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Hartz Mountain Corporation

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1. Posted by: hamishdad on May 29, 2009, 5:43 pm

   “The Hartz lady doth protest too much, methinks.”

2. Posted by: rich parsons on May 30, 2009, 1:54 pm

   Thanks to the Center for Public Integrity for publishing this “Open Letter”, including your own response to Dr. Marta Draper, Hartz Mountain Corporation.  Hartz Mountain is clearly troubled by the very negative public information on flea and tick products containing pesticide ingredients.  They vigorously defend the indefensible.  To point to other manufacturers and imply that their products are worse than Hartz’ is hardly a credible defense when many thousands of animals are injured and killed each year—many by Hartz’s own products and by their own admission.  Hartz may or may not have the most dangerous products on the market—Sergeant’s product containing cyphenothrin has been documented as doing tremendous damage—that’s hardly the point.  All of these products injure and kill far too many animals, and by the EPA’s own admission, the cumulative negative effects over time on children is not completely determined.  In other words, the risk to infants and children may be unacceptable.  Hartz, because of very negative media attention combined with recent EPA announcements, has attempted to stifle discussioon on this subject.  Their legal department has sent threatening and intimidating letters to NBC, ABC (resulting in a major story being pulled from its national website on April 24th), the Miami Herald, Dr. Patty Khuly, DVM and even private citizens voicing their opinions.  The website Dr. Draper referred to in her letter still—to this day—indicates that the EPA Public Advisory lists only Hartz’s cat products and not their dog and puppy products—that’s completely false and they know it.  They have even published information on the internet about private citizens that is completely false and defamatory, but more on that at another time.  They used the same tactics with the organization “Beyond Pesticides” in the early 2000’s just before the EPA issued a Cancellation Order on their cat and kitten products in 2005—products that injured and killed thousands of animals, according to the EPA.  It appears that this company, owned by the Japanese chemical company Sumitomo, will do whatever is necessary—including preventing a Constitutional right to free speech—to prevent discussion and, most certainly, awareness of the dangers.  Frankly, The Center for Public Integrity contributed a wonderful public service with their reports on this issue.  You should be commended.  The depth and substance, attention to detail, combined with data and facts resulted in an outstanding piece of journalism.  Please do not let Hartz Mountain or any other manufacturer attempt to intimidate you as you do your good work.  When the public becomes truly informed of the damage being done to animals and families, the regulatory agencies will have no choice but to take action.  Thank you, again, for your outstanding journalism and for having the courage to speak up.

3. Posted by: James TerBush on May 31, 2009, 4:14 am

   I would like to thank The Center for Public Integrity for their excellent series of articles on flea and tick products for pets.

   Hartz says “consumers deserve and should have accurate information.”  If that were true, they would not be trying to convince consumers that Hartz topical pesticides are non-systemic to animals.

   In the letter Hartz sent to the CPI, they claim:

   “While all topical pet pesticide products registered by the EPA are “neurotoxins” to insects and target the insect’s nervous system, they do NOT target nerve and muscle cells in pets.”

   “By formulating topical pesticides to be non-systemic to animals, they do not target the animal’s nervous system.”

   On www.thetruthabouthartz.com, Hartz claims:

   “ALL EPA-regulated topical flea and tick products, including Hartz products, are non-systemic. They do not penetrate the skin, they do not enter the blood-stream and, therefore, they do not result in damage to internal organs.”

   Federal pesticide laws prohibit pesticide product manufacturers from making safety claims, such as “non-systemic to animals”  These laws apply to the product label, but they also apply to advertising and collateral literature, such as an open letter and websites.

   Last September, the EPA issued a Reregistration Eligibility Decision for d-Phenothrin (the main active ingredient in Hartz UltraGuard products for dogs). 

   http://www.epa.gov/oppsrrd1/REDs/sumithrin_(d-phenothrin)_red.pdf

   Here are excerpts:

   “The toxicity database for phenothrin is currently incomplete.  The toxicity database lacks acute, chronic, and developmental neurotoxicity studies that are required to fully evaluate risks to infants and children.” p.14

   “There are no studies of dermal absorption available specifically for phenothrin.” p.16

   Without dermal absorption studies for phenothrin, how can Hartz claim that it does not enter the bloodstream?  If it is ingested by a dog or cat while grooming, does it enter the bloodstream?

   Here is the Material Safety Data Sheet for phenothrin:

   http://www.sumitomo-chem.com.au/msds/d-phenothrin.pdf

   Excerpt:

   “Swallowed: High systemic doses may cause tremor, hyperexcitability, uncoordinated movements, salivation, nausea, vomiting and/or diarrhea.”

   If Hartz topical pesticides were formulated to be non-systemic to animals, it would not have been necessary for Hartz to cancel their phenothrin-based flea and tick product for cats and kittens, after the EPA received thousands of reports concerning seizures and deaths in cats and kittens.  Also, it would not be necessary for Hartz to include the following precautionary statement on the label, “Do not use this product on debilitated, aged, medicated, pregnant or nursing animals or on animals known to be sensitive to pesticide products without first consulting a veterinarian,” because the age or health of the animal would not matter if the product was non-systemic.  Also, if Hartz topical pesticides were non-systemic to animals, it would not be possible to overdose.

