EPA Tightening Restrictions on Flea and Tick Products

Below is an excerpt from the EPA concerning flea and tick products which goes along with my previous post on flea control. Most of the adverse reactions on pets occur when products are not used correctly, such as dog products used on cats, or large dog products used on small dogs. Over the counter products are especially under scrutiny. The EPA wants better labeling and clearer instructions to avoid possible adverse reactions.

See this post about a case against Hartz flea and tick spot that killed a bulldog on http://www.consumeraffairs.com/news04/2010/03/hartz_mountain_court.html

Due to a significant increase in adverse incidents, the U.S. Environmental Protection Agency is taking a series of actions to increase the safety of spot-on pesticide products for flea and tick control for cats and dogs. Immediately, EPA will begin reviewing labels to determine which ones need stronger and clearer labeling statements. Next, EPA will develop more stringent testing and evaluation requirements for both existing and new products. EPA expects these steps will help prevent adverse reactions. In dogs and cats that can include skin effects, such as irritation, redness, or gastrointestinal problems that include vomiting or diarrhea, or effects to the nervous system, such as trembling, appearing depressed or seizures—from pet spot-on products.

“EPA is committed to better protecting the health and safety of pets and families in all communities across our nation,” said Steve Owens, assistant administrator of EPA’s Office of Prevention, Pesticides and Toxic Substances. “New restrictions will be placed on these products, and pet owners need to carefully read and follow all labeling before exposing your pet to a pesticide.”

Following the 2008 increase in incident reports, EPA received additional information from the pet spot-on pesticide registrants and others and began an intensive evaluation of these products. Today, EPA is reporting the results of this evaluation, and taking steps to address the spike in reported incidents.

Among immediate actions that EPA will pursue are:

· Requiring manufacturers of spot-on pesticide products to improve labeling, making instructions clearer to prevent product misuse.

· Requiring more precise label instructions to ensure proper dosage per pet weight.

· Requiring clear markings to differentiate between dog and cat products, and disallowing similar brand names for dog and cat products. Similar names may have led to misuse.

· Requiring additional changes for specific products, as needed, based on product-specific evaluations.

· When new products are registered, granting only conditional, time-limited registrations to allow for post-marketing product surveillance. If there are incidents of concern associated with the product, EPA will take appropriate regulatory action.

· Restricting the use of certain inert ingredients that EPA finds may contribute to the incidents.

· Launching a consumer information campaign to explain new label directions and to help users avoid making medication errors.

In addition, to improve the regulatory oversight of pet products, EPA will require more standardized post-market surveillance reporting on adverse effects, require submission of more sales information so the agency can better evaluate incident rates, and bring up-to-date the scientific data requirements on pre- and post-market testing so they are more in line with the Food and Drug Administration’s requirements.

Flea and tick products can be appropriate treatments for protecting pets and public health because fleas and ticks can transmit disease to animals and humans. While most people use the products with no harm to their pets, the agency’s analysis determined that smaller dogs tend to be disproportionately affected by some products and that the exposure of cats to some dog products is a concern.

People should carefully follow label directions and monitor their pets for any signs of an adverse reaction after application, particularly when using these products for the first time.

EPA recommends that owners consult a veterinarian about the best way to protect their pets from fleas and ticks or whether pesticides are needed, especially before using any product on weak, aged, medicated, sick, pregnant or nursing pets, or on pets that have previously shown signs of sensitivity to pesticide products.

EPA is coordinating these actions with Health Canada as Canada also identified similar concerns about the use of spot-on flea and tick products last year, and with the Food and Drug Administration’s Center for Veterinary Medicine.

The agency is inviting public comment on how best to implement these new measures. A Federal Register notice announcing the opening of a docket will be published on March 19, 2010. The docket number is EPA-HQ-OPP-2010-0229.

