Artificial Water Fluoridation


Request for town to notify pregnant women about the latest studies on fluoride’s link to reduced IQ in children (began September 1, 2019)

— 2021 —

Presentation to Town Meeting on Fluoride 052221 (Article 36 DEFEATED)

Presentation slides – Article 36 – Fluoride’s link to Reduced IQ in Children – 050821

Presentation to BOH on Fluoride 051321 (BOH VOTED 2-1 to NOT RECOMMEND ARTICLE 36)

Presentation to BOS on Fluoride 042721 & Vote 051121

Presentation to FinComm on Fluoride 042221 (FinComm VOTED 8-0 to NOT RECOMMEND ARTICLE 36)

Presentation to BOH on Fluoride 022621

  — 2020 —

Email to BOH on Fluoride 121720 – New information on Fluoride’s link to reduced IQ in children – Request to be placed on January agenda

Email to BOH on Fluoride 121120 – Request to be placed on Dec 18th agenda on the topic of Fluoride’s link to reduced IQ in children

BOH on Fluoride 032720 – BOH corrects the record and confirms JAMA Pediatrics study was indeed funded by the US Government

Email to BOS on Fluoride 030320 – Request for the BOS to provide evidence proving swallowing fluoride is safe for pregnant women and their fetus

Email to BOH on Fluoride 030220 – Factual Correction: JAMA Pediatrics study on fluoride’s link to reduced IQ in children was funded by the US Government

Email to BOS on Fluoride 030120 – Evidence shows Selectmen have oversight responsibility for fluoride in Shrewsbury’s drinking water

Presentation to BOH on Fluoride 022820

Email to BOS on Fluoride 021920 – Re: Request for town to notify pregnant women about the latest study on fluoride’s link to reduced IQ in children

Email to BOS on Fluoride 020720 – Re: Request for town to notify pregnant women about the latest study on fluoride’s link to reduced IQ in children

Email to BOH on Fluoride 012220 – Re: Request for town to notify pregnant women about the latest study on fluoride’s link to reduced IQ in children

Email to BOS on Fluoride 010620 – Fwd: Request for town to notify pregnant women about the latest study on fluoride’slink to reduced IQ in children

— 2019 —

Discussion by BOH on Fluoride 122019

Email to BOH on Fluoride 120919 – Request for town to notify pregnant women about the latest study on fluoride’s link to reduced IQ in children

Email to BOH on Wireless Fluoride 112119 – BOH 11/22/19 Meeting – Wireless & Fluoride topics

BOH Minutes on Fluoride 102319

Email to BOH on Fluoride 101519 – Request for town to notify pregnant women about the latest study on fluoride’s link to reduced IQ in children

Email to Town Manager on Fluoride 090119 – Request for town to notify pregnant women about the latest study on fluoride’s link to reduced IQ in children

— 2018 —

Presentation to BOH on Fluoride 122118

Fluoride Shrewsbury FSA hazardous waste removal 112018

Fluoride Shrewsbury FSA hazardous waste manifest 110218

Email Shrewsbury Fluoride China Source 062018

Annual Town Meeting 052318 – Fluoridation Discontinuance Citizen’s Petition to see if the Town will vote to adopt a bylaw to discontinue the fluoridation of the public water supply; recognizing the benefits of switching to the Massachusetts Department of Public Health (MDPH) School Fluoride Mouthrinse Program.

Discussion by BOH on Fluoride 050418

— 2016 —

Special Town Meeting 092616

Discussion by FinComm on Fluoride 092216 – VOTED 7-1 to NOT RECOMMEND the petition

Presentation to FinComm on Fluoride 092216

Discussion by BOS on Fluoride 091316 – VOTED 5-0 to NOT RECOMMEND the petition

Presentation to BOS on Fluoride 091316

Presentation to BOH on Fluoride 083116 – VOTED 3-0 to NOT RECOMMEND the petition

Email to BOH BOS FINCOMM on Fluoride 082916 – Safe Drinking Water Protection By-law – Important Supplemental Information

Citizens Petition to BOS on Fluoride 082316 – Safe Drinking Water Protection By-law. No town board, officer, or committee shall require the addition of any substance to the public drinking water supply for preventive health care purposes unrelated to contamination of drinking water.

— 2015 —

Presentation during the Voice of Reason Program on Fluoride 071415

Annual Town Meeting 052015

Citizens Petition to BOS on Fluoride 051815 – This citizens petition to end water fluoridation in the town of Shrewsbury.

BOH Minutes on Fluoride 050715 – Bryan Moss, resident. He and his wife have concerns about findings that fluoride in drinking water is a neurotoxin and endocrine-disrupting chemical. Recent studies have shown lower IQ test scores, hypothyroidism, and an increased incidence of Attention Deficit and Hyperactivity Disorder (ADHA). At the present time, there is no government body mandating the fluoridation of drinking water.

FinComm Discussion on Fluoride 043015 – VOTED 7-0-2 to NOT RECOMMEND the petition

BOS Discussion on Fluoride 042815 – VOTED 5-0 to NOT RECOMMEND the petition

FinComm Discussion on Fluoride 041615

Presentation to FinComm on Fluoride 041615

Letter to BOH on Fluoride 041315 – Request to suspend water fluoridation.  This letter expressed concerns in regards to the recent discoveries that fluoride in drinking water is a neurotoxin and endocrine-disrupting chemical. Considering these findings, we requested that the BOH immediately suspend Shrewsbury’s water fluoridation program until this matter can be fully investigated, and we can be certain that any fluoride added to the drinking water is having no adverse effect on children’s minds.

