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8-6-2005
from
Rense Website
Hon. Stephen L.
Johnson, Administrator
U.S. Environmental Protection Agency
August 4, 2005
Dear Administrator Johnson:
We, the undersigned representatives of a majority (eleven) of
EPA's employee unions, are requesting that you direct the Office
of Water to issue an Advanced Notice of Proposed Rulemaking
setting the maximum contaminant level goal for fluoride at zero,
in accordance with Agency policy for all likely or known human
carcinogens. Our request is based on the overall weight of the
evidence supporting the classification of fluoride as a human
carcinogen, including new information from Harvard on the link
between fluoride in drinking water and osteosarcoma in boys that
was conveyed to you in a meeting with union officials on May 4,
2005.
We appreciate that the Agency anticipates a report next year
from the National Research Council on the propriety of its
current drinking water standards for fluoride. But it seems
highly inappropriate for EPA to do nothing now that it is in
possession of this science, while millions of young boys
continue to be exposed unwittingly to the elevated risk of a
fatal bone cancer as the Agency waits for the NRC to issue its
report, then for the report to undergo peer review, and then for
the Agency to undertake its own deliberations.
By issuing an Advanced Notice of Proposed Rulemaking the Agency
would inform the public and local health authorities about the
results of the doctoral dissertation from the Harvard School of
Dental Medicine by Elise Bassin without committing the Agency to
a formal rulemaking until all those other steps are taken.
It is noteworthy that when industry becomes aware of important
new scientific findings like this, it has (depending on the
specific statute) a very brief time to notify EPA (Environmental
Protection Agency). The Agency is
then expected to take timely and appropriate action based on the
specifics of that notification. In the present case EPA is aware
of important new, high quality evidence of potentially serious
danger to young boys drinking fluoridated water, and we believe
EPA has an ethical duty to send an effective warning immediately
about this hazard.
It may, in fact, be appropriate for you to direct EPA's Office
of Criminal Enforcement to investigate why Dr. Bassin's study,
which was of sufficient quality for her to earn her doctoral
degree, remained hidden from EPA for four years. Alternatively,
you could request that the Department of Justice undertake the
investigation.
As you know, the apparent cover-up of the link between water
fluoridation and a seven-fold increased risk of osteosarcoma in
young boys, shown by the research of Dr. Bassin, is now national
news. Major newspapers, including the Washington Post and the
Wall Street Journal have covered the story. The Environmental
Working Group has petitioned the National Toxicology Program to
classify fluoride as a human carcinogen based in part on Dr. Bassin's work. (We recommend EWG's petition as a succinct and
authoritative overview of the total weight of peer-reviewed
evidence supporting the classification of fluoride as a human
carcinogen.) EWG has also caused an investigation of the cover
up to be started by Harvard and NIEHS, which funded the
research.
The eyes of the nation are on the federal science establishment
because of a host of scientific integrity issues. Former EPA
Assistant Administrator Lynn Goldman and Roni Neff have just
published a paper in the American Journal of Public Health on
the cost of delayed adoption of health-protective standards that
illuminates the real public health costs of the government's
failure to act on sound scientific evidence.
We believe our Agency can make an important statement about its
commitment to scientific integrity and its application to public
health protection by taking the precautionary action we are
recommending.
We at EPA can be ahead of the curve on this important issue or
behind it. We do not think the latter choice is in the best
interest of the public, the Civil Service or EPA, and we
fervently and respectfully hope that you will agree with us. As
a wise man once said, The science is what the science is.
We will be happy to discuss this with you and your advisers at
your convenience.
Sincerely,
Dwight A.
Welch, President
NTEU Chapter 280
EPA Headquarters
J. William Hirzy, Vice-President
NTEU Chapter 280
EPA Headquarters
/s/Steve Shapiro, President
AFGE local 3331
EPA Headquarters
/s/Paul Sacker, President
AFGE local 3911
Region 2 Office, New York
/s/Larry Penley. President
NTEU Chapter 279
EPA Cincinnati Laboratory
/s/Nancy Barron, President
NAGE Local R5-55
Region 4 Office, Atlanta
/s/Wendell Smith, President
ESC/IFPTE Local 20
Region 9 Office, San Francisco
/s/Patrick Chan, President
NTEU Chapter 295
Region 9 Office, San Francisco
/s/Henry Burrell, President
AFGE Local 3428
Region 1 Office, Boston
/s/Alan Hollis, President
AFGE Local 3611
Region 3 Office, Philadelphia
/s/Frank Beck, President
AFGE Local 2900
Ada Laboratory
/s/Mark Coryell, President
AFGE Local 3907
Ann Arbor Laboratory
cc:
Sen. James Inhofe
Sen. James Jeffords
Sen. Mike Enzi
Sen. Edward Kennedy
Sen. Saxby Chambliss
Sen. Tom Harkin
Sen. Ted Stevens
Sen. Daniel Inouye
Rep. Joe Barton
Rep. John Dingell
Rep. Sherwood Boehlert
Rep. Bart Gordon
Rep. Paul Gillmor
Rep. Hilda Solis
Rep. Nathan Deal
Rep. Sherrod Brown
Rep. Henry Waxman
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