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Most of the links to rvi.net/~fluoride were removed long before I shut the web site down in December.
.
I'd been checking Google regularly on fluoridation to see where I stood, and when #1 became #2 I checked to see who was linking to my site. Several were missing. A few weeks later I checked again and found the same thing. By the end of November there wasn't much to see. I decided there was little point in paying for another year's dial-up in Oregon with a too-small space for pages that no one will find with Google.
.
People removed the links and even blocked my email after Ellen Connett accused me of trying to "torpedo" FAN's sulfuryl fluoride pesticide project. It started last Summer when I posted a page on my site titled "Larry Moe and Curly take on EPA over pesticide residues" and notified FAN's lawyer he had been misled regarding EPA's methods.
.
I made the mistake of telling Paul, Ellen, and Michael Connett their many arguments about the "childhood RfD" and "the RfD for infants" were entirely erroneous because there is no separate RfD for infants. There is only one RfD for all humans. It represents the maximum allowable intake of fluoride which, taken on a daily basis over a lifetime, will not result in skeletal fluorosis.
.
I thought the people at FAN might want to fix their story rather than get laughed out of court. I was wrong. They don't want to fix it. I don't think they want anyone to know about it either.
.
At first I hadn't fully grasped all that was wrong with FAN's arguments about EPA's maximum allowable daily intake of fluoride — but knew what they believed was physically impossible. In their November 2006 submission to EPA the focus is on the Office of Pesticide Programs (OPP's) decision to increase the RfD for infants by a factor of ten.
.
Michael wrote: "While we think that the adult RfD should also be reduced (as we have detailed in our submissions), we have not made this the centerpiece of our argument since we believe that both the law (e.g. FQPA) and the specific circumstances of this case (e.g. EPAs repeated alterations of the childhood RfD) underscore the tactical effectiveness of focusing on the childhood RfD."
.
Apparently, Michael doesn't understand that applying the additional 10x safety factor normally required by the Food Quality Protection Act (FQPA) would lower the RfD for everyone. It would not produce separate RfDs for infants and children.
.
The Connett's either don't understand or are unwilling to admit that the 0.114 mg/kg/day RfD for fluoride represents the maximum "safe" total daily intake of fluoride for humans throughout their lifetime. It represents the maximum allowable quantity of fluoride in the U.S. diet (including toothpaste and air pollution).
.
We don't have individual pesticide residue tolerances based on the age and body weight of the consumer. Carrots fit for adults are considered fit for infants as well. Pears consumed by children age 1 to 2 years are also consumed by children age 6 to 12, as well as adults age 20-49. We eat the same fruits and vegetables, the same oatmeal, the same bread. If the fluoride is there for adults, it's there for children too. For dietary contaminants EPA sets the RfD at a point which is "safe" for those who consume the most food and water. They describe the risk for various age groups as a percentage of the maximum allowed for 70 kg adults. They do not establish multiple reference doses based on age and body weight.
.
EPA made no alterations whatsoever in the maximum allowable intake of fluoride for any population group. In fact, the Maximum Contaminant Level for fluoride in drinking water is also referred to by EPA as 0.114 mg/kg/day. It represents 2 liters of water with 4 ppm fluoride. The MCL hasn't changed for over twenty years.
.
Of course, a 7 kg infant who regularly drinks almost 8 liters of "optimally" fluoridated water (1 ppm) could get as much as 8 milligrams of fluoride daily (1.14 mg/kg/day), but skeletal fluorosis would not be the primary reason for concern.
.
Nonetheless, according to FAN the RfD for adults is 0.114 mg/kg/day, but EPA raised the RfD for infants to 1.14 mg/kg/day - 10 times as much! FAN wants EPA to reverse their decision. I'm sure they would — if they could — but since EPA didn't change the RfD they cannot undo the change.
.
This is not an insignificant part of FAN's various submissions to EPA.
.
On the contrary ... it is the only "legal" argument used by FAN. Unfortunately, it's EPA's Office of Drinking Water (ODW), and the Institute of Medicine's fraudulent No Observed Adverse Effect Level (NOAEL) which deserves FAN's attention — not EPA's Office of Pesticide Programs (OPP). Fix the MCL and NOAEL, and the RfD for fluoride would automatically drop by a factor of ten — if not more. In fact, OPP suggested that FAN contact ODW about their concerns. ODW set the MCL — not OPP. The MCL is equal to the RfD (i.e., both are 0.114 mg/kg/day).
