Comment from Elizabeth Pandolfelli

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Summary: A concerned citizen and wild horse supporter is urging the FDA to grant a citizen petition regarding the safety and efficacy of GonaCon-Equine and ZonaStat-H. The commenter argues that these products cause heritable genetic issues, ovarian dysfunction, and chronic welfare problems in wild horses, violating federal protections.
I am a concerned citizen and supporter of America's wild horses, I urge the FDA to grant the requests in Tirza Eden's Citizen Petition regarding GonaCon-Equine and ZonaStat-H. The petition correctly highlights that current EPA classification as temporary "pesticides" does not match the real-world effects: heritable selection for non-responders as seen with Carol’s Girl on Assateague Island, declining reversibility with boosters (ie. Kirkpatrick 1995 and Nunez 2017; Baker 2023 determined no known reversibilty for more than one dose of GonaCon), ovarian dysfunction and undetectable Anti Müllerarian hormone levels-AMH (Joonè 2017 & 2018), and adjuvant-related welfare issues in target animals seen from the 70+ years of research done on Freund’s adjuvants. (ie. abscesses, chronic inflammation, metabolic damage, mineral oil migration causing tumors on internal organs). Wild horses on public lands are a national treasure protected under the 1971 Act. Using products that act as chemical spays, cause chronic pain/inflammation, harms herd stability, and risks genetic bottlenecks, violates the protective intent of the Wild Free Roaming Horses and Burros Act. Taxpayers deserve better transparency, oversight, and accountability. I request expedited FDA CVM review, full safety/efficacy/genetic/welfare evaluations, and any actions needed to protect target animals and public health, particularly the lack of publicly available long-term research on reversibility, welfare impacts, and over all herd health.

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