Richard D. Sauerheber, Ph.D.
Palomar College
1140 W. Mission Rd.
San Marcos, CA 92069
April 22, 2011
Environmental Protection Agency
Health & Human Services
CWFcommentsd@cdc.gov
copy to FluorideScience@epa.gov
Dear Environmental Protection Agency,
Enclosed are additional necessary comments that supplement earlier submissions regarding fluosilicic acid injections into public drinking water. I have now examined additional published data regarding the nature of, and reactivity of, the fluoride ion at varying levels of acidity (Sauerheber, 2010, Chemical Analysis of Poisoning from a Fluoridated Water Supply, see attachment; Westendorf, J., “The Kinetics of Acetylcholinesterase Inhibition and the Influence of Fluoride and Fluoride Complexes on the Permeability of Erythrocyte Membranes”, Dissertation to receive Ph.D. in Chemistry, University of Hamburg, Hamburg, Germany, 1975; see www.fluoridealert.org).
As mentioned before, our San Diego water here ranks as one of the most contaminated in the nation (see news release below), and more of us citizens are learning NOT to consume municipal water any further. Not only were several contaminants, namely manganese and trihalomethanes, above the EPA allowed limits here, the EPA must be made aware of the fact that several contaminants are near those limits, depending on which section of San Diego one examines. Importantly, lead levels range up to 9 ppb (San Diego Water Quality Report, 2010), and arsenic is always also present with lead and in one city actuallly reaches 10 ppb (Carlsbad Water Quality Report, 2010). It is of course time to halt the procedure of injecting fluosilicic acid into such contaminated water for the purpose of treating human tissue; citizens here quickly eliminate this source of water from dietary considerations, and fluoride water drug injections serve no purpose.
As discussed in previous submissions, the ion level in saliva after ingestion from water supplies is only 0.02 ppm (National Research Council, Report on Fluoride in Drinking Water, 2003) , and even lower, 0.01 ppm, when ingested from water at 0.7 ppm now allowed by the U.S. Health and Human Services. This miniscule level of fluoride in saliva is useless in affecting teeth caries topically, compared to levels in toothpaste 150,000 times higher! We are spending vast sums in this country for a procedure that does not work and is harmful as well. This was the incorrectly presumed premise for a State law in CA to fluoridate water in large cities. The state regulation is invalidated andmust be recognized by the EPA as such, since ingested fluoride, as opposed to high level applied topical fluoride, has no effect on teeth (as was published by the U.S. Ceters for Disease Control in: Morbidity and Mortality Weekly Report, Aug. 17, 2001 that confirmed ingested fluoride, as opposed to applied topical fluoride, leads to abormal tooth fluorosis and does not decrease incidence of caries). Not only are the CA and other state fluoride laws incorrect and invalid, the procedure also contradicts the original missions of both the Safe Drinking Water Act and the Water Pollution Control Act.
The MCL for lead allowed in water by the EPA is 10 ppb for lifetime consumption, but this value has meaning only if no other significant sources of lead exist for an individual lifetime. The same MCL is applied for arsenic, but again only as long as other arsenic sources are not significant. The real problem lies in the fact that in today’s society (see article below) more and more large city water supplies have become contaminated with both arsenic and lead at the same time. There are no EPA MCL guidelines for such a mixture, even though both these heavy metals bind irreversibly to protein in their toxic mechanism of action, while consumed lifetime at levels allowed when separate. Therefore, it is necessary as a minimum to add the lead and arsenic prevailing levels together in any water district supply and use that sum to compare with the allowed MCL of 10 ppb, to help avoid adverse health effects during lifetime consumption. With this in mind, many cities in the U.S. including San Diego now exceed 10 ppb for total heavy metal levels in water. Most of the arsenic is assumed to come from herbicides and pesticides and have sadly accumulated in farm soil and now in water supplies because of long-term heavy use in the past. The U.S. also still imports massive amounts of arsenic products from China. Arsenic is a Class A, Class I human certain carcinogen (as classed by the IARC and EPA) and lead is a probable human carcinogen (see Agency for Toxic Substances and Disease Registry). The incidence of lethal cancers in the U.S. is extremely large and acid fluorides have been reported to casue dissoluton of lead from home pipe fittings in some cases to very high amounts (Masters and Coplan, www.fluoridealert.org). Many homes after acid fluoride injections begin test water supplies with excessive lead, even though the supplied water into the home is below 10 ppb. There is no longer any excuse for public water supplies to remain in any dietary allowance as long as water remains in this condition, particaurly when fluorides are so plentiful in pastes, mouth rinses, foods and other sources (
In addition to this, aluminum is injected into Los Angeles, San Diego (and other) U.S. city water supplies as a cheap procedure to eliminate clay particles. This leaves residual 0.05 ppm aluminum in the water. Normally only trace amounts of aluminum ion are assimilated from the gut, but in February, 2011 San Diego began injecting 0.7 ppm synthetic fluosilicic acid fluoride (under the new U.S. Health and Human Services allowed 0.7 ppm guideline). The problem is that aluminum fluoride complexes form in stomach acid that are assimilated significantly before being re-neutralized in the intestine distant from the Ampulla of Vater. Various aluminum complexes with fluoride are known to exist under acidic conditions that are assimilated far better than the trace amounts normally incorporated in the absence of fluoride, including AlF3, AlF+, and AlF+2 (Westendorf). The 4th leading cause of death in San Diego today is Alzheimer’s disease, and it is commonly found that aluminum is bound to the abnormal brain proteins in victims of this condition. Water fluoride injections into arsenic, lead and aluminum contaminated water must now be halted.
