Fluoride Action Network

FAN Versus DOW

Source: International Fluoride Information Network | March 18th, 2002

Dear All,

I am happy that we met the deadline and got our comments into the US EPA on DOW’s attempt to get sulfuryl fluoride accepted for use on 40 foodstuffs. If DOW is successful they would be adding yet another fluoride source to our diet and thereby further increasing our daily dose of fluoride – and we -and our children -are already getting far too much!

You can find our comments at http://www.fluoridealert.org/pesticides/Sulfuryl.F.Mar.2002comments.htm
Meanwhile, some of our readers and FAN members – at ridiculously short notice -pulled out the stops and also got some excellent letters off to the USEPA in time. Thank you all very much. Four of the letters are printed below.

Paul Connett.

1) From Lynne Campbell, Oregon.

To Whom It May Concern:

OCSDW firmly opposes the use of sulfuryl fluoride as a fumigant on food items.

We respectfully ask that the EPA give appropriate weight to current scientific data showing harm and take seriously its responsibility to protect public health.

Ours is a population whose food chain is now thoroughly contaminated with fluoride. We’re also exposed through industrial air pollution, pharmaceuticals, dental products and treatments, and anesthetics.

Public Health Service data (DDHS Review of Fluoride, 1991) showed that fluoridated populations 11 years ago were getting up to 6.6 times the maximum dose that can be prescribed for a 6-16 year old in a non-fluoridated community. Based on the continual upward trend of the sources and levels of fluoride exposure, current figures would certainly be even higher.

The only national survey of dental fluorosis in US school children (NIDR, 1986-87) showed a dramatic rise in its prevalence, with 29.9 percent in “optimally fluoridated areas” affected on two or more teeth, and an astounding 66.4% affected on one or more teeth.

Dental fluorosis is medically defined as “chronic fluorine poisoning,” and these high percentages are a clear sign of the excessive and uncontrolled fluoride exposure across this country.

What Americans don’t need is another source of this persistent, bioaccumulative toxin in their diet.

DOW is incorrect in saying that fluoride is not an endocrine disrupter and that 16 mg/day is safe.

While we can’t expect DOW to honestly do its homework — after all, its primary interest is in making a profit — we do expect better from you, as a government agency serving your public.

We ask that you research this issue with all due diligence in accordance with your sworn duty to protect our health. We ask that you err, if you must, on the side of caution.

Surely you are aware of your union’s (NTEU 280) opposition to fluoridation based on their review of the scientific and medical literature. Please consult them in this critical matter.

And please keep us posted on further actions and decisions. Thank you.


Lynne Campbell,
Executive Director
Oregon Citizens for Safe Drinking Water

2). From Robert Pocock, Ireland.

Dear Sirs,

I am writing to object to the Pesticides Petition PP IF6312 by DOW AgroSciences LLC.

The information provided by the petitioner is seriously flawed and misleading.

It has serious implications for consumers of the proposed products if they are exposed , as we are in Ireland to excessive amounts of fluoride in the environment and to food sources, including fluoridated drinking water which is mandatory in Irish public water supplies. Therefore any further exposure of Irish consumers to food substances containing sulfuryl fluoride such as proposed by the petitioner is completely unacceptable and would constitute an unacceptable health risk.

There are other serious inaccuracies in the petitioner’s claims about the toxicity of fluoride, in particular the denial that fluoride is an endocrine disruptor, which it most certainly is recognised to be throughout Europe.

For these and other reasons we will alert the regulatory authorities in both Ireland and the European Union to our objections to the said Pesticides Petition PF -1068 and the risk which it poses to health of citizens both in Ireland and throughout the European Union.

Robert Pocock
Fluoride Campaigner for
VOICE of Irish Concern for the Environment

3) From Dr. Albert Burgstahler, Kansas.

To US EPA Regulators:

The proposed fluoride tolerance for residues in various grains, nuts, and dried food commodities fumigated with sulfuryl fluoride are in the range of what research on coal burning fluorosis has shown to be seriously toxic, producing not only moderate to severe dental fluorosis from early childhood exposure but also crippling skeletal fluorosis in adults (D. Li et al., Fluoride 1999;32:55-59 plus other earlier references). From the ranges proposed for various common food grains and flour (5-40 ppm and more) it is difficult to see how daily fluoride (F) intakes of only 0.002419 mg/kg/bwt/day for a child aged 1-6 years eating generous amounts of such foods could be arrived at. In the report just cited, F levels in chaff rice from fluoride-polluted coal burning were in the 15 mg/kg range and, together with other F-polluted sources, produced mean total F intakes exceeding 10 mg/person/day where “severe fluorosis was epidemic.”

A daily total fluoride intake from foods containing an average of 20-30 mg/kg will easily reach 10 mg/day, which, for a 70-kg adult is 0.14 mg F/kg/bwt/day–enough to cause osteofluorosis in time. For a 15-kg child eating food with 20-30 mg F/kg, the F intake/kg/bwt/day would be in the same range. Clearly, if the proposed fluoride tolerance levels are reached from sulfuryl fumigation of common commodities, serious fluoride intoxication can be expected. Are people not expected to consume these foods?

Unfortunately, data compilations on chronic fluoride intoxication have generally relied on limited sources of information that have often omitted reference to reports such as that cited above, partly for the reason that they have been excluded from coverage in Index Medicus and PubMed for reasons that cannot be justified scientifically.

Albert W. Burgstahler, Ph.D. (Harvard, 1953)
Editor, Fluoride
(Professor Emeritus of Chemistry,
The University of Kansas,
Lawrence, KS 66045)

4) Tom Owen, California.

Dear Sir or Madam:

I am a 51 year old male, having been over-exposed to fluoride in bottled drinking water. For several years, I drank water with fluoride added (as did the rest of our family). At one point, my thyroid stopped functioning properly, and my TSH levels were 4-5 times normal. There was a direct correlation between the consumption of this fluoridated water (courtesy of Arrowhead) and it’s thyroid-inhibiting nature. This can all be corroborated with my medical records.

In any event, I can attest, first-hand, to a severe medical problem called hypothyroidism that can result from ingesting flouride compounds. Evidently, there are other medical conditions that have also been documented from over-exposure to fluoride intake.

Therefore, I would like to ask the EPA why the review panels comprised of scientists and other professionals would continue to allow the unabated dumping and spraying of fluoride compounds into our precious waters and foods? If DOW is allowed to manufacture the fumigant sulfuryl fluoride, and this ultimately ends up on the food we eat, I am absolutely convinced that there will eventually be an epidemic of fluoride poisoning in this country.

It may only start with walnuts and raisins, which is simply reckless fumigation. However, to consider other foods like nuts and grains (and the tolerance in ppm for fluoride – wheat germ at 98 ppm?) is incredibly irresponsible.

It’s time for the EPA to recognize a series of other independent studies on the impact of fluoride ingestion before they allow DOW and other companies to slowly poison us. Please, please do not allow this to happen, for the sake of the citizens’ health in this country.

Thank you for listening.

Tom Owen
10723 Foxwood Road
San Diego, CA 92126