Protecting Our Food from Fluoride Pesticides:
The Campaign Against Sulfuryl Fluoride
THE CAMPAIGN AGAINST SULFURYL FLUORIDE
VICTORY!: After a vigorous nine-year campaign by the Fluoride Action Network, EPA announced on January 10, 2011 that they are granting all of FAN's objections to sulfuryl fluoride and will be withdrawing ALL sulfuryl fluoride residue tolerances from food in the U.S.!
NEW: EPA Proposes Phaseout of Fluoride-Pesticide - New York Times, January 11, 2011
BACKGROUND:FAN's Consolidated Set of Objections to Sulfuryl Fluoride (The most comprehensive critique of the science underpinning the sulfuryl fluoride tolerances.)
Overview:
Sulfuryl fluoride is a gas fumigant that has been used -- since the 1950s -- to kill bugs and rodents in indoor structures, such as homes, warehouses, and railroad cars.
Up until recently, federal guidelines prohibited food-related uses of sulfuryl fluoride. This prohibition, however, has recently been rescinded -- due to an intensive lobbying effort from DOW AgroSciences.
In DOW's quest to find an alternative to the fumigant methyl bromide (an ozone-depleting chemical that DOW also produces), the pesticide manufacturer worked hard to get EPA's approval of sulfuryl fluoride as a "post-harvest fumigant". Post-harvest fumigants are chemcials used to fumigate food-processing, and food storage, facilities.
In 2004, EPA gave Dow what they wanted: the approval to use sulfuryl fluoride on food.
As a result, hundreds of food processing companies across the US have begun fumigating their facilities with sulfuryl fluoride (trade name = ProFume ®).
Since companies are not required to remove food from the premises before fumigating, fumigations with sulfuryl fluoride produce high levels of fluoride residues "in or on" the stored foods. According to recent regulations approved by EPA, it is now acceptable for fumigations to produce fluoride residues of 70 ppm "in or on" all processed foods (except for the processed foods otherwise specified), 130 ppm "in or on" wheat, and 900 ppm "in or on" dried eggs. (See full list of foods that can be fumigated)
The end result, according to estimates released by EPA in January 2006, is that the use of sulfuryl fluoride as a food fumigant could become the second largest daily source of fluoride exposure in the US.
Morever, because there are no labeling requirements for foods fumigated with sulfuryl fluoride, the use of sulfuryl fluoride will make it more difficult for health-conscious people to limit, or monitor, their fluoride intake. This is because all processed foods (from cookies to cakes to frozen meals, etc.) are now allowed to have high fluoride residues. Not every batch of processed food will be fumigated. In fact, most will not be. However, it’s similar to Russian-roulette: there is now no way to know if the processed food you're about to eat has high fluoride levels.
Current Status:
In two recent rulings (January 2004 & July 2005), EPA granted DOW the green light to begin fumigating food with sulfuryl fluoride. Thus, food processors in the US are beginning to adopt sulfuryl fluoride as their food fumigant of choice. That's the bad news.
The good news is that EPA's "gift to DOW" is being rigorously challenged by three environmental groups: Fluoride Action Network, Environmental Working Group, and Beyond Pesticides. In June of 2006, the three groups filed a petition to EPA calling for a "stay", or immediate suspension, of all food-uses of sulfuryl fluoride pending a full evidentiary hearing. The environmental groups’ are represented by attorney Perry Wallace, of the international law firm, Zelle, Hofmann, Voebel, Mason and Gette.
After receiving the groups' petition, the EPA issued a request for public comment noting that "the request for a stay raises complex science issues of great public interest."
In response to EPA's request, the New York State Attorney General's Office, the Union representing EPA's scientists and professionals in Washington DC, and over 7,000 citizens wrote to EPA expressing their support for the petition and urging the Agency to terminate the food uses of sulfuryl fluoride.
With the comment period now over, the public now awaits EPA's next move. Will the Agency bow to industry pressure, or will it fulfill its mandate and protect the public's health?
