Sufuryl fluoride UPDATE:
EPA selected sulfuryl fluoride for a registration review and and has released several new documents, including a new Human Health Risk Assessment for public comment.
• See FAN's Submission to EPA on August 24, 2009
On June 10, Dow AgroSciences petitioned EPA for a 3-year Experimental Use Permit for a first-time use of sulfuryl fluoride as a pre-plant fumigant.
• See FAN's submission of July 10.
-- The Sierra Club organized a sign-on petition to EPA to deny the permit on the basis that sulfuryl fluoride has 4,780 times the global warming impact of carbon dioxide.
-- July 13: Dow Pitching New Pesticide That Doubles as an Extraordinarily Potent Greenhouse Gas (Press release from Pesticide Action Network)
The
Campaign Against Sulfuryl Fluoride
Molecular structure of sulfuryl fluoride
Produced
exclusively by Dow AgroSciences
Three groups -Fluoride
Action Network, Environmental
Working Group, Beyond
Pesticides- are challenging US EPA on its approval
of sulfuryl fluoride as a food fumigant (trade name ProFume®).
The groups are represented, pro-bono, by Zelle, Hofmann,
Voelbel, Mason & Gette's attorney Perry E. Wallace,
Esq., a law professor at American University. The groups
have submitted three formal Objections and Requests for
an Evidentiary Hearing (2002, 2004, 2005).
• Documents
on Sulfuryl Fluoride --
This compilation represents most of the essential documents
that pertain to the groups' Objections to sulfuryl fluoride tolerances. A
tolerance is the legal amount of a pesticide residue
allowed in and/or on specific foods.
Below are the most recent documents:
• JANUARY 17, 2007. Memorandum to USEPA, Legal
Standard for Grant of Hearings on Objections under Federal Food,
Drug, and Cosmetic Act Section 408. This was submitted by
the group's attorney, Perry Wallace, Esq., in response to Dow
AgroSciences October 31, 2006, submission to USEPA, that
argued against EPA granting an evidentiary hearing.
• NOVEMBER 2006. At the request of
EPA, the groups submitted a consolidation of their Objections.
This submission is the most succinct representation of the groups' arguments
for EPA to grant them an evidentiary hearing.
• JUNE 2006. The groups submittted
a Petition to US EPA to revoke all tolerances for the use of sulfuryl fluoride
(ProFume®) as a food fumigant. This Petition was in response
to the finding by the National Research Council's report (Fluoride
in Drinking Water) that the Maximum Contaminant Level Goal
(MCLG) of 4 ppm fluoride in drinking water was not protective
of human health. EPA used this MCLG in its health risk assessments
on the basis that it was "safe."
• AUGUST
2006. The Office of the NY State
Attorney General submitted
comments to EPA in support of the groups' Petition to stay
sulfuryl fluoride tolerances.
• US: List
of all foods with fluoride pesticide residue tolerances - ( pdf version)
Phosphate
Fertilizer & Water Fluoridation
The primary
use of phosphate rock is in the manufacture of phosphatic
fertilizer. Phosphate fertilizers are produced by adding
acid to ground or pulverized phosphate rock (ref)
- either sulfuric
or phosphoric acid. Significant quantities of fluoride
(hydrogen fluoride and silicon tetrafluoride) are released
in this process due to an estimated 2 to 4% of fluoride
in the phosphate rock. These fluorides are captured
in the pollution control "scrubbers." Hydrofluorosilicic
acid is the waste product from the "scrubbers"
that is used to fluoridate approximately 90% of US public
drinkng water systems.
FYI: "Phosphate
rock contains radionuclides in concentrations that are
10 to 100 times the radionuclide concentration found
in most natural material. Most of the radionuclides
consist of uranium and its decay products. Some phosphate
rock also contains elevated levels of thorium and its
daughter products. The specific radionuclides of significance
include uranium-238, uranium-234, thorium-230, radium-226,
radon-222, lead-210, and polonium-210. (Ref).
Trace levels of these radionuclides and several heavy
metals will be in the hydrofluorosilicic acid added
to public drinking water systems. For more info, see phosphate
fertilizer industry
THE HONEYBEE
•
Dec 4, 2007: Hawaii's Department of Agriculture says fipronil killed bees in Moloa's, Kauai.
