Fluoride Action Network

The Toxic Release Inventory for Fluorides

The U.S. Environmental Protection Agency manages the "Toxic Release Inventory" (commonly known as TRI) which was created to provide the public with information about releases of toxic chemicals in their community. It is an essential tool for finding information on chemicals by city, zip code, state, and year. TRI tracks Hydrogen Fluoride, Sulfuryl Fluoride, Fluorine, and other fluoride compounds.

The Fate of Industry’s Fluoride Emissions

In 1986, the U.S. Congress passed the Emergency Planning and Community Right-to-Know Act to provide the public with information about releases of toxic chemicals in their community. Section 313 of this Act created the Toxic Release Inventory which is managed by the Environmental Protection Agency (EPA). The law grew out of concern surrounding Union Carbide’s releases of toxic gases in the December 4, 1984, Bhopal disaster in India where thousands of people died in what is considered to be the worst industrial disaster in history.

It’s important for those working on the fluoridation of drinking water to know about all the sources of fluoride that a targeted community is exposed to. And it’s equally important for communities that began fluoridation decades ago to update their knowledge of these exposures. Unfortunately, Public Health officials across the U.S. actively promote fluoridation without knowledge or interest in this information.

Why should we be interested in background exposures?

  • Fluoride was labeled an endocrine disruptor in 20061 (p 266)
  • Fluoride was labeled a developmental neurotoxicant in 20142
  • 76 studies report an association of decreased IQ in children with moderate exposure to fluoride3
  • American children are overexposed to fluoride41% of Americans age 12-15 had dental fluorosis as reported in 2010
  • Federal statistics reveal dental fluorosis rates have risen since 2010 and now range from 41% to 58%.
  • Fluoride bioaccumulates in the body, mainly in the bone.
  • Fluoride has a significantly long half-life in the human bone estimated at twenty years1 (p 92). A half-life is the time required to decrease a substance by half.

Commonly known exposures to fluoride are:

  • Fluoridated public drinking water
  • Infant formula made with fluoridated water
  • Toothpaste with fluoride, especially for children under five years of age
  • Food grown with the pesticide Cryolite4
  • Fumigation of processed food, warehoused food, and grains with Sulfuryl fluoride4
  • Drinking water with high levels of naturally occurring fluoride5,6

Another source of exposure to fluoride comes from the millions of pounds of fluoride that are legally released each year across America from industry. And it is the fate of these industrial releases that we need to be concerned about as these releases pollute our bodies, air, water, soil, and wildlife.

The Toxic Release Inventory (TRI) allows one to find information on specific industrial releases by city, zip code, county, state, and year. Canada has something similar7 and FAN will do a breakdown of the Canadian fluoride releases in the future as it’s relevant for the border areas8 of both countries.

The major fluorides covered by TRI are Hydrogen Fluoride, Fluoride, Sulfuryl Fluoride, and the fluorinated ozone-depleting gases – see them here – which release millions of pounds of fluoride each year into our environment..

It’s important to know that not all industries or sources that release fluoride into the environment are included in the TRI9-11. Those working for healthy communities need to find out, and share, the industrial releases that may be impacting their communities. One can ascertain industrial toxic releases not listed on TRI by searching your state’s databases for air or other discharge permits granted in your area.

What happens to the millions of pounds of fluoride emitted annually in the U.S.?

We know from the published literature that grazing animals in areas contaminated by fluoride-emitting industries have been found with severe dental and skeletal fluorosis12.

In 1998 Environment Canada collected fluoride samples in foliage and soil in Cornwall, Ontario, and reported very high levels of fluoride in both8. Cornwall is approximately five miles downwind of two aluminum smelters located in Massena, New York. The Canadian results demonstate that residues of fluoride will deposit in areas surrounding fluoride-emitting industries, especially during times of rain or snow.

A source of exposure for young children is their tendency to put non-food objects into their mouth. Education in areas surrounding fluoride-emitting industries should include the message that children’s toys should not be left outside and that those with vegetable gardens, fruit trees or berry bushes, should wash all produce before eating.

Criteria used by TRI to list toxic substances

According to EPA, TRI tracks the management of certain toxic chemicals that may pose a threat to human health and the environment. U.S. facilities in different industry sectors must report annually how much of each chemical is released to the environment and/or managed through recycling, energy recovery and treatment. (A “release” of a chemical means that it is emitted to the air or water, or placed in some type of land disposal.)

