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Government Reports & FAN Submissions

FAN's compilation of official reports from the US, EU, WHO, UN, Australia, Canada, Ireland, NZ, and the UK. The majority of FAN's submissions to various government agencies over the years are also included.

FAN Submissions & Reports

The following are submissions written by members of FAN’s staff.  Nearly all of the submissions on Sulfuryl Fluoride were written in conjunction with Perry E. Wallace, Counsel for Objectors (FAN, Environmental Working Group and Beyond Pesticides).

• See also, FAN Press Releases

DATE ABOUT TITLE
March 13, 2017 Response to EPA’s decision not to perform a 6-Year-Review of fluoride as required by the National Primary Drinking Water Regulations Comments on the U.S. EPA’s Proposed Rule,  published in the Federal Register on January 11, 2017.

Docket ID No. EPA-HQ-OW-2016-0627
November 22, 2016 Petition to the U.S. EPA to ban fluoridation due to fluoride’s neurotoxicity submitted by the Fluoride Action Network, Food & Water Watch, Organic Consumers Association, American Academy of Environmental Medicine, International Academy of Oral Medicine and Toxicology, Moms Against Fluoridation, and undersigned individuals. Petition under Section 21 of the Toxic Substances Control Act (“TSCA”), 15 U.S.C. § 2620, to EPA Administrator Gina McCarthy.
June 29, 2016 FAN investigation found that Texas regulators failed to notify residents of high fluoride levels in their drinking water Toxic Waters, Broken Laws
May 16, 2016 Petition to remove fluoride supplements from the marketplace Citizen Petition to the U.S. Food and Drug Administration.  Petitioned by the Fluoride Action Network and the International Academy of Oral Medicine and Toxicology
Feb 10, 2016 Lead crisis in drinking water FAN SPECIAL REPORT:
Fluoridation: Worsening the Lead Crisis in Flint, and Beyond
By Michael Connett
Jan 8, 2016

Fluoride’s carcinogenicity

Submission to the National Toxicology Program’s review of fluoride as a carcinogen. Connett & Neurath.

APPENDICES attached to submission:

Appendix 1A. Revisiting the Fluoride-Osteosarcoma connection in the context of Elise Bassin’s findings: Part I. Originally submitted to the NRC on March 2, 2005.

Appendix 1B. Revisiting the Fluoride-Osteosarcoma connection in the context of Elise Bassin’s findings: Part II. Originally submitted to the NRC on March 2, 2005.

Appendix 1C. Submission from FAN to the National Research Council Committee: Toxicologic Risk of Fluoride in Drinking Water; BEST-K-02-05-A. Originally submitted to NRC on March 30, 2005.

Appendix 2. FAN submission to NRC 2006 on cancer [Grandjean 2004]. Originally submitted to NRC on Mary 27, 2004. Submitted to NTP on January 8, 2016.

Appendix 3. Kenya study abstract [Neurath 2005a]. Correlation between the incidence of dental fluorosis and osteosarcoma in provinces of Kenya.

Appendix 4. Kenya study of fluoride and osteosarcoma in Kenya [Neurath 2005b]. Introduction and full study.

Appendix 5. Thiessen submission to California Office of Environmental Health Hazard Assessment, July 2011.

Appendix 6-A. Review of Kim et al. (2011) & Comparison to Bassin et al. (2006).

Appendix 7A. Review of Gelberg 1994, 1995 for NTP.

Appendix 8-A. Review of Blakey/McNally 2014 fluoride-­-­osteosarcoma ecological study Great Britain.

Appendix 9. Comber 2011 Ireland osteosarcoma­-F study review for NTP cancer review.

Appendix 10A. Review of Young 2015 F-­osteosarcoma ecological study.