•
July 11, 2007 - EPA failed to consider
the "high" toxicity to bees by contact (not
dietary) exposure to the insecticide Indoxacarb when it approved approximately 130 new food tolerances. (See EPA's
Fact sheet on Indoxacarb
for toxicity to bees, pp 14-15). Indoxacarb is a potent neurotoxiicant.
On July 23, FAN asked EPA for its reasons why it didn't consider
indoxacarb's effects on bees. Also, a 2005 study reported that
indoxacarb was harmful to the Asian lady beetle, which is considered a
beneficial insect in agriculture.
• May 28,
2007 - Neonicotinoids,
such as fluorinated fipronil, a suspect in honeybee colony collapse disorder.
• Catastrophic Bee Colongy Collapse may not be affecting organic hives.
Researchers are struggling to find the causes of this mysterious
collapse. A crucial element of this story, missing from reports in the
mainstream media, is the fact that organic beekeepers across North
America are not experiencing devastating colony collapses...
SEE: "Organic
Bees Are Thriving While Pesticide Intensive Conventional
Bee Hive Colonies Are Collapsing." Note
from FAN: The media reports that intensive tests are
underway to find the source of the honeybee "colony
collapse disorder." Theories for this devastating
collapse range from the use of pesticides to cell phones. If it were a neurotoxic
pesticide (disrupting the neurons that enable bees to
find home) it would have to be in wide-spread use across
the country. Some have mentioned the rise in cell phone
use: radiation from mobile phones may interfere with
the bees' navigation systems.
Fluoride Pesticides
The
concern centers on the fluoride ion's toxicity, persistence,
and bioaccumulation in humans, wildlife, and soil. The
main pesticides are:
• Cryolite:
(sodium aluminum fluoride) - mainly used on grapes, fruits,
and potatoes. EPA allows fluoride tolerances of 7 ppm,
except for kiwifruit, which has a residue tolerance of
15 ppm.
•Sulfuryl
fluoride is the most immediate and important pesticide
issue for the FAN Pesticide Project. This acutely toxic
fumigant received its first-time approval for use on stored
food commodities (raw and processed) in the US in January
2004. This approval allows the highest levels of fluoride
residue levels in food in the history of the EPA. FAN,
together with Beyond Pesticides, submitted formal objections to EPA on this approval (see press
release). See the food tolerances approved and petitioned for as
of July 15, 2005.
• Sodium
fluoride - its only known use is in wood preservatives(railroad ties and utility poles).
However, sodium fluoride was used as a "List
4 Inert" until USEPA revoked that use in September 2005. Prior to its revocation, sodium fluoride, as a "List 4 Inert," was approved
for use in the US National Organic Program administered
by the US Department of Agriculture (USDA). In 2000, approximately
125 individuals contacted USDA requesting that the use
of sodium fluoride be denied in organic agriculture -
all to no avail. UPDATE: On October 10, 2007, USEPA released a series of documents in preparation for a final risk assessment.
Fluorinated Pesticides
• The majority of the pesticides in our data base are
fluorinated. We had used the term "organofluorine"
to describe organic pesticides containing fluorine in their
chemical formula. However, this term is not precise, as
the majority of pesticides contain other halogens, primarily
chlorine. Seven pesticides in our data base contain three
halogens in their chemical formula: fluorine, bromine, and
chlorine.
• The toxicity of the
fluorinated compound is not due to the release of a free
fluoride ion, but to the particular molecular structure
of the compound. From our research to date it appears that
fluorinated pesticides intensify pesticidal and biological
activity. Animal studies available
on pesticides with fluorine + bromine in their chemical
formula consistently report severe brain effects.
The journal FLUORIDE = essential
reading
Published
quarterly by the International Society for Fluoride
Research (ISFR).
SUBSCRIPTION
FEE: US$51, Canadian$63, £28, Japan„5500,
€42, Australian$66, New Zealand$72, with a
10% discount for New Zealand.
CONTACT: Dr
Bruce Spittle
<spittle@es.co.nz>
de
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