would provide a test case for the agency's interpretation that petitioners must provide a comprehensive analysis of all uses of a chemical in order to seek a restriction on a particular use. Legal experts have suggested that the EPA’s interpretation essentially makes the requirements for gaining Agency action using section 21 petitions impossible to meet.
Background Information
On Nov 22, 2016, a coalition including FAN, Food & Water Watch, Organic Consumers Association, American Academy of Environmental Medicine, International Academy of Oral Medicine and Toxicology, Moms Against Fluoridation, and several individual mothers, filed a petition calling on the EPA to ban the deliberate addition of fluoridating chemicals to the drinking water under provisions in the Toxic Substances Control Act (TSCA). The full TSCA petition can be accessed here, a shorter 8-page summary here, and our press release here.
We presented the Agency with a large body of human and animal evidence demonstrating that fluoride is a neurotoxin at levels now ingested by many U.S. children and vulnerable populations. We also presented the Agency with evidence showing that fluoride has little benefit when swallowed, and, accordingly, any risks from exposing people to fluoride chemicals in water are unnecessary. We believe that an impartial judge reviewing this evidence will agree that fluoridation poses an unreasonable risk.
On February 27th, the EPA published their response. In their decision the EPA claimed, “The petition has not set forth a scientifically defensible basis to conclude that any persons have suffered neurotoxic harm as a result of exposure to fluoride in the U.S. through the purposeful addition of fluoridation chemicals to drinking water or otherwise from fluoride exposure in the U.S."
As many independent scientists now recognize, fluoride is a neurotoxin. The question, therefore, is not if fluoride damages the brain, but at what dose.
While EPA quibbles with the methodology of some of these studies, to dismiss and ignore these studies in their entirety for methodological imperfections is exceptionally cavalier, particularly given the consistency of the findings and the razor-thin margin between the doses causing harm in these studies and the doses that millions of Americans now receive.
EPA's own Guidelines on Neurotoxicity Risk Assessment highlight the importance of having a robust margin between the doses of a chemical that cause neurotoxic effects and the doses that humans receive. We presented the EPA with over 180 studies showing that fluoride causes neurotoxic harm (e.g. reduced IQ), and pointed out that many of these studies found harm at levels within the range, or precariously close to, the levels millions of U.S. children now receive. Typically, this would be a cause for major concern. But, unfortunately, the EPA has consistently shied away from applying the normal rules of risk assessment to fluoride -- and it has unfortunately continued that tradition with its dismissal of the Petition.
Fortunately, the TSCA statute provides that citizens can challenge an EPA denial in federal court. For too long, EPA has let politics trump science on the fluoride issue (see examples). We welcome therefore having these issues considered by a federal court.
The Fluoride Action Network is offering a new video available on DVD and flash drive, "Fluoride and the Brain." In this he explains that fluoride's ability to lower IQ in children is just the tip of an iceberg of over 300 animal and human studies that indicate that fluoride is neurotoxic.
FAN has also made a comprehensive collection of campaign and educational videos available on a single flash drive for a limited time. This is a must-have for every fluoride-free campaigner's toolkit.
PLEASE make a donation today to help FAN end water fluoridation and demand a clean, treatment-free public water supply. With over 70% of the human body being water, having clean, properly hydrating drinking water is vital for everyone’s survival.