Click this link for the first article in our Hartz “Executive Summary” exposé: Proof of Hartz’ “Commitment” to Providing Factual Information
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.
Click this link for the next article in our Hartz “Executive Summary” exposé: Hartz Claims Advantage Doesn’t Have FDA Approved Drugs