11
Mar
Take Action: Chemical Mixture Issues in Pesticide Products Elevated by the EPA Inspector General
(Beyond Pesticides, March 11, 2024) Inside a recent disagreement between the Office of the Inspector (OIG) and the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs (OPP) on the agency’s review of pet flea and tick collars—leading to thousands of deaths and poisonings—is a basic question of the adequacy of pesticide regulation. The disagreement is over the cause of 105,354 incident reports, including 3,000 pet deaths and nearly 900 reports of human injury, and the February 2025 OIG report’s conclusion that “[EPA] has not provided assurance that they can be used without posing unreasonable adverse effects to the environment, including pets.” While the disagreement focuses on a number of EPA process failures, Beyond Pesticides urges that the findings advance the need for the agency to address a key element of chemical mixtures in pesticide products not currently evaluated, potential synergistic effects—the increased toxic potency created by pesticide and chemical combinations not captured by assessing product ingredients individually.Â
Key to the dispute is what many see as a foundational failure of EPA to evaluate the effect of pesticide mixtures and full formulations of pesticide end products, a longstanding criticism of the agency’s pesticide registration process, which focuses on pesticide products’ active ingredients. The manufacturer identifies the active ingredient as the compound in the product formulation that kills the target pest—even though the other ingredients (called inerts) may be toxic. The concern stems from two scenarios present with the Seresto collar in which EPA is not evaluating (i) the mixture of chemicals in the product purchased by consumers, including the so-called inert ingredients (other chemical agents to increase performance, such as adjuvants, surfactants, solvents, carriers, etc.) and contaminants (both not disclosed on the product label); and (ii) the effect of the mixture of two or more active ingredients in the pesticide product, which may increase the product’s overall toxicity.
In the case of the Seresto flea and tick collar, there is concern that EPA missed the true toxicity of the product by not fully evaluating whether there is a synergistic effect that increases the product’s overall toxic effect. Seresto contains two active insecticide ingredients—the neurotoxic insecticide flumethrin, and the notorious neonicotinoid imidacloprid with adverse effects on the endocrine system and environment.
As Beyond Pesticides pointed out in 2021, when the pet poisonings and deaths made headlines, a 2012 study found that flumethrin and imidacloprid have a synergistic effect in attacking fleas. However, EPA dismissed or ignored this science, stating in a 2016 EPA bulletin, “The risk of the combination of the two active ingredients, flumethrin and imidacloprid, was not assessed because the two chemicals act in completely different ways.â€
Synergistic effects have been widely reported. For example, Beyond Pesticides has reported that researchers found elevated neurotoxic effects from exposure to the glyphosate/Roundup formulation with the so-called inert ingredient polyethoxylated tallowamine (POEAs), also shown to kill human cells.Â
>>Tell EPA to start protecting people and pets from pesticide poisoning.Â
Despite all the concerns, at the time the poisoning and deaths of pets made headlines in 2021, the agency defended the product’s registration, telling the media that, despite these incidents, EPA deemed Seresto collars “’eligible for continued registration’ based on best available science, including incident data… No pesticide is completely without harm, but EPA ensures that there are measures on the product label that reduce risk.â€
Overall, the OIG highlights known shortcomings in EPA’s pesticide registration program, including (but not limited to):Â
- Failure to address combined effects of multiple pesticides;Â
- Failure to investigate impacts on pets;Â
- Failure to adopt standard operating procedures and a methodology to determine when pet products may pose unreasonable adverse effects to the environment;Â
- Failure to collect complete incident data that would allow EPA to fully understand the risks and take appropriate action; andÂ
- Failure to assure the public of the safety of the products.Â
Furthermore, EPA continues to rely on labeling to reduce risk, despite its failure to protect pets, children, farmworkers, pollinators, and biodiversity. Advocates point out that If the labeling is not protecting people, then the agency is not fulfilling its responsibility to protect public health and safety and the pesticide products should not be allowed on the market
>>Tell EPA to start protecting people and pets from pesticide poisoning.Â
Letter to EPA
More proof of multiple systemic failures by the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs (OPP) to protect people and their pets from pesticides was presented in a report of the Office of Inspector General (OIG) report, published on February 29, 2024.