Appendix 11. Review of Levy 2012 F­-osteosarcoma ecological study USA.
Jan 8, 2016
Comparative sensitivity to fluoride: rodents vs humans
 National Toxicology Program Submission on the sensitivity to fluoride: rodents vs humans. Connett & Neurath.
Nov 30, 2015
Developmental
neurotoxicity and
Endocrine
disruption
 National Toxicology Program Submission on developmental neurotoxicity and endocrine disruption. MIchael Connett.
Nov 6, 2015
Developmental
neurotoxicity and
Endocrine
disruption
 National Toxicology Program FAN’s submission in response to solicitation for comments in the Oct 7, 2015 Federal Register.
Nov 6, 2015 Mosaic Fertilizer LLC Department of Justice (DOJ) and EPA FAN’s response to two Consent Decrees issued by the DOJ and the EPA against the gross pollution of Mosaic Fertilizer LLC’s sites in Florida and Louisiana.
Sept 25, 2015 Environmental Justice EJ Interagency Working Group Environmental Justice and Fluoridation
June 13, 2013 Fluoride European Food Safety Authority (EFSA) Comments on draft Dietary Reference Values
July 30, 2012 Sulfuryl Fluoride
Second Request for Comment on Proposed Order Granting Objections to Tolerances and Denying Request for a Stay
 US EPA Office of Pesticides Comments of Objectors Fluoride Action Network, Environmental Working Group, and Beyond Pesticides on the United States Environmental Protection Agency Proposed Rule to Withdraw Sulfuryl Fluoride Tolerances – (Included is the ADDENDUM of translations of eleven studies from China)
Feb 2012 Cryolite US EPA Office of Pesticides Comments on the U.S. EPA’s
Amended Cryolite Final Work Plan
Registration Review
Sept 2011 Fluoride California EPA’s Cancer Hazard Assessment Branch, OEHHA and
Carcinogenicity
Identification
Committee		 Comments on Evidence on the Carcinogenicity of Fluoride and Its Salts
July 5, 2011 Sulfuryl Fluoride
Proposed Order Granting Objections to Tolerances and Denying Request for a Stay		 US EPA Office of Pesticides Comments on Sulfuryl Fluoride; Proposed Order Granting Objections to Tolerances and Denying Request for a Stay.
July 5, 2011 Cryolite
Registration Review
 US EPA Office of Pesticides Comments on the U.S. EPA’s Registration Review for Cryolite
April 19, 2011 Fluoride Reassessment
Proposal to lower the level of fluoride added to drinking water.		 US EPA Office of Drinking Water Comments on the U.S. EPA’s Report Fluoride: Exposure and Relative Source Contribution Analysis
April 19, 2011 Fluoride Reassessment
Proposal to lower the level of fluoride added to drinking water.		 US EPA Office of Drinking Water Comments on the U.S. EPA’s Report Fluoride: Dose-Response Analysis for Non-Cancer Effects
March 11, 2011 Sulfuryl Fluoride
Response to Dow’s request for an Administrative Hearing
 US EPA, Administrator Lisa Perez Jackson Response to Request of Dow AgroSciences LLC for Administrative Hearing Regarding Proposed Order Granting Objections to Tolerances and Denying Request for Stay
Feb 4, 2011 Fluoride Reassessment
Proposal to lower the level of fluoride added to drinking water.		 US Department of Health and Human Services (HHS) FAN’s Comments to HHS: The Time Has Come to End Fluoridation
Nov 15, 2010 Sulfuryl Fluoride
Re: Objections to Final Rules for Sulfuryl Fluoride
 James J. Jones, Deputy Assistant Administrator, US EPA Third Demand Letter Relative to Objections to Final Rules Establishing Tolerances for Residues of Sulfuryl Fluoride and Fluoride Anion
August 18, 2010 Sulfuryl Fluoride
Re: Objections to Final Rules for Sulfuryl Fluoride		 Steve Owens, Assistant Administrator, US EPA Second Demand Letter Relative to Objections to Final Rules Establishing Tolerances for Residues of Sulfuryl Fluoride and Fluoride Anion
April 21, 2010 Sulfuryl Fluoride
Re: Objections to Final Rules for Sulfuryl Fluoride		 Steve Owens, Assistant Administrator, US EPA Re: Objections to Final Rules Establishing Tolerances for Residues of Sulfuryl Fluoride and Fluoride Anion
May 2009 Fluoride
 California EPA’s Cancer Hazard Assessment Branch, OEHHA and
Carcinogenicity
Identification
Committee		 Evidence supporting prioritizing fluoride for carcinogenicity hazard identification
By Chris Neurath and Paul Connett
March 2009 Fluoridation Scientific Committee on Health and Environmental Risks (SCHER), The European Commission Re: Public Consultation on Fluoridation ‘Working Mandate’
Feb 2009 Sulfuryl Fluoride
Re: Objections to Final Rules for Sulfuryl Fluoride		 Public Information and Records Integrity Branch Information Resources and Services Division 18 IQ Studies Submitted to the Docket.
No. EPA-HQ-OPP-2005-0174-0102
Dec 2008 Fluoridation South Central Strategic Health Authority (SHA), England The Arguments Against the Proposal to Fluoridate Southampton
Dec 2007 Sodium Fluoride US EPA Office of Pesticides Comments on Sodium Fluoride Risk Assessment: EPA-HQ-OPP-2007-0833
Jan 17, 2007 Sulfuryl Fluoride
Re: Legal Standard for Grant of Hearings on Objections
 US EPA Office of Pesticides Memorandum: Legal Standard for Grant of Hearings on Objections under Federal Food, Drug, and Cosmetic Act Section 408
Jan 2007 Sulfuryl Fluoride
California’s proposal to designate it as a toxic air contaminant
 CA Department of Pesticide Regulation Joint submission with Beyond Pesticides: Re: DPR’s proposal to designate sulfuryl fluoride as a toxic air contaminant (TAC).
Nov 2006 Sulfuryl Fluoride
Consolidated Objections
 US EPA Office of Pesticides Objector’s Consolidated Objections to Final Rules Establishing Tolerances for Residues of Sulfuryl Fluoride and Fluoride AnionThis document best summarizes the Objections
June 2006 Sulfuryl Fluoride
Re: Objections to Final Rules for Sulfuryl Fluoride		 US EPA Office of Pesticides Motion of Objectors for Stay of Final Rules Establishing Tolerances for Residues of Sulfuryl Fluoride and Fluoride Anion
Jan 2006 Sulfuryl Fluoride
Request to revoke NY’s  use of ProFume®
 Director, Bureau of Pesticides Management Albany NY Re: NYS Registration of ProFume® (EPA Reg. No. 62719-376). Your letter of November 28, 2005, to Mr. Jim Baxter of Dow AgroSciences
Dec 16, 2005 Sulfuryl Fluoride
Issues for an Evidentiary Hearing
 James J. Jones,
Director, US EPA Office of Pesticides		 Issues for an Evidentiary Hearing Concerning Sulfuryl Fluoride
Tolerances
2003 – 2005 Fluoride toxicology Committee studying the toxicology of fluoride in Water, National Research Council of the National Academies See Submissions
March 23, 2004 Sulfuryl Fluoride
Pesticide Tolerances, Final Rule.		 US EPA Office of Pesticides Objections and Request for Hearing in the matter of: Sulfuryl Fluoride; Pesticide Tolerance. Final Rule.
July 2002 Perfluoroalkyl Sulfonates
Proposed Significant New Use Rule