— 1952 —

Annual Town Meeting 1952 Article 23 Fluoridation Vote – Article 23: Addition of Sodium Fluoride to Water Supply – “Dr. Martin explained the nature and properties of fluorine and stated that 488 communities already have fluorine in their water supply and that others are planning to add fluorine to their water.  He stated that certain amounts of fluorine are naturally present in the Shrewsbury water.  In correct proportion, the addition of fluorine would be helpful in preventing tooth decay.  He then moved and it was seconded “that the Town vote to purchase, install and maintain equipment for adding sodium fluoride to the water supply and that the sum of $4,000.00 be raised and appropriated to the use of the Board of Water Commissioners therefor. Mrs. Dudley then opposed adoption of the article citing evidence to prove that fluorine was harmful and not the answer to teeth care.  After further discussion a motion was made and seconded “that we take an immediate vote.”  So voted.  It was then moved “that the motion previously made be adopted.”  So voted.”

Annual Town Meeting 1952 – Article 23 Fluoridation Warrant Article – ARTICLE XXII – To see if the Town will vote to raise and appropriate a sum of money not in excess of Four thousand ($4,000.00) dollars, to purchase, install and maintain equipment for adding sodium fluoride to the source of water supply, or do or act in any way relative thereto.

Top Reasons Why We Should Stop Adding Fluoride To Shrewsbury’s Drinking Water

Fluoridation violates our most basic human freedom over what is done to our body

The Town of Shrewsbury has required since 1953 that fluoride be added to the public drinking water supply for preventive health care purposes which violates the individual’s right to decide for themselves if they want to be treated with fluoride or not (aka violates informed consent).   This is contradictory to the American Dental Association’s Statement on Patient Rights which clearly states:

You have a right to accept, defer or decline any part of your treatment recommendations.

 Moreover, it also conflicts with the American Medical Association’s Code of Medical Ethics which clearly states:

The process of informed consent occurs when communication between a patient and physician results in the patient’s authorization or agreement to undergo a specific medical intervention.

Fluoridation adds an industrial hazardous waste ‘bi-product’ to our water supply

Shrewsbury switched in October 2018 from Hydrofluorosilicic Acid (HFSA) to Sodium Fluoride (NaF) as part of the new water treatment plant.  The Town of Amesbury stopped adding Sodium Flouride citing poor quality supplies of Sodium Fluoride from China.

  • 11/01/18 – present
    • Supplier = Lincoln Fine Ingredients, a Maroon Group LLC company – Lincoln, RI
    • Distributor = WEGO Chemical & Mineral Corporation, Great Neck, NY
    • Source Factory = The factory is located in Hengyang City, Hunan, China – producing Sodium Fluoride (SF) from Sodium Silicofluoride (SSF) and Soda ash.  The material SSF is a product from Phosphate Fertilizer producer.
    • Source Phosphate Fertilizer Plant = Phosphate Fertilizer Plant in China (details unknown)
    • Source Phosphate Mine = China (details unknown)

WEGO Sodium Fluoride Product Data Sheet – Town of Shrewsbury verified that we  moved to Sodium Fluoride from China.

Town of Amesbury Massachusetts – Fluoride Statement

Amesbury Voters reject fluoridation of city water

“Amesbury’s Department of Public Works director, Rob Desmarais, said that six years ago, powdered fluoride purchased from China began clogging the plant and leaving a residue. “We just wanted to get a good supply or end the use,’’ said Desmarais, who added that most of the powdered fluoride is now shipped from China and Japan. He said since the earthquake struck Japan earlier this year, its supply has decreased, leaving China as the main supplier.  Until 2009, the city purchased its powdered fluoride from Solvay, an international industrial and chemical company. ”

A new perspective on metals and other contaminants in fluoridation chemicals by PJ Mullenix (2014)

“Barium and aluminum levels approached those that the EPA found in samples of electroplating sludge, river sediment, and hazardous soils… contaminant content creates a regulatory blind spot that jeopardizes any safe use of fluoride additives.”

Prior Fluoride Sources for Town of Shrewsbury:

  •  07/01/17-10/31/18
    • Supplier = Pencco – Sealy, TX
    • Source Plant = Potash Corporation of Saskatchewan (PCS) Phosphate Fertilizer Plant – Aurora, NC
    • Source Mine = Lee Creek Phosphate Mine – Aurora, NC
    • Shrewsbury’s supplier during this time was Pencco out of Sealy, Texas and that supply came from the Potash Corporation of Saskatchewan (PCS) Phosphate Fertilizer Plant in Aurora, NC which mined the Phosphate rock from the Lee Creek Phosphate Mine in Aurora, North Carolina.   PCS Phosphate is the largest integrated phosphate mining and chemical plant in the world.  During the first quarter of 2008, two phosphoric acid evaporators were commissioned for producing hydrofluorosilicic acid at that plant.
    • The Hydrofluorosilicic Acid Fluoridation additive that the Town of Shrewsbury used also contained the toxic contaminants Lead and Arsenic!

