dwelling mammals.

Among the many controversies that Hartz Mountain Industries has been engulfed in, its Blockade®, an aerosol flea & tick spray backed by a multi-million dollar advertising campaign, was discontinued in 1987, after the company acknowledged that it had caused 366 animal deaths and 2,700 injuries; (as well as 56 human injuries).  Hartz had been vigorously fighting negative press reports for years, during which time it added a precautionary wired-on tag to the cans as an interem step. 
Black labrador retriever "Leroy" stops for a moment of wistful reflection
Leroy: a moment of wistful reflection
Reviewing the company’s LD50 and LC50 lethal toxicology studies, the EPA observed that Hartz’s methodologies were “inadequate to demonstrate the safety of the formulation,” and that since “the application rate of normal anticipated use” wasn't even specified, there was “no indication as to what margin of safety (was) present”; (click to view PDF).  Eventually Hartz paid the EPA $45,000 to settle charges that they failed to report animal illnesses and deaths; EPA registration was cancelled in 1999.  Subsequent replacement products seemed little more than reformulations.

In 2005, the EPA cancelled permission to use phenothrin in certain flea and tick products, at the request of Hartz itself.  
The products were linked to a range of adverse reactions, including hair loss, salivation, tremors, seizures, and numerous deaths in cats and kittens.  Initially, the agreement called for new warning labels on the products.  In March of 2006, the sale and distribution of Hartz's phenothrin-containing flea and tick products for cats was terminated.  Consumer advocates complained that Hartz was clearly aware for years that the products were dangerous, and even once discontinued, they were not removed from retail shelves and continued to be sold, indefinitely.  EPA's product cancellation order did not apply to Hartz flea and tick
products for dogs,
and Hartz continues to use phenothrin in a concentration of 85.7% in its Ultraguard® line of
flea and tick products for dogs.

“The use of any product on the market
to control fleas on pets
 is associated with a degree of
hazard to the animal.”
—Claude Kissin, Vice President,
Hartz Mountain Corp., 1987

1987: Hartz Blockade® withdrawn from sale; 
Today: Hartz Ultraguard® Flea and Tick Collar
for Dogs; Active ingredient:
Tetrachlorvinphos (14.55%)
(classified a likely human carcinogen);
Inert (undisclosed) ingredients, 84.43%.
 

Labradoodle "Lily" posesses an infectiously sunny disposition on Jennings Beach in Fairfield, CT
Lily: Can you spell "Supercalifragilisticexpialidocious" ?!
ENDNOTES:
[1]  Journal of Pesticide Reform v.17, n.3 Fall97; Northwest Coalition For Alternatives To Pesticides.  See also: Reregistration Eligibility Decision (RED) for Permethrin, EPA 738-R-06-017, April 2006.

[2]  Organophosphates are biochemicals, esters of phosphoric acid.  Organophosphates are the basis of many insecticides, herbicides, and nerve gases, effective by irreversibly inactivating acetylcholinesterase, an enzyme which is essential to nerve function in insects, humans, and many animals.  They can be absorbed through the lungs or skin, or by eating contaminated food.  Studies indicate a possible link to adverse effects in the neurobehavioral development of fetuses and children, even at very low levels of exposure: research spanning decades idenfities them as mutagents (genetic damage), as well as hormone and immune system disruptors.  Organophosphates are widely used as solvents, plasticizers, and
Ethylene Propylene additives.


[3]  Carbamates are organic compounds derived from carbamic acid: These insecticides kill insects by reversibly inactivating the enzyme acetylcholinesteraste; (see footnote 2, immediately above).

[4]  FIFRA defines the term “unreasonable adverse effects on the environment” to mean: “(1) any unreasonable risk to man or the environment,  taking into account the economic, social, and environmental costs and benefits of the use of any pesticide, or (2) a human dietary risk from resideues that result from a use of a pesticide in or on any food inconsistent with the standard under section 408 of the Federal Food, Drug and Cosmetic Act”; (click here).

