by Michael Connett

Research for this article provided by Shelley Nelkens of Antrim, NH.

Ninety percent of the fluoride we use to fluoridate U.S. water systems comes directly from the pollution scrubbing systems of the phosphate fertilizer industry. Recently, there has been some concern among clean water activists about the purity of this industrial grade fluoride, known as hydrofluosilicic acid. As investigative journalist George Glasser has pointed out, this hydrofluosilicic acid contains trace amounts of numerous heavy metals such as lead, mercury, and arsenic.

Proponents of fluoridation, however, claim that while heavy metals are found in the acid, they are at such low levels as to be of no concern. As Thomas Reeves of the Centers for Disease Control and Prevention recently stated, “the point I’m trying to make is it’s really not a problem” (Wenatchee World, October 20, 2000).

After a quick look at the numbers, Reeves would seem to be right. After all, the hydrofluosilicic acid is diluted down approximately 240,000 times when added into the public’s drinking water. If, therefore, these heavy metals are in concentrations of parts per million in the undiluted fluorosilicic acid, they will be much lower after being diluted down 240,000 to 1.

However, while this argument sounds legitimate, a careful look at the numbers reveals a different picture.

Take for instance, arsenic.

In a recent letter (July 7, 2000) to Congress, NSF International (National Sanitation Foundation) submitted the results of tests it has conducted on hydrofluosilicic acid over the past few years. According to the NSF, the most common contaminant found was arsenic. (Arsenic was found about 5 times more frequently than any other contaminant and at considerably higher levels).

While not all hydrofluosilicic acid was found to contain arsenic, the NSF states that where found, the average level of arsenic in the acid would lead to arsenic levels in water, after dilution, of 0.43 parts per billion (ppb). (When the "non-detects" are factored in, the average arsenic level would be 0.1 ppb; see http://www.fluoridealert.org/NSF-letter.pdf ). The maximum levels of arsenic found by the NSF would result in arsenic levels in water of 1.66 parts per billion.

Putting the numbers into Perspective

To the ordinary person, these numbers may seem small and insignificant, which is exactly what the NSF and the CDC’s Thomas Reeves claim. However, in examining their arguments, one finds that the NSF and Reeves are basing their reasoning on the fact that 0.43 parts per billion arsenic falls below the EPA’s Maximum Contaminant Level (MCL). In other words, they are looking to the letter of the law, and the letter of the law says having this much arsenic in water is ok.

But the letter of the law on arsenic is currently under serious challenge.

According to a 1999 review done by the National Academy of Sciences, “it is the subcommittee’s consensus that the current EPA MCL for arsenic in drinking water of 50 µg/L (50 parts per billion) does not achieve EPA’s goal for public-health protection and, therefore, requires downward revision as promptly as possible.”

The Natural Resources Defense Council (NRDC) states that the EPA’s current Maximum Contaminant Level for arsenic, “is grossly inadequate for protecting public health.” The NRDC points out that the EPA’s Maximum Contaminant Level was set in 1942, “before arsenic was known to cause cancer.” Arsenic, which has since been classified as a Class 1 human carcinogen, is now known to cause cancer of the skin, and cancer of the internal organs, particularly the lung and bladder.

In light of the growing accumulation of scientific literature on arsenic, the NRDC is currently calling on the EPA to set a new Maximum Contaminant Level for arsenic at 3 parts per billion. However, the NRDC argues that even 3 parts per billion is not a satisfactory level. For as they state, “Based on an extrapolation of NAS's risk estimates, even a relatively strict arsenic standard of 3 ppb could pose a fatal cancer risk several times higher than EPA has traditionally accepted in drinking water.”

In fact, based on risk estimates from the National Academy of Sciences, just 0.5 parts per billion arsenic in water “presents the highest cancer risk EPA traditionally allows in tap water” (see chart 1 below) (NRDC, 2000). Using NAS data, and assuming a linear dose response, the NRDC estimates that drinking water containing 0.5 parts per billion presents the public with a 1 in 10,000 risk of developing cancer.

