Hartz Claims Advantage Doesn’t Have FDA Approved Drugs

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Click this link for the previous article in our Hartz “Executive Summary” exposé: Fun with Charts!

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We have challenged Hartz’ claims of being committed to providing factual information and also shed some light on the false nature of their charts.

Now we’re ready to tackle a brazen lie Hartz makes in their infamous Executive Summary of EPA Evaluation of Pet Spot On Products. Page 5, Paragraph 1, Sentence 3:

“Frontline® and Advantage® are NOT prescription products nor are they registered with the FDA.”

This is inaccurate, but first additional information and clarification is necessary.

Prior to our Broken Hartz affiliates’ email to the distributor involved in this case Rite Aid Corporation, on 1/21/12, they had found some resources citing Frontline as being FDA approved. We are unable to substantiate Frontline’s FDA status. Since the product recommended by the Broken Hartz affiliates’ Vet was Advantage, we see no harm in removing Frontline from the equation.

Moving on, we have seen this argument from Hartz before. They try to confuse the public, using the fact not all Advantage products are FDA approved. We will not bother listing every product in the Advantage family that has received the distinction of being FDA approved to point out the false nature of Hartz’ statement, but it’s appropriate to list:

ADVANTAGE MULTI for Cats: NADA 141-254 (Active Ingredients: imidacloprid and moxidectin)
– Approval Document

ADVANTAGE MULTI for Dogs: NADA 141-251 (Active Ingredients: imidacloprid and moxidectin)
– Approval Document

This is a screen capture from the FDA’s PowerPoint titled “What You Need to Know: Approved vs. Unapproved Animal Drugs”.

Actually, Advantage isn’t the only flea control product line to have FDA approved products. Here are some more examples of FDA approved flea control products:

Sentinel Flavor Tabs and Capstar Flea Management System: NADA 141-204 (Active ingredients: nitepyram, lufenuron and milbemycin oxime)

Pro-Spot Solution: NADA 132-789 (Active Ingredient: Fenthion)

Program Suspension: NADA 141-026 (Active Ingredient: Lufenron)

Revolution: NADA 141-152 (Active Ingredient:Selamectin)

These FDA approved products are indicated for the treatment of flea infestations and are administered in an identical procedure to Hartz spot-on products.

As it turns out, Hartz was being modest! They refrained from mentioning they have a flea control product on the FDA website, too:

Hartz Flea Control Capsules AKA Zodiac Fleatrol Caps: NADA 141-162 (Active Ingredient:S-methoprene)

Additionally, the Hartz product has a distinction on its page that none of the others do:

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“This product Voluntarily Withdrawn By Sponsor”

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We guess there was a problem. It’s odd, because as an (s-)methoprene only product, this wouldn’t make sense unless, of course, there’s something questionable in the “secret sauce”.

These products and more can be found by searching the Animal Drugs portion of the FDA’s website.

Additionally, Hartz seems to be confused about the finer points of FDA terminology. “Registered with the FDA” does not mean the same thing as “Approved by the FDA”. Many products are “registered” with the FDA, while not all receive approval.

Again, the above linked products, with one notable exception, are approved by the FDA. Furthermore, these products have been FDA approved for years.

More information from the FDA regarding vital differences between FDA-Approved and Unapproved Animal Drugs can be found here.

Please Note: No members of Broken Hartz are Veterinarians. Please speak with a reputable Vet before using any product on your animal(s).

More to come.

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Click this link for the next article in our Hartz “Executive Summary” exposé: Rite Aid Corporation Still in Bed with Hartz

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Fun with Charts!

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Click this link for the first article in our Hartz “Executive Summary” exposé: Proof of Hartz’ “Commitment” to Providing Factual Information

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As Broken Hartz continues to expose Hartz Mountain Corporation for the liars they are, we’d like to talk about Hartz’ love of charts. Hartz thinks charts can hide its lies, but we’ll show a different use for them. To do this, we turn to another portion of the soon-to-be-notorious Hartz document, entitled “Executive Summary of EPA Evaluation of Pet Spot-On Products” (Word document).

Within this document, Hartz claims (on four separate occasions) the information used to create the charts found in their “Executive Summary” to represent all adverse reactions reported to the EPA in 2008.

This is false.

The report responsible for Figures 3 and 1 in Hartz’ “Executive Summary”, was created by Dr. Charles T. Gaskins (more on him in another post), using information from Hartz, gathered from the EPA (using FOIA), spanning July 1, 2006 – June 30, 2008. Dr. Gaskins’ “independent statistical analysis” can be found here.

