UNI TED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON D.C., 20460 OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION

MEMORANDUM DATE : November 6, 2014 SUBJECT:

FROM: Tetrachlorvinphos Response to Comments Submitted in Response to the Natural Resources Defense Council's April 23, 2009 Petition Requesting Cancellation of All Pet Uses ofTetrachlorvinphos Kelly Ballard, Chemica l Review Manager Risk Management and Implementat ion Branch 1 Pesticide Re-evaluation Division**~1508 P)**  THROUGH : Neil Anderson, Branch Chief

# ~ 

# .J) Risk Management and

# Implementa~anch 1 Pesticide Re-evaluation Division (7508 P) TO: Tetrachlorvinphos Petition Docket Docket Number: EPA-HQ-OPP

-2009-0308 www .regulations.gov
This memorandum serves to respond to comments that were submitted to the tetrachlorvinphos (TCVP) public docket (EPA-HQ

-OPP-2009

-0308)
. On June 5, 2009, the U.S
. Environmenta l Protection Agency (EPA or the Agency) announced receipt of a petition, dated April 23, 2009, from the Natural Resources Defense Council (NRDC) that requested cancellation of all pet uses for TCVP in the Federal Register (74 FR 27035) and posted the petition in the public docket for a 60-day publi c comment period. The public comment period ended on August 4, 2009. During the comment period , EPA received approximately 8,600 form letters as part of a mass campaign supporting NRDC's petition to ban TCVP pet products. In addition, the Agency also received a comment from The Humane Society ofthe United States (HSUS) that supported NRDC ' s Petition and a comment from one TCVP registrant, Hartz Mountain Corporation, which opposed NRDC's Petition
. Below is a summa ry of the comments and the Agency's corresponding responses. Form Letter Comment: I urge you to cancel thepet uses of the pesticides tetrachlorvinphos and propoxur. Chemical residues from these products left on pet fur can damage the human brain and nervous system and cause cancer . Children are particularly at risk from these pesticides because their neurological and metabolic

1 of4systems 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. New testing by the Natural Resources Defense Council reveals that the EPA's decision to leave these products on the market may create a significant health risk to pet owners , most notably young children. I am therefore extremely disturbed to learn that the EPA still permits the use of these products on pets. The availability of many safer alternatives for flea and tick control renders the continued use of these pesticides in pet products an unnecessary risk. The EPA must reconsider the safety of these products and remov e them from the market. I urge you to protect the health of our children as well as our pet s by immediat e ly ordering the removal of products containing tetrachlorvinphos and propoxurfrom the market. Agency Response : The Agency understands the concerns expressed by NRDC and th e pub li c. The Agency has addressed

the claims presented by N RD C i n a petition response , entitled Respo n se to Natural Resources Defense Council's April 23, 2009 Petition Requesting Cancellation of All Pet Uses ofTetrachlorvinphos , dated November 6, 20 1 4 , and a new residential exposu r e assessment, ent i t l e d Tetrachlorvinphos: Residential

Exposure Assessment in Response to the Natural Resources Defense Council Petition to Cancel All Pet Uses for Tetrachlorvinphos, dated November 5, 20 1 4. T hese documents can be found in the TCVP public d ocket number EPA - HQ-OPP

- 2009-0308 a t www.regula t ions . gov. HSUS Comment:

These comments are being submitted on behalf ofThe Humane Society of the United States (HSUS)

