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,
| DATE | ABOUT | TITLE | |
Note: The TSCA law suit submissions are in this new location |
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| February 4, 2019 | Submission in support of a surveillance system that collects the fluoridation status of the nation’s approximately 52,000 community water systems (CWS) which serve the 50 states and the District of Columbia. It also collects fluoride level testing data for those CWS which adjust naturally occurring fluoride levels. CDC request for public comment was in a Notice of the Dec 6, 2018, Federal Register. |
Comment on CDC’s Proposed Data Collection Submitted for Public Comment and Recommendations Docket No. CDC–2018–0108 |
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| October 12, 2018 | Submission to CDC’s request in the Federal Register for guidance to achieve optimal fluoride concentrations. |
Docket No. CDC-2018-0064 |
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| November 20, 2018 | Response to the American Water Works Association | Comments on the AAWA’s draft report, Sodium Fluoride, September 2017
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| 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
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| 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 |
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| Jan 8, 2016 |
Fluoride’s carcinogenicity |
APPENDICES attached to submission: 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. |
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| Jan 8, 2016 |
Comparative sensitivity to fluoride: rodents vs humans
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National Toxicology Program | Submission on the sensitivity to fluoride: rodents vs humans. Connett & Neurath. |
| Nov 30, 2015 |
Developmental
neurotoxicity and
Endocrine
disruption
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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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