The EPA has been and will continue to be the National guardian of the U.S. environment. When the EPA bans further fluosilicic acid injections, it will be behaving with the will of the majority of ciizens in the United States. More often than not when people are allowed to vote, the injections are opposed. In San Diego, citizens voted against the injections twice and passed a city ordinance section 67 that forbids injecting fluoride compounds into our public water supplies. Because of pressure from CDC officials directed at the Metropolitan Water District, Los Angeles (well-documented in the Los Angeles Times and the North County Times, San Diego), both MWD and San Diego Water decided to inject acid fluoride into water in spite of the ordinance and duplicate elections. This may be difficult for citizens to overcome, but it is not difficulte for the U.S. EPA, and we ask for your help. It is ironic that the Safe Drinking WaterAct prohibits any National reqauirement for any chemical injections into public water supplies other than to sanitize the water, and yet it is dental officials in offices of the CDC who continue to promot this discredited practice with local water districts (Connett, P., “The Case Against Fluoride”, Chelsea Green Publishing, White River Junction, Vermont, 2010). The stated prime directive of the U.S. Federal Clean Water Act (Water Pollution Cohtrol Act), as originally conceived by President John F. Kennedy, is to maintain the normal chemistry of public U.S. waters (Sectrion 101a). How far we have slowly drifted from this mission is hard to fathom, but it is the EPA who is able, has the authority to, and we trust will bring us back. Our water supplies can no longer be used as a vehicle with which to disseminate drugs, no matter the desires of any group or lobby with vested interests otherwise, who have used Federal officials as though they are assistants in this matter.
Richard Sauerheber, Ph.D., Chemistry
University of CA, San Diego
Currently Palomar College, San Marcos, CA
richsauerheb@hotmail.comBy Douglas McIntyre
From MSNBC.MSN.COM
Unknown to most Americans, a surprising number of U.S. cities have drinking water with unhealthy levels of chemicals and contaminants.
In fact, some organizations and state environmental agencies that collect and analyze water data say the level of chemicals in some Americans’ drinking water not only exceeds recommended health guideline but the pollutants even exceed the limits set by the U.S. Environmental Protection Agency (EPA), the national legal authority in these matters.
The website 24/7 Wall St examined the quality of water supplies in most major America cities, using data collected from multiple sources for five years (ending in 2009) by Environmental Working Group (EWG), based in Washington, D.C. The fact that the data covered a half-decade is important because it shows that the presence of certain chemicals is persistent.
Cities in Kansas, Louisiana, Mississippi, Tennessee and Georgia provided insufficient data to be included in EWG’s database. Some other major cities outside of these states also failed to submit information, including Detroit, Salt Lake City and Washington, D.C.
Test results from EWG’s national database covered “a total of 316 contaminants in water supplied to 256 million Americans in 48,000 communities in 45 states.” According to the data, among the contaminants were 202 chemicals that aren’t subject to any government regulation or safety standards for drinking water.
Based on the EWG’s methodology, 24/7 Wall St. came up with its 10 worst cities list. These cities’ water quality rank is based on three metrics, in order of increasing importance:
- The percentage of chemicals found based on the number that were tested for.
- The total number of contaminants found.
- The most dangerous average level of a single pollutant.
Here’s that list, in descending order, with the city’s water utility in parenthesis:
10. Jacksonville, Fla. (JEA)
Located on the northeast coast of Florida, Jacksonville is the state’s largest city. According to EWG, 23 different toxic chemicals were found in Jacksonville’s water supply. The chemicals most frequently discovered in high volumes were trihalomethanes, which consist of four different cleaning byproducts — one of which is chloroform. Many trihalomethanes are believed to be carcinogenic. Over the five-year testing period, unsafe levels of trihalomethanes were detected during each of the 32 months of testing, and levels deemed illegal by the EPA were detected in 12 of those months. During at least one testing period, trihalomethane levels were measured at nearly twice the EPA legal limit. Chemicals like arsenic and lead were also detected at levels exceeding health guidelines.
