Contrary to the assertions of George Van Dyke Tiers, the EPA Office of Pesticide Programs was justified in accepting the objections submitted by the Fluoride Action Network (FAN) and others on the use by Dow AgroSciences of sulfuryl fluoride (ProFume) as a post-harvest food fumigant (C&EN, Feb. 28, page 5).
Any independent review of FAN’s objections on this matter, submitted over a period of 8 years, will indicate that they were science-based and well documented – see Objectors’ Consolidated Objections at www.fluoridealert.org/pesticides/sf.nov.2006.submission.pdf
The problem for Dow is that American children are already being overexposed to fluoride from other sources (especially fluoridated water). This has resulted in 41% of 12- to 15-year-olds having some form of dental fluorosis (an indicator of overexposure to fluoride before the permanent teeth have erupted). Thus the notion of allowing further additions of fluoride from another source is totally unacceptable.
Nor is Tiers correct in his assertion that the tolerances (residues allowed in or on a food commodity) for the fluoride ion resulting from the breakdown of sulfuryl fluoride permitted by EPA were negligible. The tolerances for fluoride were exceptionally high. For example, EPA set a fluoride tolerance for wheat flour at 125 ppm. That is certainly not negligible as a simple calculation will show. Three slices of bread (about 75 g wheat) made from wheat flour at 125 ppm fluoride would contain 9 mg of fluoride. For a 25-kg child this would produce a dosage of 0.36 mg/kg, which exceeds the dosage that can cause acute toxicity.
Unfortunately, all the divisions of the EPA are not speaking with the same voice on fluoride’s dangers. While the EPA’s Office of Pesticide Programs was announcing the phase out of the use of sulfuryl fluoride, EPA’s Office of Water was making it clear that it was going to set a new maximum contaminant level goal (MCLG) for fluoride that would protect the water fluoridation program. Consideration of a supposed benefit should not influence what is deemed to be safe enough to protect the whole population from harm.
If the Office of Water were to use an appropriate margin of safety to known health effects, a new MCLG would have to be set below 1 ppm fluoride and thus force an end to the water fluoridation forthwith. If Tiers wants to find some politics operating behind EPA’s decisions, this would be a better place to look.
Director, Fluoride Action Network
Professor Emeritus of Chemistry,
St. Lawrence University, Canton NY?