      Pencco Fluorosilicic Acid Product Data Sheet

      • Lead, as Pb 1.0 ppm
      • Arsenic as As 6.0 ppm
  • 07/01/15-06/30/17

The town has spent more than a million dollars over the past couple of decades on adding fluoride to the drinking water

Previously, when the town was using HFSA, which used to cost the town $1 Million dollars over two decades and thru Sustainable Shrewsbury’s questioning of the town discovered that the fluoride was making our water too acidic and that the town had been spending even more money to make it less acidic:

  • Hydrofluorosilicic Acid (HFSA) = $15,000 / yr
  • Potasium Hydroxide (KOH) = $30,000 / yr (note: used to raise the PH of the water back up after the addition of Fluroide made it too acidic)
  • New Fluoridation equipment in 2018 = $30,000

Now the town uses Sodium Fluoride, which is budgeted for $15,000/year.

Fluoridation is very wasteful and inefficient as 99% never even touches a tooth

Very little water is actually used for drinking, less than 1%.    Most fluoridated water ends up on lawns, down shower drains, toilets, etc., where it ends up polluting the environment.   And in the case of Shrewsbury’s Unaccounted for Water (UAW) issue where 33% of the water is unaccounted for, that means that for every 3 gallons of water that is pumped and fluoridated, only 2 gallons are actually delivered to residents.

Fluoridation is based on ingesting fluoride and therefore exposes the whole body to this toxic chemical

Fluoridation is based on ingesting fluoride, so why should we swallow it if it’s benefits are primary topical?

In 1999, the CDC acknowledged that the predominant benefit of fluoride is topical not systemic.  Fluoride’s benefits are largely topical thus it makes more sense to provide readily available topical treatments such as fluoride toothpaste instead of ingesting fluoride through the public water supply.   What is clear is that ingesting fluoride offers little, if any, benefit to your teeth.

“Fluoride’s caries-preventive properties initially were attributed to changes in enamel during tooth development because of the association between fluoride and cosmetic changes in enamel and a belief that fluoride incorporated into enamel during tooth development would result in a more acid-resistant mineral. However, laboratory and epidemiologic research suggests that fluoride prevents dental caries predominately after eruption of the tooth into the mouth, and its actions primarily are topical for both adults and children.”

“The effect of systemically ingested fluoride on caries is minimal.”

Fluoridation is even more risky for Shrewsbury residents that can’t drink the fluoridated water (ie. infants, kidney patients, thyroid patients, diabetics, elderly etc.)

Not everyone can drink the fluoridated water.  The 2006 National Research Council (NRC) of the Academy of Sciences report on Fluoride in Drinking Water that was commissioned by the EPA designated kidney patients, diabetics, seniors, and babies as ‘susceptible sub-populations’ that are especially vulnerable to harm from ingested fluorides.  Also, according to the NRC report, there is substantial evidence that fluoride exposure can impact thyroid function in some individuals.


“My career has been about making people aware of harmful exposures and the deception that often accompanies those exposures. Drinking water fluoridation is harmful, we’ve been deceived to believe it is safe, and with new found knowledge we must all act now to stop it.” (see original facebook post) – Erin Brockovich

Community Artificial Water Fluoridation “is a Government program that supports putting a hazardous industrial waste product into the public water supply to deliver a topical medical treatment, without fully understanding its long-term health effects and without receiving the informed consent of all the citizens involved.”  – The Case Against Fluoride


08/21/19 – Criticisms of Recent JAMA Fluoride/IQ Study Are Unfounded


01/09/19 – U.S. Water Fluoridation: A Forced Experiment that Needs to End

10/10/18 – We add it to drinking water for our teeth — but is fluoride hurting us?

05/07/18 – Pentagon: Fluorinated Chemicals Taint Water at Scores of Bases, Neighboring Communities

10/10/18 – University of Toronto: Higher levels of urinary fluoride associated with Attention Deficit Hyperactivity Disorder (ADHD) in children

09/21/17 – Fluoride exposure in utero linked to lower IQ ini kids, new study says

09/19/17 – Children’s IQ Could Be Lowered by Mothers Drinking Tap Water While Pregnant

A new study suggests that prenatal exposure to this chemical may affect cognitive abilities and that children born to mothers exposed to high amounts of fluoride could have lower IQs.

04/27/16 – Erin Brockovich letter to National Governor’s Association

The NGA and member governors should now consider themselves ‘learned intermediaries’ regarding the content of this letter and attached modern references that were apparently not made available to them by lobbyists. Consequently, we urge the NGA to rescind the specious 2015 Health Investments that Pay Off: Strategies to Improve Oral Health and issue a recommendation that governors enact immediate fluoridation moratoriums at the state level in order to protect their constituents, preserve their infrastructure, conserve the environment, and limit their legal liability.

06/29/15 – Fluoridation May Not Prevent Cavities, Scientific Review Shows

A recent Scientific review by the Cochrane Collaboration, which is considered to provide the gold standard in evidence based reviews of health science by doctors and researchers, says there is No Reliable Evidence that Fluoridation prevents cavities!

“Frankly, this is pretty shocking,” says Thomas Zoeller, a scientist at UMass-Amherst uninvolved in the work. “This study does not support the use of fluoride in drinking water.”

