It is extremely important…

It is extremely important for the industry and the consumer that no change occur to disrupt the market, specifically in the existing Class 5 and Class 6 products being grouped as Class D. Presently, Class 5 pesticides must be sold by licensed vendors but not Class 6 pesticides which are exempt. Class 6 products such as flea and tick (topicals, pet sprays, shampoos, collars and premise/home sprays) sold in the pet/retail markets (PetSmart, Global Pet Foods, Pet Valu etc) have never required a license. Under the proposed licensing regulations, the following is suggested "As a result of reclassification, Class D and would include both Class 5 and 6 pesticides. It is proposed that vendors would require a licence for the sale of Class D pesticides, not including personal use insecticides and rodenticides." The general comment “not including personal use insecticides” is confusing because it is not clear if this includes flea and tick pest control products which are Class 6 products or any other existing Class 6 products (which should be exempt). This current license exemption should continue with flea and tick products in the retail market as there are thousands of retail locations for flea and tick who could not afford a license. This would inhibit the average family from protecting its pets because veterinarians would become the only location for consumers to obtain product, only available with a veterinarian visit cost, in addition to the extreme high product cost (average $15 retail cost vs a $150 veterinarian cost). Consumers then would not be able to afford the flea, tick and mosquito protection for their companion animals, and therefore, these pets risk infestation of pests and infection with disease. Therefore, it is extremely important that the current classification continue and that Class 6 products like flea and tick remain exempt (without a license). Furthermore, it is imperative that clarification occur in the proposed document so that “personal use insecticides” which are Class 6 products, are defined and flea and tick products are included in the exemption.