SULFURYL FLUORIDE – NOT OKAY
January 30, 2014Patty Murray, Senator
2988 Jackson Federal Bldg.
915 2nd Avenue, Suite 600
Seattle, WA 98174
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Telephone: 206-553-5545 Maria Cantwell, Senator
2988 Jackson Federal Bldg.
915 2nd Avenue, Suite 600
Seattle, WA 98174
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Dear Senator Murray and Senator Cantwell,
I am an attorney and the president of Fluoride Class Action, a group of lawyers and scientists who study the law and science related to chronic fluoride poisoning. See www.Fluoride-Class-Action.com
The EPA has been considering banning the use of sulfuryl fluoride as a fumigant. See:http://www.epa.gov/pesticides/sulfuryl-fluoride/evaluations.html.
The National Research Council has said that we are all consuming too much fluoride. Some believe a little fluoride in drinking water is a good thing, but all recognize that too much fluoride is a bad thing. Google for “NRC 2006 on Fluoride”. When foods are sprayed or fumigated with sulfuryl fluoride, there are enormous fluoride residues in foods such as bread, eggs, corn, in fact, pretty much all non-organic foods.
You may read this letter online at https://www.fluoride-class-action.com/sulfuryl-fluoride-should-be-banned, which will make it easier to follow links.
The chemical industry is fighting back. Section 122 of the new Farm Bill, referred to as the Pest Free Food Supply Act, would effectively exempt sulfuryl fluoride from EPA regulation, thus allowing continued and increased use of this very potent poison.
The new provision would say:
SEC. 122__. Exclusion of Fluoride from Aggregate Exposure
Notwithstanding any other provision of law, the Administrator of the Environmental Protection Agency shall exclude naturally occurring fluoride in drinking water and fluoride in dental health products from any determination required under section 408(b)(2) of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 346a(b)(2)) regarding the aggregate exposure to the pesticide chemical residue of sulfuryl fluoride.
The Pest Free Food Supply Act is supported by members of the Sulfuryl Fluoride Agricultural Coalition whose members include: American Agri-Women, American Farm Bureau Federation, American Seed Trade Association, California Grape and Tree Fruit League, California Walnut Commission, California Women for Agriculture, Cardinal Professional Products, Cocoa Merchants’ Association of America, DFA of California, Dow AgroSciences, National Confectioners Association’s Chocolate Council, National Pasta Association, National Pest Management Association, North American Millers’ Association, Sunsweet Growers Inc., Trical, USA Rice Federation, Western Growers.
Sulfuryl fluoride is used to fumigate grains and other products to kill insects. The product to be fumigated is put in a sealed building. An alarm is sounded to warn everyone to leave – or else suffer a quick death. The sulfuryl fluoride is then released into the product. Whereas most insecticides – typically made of oxygen, hydrogen, phosphorus, nitrogen, and chlorine, eventually break down into harmless components, fluoride does not. Fluoride is the ion of the fluorine atom, and it does not break down further. And this means there is fluoride in harmful quantities in the food we eat.
The Environmental Working Group notes, for example, that the EPA allows up to 900 ppm fluoride in dried eggs. See: http://www.fluoridealert.org/pesticides/sf.press.release.9-21-05.html.
How does the fluoride get into dried eggs? The grains which chickens eat are fumigated with sulfuryl fluoride to kill weevils. It is also legal to apply sulfuryl fluoride to finished dried eggs – again to kill weevils. See http://en.wikipedia.org/wiki/Sulfuryl_fluoride.
One-third of all eggs are dried and then added to hundreds of food products. Seehttp://www.ewg.org/search/site/sulfuryl%20fluoride. The 900 ppm fluoride level in dried eggs is not far below the typical 1,500 ppm fluoride level in toothpaste, and one is to call poison control if he swallows more than a pea size amount of toothpaste.
