Tag Archives: EPA

Tougher Than Tom’s Mosquito TNT review

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I tested the Mosquito TNT in my Pennsylvania yard and have concluded that they do not control mosquitoes. Moreover, they kill a considerable number of non-target organisms, including pollinators, and provide a habitat for developing flies that feed on the decaying carcasses of previous victims. My full review is below. I include instructions for reporting the product to federal and state regulators, plus tips on how to get your money back if the company refuses to honor its refund policy.

Marketing claims

The company says the four-trap kit ($39.99 plus tax) will make a 1-acre yard “mosquito-free” for 30 days. At the end of this period you dump out the contents and add fresh bait (sold separately for $19.99).

Marketing materials assert that female mosquitoes are attracted to the containers because they emit carbon dioxide, which is produced by two pairs of “inert” (i.e., not inert) ingredients (yeast and D-glucose; sodium bicarbonate and citric acid). The active ingredient, sodium lauryl sulfate is said to make them drown faster.

Note that in reality the device would not be able to produce enough CO2 to attract mosquitoes, and certainly not for 30 days. And the active ingredient, sodium lauryl sulfate, is not listed anywhere in the primary literature as a chemical that can kill adult mosquitoes.

My test results

I took photographs of the four traps every several days as a way to record what types of insects were being killed. By far the most common were flies (fruit flies, blow flies, picture-winged flies, etc.), wasps (yellowjackets and hornets), earwigs, and beetles. Initially they were attracted by the sugar and yeast, but eventually the rotting carcasses attracted species that feed on decaying organic matter. Some of these latter individuals laid eggs, resulting in rather large white larvae moving around in the fluid. After about 20 days the stench was enough to make me gag whenever I got close. At no point during my inspections did I notice a single mosquito.

Below are photographs of the other three Mosquito TNTs. Like the trap above, these did not kill any mosquitoes. One had trapped two bumblebees. Although these seemed to attract fewer insects, all contained living fly larvae.

Containers are filled with larvae

I think the larvae moving around in the fluid might be some sort of shore fly (Ephydridae), in part because they have very prominent posterior respiratory siphons that are characteristic of the family.

I wasn’t able to rear any of the above to adulthood but did succeed for a different species, below, which I’ve tentatively identified as Coboldia fuscipes, a type of minute scavenger fly (Scatopsidae).

Ads are misleading

Many of Tougher Than Tom’s ads assert that the dead insects inside the traps are mosquitoes, even though the insects appear to be fruit flies, bottle flies, and wasps. I.e., the company uses gaslighting to convince people that traps work even though it is very apparent they do not.

Another tactic is to show images that have been Photoshopped to falsely convey high efficacy. For example, the image below has mosquitoes that were copied from a photograph taken in Germany by Steffen Kugler. It’s unclear whether Tougher Than Tom has legally licensed that photograph.

Photoshopped illustration copyright Zachary Snyder Collins of Tougher Than Tom (from Amazon listing).

Tougher Than Tom also uses “user-generated content” (UGC) to push the Mosquito TNT on TikTok, Instagram, and YouTube. Users seem to be following a script that frequently includes how safe the ingredients are, how yards become “mosquito-free,” and how traps eliminate worries over mosquito-borne diseases (all claims that violate FIFRA). None shows mosquitoes inside the Mosquito TNT. The UGCs rarely disclose a financial relationship with the company even though that is required by the FTC.

How to get a refund

Tougher Than Tom has generous return language (“100% guaranteed,” “hassle-free refunds,” “If Tom’s products don’t work for you, you get your money back!“) but tends to ignore refund requests. For those who persist, company then insists that traps need to be mailed to Texas at customer’s expense. To get around these tactics, I highly recommend posting a review on Trustpilot. The company seems to monitor this site and will usually try to appease consumers in an effort to maintain a good standing on the review site. You can also leave reviews at the Better Business Bureau and PissedConsumer.

If that doesn’t work, file a complaint with the Attorney General in your state. You can do this by conducting an internet search for “file complaint with attorney general [your state]” and then submitting a short form. The office will then contact Tougher Than Tom on your behalf, using legal language that may get the company’s attention. It’s easy.

How to file a state or federal complaint

If you’d like to help protect other consumers, you can report the company for making false or misleading claims.

To locate the person in charge of pesticide registration and enforcement in your state, click on this map. These people have the power to revisit a product’s registration status as well as levy fines against the company for shipping to the state without a registration. In your email, provide details of what your traps have captured and attach photographs if possible.

