Tim,
If I may, I'd like to address the above CPI report, which is outdated and contains many inaccurate statements and statistics, particularly in regard to the safety of pyrethroid-based pet pesticides and those flea & tick pet products sold in retail distribution ("OTC").

To bring this entire topic quickly up-to-date, I am attaching the link to an EPA Advisory dated 4.16.09 "Increased Scrutiny of Flea and Tick Control Products for Pets." www.epa.gov/pesticides/health/flea-tick-control.html

Based and relying on current statistics, an analysis of 2008 Adverse Product Reactions reported to the EPA (not 5 yr-old unauthenticated data), the EPA is quite clear that its "Increased Scrutiny" involves ALL the pet pesticide products under its regulation, both OTC & those sold by veterinarians. Furthermore, there are exactly 4 brands, with a total 7 products, under scrutiny because combined they were responsible for 80% of 44,000 reports of Adverse Reactions in 2008. There are 2 each of OTC and vet brands in the group, including Frontline, the #1 vet brand.

As for the misleading statements re pyrethroids in the CPI report, the two vet brands under scrutiny are non-pyrethroid products, one of which is characterized by CPI's analysis as accounting for significantly less Adverse Events than OTC pyrethroids, on average 50% less.

In actual fact, the pyrethroids in the leading retail brand of pet pesticide, Hartz, has a lower EPA oral toxicity rating than the two leading vet brands and, as you can see from the EPA Advisory list of high volume AE brands, has a low incidence of reported reactions since it has not been singled out for scrutiny.

If an organization bears the word Integrity in its name and mission statement, the integrity of its research, analysis and conclusions should follow. This week's Advisory from the EPA, the regulatory authority for both OTC & non-Rx vet pet pestiicdes, lends suport & clarity to a summary challenge of content of CPI's Report.

Pet pesticides are chemicals. Whether in a costly or more affordably priced product, they are all chemicals. Subject to the same regulatory & testing standards, and requiring of the same care, caution and respect when handling & applying. Their "safety" can be measured by two factors; how they fare and are rated in the standardized EPA-required safety & eficacy studies. And by their real-life record, in the marketplace when they are handled by pet owners and applied on pets. CPI's research approach ignored this basic protocol for comparative product analysis, choosing instead a singularly biased route with a distorted spin on the facts.

Facts are truths. The facts in the EPA Advisory challenge CPI's truth - - the EPA is not 'looking into' pyrethroids in OTC products, rather a scrutiny of specific OTC and Vet products, pyrethroids and non-pyrethroids, 50/50, based on an analysis of in-usage adverse product reactions by EPA, which does not resemble the CPI's "spin" on EPA findings.