US EPA Office of Pesticides Perfluoroalkyl Sulfonates. Proposed Significant New Use Rule.
May 2002 Cryolite
Gowan’s petition for new, modified, and proposed tolerances 		 US EPA Office of Pesticides Cryolite: FAN Comments submitted to EPA in May 2002
April 8, 2002 Sulfuryl Fluoride
Temporary Pesticide Tolerances for fluoride on raisins and walnuts		 US EPA Office of Pesticides Sulfuryl Fluoride – FAN’s first Objection & Request for Hearing
March 2002 Sulfuryl Fluoride
Re: Dow’s request for pesticide tolerances on raw & processed foods.		 US EPA Office of Pesticides Sulfuryl Fluoride – FAN’s Comments to EPA, March 18, 2002
September 2001 Sulfuryl Fluoride
Proposed temporary tolerances for raisins and walnuts		 US EPA Office of Pesticides Sulfuryl Fluoride – FAN’s comments submitted to EPA, September 2001
– As part of this submission FAN sent EPA a copy of Jennifer Luke’s PhD thesis, The Effect of Fluoride on the Physiology of the Pineal Gland (1997).

Pesticides: More submissions

Flusilazole: October 6, 2005, Comments submitted to US EPA Office of Pesticides, http://www.fluoridealert.org/uploads/flusilazole.flutriafol.2005.comments.pdf

 

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