19
Oct
Over a Decade and Countless Children Poisoned, EPA Bans Hazardous Flea Collar Products
(Beyond Pesticides, October 19, 2022) Pet flea collars containing the insecticide tetrachlorvinphos (TCVP) are set to be banned by the U.S. Environmental Protection Agency, according to the agency’s long overdue response to a petition from the Natural Resources Defense Council (NRDC). The highly toxic pesticide has not been used on crops since 1987, yet was permitted for decades in flea collars where children could be intimately exposed to the chemical while petting and playing with the family pet. The decade-long process of bringing use of these products to an end exposes the failures of the U.S. pesticide regulatory system, and how EPA’s weak and flawed decisions that infect the marketplace with severe consequences. One may ask: How many veterinarians prescribed these dangerous flea collars to pet owners, assuming that EPA has properly assessed exposure risks to their human owners? Advocates concerned about EPA’s ongoing propensity to defer to the pesticide industry are urging an overhaul of the regulatory process and a reorientation toward toxic pesticide elimination and the adoption of organic in order to address serious health and environmental threats.
NRDC originally filed its petition to ban all uses of TCVP in 2009. The petition noted that the agency completely neglected to include exposures from pet collars in its risk assessment for residential uses of the chemical, despite finding that pet collar uses represent the highest level of exposure for adults. It further explained that EPA’s review of risks to toddlers were flawed, and significantly underestimated their likely exposure. Specifically, the agency assumed that toddlers only interacted with one treated pet per day, for no more than one hour a day. EPA also ignored the potential for a toddler to touch food or another object with pesticide-contaminated hands, and then place that food or object in their mouth. Further, testing from NRDC contradicted EPA’s assertion that exposure risks from TCVP pet collars were “insignificant,” finding that residue levels found on pets exceeded the dose considered safe by the agency.
Despite strong evidence of flawed science, the agency denied NRDC’s petition in 2014. A petition for review was filed and EPA requested a voluntary remand of its denial, which the court granted. Rather than investigate the specific issues raised by NRDC in its original petition, the agency explained it would incorporate new risk mitigation measures into its risk assessment for TVCP, and in 2017 proceeded to reregister all uses of the chemical. In doing so, the agency noted label precautions it said would protect pet owners, including not allowing children to play with TVCP collars, keeping TCVP out of the reach of children, and washing hands after handling. Advocates at the time noted how these precautions fly in the face of reality, as they suggest a scenario where kids must be prevented from petting and coming in close contact with a family dog or cat.
Another legal challenge was filed in 2019, aimed at forcing the agency to respond. After ten years, the agency required TCVP’s major manufacturers to provide data specifically on the release of TCVP from pet collars. A review of that data resulted in minimal mitigation measures, and ultimately, the agency denied the petition.
NRDC again challenged this decision, noting that EPA’s analysis of the new test on the release of TCVP from pet collars was miscalculated and significantly underestimated exposure risks. “EPA’s 2020 risk analysis was profoundly flawed in its approach and conclusions. It has needlessly delayed the removal of these dangerous products and further exposed millions of children to serious, life-long health risks,” said Miriam Rotkin-Ellman, NRDC senior scientist. In April of this year, a federal court agreed with the group, vacated the denied petition yet again, and required EPA to provide a response by October 11, 2022.
In its latest response granting the cancellation request, the agency explains that a reevaluation of the data submitted for the 2020 assessment finds that it did not “adequately assess the physical form (liquid or dust) of TCVP released from the pet collars.”
In the same breath, however, the agency explains that it is still waiting on outstanding data from manufacturers that may impact its decision, and is retaining all other use of TCVP on the marketplace, including liquid and dust products intended for use on dogs and cats.
“Other types of TCVP exposures, including residues on food, also pose worrisome health risks, particularly in combination with exposure from pet products, said Ms. Rotkin-Ellman. “EPA must act swiftly to prohibit other dangerous uses of this toxic pesticide. The health of our families can no longer wait.”
TCVP and other organophosphates in its class work by inhibiting the enzyme acetylcholinterase. Inhibition leads to the accumulation of acetylcholine and ultimately toxicity to the central and peripheral nervous system. Insects are killed through this mechanism, yet with humans such toxicity can cause numbness, tremors, nausea, incoordination, blurred vision, difficulty breathing or respiratory depression, and slow heartbeat. Risks are most pronounced for young children, who have developing organ systems and take in more of a pesticide relative to their body weight than adults. In calling for a ban on all organophosphate use in the United States, scientists noted how even low-level exposures to organophosphates put children at risk of neurodevelopmental disorders, and cognitive and behavioral deficits. A study published in 2020 shows the real-world effect of these risks. It finds that organophosphate pesticide exposure results in an estimated 26 million lost IQ points and 110,000 cases of intellectual disability, totaling roughly $735 billion in economic costs to society based on data beginning in 2008.
EPA’s characteristic response to nonprofit groups critiquing their science stands in stark contrast to how it responds to industry groups doing the same. When it comes to protecting health and the environment, the agency drags its feet, strongly challenges criticism, and requires public interest groups to fight for years in the courts to implement critical protections. The fight over a different organophosphate, chlorpyrifos, is another example of this. In finally forcing EPA’s hand on chlorpyrifos, a federal court ruling took the agency to task, asserting, “The EPA has had nearly 14 years to publish a legally sufficient response to the 2007 Petition [filed by environmental and farmworker groups]. During that time, the EPA’s egregious delay exposed a generation of American children to unsafe levels of chlorpyrifos.”
Yet when the industry challenges EPA, the agency almost invariably capitulates. With the chemical paraquat, EPA allowed an industry umbrella group dubbed the Agricultural Handler Exposure Task Force to correct its data risks posed to workers, resulting in the agency changing its position within months. With the synthetic pyrethroid class of insecticides, EPA allowed an industry group to rework its methodology for addressing pyrethroid risks to children, and followed the request of another industry group to allow the pyrethroids to be sprayed with smaller buffer zones during windier conditions. With the chemical glyphosate, despite overwhelming evidence of its carcinogenic properties, the agency has refused to acknowledge this risk, even after a federal court chastised its review process, and instead has acted on the behest of chemical manufacturers to stop glyphosate from being banned in other countries.
With federal protections consistently failing U.S. residents by harming their health and the environmental on which we all rely, while contributing to outsized corporate profits, concerned residents can still join together to push for change. Join Beyond Pesticides in supporting changes to our pesticide laws by urging your Senators to cosponsor Senator Cory Booker’s (D-NJ) Protect America’s Children from Toxic Pesticides Act, and take further action to reform our toxic and no longer functioning federal pesticide regulatory system. And for more information on the risks pesticides pose to pets and how to address flea and tick problems without toxic pesticides, see Beyond Pesticides’ Pets and Pesticides program page.
All unattributed positions and opinions in this piece are those of Beyond Pesticides.
Source: EPA TCVP, NRDC press release and TCVP case documents