EPA’s report on the evaluation of products and incidents is available at: http://www.epa.gov/pesticides/health…ductseval.html

EPA recommends that veterinarians use the National Pesticide Information Center’s Veterinary Pesticide Adverse Effects Portal to report incidents: http://npic.orst.edu/vet

Flea Control

fleaFleas are pesky parasites and have adapted very well to living in our houses. In fact, houses are at the perfect temperature and humidity to become hatching factories for fleas. I no longer recommend flea control just in the spring and summer, but prefer to use flea control on pets all year round. It is better to prevent a flea infestation that try to eradicate one. One flea can hitch a ride on your pants leg from visiting a friends house, and if this flea is a female, chances are she already laden with thousands of eggs. Fortunately, fleas prefer to feast on the smaller critters rather than humans, because our pet’s body temperature is a few degrees higher than ours. But if the dog, cat or ferret are not present, then fleas will indeed bite a human.

To control fleas, you must have an understanding of the flea life cycle and the points in that life cycle where they are vulnerable to eradication. You also need to know what products that will kill the fleas and which ones are safe for your pets. Because some people may have more than one species of pets in the household, you do not want to use a product on a dog that may be potentially toxic to a cat or a ferret.

We will start with the life cycle of the flea.

  • A female flea begins to feed on her host as soon as she hops a ride. Her blood meal nourishes the eggs and egg production begins within 20 to 24 hours after her first feeding.
  • Female fleas can lay 20 to 50 eggs a day and 2000 in her lifetime.
  • The female flea consumes 15 times her weight in blood a day.
  • A flea bites your pet 400 times a day.
  • The “flea dirt” found on your pet is the flea feces made of your pet’s blood. You can tell it is flea dirt if you put a small amount on a white paper towel and apply a small amount of water. As the dirt dissolves it will turn the paper towel red.
  • The eggs are pearly white, oval and about 0.5 mm in length. flea eggs
  • The term “salt and pepper” refers to the flea eggs that are about the size of a grain of salt and the flea dirt that falls off of the pet. It is most notable on the bedding of the pet or where ever the pet lays.
  • The eggs are laid on the pet and roll off the pet into the environment.
  • Depending on the temperature and humidity, fleas can go from eggs to adults in as little as 13 days to as long as 8 months.
  • The flea eggs hatch into flea larvae which look similar to small maggots covered with tiny hairs.flea larvae
  • The flea larvae do not like light and will crawl through the carpet to seek darkness under the furniture, in cracks and crevices of cushions and in other out of the way areas.
  • This is one reason why traditional “flea bombs” are sometimes ineffective. The spray goes up and comes back down, and does not reach where the larvae are hiding and feeding.
  • Flea larvae feed on the adult flea blood feces dropped off your pet and other organic matter in your carpet.
  • The length of the larval stage of the flea is dependent on the temperature and humidity of the house.
  • The next stage of development is the pupae or cocoon.flea pupae
  • The larvae builds the cocoon and uses some of the debris in the environment such as carpet fibers into the shell of the cocoon.
  • The shell of the cocoon is now “glued” into the carpet and impossible to vacuum up.
  • The shell also provides protection from the elements and also insecticides.
  • Fleas will emerge from the cocoon when the temperature is around 24° (75.2° F) and a relative humidity of 78%.
  • The flea can remain in the cocoon for up to 30 weeks.
  • The flea will emerge from the cocoon when stimulated by:
  1. Mechanical pressure or vibrations- such as someone or a pet walking by.
  2. CO2 – Carbon dioxide from the pet or person breathing.
  3. Increased temperature.
  • Homeowners away for a vacation can sometimes experience the sudden hatch out of thousands of fleas that were in the cocoon state ready to emerge. The vibrations of the owners returning and the exhaled carbon dioxide coupled with the air conditioner turning back on will stimulate the fleas to emerge and start to bite anything that is near. This sudden hatch out can also occur in vacant houses that have just been moved into.

Now that you understand the life cycle of the flea, let us find the points that the flea can be killed.

  • The first point is on the pet. There are newer products available that are safe to use and will kill the flea with in the first 24 hours of the flea jumping on the pet. Why is this important? Remember that the flea does not start laying eggs until 20 to 24 hours after her first blood meal. If you can kill the female flea before she begins to lay eggs, you are a giant leap ahead of controlling your flea population.
  • Point number two. Intermittently applying flea control products will result in gaps in your flea control that will result in female fleas laying eggs that can hatch out a year later. I recommend that you use the flea preventative products once a month all year round. Consider the flea not as a seasonal critter, but an indoor monster waiting to hatch out of your carpet and suck your pet’s blood.
  • Point number three. The eggs and cocoons have a protective shell that make them resistant to the insecticides. The larvae and the adult fleas are the only stages that can be killed by insecticides.
  • Point number four. Insect growth regulators are effective to keep flea eggs from hatching, but are difficult to apply in the areas that the flea eggs are hiding.
  • Point number five – Frequent use of insecticides in your house and yard can build up and may cause toxicity to you and your family.For these reasons, I do not like insecticide foggers or bombs in the house. They do not get in the areas that hide the fleas and they contain insecticides that can build up in your house.

