By Dr. Becker
According to dvm360 in an article dated January 1, 2012:
Manufacturers of spot-on flea-and-tick products have six months to make labeling changes, according to a new directive from the Environmental Protection Agency, to address increasing adverse events associated with the misapplication of these products by pet owners.
(These products are chemical pesticides applied to the necks or backs of dogs and cats as a flea/tick preventive.)
Per dvm360, the new labeling will include repeated use of the word 'dog' or 'cat' to clearly identify who the product is intended for.
Font size changes will be made (I assume larger fonts will be used), and images of cats or dogs will appear on labels so pet owners can quickly distinguish a dog spot-on product from one intended for cats.
Also, dog products will carry specific warnings about use on cats.
According to dvm360, the EPA also requested more labeling information about possible adverse effects, as well as instructions to pet owners to consult a veterinarian or the product manufacturer in case of an adverse event.
A Little Background on the EPA's Concern about Pet Spot-on Products
Even though I don't recommend use of these pesticides in most situations, I was encouraged to learn that some three years after the EPA started paying attention to problems with spot-on products, it finally issued a directive to make them safer.
In April 2009, the EPA issued an advisory about spot-on products after receiving over 44,000 reports of adverse reactions during 2008, including 600 deaths. This represented a very disturbing 57 percent increase in reported incidents in a single year -- incidents ranging from mild skin irritation to seizures and death.
In March 2010, the EPA published the results of a year long study of spot-on flea and tick products. Findings included the following:
- Most adverse reactions were seen in dogs weighing between 10 and 20 pounds.
- Reactions in mixed breed dogs were most commonly reported, however, the Chihuahua, Shih Tzu, Miniature Poodle, Pomeranian, Dachshund, Maltese, Yorkshire terrier and Bichon Frise seem particularly at risk.
- Products containing cyphenothrin and permethrin were especially problematic for small breed dogs.
- Most incidents occurred in dogs under three years old, likely at their first exposure to a spot-on product.
- Adverse reactions for both dogs and cats were primarily skin, GI tract and nervous system related. Skin reactions included redness, itching, hair loss, sores and ulcers.
- Gastrointestinal symptoms included vomiting, diarrhea and salivation.
- Reported nervous system symptoms included lethargy, nervousness, ataxia (movement problems), tremors and seizure.
- A number of adverse reactions in cats were the result of the cat either being treated with a product intended for dogs, or through exposure to a treated dog. Cats treated with products intended for dogs had an especially high rate of serious reactions and fatalities.
- Inert ingredients in spot-on products were generally assumed to contribute to toxicity.
- Dosage ranges were considered to be too wide in some cases.
- Product labeling was identified as needing a revamp in many cases.
- The EPA's Companion Animal Studies guidelines are insufficient to predict the toxicity of spot-on products.
What Happened Next
As a result of its investigation, in March 2010 the EPA acknowledged that current label warnings on spot-on products were not effective.
To rectify the situation, the Agency called for new labeling requirements to include updated warnings, a listing of possible symptoms, better instructions for use and dosage guidelines, and possible restrictions on certain ingredients.
Then for 60 days the EPA took comments from the public on its product labeling recommendations.
Some 16 months later, on September 30, 2011, the EPA released a document in response to the public comments received between mid-March and mid-May 2010.1
The document organizes over 1,100 comments submitted by the public into 12 general issues. After each issue, the EPA provides their response. Two examples:
- Issue 4 asks for a ban on all products with the potential to cause death in cats. The EPA's response is that while they don't intend to ban dog spot-on products that have proved lethal to cats, they are working with product manufacturers to change product labels to clearly address the risk to cats.
The EPA said it intended to send a letter to manufacturers requesting revised labels be submitted within 6 months. The date of the EPA letter will presumably determine when product manufacturers submit revised labels.
What happens after submittal to the EPA is a mystery to me, so I don't think I'll hold my breath waiting for revised labels to appear this year.
- Issue 9 asks for label changes to include a toxicity warning by ingredient, directions for pet owners in the event a dog or cat experiences side effects, and clear acknowledgement on all packaging that spot-on products are pesticides.
The EPA's response was essentially identical to the response to issue 4. So again, I don't expect to see toxicity information on spot-on labels anytime soon.
As It Stands Today ...
The folks at dvm360 are more optimistic than I am about this latest effort by the EPA to make spot-on products safer to use.
It seems to me this latest EPA 'directive' is actually a series of recommendations provided to spot-on product manufacturers with a request to comply within six months (six months from when is not clear).
Hopefully by this time next year, we'll see improved labeling of spot-on products.
How You Can Avoid Using Spot-on Products Altogether
Regardless of improvements to the labeling of spot-on pesticides, please know there are safer solutions for flea and tick control for your pet. Chemical pesticides, no matter what form they come in, can have side effects.
Just because a spot-on product is applied to the outside of your pet doesn't mean it can't make its way inside. Any sort of product applied to your pet's coat and skin can be absorbed into the body.
Alternatives I recommend include:
- A safe pest deterrent, like Flea and Tick Defense. This product contains no synthetic chemicals -- only safe Brazilian oils and pure water. It has a pleasant smell, is non-sticky, and repels not only fleas and ticks, but also flies and mosquitoes.
- Cedar oil (specifically manufactured for pet health)
- Natural, food-grade diatomaceous earth
- Fresh garlic -- work with your holistic vet to determine a safe amount for your pet's body weight
- Feeding your pet a balanced, species-appropriate diet. The healthier your dog or cat is, the less appealing she'll be to parasites. A biologically appropriate diet supports a strong immune system.
- Bathing and brushing your pet regularly and performing frequent full-body inspections to check for parasite activity.
- Making sure your indoor and outdoor environments are unfriendly to pests.
For Those Who MUST Use a Chemical Flea/Tick Control Product
If you find yourself faced with no choice but to use a chemical pest preventive, I strongly urge you to take the following steps to reduce the health risk to your pet:
- Be very careful to follow dosing directions on the label, and if your pet is at the low end of a dosage range, step down to the next lowest dosage.
- Be extremely cautious with small dogs, especially if you own one of the breeds reported to be at high risk for adverse reactions. And do not, under any circumstances, apply dog product to your cat.
- Don't depend exclusively on chemical treatments. Rotate natural preventives with chemical ones.
- Use only when your pet is in a high-risk environment (i.e. camping in a Lyme disease endemic area), then discontinue.
- Monitor your pet for symptoms and adverse reactions after you apply a chemical product -- especially when using one for the first time.
- Consult your holistic vet about natural therapies that can help alleviate your pet's toxic load.