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PO Box 2276, Lynnwood, Washington  98036-2276
Telephone 425-771-1110, Fax 425-776-8081

May 29, 2012

Everett City Council, Mayor, and Advisors
Attention: Council President Ron Gipson
3002 Wetmore Ave
Everett, WA 98201

Sent by email to:;;;;;;;;;;

Dear City Council, Mayor, Attorneys, and Advisors:

On February 7, 2012, I wrote a letter to Simplot, supplier of Everett’s fluoridation materials. I wrote on behalf of Fluroide Class Action. You may read the letter at:

I quote from my letter to Simplot:

NSF states on its web site[5]:

Standard 60 … requires a toxicology review to determine that the product is safe at its maximum use level and to evaluate potential contaminations in the product. … A toxicology evaluation of test results is required to determine if any contaminant concentrations have the potential to cause adverse human health effects. …

In the NSF/ANSI 60 – 2009 Guide on Drinking Water Treatment Chemicals – Health Effects, NSF states[6]:

For each substance requiring a new or updated risk assessment, toxicity data to be considered shall include but not be limited to, assays of genetic toxicity, acute toxicity …, short term toxicity …, subchronic toxicity …, reproductive toxicity, developmental toxicity, immunotoxicity, neurotoxicity, chronic toxicity (including carcinogenicity), and human data (clinical, epidemiological, or occupational) when available. To more fully understand the toxic potential of the substance, supplemental studies shall be reviewed, including, but not limited to, mode or mechanism of action, pharmacokinetics, pharmacodynamics, sensitization, endocrine disruption, and other endpoints, as well as studies using routes of exposure other than ingestion. Structure activity relationships, physical and chemical properties, and any other chemical specific information relevant to the risk assessment shall also be reviewed. …

When Simplot applied for NSF 60 certification and became one of the 49 approved suppliers of fluoridation materials, Simplot should have prepared and presented the above mentioned “toxicology review”, “toxicological evaluation”, and “toxicity data” to NSF. NSF repeatedly states in its 2008 Factsheet on Fluoridation that such toxicological evaluations are “required”. NSF never states that NSF is providing the “toxicology review”, “toxicological evaluation”, and “toxicity data”, which would imply that the supplier is to provide them.

If you have such “toxicology review”, “toxicological evaluation”, and “toxicity data”, please send them to me at the above address. Send them also to the City of Everett. If you do not have said materials, please confirm that fact.

Simplot never replied to my request. I am asking that Everett follow up with Simplot and get answers to these questions. I suggest that Everett send a letter to Simplot, enclosing my February 7 letter, and stating the following:

The City of Everett has been a long time buyer of fluoridation materials from Simplot. The City of Everett has an interest in seeing the response of Simplot to the questions which Mr. Deal asked in his letter dated February 7, 2012, along with the documents he requested. Mr. Deal’s letter can be found at this web address:

Please reply to Mr. Deal’s letter and send a copy of your response to us.

The City of Everett wants to see all the toxicological reviews which NSF claims are done in connection with NSF approval of Simplot as a supplier and the fluoridation materials which Simplot supplies.



James Robert Deal, Attorney
WSBA Number 8103