- Hon. Stephen L. Johnson, Administrator
U.S. Environmental Protection Agency
August 4, 2005
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- Dear Administrator Johnson:
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- 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.
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- 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.
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- 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. 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.
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- 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 coverup 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.
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- 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.
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- We will be happy to discuss this with you and your advisers
at your convenience.
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- 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
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- /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
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- /s/Frank Beck, President
AFGE Local 2900
Ada Laboratory
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- /s/Mark Coryell, President
AFGE Local 3907
Ann Arbor Laboratory
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- 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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