.
In short, the maximum allowable fluoride intake hasn't changed for more than twenty years. DOW is using a small piece from a large pie that people have been eating for many decades. It isn't safe by any means, and it will expose virtually everyone to more fluoride than usual; but you can't change a regulation that doesn't exist. If, as Michael explained, FAN wants the RfD for infants to be no higher than the RfD for adults, you could say it's a done deal — the RfD is already the same for all humans and all of them have been infants at least once.
.
FAN's November 2006 submission to EPA states: "Before arguing why a lower RfD for children "is not necessary", OPP needed to first demonstrate that a higher RfD for children (when expressed in the relevant terms of mg/kg/day) is safe. OPP's failure to do this, and its failure to acknowledge the fundamental need to do this, represents a flagrant violation of standard protocol and basic toxicological principles." ... "On the face of it, OPP's assumption that the safe daily dose for adults will also be safe for infants and children -- irrespective of the difference in weight and sensitivity -- is absurd. It is the toxicological equivalent of assuming that, because 250-500 mg of aspirin is safe for an adult, that therefore the same dose of aspirin will be safe for infants as well. Objectors are not aware of any other instance in OPP regulatory history where the cardinal rule that bodyweight affects the impact of a chemical has been abandoned. Unprecedented actions warrant a high burden of proof. As described below, this burden of proof was not met by OPP."
.
FAN's lawyer wrote: "What makes EPA's decision to increase the RfD (from less than 1 mg/day for infants to 8 mg/day for infants) so arbitrary and capricious is that it was derived from the same starting point (the MCLG of 4 ppm in water) and no new scientific research was offered to justify the increase. The end result of these alterations is that EPA has promulgated an RfD for infants that is ten times higher than the initial RfD, and ten times higher than the RfD currently allowed for adults."
.
As long as the people who eat and drink the most (the adults) don't exceed 8 mg/day, neither will infants and young children. This has been the case with all pesticides and other toxic chemicals in our diet forever. One mg/day for a 7 kg infant is equal to 0.14285714 mg/kg/day, while 8 mg/day for a 70 kg adult is equal to only 0.114 mg/kg /day.
.
According to EPA's dietary fluoride anion exposure estimates, adult males age 20-49 currently ingest 2.742 mg/day, which is 34% of 8 mg. Infants under the age of 1 year ingest 1.152 mg/day, which is 14% of 8 mg. That means that if dietary fluoride levels were about three times those believed to be current today adults would just barely exceed their maximum allowable 8 mg/day. However, for an infant to reach 8 mg/day the quantity of fluoride ingested from foods and beverages would have to be almost seven times what it is today.
.
EPA's January 18, 2006 Human Health Risk Assessment states: "For fluoride risk assessments addressed in this document, the 8 mg/day value has been used in a manner analogous to a reference dose (RfD) and is referred to as such for ease of communication. We note that the previous human health risk assessment for sulfuryl fluoride (M. Doherty, 10/12/2004, D309013) expressed toxicology and exposure in terms of mg/kg/day in order to match the units used by the dietary exposure model. In this assessment, those values are being expressed in mg/day to better harmonize with the more typical units found in the open literature describing fluoride exposures. In both cases, the values listed are derived from the same toxicological data and conclusions."
.
Obviously, FAN's claim that EPA's Pesticide Division raised the "childhood RfD" from 0.114 to 1.14 mg/kg/day is ludicrous. It didn't happen.
.
Furthermore, it is inconceivable that Ellen, Paul, and Michael Connett haven't been able to understand their error regarding the non-existent RfD for infants. In the "final rule" for sulfuryl fluoride dated 2004 and 2005 EPA states: "EPA performs a number of analyses to determine the risks from aggregate exposure to pesticide residues. For further discussion of the regulatory requirements of section 408 of FFDCA and a complete description of the risk assessment process, see the final rule on Bifenthrin Pesticide Tolerances (62 FR 62961, November 26, 1997) (FRL-5754-7)."
.
See: http://www.epa.gov/fedrgstr/EPA-PEST/1997/November/Day-26/p30948.htm
.
EPA's Integrated Risk Information System describes the RfD here: http://www.epa.gov/iris/rfd.htm
.
