13 February 1999

U.S. Department of Justice
Environmental Crimes Division
601 Pennsylvania Ave., NW 6th Floor
Washington, DC 20004

 

Subject: Safe Drinking Water Act
Maximum Contaminant Level
for fluoride in drinking water

 

When EPA set the maximum contaminant level for fluoride in drinking water at four milligrams per litre, they based their calculation on incorrect dosage figures, which they described as 20 mg/day for 20 or more years. The calculation should have been based on a minimum of 10 mg/day for 10 or more years. This figure represents the total daily fluoride dosage according to the National Research Council, which might cause crippling skeletal fluorosis. EPA also erred in failing to consider individual tolerances and lifetime exposures. Twenty years does not a lifetime make.

EPA further violated the essence of the Safe Drinking Water Act in failing to consider arthritis (phase 1 and 2 skeletal fluorosis) as an “adverse” health effect… and in classifying disfiguring dental fluorosis as not an adverse health effect but merely “cosmetic.”

EPA has set the MCL at a level too high to provide the legally required margin of safety. In addition to the errors mentioned above, EPA also neglected to consider background levels of fluoride which, unlike the situation fifty years ago, can be several times the dosage delivered in drinking water. In short, EPA has relied on out-dated and inaccurate information.

EPA must re-calculate the MCL according to law. Their minimum dosage figures 20 mg/day for 20 years for crippling skeletal fluorosis, were the result of an error in arithmetic, miscalculated by Harold C. Hodge, Ph.D., in 1953 and corrected by Dr. Hodge in 1979. NAS/NRC corrected their figures in 1993. The minimum is currently estimated to be 10 mg/day for 10 years, or far less, on a daily basis, when ingested over a lifetime, or by individuals who are more vulnerable to the toxic effects of soluble fluorides.
EPA management, however, has steadfastly ignored these facts.

I am writing to you today to ask your assistance in forcing the U.S. Environmental Protection Agency to obey the law.

 

References:

• The Safe Drinking Water Act, 42 U.S.C. 300f, et seq.

• National Primary Drinking Water Regulations; Fluoride, Federal Register, 50(220): 47142-47171, Nov 14, 1985.

• National Academy of Sciences / National Research Council, HEALTH EFFECTS OF INGESTED FLUORIDE, 1993, p 59.

• U.S. Department of Health & Human Services, REVIEW OF FLUORIDE BENEFITS AND RISKS, 1991, page 46.

• See images of the USDHHS symptoms & NAS/NRC dosage figures at: http://move.to/stopfluoride

       Sincerely,

       Philip Heggen

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