EPA Rejects Appeal on|Pet Collar Insecticide Use

     WASHINGTON (CN) – Carbaryl, an insecticide commonly sold under the name Sevin, can safely be used as a flea and tick treatment on pet collars, according to the Environmental Protection Agency in final orders overruling objections.



The Natural Resources Defense Council filed an objection to such uses, but the EPA has refused to hear the environmental group’s case.
     The Natural Resources Defense Council (NRDC) objected to the agency’s approval of acceptable tolerance levels of the insecticide for use on pet collars in 2005, arguing that the agency lacked proper studies on the long term exposure risks to children, of such use, and that it did not follow its own rules requiring a ten fold safety factor for applications that come in contact with children.
     Consideration of this safety factor is mandated under the Food Quality Protection Act and is called the Children’s Safety Factor. The EPA asserts that the children’s safety factor has always been a presumptive default that may be reduced where sufficient data exists to show that a lower factor will not endanger infants and children.
     Safety factors are considered as multiple reductions in the acceptable level of a substance from the initial concentration at which it is first found toxic. So a safety factor of 10X would mean reduction by 10 times of the amount of the substance at its toxic concentration.
     “Safe” is defined by the Federal Food Drug and Cosmetic Act to mean that “there is a reasonable certainty that no harm will result from aggregate exposure to the pesticide chemical residue, including all anticipated dietary exposures and all other exposures for which there is reliable information.”
     The EPA maintains that studies performed by its own Office of Research and Development indicate that a safety factor of 1.8 was sufficient to protect against potential harm to children from exposure to carbaryl products. These studies already include other safety factors to account for potential differences in the way humans are affected by exposure to carbonyl as contrasted with the animal subjects used for exposure testing.
     For its part, the NRDC cites studies showing that juvenile test animals suffered developmental abnormalities at doses that had no effect on adult test animals and that this alone should require a 30X safety factor–10X for age related differences and 3X because initial testing missed the lack of effect on adult versus juvenile test subjects. Along with the Children’s Safety Factor of 10X, NRDC argued that the proper safety factor was 300X.
     The agency’s action exhausts the administrative appeals process for the NRDC objections to the approved tolerances for carbaryl.

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