Most of the links to rvi.net/~fluoride were removed long before I shut the web site down in December.
.
I'd been checking Google regularly on fluoridation to see where I stood, and when #1 became #2 I checked to see who was linking to my site. Several were missing. A few weeks later I checked again and found the same thing. By the end of November there wasn't much to see. I decided there was little point in paying for another year's dial-up in Oregon with a too-small space for pages that no one will find with Google.
.
People removed the links and even blocked my email after Ellen Connett accused me of trying to "torpedo" FAN's sulfuryl fluoride pesticide project. It started last Summer when I posted a page on my site titled "Larry Moe and Curly take on EPA over pesticide residues" and notified FAN's lawyer he had been misled regarding EPA's methods.
.
I made the mistake of telling Paul, Ellen, and Michael Connett their many arguments about the "childhood RfD" and "the RfD for infants" were entirely erroneous because there is no separate RfD for infants. There is only one RfD for all humans. It represents the maximum allowable intake of fluoride which, taken on a daily basis over a lifetime, will not result in skeletal fluorosis.
.
I thought the people at FAN might want to fix their story rather than get laughed out of court. I was wrong. They don't want to fix it. I don't think they want anyone to know about it either.
.
At first I hadn't fully grasped all that was wrong with FAN's arguments about EPA's maximum allowable daily intake of fluoride — but knew what they believed was physically impossible. In their November 2006 submission to EPA the focus is on the Office of Pesticide Programs (OPP's) decision to increase the RfD for infants by a factor of ten.
.
Michael wrote: "While we think that the adult RfD should also be reduced (as we have detailed in our submissions), we have not made this the centerpiece of our argument since we believe that both the law (e.g. FQPA) and the specific circumstances of this case (e.g. EPAs repeated alterations of the childhood RfD) underscore the tactical effectiveness of focusing on the childhood RfD."
.
Apparently, Michael doesn't understand that applying the additional 10x safety factor normally required by the Food Quality Protection Act (FQPA) would lower the RfD for everyone. It would not produce separate RfDs for infants and children.
.
The Connett's either don't understand or are unwilling to admit that the 0.114 mg/kg/day RfD for fluoride represents the maximum "safe" total daily intake of fluoride for humans throughout their lifetime. It represents the maximum allowable quantity of fluoride in the U.S. diet (including toothpaste and air pollution).
.
We don't have individual pesticide residue tolerances based on the age and body weight of the consumer. Carrots fit for adults are considered fit for infants as well. Pears consumed by children age 1 to 2 years are also consumed by children age 6 to 12, as well as adults age 20-49. We eat the same fruits and vegetables, the same oatmeal, the same bread. If the fluoride is there for adults, it's there for children too. For dietary contaminants EPA sets the RfD at a point which is "safe" for those who consume the most food and water. They describe the risk for various age groups as a percentage of the maximum allowed for 70 kg adults. They do not establish multiple reference doses based on age and body weight.
.
EPA made no alterations whatsoever in the maximum allowable intake of fluoride for any population group. In fact, the Maximum Contaminant Level for fluoride in drinking water is also referred to by EPA as 0.114 mg/kg/day. It represents 2 liters of water with 4 ppm fluoride. The MCL hasn't changed for over twenty years.
.
Of course, a 7 kg infant who regularly drinks almost 8 liters of "optimally" fluoridated water (1 ppm) could get as much as 8 milligrams of fluoride daily (1.14 mg/kg/day), but skeletal fluorosis would not be the primary reason for concern.
.
Nonetheless, according to FAN the RfD for adults is 0.114 mg/kg/day, but EPA raised the RfD for infants to 1.14 mg/kg/day - 10 times as much! FAN wants EPA to reverse their decision. I'm sure they would — if they could — but since EPA didn't change the RfD they cannot undo the change.
.
This is not an insignificant part of FAN's various submissions to EPA.
.
On the contrary ... it is the only "legal" argument used by FAN. Unfortunately, it's EPA's Office of Drinking Water (ODW), and the Institute of Medicine's fraudulent No Observed Adverse Effect Level (NOAEL) which deserves FAN's attention — not EPA's Office of Pesticide Programs (OPP). Fix the MCL and NOAEL, and the RfD for fluoride would automatically drop by a factor of ten — if not more. In fact, OPP suggested that FAN contact ODW about their concerns. ODW set the MCL — not OPP. The MCL is equal to the RfD (i.e., both are 0.114 mg/kg/day).
