Human Toxicity, Environmental Impact and Legal Implications of

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HUMAN TOXICITY, ENVIRONMENTAL IMPACT AND LEGAL IMPLICATIONS OF WATER FLUORIDATION 10.2 European Council Directive on the Protection of Groundwater against Pollution Caused By Certain Dangerous Substances (80/68/EEC). Fluoride is a List ii substance under the Council Directive 80/68/EEC 968 . Council Directive 80/68/EEC aims to prevent the discharge of certain toxic, persistent and bio-accumulable substances into groundwater. There are two lists of dangerous substances within this directive that are drawn up for the protection of groundwater. Article 3 of the Groundwater Directive requires member states to take the necessary steps to ensure the effective protection of groundwater in the community. It is necessary to prevent the discharge of List i substances and limit the discharge of substances in List ii so as to avoid pollution of groundwater by certain substances including fluoride. All indirect discharges of substances in List i and all direct or indirect discharges of substances in List ii are subject to prior authorisation. Such authorisation is granted after an investigation into the receiving environment for a limited period and subject to regular review. Certain conditions have to be met for discharges. If they have not been or cannot be met, the authorisation is withdrawn or refused. It is clear that by continuing with the policy of water fluoridation the State cannot comply with the conditions of the Groundwater Directive. Monitoring of compliance with this Directive and of the effects of discharges on groundwater is the responsibility of the competent authorities of the member States. Monitoring the effects or environmental impact of fluoride discharges into the environment from leaking infrastructure has not been undertaken by the Irish State to date. The EPA has acknowledged 969 that fluoride pollution from leakage in drinking water infrastructure is contaminating groundwater and poses a significant source of fluoride pollution in the environment. It is clear that the Government of Ireland cannot comply with Article 3 of this Directive by continuing with the policy of water fluoridation. 968 Council Directive 80/68/EEC of 17 December 1979 on the protection of groundwater against pollution caused by certain dangerous substances. 969 Clenaghan, C,. O‘Neill N, Page, D., Dangerous Substances Regulations National Implementation Report, 2005 Under the Water Quality (Dangerous Substances) Regulations, 2001 (S.I. No. 12 of 2001), Environmental Protection Agency, 2006. www.enviro.ie Page 179
HUMAN TOXICITY, ENVIRONMENTAL IMPACT AND LEGAL IMPLICATIONS OF WATER FLUORIDATION Fluoridated water distributed through the water infrastructure in Ireland is an expensive, unscientific and inefficient mechanism that results in unnecessary health risks for the public as well as pollution of soil, groundwater and surface waters by the uncontrolled release of fluoride into the environment. Fluoride is not only discharged through leaking water distribution systems into soil and groundwater but from wastewater treatment plants into rivers. It is bioaccumulated in foods grown on soil used for sewage or processed sludge disposal and incorporated into foods and beverages made in areas where water is fluoridated. Food cooked in water with added fluorides will also have increased fluoride levels 970 . It is clear that water fluoridation undertaken using the existing water infrastructure cannot comply with Article 5 of this Directive. Article 5 requires that a member state take all appropriate measures to limit all indirect discharge of substances in List ii due to activities on or in the ground. The only appropriate measure to control the discharge of List ii substances is to limit them at source. This requires termination of the policy of water fluoridation. In the absence of such action, the only other appropriate measure would require the Government of Ireland to immediately replace the tens of thousands of kilometres of leaking infrastructure throughout the State and take measure to prevent such leakages into the future. Until such time as this occurs, toxic persistent and bio-accumulative substances will continue to pollute groundwater. 10.3 European Council Directive on Pollution Caused by Certain Dangerous Substances Discharged into the Aquatic Environment (2006/11/EC) In order to ensure effective protection of the aquatic environment of the Community, this Directive establish a first list, called List i, of certain individual substances selected mainly on the basis of their toxicity, persistence and bioaccumulation and a second list, called List ii, containing substances which have a deleterious effect on the aquatic environment. Pollution through the discharge of the various dangerous substances within List i must be eliminated. It is necessary to reduce water pollution caused by the substances within List ii. Any discharge of these substances should be subject to prior authorization which specifies emission standards. Fluoride is a List ii substance under Council Directive 2006/11/EC. It should be noted that sodium fluoride was found to be an equivocal carcinogen by the 970 Toxicological profile for fluorides, hydrogen fluoride, and fluorine, Agency for Toxic Substances and Disease Registry U.S. Public Health Service, April 1993 www.enviro.ie Page 180
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FEBRUARY 2012 EnviroManagement Serv
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Mr. David J. O‘Hagan, Chief State
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TABLE OF CONTENTS Acknowledgements
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10.0 LEGAL FRAMEWORK 174 10.1 The C
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16.5 Recommended Further Bone Studi
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HUMAN TOXICITY, ENVIRONMENTAL IMPAC
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