You can also report the company to the EPA and the FTC. For these communications it is also helpful to attach screenshots of the marketing materials that led you to believe that the product eliminated mosquitoes. And if you noticed zero mosquitoes inside your traps, mention that, too.

Here’s the company contact information to share in your report:

Tougher Than Tom
2028 E Ben White Blvd, Suite 240-1328, Austin, TX 78741
(413) 400-0067
owner: Zachary Snyder Collins
zach@simplystrive.com

Further information

  • The Mosquito TNT is a 69-cent wasp trap made in China.
  • I highly recommend reading the consent agreement (PDF) between the company and the EPA. The company had to pay $80,880 in fines for violating federal pesticide laws.
  • The owner of Simply Strive (“Tougher Than Tom”) is Zachary Snyder Collins (photo). He likely got into the mosquito-control business from fellow Austin resident Nick Olnyk, founder of Grandpa Gus, a company that had an identical product lineup before being sold a few years ago. I think Collins copied the “folksy, honest grandpa” marketing schtick from Grandpa Gus.

Where can the Mosquito TNT be sold?

From searching databases and regulations, I think the following states allow the product to be sold: Alaska, Arizona, Arkansas, California, Colorado, Delaware, Florida, Georgia, Hawaii, Idaho, Iowa, Kansas, Kentucky, Michigan, Mississippi, Montana, New Hampshire, New Jersey, New York, North Carolina, North Dakota, Pennsylvania, South Dakota, Texas, Vermont, Virginia, Wisconsin, and D.C.

The search revealed that the following states do not allow sales: Alabama, Connecticut, Illinois, Indiana, Louisiana, Maine, Maryland, Massachusetts, Minnesota, Missouri, Nebraska, Nevada, New Mexico, North Carolina, Ohio, Oklahoma, Oregon, Rhode Island, South Carolina, Tennessee, Washington, West Virginia, and Wyoming.

However, Tougher Than Tom’s website indicates that sales are prohibited only in New Mexico and Tennessee. And the company’s Amazon listing says product cannot be shipped to Oklahoma, North Carolina (which allows sales, actually), and Maine. That these two sources list different states suggests that the company is not paying close attention to where the device may legally be shipped. The company is probably regularly shipping the product to states that have denied a registration. E.g., per a review that Tougher Than Tom features on its website, it has shipped the device to Minnesota (jpg screenshot).

Other reviews

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If you have a question, information you think I should provide, or find errors, send me an email.

Snippet of a letter from Spartan Mosquito's Chris Spence to EPA Administrator Scott Pruitt

Spartan Mosquito’s letter to the EPA asking for a testing waiver

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In a prior post I detailed Spartan Mosquito’s secret efforts to secure an EPA registration for the Spartan Mosquito Pro Tech, a plastic tube filled with sugar, yeast, boric acid, and water that the company claims, “kills mosquitoes.” Below is an early part of that successful campaign, a letter sent by Spartan Mosquito’s Chris Spence (CFO/CEO) to EPA’s then-administrator, Scott Pruitt, in April of 2018. In it, the company asks to bypass the normal pesticide-approval process. In particular, it didn’t want to have to prove that the pesticide killed mosquitoes. I obtained the letter through a FOIA request.

Letter from Chris Spence of Spartan Mosquito to Scott Pruitt of the EPA asking for a waiver from pesticide testing requirements. Page 1 of 2.
Letter from Chris Spence of Spartan Mosquito to Scott Pruitt of the EPA asking for a waiver from pesticide testing requirements. Page 2 of 2.

Notes and additional files

Given the style of writing and word choice, I’m 99% sure the letter was written by Spartan Mosquito’s Jeremy Hirsch, one of the company’s cofounders and current chairman of the board.

I have asked the EPA for Mr. Trump’s letter (“Exhibit A”) but they have refused to give it to me.

Here is “Exhibit B” referenced in the letter. It’s a graphic that shows the boric acid concentration of the Spartan Mosquito Pro Tech relative to other objects such as Silly Putty.

Here is “Exhibit C” referenced in the letter. It’s a collection of facts pulled from papers on toxicity of boric acid to mosquitoes. NB: the toxicity of boric acid to insects is well known, but Spartan Mosquito likes to focus on the ingredient to distract from the real issue of whether mosquitoes would go inside the tubes and drink the fluid that has the boric acid. Research (by me) shows that mosquitoes do not.

