Love for Life

Full technical reports for Profume Gas Fumigant FYI

See three PDF attachments at bottom.

----- Original Message -----
From: Merilyn Haines
To: Merilyn Haines
Sent: Tuesday, September 18, 2007 7:22 PM
Subject: FLUORIDATED FOOD ......PLEASE READ and foward

Dear Water Fluoridation opponents, PLEASE READ , FORWARD TO OTHERS OF LIKE
MIND, CONSIDER IF YOU WISH TO SEND SUBMISSIONS TO APVMA AND
politicians................Merilyn Haines

Prepare to be fluoridated big time in our FOOD if APVMA (Australian Pesticides and Veterinary Medicines Authority approves DOW's PROFLUME SULFURYL FLUORIDE food fumigant .The APVMA is saying APVMA is a only allowing until the 2nd Oct for public comment or submissions ( despite a delay in the PRS being available and then being put in a different location of the APVMA website other than their PRS page)

I have sent a copy of the purchased, just received, APVMA technical report as attachments.

If you would like to put in a response please also look at the gazette page and the PRS page for a little more information . Links to FAN's pesticides pages Also, a link to an assessment from the Hague. I will send any other information I can find .

http://www.apvma.gov.au/gazette/0709downloads/profume_p18.pdf

http://www.apvma.gov.au/publications/downloads/prs_profume.pdf

http://www.fluoridealert.org/pesticides/sulfuryl.f.all.food.html
http://www.fluoridealert.org/pesticides/sulfuryl-fluoride-page.htm

http://www.gr.nl/pdf.php?ID=1104

ALSO............Copied below is an email that I sent to Lithgow Council meeting last night. There were about 11 NSW Health staff at that meeting and they tried to dismiis this new development. While they did not agree to fluoridate at the meeting, they are having a public meeting very soon and will probably go ahead as soon as they can ( before the public find out about SF ) As below , some emails from APVMA contact . Merilyn

Dear Lithgow Councillors sent 17/9/07 I wish to advise you of a very recent development that will see much more FLUORIDE entering the food supply. It is urgent that you be aware of this when considering water fluoridation at tonights meeting. Please do not progress water fluoridation until you
consider this upcoming major issue.

The Australian Pesticide and Veterinary Medicines Authority APVMA on 4th September 2007 gazetted a new DOW AGROSCIENCES product PROFLUME with the active ingredient SULFURYL FLUORIDE as a new food fumigant to kill pests in food storage areas.

The Pubic Release Summary PRS (that is only available on request after gazetting) advised that public submissions are to be accepted until the 2nd October. DOW got approval in America for this use just a couple of years ago.

SULFURYL FLUORIDE is a gas and until now, it's only allowable use in Australia has been as a structural fumigant has been to kill termites. The proposed first time use with foodstuffs is as a replacement for Methyl Bromide.

Spraying SULFURYL FLUORIDE on, or near food, results in a considerable amount of the chemical being absorbed into the food, reacting with it and remaining in it.

SULFURYL FLUORIDE and FLUORIDE residues remain in the food and will massively increase the amount of FLUORIDE that people will now ingest .

So far, the APVMA have only released a couple of preliminary MAXIMUM RESIDUE LIMITS ( MRLs) , or food tolerances but in the US Dow asked for very high tolerances and this has been allowed.

In the APVMA PRS only 3 recommended MAXIMUM RESIDUE LMITS have been put forward for SULFURYL FLUORIDE and FLUORIDE RESIDUES.

http://www.apvma.gov.au/publications/downloads/prs_profume.pdf

Page 14 of the PRS document ( link above ) shows recommended allowable MRLs for SULFURYL FLUORIDE in dried fruit as being 0.07 mg/kg tree nuts and peanuts as 7 mg /kg

The APVMA recommended allowances for FLUORIDE residues in these same food 3 commodities are much, much higher... 5mg/kg for dried fruit..... ..........30mg/kg tree nuts and peanuts.

Water is fluoridated at 1mg/kg or 1 part per million FLUORIDE .

The APVMA MRLS being put forward as allowable are 5 times higher FLUORIDE in dried fruit as in fluoridated water and 30 times higher in nuts: other foods not yet listed will probably be allowed even higher residues.

In the US DOW petioned and got approval for very high allowable residues. The US allowable levels for FLUORIDE are dried fruit 3ppm , raisins 7 ppm, wheat flour 125 ppm and dried eggs 900 ppm ( see link below ). FLUORIDATED TOOTHPASTE contains 1000ppm.

http://www.fluoridealert.org/pesticides/sulfuryl.f.all.food.html

IT IS LIKELY THAT APVMA WILL ALSO ALLOW WHEAT FLOUR IN AUSTRALIA TO CONTAIN 125 TIMES THE AMOUNT OF FLUORIDE AS IN FLUORIDATED WATER AND 900 TIMES THE AMOUNT IN DRIED EGGS AS IN FLUORIDATED WATER (AS NOW ALLOWED IN THE US).

THE NHMRC HAS IN 1991 and 1999 called for urgent health and safety studies and total fluoride intake studies to be done in reation to water fluoridation. These have never been done. It is urgent that these be done.

If APVMA gives approval for PROFLUME to be used with foods, the amount of fluoride that people will be ingesting in their food will be massively increased.

Please do not proceed with water fluoridation . Please consider what effect APVMA approval will have on the amount of FLUORIDE people may now be going to ingest in their food.

Water fluoridation must be stopped if APVMA gives approval to the use of SULFURYL FLUORIDE use on foodstuffs.