So, what products are safe to use on my pet?


– The advantage product by Bayer (Imidacloprid) is an excellent product for the control of fleas on dogs, cats and ferrets. (not officially labeled for use on ferret see post on http://www.allferret.com/1425/controling-fleas-on-ferrets/)

Advantage has unique crystals that are not harmful to mammals, but totally incapacitate the fleas. There is a 99% kill rate within 12 hours after applying the advantage. The obvious advantage is it kills the female flea before she begins to lay her eggs, thus breaking the life cycle. The other advantage is the imidacloprid crystals that are attached to the hairs of the pet fall off the animal into the environment, i.e. the carpet, etc. as the pet sheds hair. When the larvae emerge from the safe confines of their egg shell and come in contact with the crystals in the carpet, the result is another dead flea larvae within 2o minutes.

So by applying the advantage product to your pet once a month,  all year round, you are also effectively treating the environment as the fleas are hatching out.

Check out how it works at  http://advantage.petparents.com/



Advantage – multi contains the imidacloprid like the Advantage but also contains moxidectin. By adding moxidectin  advantage- multi  prevents heartworm disease, kills adult fleas and controls flea infestations, and treats and controls intestinal worms (hookworms and roundworms). Advantage-multi is applied once a month for both cats and dogs.  We have also used it to control ear mites and other mites. Advantage -multi is only available with a prescription but is well worth it for what it covers.



Revolution is the first-ever FDA-approved, topically applied medication for dogs and cats that kills adult fleas and prevents flea eggs from hatching out, treats and controls earmites, treats and controls sarcoptic mange, and also helps control the brown dog tick. Revolution contains selamectin and is topically applied. Revolution then enters the bloodstream through the skin. Concentrations of Revolution in the blood and tissues prevent heartworm disease and treats the intestinal parasites (hookworms and roundworms). Revolution selectively redistributes from the blood to the skin, where it provides protection against fleas, flea eggs, American dog tick, and mites. I recommend the Revolution be applied once a month to both dogs and cats all year round. Revolution is also only available with a prescription.


Vectra 3D

Vectra 3D for dogs contains 3 ingredients dinotefuran, pyriproxyfen, permethrin. Because cats are sensitive to permethrins, you cannot use the Vectra 3D dog product on cats. The combination of Vectra’s ingredients help to protect dogs from 4 species of ticks, 3 species of mosquitoes and all stages of fleas.

Dinotefuran is a quick-kill insecticide discovered by researchers at Mitsui Chemicals. A third generation neonicotinoid, dinotefuran was synthesized with acetycholine as the lead compound, making it different from other flea control products currently in use which are based on nicotine.

Over the last 10 years, fleas have developed tolerance to older products, making them less effective in protecting pets from infestation and infection.

In addition, dinotefuran does not bind to the same insect receptor sites in the nerve synapse as imidacloprid and other neonicotinoids. The binding is permanent causing continuous nerve stimulation and death of the insect. Ingestion is not necessary. Dinotefuran kills by contact.

In numerous studies and clinics across the U.S., Vectra® vectoricides – which are based on the compound dinotefuran – have killed fleas quickly and safely for a full 30 days between applications.

The permethrin helps repel mosquitoes and ticks is not adequate enough to totally protect from heartworms. If you are using Vectra 3D for fleas, you should also use a heartworm preventative to protect from heartworms and intestinal parasites. Vectra 3D is also applied topically once a month and should also be used year round.

Vectra for Cats

The Vectra for cats does not contain permethrin.

