By The Fluoride Action Network
ProFume® is the name of the Dow AgroSciences fumigant that was approved for use on food by U.S. Environmental Protection Agency's Office of Pesticides Programs (EPA) in January 2004. It contains 99.8 percent sulfuryl fluoride.
Sulfuryl fluoride breaks down to the fluoride anion in the human body and is the toxicological endpoint of concern.
The History of Highly Toxic Sulfuryl Fluoride
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Sulfuryl fluoride, a highly toxic fumigant, was first registered in 1959 for the control of termites. It is now used as a structural fumigant to kill all living organisms, such as rodents, cockroaches, insects, bed bugs and fungi, and is used in homes, offices, libraries, trains, ships, etc.
In fact, it will kill almost anything. Its trade name is Vikane® and it's made exclusively by Dow Chemical.
It's bad enough as a pest control fumigant, but it didn't end there. In June 2001, Dow AgroSciences (Dow) petitioned the EPA for an Experimental Use Permit to use sulfuryl fluoride as a first-time food fumigant on raisins and walnuts in California. At the same time, Dow also requested an exemption from a fluoride tolerance for raisins.
A tolerance is the term used for the legal level of residue in and/or on a food commodity.
It was at this time that the U.S. was obligated, as a signatory to the Montreal Protocol, to phase out the most widely used food fumigant, methyl bromide (also made by Dow), because it's an ozone destroyer. Dow was pushing sulfuryl fluoride as the alternative even though it is was later identified as a "potent" greenhouse gas.
In September 2001, the EPA responded to Dow and denied their request for a fluoride tolerance exemption for raisins and recommended a tolerance of 30 parts-per-million (ppm).
The EPA noted that drinking water and food were the primary routes of exposure to fluoride, omitting a major route for children: ingestion of toothpaste. The Fluoride Action Network (FAN) submitted comments and warned the EPA that its review of exposure routes to fluoride were deficient, particularly for children, stating, "Children in North America are already being over-exposed to fluoride."
FAN also expressed concerns about the serious brain effects that were cited in Dow's animal experiments on sulfuryl fluoride.
The EPA also had to set tolerances for sulfuryl fluoride.
We actually know little of this highly toxic gas, except that it breaks down quickly to fluoride in the human body, and that its residue we are exposed to in food, albeit at seemingly low levels, is a toxic gas. The EPA had to set two tolerances for sulfuryl fluoride use as a food fumigant: one for fluoride, and one for sulfuryl fluoride.
Consumer Advocate Groups Take on the EPA
In 2002, the EPA granted Dow's request to use sulfuryl fluoride as a food fumigant. In response, FAN submitted formal Objections. The EPA responded two years later, in 2004, and said that FAN's objections were "moot" because Dow did not get permission from California to use the Experimental Use Permit.
But simultaneous with this response, the EPA granted Dow sweeping tolerances for several non-organic food commodities, and the following year they granted tolerances for all post-harvest, stored, and processed non-organic food.
In so doing, the EPA approved the highest fluoride levels for food in its history, and levels for a highly toxic gas on your food that, when inhaled, breaks down to fluoride in your body (EPA, 2004, 2005).
At every stage of Dow's requests and EPA approvals, the Fluoride Action Network (FAN) submitted comments and formal Objections and Requests for Hearings. Two excellent advocacy groups, the Environmental Working Group and Beyond Pesticides, joined FAN in these submissions and collaborated on each new development. Collectively these groups are known as the Objectors. On two occasions, the EPA requested the Objectors to consolidate their several Objections. It is the final consolidation that best describes them.
The Objectors secured a pro-bono lawyer from the firm Zelle, Hofmann, Voelbel, Mason & Gette. Perry E. Wallace, a law professor at American University, became the Objectors attorney and performed brilliantly as their counsel.
For more information about FAN's pesticide project and the campaign against sulfuryl fluoride, please see this project page.
Inaccurate Risk Assessments were the Basis for the Approval
There were many inaccuracies in the EPA's three Health Risk Assessments (2004, 2005, 2006), which were the basis for its approval of sulfuryl fluoride, and this was the focus of the Objections. In brief:
1. All three health risk assessments were based solely on the safety of the Maximum Contaminant Level Goal (MCLG) for fluoride in drinking water, which is 4 ppm.
The MCLG is a science-based determination of the level of a contaminant in drinking water below which there is no known or expected risk to health. The EPA's Office of Water set the MCLG for fluoride in 1986.
In March 2006, the National Research Council of the National Academies (NRC) released a landmark report on the toxicity of fluoride and stated that the MCLG for fluoride in drinking water is not protective of human health. Thus the basis for the safety of the EPA's approval of sulfuryl fluoride was thrown out the window.