The 2015 Reporting Criteria for companies that must report chemical releases to TRI are:

  • Those in a specific industry sector (chemical, mining, paper, oil, gas, etc.) that produce or handle a specific amount of a listed toxic
  • Employs 10 or more full-time equivalent employees
  • Manufactures, processes, or otherwise uses a TRI-listed chemical in quantities above threshold levels in a given year.
  • Persistent, Bioaccumulative, Toxic chemicals (PBTs) have lower reporting thresholds.
  • Facilities may be eligible to submit a shorter version of a TRI form (Form A) if all three of these criteria are met:
    1. The chemical being reported is NOT a PBT chemical;
    2. The chemical has not been manufactured, processed, or otherwise used in excess of 1,000,000 lbs.; and
    3. The total annual waste management (i.e., recycling, energy recovery, treatment, and disposal or other releases) of the chemical does not exceed 500 lbs.

Hydrogen Fluoride was included since TRI first began in 1988, and in 1995 Sulfuryl Fluoride and Fluorine were added to the list. The first TRI list in 1988 contained 273 substances compared to the 2015 TRI which contains 499. Some sources of toxic releases not included in TRI are municipal waste incinerators, hazardous waste incinerators, other incinerators run by industry or hospitals, and also burn barrels (the burning of household and/or agricultural waste). All these should elicit concern in communities.

Chemicals and substances that TRI lists for inclusion for the following years: 1997, 1998, 1999, 2000, 2001, 2002, 2003, 2004, 2005, 2006, 2007, 2008, 2009, 2010, 2011, 2012, 2013, 2014, 2015

We have introduced the wealth of data that the TRI contains about fluoride with the following:


1.  Fluoride in Drinking Water: A Scientific Review of EPA’s Standards. 2006. National Research Council of the National Academies.

2. Grandjean P, Landrigan PJ. 2014. Neurobehavioural effects of developmental toxicity. The Lancet Neurology 13(3):330-338.

3. Connett M. 2016. The Fluoride IQ Studies, Fluoride Action Network.

4. See the levels of fluoride from pesticides and fumigation that U.S. EPA has approved for foods grown, stored, and processed in the U.S.

5. Levels of naturally occurring fluoride in drinking water in the U.S.

6. The following news report from Maine is a worrying example of the number of people who drink well water and are not aware of the fluoride levels it contains. The August 2014 newspaper article stated: “Tests done on private wells in one-quarter of Maine towns found pockets of dangerously high fluoride levels, particularly in Hancock County… The survey, in which about 25 percent of all Maine towns participated, was reported by Scientific American …”

7. The National Pollutant Release Inventory (NPRI) is Canada’s legislated, publicly accessible inventory of pollutant releases (to air, water and land), disposals and transfers for recycling.

8. See Fluoride levels in Soil & Foliage in Cornwall, Ontario, Canada – 1998

9. The fluoride releases not tracked by TRI.

10. Intel in Hillsboro, Oregon, emitted fluoride from its large manufacturing site since 1978 but never informed the state’s Department of Environmental Quality (DEQ) nor did the DEQ consider to ask -even though software manufacturing is a major source of fluorine entering the environment. See news report in The Oregonian, Intel has been emitting fluoride for years without state knowledge, permit, Sept 13, 2013.

11.  It’s likely that all types of incinerators emit Hydrogen fluoride most, if not all, of the time. The following is an incident that few people could have predicted for HF releases. A January 5, 2016, news report noted the effort to remove chemical weapons from Syria: “The last remaining vestiges of the declared stockpile – some 75 cylinders of highly-corrosive hydrogen fluoride – were destroyed by the US firm Veolia at its treatment plant Port Arthur in Texas, the OPCW said. ‘This completes destruction of all chemical weapons declared by the Syrian Arab Republic,’ the Hague-based OPCW said in a statement issued yesterday.'” Veolia operates a hazardous waste incinerator in Port Arthur. See news article, Syria’s declared chemical arms ‘100% destroyed’: Watchdog, in the Times of India.