   The reason why it is important to consider the age, health, and weight of the animal before using a topical pesticide product is because these products are systemic.  They do get into the bloodstream.  Failure to heed the precautionary statements on the label will increase the possibility of an adverse reaction.

   If Hartz is truly committed to providing accurate information to consumers, they should disclose all of the risks of their topical pesticides, including the potential for severe reactions in pets, and the risks children face when they come into contact with a treated pet.

4. Posted by: rich parsons on June 01, 2009, 5:54 pm

   Dr. Marta Draper of Hartz Mountain writes that Hartz likes to deal in facts, supported by data and science.  That’s great—here are a few facts: 
   1)  Hartz Mountain has a deplorable safety record over the years.  Their product, “Blockade” was pulled from the market after the first year because of 496 documented animal injuries, including 75 deaths. 
   2)  Hartz Mountain was cited by the EPA and fined $45,000 for not reporting the adverse incidents from “Blockade” to the EPA as they are required to do by federal law.
   3)  Hartz Mountain’s products were required by the EPA to be repackaged and relabeled multiple times between 2000-2004, because of injuries and deaths that the EPA attributed to the use of their products. 
   4)  The EPA issued a Cancellation Order in 2005 on Hartz Mountain’s cat and kitten products containing d-phenothrin and s-methoprene, terminating the sale of these products and requiring reformulation of their future cat and kitten products.
   5)  Hartz Mountain’s current dog and puppy flea and tick products contain precisely the same ingredients (d-phenothrin, 85.7%, and s-methoprene, 2.3%) in exactly the same volumes as their EPA “Cancelled” cat and kitten products.  Yes, cats are more sensitive to pyrethroids than dogs, but EPA documentation shows thousands of dogs and puppies injured and killed by Hartz’s products containing these ingredients. 
   6)  Hartz Mountain has a pattern of using legal intimidation with advocacy groups, (Beyond Pesticides, Center for Public Integrity), the media (NBC, Miami Herald, CBS), veterinarians (Dr. Patty Khuly) and private citizens to silence their Constitutional right to free speech and expression of their opinions on the safety of these pesticide products.
   7)  On April 16th the EPA issued a Public Advisory stating that they were intensifying their analysis of these products, citing over 44,000 reported potential adverse incidents in 2008, a 53% increase over the year before.  They originally listed seven companies that they were focusing on.  Although Hartz Mountain was one of those seven, their spokespersons, Dr. Melinda Fernyhough and Dr. Draper, crowed to the media that it was significant that no Hartz dog products were listed by the EPA.  When the EPA issued a revised list that contained every manufacturer and every known registered pesticide topical product, including Hartz Mountain’s dog products, Dr. Draper was quoted in the media as saying, “That’s a mistake.”  She continues to obfuscate on this issue—on Hartz’s website, “the truth about Hartz”, they list only the original EPA announcement that focused on seven companies as opposed to posting the revised EPA advisory—once again misleading the public by implying that their dog products are not being investigated.  Ironically, the “truth” is they are. 
   8)  Hartz Mountain uses the highest volume of d-phenothrin in the industry in their dog and puppy pesticide products.  Many veterinary toxicologists and neurologists are most concerned about phenothrin in any volume, let alone 85.7%.
   9)  The EPA, in its d-phenothrin Re-Registration Eligibility Document, Sept. 2008, states that the cumulative health effects of d-phenothrin on infants and children are not determined.  In other words, there is risk to humans as well as animals. 
   10)  The National Pesticide Information Center (NPIC), the organization that works in cooperation with the EPA in compiling the statistical database of reported incidents, has listed phenothrin and methoprene in their top ten of all chemicals causing injuries or deaths every year since 2005.  They actually reported two human deaths attributed to these ingredients in 2005. 

   Dr. Draper, I’ve just listed ten truths about Hartz.  I could go on if you’re interested.  If I take you at face value, that is you and Hartz Mountain are interested in “the truth”, then I assume you’re pleased these facts are made public.  Now please, get off The Center for Public Integrity’s back…they have done us all a great public service.  Hartz Mountain Corporation could also do a great public service by demonstrating leadership and personal initiative and reformulating your products to safer alternatives which are available today.

5. Posted by: James TerBush on June 01, 2009, 9:02 pm

   Hartz has a long claimed that their products are among the safest insecticides available for pets, right up to the day the EPA insisted they be removed from the market.