04/27/15 – American Academy of Environmental Medicine (AAEM) signs on to a letter with Erin Brockovich sent to members of the Institute of Medicine / National Academy of Sciences

The letter discusses the IOM and NAS’ failure to maintain the ‘DRI: Elements’ table with current and accurate information reflective of the science on fluoride, some of which was provided by Committee on Fluoride in Drinking Water for the 2006 National Research Council AND failure to warn the government and public of the health risks fluoride ingestion poses to the young, elderly, and those with health conditions


  • Fluoride is an enzyme poison and an endocrine disruptor
  • Fluoride is a potent adjuvant… causing or worsening allergies
  • Fluoride is a proliferative agent… causing or worsening inflammation
  • Fluoride accumulates in bones and tissue… causing or worsening arthritis and other ailments
  • Fluoride impacts thyroid hormones… resulting in both hypo and hyper disorders
  • Fluoride interferes with glucose metabolism… a concern for diabetics
  • Fluoride causes dental fluorosis… disproportionately by race and social economic status
  • Fluoride is neurotoxic to fetuses, infants and young children… resulting in permanent deficits
  • Fluoride is a burden to kidneys… resulting in increased fluoride retention and possible renal damage in those with kidney disease.

03/10/15 – Water Fluoridation Linked to Higher ADHD Rates

New research shows there is a strong correlation between water fluoridation and the prevalence of Attention Deficit Hyperactivity Disorder, or ADHD, in the United States.

Thomas Zoeller, a scientist at UMass-Amherst who studies endocrine disruptors—chemicals that interfere with the activity of the body’s hormones, something fluoride has been shown to do—says that this is “an important observation in part because it is a first-of-a-kind. Given the number of children in the U.S. exposed to fluoridation, it is important to follow this up.”

02/24/15 – Water Fluoridation May Increase Risk of Underactive Thyroid Disorder

A large study that looked at data from nearly every general medical practice in England suggests that water fluoridation may increase the risk of developing hypothyroidism, or underactive thyroid. This condition, in which the thyroid gland doesn’t produce enough hormones, is associated with symptoms such as fatigue, obesity and depression.

“It raises a red flag,” says Dr. Philippe Grandjean, an environmental health researcher and physician at Harvard University, “that possible interference with thyroid function needs serious consideration when regulating fluoride levels in drinking water.”

02/14/14 – Neurobehavioural effects of developmental toxicity

Neurodevelopmental disabilities, including autism, attention-deficit hyperactivity disorder, dyslexia, and other cognitive impairments, affect millions of children worldwide, and some diagnoses seem to be increasing in frequency. Industrial chemicals that injure the developing brain are among the known causes for this rise in prevalence. In 2006, we did a systematic review and identified five industrial chemicals as developmental neurotoxicants: lead, methylmercury, polychlorinated biphenyls, arsenic, and toluene. Since 2006, epidemiological studies have documented six additional developmental neurotoxicants—manganese, fluoride, chlorpyrifos, dichlorodiphenyltrichloroethane, tetrachloroethylene, and the polybrominated diphenyl ethers.

07/25/12 – Impact of fluoride on neurological development in children

In a meta-analysis, researchers from Harvard School of Public Health (HSPH) and China Medical University in Shenyang for the first time combined 27 studies and found strong indications that fluoride may adversely affect cognitive development in children. Based on the findings, the authors say that this risk should not be ignored, and that more research on fluoride’s impact on the developing brain is warranted.

“Fluoride seems to fit in with lead, mercury, and other poisons that cause chemical brain drain,” Grandjean says. “The effect of each toxicant may seem small, but the combined damage on a population scale can be serious, especially because the brain power of the next generation is crucial to all of us.”

03/02/00 – The Secret History of Lead

Note: this article on the history of leaded gasoline is included here to show the nasty history of how corporations purposely expose the population to toxic chemicals so that they can protect their profits, all while knowing its harmful effect on us.  In this case, it took 60 years before it was banned.



Shrewsbury – Town Meeting voted to provide funds & responsibility of fluoridation to the Shrewsbury Water Commissioners (aka Board of Selectmen)
Westborough – ordered in 1969, started 1974
Holden – ordered in 1969 (subsequent town-wide referendum rejected the BOH’s fluoridation order) & ordered again in 1988, started 1995

Shrewsbury Citizens for Safe Drinking Water

MAHB – Per & Polyfluorinated compounds (PFAS) in Drinking Water Presentation – November 2017

03/01/20 – BOS – Evidence shows Selectmen have oversight responsibility for fluoride in Shrewsbury’s drinking water

02/19/20 – Request to BOS to notify pregnant women of lower IQ risk for children

02/07/20 – Request to BOS to notify pregnant women of lower IQ risk for children

01/22/20 – Request to BOH to notify pregnant women of lower IQ risk for children

01/06/20 – Request to BOS to notify pregnant women of lower IQ risk for children



02/01/16 – Erin Brockovich Discussing Her Opposition to FLUORIDE on Dr. Oz Show


Erin Brockovich Discussing Dupont’s role in PFOA (Perfluorooctanoic acid (PFOA) is a synthetic, fully fluorinated organic acid).   Notice that PFOA is a Fluorinated Compound!  It is used in the manufacture of Teflon.  Teflon has fluoride in it!   If you wouldn’t cook on a Teflon coated pan, then why would you ever drink fluoridated water?

Fantastic 10 minute video showing the environmental disaster that is caused by phosphate fertilizer mining and where our Fluoride comes from.