2. Infants are at greatest risk, as the EPA's final health risk assessment allowed an infant ten times more exposure to sulfuryl fluoride than an adult.
The safe reference dose for infants was set at 1.14 mg/kg/day compared to the safe reference dose for adults of 0.114 mg/kg/day. This was the first time in EPA's history that infants (and children) were deemed less sensitive to a contaminant than adults!
It was also a clear violation of the Food Quality Protection Act, which states that children need more protection than adults in the approval process for pesticides.
3. Risks of brain damage are ignored.
In ALL the animals tested (rat, mouse, rabbit, dog) in Dow's experiments for chronic and acute exposure to sulfuryl fluoride, the damage to their brains was unusually severe. Sulfuryl fluoride attacked the white matter of the brain and necrosis (cell death) and vacuolation (holes in the brain) were commonly observed.
And while the EPA stated that Dow would have to perform a Developmental Neurotoxicity Test with rats, they withdrew this mandate behind closed doors. One of the reasons Dow gave for a waiver of this mandate was "Animal welfare concerns (1500 to 4000 animals)."
Rather disingenuous considering sulfuryl fluoride is targeted to kill rats!
4. Risks to bone health are ignored.
Dow performed all the animal tests and curiously only two observations were made on bone effects. This is of some interest, as high levels of fluoride, as used in Dow's animal tests, are known to concentrate in and damage your bones.
First, Dow's scientists found no chromosomal effects on bone.
And the second observation, during Dow's two-year carcinogenicity test on rats, was atrophy in a variety of tissues, including bone. And even though there was a 100 percent mortality rate in the 80-ppm group, (the last animal died between day 701-707, California EPA, 2005, page 42), the results were deemed acceptable…
Anyone who has followed this issue knows the most contentious unanswered question: Does fluoride cause osteosarcoma?
In 1990 the National Toxicology Program reported a dose-response curve in osteosarcomas among fluoride-treated male rats. The failure to carefully look for sarcomas in the bone must be viewed as a significant oversight in Dow's study and with EPA's approval of it as a food fumigant.
Legal Levels of Fluoride in Food
In 2005, the EPA approved a legal residue level of 70 ppm for fluoride in all but a handful of processed non-organic foods. They also approved a 900-ppm residue level of fluoride in dried eggs – and approximately one-third of all eggs used are dried!
After receiving comments from the Fluoride Action Network as to the absurdity of such a high level – equivalent to a pea-sized dab of toothpaste that we are told to spit out, NOT swallow – EPA withdrew this tolerance, but didn't state the fluoride residue it would permit…
Other high levels include 125 ppm for wheat flour and 130 ppm for wheat germ.
In a 2005 health risk assessment, the EPA calculated that sulfuryl fluoride would be the second-largest source for fluoride exposure after fluoridated drinking water.
The EPA now says that that our fluoride exposure to food fumigated with sulfuryl fluoride is minimal. But the one thing that didn't change is the legally permitted fluoride residue tolerances.
A letter to Chemical & Engineering News (C&EN), published February 8, 2011, states that the fluoride residues from sulfuryl fluoride were negligible. C&EN printed a response on May 2 from the director of the Fluoride Action Network, which noted:
"… EPA set a fluoride tolerance for wheat flour at 125 ppm. That is certainly not negligible as a simple calculation will show. Three slices of bread (about 75 g wheat) made from wheat flour at 125 ppm fluoride would contain 9 mg of fluoride. For a 25-kg child this would produce a dosage of 0.36 mg/kg, which exceeds the dosage that can cause acute toxicity…"
The Russian roulette that consumers unknowingly play is this: not all stored and processed non-organic foods are fumigated and there is no way to know which foods are.
All the consumer knows is that it is legal for these foods to have very high levels of fluoride residues. So the end result is woe to the consumer who eats food fumigated with sulfuryl fluoride, as they may receive an acute exposure that will either give them a miserable stomachache, or, if lucky, they'll vomit.
It's estimated that for a healthy individual, 50 percent of fluoride consumed or inhaled is retained in the body, primarily in your bones. With an estimated half-life for fluoride of 20 years in the body, vomiting is the very best option...
Cryolite is another food pesticide with a uniform fluoride tolerance of 7 ppm.
Cryolite is used in the growing of all berries (blueberry, strawberry, etc.), and most, if not all, fruits and vegetables, and is the main source for fluoride levels in fruit drinks, food and wine. (See the list of all fluoride tolerances.) The EPA has also solicited public comments on a new registration review of Cryolite, which was due on May 30.
Victory! Ban on Sulfuryl Fluoride as Food Fumigant Granted
In 2010, the Objectors' attorney made several demands to the EPA to respond to the Objections, the Requests for a Hearing, and the Petition (Wallace, Apr. 2010, Aug. 2010, Nov. 2010). Just days before the Objectors were to sue for a response, the EPA finally announced that they granted all of their Objections.