Vectra® for Cats & Kittens and Vectra for Cats® contains a unique dual-action formulation that’s proven highly effective against fleas:

  • Dinotefuran: quick-kill contact neonicotinoid that causes continuous nervous stimulation in insects resulting intremors and death.
  • Pyriproxyfen: potent IGR prevents development of all immature flea stages; stable in sunlight.

In numerous studies and clinics across the country, Vectra for Cats & Kittens and Vectra for Cats have provided fast, safe, long-lasting protection against fleas and flea-borne diseases.

  • Kills fleas within 6 hours.
  • Kills on contact; fleas do not have to bite to die.
  • Prevents development of all immature flea stages: eggs, larvae and pupae.
  • Protects against flea-borne diseases including tularemia, rickettsiosis, bartonellosis and tapeworm.
  • One application protects cats for 1 month.
  • Safe for kittens as young as 8 weeks of age.
  • Patented applicator makes administration fast, easy and accurate.

Vectra does not cover intestinal parasites, heartworms, or earmites.



Comfortis® is the first FDA-approved, chewable, beef-flavored tablet that kills fleas and prevents flea infestations on dogs for a full month.

Only Comfortis® offers you all of these benefits in a single product:

  • Fast, month-long flea protection
    • Starts killing fleas within 30 minutes
    • Lasts a full month
  • Kills fleas before they can lay eggs
  • The convenience of a chewable, beef-flavored tablet

COMFORTIS chewable tablets  contain (spinosad) . Spinosad is a member of the spinosyns class of insecticides, which are non-antibacterial tetracyclic macrolides. Because it is ingested, the flea must bite the dog to receive the deadly dose. Comfortis also does not treat the environment so you will continue to find fleas for several months until all the eggs, larvae and pupae have completed their life cycle.

Comfortis does not protect your pet from heartworms, intestinal parasites, ticks or mites and is only effective against the fleas. You must use other products in conjunction with Comfortis to protect from the other parasites.

Go to http://comfortis4dogs.com/ for more information


Capstar contains nitenpyran and is also given orally. It is effective at killing fleas in 30 minutes and the flea must bite the dog to get the lethal dose. Capstar is only effective for one day so I seldom use it especially when other products that last the full month are available. Capstar is only used to kill fleas and does not protect your pet from heatworms, intestinal parasites, mites or ticks.

A few words about OTC (over the counter) flea medications. It has been my experience that the OTC flea spot-ons sprays and flea collars are NOT effective flea control products and I do not recommend them.

As you can see, there is a variety of products available for flea control. Each one has it’s own merits and covers different parasites. If you seem at all confused, get with your veterinarian and discuss with him or her what products they recommend. Since I live in a mosquito, flea, tick, and intestinal parasite hot bed in Houston, TX, my preference has been Revolution because it covers almost everything and because it is absorbed through the skin, bathing does not remove the product. Also cats are now getting heartworms so I am also recommending the Revolution be applied to cats year round to help prevent heartworm disease. I also like the Revolution for the earmite and sarcoptic mange control as well as the intestinal parasite control.


Trifexis is the newest product to be introduced and it is a chewable tablet that controls fleas, prevents heatworms and protects against the intestinal parasites; roundworms, hookworms and whipworms.  Trifexis starts killing fleas in 30 minutes and keeps working to prevent flea infestations all month long. Because fleas, heatworms and intestinal parasites are major problems here in Houston, I routinely recommend for my client to use both the flea and heatworm medication every month all year long, in order to prevent flea infestations in the home and to prevent heartworm disease. Since the Trifexis is a chewable tablet, you don’t have to worry about it being washed off or leaving a dirty streak down the back of your dog.   I have even switched my own dog to this medication.

Information on Trifexis can be found at Trifexis.com






INDICATIONS: Bravecto kills adult fleas and is indicated for the treatment and prevention of flea infestations (Ctenocephalides felis) and the treatment and control of tick infestations [Ixodes scapularis (black-legged tick), Dermacentor variabilis (American dog tick), and Rhipicephalus sanguineus (brown dog tick)] for 12 weeks in dogs and puppies 6 months of age and older, and weighing 4.4 pounds or greater.

Bravecto is also indicated for the treatment and control of Amblyomma americanum (lone star tick) infestations for 8 weeks in dogs and puppies 6 months of age and older, and weighing 4.4 pounds or greater.




Debra Garrison, DVM