Young basset hound "Tank" on an early morning stroll across the public trust area of Penfield Beach in Fairfield, CT
Tank: a conspicuously dignified fellow
[5]  Example: naphthalene, an “inert” in an imidacloprid product, showed clear evidence of cancer activity through inhalation (nasal cancers), as well as anemia, liver damage, cataracts, and skin allergies.  An “inert” (unidentified) ingredient in the flea product Advantage® was implicated in the death of kittens who received doses within laboratory tolerances. (Kathleen Dudley, 2002: Are “Spot-On” Flea Killers Safe?).

[6]  Status Report for PPDC, 
EPA. 1987. Inert ingredients in pesticide products (click here); Policy statement. Fed. Reg. 52(77):13305, Apr. 22 (click here).

[7]  
  Examples: head-nodding; facial twitching; exaggerated blinking; gag responses; weight increase of the spleen, thymus, and adrenal glands; and/or atrophy of the thymus.

[8]  Wallinga & Greer, 2000: Poisons on Pets, Heath Hazards from Flea & Tick Products; NRDC (click here).

Short-coat mix "Timon" casts a thoughtful eye across the public trust area of Penfield Beach in Fairfield, CT
Timon: the circumspect adventurer
[9]  According to an analysis by the Center for Public Integrity, more than 1,600 pet deaths related to spot on treatments with pyrethroids were reported to the EPA over a recent 5-year period, about double the number of reported fatalities tied to similar treatments without pyrethroids, such as Frontline® and Advantage®.  Pyrethroid spot-ons also account for more than half of “major category” (brain damage, heart attacks, violent seizures) pesticide pet reactions reported to EPA in that period.  The EPA received more than 25,000 reports of pet pesticide reactions (fatal, major, moderate, and minor) to OTC pyrethroid spot-on products; compared to 10,500 reports of all pet incidents related to shampoos, powders, sprays, collars, dips, mousses, lotions, and towels. This analysis does not consider how much of each product was used over the last five years, as the EPA does not have that information.

[10|  The patent on fipronil has expired, and "generic" products include Sergeants® Sentry Fiproguard/Fiproguard Plus™ and Fidopharm PetArmour™.

[11]  Journal of Pesticide Reform, vol.25, n.1 Spring 2005; Northwest Coalition For Alternatives To Pesticides.

[12]  S-methoprene mimicks natural juvenile hormones of insects, which much be absent for treated larvae to mature into adults; therefore breaking the flea life cycle.  Referred to as a biochemical insecticide (not directly toxic, but causing chemical changes in the host animal), it is used as a food additive in cattle feed, and to control mosquito infestations in drinking water cisterns.  It has been suggested that methoprene is responsible for killing and stunting the growth of lobsters in
Narrangansett Bay, RI.

[13]
  Information about reporting adverse events: click here.  According to the report, in 2010: 27,216 reported incidents; 2009: 36,472 reported incidents.  Though that may appear an improvement , most of the reduction was due to the number of incidents reported for one product: Sergeant’s Gold® Flea & Tick Squeeze-On for Dogs (EPA Reg. No. 002517-00080), which is also sold under the name Sentry Pro XFC® and TriForce Canine Squeeze-On®, which were discontinued (not recalled; and still being sold) in 2010, (and no longer appear on Sergeant’s website).

[14]  Looking for more preventive action, in 2009 the National Resources Defense Council (NRDC) filed a lawsuit against major pet product retailers and manufacturers that sell a flea and tick control product containing propoxur, under California’s Proposition 65 list because it is known to the state to cause cancer.  NRDC is also petitioning the EPA to ban all uses of tetrachlorvinphos in pet products, citing evidence that the chemical is a carcinogen.
Whippet "Tucker" dashes along Jennings Beach in Fairfield, CT
Tucker: K-9 torpedo
Among actions that EPA will pursue are: •1) Requiring manufacturers of spot-on pesticide products to improve labeling, making instructions clearer to prevent product misuse; •2) Requiring more precise label instructions to ensure proper dosage per pet weight; •3) Requiring clear markings to differentiate between dog and cat products, and disallowing similar brand names for dog and cat products; •4) Requiring additional changes for specific products, as needed, based on product-specific evaluations; •5) Granting only conditional, time-limited registrations to allow for post-marketing product surveillance.; •6) Evaluating certain inert ingredients; and •7) To improve regulatory oversight, require more standardized post-market surveillance reporting on adverse effects, require submission of more sales information so EPA can evaluate incident rates, and bring up-to-date the scientific data requirements on pre- and post-market testing so they align with FDA requirements.
To report an adverse event associated with a pesticide (such as a flea and tick product), 
notify the National Pesticide Information Center (NPIC: 1-800-858-7378, 7:30am - 3:30pm PST)
NPIC provides these reports to the EPA under a cooperative agreement. 
Also, consider reporting the incident to the product's manufacturer: pursuant to FIFRA,
manufacturers are required by law to submit reports of adverse effects to the EPA
(click here).

