Fluoride: Fluorinated Pesticide Project used in food (Toxicology Program)

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Fluoride and Fluorinated PesticidesFluoride Action Network Pesticide ProjectEllen Connett, DirectorMarch 10, 2007http://www.fluoridealert.org/f-pesticides.htmThe only online database for fluoride and fluorinated pesticides.For data on pesticides beginning with:A to E FG to PQ - Z Produced exclusively byDow AgroSciences SULFURYL FLUORIDE:Three groups (Fluoride Action Network, Environmental Working Group, Beyond Pesticides) are challenging US EPA on its approval of sulfuryl fluoride as a food fumigant (trade name ProFume®). The groups are represented, pro-bono, by Zelle, Hofmann, Voelbel, Mason & Gette's attorney Perry E. Wallace, Esq., a law professor at American University. The groups have submitted three formal Objections and Requests for an Evidentiary Hearing (2002, 2004, 2005). •• JANUARY 17, 2007. Memorandum to USEPA, Legal Standard for Grant of Hearings on Objections under Federal Food, Drug, and Cosmetic Act Section 408. This was submitted by the group's attorney, Perry Wallace, Esq., in response to Dow AgroSciences October 31, 2006, submission to USEPA, that argued against EPA granting an evidentiary hearing.•• NOVEMBER 2006. At the request of EPA, the groups submitted a consolidation of their Objections. This submission is the most succinct representation of the groups' arguments for EPA to grant them an evidentiary hearing.•• JUNE 2006. The groups submittted a Petition to US EPA to revoke all tolerances for the use of sulfuryl fluoride (ProFume®) as a food fumigant. This Petition was in response to the finding by the National Research Council's report (Fluoride in Drinking Water) that the Maximum Contaminant Level Goal (MCLG) of 4 ppm fluoride in drinking water was not protective of human health. EPA used this MCLG in its health risk assessments on the basis that it was "safe." •• JULY 5, 2006: EPA solicited public comments to the June petition. Over 8,000 letters were sent to EPA Administrator Stephen Johnson in support of the petition.•• AUGUST 2006. The Office of the NY State Attorney General submitted comments to EPA in support of the groups' Petition to stay sulfuryl fluoride tolerances.• July 18 Inside EPA report on issue• July 25 Letter to EPA Administrator from EPA Union in Washington DC• July 7 Press Release from the Environmental Working Group•• January 18, 2006: EPA's Final Human Health Risk Assessment•• June 2, 2005: EPA's Draft Human Health Risk Assessment• Documents on Sulfuryl Fluoride -- This compilation represents most of the essential documents that pertain to the groups Objections to sulfuryl fluoride tolerances. A tolerance is the legal amount of a pesticide residue allowed in and/or on specific foods. • List of all foods with fluoride pesticide residue tolerances (click here for pdf version)• Suggestions for reducing exposure to fluorideRead or buy the National Research Council report on toxicity of fluoride at http://www.nap.edu/catalog/11571.html• See excerpts from Chapter 7: Neuroxicity and Neurobehavioral EffectsThe 2nd Citizens' Conference on Fluoride was terrific. Approximately 90 people attended (Photo by Chris Neurath of FAN. )July 28 - August 1, 2006Held on the campus of St Lawrence University, Canton NYSponsored by Fluoride Action Network• Chemical & Engineering News 4-page report by Bette Hileman on Conference• Ralph Nader's statement on the Conference• About the Conference• Conference Agenda(Photo by Chris Neurath of FAN) Some of FAN's activities onSulfuryl fluoride (ProFume®) in 2005:December 21: Press release on December 16 submission to US EPA.December 16: Submission to EPA on issues for an evidentiary hearing to revoke the tolerances for sulfuryl fluoride. This was in response to EPA's June 4 request. Submitted by FAN, EWG and Beyond Pesticides. When EPA approved sulfuryl fluoride for food use, it approved two tolerances: fluoride and sulfuryl fluoride. These are the tolerances that the groups are seeking to revoke.September 13: Objections and Request for Hearing submitted to US EPA on the new residue tolerances for fluoride and sulfuryl fluoride approved July 15, 2005 by EPA. Submitted by FAN, the Environmental Working Group, and Beyond Pesticides:• Submission• Links to Tables, Appendices, and References• Press ReleaseMarch 4, - Comments submitted to EPA by FAN Pesticide Project on Dow AgroSciences petition for several new tolerances for the use of sulfuryl fluoride as a fumigant on food. Dow petitions for exceptionally high fluoride residue tolerances. See - EPA's response to comments submitted on Dow's March 4, 2005, PetitionFrom July 2005 California report on Vikane: Environmental Fate - Volume III ... pages 7-8: A search of the open science literature produced no citations relevant to the fate of sulfuryl fluoride in the atmosphere ... Little or no data on sulfuryl fluoride’s environmental and atmospheric loss processes are available. There are no experimental data to confirm that it photolyzes in the troposphere or reacts with OH radicals, NO3 radicals, or O3. It is entirely possible that sulfuryl fluoride has a long or very long atmospheric lifetime and should therefore be considered a greenhouse gas. http://www.fluorideaction.org/pesticides/sf.ca.epa.env.fate.july.05.pdfNovember 2005 - EPA's new National Pesticide Information Retrieval System (NPIRS): http://ppis.ceris.purdue.edu/State and County Water Fluoridation Information is available athttp://www.cdc.gov/OralHealth/index.htm Scroll down to My Water's Fluoride -- includes levels in each communities' drinking water system.