The report, The EPA Needs to Determine Whether Seresto Pet Collars Pose an Unreasonable Risk to Pet Health, concludes that, “The EPA’s response to reported pesticide incidents involving Seresto pet collars has not provided assurance that they can be used without posing unreasonable adverse effects to the environment, including pets.†At the time the animal effects made headlines in 2021, the agency defended the product’s registration, telling the media that, despite these incidents, EPA deemed Seresto collars “‘eligible for continued registration’ based on best available science, including incident data. . . . No pesticide is completely without harm, but EPA ensures that there are measures on the product label that reduce risk.â€â€¯Despite the scathing criticism, EPA maintains the position that it conducted an adequate review of the two active insecticide ingredients in the pet collars— the neurotoxic insecticide flumethrin, and the notorious neonicotinoid imidacloprid with adverse effects on the endocrine system and environment.
The OIG points out that EPA’s handling of the flea and tick collars—implicated in 105,354 incident reports, including 3,000 pet deaths and nearly 900 reports of human injury—highlights known shortcomings in EPA’s pesticide registration program, including (but not limited to):
– Failure to address combined effects of multiple pesticides;
– Failure to investigate impacts on pets;
– Failure to adopt standard operating procedures and a methodology to determine when pet products may pose unreasonable adverse effects to the environment;
– Failure to collect complete incident data that would allow EPA to fully understand the risks and take appropriate action; and
– Failure to assure the public of the safety of the products.
Furthermore, EPA continues to rely on labeling to reduce risk, despite its failure to protect pets, children, farmworkers, pollinators, and biodiversity. When EPA cannot protect against ongoing harm to humans and the biosphere with the labeling it approves on pesticide products, it must remove the pesticide product from the market. When faced with evidence of harm from a pesticide, despite its labeling restrictions and warnings, EPA must take steps to halt its use.Â
The deaths and poisonings associated with Seresto animal collars requires EPA to immediately establish the necessary protocol to evaluate full formulations of products it allows on the market for additive and synergistic effects. When will you do this?
Thank you for your consideration.
Letter to U.S. Congress
More proof of multiple systemic failures by the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs (OPP) to protect people and their pets from pesticides was presented in a report of the Office of Inspector General (OIG) report, published on February 29, 2024.Â
The report, The EPA Needs to Determine Whether Seresto Pet Collars Pose an Unreasonable Risk to Pet Health, concludes that, “The EPA’s response to reported pesticide incidents involving Seresto pet collars has not provided assurance that they can be used without posing unreasonable adverse effects to the environment, including pets.†At the time the animal effects made headlines in 2021, the agency defended the product’s registration, telling the media that, despite these incidents, EPA deemed Seresto collars “‘eligible for continued registration’ based on best available science, including incident data… No pesticide is completely without harm, but EPA ensures that there are measures on the product label that reduce risk.â€â€¯Despite the scathing criticism, EPA maintains the position that it conducted an adequate review of the two active insecticide ingredients in the pet collars— the neurotoxic insecticide flumethrin, and the notorious neonicotinoid imidacloprid with adverse effects on the endocrine system and environment.
The OIG points out that EPA’s handling of the flea and tick collars—implicated in 105,354 incident reports, including 3,000 pet deaths and nearly 900 reports of human injury—highlights known shortcomings in EPA’s pesticide registration program, including (but not limited to):
– Failure to address combined effects of multiple pesticides;
– Failure to investigate impacts on pets;
– Failure to adopt standard operating procedures and a methodology to determine when pet products may pose unreasonable adverse effects to the environment;
– Failure to collect complete incident data that would allow EPA to fully understand the risks and take appropriate action; and
– Failure to assure the public of the safety of the products.
Furthermore, EPA continues to rely on labeling to reduce risk, despite its failure to protect pets, children, farmworkers, pollinators, and biodiversity. When EPA cannot protect against ongoing harm to humans and the biosphere with the labeling it approves on pesticide products, it must remove the pesticide product from the market. When faced with evidence of harm from a pesticide, despite its labeling restrictions and warnings, EPA must take steps to halt its use.Â
Please let EPA know that the deaths and poisonings associated with Seresto animal collars requires it to immediately establish the necessary protocol to evaluate full formulations of products it allows on the market for additive and synergistic effects.
