Chemically sensitive and concerned about fluoride?

FSANZ online 2006 “Fluoride in foods” shows most foods presently contain very little fluoride (unless prepared with fluoridated water). Most tree nuts and peanuts do not contain measurable fluoride levels but when fumigated, will be allowed to contain 30mg/kg (equivalent to 30 ppm; water fluoridated at 1ppm).

FSANZ online 2006 data also shows dried apricots, fresh grapes and apples do either not contain fluoride, or very little fluoride, yet fumigated dried fruits will now be allowed to contain 5 ppm (5 times more than Fluoridated water).

JMPR (Joint FAO/WHO Meeting on Pesticide Residues) 2005 states sulfuryl fluoride is approved for “food purposes” in the US, also UK, Germany and Italy, but in the UK, Gemany and Italy, structures must be emptied of food before fumigation.

Currently APVMA is not allowing sulfuryl fluoride to be used on “processed foods” such as flour. Flour has a much greater surface area compared to its volume than the whole grains that the flour is made from, thus if flour is fumigated it absorbs a lot more sulfuryl fluoride resulting in very high levels of fluoride ion.

Although APVMA does not propose letting flour and other processed foods be fumigated at this time, APVMA has put forward recommended MRLs of 120 ppm for fumigated wheat germ and a MRL of 75 ppm for fumigated maize flour if processed foods fumigation allowed at a future date.

In the US the EPA has appoved fluoride MRLs of 125 ppm in flour and a massive 900 ppm in dried eggs (common fluoride toothpaste contains 1000 ppm fluoride).

The proposed approval for use does not preclude mutiple fumigations.

There is a dearth of data provided on toxicity of fluoride by the oral route, one study that oral toxicity claims are based on, is an unpublished Anonymous study from 1959 with rats consuming fumigated foods. Comments include that it was prior Good Laboratory Practice. Another study was using ingested corn oil that had had sulfuryl fluoride bubbled through. Comment on this study was that it was difficult to interpret.

Almost all studies on sulfuryl fluoride are animal inhalation studies and the Australian Office of Chemical Safety Health Risk Assessment says that the absence of suitable studies with oral exposure (as in foods) is the main deficiency.

There were apparently no cancer studies required to register sulfuryl fluoride as a pesticide in the US.

There is no known antidote to over-exposure to sulfuryl fluoride (Dow MSDS)

Sulfuryl fluoride is scheduled as an S6 poison, but the fluoride chemical mostly used for water fluoridation in Australia is classed as an S7 poison. There is reasonable argument that sulfuryl fluoride should be scheduled as S7.

Sulfuryl fluoride is 3.2 times heavier than air. After fumigation, the gas is released, often blown out with fans and potentially a risk to humans and animals in the nearby vicinity. Being heavier than air, the gas could flow to lower areas. In small Australian country towns silos are often in the heart of populated areas.

Sulfuryl fluoride is colourless and odourless and the Australian Office of Chemical Safety Assessment and advice and recommendation to APVMA was that a suitable stenching agent (a warning gas such as Chloropicrin, a tear gas) MUST be used with sulfuryl fluoride, yet APVMA’s proposed label for use shows instead that it “MAY” be used. There is NO compulsion to use a safety warning agent.

In the US since 1993 there have been 13 human deaths resulting from entry into fumigated premises and 335 reports of adverse health effects. No data has been provided on how many deaths there have been worldwide in the last 40 years it has been used as a fumigant for termites.

Fluoride has never been shown to be nutrient, vitamin or mineral necessary for life, yet the NHMRC has listed it as a nutrient depite the lack of any human or animal studies showing that it is necesary for life, or good health. It is not even necessary for good teeth, you can have perfectly good teeth and no decay without ever having consumed fluoridated water, fluoride supplements or having used fluoridated toothpaste.

The NHMRC classed fluoride as a “nutrient” only because of a belief that fluoride reduces decay. There are now many children’s dental surveys that show the same low levels of tooth decay in areas without water fluoridation as in areas with water fluoridation.

