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The CDC asked for comments on it’s proposed control range. The CDC is proposing a control range of 0.6ppm to 1.0ppm with the national target at 0.7ppm. From my reading of the CDC supporting document which looked at CDC gathered data from states and water systems,there were many water systems are unable to keep the fluoride level within .1ppm of their target. If the proposed control range is adopted by states some water systems may target .8 simply because at that level they have .2ppm above and below the target and it’s easier to stay within the control range.

There is precedent for these unbalanced control ranges. Here’s the probably still current (although ignored) control ranges for California. https://govt.westlaw.com/calregs/Document/I118E7353D3714B8E8704B77DB703F890?originationContext=Search+Result&listSource=Search&viewType=FullText&navigationPath=Search%2fv3%2fsearch%2fresults%2fnavigation%2fi0ad7140a0000016249fdd1d12a70b912%3fstartIndex%3d1%26Nav%3dREGULATION_PUBLICVIEW%26contextData%3d(sc.Default)&rank=1&list=REGULATION_PUBLICVIEW&transitionType=SearchItem&contextData=(sc.Search)&t_T2=+64433.2&t_S1=CA+ADC+s

The lower end of the control range is always .1ppm lower than the target while the upper end of the control range is .5ppm higher. It makes me wonder how high fluoridation levels have actually been in California. Note that with a 1.2ppm target the upper control level was 1.7pppm. At 2ppm and above public notification is required to encourage parents to not give that water to children. Severe dental fluorosis can be the result.

Sincerely,

James Robert Deal , Attorney & Broker
James
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