12. Skeletal Fluorosis & Brittle Bone in grazing animals exposed to high levels of fluoride. The following is a sampling of some of the published literature on this issue:

The bones are subject to easy fracture.”
SOURCE: Blood DC, Henderson JA, Radostits OM, eds. 1979. Veterinary Medicine: A Textbook of the Diseases of Cattle, Sheep, Pgs and Horses. 5th Edition. Lea & Febiger, Philadelphia.

“The bone was brittle and shattered easily when cut on a bandsaw.”
SOURCE: Krook L, Maylin GA. 1979. Industrial fluoride pollution. Chronic fluoride poisoning in Cornwall Island cattle. Cornell Veterinarian 69(Suppl 8): 1-70.

“fluorotic specimens had a lower tensile strength and strain but a higher compressive strength and strain than the nonfluorotic ones.”
SOURCE: Evans FG, Wood JL. 1976. Mechanical properties and density of bone in a case of severe endemic fluorosis. Acta Orthopaedica Scandinavica 47: 489-495.

“Lameness, pain, exostoses, emaciation, and bone fractures were symptoms associated with horses exposed to F ingestion.”
SOURCE: Lillie RJ. 1970. Air Pollutants Affecting the Performance of Domestic Animals: A Literature Review. U.S. Dept. of Agriculture. Agricultural Handbook No. 380. Washington D.C.

“The first sign of fluorosis in cattle (and probably also in deer) is mottling, pitting, and black discoloration of the teeth. Affected teeth are soft and show abnormal wear. Later the leg and foot bones may become deformed or fractured, resulting in lameness.”
SOURCE: Karstad L. 1967. Fluorosis in deer (Odoceileus virginianus). Bulletin of the Wildlife Disease Association 3:42-46.

“In advanced skeletal fluorosis the bones are brittle.”
SOURCE: Adams PH, Jowsey J. 1965. Sodium fluoride in the treatment of osteoporosis and other bone diseases. Annals of Internal Medicine 63: 1151-1155.

“In the macerated cattle specimens the bone was brittle and crumbled readily. The new bone was as fragile as chalk…”
SOURCE: Johnson LC. 1965. Histogenesis and mechanisms in the development of osteofluorosis. In: H.C.Hodge and F.A.Smith, eds : Fluorine chemistry, Vol. 4. New York, N.Y., Academic press (1965) 424-441.

“One of the most prominent features of fluorosis in cattle in England, however, was the frequency of actue severe lameness, especially in the early summer. It resembled that described by Towers (1954) who associated it with fracture of the pedal bone (3rd phalanx)….This suggests that traumatic factors played a part in producing the lameness by causing damage to bones which were relatively fragile as a result of skeletal accumulation of fluorine…”
SOURCE: Burns KN, Allcroft R. 1964. Fluorosis in Cattle. 1 – Occurrence and Effects in Industrial Areas of England and Wales 1954-57. Ministry of Agriculture, Fisheries and Food. Animal Disease Surveys Report No 2, Part I. Her Majesty’s Stationery Office, London.

“Increased fragility of the bones may be present, and they can be friable and crumbly.”
SOURCE: Kumar SP, Harper RA. 1963. Fluorosis in Aden. British Journal of Radiology 36: 497-502.

“During the examination of the Achintee sheep, an unusally large number of fractures were detected; these involved ribs, mandible, and pelvis.”
SOURCE: Agate JN, et al. 1949. Industrial fluorosis: A study of the hazard to man and animals near Fort William, Scotland. Medical Research Council Memorandum No. 22. His Majesty’s Stationery Office, London.

“High fluorine levels interfere with mineral metabolism and cause abnormal growth of bone that may be structurally weak.”
SOURCE: Huffman WT. 1949. Effects on livestock of air contamination caused by fluoride fumes. In: Air Pollution. Proceedings of the United States Technical Conference on Air Pollution. McGraw-Hill Book Co, New York. pp. 59-63.

“The bone is abnormally brittle.”
SOURCE: Lyth O. 1946. Endemic fluorosis in Kweichow, China. The Lancet 1: 233-235

“The osteomalacic condition (of fluorosis) to some extent varies with the species and age of the animal. Certain features are common, however… Common features are the reduced strength of the bones, the tendency to form exostoses, bone atrophy, and a deficient calcification.”
Roholm K. 1937. Fluoride intoxication: a clinical-hygienic study with a review of the literature and some experimental investigations. H.K. Lewis Ltd, London.

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