Recent epidemiological work from Finland (Kurttio, et. al, 1999) found that people drinking water with 0.1 to 0.5 parts per billion arsenic, had an approximately 50 percent greater risk of getting bladder cancer than people drinking water with arsenic levels less than 0.1 parts per billion (NRDC, 2000). The range 0.1 to 0.5 ppb is the range of arsenic we can expect to add to the water from the use of hydrofluosilicic acid.

In conclusion: What do we know?

* 90% of the fluoride used to fluoridate US water systems comes from the pollution scrubbing devices of the phosphate fertilizer industry. It is industrial grade, not pharmaceutical grade.

* The most common contaminant found with the captured fluoride acid (hydrofluosilicic acid) is arsenic.

* When detected, the average amount of arsenic found in the acid would lead to levels of arsenic in drinking water of 0.43 parts per billion.

* If we include the samples that did not contain arsenic, the average amount of arsenic fluoridation is adding to the water would be 0.1 ppb.

* The level of arsenic in hydrofluosilicic acid varies, reaching levels high enough to produce concentrations of 1.66 parts per billion in water.

* According to risk estimates from the National Academy of Sciences, water containing 0.5 parts per billion arsenic presents a 1 in 10,000 risk of developing cancer.

* A study from Finland (Kurttio, et al, 1999) found that people drinking water with 0.1 to 0.5 parts per billion arsenic had a 50% greater risk of developing bladder cancer than people drinking water with less than 0.1 ppb.

Research for this article provided by Shelley Nelkens, Consultant for NH Pure Water Coalition.

Chart 1: Lifetime Risks of Dying of Cancer from Arsenic in Tap Water
Based upon the National Academy of Sciences' 1999 Risk Estimates*

From the Natural Resource Defense Council's February 2000 Report "Arsenic & Old Laws"

References:

Gilstrap, Kathleen. (2000). Fluoride battle heats up: Vote is non-binding, but that won't make this election any less volatile. Wenatchee World. 20 October 2000.

Kuttrio P, et al. (1999). Arsenic Concentrations in Well Water and Risk of Bladder and Kidney Cancer in Finland. Environ. Health Perspect. 107:705-710.

Natural Resources Defense Council. (2000). Arsenic and Old Laws: A Scientific and Public Health Analysis of Arsenic Occurrence in Drinking Water, Its Health Effects, and EPA's Outdated Arsenic Tap Water Standard. http://www.nrdc.org/water/drinking/arsenic/aolinx.asp

• Executive Summary and Recommendations
• Chapter 1: Arsenic Found at Levels of Concern in the Tap Water of Tens Of Millions of Americans in 25 States
• Chapter 2: An Overview of the Scientific and Health Issues Raised by Arsenic Regulation
• Chapter 3: Conclusions for Safe Regulation of Drinking Water
• Bibliography

Hazan, Stan (2000). Letter to Florida Department of Health from Stan Hazan, General Manager, Drinking Water Additives Certification Program, National Sanitation Foundation International. 24 April 2000. http://www.fluoridealert.org/NSF-Letter.pdf

Hazan, Stan. (2000). Letter to Rep. Ken Calvert from Stan Hazan, General Manager, Drinking Water Additives Certification Program, National Sanitation Foundation International. 7 July 2000. http://www.citizens.org/Food_Water_Safety/Fluoridation/Materials/NSF_response.pdf

A Note about Current Levels of Arsenic in US Water Systems

According to analysis of water conducted in 25 US states, approximately 70% of the tap water tested was found to contain between 0 (non-detectable) to 3 parts per billion arsenic (see http://www.nrdc.org/water/drinking/arsenic/chap1.asp).

