Click this link for the previous article in our Hartz “Executive Summary” exposé: Let’s Get “Technical”
We’d like to take this moment to revisit the subject of Hartz’ love of the “misuse” defense.
While we are sure this argument carries some level of merit, it has been excessively shouted from the Hartz Mountain-top into the faces of consumers for decades in an attempt to shame the public into believing the issue lies with them, not Hartz’ negligent menagerie of dangerous “pet-care” options.
Many examples of this shameless tactic are well-represented in the “Executive Summary” document; brazenly, defiantly, mockingly submitted by Hartz’ Manager of Scientific Affairs and Resident Veterinarian. Who was that again?
Broken Hartz has already pointed out one example of the fallacy behind the “overabundance of misuse” defense used by Hartz Mountain Corporation and its cronies, but we’d be remiss to let this next example escape scrutiny.
(Hartz’ Executive Summary of EPA Evaluation of Pet Spot-On Products, Page 1, Bulleted Section 1, Bullet 2)
“In dogs, small dogs and dogs under 3 years were overrepresented in the reports. Some of these reports may be attributed to applying a product labeled for a larger dog on a small dog.”
Again, this had no relevance to our affiliate’s case. Our affiliate has a cat, not a dog, and the product purchased has no weight restrictions.
On a side note:
Hartz’ repeated inability to understand the issue being discussed in this particular case involved a cat, not a dog, combined with mislabeled Hartz products still sitting on shelves and killing animals years after having been recalled, suggests who really has the problem keeping these two distinct species straight.
Continuing, Hartz and their counterparts are often heard claiming their products have been misused because they have been applied to smaller animals than intended.
We at Broken Hartz find this interesting, due to a correspondence on March 16, 2009 between Hartz Mountain and KNBC’s Joel Grover. Mr Grover had contacted Hartz to let them know he was doing a piece on flea-control products and invited them to answer some questions.
This letter has some interesting parts, but we’d like to focus our readers’ attention here:
(Hartz Correspondence on March 16, 2009; with KNBC’s Joel Grover, Page 3, Paragraph 5)
“All flea and tick products – whether sold by veterinarians or at retail stores – are required to provide the EPA with companion animal safety studies to demonstrate the safety of their products even if those products are used at five times above the labels’ recommended dose. EPA-required companion animal safety studies are in place to show that if flea and tick topicals, including Hartz, are misused or overused in quantities five times greater than the recommended dosage on the label directions, an adequate margin of safety still exists”
Since these products are supposed to be designed to account for overuse up to five times more than the intended dosage (while maintaining an adequate margin of safety), this admission makes virtually all claims of misuse due to not following weight range restrictions null and void.
No product named in the EPA Public Advisory published in March 2010 features a single-use application, for any defined weight-class, in excess of this “5x margin of safety”, even if accidentally administered on an animal in the lowest weight-class for any given product. This means, to even begin to have a chance of applying more than 5x the recommended dose for your animal, you’d not only have to grossly overestimate the weight of your animal, you’d have to use at least two applications in order to exceed this intended fail-safe as well.
We at Broken Hartz wish to stress the paragraph above should not be mistaken to mean there is no need to follow weight-restrictions in flea medications. Always talk to your Veterinarian before applying any product to your animal and follow all instructions strictly.
Here is Mr. Joel Grover’s report, which aired in 2009. We applaud Mr. Grover for his work on this piece:
Aside from this “5x margin of safety” issue, we’d like to address Hartz’ repeated emphasis placed on the idea:
(Excerpt from quote above)
“All flea and tick products – whether sold by veterinarians or at retail stores – are required to provide the EPA with companion animal safety studies…”
This is untrue.
(EPA Public Advisory published in March 2010, Page 16, Paragraph 2)
“Incidents were reported for all products, including 2 products containing S-methoprene as the sole active ingredient. Companion animal safety studies were not required for these products because S-methoprene, which is an insect growth regulator, is of low toxicity to mammals. There are concerns for the potential toxicity of a formulant ingredient being responsible for toxicity of these products in cats. There are no toxicity data in cats for this formulant, and cats are sensitive to many chemicals because of a decreased ability to detoxify chemicals compared to other species.”
The two products referenced above by the EPA are Wellmark’s product (EPA# 2724-488) and Hartz’ Product (EPA# 2596-147). They were exempt from having to submit Companion Animal Safety Studies during the EPA’s review of the products named in their Public Advisory published in March 2010 even though, in the statement above, the EPA clearly states they believe Hartz is putting something other than (s)-Methoprene in Product 2596-147 and this secret ingredient is the true culprit. Hartz Product 2596-147 is the one purchased by our affiliate and therefore directly correlates to the case being discussed.
You may recall we mentioned two Companion Animal Safety Studies previously submitted to the EPA by Hartz for the Hartz Ultraguard OneSpot Flea Egg and Flea Larvae Treatment for Cats and Kittens (EPA# 2596-147). These studies were cited in the EPA’s “Review of Incident Data for Four Hartz Mountain Flea and Tick Control Products” in 2001 and were deemed unacceptable.
One of those studies was rejected due to inadequate observation on the part of Hartz employees and the other was rejected for failing the “5x margin of safety” requirement.
Also, in the EPA’s individualized report for Hartz Product 2596-147, there were 34 reported deaths (33 from dermal exposure, 1 from oral exposure) in the intended species (cats). The EPA clearly states:
(EPA’s DATA EVALUATION RECORD FOR ENHANCED SPOT-ON REPORTING CAT PRODUCT [2596-147], Page 4, the paragraph beneath Table 1)
“Of the 33 deaths reported following only dermal exposure, 16 animals were treated by a veterinarian. Eight of these animals were euthanized. Label directions were not followed for five of the 33 deaths.”
This means, 85.85% of all deaths associated with this product occurred when the product was used as directed and the route of exposure was limited to its intended method (dermally).
More to come.
Click this link for the next article in our Hartz “Executive Summary” exposé: It “Figures”