Continuing, the EPA is quite clear in pointing out it would be inappropriate to try and extrapolate absolute numbers of incidents among the different spot-on products in the EPA Public Advisory published in March 2010:

(EPA Public Advisory published in March 2010, Page 4, Paragraph 3)

“A comparison of the absolute numbers of incidents among the different spot-on products in this report is not appropriate. This is because 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.”

This same caution is given, with greater emphasis and detail, on page 12 of the EPA Public Advisory published in March 2010 as well as other places. Despite this caution, Hartz has seen fit to make a comparison of the absolute numbers of incidents among the different spot-on products in attempt to show themselves as being the safest, even though a true analysis of these reports proves Hartz to be the worst by far.

Additionally, in this document, Hartz continually tries to focus attention on (s)-Methoprene.

Broken Hartz is not interested with (s)-Methoprene, although we’re sure Hartz wishes we were. Rather, we are interested in the inert, unlisted ingredients. So is the EPA:

(EPA Public Advisory published in March 2010, Page 16, Paragraph 2, Sentences 1-3)

“Incidents were reported for all products, including two 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.”

While a comparison of the absolute numbers of incidents among the different spot-on products in the EPA Public Advisory published in March 2010 is not appropriate, we have found legitimate methods for interpreting the data compiled by the EPA.

We accessed and analyzed the individual reports for every product listed in the EPA Public Advisory published in March 2010.

The EPA’s “DATA EVALUATION RECORD FOR ENHANCED SPOT-ON REPORTING CAT PRODUCT”, concerning EPA registration numbers 2724-504 (Wellmark), 2724-504-270 (Farnam) and 2724-504-2596 (Hartz) reveals some intriguing information in support of an inert ingredient problem in the Hartz product. These three products are identical in terms of active ingredients (40% Etofenprox, 3.6% s-Methoprene), varying only in the contents of these products’ inert ingredients.

This chart reflects the percentage of adverse events that resulted in deaths and major incidents from dermal exposures only (i.e. proper use).

This next chart is another valid way to use the data gathered by the EPA through their review of pet spot-on incidents.

All products associated with only one chemical class were included in this chart. Since manufacturer specifics have been removed, sales data becomes irrelevant. The data included accurately represents all deaths, resulting from proper use; that can be uniquely attributed to a specific chemical class.

The previous chart is important because it shows Insect Growth Regulators [(s)-methoprene and pyriproxyfen] to be the primary culprits for death from products with only one active ingredient even though insect growth regulators are widely accepted to be non-toxic to mammalian species. Again, this suggests the real problem is with the inert, proprietary ingredients found in these products.

Although this is not the case for the other Hartz products in the EPA Public Advisory published in March 2010, the (s)-Methoprene product (2596-147) was exempt from having to conduct Companion Animal Safety studies, even though previous Companion Animal Safety studies for these products were deemed unacceptable by the EPA.

We’ll have more fun with charts in a future post. Stay tuned.

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Click this link for the next article in our Hartz “Executive Summary” exposé: Hartz Claims Advantage Doesn’t Have FDA Approved Drugs

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Proof of Hartz’ “Commitment” to Providing Factual Information

Through a correspondence between some Broken Hartz affiliates who experienced a problem with a Hartz Spot-On Flea Product and a distributor whose position regarding Hartz products remains to be seen Rite Aid Corporation; a document, authored by Dr. Melinda Fernyhough, Hartz’ Manager of Scientific Affairs and Resident Veterinarian (at least for a little while longer, anyway) was produced. To save Dr. Melinda the embarrassment of claiming she didn’t author this, we provide this screenshot of the document’s properties:

The seven page document is filled with bold lies and makes for very interesting reading, to say the least. We plan to share more of this document in future posts but, today, we will address this particular section:

 “Unfortunatley [sic], there is a lot of misinformation on the internet about flea and tick products. Hartz is working constantly to offer factual information about flea and tick products, including a [sic] education tab on our Facebook page that will link you directly to the EPA website for accurate, independent information.”

We agree with Hartz. There is a lot of “misinformation on the internet”, however, we feel the source of misinformation comes from them, not the public.

Hartz has no interest in providing factual information, which brings us to Hartz.com’s Press Releases page:

At the start of our investigation, a couple of weeks ago, this page featured links to twelve different press releases. We clicked through every press release link and found three of the twelve links did not work.

One broken link was to an article called “Nature’s Collection Fundraiser” and the other two non-functioning links were, conveniently enough, “Hartz recalls Naturals® beef treats” and “EPA Flea & Tick Topical Advisory Update”.