The NHMRC has set recommended upper limits of intake for their self declared nutrient fluoride of 10mg fluoride/day for adults and 1.3 to 2.2 mg fluoride a day for children aged 1 to 8 years old. A child drinking 2 litres of water a day if water is fluoridated at 1mg/L would already be getting 2mg a day and this would be before figuring in any fluoride ingested from any sources such as from swallowed toothpaste, or dental treatments or fluoridated antibiotics, air pollution etc.

Adults who are big tea drinkers can already be consuming amounts of fluoride from their favourite beverage as tea is a peculiar plant that takes up fluoride from soil. Adults who are outdoor workers and who drink lots of water could already be breaching intake levels of 10 mg/day just from fluoridated water and tea.

The NHMRC in 1991 and 1999 said that health and safety studies on water fluoridation should be done and that total fluoride intake studies should be done and bone fluoride estimations should be done. These studies have not been done but FSANZ is slated to do fluoride intake modellling studies next year, but this would almost certainly be after ProFume is approved for use.

FSANZ has already done a DIAMOND (DIetAry Modelling Of Nutritional Data) computer modelling of sulfuryl fluoride to estimate the chronic (long term) estimated dietary exposure of the general population, but this data was not to be released to the public citing “Commercial Confidence” It is not known if a model of fluoride exposure resulting from sulfuryl fluoride use has been done.

Considering that inorganic fluoride is the major and cumulative residual of sulfuryl fluoride, APVMA should had considered the National Research Council (US) report from March 2006 that reported on many adverse health effects linked to fluoride in drinking water (regardless from artificial fluoridation or from natural contamination up to 4.0 ppm in a very small percentage of water supplies) This recent report does not appear to have been considered.

APVMA should have considered the Elise Bassin paper in “Cancer Causes Contol” from 2006 that links Osteosarcoma to fluoride in drinking water (a link previously reported in other human and animal studies).

APVMA should have also considered the American Dental Association and the Centers for Disease Control and Prevention advisories from late 2006 that infants under 12 months of age not consume fluoride (mainly as in fluoridated water) as part of APVMA’s approval decision process. The advisories resulted from the NRC report with recognition that infants under 12 months of age are at risk of dental fluorosis from fluoride overdose.

APVMA admits that that there may be a transfer of fluoride ion into milk, meat and other commodities as a result of fumigated grain being fed to livestock, but no infomation has been provided.

Countries that do not allow sulfuryl fluoride residues, or have lower allowable levels could be a problem for trade in fumigated food commodities.

APVMA has said that it would be up to Dow to alert all stakeholders of potential risk with residues and trade.

Sulfuryl fluoride is being promoted as a more “greenhouse friendly” replacement for methyl bromide, yet no carbon dioxide equivalent comparison data for sulfuryl fluoride and methyl bromide is yet available from APVMA and apparently was not considered. Another sulphur-fluoride gas, sulfur hexafluoride is now being recognized as potentially the worst greenhouse gas, being 23 thousand times more potent than carbon dioxide.

The California Department of Pesticide Regulation considers only limited information is available regarding any potential environmental breakdown products of sulfuryl fluoride and also that it has a long, or very long lifetime and should, therefore be considered as a greenhouse gas.

APVMA website home page

APVMA Sulfuryl Fluoride Gazette Notice (PDF, 31KB – you can also download it here)

APVMA Sulfuryl Fluoride Public Release Summary (PDF, 374KB – you can also download it here)

FSANZ “Foods that contain Fluoride” webpage
FSANZ fluoride content expressed as microgram per 100 gram (ug /100g) For conversion purposes 100ug/100g is equivalent to 1mg/kg or 1 part per million

FLUORIDE ACTION NETWORK SULFURYL FLUORIDE PAGE

FLUORIDE ACTION NETWORK EPA FLUORIDE MRLS

JMPR 2005 (FAO/WHO) (PDF, 317KB – you can also download it here)

NHMRC

HAGUE ASSESSMENT of Sulphuryl difluoride (another name for Sulfuryl Fluoride) (PDF, 258KB – you can also download it here)

VIKANE (the product name for termite fumigation) – a cause for concern (PDF, 39KB – you can also download it here)