ADDENDUM:

According to an article ("Treatment Chemicals Contribute to Arsenic Levels" ) in the October 2000 issue of the Journal of the American Water Works Association ("Opflow"):

"Utilities should review and estimate the maximum possible arsenic concentrations contributed by the chemicals they use in drinking water treatment.  Even trace amounts add up and may contribute to a substantial portion -- possibly up to 10 percent -- of a 3 or 5 [ppb] maximum contaminant level." - (C. Wang, D.B. Smith, G.M. Huntly, "Treatment Chemicals contribute to Arsenic Levels," Opflow (AWWA), October 2000.)

"90 percent of the arsenic that would be contributed by treatment chemicals is attributable to fluoride addition." (C. Wang, D.B. Smith, G.M. Huntly, "Treatment Chemicals contribute to Arsenic Levels," Opflow (AWWA), October 2000.)

The following article was written following the Clinton Administration's January 2001 decision to lower the Maximum Contaminant Level of arsenic in water from 50 parts per billion to 10 parts per billion. The article discusses the implications of a 10 ppb MCL on the US fluoridation program, in particular, on how it would effect the "Maximum Allowable Level" of arsenic that water companies can add to municipal water.

INTERNATIONAL FLUORIDE INFORMATION NETWORK

January 19, 2000

IFIN Bulletin #228: Fluoridation & Arsenic

by Michael Connett

As some of you may have heard, the EPA has just issued its ruling on the new Maximum Contaminant Level (MCL) for arsenic in drinking water. On Wednesday of this week, the EPA ruled that the new MCL for arsenic in drinking water be lowered from 50 parts per billion to 10 parts per billion. (See article below).

The question of concern in this bulletin is how this lowered MCL for arsenic will effect the fluoridation program.

We'll start first with a discussion of the levels of arsenic known to exist in fluoridation chemicals, and then move on to a discussion of the implications of the new arsenic Maximum Contaminant Level.

Arsenic levels in fluoridation chemicals:

Over 90% of the fluoride which is used to fluoridate water is an industrial waste product from the phosphate fertilizer industry. Being an industrial waste product, these fluoridation chemicals (hydrofluosilicic acid & sodium silicofluorides) contain a number of impurities, most notably of which is arsenic.

The body responsible for testing water treatment chemicals for impurities is the National Sanitation Foundation (NSF International). According to a letter from the NSF to Florida's Department of Public Health (4/24/2000), arsenic is the most common contaminant found in fluoridation chemicals, and it is the contaminant found at the highest levels (see letter at http://www.fluoridealert.org/NSF-letter.pdf). When detected, the average arsenic concentration in the chemicals would lead to an addition of 0.43 parts per billion to the water supply. The highest level of arsenic which the NSF has admitted to finding would lead to an addition of arsenic to the water supply of 1.66 parts per billion.

The problem with arsenic contamination of fluoridation chemicals has recently been recognized by the American Water Works Association. According to the October 2000 issue of the AWWA's Journal, "about 90 percent of the arsenic...contributed by treatment chemicals is attributable to fluoride addition."

Implications of the new Arsenic MCL:

In the world of water treatment there is a phrase called "Maximum Allowable Level" or MAL. The MAL determines how much of a particular contaminant a water treatment company is allowed to knowingly add to the water supply. The MAL for each contaminant is determined by dividing the EPA's Maximum Contaminant Level by a factor of ten.

(MAL = Maximum Contaminant Level divided by 10)

Thus, if the EPA's Maximum Contaminant Level for arsenic is now 10 parts per billion, than the MAL for arsenic has now become 1 part per billion. With the MAL for arsenic being 1 ppb, no water company can knowingly add more than 1 part per billion arsenic to the water supply.

So how does this new MAL effect the US fluoridation program?