Merilyn Haines spokesperson for Queenslanders Against Water Fluoridation Inc

-----Original Message-----
From: LEIS, Laura [mailto:Laura]
Sent: Tuesday, 18 September 2007 4:33 PM
To:
Cc: NORDEN, Alan; BHULA, Raj
Subject: Full technical reports for Profume Gas Fumigant

< <<59952 - Tox and OH and
S report.pdf>> <<59952-environment report.pdf>>

Dear Merilyn,

I have attached the following reports for your perusal:

Environment
Residues
Toxiciology and OH and S

In deciding whether to register a product or not the APVMA works closely with advisory agencies including the Department of Health and Ageing (Office of Chemical Safety), and Department of Environment and Water Resources (DEW). The full technical reports completed by these agencies (OH & S, Toxicology and environment) are used to form the basis of our assessment and final
recommendation, as containedpublic release summary.

Les Davies indicated, you have 28 days from today to provide written comment to the APVMA. Therefore the due date for your written comment is Tuesday 16th October 2007.

In response to your query as to whether the date for close of comment on the website will be extended, the answer is no. The reason you are getting an extension is that you have requested the full technical report, and due to the time lag in providing this to you we have extended the comment due date for you only until 16th October 2007.

Regards
Laura Leis
Australian Pesticides and Veterinary Medicines Authority (APVMA)
18 Wormald Street
SYMONSTON ACT 2609
Ph: (02) 62 104763
Fax: (02) 62 104776
E-mail: laura.leis @ apvma gov.au

_____________________________________________

From: Merilyn Haines [mailto:]
Sent: Wednesday, 12 September 2007 11:51 AM
To: LEIS, Laura
Subject: RE: PURCHASE OF FULL TECHNICAL REPORT SULFURYL FLUORIDE
EVALUATION
Importance: High

Hi Laura

I am very suprised to learn that a full technical report on Proflume would need to be prepared after it was gazetted and within the public comment period . I would have thought that this would have been "ready to go "

I am interested not only in the residues in food but in any aspect of the evaluation that would allow for a substantive and relative comments on the proposal; therefore I am interested in all information that has been used to allow the gazettal as an active ingredient and product for use on foodstuffs.

So far only a handful of MRLs for either Fluoride or Sulfuryl Fluoride have been provided. A very comphrensive list of MRLS need to be provided for both. Of particular interest are flours and dried eggs considering DOW has been allowed a massive 900 ppm Fluoride tolerance in dried eggs in the US.

Considering that this will be a first -time food use it needs very careful examination; the proposed time period is totally inadequate, I request a period of 2 months for comment after the full technical report is supplied.

Please advise my request for a 2 month public comment period if you have the authority , or if not, please immediately forward to those who have the authority to approve.

Please take into consideration that I had requested by email the week before the gazettal asking if SF was going to be gazetted last week and asking in advance for a PRS if it was to be gazetted.

I got no response to this email and then there was a delay getting the PRS, which was not even put onto the " PRS " web page but in a different location. There were further dealys in getting my emails and phone calls responded to.

Futhermore , it was only after the PRS became available that it was advised in the PRS that a full technical report is available, but now you advise that it would have to be prepared and it is not actually currently available.

I am concerned that delays in allowing the public full information about the evaluation process gives DOW great advantage in gaining approval and stress that a 2 month public comment period is imperative.

I await your urgent advice. I have requested a read receipt as acknowledgment of the receipt of this email.

Merilyn

-----Original Message-----
From: LEIS, Laura [mailto:Laura.Leis @ apvma.gov.au]
Sent: Wednesday, 12 September 2007 9:17 AM
To: Merilyn Haines
Subject: RE: PURCHASE OF FULL TECHNICAL REPORT SULFURYL FLUORIDE
EVALUATION

Dear Merilyn,
I am in the process of organising a full technical report for you. I know you are interested in residues of fluoride in food, therefore would I be correct in saying you would be interested in the toxicology and residues assessment only? Please confirm. I have asked the agencies to go through the full
technical reports and remove any commercial in confidence information. I hope this can be done quickly. If you do need an extension of time please advise and I will await your response within reason.

Regards

Laura

_____________________________________________

From: Merilyn Haines [mailto
Sent: Tuesday, 11 September 2007 8:58 AM
To: LEIS, Laura
Subject: PURCHASE OF FULL TECHNICAL REPORT SULFURYL FLUORIDE EVALUATION
Importance: High

Dear Laura
I have just FAXED my credit card details to you for the purchase of the Sulfuryl Fluoride evaluation report. Please still advise as to my queries in my previous email.

My preference is for an electronic copy of the report to be sent to this email address.

Many thanks
Merilyn Haines

-----Original Message-----
From: Merilyn Haines [mailto:]
Sent: Monday, 10 September 2007 5:51 PM
To: Laura.Leis @ apvma.gov.au
Subject: FW: PRS SF
Importance: High

Hi Laura
I have the requested Sulfuryl Fluoride PRS now and have just read at the end of the PRS document that a full technical report of the evaluation is available for sale for $30.

Could you please tell me if this report is available electronically, pdf or word, or just by hard copy delivered by snail mail? Also , do I send the request for the report and payment to you or another section?

Also how big would this report be and would this be a APVMA document or a DOW document that DOW has used in the USA, or in other countries when applying for registration?

If the PRS was not put on the website until the 7th Sept I quess that gives 28 days until the 5th October for submissions to be accepted?. Could you confirm this please? How tight the deadline be considering that the full technical report might also take time to get ?

Many thanks
Merilyn

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