5 FAN Responds to the EPA
Ellen Connett, FAN Managing Director
On March 13, FAN submitted comments to the U.S. EPA on their decision not to do a compulsory “Six-Year Review” of fluoride on the basis that it was a “Low priority and/or no meaningful opportunity” issue.
On January 11, 2017, the EPA published a Proposed Rule in the Federal Register1 on its decision to defer the Six-Year Review of fluoride for the National Primary Drinking Water Regulations (NPDWR). According to EPA, the purpose of a Six-Year Review is:
…to evaluate current information for regulated contaminants to determine if there is new information on health effects, treatment technologies, analytical methods, occurrence and exposure, implementation and/or other factors that provides a health or technical basis to support a regulatory revision that will improve or strengthen public health protection.
In the Proposed Rule, EPA stated its decision to forego a review:
The Agency has determined that a revision to the NPDWR for fluoride is not appropriate at this time. EPA acknowledges information regarding the exposure and health effects of fluoride (as discussed later in the “Health Effects” and “Occurrence and Exposure” sections). However, with EPA’s identification of several other significant NPDWRs as candidates for near-term revision (see Sections VI.B.3 and VI.B.4), potential revision of the fluoride NPDWR is a lower priority that would divert significant resources from the higher priority candidates for revision that the Agency has identified, as well as other high priority work within the drinking water office.
FAN disagrees with EPA’s decision to defer performing a review as we find that fluoride poses unacceptable risks to the fetus, infant, child, and adult. In April 2011 FAN submitted two substantive submissions2,3 to EPA. Because EPA never responded to these submissions, we attach them as a major part of this submission as they are relevant to the risks we are concerned with and also deserving of a response. Added to those submissions we include the following:
- The Neurotoxicity of Fluoride (pp 7-34). This new section, written by Michael Connett, includes 196 published studies that have addressed the neurotoxic effects of fluoride exposure subsequent to the National Research Council’s 2006 report7, including 61 human studies, 115 animal studies, 17 cell studies, and 3 systematic reviews. In FAN’s 2011 submissions we listed 15 studies reporting an association of fluoride and reduced IQ (see pages 39-412) – today there are 50 studies. A Flash Drive containing over 300 studies referenced in this section was sent to EPA’s Docket Reading Room.
- Fluoride was labeled a developmental neurotoxin in 20148; this is discussed in the above section on the Neurotoxicity of Fluoride.
- In a 2015 study, Malin & Till9 found a statistically significant correlation between the prevalence of water fluoridation at the state level and Attention-Deficit Hyperactivity Disorder (ADHD). This is discussed in the above section on the Neurotoxicity of Fluoride.
- In a 2015 study, Peckham et al.10 reported an association or risk of higher levels of hypothyroidism in practices in fluoridated areas across England. (Approximately 10% of the population live in fluoridated areas.)
- In 2016, Hirzy et al. published a risk assessment that found U.S. children receive unsafe levels of fluoride11 (pp 35-36).
- In 2013, Hirzy et al. reported on the cancers due to, and their costs associated with, the chemicals used in community water fluoridation programs12,13 (pp 37-38).
- Fluoride and Cancer, particularly Osteosarcoma (p 39)
- Food treated with Highly Neurotoxic Fumigant (pp 40-41)
- Fluoridation is an Environmental Justice Issue (pp 42-85)
- According to the Toxic Release Inventory there are millions of pounds of fluoride and fluorine emissions released legally each year into the environment, yet no regulatory agency is studying or protecting the residents who live downwind of these facilities. (pp 88-94)
- Against Forgetting: Published Fluoride Studies: 2010 – February 2017 (pp 95-158). The top five categories with the most studies for this time period are: 104 Bone/Joint studies; 82 Reproductive studies; 81 Animal Brain Studies; 75 Dental Fluorosis studies; 75 Total Body Burden studies; 48 Kidney studies. This list updates the studies we submitted to EPA in 20112 in Appendix A: Selected studies published since the release of the NRC report in 2006.
- NHANES in 201414 reported dental fluorosis rates at 58.3% of U.S. surveyed adolescents, including an astonishing 21.2% with moderate dental fluorosis, and 2% with severe dental fluorosis. This represents significant over-exposure to fluoride in America’s children.
- NHANES in 201615 reported that 350,000 U.S. children (1 in 200) have serum fluoride levels in the approximate range associated with overt neurotoxic effects.
- According to the 2015 Cochrane Report16, “We did not identify any evidence, meeting the review’s inclusion criteria, to determine the effectiveness of water fluoridation for preventing caries in adults.”
- In 2015, Ko and Thiessen17 released a study that found no cost-savings from community water fluoridation because of the costs associated with treating dental fluorosis.
FAN Senior Adviser Paul Connett said that the EPA’s decision to give a “low priority” to the determination of a new MCLG (safe drinking water goal) for fluoride some eleven years after the National Research Council (NRC) concluded that the current MCLG of 4 ppm was not protective of health was “unbelievable.” EPA’s “lack of concern for the potential impacts of fluoride on the I.Q. of millions of American children is as irresponsible as it is reprehensible.”
Connett believes that the EPA has dragged its feet to protect the obsolete water fluoridation program.
“A new – and safe – MCLG must be determined without any further delay. William Hirzy PhD (a former risk assessment specialist at the EPA) has shown the EPA exactly how the Office of Water can do this. There simply are no excuses left.”
FAN’s Request: An Immediate Moratorium
Because of the lack of timeliness that EPA has demonstrated in responding to the public’s concerns on fluoride, and the critical nature of those concerns, FAN requests the EPA’s Office of Water place an immediate moratorium on drinking water fluoridation in order to protect the health of the public while EPA finds the time to examine the material in this submission, as well as the submissions of others, including those submitted by Kathleen Thiessen PhD.
To read the whole of the submission go to: http://fluoridealert.org/wp-content/uploads/fan-submission-to-epa.3-13-17-final.pdf
To see the references cited above, go to pages 5-6
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