DOW and their paid-for Senator move to stop SF use
The New York Times just reported that a "political battle" is brewing on EPA's decision to phase out the use of sulfuryl fluoride as a food fumigant in the US. According to the Times, Senator James Inhofe (R-Okla.) wants to initiate a congressional inquiry into how EPA made its decision since sulfuryl fluoride only contributes a "negligible" contribution to aggregate fluoride exposure. Based on this article, FAN was asked the following question by a visitor: "Can someone explain why the removal of a pesticide that constitutes a 'tiny fraction' of total fluoride exposure is worth the added expense of finding a new and equally effective pesticide?"
Since we expect that Dow AgroSciences and Senator Inhofe may attempt to use this argument in the coming days/months, Michael Connett (who co-authored many of FAN's submissions to EPA on sulfuryl fluoride and is currently Editor-in-Chief of the Temple Law Review) penned the following response:
First, as a legal matter, the issue is very clear. The FFDCA, as modified by the Food Quality Protection Act, forbids EPA from granting pesticide tolerances for chemicals to which the population is already over-exposed. Thus, since abundant data shows that we have a fluoride over-exposure problem in the US, the EPA had essentially two, mutually-exclusive options: follow the law, or allow sulfuryl fluoride. Senator Inhofe's real beef, therefore, is not with the science, but with the law.
Second, and more to the point of your question: why should we be concerned when -- as a practical matter -- sulfuryl fluoride provides only a relatively small contribution to our AGGREGATE fluoride exposure? The answer is analogous to the idea that you should know more than the average depth of a river before attempting to ford across it. More specifically, the reason our annual exposure to sulfuryl fluoride is minimal is because it is a fumigant and most food is not fumigated (e.g. food processing facilities typically fumigate about 2 to 3 times a year). However, the food that IS fumigated contains extremely high levels of fluoride (e.g. 125 ppm on wheat flour). Thus, while you won't receive a large annual exposure to fluoride from sulfuryl fluoride, you can receive massive wallops on any given day. Fumigating the food supply with sulfuryl fluoride, therefore, creates a situation akin to Russian roulette, where some (unknowing) consumers will (unknowingly) buy flour, grain, or processed foods with extremely high levels of fluoride -- high enough, in fact, to exceed the dose (>0.1 mg/kg) that causes symptoms of acute fluoride toxicity (e.g. gastrointestinal pain and vomiting).
Take, for example, EPA's initial tolerance for dried eggs. Amazingly, EPA allowed Dow to add 900 ppm of fluoride to dried eggs, which is virtually the same level of fluoride as is added to toothpaste (1000 ppm). What's the problem with this? Well, next time you pick up a tube of fluoride toothpaste, read the FDA-mandated warning on the back which reads: "if you swallow more than used for brushing, contact a poison control center immediately." Now, it's one thing to brush your teeth with a poison -- since toothpaste is designed to be spit out. It's a whole different thing, however, to turn dried eggs into a poison, as -- unlike toothpaste -- dried eggs are designed to be eaten. And, in case you're wondering, dried eggs constitute one-third of the eggs consumed in the US.
Thankfully, the EPA eventually rescinded its dried-egg tolerances (after we brought the absurdity to light). However, EPA's standards still allow 125 ppm of fluoride in wheat flour and similarly high levels on hundreds of other foods. The concern with acute toxicity remains, and you can read more about it on pages 96 to 104 at http://www.fluoridealert.org/sf/nov-2006.pdf.
In addition to the acute toxicity problem, high spikes in temporary fluoride exposure have been shown -- in animal studies -- to cause dental fluorosis. Creating a food system which gives kids random wallops of fluoride ingestion could worsen the severity of dental fluorosis in the country.
Finally, alternatives exist to sulfuryl-fluoride fumigation, and they are being widely used in Europe (despite significant lobbying efforts by Dow AgroSciences). Even in countries where sulfuryl fluoride has been approved (Canada, UK, Switzerland) food processors are required to REMOVE all food from the food processing facility PRIOR to fumigating with sulfuryl fluoride -- thereby preventing the contamination of food.
Paul Connett, Director
Fluoride Action Network
http://fluoridealert.org/
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In the recent past couple of years an effort to stop the use of sulfuryl fluoride from being applied to strawberries has been waged. What few probably know is that the effort to stop its use all together goes back to the early days of the 21st Century.But this week, "FAN (Fluoride Action Network), had a stunning victory. This was a wonderful answer to those who believe that the little guy never wins. In a 9:30am conference call with Jonathan Fleuchaus, the general counsel of EPA's Pesticides program and 7 other EPA pesticide staff members, we were told that EPA was granting ALL our objections to the use of sulfuryl fluoride as a food fumigant. Mr. Fleuchas told us that it was was the first time in the history of EPA that such objections were granted. What this means is that EPA is going to end all uses of sulfuryl fluoride on food."
Pesticides: Despite repeated warnings that humans, particularly children, are currently receiving too much fluoride from their diets,fluoride pesticides continue to be added to the food supply under extremely lax regulations from the US Environmental Protection Agency (EPA).
Currently, the main fluoride pesticide used in the US is cryolite (sodium aluminum fluoride). The EPA currently allows up to 7 ppm of fluoride on over 30 fruits and vegetables treated with cryolite. This 7 ppm fluoride tolerance applies to: apricots, beets, blackberries, broccoli, Brussels sprouts, cabbage, cauliflower, citrus fruits, collards, cranberries, cucumbers, eggplants, grapes, kale, lettuce, melons, nectarines, peaches, peppers, plums, pumpkins, radishes, raspberries, squash, strawberries, tomatoes and turnip.
A 2 ppm standard has also been established for potatoes, which are second to grapes for total cryolite usage. The EPA's standard of 7 ppm for fluoride residues is over 5 times greater than the standard set by the US Department of Agriculture (USDA) in 1933. In 1933, the USDA established the maximum level for fluoride residues on fruits and vegetables at 1.2 ppm, which was the same standard the USDA established for arsenic. While arsenic pesticides have since been phased out of use in the US , fluoride pesticides remain. In fact, the current tolerance levels for fluoride pesticides could become even higher--if the US EPA, under intense pressure from Dow Chemical, approves sulfuryl fluoride as a replacement fumigant for methyl bromide.
If EPA approves sulfuryl fluoride (an indoor fumigant that has never before been used on food) as the replacement for methyl bromide, there will be a substantial increase in the fluoride contamination of the food supply.
In a recent petition (February 15, 2002) to the EPA, Dow Chemical asked for extremely high fluoride tolerances on a wide number of common foods, including, 98 ppm for wheat germ, 40 ppm for wheat bran, 31 ppm for rice bran, 30 ppm for a variety of nuts, 28 ppm for corn meal, 26 ppm for corn flour, 25 ppm for millet grain, 25 ppm for wild rice grain, 25 ppm for sorghum grain, 25 ppm for wheat grain, and 17 ppm for oat grain!
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