   Cut and paste these links into the address window of your browser:

   http://news.google.com/newspapers?id=HBATAAAAIBAJ&sjid=_voDAAAAIBAJ&pg=5616,30764&dq=hartz+flea+statement+we+believe+safest+insecticides+1987

   
   http://news.google.com/newspapers?id=cIIIAAAAIBAJ&sjid=kzUDAAAAIBAJ&pg=3436,6186572&dq=hartz+flea+safest

   
   http://news.google.com/newspapers?id=Q9cTAAAAIBAJ&sjid=cwYEAAAAIBAJ&pg=6335,5768064&dq=hartz+flea+safest+insecticides

   
   http://www.news8austin.com/content/headlines/?ArID=57438&SecID=2

6. Posted by: James TerBush on June 02, 2009, 12:13 pm

   On May 13, 2009, Dr. Melinda Fernyhough, manager of scientific affairs at Hartz, posted a message concerning the safety of Hartz products on the following website:

   http://www.newsadvance.com/lna/lifestyles/pets/article/pets_can_have_reactions_to_topical_flea_medication/15885/

   She wrote:

   “And there is absolutely no fact-based reason to avoid tetrachlorvinphos. Tetrachlorvinphos has been used safely for many years.  The EPA recently reaffirmed its use for on-animal application, including sprays, powders and collars, based on a significant number of safety studies. These studies were fully reviewed and approved by the EPA, resulting in the re-registration of tetrachlorvinphos; all of which is available on EPA’s website.”

   The safety studies that Dr. Fernyhough refers to can be found here:

   http://www.regulations.gov/search/search_results.jsp?No=0&sid=121A1A157241&Ne=2+8+11+8053+8054+8098+8074+8066+8084+8055&Ntt=tetrachlorvinphos&Ntk=All&Ntx=mode+matchall&N=0&css=0

   Where did these safety studies originate?

   Here is the EPA’s Reregistration Eligibility Decision for tetrachlorvinphos:

   http://www.epa.gov/oppsrrd1/reregistration/REDs/tcvp_red.pdf

   Here are excerpts:

   “In response to studies submitted by Hartz and other public comments received during Phase 3 of the public participation process, the occupational and residential risk assessment was further updated and refined on October 25, 1999. During this period, Hartz also committed to providing additional studies to support pet uses. On December 8, 1999, the Human Health Risk Assessment was revised to incorporate changes to the residential assessment and new Quantitative Usage Analysis (QUA) information.”

   “A meeting was held with Hartz in July 2001. Hartz submitted exposure and toxicity studies in November 2001. On February 4, 2002, the residential assessment was refined further to incorporate new applicator and postapplication exposure data submitted by Hartz; the toxicity study did not result in a change in the risk assessment. The residential assessment was again refined on April 1, 2002 to incorporate changes to the toxicological endpoint.”

   Here is The Natural Resources Defense Council’s webpage concerning dangerous pet pesticides:

   http://www.nrdc.org/health/effects/npets.asp

   Here are excerpts:

   “Each year, Americans purchase and apply to their pets a vast array of toxic chemicals intended to kill fleas and ticks. These include collars, sprays, dusts and more. Many consumers probably assume that the products they use have been subjected to rigorous testing, and must, by virtue of their very ubiquity, be safe. After all, how could the government let deadly poisons be sold on grocery store shelves without applying stringent standards?”

   “The simple truth, however, is that the poisons in many of these products are not safe, either for pets or humans. Government regulation of these products has been sketchy, and testing of their impact in the home has been inadequate. The result is that many of the products sold by the millions in grocery, drug and pet supply stores, even when applied as instructed on the box, can cause serious health consequences to pets and humans.”

   “The main culprits are products that rely on a family of chemicals called organophosphates. One of these, tetrachlorvinphos, is still found in stores. Six others were removed from the market, one by one, from 2000 through 2006: chlorpyrifos, dichlorvos, phosmet, naled, diazinon and malathion.”

   In April, 2009, the NRDC issued a report titled, Poison on Pets II:

   http://www.nrdc.org/health/poisonsonpets/

   Here is a summary of the report::

   “The April 2009 paper Poison on Pets II details a first-of-its-kind study by NRDC showing that high levels of pesticide residue can remain on a dog’s or cat’s fur for weeks after a flea collar is put on an animal. Residue levels produced by some flea collars are so high that they pose a risk of cancer and damage to the neurological system of children up to 1,000 times higher than the EPA’s acceptable levels.”

   “Children are particularly at risk from these pesticides because their neurological and metabolic systems are still developing. They are also more likely than adults to put their hands in their mouths after petting an animal, and so are more likely to ingest the hazardous residues. We found that residues from two pesticides used in flea collars—tetrachlorvinphos and propoxur, among the most dangerous pesticides still legally on the market—were high enough to pose a risk to both children and adults who play with their pets.”

   Here is an internal EPA memorandum titled, Tetrachlorvinphos. Animal Incident Summary, which was drafted on February 3, 2009:

   http://www.biospotvictims.org/EPA-HQ-OPP-2008-0316-0018_3_.pdf

   Here is an excerpt:

   “Since 1992, 4,576 incidents for tetrachlorvinphos have been received (see Table 1). A total of 363 incidents were coded DA which means that the domestic animal died or was euthanized. There were 206 major incidents in which symptoms may have been life-threatening or caused residual disability.”

   In my opinion, these are fact-based reasons to avoid using tetrachlorvinphos.

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