EPA: the MCLG - fluoridation connection
THE FLUORIDE ACTION NETWORK
FAN Bulletin #570: EPA: the MCLG - fluoridation connection.
April 12, 2006
Dear All,
For those of you who, like me, are incensed by the way that officials from the CDC, ADA and state Health Departments are "spinning" the NRC report to suggest that there is no relation with its findings and water fluoridation, here is another piece of ammunition from the US EPA itself -i.e. straight from the horse's mouth as it were.
This is what EPA scientists stated - in a recent health risk assessment performed for sulfuryl fluoride (January 2006)* - about the connection between the 1985 MCLG (4 ppm) and water fluoridation:
"Fluoride Anion: In assessing the risks associated with expsoure to fluoride, HED has relied on the toxicological assessment completed by the Agency's Office of Water (this is referring to the determination of the MCLG in 1985, PC). That assessment identified crippling skeletal fluorosis as the end point of regulatory concern and determined that a value of 8 mg/day is protective against skeletal fluorosis without being so low as to negate the beneficial, cavity-fighting effects of fluoride exposure." (my emphasis, PC)
Reference: "Human Health Risk Assessment for Sulfuryl Fluoride and Fluoride Anion Addressing the Section 3 registration of Sulfuryl Fluoride as Fumigant for Foods and Food preocessing Facilities. PP# 3F 6573" Office of Prevention, Pesticides and Toxic Substances, January 18, 2006, page 4.
www.fluoridealert.org/pesticides/sf.hra-jan18.2006.pdf
To appreciate that 8mg/day and the MCLG of 4 ppm are one and the same thing, here is the way the EPA derived the MCLG of 4 ppm in 1985:
Step 1: 20 mg per day needed to produce crippling skeletal fluorosis in industrial workers.
Step 2: Apply a safety factor of 2.5 to account for the range of sensitivities in the whole population - 20 mg/day divided by 2.5 = 8 mg/day.
Step 3: Assume that people drink 2 liters of water per day. 2 liters of water at 4 mg/liter ( 4ppm) would give a dose of 8 mg. Thus the MCLG is set at 4 ppm.
In a previous bulletin, I have explained how this derivation is flawed on no less than 5 counts, three of which the NRC panel has addressed:
1) Crippling skeletal fluorosis is not the only end point of concern, and when other end points are considered (severe dental fluorosis; phase 2 of skeletal fluorosis and bone fractures).
2) Water is not the only source of fluoride exposure.
3) Many people drink far more water than two liters per day.
The NRC panel concluded that the MCLG should be lowered from 4 ppm.
Moreover, if the NRC exposure analysis in Chapter 2 is examined, it is clear that there are many people - especially diabetics - who are already exceeding the current "safe" limits (based upon the MCLG of 4 ppm). When the MCLG is lowered this number will greatly increase.
What the NRC panel did not do - correctly in my view - was to allow any notion of the so-called benefits of fluoridation to interfere with their analysis of what level might cause health problems. Unfortunately, this correct approach to addressing an MCLG has been deliberately misinterpreted by the ADA-CDC spinners to suggest that their considerations had no relevance to fluoridation at 1 ppm. This is clearly nonsense.
Having thrown the ball back into the EPA's court by asking them to do a health risk assessment, the key question is whether - ONCE AGAIN -the EPA (the Office of Water) will work backwards and choose a standard which will attempt to protect the water fluoridation program. If they do this it will be illegitimate - but this time there will be many more people watching. The EPA should be setting goals to protect the citizens' health not one to protect an ill-conceived policy. Considerations of possible "benefits " might come into play when considering the MCL (the enforceable standard). At which point any rational person - not trapped by the dental lobby - would attempt a risk-benefit analysis. A risk benefit analysis should wipe water fluoridation off the face of the earth.
Paul Connett
*I will return to the Pesticide Division's latest corruption of science in the service of DOW in a future bulletin.