Based upon the NSF's testing data, we can now expect that certain batches of fluoridation chemicals will have arsenic levels that exceed the Maximum Allowable Level of arsenic that a water supplier can add to the water. The NSF admitted as much in its letter to the Florida Department of Health. In its letter, the NSF stated that if the MCL for arsenic was lowered, "future tests of fluoridation chemicals may result in increased product failures." As noted above, the NSF has already found samples of fluosilicic acid which add 1.66 parts per billion of arsenic to the water. These samples will now be what the NSF termed "product failures", i.e., they have too much arsenic in them to add to water.

The question we now need to ask is: can we rely on the NSF and water treatment companies to detect the "product failures" before they are dumped into our water?

The answer: Most likely not.

Since 1992, the NSF has done relatively little testing of fluoridation chemicals. In its letter to the Department of Health, the NSF stated that "the exact number of laboratory tests performed is not readily available, but these products have been tested more than 100 times." More than 100 times, however, is barely adequate when considering the hundreds of thousands of barrels of fluosilicic acid which have been dumped into the water over the past 8 years.

Another question which we need to ask, and which will bring us to the front end of this problem, is: why on earth are we using industrial effluent from the phosphate fertilizer industry as our source of fluoride for fluoridation? Who, other than Cargill Fertilizer and the phosphate fertilizer companies, would find this deal attractive?

Mike Connett
Fluoride Action Network
http://www.fluoridealert.org

p.s. A valuable source of information concerning the health concerns of low level arsenic exposure is the Natural Resources Defense Council's paper "Arsenic & Old Laws", available at: http://www.nrdc.org/water/drinking/arsenic/aolinx.asp

Associated Press

Jan 17, 2001

EPA Orders Sharp Reduction in Arsenic Levels in Drinking Water

By H. Josef Hebert

WASHINGTON (AP) - The Environmental Protection Agency ordered Wednesday that allowable levels of arsenic in drinking water be reduced by 80 percent. The action updating an arsenic standard that has been in effect for nearly 60 years is expected to require about 3,000 communities - generally small water systems - to make changes in treatment of drinking water, the agency said. "This new drinking water standard will provide additional public health protection for 13 million Americans," President Clinton said in a statement. Environmentalists have argued for years that the arsenic standard, established in 1942, of 50 parts per billion should be lowered. Last year, the EPA proposed going to 5 parts per billion as demanded by many environmentalists, but then settled at 10 parts per billion. Efforts to tighten the federal requirement gained momentum after a National Academy of Sciences report in 1999 found arsenic in drinking water causes bladder, lung and skin cancer, and might cause kidney and liver cancer. The EPA also had been sued by a leading environmental group, the Natural Resources Defense Council, which claimed the EPA had been negligent in not moving quickly to lower the standard. "It's a significant accomplishment to have gotten this through with so much opposition over the last several decades," said Erik Olson, an NRDC water quality expert. "It will save many people's lives who would have died from cancer." The mining and chemical industries had opposed the standard because it is expected to be used as the cleanup standard on some toxic waste sites. Water supply agencies also had complained about the cost of making improvements, estimated capital costs alone at about $5 billion. The EPA estimated its new standard will increase the annual water bill $60 or less per household in communities where improved treatment and upgrades are needed. Some financial and technical assistant will be available for small systems needing to make improvements to meet the new standard, the EPA said. All the 54,000 community water systems, serving about 254 million people, will be subject to the new standard. But the EPA said that only about 5 percent, or 3,000 systems serving 13 million people, will have to upgrade their systems to meet the new standard. Most of the systems affected by the standard serve fewer than 10,000 people. The agency said that communities in parts of the Midwest and New England that depend on underground sources for drinking water will be affected most. Water industry representatives had lobbied for a standard of 10 parts per billion as is the standard for the World Health Organization. They said the earlier proposed 5 parts per billion standard would have been extremely costly.

On the Net: EPA: http://www.epa.gov/safewater U.S. Geological Survey map of counties with high arsenic levels: http://co.water.usgs.gov/trace/arsenic AP-ES-01-17-01 1900EST