On December 7 and 8, the EPA's National Drinking Water Advisory Council held its annual meeting at their headquarters office on Constitutional Avenue in Washington, DC. After sitting through lengthy discussions all day on December 7 (in which the word "fluoride" was not mentioned once), Bill Hirzy PhD, Ellen Connett and myself (Paul Connett) finally got our chance to speak during the Public Comment period on Friday morning, Dec 8.
We were told that we had three minutes each to say what we had to say. When you bear in mind all the things that we wanted to say about fluoride's neurotoxic effects - which the EPA's Office of Water has largely ignored for over 20 years - and their recent cavalier declaration that further review of fluoride's toxicity was a "low priority," three minutes was grossly inadequate. In fact, not one of us got very far before we were cut off. Here as best we can recall it are what each of us had to say in our 3 minutes before we were cut off.
Dr. Bill Hirzy reports:
I cited my 27-year career as the highest ranking chemist/senior scientist at EPA headquarters in the Toxics Office and my study of fluoride toxicity dating from 1986. I pointed out the study Dr. Connett, three other Fluoride Action Network (FAN) supporters and I published in December 2016, and how it predicted a substantial IQ difference would exist between U.S. children with slightly higher fluoride exposure and those with lower exposure. I added that "a study funded by federal public health agencies (Basash et al., 2017) - including EPA - recently confirmed FAN's prediction of IQ losses among children in Mexico whose pregnant mothers' urine fluoride levels were slightly higher than mothers with lower fluoride levels. And that FAN's prediction of lower IQ associated with fluoride exposure had been transmitted several times to EPA, orally and in writing, since 2014."
I was cut off at that point.
I was going to point out that the groups of children born each year - about four million - would suffer an aggregate lifetime income loss of at least about $100 billion, based on published data on the connection between IQ and income; that this was an annual loss to the U.S. economy. I also stated, at the very end of the meeting (after the chairperson had gaveled the meeting to a close) that I realized that EPA was - in the federal power structure of cabinet vs. non-cabinet agencies - a junior partner to the Department of Health and Human Services, the parent agency of the U.S. Public Health Service and its CDC/Oral Health Division. I entreated the EPA officials there to nevertheless display some courage, "buck it up," I said and "show the courage that EPA's Union employees have shown in dealing with fluoride."
Ellen Connett reports:
This is what I was able to say before I was cut off (section 1). I have included three other points (sections 2, 3 and 4) I wasn't able to say. After introducing myself to the committee and mentioning that we are sisters and brothers on this issue as we all work for safe drinking water, I said that the Office of Water has a problem with not being responsive to the public:
- At the meeting on December 7, Eric Burneson, Director of the Standards and Risk Management Division of the Office of Ground Water and Drinking Water, stated that the Third 6-Year Review of the National Primary Drinking Water Regulations was published on January 11, 2017. He didn't mention that it was published as a Proposed Rule in the Federal Register and that public comments were solicited. In their review of fluoride, EPA's Office of Water determined that fluoride was "a lower priority that would divert significant resources from the higher priority candidates" and they classified fluoride as Low priority and/or no meaningful opportunity.
FAN disagreed with EPA's decision and we delineated our concerns in a substantive submission to EPA dated March 13, 2017. http://fluoridealert.org/wp-content/uploads/fan-submission-to-epa.3-13-17-final.pdf We stated that "fluoride poses unacceptable risks to the fetus, infant, child, and adult". Along with our submission we included over 200 animal and human studies on the neurotoxicity of fluoride that were published since 2006 - the year the National Academies published a report on the toxicology of fluoride. Included in the studies we sent to EPA were 50 IQ studies that reported an association of fluoride exposure with the lowering of the IQ of children in China, India, and Iran. In November, I spoke with Richard Weisman of the Office of Water to ask about the status of the Proposed Rule. He said that he would ask his supervisor and would get back to me, which he did. He said that EPA will not be responding to our submission because a final determination was made not to include fluoride for review and that the next time EPA looks at fluoride for the Safe Water Drinking Act will be six years from now in 2023. In the summary of this proposed Rule it stated: "This document is not a final regulatory decision, but rather the initiation of a process that will involve more detailed analyses of factors relevant to deciding whether a rulemaking to revise an NPDWR should be initiated." This was a Proposed Rule that solicited Public Comment, yet we were denied a response on the basis that a decision has been made without any input from the public or notice to the public. I ask this committee, what would you do?