The maximum fluoride allowed in wheat flour is 125 ppm. Similar levels are allowed in other grains, beans, corn, and other dry products typically stored for long periods of time. See:http://www.ewg.org/news/news-releases/2005/09/21/environmental-groups-petition-epa-retract-fluoride-pesticide.
Sulfuryl fluoride gradually breaks down, and one of the end products is the fluoride ion. The 2006 National Research Council study on fluoride goes into detail about sulfuryl fluoride. Go to: http://www.nap.edu/openbook.php?booksearch=1&record_id=11571 and do a search for “sulfuryl fluoride”.
The Environmental Working Group opposes the use of sulfuryl fluoride as a fumigant. See:http://www.fluoridealert.org/news/sulfuryl-fluoride-natural-resources-defense-council-nrdc-opposes-phase-out/
Insects such as weevils infest grains, dried eggs, and other mass produced products which can be saved for long periods of time. Regarding this weevil business my response is:
1) Grain storage facilities should be upgraded and kept clean so that pests have a harder time infesting the grain.
2) Freezing can kill weevils. See: http://www.wikihow.com/Get-Rid-of-Weevils-(Flour-Bugs).
3) We should be less concerned about a few weevils in our bread, cakes, or eggs. I would rather eat organic weevils than sulfuryl fluoride. Weevils are a good source of protein and omega-3 fatty acids. Even under current standards, wheat flour, for example, is allowed to contain up to 150 insect fragments per 100 grams. See:http://en.wikipedia.org/wiki/The_Food_Defect_Action_Levels.
“You’re probably ingesting one to two pounds of flies, maggots and mites each year without knowing it.” See: http://www.nytimes.com/2009/02/13/opinion/13levy.html?_r=0.
If the allowable levels of insect parts were raised, we could reduce use of fumigants. Complete elimination of insects from our food is impossible and unnecessary.
Fluoride Action Network has issued the following statement. See:http://www.fluoridealert.org/articles/sf_legislation:
• Sulfuryl fluoride is a highly neurotoxic substance and Americans don’t need another substance, especially on their food, that is known to damage the brain. All of Dow’s animal experiments with sulfuryl fluoride reported significantly rare and serious brain damage in every species tested.
• EPA pesticides division made the right decision to protect the American public when they proposed to phase-out sulfuryl fluoride as a food fumigant in January 2011. This Amendment punishes EPA for doing the job Congress mandated them to do in the Food Quality Protection Act (FQPA).
• Congress passed FQPA in 1996. This Act gave stronger protections to children from pesticide risks. One of these protections was the necessity to evaluate “aggregate exposure” to a pesticidal substance. And EPA found that children were being overexposed to fluoride. For example, CDC has reported that 41% of children ages 12-15 have some form of dental fluorosis which is a biomarker for fluoride overexposure.
• This Amendment is devious because it eliminates important exposure pathways. If the Amendment passes, infants and children will be put in harm’s way. More than 37 studies have been published reporting an association between fluoride exposure and lowered IQ. Black and Hispanic American children already suffer significantly higher rates of the more severe forms of dental fluorosis, a biomarker for fluoride overexposure.
• Sulfuryl fluoride is a potent greenhouse gas.
• There has been no transparency in putting this Amendment forward. This Amendment needs to be stopped and if necessary a hearing should be held at a future date.
• Three advocacy groups worked together for many years to get EPA to do the right thing to protect the health of Americans on this issue. They submitted substantive objections in a timely manner over 8 years. They responded to every request from EPA, including mediation efforts. These groups are: the Fluoride Action Network, Beyond Pesticides and the Environmental Working Group.
Sulfuryl fluoride is sprayed on grapes and other fruit. Unless you are buying organic, you are eating sulfuryl fluoride.
Chemical companies will poison their own children for a profit.
The Pest Free Food Supply Act is a bad law, and it should be stripped from the new Farm Bill.
James Robert Deal, Attorney
WSBA Number 8103
PO Box 2276, Lynnwood, Washington 98036-2276
Telephone 425-771-1110, Fax 425-776-8081