.
In short, the maximum allowable fluoride intake hasn't changed for more than twenty years. DOW is using a small piece from a large pie that people have been eating for many decades. It isn't safe by any means, and it will expose virtually everyone to more fluoride than usual; but you can't change a regulation that doesn't exist. If, as Michael explained, FAN wants the RfD for infants to be no higher than the RfD for adults, you could say it's a done deal — the RfD is already the same for all humans and all of them have been infants at least once.
.
FAN's November 2006 submission to EPA states: "Before arguing why a lower RfD for children "is not necessary", OPP needed to first demonstrate that a higher RfD for children (when expressed in the relevant terms of mg/kg/day) is safe. OPP's failure to do this, and its failure to acknowledge the fundamental need to do this, represents a flagrant violation of standard protocol and basic toxicological principles." ... "On the face of it, OPP's assumption that the safe daily dose for adults will also be safe for infants and children -- irrespective of the difference in weight and sensitivity -- is absurd. It is the toxicological equivalent of assuming that, because 250-500 mg of aspirin is safe for an adult, that therefore the same dose of aspirin will be safe for infants as well. Objectors are not aware of any other instance in OPP regulatory history where the cardinal rule that bodyweight affects the impact of a chemical has been abandoned. Unprecedented actions warrant a high burden of proof. As described below, this burden of proof was not met by OPP."
.
FAN's lawyer wrote: "What makes EPA's decision to increase the RfD (from less than 1 mg/day for infants to 8 mg/day for infants) so arbitrary and capricious is that it was derived from the same starting point (the MCLG of 4 ppm in water) and no new scientific research was offered to justify the increase. The end result of these alterations is that EPA has promulgated an RfD for infants that is ten times higher than the initial RfD, and ten times higher than the RfD currently allowed for adults."
.
As long as the people who eat and drink the most (the adults) don't exceed 8 mg/day, neither will infants and young children. This has been the case with all pesticides and other toxic chemicals in our diet forever. One mg/day for a 7 kg infant is equal to 0.14285714 mg/kg/day, while 8 mg/day for a 70 kg adult is equal to only 0.114 mg/kg /day.
.
According to EPA's dietary fluoride anion exposure estimates, adult males age 20-49 currently ingest 2.742 mg/day, which is 34% of 8 mg. Infants under the age of 1 year ingest 1.152 mg/day, which is 14% of 8 mg. That means that if dietary fluoride levels were about three times those believed to be current today adults would just barely exceed their maximum allowable 8 mg/day. However, for an infant to reach 8 mg/day the quantity of fluoride ingested from foods and beverages would have to be almost seven times what it is today.
.
EPA's January 18, 2006 Human Health Risk Assessment states: "For fluoride risk assessments addressed in this document, the 8 mg/day value has been used in a manner analogous to a reference dose (RfD) and is referred to as such for ease of communication. We note that the previous human health risk assessment for sulfuryl fluoride (M. Doherty, 10/12/2004, D309013) expressed toxicology and exposure in terms of mg/kg/day in order to match the units used by the dietary exposure model. In this assessment, those values are being expressed in mg/day to better harmonize with the more typical units found in the open literature describing fluoride exposures. In both cases, the values listed are derived from the same toxicological data and conclusions."
.
Obviously, FAN's claim that EPA's Pesticide Division raised the "childhood RfD" from 0.114 to 1.14 mg/kg/day is ludicrous. It didn't happen.
.
Furthermore, it is inconceivable that Ellen, Paul, and Michael Connett haven't been able to understand their error regarding the non-existent RfD for infants. In the "final rule" for sulfuryl fluoride dated 2004 and 2005 EPA states: "EPA performs a number of analyses to determine the risks from aggregate exposure to pesticide residues. For further discussion of the regulatory requirements of section 408 of FFDCA and a complete description of the risk assessment process, see the final rule on Bifenthrin Pesticide Tolerances (62 FR 62961, November 26, 1997) (FRL-5754-7)."
.
See: http://www.epa.gov/fedrgstr/EPA-PEST/1997/November/Day-26/p30948.htm
.
EPA's Integrated Risk Information System describes the RfD here: http://www.epa.gov/iris/rfd.htm
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