01/12/20 – [Gloucester] Fluoridated water case is going to federal court

08/12/19 – [Gloucester] Council to consider fluoride petition

12/04/18 – Water Treatment Plant Update DECEMBER 2018

09/25/18 – Water Quality Improvement Program Update SEPTEMBER 2018

07/26/18 – Water Quality Improvement Program Update JULY 2018

04/12/18 – [Edgartown] Fluoride loses

12/13/17 – [Gloucester] Activists want ban on fluoride in drinking water

11/09/17 – [Edgartown] Board of Health Votes to Add Fluoride to Water, Causing Outcry

03/07/17 – [Gloucester] Science and Alternative Facts: About fluoridation, false dilemmas and fake news

02/26/17 –  Fluoridation remains a complicated matter for Worcester

12/06/17 – [Martha’s Vineyard Edgartown] Health board didn’t follow law on adding fluoride

11/23/16 – Anti-fluoridation a Worcester tradition


10/10/16 – Fluoridation championed in U.S. communities (Shrewsbury mentioned); ADA recognized for fluoridation campaign

09/26/16 –  Shrewsbury town meeting rejects effort to stop water fluoridation

09/14/16 –  Environmentalist continues fight against fluoride in water

05/20/15 –  Shrewsbury town meeting says keep fluoride in the water

02/05/15 – The Fluoride Debate Rages On In Some Massachusetts Cities [Cambridge, Newburyport, and Gloucester]

03/16/10 – Chinese Fluoride In Mass. Water Raises Concern

01/19/10 – Town halts use in water supply, seeks solutions Amesbury DPW no longer adding element to water supply

AMESBURY – Citing problems with the quality of sodium fluoride flooding the American market, Department of Public Works director Rob Desmarais said Amesbury has no current plans to resume its practice of adding fluoride to the town’s water supply.

10/01/01 – Water Fluoridation: Scientific Or Shameful?


This one sentence will eventually end fluoridation – Fluoride is neurotoxic!


It borders on insanity for a society to knowingly expose the next generation –womb to grave – to a substance that can interfere with the development of the brain.

Recent scientific and medical research shows that ingesting fluoride poses serious health risks. In 2006, the National Research Council identified fluoride as an “endocrine disruptor” that can impair the normal functioning of the thyroid gland, and in 2014, The Lancet published a paper classifying fluoride as one of 11 chemicals known to damage the developing human brain (i.e., a “developmental neurotoxin”), alongside arsenic, lead, and mercury.

Shrewsbury adds a corrosive fluoride chemical to its water in the name of preventing tooth decay (aka “water fluoridation”). This fluoride chemical is not only a neurotoxin, its repeatedly been found to leach lead from water pipes and increase the levels of lead in children’s blood.

In short, fluoridation programs are adding fuel to the fire of America’s lead crisis, in Flint and beyond.

Is Fluoride Bad for You? It’s Not Just in the Water

SIERRA CLUB – Fluoride in Drinking Water Policy

Fluoride And Your Thyroid by DR. IZABELLA WENTZ, PHARM D

EPA’s Fluoride in Drinking Water A Scientific Review of EPA’s Standards (2006)

 I worked with the most prominent scientist in China, where 27 studies had been done l

Massachusetts TURA Toxic or Hazardous Substance List

The Toxics Use Reduction Act establishes a Toxic or Hazardous Substance List, often referred to as the TURA list.  All toxic or hazardous substances regulated under TURA and subject to reporting and planning requirements are compiled into one list (301 CMR 41.00: Toxic or Hazardous Substances List). This list was originally created based on two federal lists: Section 313 of the Emergency Planning and Community Right to Know Act (EPCRA) and Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or “Superfund”).

HHS = higher hazard substance, LHS = lower hazard substance, PBT = persistent bioaccumulative toxic chemical
C = Reportable as Part of a Chemical Category, X = Reportable as Individual Chemical

Hydrogen fluoride 7664393 X X HHS Higher hazard and threshold lowered to 1000 pounds as of reports covering
CY 2016. State Only Form R required. Submit separate Form R to EPA.
1000 lbs
Hydrogen fluoride (anhydrous) 7664393 X X HHS Higher hazard and threshold lowered to 1000 pounds as of reports covering CY 2016. State Only Form R required. Submit separate Form R to EPA. 1000 lbs
Sodium fluoride 7681494 X

Massachusetts Toxics Use Reduction Act (TURA) – Higher Hazard Substance Designations

The Higher Hazard Substance designation lowers the chemical use threshold for reporting, planning, and paying TURA fees to 1,000 pounds per year.

As of January 2015, the following chemicals have been designated as Higher Hazard Substances: 1-bromopropane (n-propyl bromide, or nPB), cyanide compounds, dimethylformamide (DMF), hydrogen fluoride (HF), methylene chloride, formaldehyde, hexavalent chromium compounds, perchloroethylene (PCE), trichloroethylene (TCE), cadmium, and cadmium compounds. For the four chemicals/chemical categories designated in 2015, requirements are not effective until reporting year 2016, as shown in the table below. Persistent, bio-accumulative, and toxic (PBT) substances as defined by US EPA, which already have lower reporting thresholds, are also automatically designated as Higher Hazard Substances.