and our more than eleven million members and constituents. We thank the EPAfor the opportunity to comment on this dange r ous chemical as it is used in flea and tick products. T he HS U S re c ognizes the need to control fleas and ticks living on companion animals (dogs and cats) for both the welfare of these species but also for the welfare of human beings. Ensuring that the public has easy and economical access to products which will reduce or eliminate these ectoparasites is crucial to improving the quality of life for companion animals and their owners. Our concerns relate to the adverse reactions caused by chemicals in flea and t i ck products . Over the past decade, the HSUS has received hundreds of complaints regardi n g severe reactions and even death of companion animals caused by many flea and tick products. These pet owners are outraged by the lack of proof that these chemicals are safe. After losing their beloved pets and incurring enormous veterinary expenses trying to save their lives , these pet owners feel b e trayed and confused. Despite an agreement between the Hartz Mountain Corporation and The EPA , The HSUS continues to receive complaints regarding Hartz flea and tick products more than any other manufacturer. This is not surprising as the EPA ' s list of registered pet products containing organophosphate insecticides , which appears on the Natural Resources Defense Council ' s website , shows that nearly all of the products listed under TCVP are manufactured by Hartz. 2 of4Even though Hartz has agreed not to sell certainproducts and to improve their labeling of other s, The HSUS continues to receive complaints. Anecdotally , we were recently contacted by a constituent in Minnesota who had adm inistered Hartz Flea Drops to her cat. The cat became lethargic and refused to eat. A visit to a veterinarian, who administered fluids and antibiotics, did not help his symptoms. Only after realizing that the time of the cat 's illness coincided with the application of the flea treatment did the owner realize what caused the cat 's decline
. Unfortunately, the veterinarian did not question the owner if there had been a recent flea/tick treatmeni. The owner ispursuing further treatment for her cat, at her own expense, but larger questions remain about the safety of theseproducts
. We urge you to ban Tetrachlorvinphos completely for use in animals
. It has likely caused significant harm to countless companion animals and theirfamilies and its safety in humans cannot be substantiated. T he HSUS supports the ban of all organophosphates for use inpetproducts and will steerpet owners away from these chemicals and the companies which manufactureproducts containing them. Instead, we will encourage use of products which work to inhibit the growth of fleas and su pport flea treatment of the living environments of animals, rather than advising that chemicals be applied directly to animals. Agency Response: The Agency thanks HSUS for its comment expressing its concern for TCVP use on pets and potential adverse reactions ofcompanion animals
. The Agency shares HSUS's concern about protecting pets, and is committed to studying this issue more closely to understand what additional measures, if any, may be appropriate to reduce the incidence ofthese unfortunate and avoidable events. While t his comment does not pertain to the human health issues raised by NRDC ' s Petition, the Agency will conduct an in

-depth review and analysis ofpet incident data resulting from pet products that contain TCVP during the regi stration review process forTCVP
. Hartz Mou1ttain Corporation Comme1tt: The EPA conducted its R eregistration .E!;gibility Decision (RED) process.f()r TCVP in 2006
. NRDC claims that EP A 'fctiled to adequately assess residential exposures to TCVP
., in the RED
. However, l · vhile the validity**(~ltesr** data submilfed by NRDC in support r?f'theirpetilion is very questionable, most significant is the lack qfregulatory complhmce as noted by EPA in their l-1'riTten response to NRDC on lvlay 28
. 2009. NRDC is required to have their studyprotocol reviewed by EPA ·s Human Studies Review Board (HSRB). which rhey.faNed to do. Without HSRB approving rhe protocol. EPA is legally obligated not to revieH' any data fi'om any such study. Without any data in support oft he petition the petition is 1vithout merit and must be denied. Hartz has submirted substantial daTa, including a dislodgeable residue study. to EPA in support 

### <?l TCVP 's REDprocess. and the current uses c?f'the active ing redient in productsforpets. The dislodgeable residue study supports residential exposure.findings.fhr calculating riskfi·orn use of companion animal insecticides. Th e work on the TCVP RED was completed in July 2006
. In California. N RDC lobbied To have TCVP revie1<ved as a highpriority chemica/for consideration fbr Prop 65 labeling requiremen ts. In i \4ay 2009. qf.Jice 

## (l Health Hazard Assessment (OEHHA) commiflee concluded that there was**ins1~{jicient** animal or human data toprioritize TC VPjbr a Prop

3 of465 listing. This was the second time TCVP has been reviewed and not considered.f(Jr the lisling. OEHH A. in making their decision. revierlled all inj(Jrmationfrom the TCVP RED data , other studies apart.fi-om the RED and examined use patterns.f(Jr exposure in a wide list o.luses. some <?(which having already been voluntarily cancelled by registrants or eliminated by EPA due to exposure issues .

Hartz is in agreement with EPA and their assessment and.findings.fl"om the TCVP RED. Hartz recommends EPA reject the NRDC petition due to the lack**(~{'acceptable** scient(/ic evidence as presented b,v NRDC. Agency Response: T he Agency thanks Hartz for its comment, and appreciates th eir role in providing information to the Agency to refine i ts risk assessment related to the Petition response. 4 of4