Impact to Water Systems and Water Operators

As the 3 ½ year, 500 page National Research Council review entitled the Toxicologic Risk of Fluoride in Drinking Water is released Wed, March 22nd, where the MCL/MCLG standards has been reviewed, some of the discussions surrounding fluoridation will change, dramatically.

EPA Standard for Fluoride in Drinking Water Not Protective

" After reviewing the collective evidence on adverse health effects associated with fluoride, our committee concluded unanimously that EPA should lower the maximum contaminant level goal for fluoride."

• NRC Fluoride in Drinking Water: A Scientific Review of EPA's Standards “Fluoride may be found in drinking water as a natural contaminant or as an additive…”

As concerning the NRC report, the adverse health effects were identified by the dose response of any fluoride chemical that gives off the fluoride ion. By definition, that includes not only calcium fluorides, the most commonly identified naturally occurring fluoride and sodium fluoride but also fluoride additives in the form of fluorosilicic acid (H2SiF6) and the sodium salt (sodium fluosilicate NaSiF6) collectively referred to as fluorosilicates (CDC 1993).

Little, if any, scientific literature reviewed by the NRC addressed calcium fluoride, the most commonly identified naturally occurring fluoride chemical. To represent the NRC report as addressing only naturally occurring fluorides at levels irrelevant to water agencies is factually incorrect.

As Waterwatch of Utah, our concern with the fluoridation issue surrounds the risks to the water operator, the impact to the water systems infrastructure and the liabilities this public policy presents.

Water agencies must comply with the requirements mandated by the Safe and Clean Drinking Water Acts. In an effort to meet all the requirements mandated under the Federal Safe and Clean Drinking Acts, water agencies must assume substantial financial burdens. Unless mandated by a political decision, the fluoridating of public water supplies is not one of those requirements. Additionally, water agencies have a fiduciary duty to maintain the highest quality water at the lowest possible price.

Our primary concern with public water fluoridation is the impact to the water operator.

Thomas J Reeves-CDC MMWR report Engineering and Administrative Recommendations for Water Fluoridation Morbidity and Mortality Reports Sept 29, 1995 It states, “Fluoride remains a safe compound when maintained at the optimal level in water supplies to distribution systems however an operator might be exposed to excessive levels if the proper procedures are not followed or if the equipment malfunctions. Thus the use of personal protective equipment (PPE) is required when fluoride compounds are handled or when maintenance of equipment is performed. The employer should develop a written program regarding the use of PPE. The water supply industry has a high incident of unintentional injury compared with other industries in the United States.”.

Are your water operators using appropriate safety protocols, specific to this substance?

As fluoride pumps often malfunction, there is an substantial risk to the water operator. Infrastructure should be carefully engineered, the equipment, state of the art and as that is expensive, water systems fiscal priorities must be considered

Any silicofluoride offgasses hydrogen fluoride (HF)

• According to the ACGIH (American Conference of Governmental Industrial Hygienists) “The Threshold Limit Value (TLV) for Hydrogen Fluoride was changed as of 2005. The current TLV-TWA is 0.5 ppm, with a TLV-Ceiling of 2 ppm and a Skin notation.” At present, the OSHA PEL for hydrogen fluoride is still set at 2.5 m/m(3). At that level, it has been reported the occupational exposure level can be as high as 25 mg per day, a level several times higher than the 4ppm the NRC committee unanimously agreed caused adverse health effects. Additionally, according to OSHA regulations, workers have the right to request their HF exposure level records, which are to be maintained for thirty years.

• The most commonly used fluoridation substance is fluosilicic acid (H2SiF6). The acid presents a hazard to the worker not only by the offgassed HF but also by the direct exposure to the acid.

• The dry fluorides, sodium salt (sodium fluosilicate NaSiF6) and sodium fluoride (NaF) present a different set of concerns. The dust when combined with moisture, such as sweat or moisture in the air of the water plant, combines to form an acid solution. There is the additional problem of air particulates. The dust is explosive.

• In light of newly revised ACGIH levels, HAZMET and OSHA standards should be very carefully implemented to ensure employee safety.

Also of concern is the impact to the water infrastructure.