Chemical Year designated Effective as of reporting year
1-Bromopropane (n-Propyl Bromide, or nPB (CAS 106-94-5))
Hydrogen Fluoride (CAS 7664-39-3)
Cyanide Compounds (MassDEP category 1016)
Dimethylformamide (CAS 68-12-2)
2015 2016
Methylene chloride (75-09-2) 2013 2014
Hexavalent chromium (MassDEP category 1216)
Formaldehyde (50-00-0)
2011 2012
Perchloroethylene (127-18-4) 2008 2009
Trichloroethylene (79-01-6)
Cadmium (7440-43-9)
Cadmium Compounds (MassDEP category 1004)
2007 2008
PBTs (automatic by statute; already had lower reporting
thresholds): Aldrin, Benzo(g,h,i)perylene, Chlordane, Heptachlor, Hexachlorobenzene, Isodrin, Lead, Lead Compounds, Mercury, Mercury Compounds, Methoxychlor, Octachlorostyrene, Pendimethalin, Pentachlorobenzene, Polychlorinated biphenyls (PCBs), Tetrabromobisphenol, Toxaphene, Trifluralin, Dioxin & dioxin-like compounds, Polycyclic aromatic compounds (PACs)
2007 2007

Safe Drinking Water Act


(11) No national primary drinking water regulation may require the addition of any substance for preventive health care purposes unrelated to contamination of drinking water.

(1) IDENTIFICATION OF CONTAMINANTS FOR LISTING.— (A) GENERAL AUTHORITY.—The Administrator shall, in accordance with the procedures established by this subsection,
publish a maximum contaminant level goal and promulgate a national primary drinking water regulation for a contaminant (other than a contaminant referred to in paragraph (2) for which a national primary drinking water regulation has been promulgated as of the date of enactment of the Safe Drinking Water Act Amendments of 1996) if the Administrator determines that—
(i) the contaminant may have an adverse effect on the health of persons;
(ii) the contaminant is known to occur or there is a substantial likelihood that the contaminant will occur in public water systems with a frequency and at levels of public health concern; and
(iii) in the sole judgment of the Administrator, regulation of such contaminant presents a meaningful opportunity for health risk reduction for persons served by public water systems.

How does fluoride get into tap water?

Fluoride can occur in drinking water naturally as a result of the geological composition of soils and bedrock. Some areas of the country have high levels of naturally occurring fluoride which can dissolve easily into ground water as it moves through gaps and pore spaces between rocks. Fluoride can also be added to public drinking water supplies as a public health measure for reducing cavities among the treated population. Fluoridation is not required by EPA, which is prohibited by the Safe Drinking Water Act from requiring the addition of any substance to drinking water for preventive health care purposes. The Centers for Disease Control and Prevention (CDC) provides recommendations about the optimal levels of fluoride in drinking water in order to prevent tooth decay. The decision whether or not to add fluoride to drinking water is made on a local basis.

How many contaminants were originally regulated by the 1976 Safe Drinking Water Act?

There were 22 contaminants regulated: 2,4-D 2,4,5-TP (Silvex), arsenic, barium, cadmium, chromium, coliform bacteria, endrin, fluoride, gross alpha, gross beta, lead, lindane. Mercury. Methoxychlor, nitrate, radium-2261, radium-2281, selenium, silver, toxaphene, and turbidity.

What is EPA’s position on fluoridation of drinking water?

EPA neither endorses nor opposes the addition of fluoride to drinking water. The decision to add fluoride is made on a local basis. EPA set a maximum contaminant level (MCL) of 4.0 mg/L to protect against adverse health effects. According to the Consumer Confidence Report (CCR) rule, as amended by the Public Notification rule (40 CFR Part 141, Appendix A to Subpart O), “Some people who drink water containing fluoride in excess of the MCL over many years could get bone disease, including pain and tenderness of the bones. Fluoride in drinking water at half the MCL or more may cause mottling of children’s teeth, usually in children less than nine years old. Mottling, also known as dental fluorosis, may include brown staining and/or pitting of the teeth, and occurs only in developing teeth before they erupt from the gums.” Because children may get mottled teeth at levels above 2.0 mg/L, EPA has set a secondary maximum contaminant level (SMCL) of 2.0 mg/L. EPA does not require water systems to meet this SMCL; however, EPA does require public water systems to notify their users (by mail or hand delivery and by a legal notice in the newspapers that serve the area) if the fluoride level is over 2.0 mg/L.

Clean Air Act

The Clean Air Act in a Nutshell:  How It Works

Congress designed the Clean Air Act to protect public health and welfare from different types of air pollution caused by a diverse array of pollution sources.  Congress established the law’s basic structure in the Clean Air Act Amendments of 1970, and made major revisions in 1977 and 1990.

The Act also contains specific provisions to address:  “Hazardous” or “toxic” air pollutants that pose health risks such as cancer or environmental threats such as bioaccumulation of heavy metals,

How the Clean Air Act regulates hazardous air pollutants

The 1970 Act had required EPA to regulate hazardous air pollutants (also known as “toxic” air pollutants, or “air toxics”) on a pollutant‐by‐pollutant basis, based on risk.  In 1990, Congress rewrote those provisions after EPA in 20 years had managed to regulate only some sources of seven pollutants.

Rather than having EPA list the substances to be regulated, Congress listed nearly 190 hazardous air pollutants but gave EPA authority to modify the list if warranted.  Congress required EPA to issue “maximum achievable control technology” (MACT) emissions standards for all new and existing major industrial sources of these pollutants, category by category, within 10 years after enactment of the 1990 amendments.  These standards require higher‐emitting sources to reduce their emissions to the levels already being achieved by other similar sources.

What are Hazardous Air Pollutants?