• The Edible Schoolyard website. This inspiring website describes the one-acre organic garden and kitchen classroom founded on the campus of Berkeley's Martin Luther King Junior Middle School, in collaboration with noted chef Alice Waters. Fluoride: In a June 6 petition to the National Toxicology Program, the Environmental Working Group nominated "fluoride in tap water for inclusion in the Report on Carcinogens based on its ability to cause osteosarcoma in males less than 20 years of age." According to the petition, "[t]he science supporting the link between fluoride and bone cancer in boys is compelling, and much of this science is recent and not reflected in current drinking water contaminant limits or the overall risk-benefit equation underlying the decision to add fluoride to the tap water of 170 million people. This widespread exposure to fluoride in tap water ensures that millions of boys are exposed during critical periods of development and growth that are relevant to the cancer in question...." Read article on the petition published in the June 12 Observer (UK).••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••Fluorinated Pesticides: (organic)• The majority of the pesticides in our data base are fluorinated. We had used the term "organofluorine" to describe organic pesticides containing fluorine in their chemical formula. However, this term is not precise, as the majority of pesticides contain other halogens, primarily chlorine. Seven pesticides in our data base contain three halogens in their chemical formula: fluorine, bromine, and chlorine. • The toxicity of the fluorinated compound is not due to the release of a free fluoride ion, but to the particular molecular structure of the compound. From our research to date it appears that fluorinated pesticides intensify pesticidal and biological activity. Animal studies available on pesticides with fluorine + bromine in their chemical formula report severe brain effects.••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••Fluoride Pesticides: (inorganic) The concern centers on the fluoride ion's toxicity, persistence, and bioaccumulation in humans, wildlife, and soil. The main pesticides are:• Cryolite: (sodium aluminum fluoride) - mainly used on grapes, fruits, and potatoes. EPA allows fluoride tolerances of 7 ppm, except for kiwifruit, which has a residue tolerance of 15 ppm.•Sulfuryl fluoride is the most immediate and important pesticide issue for the FAN Pesticide Project. This acutely toxic fumigant received its first-time approval for use on stored food commodities (raw and processed) in the US in January 2004. This approval allows the highest levels of fluoride residue levels in food in the history of the EPA. FAN, together with Beyond Pesticides, submitted formal objections to EPA on this approval (see press release). See the food tolerances approved and petitioned for as of July 15, 2005. • Sodium fluoride - its main known use is in wood preservatives. However, sodium fluoride is designated as a "List 4 Inert" by US EPA and is approved for use in pesticidal formulations. US EPA treats "Inerts" as confidential proprietary information which means the public is denied the right to know which pesticides contain them, or on what crops they are used. "List 4 Inerts" are approved for use in the US National Organic Program administered by the US Department of Agriculture (USDA). In 2000, approximately 125 individuals contacted USDA requesting that the use of sodium fluoride be denied in organic agriculture - all to no avail. Because fluoride accumulates in the human body, the public has a right to know all exposure sources.Essential reading: the journal FLUORIDEpublished quarterly by the International Society for Fluoride Research (ISFR). SUBSCRIPTION & MEMBERSHIP FEE for the year 2006, payable in advance, is: US$51, Canadian$63, £28, Japan¥5500, €42, Australian$66, New Zealand$72, with a discount of 10% for copies posted to a New Zealand address, which incurs a lower postal cost. Personal cheques, bank cheques or drafts, and cash may be posted to Dr Bruce Spittle, 727 Brighton Road, Ocean View, Dunedin 9051, New Zealand.spittle. Personal or bank cheques, and cash, in US$, Canadian$, £, w, Australian$, and NZ$ are fine. Cash as Japanese Yen is also fine. Please do not send Canadian or British Postal Notes, cheques drawn on Japanese banks, or cheques in US$ drawn on British banks in the United Kingdom as they cannot be negotiated in New Zealand. 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