I was cut-off here.
In 2011 EPA released two risk assessments on fluoride in relation to a proposal to lower the level of fluoride to .7 ppm in fluoridation schemes and they solicited public comment on their assessments. FAN, as did others, submitted two (here and here) detailed and substantive comments pointing out the errors in their assessments and that the new .7 ppm fluoride in fluoridated water was still not protective of human health. EPA never responded to the comments they received on these assessments.
In September 2015, we submitted a substantive report to the Environmental Justice Interagency Working Group http://fluoridealert.org/wp-content/uploads/ej-report-9-25-15.pdf (which EPA is part of) on the issue of Fluoride. We received neither an acknowledgment nor a response, even though it took us over a month to write, and it is the only report we know dedicated to this issue. For example, A January 10, 1962 internal memorandum by a top Public Health Service official, in connection to the first fluoridation trial, revealed that "negroes in Grand Rapids had twice as much [dental] fluorosis than others." This was never shared with the Black Community then, or even after the CDC reported in 2010 that African Americans had significantly higher levels of the more severe forms of dental fluorosis.
In June 2016, we released a report titled Toxic Waters, Broken Laws http://fluoridealert.org/articles/texas_fluoride_violations/ on a FAN investigation by Doug Cragoe and Michael Connett that found Texas regulators failed to notify residents under the Safe Water Drinking Act of both high arsenic and high fluoride levels in their drinking water.
Dr. Paul Connett reports:
Before I started, I pointed out to the Chairwoman that we were already an hour ahead of schedule and as they had set aside 45 minutes for public comment and as there didn't seem to be many others who wanted to speak beside ourselves, I could see no reason why they should limit the three of us to 3 minutes. I explained that we had come a long way to get to this meeting. That didn't work: 3 minutes maximum. I even threw in the fact that there were powerful people in this country who would like to do away with the EPA altogether and that one day they might need the public to speak up for them, especially environmental activists like ourselves. That didn't work: 3 minutes maximum.
I reminded them again that they had set aside 45 minutes for public input - and that I realized that they wanted to give everyone a chance to speak - but how about when everyone has had their chance they come back to us to let us complete our statements? That still didn't work: 3 minutes maximum. At this point I got the feeling that I had got into a power-play between the chairperson and myself. She had assumed a rigid position and was not willing to yield a millimeter (or millisecond!) and I was getting hotter and hotter under the collar. And thus with the saliva draining from my mouth I gave my comments:
I titled my presentation, "The EPA is not Doing Its Job on Fluoride"
In Jan 2017, the EPA declared that further review of fluoride's toxicity was considered a "low priority." I think that is a very candid assessment of the EPA's attitude towards protecting the public from fluoride since 1986, when the EPA established a highly questionable MCLG (and MCL) for fluoride at 4 ppm. For us, the appearance is that the EPA is more interested in protecting the outdated practice of "water fluoridation" than in protecting the health of the American people. How can the EPA treat this matter so lightly? How can the EPA sanction - via its indifference - the deliberate addition of a developmental neurotoxin to the drinking water of millions of children and pregnant women -
Without control of dose, and without any monitoring of the individual?
For which families of low-income are less able economically to avoid the substance? Are low-income families of low priority? For which communities of color are more likely to be more vulnerable to fluoride's toxic effects? Are communities of color of low priority? The last children who need their IQ lowered in the USA are children from low-income families, precisely those being targeted by the pro-fluoridation lobby. Can the EPA provide a body of solid scientific evidence that negates the concerns about fluoride's neurotoxicity? And addresses the recent important study published in Environmental Health Perspectives, which Dr. Hirzy talked about.
Your actions and concerns on both lead and perchlorate do you proud but they stand in huge contrast to your indifference and unscientific attitude towards fluoride: even though fluoride like lead is neurotoxic, and even though fluoride ion like the perchlorate ion interferes with thyroid function. The EPA should not be putting an outdated practice (policy) above the mental and intellectual development of millions of children...
I was cut-off here.
EPA has a shocking track record of failing to protect the public from fluoride. The current allowed fluoride levels still stand at the values set in 1986 - despite all the evidence of harm that has emerged since then and despite the NRC panel in 2006 (in a review the EPA paid for!) concluding that this value was unprotective of health.