Thank you for your consideration.
Flea and tick collars have been full of pesticides for years. These need to be properly tooled so humans and pets are not at such great risk.
March 13th, 2024 at 7:32 pmPesticides are killing us. They must be banned.
March 13th, 2024 at 9:23 pmPesticides are killing people, kids, adults, all of us and our animals. The studies being done on pesticides must include full resting on theirk effect on humans and animals
March 13th, 2024 at 9:29 pmKeep pesticides out of our daily lives!
March 14th, 2024 at 7:29 amMore proof of multiple systemic failures by the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs (OPP) to protect people and their pets from pesticides was presented in a report of the Office of Inspector General (OIG) report, published on February 29, 2024.
The report, The EPA Needs to Determine Whether Seresto Pet Collars Pose an Unreasonable Risk to Pet Health, concludes that, “The EPA’s response to reported pesticide incidents involving Seresto pet collars has not provided assurance that they can be used without posing unreasonable adverse effects to the environment, including pets.†At the time the animal effects made headlines in 2021, the agency defended the product’s registration, telling the media that, despite these incidents, EPA deemed Seresto collars “‘eligible for continued registration’ based on best available science, including incident data. . . . No pesticide is completely without harm, but EPA ensures that there are measures on the product label that reduce risk.â€â€¯Despite the scathing criticism, EPA maintains the position that it conducted an adequate review of the two active insecticide ingredients in the pet collars— the neurotoxic insecticide flumethrin, and the notorious neonicotinoid imidacloprid with adverse effects on the endocrine system and environment.
The OIG points out that EPA’s handling of the flea and tick collars—implicated in 105,354 incident reports, including 3,000 pet deaths and nearly 900 reports of human injury—highlights known shortcomings in EPA’s pesticide registration program, including (but not limited to):
– Failure to address combined effects of multiple pesticides;
– Failure to investigate impacts on pets;
– Failure to adopt standard operating procedures and a methodology to determine when pet products may pose unreasonable adverse effects to the environment;
– Failure to collect complete incident data that would allow EPA to fully understand the risks and take appropriate action; and
– Failure to assure the public of the safety of the products.
Furthermore, EPA continues to rely on labeling to reduce risk, despite its failure to protect pets, children, farmworkers, pollinators, and biodiversity. When EPA cannot protect against ongoing harm to humans and the biosphere with the labeling it approves on pesticide products, it must remove the pesticide product from the market. When faced with evidence of harm from a pesticide, despite its labeling restrictions and warnings, EPA must take steps to halt its use.
The deaths and poisonings associated with Seresto animal collars requires EPA to immediately establish the necessary protocol to evaluate full formulations of products it allows on the market for additive and synergistic effects. When will you do this?
Thank you for your consideration.
March 14th, 2024 at 8:59 amJoseph Quirk
In the case of the Seresto flea and tick collar, there is concern that EPA missed the true toxicity of the product by not fully evaluating whether there is a synergistic effect that increases the product’s overall toxic effect. Seresto contains two active insecticide ingredients—the neurotoxic insecticide flumethrin, and the notorious neonicotinoid imidacloprid with adverse effects on the endocrine system and environment.
March 14th, 2024 at 2:22 pmWhile disagreements surrounding the recent OIG report focuses on process failures by EPA’s review of pet flea and tick collars, Beyond Pesticides urges that the findings advance the agency’s need to address potential synergistic effects—the increased toxic potency created by pesticide and chemical combinations not captured by individual assessment.
March 14th, 2024 at 2:33 pmAnimals are God’s creations, and we need to take better care of them.
March 14th, 2024 at 11:36 pmThe deaths and poisonings associated with Seresto animal collars requires it to immediately establish the necessary protocol to evaluate full formulations of products it allows on the market for additive and synergistic effects.
March 15th, 2024 at 3:58 amPlease do the right thing and protect the future of our children, pets and planet.
March 18th, 2024 at 8:19 pm