Tetra-who-vin-what?

Today, we’d like to start by talking about the Hartz Rabon Collar with (s)-Methoprene.

This product contains 1.02% (s)-Methoprene but the dominant ingredient, at a concentration of 14.55%, is a nasty little guy called tetrachlorvinphos, AKA Rabon. This product is not only a direct Hartz product, but Hartz distributed this product to Zodiac and Defy. Interestingly, the Zodiac and Defy versions of this product were cancelled on May 28, 2009.

Tetrachlorvinphos (TCVP) is one of the last dinosaurs of the deadly organophosphate family of pesticides used to kill fleas and ticks. Hartz would have you believe this chemical is safe, but the Natural Resources Defense Council (NRDC), one of the most respected non-profit organizations in the country, has quite a different opinion:

“TCVP interferes with an essential enzyme, acetylcholinesterase, which normally controls messaging between nerve cells. It kills fleas and ticks by inducing spasmodic overexcitation of the nervous system. In large doses, it can harm or kill cats, dogs and, in extreme poisoning cases, humans. At lower levels of exposure, TCVP cause [sic] a variety of poisoning symptoms, many of which can mimic common illnesses; these include nausea, vomiting, diarrhea, wheezing, sweating and tearing eyes. More severe poisoning can cause muscle twitching, drooling, seizures, respiratory paralysis and death.

Young children are also particularly vulnerable to TCVP and other pesticides because their bodies and brains are still developing, and chemicals that interfere with the nervous system during development may cause long-term or permanent damage. Some recent research indicates that exposure to this type of pesticide can impair children’s neurological development, resulting in pervasive disorders that may include delays in motor development and attention deficit/ hyperactivity disorder.

Where it is Found

TCVP is used in pet flea and tick collars, shampoos and powders. Flea and tick collars can leave high levels of pesticide residue on a pet’s fur, posing a health risk to adults and children who play with the pet. Children are especially vulnerable, as they may be more likely to spend extended time in close contact with pets, or put their hands in their mouths after petting an animal.”

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Here is more concerning information from the NRDC:

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Child Poisoning Linked to Use of Flea Control Product*

In August 1999, a two-year-old boy was rushed by his parents to the emergency department of a hospital in Modesto, California. The child had had a seizure and was unresponsive; he had severe muscle weakness, no reflexes, strange eye movements, abnormal pupils, irregular breathing, and a rapid heart rate. Routine laboratory results were all normal; a brain MRI showed no abnormalities and an EEG showed diffuse slowing of brain activity. The child was put on a respirator and admitted to the intensive care unit. The father reported that he had used Zodiac Flea Spray, which contained a carbamate pesticide, in the house a few days previously.

The laboratory reported that the child’s level of a critical enzyme, cholinesterase, was severely depressed. Cholinesterase in the blood was less than one-tenth the normal level, and in the child’s red blood cells it was less than half of what is considered minimally normal. Cholinesterase is essential for transmission of nerve signals in the body. It is also the target of certain pesticides, including carbamate chemicals in flea sprays and collars. When cholinesterase levels in the blood drop, as in this child, a variety of severe medical problems occur. However, the symptoms of carbamate poisoning in young children are often different from those seen in adults, and this can confuse health care providers.** Adults may develop vomiting, diarrhea, profuse sweating, tearing eyes, and muscle twitching, along with more serious neurological symptoms. Poisoned children often come to the hospital with flaccid muscles, seizures, and coma—just as this child had.

Over the course of a week, the child slowly recovered with treatment; he resumed breathing on his own and gradually woke up. He was discharged from the hospital after 10 days, and tube feedings were stopped several days later. The record indicates that he recovered from this event. Information about long-term impacts, however, is unavailable.

*Case report obtained from the California Poison Control System confidential database and provided to NRDC without personal identifying information.

**Lifshitz, M., Shahak, E., Sofer, S. “Carbamate and Organophosphate Poisoning in Young Children.” Pediatric Emergency Care, 1999. 15(2):102-3.

