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

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
. 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

"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.


Alan Muller

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
receiving information from Green
Delaware? Please consider contributing or
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greendel@no.address, , Box 69, Port Penn, DE, USA, 19731-0069

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