According to the EPA's General Counsel for the Office of Pesticides, it was the first time in its history that it had done so.
The EPA announced on January 10, 2011, that it was proposing a phase-out ban on the use of sulfuryl fluoride. This was unprecedented and an enormous credit to the EPA's new administrator, Lisa Jackson, and to those in the Pesticides division who stood up for sound science and resisted the enormous lobbying effort by Dow.
Three days prior to this decision the Department of Health and Human Services used the fact that "41percent among adolescents aged 12-15" now have dental fluorosis as one of its reasons to propose a lowering of the fluoride level in fluoridation schemes. It's a great start, but the fight is far from over.
In the Works… Testing Food for its Fluoride Content
The Fluoride Action Network wants to launch a project to test various foods (including dog food) for its fluoride content, and to post the levels in the foods tested online. Unfortunately, so far they've been unable to find an EPA-approved laboratory in the U.S. to do the tests.
The head of one laboratory told FAN's pesticides director, "It's easier for us to test the fluoride levels in hazardous waste than to test for fluoride in corn flakes."
At this point in time, the public cannot independently verify the levels of fluoride in their non-organic and organic food. And this is important, not just from the standpoint that a fluoride fumigant may have been used on a conventionally-grown food, but many organic processed foods, such as soups and beverages, are made with fluoridated water.
How to Reduce Your Exposure to Fluoride
Although not discussed in this article, the health effects of fluoride ingestion are numerous. For a list of documented health effects, please see FAN's Health Effects Database.
The science is quite clear: Fluoride should NOT be ingested. So, first of all, don't drink fluoridated water. You can remove about 80 percent of the fluoride from your drinking water using a reverse osmosis (RO) filter. It is really hard to remove all of it with virtually any commercial filter. If you are concerned about fluoride the BEST solution is to help the Fluoride Action Network in their campaign to remove it from the water supply entirely.
As discussed above, you are exposed to fluoride from many sources other than the obvious lineup of toothpastes and mouth rinses (which I recommend using fluoride-free versions of as well). Far less obvious sources of fluoride, which I highly recommend avoiding, include:
✓ Non-organic foods (to avoid pesticide residue)
✓ Food and beverages processed with fluoridated water, including organic processed foods and beverages
✓ Mechanically de-boned meat
✓ Pharmaceutical drugs, especially SSRI antidepressants and fluoroquinolone antibiotics like Cipro
✓ Soy baby formulas
✓ Instant tea
✓ Processed breakfast cereals
✓ Soda and fruit juices
You're even exposed to fluoride through air pollution! For more information about airborne fluoride pollution, please review FAN's Fluoride Pollution page.
What You Can Do TODAY!
The Fluoride Action Network has a game plan to END water fluoridation in both Canada and the United States, and this Fluoride Awareness Week will hopefully bring us a lot closer to that goal by spreading mass awareness. Our fluoride initiative will primarily focus on Canada since 60 percent of Canada is already non-fluoridated. If we can get the rest of Canada to stop fluoridating their water, we believe the U.S. will be forced to follow.
Please, join the anti-fluoride movement in Canada, New Zealand and the United States by contacting the representative for your area below.
Contact Information for Canadian Communities:
- If you live in Ontario, Canada, please join the ongoing effort by contacting Diane Sprules at email@example.com.
- The point-of-contact for Toronto, Canada is Aliss Terpstra. You may email her at firstname.lastname@example.org.
Contact Information for American Communities:
We're also going to address three U.S. communities: New York City, Austin, and San Diego:
1. New York City, NY: With the recent victory in Calgary, New York City is the next big emphasis. The anti-fluoridation movement has a great champion in New York City councilor Peter Vallone, Jr. who introduced legislation on January 18 "prohibiting the addition of fluoride to the water supply."
A victory there could signal the beginning of the end of fluoridation in the U.S.
If you live in the New York area I beg you to participate in this effort as your contribution could have a MAJOR difference. Remember that one person can make a difference.
The point person for this area is Carol Kopf, at the New York Coalition Opposed to Fluoridation (NYSCOF). Email her at NYSCOF@aol.com . Please contact her if you're interested in helping with this effort.
2. Austin, Texas: Join the effort by contacting Rae Nadler-Olenick at either: email@example.com or firstname.lastname@example.org, or by regular mail or telephone:
Austin, Texas 78713
Phone: (512) 371-3786
3. San Diego, California: Contact Patty Ducey-Brooks, publisher of the Presidio Sentinel at email@example.com.
Contact Information for New Zealand Communities:
- New Zealand: Contact Mary Byrne if you would like to be involved in stopping fluoridation in New Zealand. Mary would like to hear from you! Email her at: firstname.lastname@example.org
In addition, you can: