Click this link for the previous article in our Hartz “Executive Summary” exposé: More Fun with Charts!
As you may have guessed, Hartz doesn’t always like what the EPA has to say. So, what does Hartz do when they don’t like the EPA’s words? Simple, they change them.
As usual, we will be referencing the EPA Public Advisory published in March 2010 along with Hartz’ deplorable Executive Summary of EPA Evaluation of Pet Spot-On Products to prove this point.
Near the beginning of Hartz’ “Executive Summary” document, it claims:
(Hartz’ Executive Summary of EPA Evaluation of Pet Spot-On Products, Page 1, Paragraph 1, Sentence 3)
“Below is a copy of the EPA’s Summary of findings from the enhanced reporting, as well as the changes proposed by the EPA for the future.”
To be clear: no portion of Hartz’ “Executive Summary” document comes from the EPA, nor is the EPA ever directly cited in Hartz’ “Executive Summary”. All this deceitful information comes straight from Hartz Mountain Corporation.
In this “Executive Summary” document, originated by Dr. Melinda Fernyhough, Hartz deceptively claims the EPA made the following statement in their Public Advisory, published in March 2010:
(Hartz’ Executive Summary of EPA Evaluation of Pet Spot-On Products, Page 1, Bulleted Section 1, Bullet 2 [this portion is posed as coming from the EPA])
“For both dogs and cats, the main organ systems affected were the dermal, gastrointestinal, and nervous systems and, although most reports were classified as minor, all products had some reported deaths and major incidents.”
This is wholly inaccurate.
The EPA does not make a blanket statement about dogs and cats in this regard, and with good reason. In the case of dogs only, the EPA states:
(EPA Public Advisory published in March 2010, Page 4, Bulleted Section titled “General Findings for Dogs”, Bullet 1, Sentence 3)
“Although most incidents were classified minor, all products had some deaths and/or incidents classified as major…”
This has been poorly worded by the EPA, but we will clarify.
In the case of dogs, Sergeant’s product 2517-94 had zero reported dog deaths. There were six cat deaths, but this product is not sold for use on cats and therefore, those deaths are misuse and should not be counted against Sergeant’s product 2517-94.
In the case of cats, the EPA makes no comment about all products having some reported deaths and major incidents. The reason for this is Summit Vetpharm LLC’s product 83399-9. This product had zero reported deaths or major events.
Hartz doesn’t stop putting words in the EPA’s mouth there.
(Hartz’ Executive Summary of EPA Evaluation of Pet Spot-On Products, Page 1, Paragraph 2)
“(When reviewing the incident reports, as the EPA itself makes clear, these incident reports are not investigated or validated by the Agency for accuracy in any manner; they are taken at face value and no effort s [sic] made to screen out demonstrably false or otherwise inaccurate reports.)”
If Hartz wishes to draw attention to the fact the EPA is aware some of the reports it receives may be false, we feel compelled to share the EPA has fined Hartz in the past for cases of under-reporting and not reporting incidents. The previous link is for a fine from 2008. The EPA stated they did not receive a report from Hartz for the calendar year 2007 on or before March 1st, 2008:
Hartz denied this, claiming they had sent the required information in time and provided the EPA with Federal Express tracking #799809068158 for a document delivered to the USEPA in Edison, New Jersey on February 26, 2008. The EPA decided to drop this fine solely for the purposes of settlement.
What we at Broken Hartz wish to point out is, in accordance with the EPA’s submission guidelines for any adverse domestic animal events, Hartz should have been submitting this information quarterly to the EPA with a grace period of 60 days. This means the majority of the information submitted to the EPA for 2007 was late, regardless of the above fine being dropped. Additionally, Federal Express is no longer able to track this number without being provided account information, so our Broken Hartz affiliate officially requested Hartz provide the proof-of-delivery document they gave to the EPA to prove compliance. We doubt Hartz would like our affiliate to scrutinize this document, so we aren’t holding our breath.
Also, Hartz’ summation regarding the EPA’s statement attaches far stronger wording than is actually used in the EPA Public Advisory published in March 2010:
(EPA Public Advisory published in March 2010, Page 4, Paragraph 3, Sentences 2 and 3)
“…some products may have more incidents than other products because more of that product is sold and because incident information is voluntarily submitted by pet owners, with varying levels of detailed information, and routine reporting is sometimes lacking. The incidents have not been verified and may have causes other than exposure to the pesticide.”
As for Hartz’ suggestion the incident reports were not investigated or validated by the Agency for accuracy in any manner; that is also fallacy. We support this assertion, citing this portion of the EPA Public Advisory:
(EPA Public Advisory published in March 2010, Page 9, Paragraph 5)
“Incidents which were not evaluated: Not all incident reports were included in the evaluations by the EPA. Incidents which were generally not included:
- Incidents with no EPA registration number
- Incidents from other countries
- Efficacy reports
- Incidents which were considered generally ambiguous
- Incidents which also involved use of other pesticides or drugs because effects may have been associated with the other product
- Incidents which involved multiple animals because it was difficult to tell which animal was affected and to what degree
- Multiple reports or contacts with the registrant for the same incident”
Out of the over 44,000 incident reports submitted to the EPA, only 28,319 were deemed suitable for inclusion in the report, meaning more than 1/3 of the incident reports received were screened out. Clearly, these reports were not taken at face value and many efforts were made to screen out inaccurate reports.
Watch out, Hartz. We doubt the EPA is going to be happy about this.
More to come.
We at Broken Hartz wish to strongly caution readers about the above named products (Sergeant’s product 2517-94 and Summit Vetpharm LLC’s product 83399-9).
While these products had no reported deaths, the Sergeant’s product contains 45% Permethrin, a very dangerous pyrethroid responsible for many deaths cited in the EPA’s Public Advisory and it’s accompanying documents. Chemicals act quite predictably and logic suggests the only reason for disparity is any deaths went unreported or Sergeant’s simply chose to lie on its incident reports.
Lastly; Summit Vetpharm LLC, during the time of the EPA’s Public Advisory, was primarily held by Sumitomo Corporation the same company that owns Hartz. Sumitomo transferred it’s primary shares of Summit Vetpharm LLC a little while ago and in May of this year, they will hand over majority stock of Hartz to Unicharm, a large player in the Asian pet-care market. Sumitomo is also the manufacturer of Permethrin, the chemical referenced above.
More on Sumitomo later.
Click this link for the next article in our Hartz “Executive Summary” exposé: Dr. Charles T. Gaskins, Dr. Melinda Fernyhough and a Little Thing Called Conflict of Interest