Hazardous air pollutants, also known as toxic air pollutants or air toxics, are those pollutants that are known or suspected to cause cancer or other serious health effects, such as reproductive effects or birth defects, or adverse environmental effects. EPA is working with state, local, and tribal governments to reduce air emissions of 187 toxic air pollutants to the environment.

Initial List of Hazardous Air Pollutants with Modifications

Under the Clean Air Act, EPA is required to regulate emissions of hazardous air pollutants.  This original list included 189 pollutants.  Since 1990, EPA has modified the list through rulemaking to include 187 hazardous air pollutants.

CAS Number Chemical Name
7664393 Hydrogen fluoride (Hydrofluoric acid)

Clean Air Act Text – Hazardous Air Pollutants

42 U.S.C.
United States Code, 2013 Edition
Part A – Air Quality and Emission Limitations
Sec. 7412 – Hazardous air pollutants

§7412. Hazardous air pollutants
(6) Hazardous air pollutant
The term “hazardous air pollutant” means any air pollutant listed pursuant to subsection (b) of this section.

(b) List of pollutants
(1) Initial list
The Congress establishes for purposes of this section a list of hazardous air pollutants as follows:

CAS Number Chemical Name
7664393 Hydrogen fluoride (Hydrofluoric acid)

(n) Other provisions
(6) Hydrofluoric acid
Not later than 2 years after November 15, 1990, the Administrator shall, for those regions of the country which do not have comprehensive health and safety regulations with respect to hydrofluoric acid, complete a study of the potential hazards of hydrofluoric acid and the uses of hydrofluoric acid in industrial and commercial applications to public health and the environment considering a range of events including worst-case accidental releases and shall make recommendations to the Congress for the reduction of such hazards, if appropriate.

Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Section 102(a) Hazardous Substances

Environmental Protection Agency

§ 302.4 Designation of hazardous substances.

(a) Listed hazardous substances. The elements and compounds and hazardous wastes appearing in table 302.4 are designated as hazardous substances under section 102(a) of the Act.

(b) Unlisted hazardous substances. A solid waste, as defined in 40 CFR 261.2, which is not excluded from regulation as a hazardous waste under 40 CFR 261.4(b), is a hazardous substance under section 101(14) of the Act if it exhibits any of the characteristics identified in 40 CFR 261.20 through 261.24. NOTE: The numbers under the column headed ‘‘CASRN’’ are the Chemical Abstracts Service Registry Numbers for each hazardous substance. The ‘‘Statutory Code’’ column indicates the statutory source for designating each substance as a CERCLA hazardous substance:

  • ‘‘1’’ indicates that the statutory source is section 311(b)(2) of the Clean Water Act,
  • ‘‘2’’ indicates that the source is section 307(a) of the Clean Water Act,
  • ‘‘3’’ indicates that the source is section 112 of the Clean Air Act, and
  • ‘‘4’’ indicates that the source is section 3001 of the Resource Conservation and Recovery Act (RCRA).

The ‘‘RCRA Waste Number’’ column provides the waste identification numbers assigned to various substances by RCRA regulations. The ‘‘Pounds (kg)’’ column provides the reportable quantity adjustment for each hazardous substance in pounds and kilograms. Appendix A to §302.4, which lists CERCLA hazardous substances in sequential order by CASRN, provides a per substance grouping of regulatory synonyms (i.e., names by which each hazardous substance is identified in other statutes and their implementing regulations).


Hazardous substance CASRN Statutory code RCRA waste No. Final Rq
pounds (Kg)
Hydrogen fluoride 7664–39–3 1,3,4 U134 100 (45.4)
Hydrofluoric acid 7664–39–3 1,3,4 U134 100 (45.4)
Sodium fluoride 7681–49–4 1 1000 (454)

CERCLA hazardous substances defined

CERCLA section 103 release reporting requirements apply to “hazardous substances.” How are CERCLA hazardous substances defined?

CERCLA section 101(14), as amended, defines “hazardous substance” by referencing other environmental statutes, including:

  • CWA sections 311 and 307(a);
  • CAA section 112;
  • RCRA section 3001; and
  • TSCA section 7.

CERCLA section 102(a) also gives EPA authority to designate additional hazardous substances not listed under the statutory provisions cited above. There are currently about 800 CERCLA hazardous substances. In addition, there are approximately 1,500 known radionuclides, approximately 760 of which are listed individually.

Clean Water Act

section 311(b)(2) of the Clean Water Act

(7) HAZARDOUS SUBSTANCE DEFINED.—For the purpose of this subsection, the term ‘‘hazardous substance’’ means (A) any substance designated pursuant to section 311(b)(2)(A) of this Act, (B) any element, compound, mixture, solution, or substance designated pursuant to section 102 of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, (C) any hazardous waste having the characteristics identified under or listed pursuant to section 3001 of the Solid Waste Disposal Act (but not including any waste the regulation of which under the Solid Waste Disposal Act has been suspended
by Act of Congress), (D) any toxic pollutant listed under section 307(a) of this Act, and (E) any imminently hazardous chemical substance or mixture with respect to which the Administrator has taken action pursuant to section 7 of the Toxic Substances Control Act.

