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From July 7, 2006                                                                                                        

Public Comments Needed by August 4, 2006: Stop Sulfuryl Fluoride Use
(Beyond Pesticides, July 7, 2006)
Responding to a petition from groups asking EPA to prohibit the use of sulfuryl fluoride in food production, the agency opened a public comment period, announced in the Federal Register (71 FR 38125), on July 5, 2006 for 30 days (ending August 4, 2006). Petitioners assert that the regulations setting fluoride tolerances (thus allowing fluoride residues) for food are seriously flawed. The petitioners say that EPA proceeded superficially, inadequately, and thus in violation of the Federal Food, Drug and Cosmetic Act (FFDCA) and the Administrative Procedure Act (APA), when the agency failed to evaluate, in the thorough and detailed manner required by law, the exposures and risks associated with the establishment of tolerances for pesticide chemical residues of sulfuryl fluoride and fluoride anion. (See additional background, 1, 2.)


On June 1, 2006, Fluoride Action Network, Environmental Working Group, and Beyond Pesticides submitted objections and requests for a hearing on sulfuryl fluoride, asking EPA to cancel (technically the petitions asks for an immediate stay) pesticide tolerances for the chemical which had been promulgated on January 23, 2004 (69 FR 3240), and July 15, 2005 (70 FR 40899). The new public comment period ending August 4, 2006 allows public input on EPA’s recent allowance of high fluoride levels in a variety of foods. The National Research Council's (National Academy of Sciences) report, entitled Fluoride in Drinking Water: A Scientific Review of EPA's Standards, was released on March 22, 2006 with convincing evidence of the dangers associated with fluoride use.

The 2004 change in tolerance was requested by Dow AgroSciences, which is expanding its use of the pesticide sulfuryl fluoride (trade named ProFume) to fumigate food processing facilities and storage areas. This use of fluoride allows the chemical to accumulate in the food and thus in the bodies of consumers, whose systems are already being exposed to the “safe” amount of fluoride through fluoridated drinking water. USDA’s surveillance program for pesticide residues on foods routinely finds samples bought at stores that exceed the EPA tolerances, casting doubt on assurances that the new tolerances continue to maintain levels safe for human health.

The American Dental Association and the Centers for Disease Control maintain that fluoride in one part per million in water can help prevent tooth decay without endangering other parts of the body. However, many scientists, including some at EPA itself, maintain that careful attention has not been paid to the effects of fluoride on the rest of the body. It is unclear how much fluoride people are being exposed to in addition to that which is added to the drinking water, as fluoride is naturally occurring and finds its way into foods processed with fluoridated water, as well as foods exposed to fluoride pesticides.

A senior scientist at the EPA, J. William Hirzy, PhD, notes that women’s bodies filter out fluoride so that a breast-feeding infant gets a minimal amount from the milk. In fact, mother's milk only contains about .01 parts per million of fluoride even if the mother is drinking fluoridated water. However, early childhood overexposure to fluoride results in one in three children in the United States developing dental fluorosis (indicating fluoride poisoning), according to the Center for Disease Control

Scientists called together by the National Academy of Sciences at the request of the EPA found that the EPA maximum contaminant level goal of four parts per million of fluoride over a lifetime, the federal drinking water standard, does not protect people from adverse health effects, including bone fractures, thyroid function losses, possible IQ deficits and possible bone cancer. Furthermore, the NRC said fluorides also might increase the risk of developing Alzheimer's disease, and boys exposed to fluoride in drinking water are five times more likely to develop osteosarcoma , a rare form of bone cancer. Eleven EPA unions, representing over 7000 professionals, are demanding a moratorium on water fluoridation because of its grave risks to children’s health.

Opponents to public fluoride use point out that there is little difference between the fluoride added to water systems and the fluoride that the EPA regulates in its drinking water standards. Public water system fluoridation, hydrofluorosilicic acid (a byproduct of the phosphate fertilizer industry) and fluoride from natural runoff from rocks can all be equally toxic to human health. Paul Connett, PhD, chemistry professor at St. Lawrence University and executive director of the Fluoride Action Network, points out that hydrofluorosilicic acid is actually more toxic because it contains traces of arsenic. Professor Connett maintains that the mass fluoridation of public water is the equivalent of the mass medication of diverse populations and is highly irresponsible.

TAKE ACTION!
It is key that people make themselves heard during the comment period ending August 4, 2006. Tell EPA to grant the petition requesting a stay of the sulfuryl fluoride tolerances, reevaluate the data, and prohibit use in food production.

Make the following points:

Major point (if you make only one).
1. The regulations setting fluoride tolerances (thus allowing fluoride residues) are seriously flawed. EPA issued the tolerances in violation of the Federal Food, Drug and Cosmetic Act (FFDCA) and the Administrative Procedure Act (APA), when the agency failed to evaluate, in the thorough and detailed manner required by law, the exposures and risks associated with the establishment of tolerances for pesticide chemical residues of sulfuryl fluoride and fluoride anion.

Additional points.
2. The health standard (the health standard that EPA used is the maximum contaminant level goal (MCLG)) which EPA used to approve the fluoride tolerances is unsafe and "should be lowered" according to a recent, three-year review by the National Research Council (NRC). According to the NRC, the level of fluoride deemed "safe" by EPA, increases the risk for bone fracture, skeletal fluorosis (an arthritic bone disease), endocrine disruption, and damage to teeth.

3. Many Americans are already exceeding EPA's reference dose for fluoride. There is no safe room for additional exposures. (According to EPA's own data, sulfuryl fluoride will become the second largest daily source of fluoride for most consumers - second only to fluoridated water.)

4. The fluoride tolerances approved by EPA are the highest fluoride tolerances ever approved in the nation's history. Most egregiously, EPA has allowed up to 900 ppm fluoride in dried eggs a level very close to the amount used in toothpaste which FDA considers toxic if swallowed in more than pea-sized portions. While FDA mandates a poison control warning on all fluoride toothpastes sold in the US, dried eggs will come with no such warning.

5. EPA's fluoride tolerances violate the Food Quality Protection Act by failing to protect children from adverse health effects. In contrast to virtually all other pesticide regulations, EPA has set a "safe" dose for children up to ten times higher than the dose for adults. As a result, children may receive doses of fluoride that EPA concedes may cause severe dental fluorosis - staining, chipping, and decay of teeth.

6. The National Research Council has identified a range of serious health effects that may be caused, or exacerbated, by fluoride exposure. These effects include endocrine disruption, neurological disorders, damage to the immune and gastrointestinal systems, and cancer. EPA has failed to issue any safety/uncertainty factors to take these concerns into account - in violation of its mandate under the Federal Food Drug and Cosmetic Act.

7. EPA made virtually no attempt to consider and protect large subsets of susceptible populations, including individuals with kidney disease and nutritional deficiencies.

Submit your comments, identified by docket identification (ID) number(s) EPA-HQ-OPP-2005-0174 and/or EPA-HQ-OPP-2003-0373, by one of the following methods:
Electronically: Federal eRulemaking Portal (http://www.regulations.gov) Follow the on-line instructions for submitting comments.
Mail: Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P), Environmental Protection Agency, 1200 Pennsylvania Ave., NW., Washington, DC 20460-0001.

Docket Facility telephone number is (703) 305-5805. EPA's policy is that all comments received will be included in the docket without change and may be made available on-line at http://www.regulations.gov.