FAN Bulletin 1080: URGENT: Help fight more DOW-EPA fraud
July 10, 2009,
We need your help before midnight tonight, if we are to prevent more fluoride exposure to our population and more fraud at the EPA.
Many of us had hoped (and believed) that when Obama took office he would restore scientific integrity to the regulatory agencies. In particular, we had hoped that he would rescue the EPA pesticide division from the stranglehold influence of the chemical industry. One way that this could have been demonstrated would have been to have put a hold on Dow AgroSciences use of the fumigant sulfuryl fluoride on foodstuffs in warehouses and processing plants. Such use leaves very high levels of fluoride on many foods, at a time when it is clear that the US population is already being grossly over-exposed to fluoride. Even the CDC admits that over 30% of American kids have dental fluorosis, which is scientific evidence of over-exposure to fluoride (CDC, 2005).
For over 5 years FAN has been intervening in EPA's permitting process and has clearly demonstrated the fraudulent manipulation of the data contained in the health risk assessments performed by EPA in this process. The health risk assessment was redone twice by the EPA in an attempt to get around the fact that FAN had shown that infants were already exceeding the safe reference dose (dosage) of 0.114 mg per kg bodyweight per day, and thus no new source should be permitted. Rather than acknowledging this, the EPA TWICE raised the reference dose for infants. First, to 0.561 mg/kg/day and then to 1.14 mg/kg/day. The latest safe reference dose for infants is now TEN times higher than the safe reference dose for adults. Such a contention not only defies common sense and basic toxicological principles but also the mandates of the Food Quality and Protection Act (FQPA), which requires that an extra safety factor be applied to protect infants and young children from pesticide residues in risk assessments because of their known extra sensitivity to toxic substances during early development. Thus, if anything the reference dose should have been set lower for infants than adults, not TEN times higher!
Ironically, even the reference dose for adults (0.114 mg/kg/day) is in doubt because it's based upon the EPA's safe drinking water standard of 4 ppm which the National Research Council panel has stated is not protective of health (NRC 20060.
The EPA has simply refused to explain these horrendous manipulations. Instead, they offered to participate in a mediation process. But this has simply been a huge delaying tactic. We had naively hoped that they were delaying the process until a more friendly administration was in place. Thus, we were shocked to discover that before the EPA had responded to our critique of their unscientific health risk assessment(s), and our appeal that the use of sulfuryl fluoride be halted pending such an explanation, that the EPA is now considering allowing Dow AgroSciences to extend the use of sulfuryl fluoride as a pre-plant soil fumigant!
How you can help fight this
Fortunately, the Sierra Club has intervened on this expanded use of sulfuryl fluoride because of the fact that sulfuryl fluoride is a very potent Greenhouse gas, contributing to Global warming. They have set up the machinery for people to send in comments to the EPA on this. We request that you piggy back on this machinery and add a comment to the effect:
"Not only am I concerned about sulfuyrl fluoride's global warming potential but I am also very concerned that the EPA is considering expanding the use of this highly toxic fumigant before it has addressed the charges raised by the Fluoride Action Network that the health risk assessments that they performed for Dow were outrageously manipulated to yield a safe reference dose for infants (1.14 mg/kg/day) which is TEN times higher than the reference dose for adults (0.114 mg/kg/day). Such a manipulation defies common sense and basic toxicological principles but also the mandates of the Food Quality and Protection Act (FQPA), which requires that an extra safety factor be applied to protect infants and young children from pesticides because of their known extra sensitivity to toxic substances during early development.
I thought with he election of President Obama we were going to get more scientific integrity at the EPA, instead we are getting more poison for our kids! They are already being over-exposed to fluoride - they don't need any more. Don't let this travesty happen."