In mid-2009, the NRDC requested the cancellation of tetrachlorvinphos for pet uses. The debate is ongoing but, through our correspondence with the EPA, we have been informed a determination should be released before the end of this year.

Until then, animals are just going to keep dying.

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This is Tigger. He was exposed to only a small amount of Hartz Flea & Tick Powder. This beautiful, healthy animal, who had recently been given a clean bill of health, died within 2 days of exposure to this product's active ingredient, tetrachlorvinphos.

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The NRDC may have only submitted its cancellation petition in 2009 but, interestingly, the EPA released a 185-page document called, “US Environmental Protection Agency Office of Pesticide Programs, Reregistration Eligibility Decision for Tetrachlorvinphos” back on July 31, 2006.

This document addresses all manner of uses for TCVP and the EPA’s interim decisions on how to mitigate risks. In the case of Residential products, the EPA was most concerned with vague dosage instructions. Here are the relevant points to the matter at hand:

(Page 7, Paragraph 3, Sentences 2 and 3)

“The Agency believes that current uses of tetrachlorvinphos may pose unreasonable adverse effects to human health and the environment, unless the risk mitigation measures identified herein are implemented. Accordingly, the Agency recommends that registrants implement these risk mitigation measures immediately.”

(Page 7, Paragraph 4, Sentence 1)

“Should a registrant fail to implement any of the risk mitigation measures outlined in this document, the Agency will continue to have concerns about the risks posed by tetrachlorvinphos.”

(Page 42, Paragraph 1, Sentences 3 and 4)

“The Agency has determined that tetrachlorvinphos is eligible for tolerance reassessment provided that: (i) current data gaps and additional data needs are addressed; (ii) the risk mitigation measures outlined in this document are adopted, and label amendments are made to reflect these measures; and (iii) cumulative risks considered for the organophosphates support a final reregistration eligibility decision. Label changes are described in Section IV.”

(Page 42, Paragraph 2, Sentences 2 and 3)

“Based on its current evaluation of tetrachlorvinphos alone, the Agency has determined that tetrachlorvinphos products, unless labeled and used as specified in this document, would present risks inconsistent with FIFRA and/or FQPA. Accordingly, should a registrant fail to implement any of the risk mitigation measures identified in this document, the Agency may take regulatory action to address the risk concerns from use of tetrachlorvinphos.”

The bottom of Page 48 is the part of Section IV referenced above, regarding required label changes. It clearly states residential flea powders need to contain the text:

“Use 1/3 oz. of powder per every 10 pounds of body weight of your cat or dog.”

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Here is a picture of the labeling for the Hartz flea powder used on Tigger:

This is the back of the actual Hartz flea powder used on Tigger. As you can see, this label is noticeably lacking the required EPA language in favor of a more vague, general guideline.

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(Page 53, Paragraph 2)

“The Agency has determined that registrants may distribute and sell tetrachlorvinphos products bearing old labels/labeling for 26 months from the date of issuance of this interim TRED. Persons other than the registrant may distribute or sell such products for 50 months from the date of the issuance of this interim TRED. Registrants and persons other than the registrant remain obligated to meet pre-existing label requirements and existing stocks requirements applicable to products they sell or distribute.”

As you can see; the EPA, although stating concern over the dangers of these products as they were labeled, allowed distributors to continue selling these vaguely-worded versions of tetracholrvinphos products for 50 months after this decision was made.

Regardless, this grace period ended on September 30, 2010. Tigger’s owner bought this product February of 2012. This is a classic example of Hartz and their negligent distributors favoring profits over public safety.

We’d like to end with this excellent National Talk Radio program from July 24th, 2008. A representative from the Natural Resources Defense Council talks about tetrachlorvinphos in pet products, followed by a great discussion with one of the biggest thorns in Hartz’ side (and a Broken Hartz hero), Mr. Richard Parsons.

The program is a half-hour long, but there is so much great information, you will definitely be rewarded. If you can’t take the time to listen now, please make it a point to stop back later.

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