Mr. Spence sent a similar letter to Senator Cindy Hyde-Smith, who sits on several important committees that regularly touch on the EPA. The ask in that letter, dated April 24, 2018, was for Hyde-Smith to get Pruitt to agree to a meeting. Spartan Mosquito employees gave at least $8,100 to her 24 hours later, on April 25, 2018.

Mr. Spence left Spartan Mosquito in November of 2023 and deleted all references to his affiliation with the company from his LinkedIn profile after three years as CEO. I don’t think people normally erase their CEO positions. Journalists should definitely give him a ring.

If you’d like to see the data that Spartan Mosquito eventually submitted to the EPA on July 29, 2019, see this page. In particular, look at the file named “Spartan Mosquito Eradicator Pro Tech EPA Reg. No. 93813-R Field Efficacy Evaluation Against Mosquitoes” (PDF). In this document, Spartan Mosquito summarizes four “experiments” conducted at various locations in Mississippi by Jeremy Hirsch, Chris Bonner, or Michael Bonner.

To the best of my knowledge, California is the only state to request the efficacy data for the Spartan Mosquito Pro Tech from the company. After reviewing the files the state banned all sales of the pesticide product.

Spartan Mosquito says it is has had meetings with multiple countries interested in hosting production facilities for the tubes. It is testing the tubes in Togo and plans to sell in areas with high rates of malaria.

Further evidence of the special consideration the EPA granted Spartan Mosquito is the letter below, sent by Jeremy Hirsch (Spartan Mosquito’s founder and chairman) to Andrew Wheeler (EPA Administrator) on 11 November 2020, almost eight months after the Spartan Mosquito Pro Tech obtained a registration:

The letter references a meeting Mr. Hirsch had with with EPA staff, likely including Susan Bodine (then Assistant Administrator of EPA’s Office of Enforcement and Compliance Assurance) and Alexandra Dunn (then Assistant Administrator for EPA’s Office of Chemical Safety and Pollution Prevention). The obsequious tone of the letter suggests that Spartan Mosquito had been in trouble for some reason. Because the EPA still allows sales of the Spartan Mosquito Pro Tech I assume the meeting diffused whatever concerns the EPA had uncovered. I obtained the letter via a FOIA request. The EPA will not give me any information on what the problem was.

That said, I do know that the pesticide-approval staff at the EPA met in September of 2020 to discuss the Spartan Mosquito Pro Tech after I shared my concerns about the quality and trustworthiness of the data. Erik Kraft (Branch Chief, Regulatory Management and Science Branch) sent an email to me after the meeting: “I’ve discussed your email about the performance of the product with my senior staff and we’ve determined to not take any further action…” It could be the case that the letter from Mr. Hirsch, above, is related somehow to the concerns that I shared. All of my concerns are listed in my review and in my analysis of the Spartan Mosquito’s efficacy tests. In summary, I am sure that Spartan Mosquito misled the EPA. And I’m pretty sure that the EPA now knows it was misled.

The other explanation for the meeting might have been that the EPA became concerned about the claims the company was making about efficacy on its website and Facebook page. Although “kills mosquitoes” was permitted, the EPA eventually asked, in February of 2021, for the addition of qualifying language to the label: “Product has not demonstrated complete kill of mosquito populations.” I don’t know what prompted that letter, but the meeting in November of the previous year could have been related. Spartan Mosquito has not made the requested change.

Why is the Spartan Mosquito Pro Tech still on the market?

The EPA can issue a “stop sale” order on a registered pesticide if it learns that the pesticide violates any provision of FIFRA (i.e., is “misbranded”). Here’s EPA’s language: “As defined in FIFRA Section 2(q)(1)(A) a pesticide is misbranded if its labeling bears any statement, design or graphic representation which is false or misleading.” Accordingly, the EPA could simply say, “the label falsely claims that mosquitoes gather around the tubes.” Similarly, the company’s patent highlights the role of CO2 in attracting mosquitoes, so listing the yeast and sugar as “inactive” ingredients is deceptive. Finally, the EPA could object to the “kills mosquitoes” claim because the tubes clearly do not kill mosquitoes (because they don’t attract them in the first place). In regard to the latter, the EPA might act on the misleading data the company submitted. I’m assuming somebody powerful is holding the EPA back from issuing a stop-sale order, or that the EPA is embarrassed to admit it erred in granting a registration (probably more likely). Only media exposure will change this strategy.

For more information, please see my 14 other posts on Spartan Mosquito.