Tom Reeves “ Let’s go back to that slide. She wants to know the actual concentration of the [hydrofluosilicic] acid, not the sodium fluoride. Okay? 1930’s. There’s nothing newer than that.” Presentation in Davis County Utah, October 13, 2005 by invitation of the Davis and Salt Lake County Health Departments

• Chloramines are produced with an excess of ammonia, which appears to react with silicofluorides to produce an ammonium-fluorosilicate intermediate which facilitates lead dissolution from plumbing components.

• Due to poor engineering, many water systems experience infrastructure corrosion. As any silicofluoride offgasses hydrogen fluoride (HF), we encourage water systems require a separate fluoride room, to better protect the rest of the infrastructure from corrosion due to the offgassed HF. A separate fluoride room also provides a better opportunity to contain exposures, spills and leaks.

• Replacing infrastructure is expensive. Water systems have fiscal priorities which may not include replacing infrastructure every 7-10 years.

There are environmental concerns

What if there is spill?

“ If you have an acid-a spill of the acid, there’s two things you can do and should do, immediately….You should treat it with lime or soda ash, and soda ash is preferred, actually. The reason for that if you use the lime it first depends if it is hydrated or not, you’ll create heat. You’re going to create heat with soda ash actually, not quite as much, but you’re going to create heat. And if you are inside the building, you use lime to put on the acid, you actually create hydrogen ions in the air. Hydrogen gas is created, ok. That’s explosive. So you can have a big spill along the line and you’ll create a lot of hydrogen gas. And somebody walks in there and lights a cigarette lighter, I don’t know why they would, but it will explode the building up. ” Tom Reeves October 13 2005

• If there is a spill while offloading the substance, what happens to the neutralized slurry? Is it dumped down the drain? As fluorides do not dissipate as do chlorines and as conventional methods will not remove fluorides from the water, is the sewer system infrastructure capable of removing the fluorides or reducing them to acceptable levels? Is the slurry hauled away to a public landfill? Are empty sodium fluoride bags being taken to a landfill where they are burned and HF, offgassed?

• In addition to other contaminating substances, there is the issue of the arsenic levels in the fluoridating substance.in levels upwards of 23ppm. Does the water system receive a certificate of analysis, per batch, outlining all the contaminants present in the substance? If the arsenic MCLG is 0, how can any arsenic be intentionally added to the water supply? Will a complete certificate of analysis be required with each delivery of fluoridating substances?

• The EPA classifies fluorides as an inorganic contaminant. As fluorides do not dissipate as do chlorines, what happens when fluorides are arbitrarily introduced to a water supply. To what levels are the TDS’s raised? Can the water classification be downgraded due to the presence of inorganic fluorides in levels that exceed the now questioned MCLGs? What happens to the waters value? Is it degraded, reducing its worth?

Liabilities

In our State, there are a number of concerns that should have been raised prior to the question being asked or fluoridation, resumed or continued. Had these issues been raised prior to a vote or mandate, litigation would have been avoided and many millions of dollars, saved. .

• Should a vote mandate a Water Provider use a fluoridation chemical that contains arsenic, a known carcinogen, at a concentration that presents a significant cancer risk, which entity will indemnify the water Company against all resulting claims and legal actions?

• As OSHA is responsible for enforcement of the (HF) PEL, what are the requirements imposed on the employer/water district to monitor the HF level to ensure the PEL is not exceeded?

• If no exposure records have been maintained to date, what are the liabilities to water districts? What is the cost of recording then maintaining those records?

• The recently released Bassin report which links osteosarcoma to fluoride at 1ppm raises a question of liabilities.

Infrastructure Corrosion

Additional Fluoride Corrosion Pictures

Should the city mandate water agencies to arbitrarily assume financial burdens beyond that which are required by the Safe and Clean Drinking Acts?

"From a constitutional standpoint, dental caries is neither communicable nor contagious; therefore, there is no substantial threat to the general public health and safety. Those citizens most susceptible to this non-communicable disease can seek treatment individually by less invasive and more discreetly targeted means.."

Finally, as a constitutional question.. should a water agency arbitrarily add an amendment, not required by the Safe and Clean Drinking Water Acts, which purportedly benefits a small segment of the population, where the financial burden is assumed by everyone?

These are just a few of the issues we should have considered more carefully. One water district suggested it would have been cheaper and far less litigious for them to hire a dentist than fluoridate.