UPDATE: FAN wins stunning victory on sulfuryl fluoride - January 11, 2011
Developments:
LINKS for FURTHER INFORMATION:
FAN's Pesticide Project
Sulfuryl Fluoride Index Page
FAN/EWG Press Releases:
EPA to Bar Fluoride-Based Pesticide - FAN/EWG/Beyond Pesticides, January 10, 2011
NYS Attorney General supports revocation of all food tolerances of Dow AgroSciences fumigant sulfuryl fluoride - FAN, August 7, 2006
Groups Demand Immediate Halt to Food Uses of Fluoride-Based Pesticide - FAN, EWG, & Beyond Pesticides, July 7, 2006
Environmental groups petition EPA to retract fluoride pesticide tolerances on food - FAN, September 21, 2005
News Articles:
EPA Proposes Phaseout of Fluoride-Pesticide - New York Times, January 11, 2011
EPA Moves to Ban Pesticide that Leaves Fluoride Behind - NPR Health Blog, January 11, 2011
Sulfuryl fluoride: Facing Threat Of Suit, EPA Weighs Broad Effort To Address Fluoride's Risks - InsideEPA, December 7, 2010
Conference debates water fluoridation, sulfuryl fluoride, and problems with EPA limits - Chemical & Engineering News, September 4, 2006
Unions Say E.P.A. Bends to Political Pressure - New York Times, August 2, 2006
Activists Target Fluoride Pesticides To Tighten Drinking Water Limits - InsideEPA, July 18, 2006
Activists worry a new pesticide will put toxic levels of fluoride in food - San Antonio Current, March 22, 2006
Dispute over methyl bromide alternative prompts debate on fluoride (pdf file) - InsideEPA, January 20, 2006
Submissions to EPA:
Consolidated List of Objections (pdf file) - FAN, EWG, & Beyond Pesticides, November 2006
Petition to EPA Calling for End to Sulfuryl Fluoride Use on Food (pdf file) - FAN, EWG, & Beyond Pesticides, June 2006
Statement from New York State Attorney General (pdf file) - New York State Attorney General's Office, August 4, 2006
Statement from EPA Headquarters Union (pdf file) - EPA Headquarters Union, July 25, 2006
Statement from Panel Member of N.R.C. Review on Fluoride- Dr. Kathleen Thiessen, August 4, 2006
FLUORIDE LEVELS ALLOWED "IN OR ON" FOOD after fumigation with SULFURYL FLUORIDE:
900 ppm: Dried eggs
130 ppm: Wheat germ
130 ppm: Wheat (milled byproducts)
125 ppm: Wheat (flour)
75 ppm: Oat (flour & rolled)
70 ppm: ALL Processed foods (excepting specific levels for foods in this list)
70 ppm: Legumes (57 types – see list below)
70 ppm: Herbs & Spices (135 types – see list below)
70 ppm: Cottonseed (used as animal feed)
70 ppm: Ginger
55 ppm: Corn (aspirated grain fractions)
40 ppm: Wheat (bran & grain)
40 ppm: Millet (grain)
45 ppm: Rice (flour)
45 ppm: Barley (bran, flour, pearled)
40 ppm: Coconut
40 ppm: Cattle (meat, dried)
40 ppm: Wheat (bran; grain; & shorts)
40 ppm; Sorghum (grain)
40 ppm: Triticale (grain)
35 ppm: Corn (flour)
35 ppm: Rice (hulls)
31 ppm: Rice (bran)
30 ppm: Corn (field, meal)
25 ppm: Rice (wild grain & polished)
25 ppm: Oat (grain)
20 ppm: Cocoa bean
20 ppm: Ham
20 ppm: Pine nut
15 ppm: Peanuts
15 ppm: Coffee
15 ppm: Barley (grain)
12 ppm: Rice (grain)
10 ppm: Corn (field, grain)
10 ppm: Corn (field, grits)
10 ppm: Corn (pop, grain)
10 ppm: Tree Nuts (14 types – see below)
10 ppm: Pistachio
7 ppm: Raisin
5 ppm: Cheese
5 ppm: Milk (powdered)
3 ppm: Dried Fruit
List of Legumes that can be fumigated (up to 70 ppm):
bean • bean, adzuki • bean, adzuki, seed • bean, broad • bean, broad, seed • bean, broad, succulent • bean, dry • bean, dry, seed • bean, kidney • bean, kidney, seed • bean, lablab • bean, lablab, seed • bean, lima • bean, lima, seed • bean, lima, succulent • bean, moth • bean, moth, seed • bean, moth, succulent • bean, mung • bean, mung, seed • bean, navy • bean, navy, seed • bean, pink • bean, pink, seed • bean, pinto • bean, pinto, seed • bean, rice • bean, rice, seed • bean, runner • bean, runner, succulent • bean, snap, succulent • bean, succulent • bean, tepary • bean, tepary, seed • bean, urd • bean, urd, seed • bean, wax • bean, wax, succulent • bean, yardlong • bean, yardlong, succulent • catjang • catjang, seed • chickpea • chickpea, seed • cowpea • cowpea, seed • cowpea, succulent • guar • guar, forage • guar, seed • gum, edible • jackbean • jackbean, succulent • lentil • lentil, forage • lentil, hay • lentil, seed • lupin, grain • lupin, grain, grain • pea • pea, blackeyed • pea, blackeyed, seed • pea, blackeyed, succulent • pea, crowder • pea, crowder, seed • pea, dry • pea, dry, seed • pea, dwarf • pea, dwarf, succulent • pea, edible podded • pea, edible podded, succulent • pea, english • pea, english, succulent • pea, field • pea, field, seed • pea, garden • pea, garden, succulent • pea, green • pea, green, succulent • pea, pigeon • pea, pigeon, seed • pea, pigeon, succulent • pea, shelled • pea, snow • pea, snow, succulent • pea, southern • pea, southern, seed • pea, southern, succulent • pea, succulent • pea, sugar snap • pea, sugar snap, succulent • pea, unshelled • soybean • soybean, aspirated grain fractions • soybean, crude oil • soybean, hulls • soybean, meal • soybean, refined oil • soybean, seed • soybean, soapstock • soybean, vegetable • soybean, vegetable, succulent • swordbean • swordbean, succulent • turtle, bean • vegetable, seed and pod
List of Herbs & Spices that can be fumigated (up to 70 ppm):
allspice • angelica • anise hyssop • anise, seed • anise, star • annatto • annatto, seed • balm • balm, dried leaves • balm, fresh leaves • basil • basil, dried leaves • basil, fresh leaves • borage • borage, dried leaves • borage, fresh leaves • burnet • camomile • caper • caper, buds • caraway • caraway, black • caraway, black, seed • caraway, seed • cardamom • cardamom, seed • cardamon amomum • cardamon amomum, seed • cassia • catnip • celery, seed • chervil • chervil, dried leaves • chive • chive, chinese • cinnamon • clary • clary, dried leaves • clary, fresh leaves • clove • coriander • coriander, leaves • coriander, seed • costmary • costmary, dried leaves • costmary, fresh leaves • culantro • culantro, leaves • culantro, seed • cumin • curry • curry, dried leaves • curry, fresh leaves • dill • dill, seed • dillweed • dillweed, dried leaves • dillweed, fresh leaves • fennel • fennel, florence, seed • fennel, seed • fenugreek • fenugreek, seed • grains of paradise • grains of paradise, seed • herbs, dried • herbs, dried, dried leaves • herbs, fresh • herbs, fresh, fresh leaves • horehound • horehound, leaves • hyssop • hyssop, tops • juniper berry • lavender • lemongrass • lemongrass, leaves • lovage • lovage, leaves • lovage, seed • mace • marigold • marjoram • mustard • mustard, seed • nasturtium • nasturtium, leaves • nutmeg • parsley, dried leaves • pennyroyal • pennyroyal, leaves • pepper, black • pepper, white • poppy • poppy, seed • rosemary • rosemary, dried leaves • rosemary, fresh leaves • rue • rue, dried leaves • rue, fresh leaves • saffron • saffron, flower • sage • sage, dried leaves • sage, fresh leaves • savory, summer • savory, summer, dried leaves • savory, summer, fresh leaves • savory, winter • savory, winter, dried leaves • savory, winter, fresh leaves • spices • spices, postharvest • sweet bay • tansy • tansy, dried leaves • tansy, fresh leaves • tarragon • tarragon, dried leaves • tarragon, fresh leaves • thyme • thyme, dried leaves • thyme, fresh leaves • vanilla • wintergreen • wintergreen, dried leaves • wintergreen, fresh leaves • woodruff • woodruff, dried leaves • woodruff, fresh leaves • wormwood • wormwood, dried leaves • wormwood, fresh leaves
List of Tree Nuts that can be fumigated (up to 10 ppm):
almond • almond, hulls • beechnut • butternut • cashew • chestnut • chinquapin • filbert • nut, brazil • nut, hickory • nut, macadamia • nutmeat, processed, except peanut • nuts • pecan • pistachio • walnut
LIST OF FOOD & FEED PROCESSING PLANTS APPROVED TO USE SULFURYL FLUORIDE. Approved by EPA on July 15, 2005.
- Food and feed processing plants
- Bakeries
- Bottlers
- Canneries
- Dairies, creameries, milk processing plants
- Feed mills, feed stores
- Fresh fruit packing and processing
- Meat processing
- Poultry processing
- Wineries, wine cellars
- Flour mills, machinery, warehouses, bins, elevators
- Egg processing
- Candy and confectionary plants
- Sugar processing, cane mills, etc.
- Cider mills
- Dry food products plants
- Tobacco processing
- Air treatment for processing and transportation of foods
- Beverage processing
- Nut processing
- Cereal processing
- Seafood processing
- Vegetable oil processing
- Spice mills
- Vinegar processing
- Farinaceous processing (noodles, etc.)
- Mushroom processing
- Dried fruit processing
- Pickle processing
- Ice plants
- Chocolate processing
- Fruit juice processing
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