Complete Directory of Flea & Tick Products → click here

NEXT: [Page 2] Continued; Flea & Tick Treatments → click here

Boxer "Farley" emerges from the surf on Jennings Beach in Fairfield, CT
Farley: a moment before landing... a wet kiss!

N.B.: This essay is written for informational purposes.  Our goal is to build awareness of concepts and define common terminology to stimulate creative thinking, so that you may effectively conduct your own research.  We draw your attention to concepts, issues or authors that are or may be important to the subject at hand, but do not consider that our interpretation is necessarily complete.  This essay is by nature, narrowly focused: there are numerous scholarly writings, as well as detailed EPA web pages, on this topic; which we encourage you to seek out.  We would welcome your comments or suggestions!  We are not medically trained, nor legal experts.  We believe that the most important thing a dog guardian may do in his companion's lifetime, is work to build an understanding of manufacturing and regulatory processes for dog food, the basics of dog food labeling; and issues involving use of pesticides on and around household pets.  We encourage you to discuss this topic thoroughly with your veterinarian.  This essay is focused on products meant for dogs: it is important to remember that pest control or medicine products intended for dogs should NEVER be used on cats. 
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Brown labrador "Browsie" is luminous in the early morning light off Penfield Beach in Fairfield, CT
Browsie: coy... luminous
“The dog observes us, thinks about us,
knows us.  Do they then have some special knowledge about us, born of their attention us and to our own attention?  They do.

In a non-verbal way, dogs know who we are, they know what we do, and they know some things about us unknown to ourselves. 
We're knowable by look and even more so by our smells.  Over and above that, how we act defines who we are.  For dogs, the identity of a person not just how s/he smells and looks; it is how s/he moves. 
We are recognizable by our behavior.

Even our most ordinary behavior, walking across a room in our characteristic style—
 is chock full of information that the dog can mine.  All dog owners watch thier pups' growing sensitivity to the rituals that precede going for what in many dog peopled households is called a W-A-L-K.  And spelling that word instead of saying it is, of course, usually futile.  Dogs can also learn the connection between the cadence of a spelled word and a subsequent walk, even if the latter does not immediately follow the former.  On the other hand, used in an unlikely context—say, sitting in the bath—the spelled word will not evoke much interest.  Chances are slim you’re about to up and take a walk when naked and sudsy.

Dogs quickly learn to recognize shoe-donning, of course; we come to expect that grabbing a leash or a jacket
will clue them in; a regular walk time explains their prescience; but what if all you did was look up from your work
or rise from your seat before you dog was on to you?

If done suddenly, or if you cross the room with a purposeful stride, an attentive dog has all the information he needs. Habitual watcher of your behavior, he sees your intent even when you think you are giving nothing away. 
Dogs are very sensitive to gaze and thus to changes in our gaze.  The difference between a head lifted up or angled down, away from them or toward them, is large for an animal so sensitive to eye contact.  Even small movements of the hands or adjustments of the body attract notice.  Spend three hours looking at a computer screen, hands tethered to the keyboard... then look up and stretch your arms overhead—this is a metamorphosis! 
The redirection of your intent is clear—and a hopeful dog can easily interpret it as a prelude to a walk. 
An acute human observer would notice this too, but we rarely let others oversee us so closely in our daily affairs.”
—Alexandra Horowitz; Inside of a Dog

(Click here to continue to page 2: Controversies & Remedies for Flea & Tick Problems)

You can brighten the long, lonely day of a needy dog: consider volunteering at a shelter.
Your used but servicable linens, towels, bathmats, or cushions can provide comfort while he waits.
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