Here is the complete list of Press Release links as well as screenshots for reference. You’ll notice the “Nature’s Collection Fundraiser” link works although, until today (2/18/12) and evidenced by our screenshot, this was not the case:

Hartz’ Unicharm Press Release

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Hartz’ Pet Week Press Release

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Hartz’ Examiner Press Release

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Hartz’ Dog Training Release

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Hartz’ “Broken” Naturals Recall Press Release

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Hartz’ Pet Dental Health Press Release

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Hartz’ Crunch ‘N Clean Press Release

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Hartz’ “Broken” EPA Advisory Press Release

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Hartz’ Shelter Donation Press Release

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Hartz’ Nature’s Collection Press Release was broken until (2/18/12). It has since come down again. A very odd history for this little guy.

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Hartz’ Nodor Press Release

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Hartz’ Wounded Warrior Press Release

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Before going into the next portion, we at Broken Hartz wish to mention we have more than twenty-five years combined experience in web design.

Upon discovering these “broken links”, we decided to research the cause of the malfunctions. To do this, we analyzed the source data for the Hartz.com Press Releases page. You may need to click on the image below to zoom in and get a better look:

The picture above shows the “links” portion of the markup from Hartz’ Press Releases page. These links are used to direct users to the appropriate press release when clicked. A quick review of the links portion of the page showed the three broken links had no defects in the way they had been written. This is further proven by the fact the above “Nature’s Collection Fundraiser” link now works, even though its coding has not changed from the time of our investigation. The point is: there is nothing wrong with these links. They are intentionally broken and Broken Hartz can prove it.

We suspected the “Nature’s Collection Fundraiser” link “error” was planted so it would not be as blatantly obvious that Hartz was hiding the more unsavory press releases from the public’s eye, so we started there. We put our knowledge of how the internet works to use and were able to find a version of the missing “Nature’s Collection Fundraiser” press release on an alternate version of the Hartz.com website:

Hartz’ Broken then Fixed then Re-Broken Nature’s Collection Press Release
(Since the release of this post, Hartz deleted this extra version of the Nature’s Collection link and fixed the link on their main site for a few weeks before intentionally breaking the link again, but the screenshot above displays the web-address where this article was originally uncovered. This particular press release has had an intriguing history.)

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Now that we had found this press release, it was time to move on to the others. We tried many different ways to locate the missing “Hartz recalls Naturals® beef treats” but were unsuccessful. That wasn’t the case when it came to the “EPA Flea & Tick Topical Advisory Update” press release, however:

Hartz’ Fixed EPA Advisory Press Release
(The link above functioned until 2/21/12. Click here for the screenshot.

For more details on what happened, click here.)

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Here is a zoomed in view of this very interesting press release:

Hartz considers consumers to be "dummies". This must be why they thought "dummy text" would be appropriate for this press release.

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The discovery of this bogus article speaks volumes. Hartz clearly has no intention of offering factual information about flea and tick products.

Actually, since compiling this information, we have been checking Hartz’ Press Releases page to see if this truly was intentional or an honest mistake. Today (February 18, 2012), more than two weeks from us noticing these “errors”, Hartz has finally paid some attention to its Press Releases page.

Hartz’ Press Release Page, Updated On 2/18/12

They did not add a new release. They fixed, then re-broke the “Nature’s Collection Fundraiser” link for some mysterious reason, left the broken “EPA Flea & Tick Topical Advisory” link up for a few weeks before ultimately removing it and saw fit to remove the “Hartz recalls Naturals® beef treats” link immediately, further proving their commitment to denial.

Much more to come.

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UPDATE: HARTZ HAS BROUGHT BACK THEIR “BROKEN” EPA FLEA & TICK TOPICAL ADVISORY LINK AND HARTZ RECALLS NATURALS BEEF TREATS LINK.

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If you visited the link above to Hartz Press Releases page you may have already seen this.

We’re sure it probably happened a while ago but; as of June 8, 2012 we noticed Hartz has chosen to bring back their “EPA Flea & Tick Topical Advisory” and “Hartz recalls Naturals® beef treats” press releases.

It is quite interesting to note, although Hartz has re-published these releases (and is well aware there were some “problems” with these links the last time they published them), the links are still “broken” despite showing no obvious reason for malfunctioning, other than intentional failure.

This, of course, is no surprise, seeing as how Hartz seems to specialize in creating products that intentionally fail.

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Click this link for the next article in our Hartz “Executive Summary” exposé: Fun with Charts!

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