9. San Diego (San Diego Water Department)
Located on the Pacific in Southern California, San Diego is the country’s eighth-largest city. According to California’s Department of Public Health, San Diego’s drinking water system contained eight chemicals exceeding health guidelines as well as two chemicals that exceeded the EPA’s legal limit. In total, 20 contaminants have been found. One of those in excess of the EPA limit was trihalomethanes. The other was manganese, a natural element that’s a byproduct of industrial manufacturing and can be poisonous to humans.
8. North Las Vegas (City of North Las Vegas Utilities Department)
North Las Vegas’s water supply mostly comes from groundwater and the Colorado River, and doesn’t contain chemicals exceeding legal limits. However, the water supply did contain 11 chemicals that exceeded health guidelines set by federal and state health agencies. The national average for chemicals found in cities’ water exceeding health guidelines is four. North Las Vegas had a total of 26 contaminants, compared with the national average of eight. The water contained an extremely high level of uranium, a radioactive element.
7. Omaha (Metropolitan Utilities District)
The land-locked city of Omaha gets its water from the Missouri and Platte Rivers, as well as from groundwater. Of the 148 chemicals tested for in Omaha, 42 were detected in some amount, 20 of which were above health guidelines, and four of those were detected in illegal amounts. These were atrazine, trihalomethanes, nitrate and nitrite, and manganese. Atrazine is an herbicide that has been shown to cause birth defects. Nitrate is found in fertilizer, and nitrite is used for curing meat. Manganese was detected at 40 times the legal limit during one month of testing.
6. Houston (City of Houston Public Works)
Houston is the fourth-largest U.S. city. It gets its water from sources such as the Trinity River, the San Jacinto Rivers and Lake Houston. Texas conducted 22,083 water quality tests between 2004 and 2007 on Houston’s water supply, and found 18 chemicals that exceeded federal and state health guidelines, compared to the national average of four. Three chemicals exceeded EPA legal health standards, against the national average of 0.5 chemicals. A total of 46 pollutants were detected, compared to the national average of eight. The city water has contained illegal levels of alpha particles, a form of radiation. Similarly, haloacetic acids, from various disinfection byproducts, have been detected.
5. Reno (Truckee Meadows Water Authority)
Reno gets most of its water from the Truckee River, which flows from Lake Tahoe. Of the 126 chemicals tested for in Reno over four years, 21 were discovered in the city’s water supply, eight of which were detected in levels above EPA health guidelines, and three of these occurred in illegal amounts. These were manganese, tetrachloroethylene and arsenic. Tetrachloroethylene is a fluid used for dry cleaning and as an industrial solvent, and is deemed a likely carcinogenic by the International Agency for Research on Cancer. Arsenic is a byproduct of herbicides and pesticides, and is extremely poisonous to humans. During at least one month of testing, arsenic levels were detected at roughly two and a half times the legal limit.
4. Riverside County, Calif. (Eastern Municipal Water District)
Riverside county is a 7,200-square-mile area located north of San Diego, part of California’s “Inland Empire.” The county is primarily located in desert territory, and so the water utilities draw their supply from the Bay Delta, which is miles to the north. The water in Riverside County contained 13 chemicals that exceeded recommended health guidelines over the four tested years, and one that exceeded legal limits. In total, 22 chemicals were detected in the district’s water supply. The contaminant exceeding legal health standards was tetrachloroethylene.
3. Las Vegas (Las Vegas Valley Water District)
Located in the Mojave desert, Las Vegas gets its water from the Colorado River through miles-long intake pipes. While its water doesn’t exceed the legal limits for any single type of contaminant, Las Vegas’s water has a large range of pollutants. Of the 125 chemicals tested for over a five-year period, 30 were identified in some amount, and 12 were found in levels that exceeded EPA health guidelines. These chemicals included radium-226, radium-228, arsenic and lead. The two radium isotopes are commonly found around uranium deposits and are hazardous to human health, even in small quantities.
2. Riverside, Calif. (City of Riverside Public Utilities)
Riverside, with a population slightly greater than 300,000, gets most of its drinking supply from groundwater. Regulators in the city of Riverside, which has a different water-treatment facility than the rest of Riverside County, detected 15 chemicals that exceeded health guidelines and one that exceeded legal standards. In total, 30 chemicals were found. Since 2004, the water has almost consistently been riddled with alpha particle activity, traces of bromoform (a form of trihalomethane) and uranium, causing an unusually unhealthy water supply.
1. Pensacola, Fla. (Emerald Coast Water Utility)
Located on the Florida Panhandle along the Gulf of Mexico, Pensacola is Florida’s westernmost major city. Analysts say it has the worst water quality in the country. Of the 101 chemicals tested for over five years, 45 were discovered. Of them, 21 were discovered in unhealthy amounts. The worst of these were radium-228 and -228, trichloroethylene, tetrachloroethylene, alpha particles, benzine and lead. Pensacola’s water was also found to contain cyanide and chloroform. The combination of these chemicals makes Pensacola’s water supply America’s most unhealthy.
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