[GreenYes] Last Day: Tell EPA not to allow use of a dangerous "structural fumigant" on food

[Alan Muller <amuller@no.address>]

In yet another rollover to special interests, the 
US EPA has decided to allow use of a very 
dangerous "structural fumigant" on food 
products.  According to the FLUORIDE ACTION 
NETWORK (FAN, Green Delaware is a member):

"The tolerances the EPA has "given" Dow 
AgroSciences on these are horrendous - including 
130 ppm on wheat flour (which goes into hundreds 
of different processed foods) and 900 ppm on 
powdered eggs (compare that to 1000 ppm on 
toothpaste - which one is not meant to swallow!)."

The FAN has made it easy to send a letter to EPA 
by going to http://actionstudio.org/?go=2367 
.  Please consider taking a few minutes to comment to EPA on this.

Below is a letter sent by Green Delaware:
         ********************
August 4, 2006

Mr. Stephen L. Johnson, administrator
United States Environmental Protection Agency

Dear Administrator Johnson:

RE: Inappropriate approval of sulfuryl fluoride for use on food products

Green Delaware does not understand the EPA's 
plans to allow the use of fulfuryl fluoride on 
food products for human consumption.  According 
to information provided online by your agency 
(http://www.epa.gov/ozone/mbr/casestudies/volume2/sulfury2.html):

"Sulfuryl fluoride (SO2F2), also known as Vikane? 
(99.8 percent by weight sulfuryl fluoride and 0.2 
percent inerts), was developed by Dow Chemical in 
the late 1950s as a structural fumigant. ... it 
is injurious to green plants, vegetables, fruits, 
and tubers. ...Guidelines for use of the fumigant 
specifically state that "under no conditions 
should Vikane? be used on raw agricultural food 
commodities, foods, feeds, or medicinal products 
destined for human or animal consumption, or on 
living plants" (UNEP 1994, Bond 1984). ...Chronic 
longer-term inhalation exposure to concentrations 
significantly above the threshold limit value 
(TLV) may result in fluorosis (i.e., fluoride 
binding to the teeth and bones) because sulfuryl 
fluoride is converted to fluoride ion in the body (DowElanco 1994)."

The public expects EPA to employ the best science 
available in its approval of 
pesticides.  However, it is apparent that this 
did not happen with sulfuryl fluoride. Indeed, 
the National Academy of Sciences recently 
concluded that the safety standard used by EPA to 
approve sulfuryl fluoride is, in fact, not safe at all.

Moreover, as the NAS report makes clear, and as 
is evident by the growing number of children with 
dental fluorosis, many Americans are being 
OVER-exposed to fluoride. There is no safety 
margin for additional fluoride exposures that 
will result from sulfuryl fluoride. I am 
particularly concerned for susceptible subsets of 
consumers, including children, people with kidney 
disease, people with excess thirst (e.g. 
diabetics, athletes, and laborers) and people with nutrient deficiencies.

Green Delaware would like you to investigate why 
EPA increased the allowable dosage for infants 
and children not once, but twice, during its 
approval process for sulfuryl fluoride. In direct 
violation of the Food Quality Protection Act, 
these manipulations have left our children ten 
times less protected than adults.

For these, and the many other reasons detailed in 
the petition to EPA, I urge you to revoke all 
food-based uses of sulfuryl fluoride.

Please add my comments to the docket #: 
EPA-HQ-OPP-2005-0174 and EPA-HQ-OPP-2003-0373.

We look forward to your response.

Respectfully,

Alan Muller
Director

copy:           Sen. Tom Carper
                 Sen. Joe Biden
                 Congressman Mike Castle

Green Delaware is a community based organization 
working on environment and public health 
issues.  We try to provide information you can 
use.  Please use it.  Do you want to continue 
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Delaware?  Please consider contributing or 
volunteering.  Reach us at 302.834.3466, 
greendel@no.address, www.greendel.org , Box 69, Port Penn, DE, USA, 19731-0069




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