Bulletin #635
July 27, 2006
I am deeply concerned about a new fluoride-based pesticide (sulfuryl fluoride) that EPA is allowing to be sprayed on all processed foods and a broad assortment of raw food. While EPA’s decision may benefit the bottom line of Dow AgroSciences, it does not protect the public health, or the public interest.
The public expects EPA to employ the best science available in its approval of pesticides. However, it is apparent that this did not happen with sulfuryl fluoride. Indeed, the National Academy of Sciences recently concluded that the safety standard used by EPA to approve sulfuryl fluoride is, in fact, not safe at all.
Moreover, as the NAS report makes clear, and as is evident by the growing number of children with dental fluorosis, many Americans are being OVER-exposed to fluoride. There is no safety margin for additional fluoride exposures that will result from sulfuryl fluoride. I am particularly concerned for susceptible subsets of consumers, including children, people with kidney disease, people with excess thirst (e.g. diabetics, athletes, and laborers) and people with nutrient deficiencies.
Finally, as Director of EPA, I would like you to investigate why EPA increased the allowable dosage for infants and children not once, but twice, during its approval process for sulfuryl fluoride. In direct violation of the Food Quality Protection Act, these manipulations have left our children ten times less protected than adults.
For these, and the many other reasons detailed in the petition to EPA, I urge you to revoke all food-based uses of sulfuryl fluoride.
Please add my comments to the docket #: EPA-HQ-OPP-2005-0174 and EPA-HQ-OPP-2003-0373.
AL - 7
AR - 21
AZ - 46
CO - 54
CT - 17
DC - 1
DE - 1
FL - 123
GA - 56
HI - 25
IA - 21
ID - 13
IL - 32
IN - 14
KS - 23
KY - 10
LA - 3
MA - 46
MD - 18
ME - 7
MI - 40
MN - 34
MO - 30
MS - 2
MT - 12
NC - 36
ND - 2
NE - 5
NH - 23
NJ - 63
NM - 9
NV - 12
NY - 92
OH - 40
OK - 14
OR - 80
PA - 52
RI - 3
SC - 12
SD - 4
TN - 15
TX - 89
UT - 41
VA - 24
VT - 17
WA - 106
WI - 38
WV - 10
WY - 3
Guam - 1
Other countries
CANADA
Alberta - 4
British Columbia - 4
Manitoba - 2
Nova Scotia - 3
Ontario - 22
Quebec - 7
Australia - 18
France - 1
India - 1
Malaysia - 1
New Zealand - 5
UK - 15
I would like to encourage both citizens and scientists to attend the Second
Citizens’ Conference on Fluoride to be held in Canton, NY, from July 28 -
August 1, 2006.
The decision to fluoridate is one that ultimately only the people in the
jurisdiction can make. There is an old Roman adage - “whatever affects all
should be decided by all.” Instead, in many instances the decision is taken
from the people and made by administrators or city councils saturated with
one-sided arguments and what has become a rigid scientific ideology by the
U.S. Public Health Service.
On any public health issue, we have to keep the doors open to what Alfred
North Whitehead once called “options for revision.” Foreclosing such options
leads to little continuing scientific reaserch. The U.S. Public Health
Service closed its mind over 50 years ago. Nonetheless, more scientists are
Tooth decay is not contagious. Even the advocates of fluoridation have
declared the substance relevant only to youngsters. So why is the entire
drinking water supply fluoridated for the entire population with its
variable risks and its variable doses and its variable intakes and the often
ignored question of the total fluoride intake from all sources in a
particular community? Why is ingestion for all preferable to topical
applications for the few?
Attendance of scientists from the Environmental Protection Agency (EPA) and
three of the National Research Council’s panel members, among others, makes
fluoridation and osteosarcoma this past May provide contemporary material
for opening the public debate further and deeper.
The scientific method should reject the ossified ideology of fluoridation as
an “acquired characteristic” to be intoned. It should be an entrenched
proposition to be examined. May this conference do so with the open mind
that is the essence of the scientific attitude and the underlying principles
Signed