(14) ‘‘hazardous substance’’ means any substance designated pursuant to subsection (b)(2) of this section;

(b)(1) The Congress hereby declares that it is the policy of the United States that there should be no discharges of oil or hazardous substances into or upon the navigable waters of the United States, adjoining shorelines, or into or upon the waters of the contiguous
zone, or in connection with activities under the Outer Continental Shelf Lands Act or the Deepwater Port Act of 1974, or which may affect natural resources belonging to, appertaining to, or under the exclusive management authority of the United States
(including resources under the Fishery Conservation and Management Act of 1976).
(2)(A) The Administrator shall develop, promulgate, and revise as may be appropriate, regulations designating as hazardous substances, other than oil as defined in this section, such elements and compounds which, when discharged in any quantity into or upon the navigable waters of the United States or adjoining shorelines or the waters of the contiguous zone or in connection with activities under the Outer Continental Shelf Lands Act or the Deepwater Port Act of 1974, or which may affect natural resources belonging
to, appertaining to, or under the exclusive management authority of the United States (including resources under the Fishery Conservation and Management Act of 1976), present an imminent and substantial danger to the public health or welfare, including, but
not limited to, fish, shellfish, wildlife, shorelines, and beaches

Clean Water Act (CWA) and CERCLA hazardous substance lists

What is the relationship between the hazardous substance lists under the Clean Water Act (CWA) and under CERCLA?

All CWA hazardous substances are CERCLA hazardous substances (only some CERCLA hazardous substances are CWA hazardous substances). Table 117.3 in 40 CFR 117.3, which is entitled “Reportable Quantities of Hazardous Substances,” lists substances that were designated as hazardous under section 311(b)(4) of the CWA. Table 117.3 provides the CWA RQs for the substances. Substances designated under this section of the CWA are automatically CERCLA hazardous substances because CERCLA section 101(14) defines “hazardous substance” chiefly by reference to lists under other statutes, including CWA section 311(b)(4). Therefore, all of the hazardous substances in Table 117.3 are also in the list of CERCLA hazardous substances.

Table 117.3 – Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act

Protection of Environment
General Provisions
Determination of reportable quantities.
§ 117.3 Determination of reportable quantities.
Each substance in Table 117.3 that is listed in Table 302.4, 40 CFR part 302, is assigned the reportable quantity listed in Table 302.4 for that substance.

Material Category RQ in pounds (kilograms)
Hydrofluoric acid B 100 (45.4)
Sodium fluoride C 1,000 (454)


Fluoride 7782414 4.0
The U.S. Environmental Protection Agency (US EPA) completed a scientific assessment of fluoride in response to a 2006 National Academy of Sciences (NAS) report recommending that US EPA update its fluoride health and exposure assessments to take into account bone and dental effects and to consider all sources of fluoride. Based upon the NAS and US EPA information and its own independent assessment, the U.S. Health and Human Services (HHS) issued a final recommendation on April 27, 2015, lowering the non-regulatory HHS limit for fluoride in drinking water to 0.7 mg/L. US EPA is currently considering whether to lower its fluoride MCL of 4 mg/L

CDC Sources of Fluoride Additives

Most fluoride additives used in the United States are produced from phosphorite rock. Phosphorite is mainly used for manufacturing phosphate fertilizer. Phosphorite contains calcium phosphate mixed with limestone (calcium carbonates) minerals and apatite—a mineral with high phosphate and fluoride content. It is refluxed (heated) with sulfuric acid to produce a phosphoric acid-gypsum (calcium sulfate-CaSO4) slurry.

The heating process releases hydrogen fluoride (HF) and silicon tetrafluoride (SiF4) gases, which are captured by vacuum evaporators. These gases are then condensed to a water-based solution of approximately 23% FSA.

Approximately 95% of FSA used for water fluoridation comes from this process. The remaining 5% of FSA is produced in manufacturing hydrogen fluoride or from the use of hydrogen fluoride to etch silicates and glasses when manufacturing solar panels and electronics.

Since the early 1950s, FSA has been the main additive used for water fluoridation in the United States. The favorable cost and high purity of FSA make it a popular additive. Sodium fluorosilicate and sodium fluoride are dry additives that come from FSA.

FSA can be partially neutralized by either table salt (sodium chloride) or caustic soda to get sodium fluorosilicate. If enough caustic soda is added to completely neutralize the fluorosilicate, the result is sodium fluoride. About 90% of the sodium fluoride used in the United States comes from FSA. Sodium fluoride is also produced by mixing caustic soda with hydrogen fluoride.

Shrewsbury’s Hydrofluorosilicic Acid Supplier (HFSA – CAS Number 16961-83-4)

Note: Shrewsbury puts out to bid each fiscal year for treatment plant chemicals.

07/01/2015 – Solvay Flourides out of Houston, Texas and the other supply comes from Lees Creek, North Carolina

Solvay Fluorides, LLC – HYDROFLUOROSILICIC ACID – Technical Data Sheet

  • Fluorosilicic acid is a transparent, clear to straw-colored, corrosive liquid having the chemical formula of H2SiF6

Solvay Fluorides, LLC – HYDROFLUOROSILICIC ACID – Safety Data Sheet

Solvay Fluorides, LLC – HYDROFLUOROSILICIC ACID – Product Safety Summary

  • Concentrated fluorosilicic acid solution (FSA) is used for water fluoridation, as a metal surface treatment and cleaner and for pH adjustment in industrial textile processing or laundries. It can also be used in the processing of hides, for hardening masonry and ceramics and in the manufacture of other chemicals.

Tax Money Wasted

Shrewsbury has paid almost $125,000 in the past 8 years to purchase industiral-grade fluoride, which means that over approximately $124,000 worth of fluoride was wasted because it never reached a citizen’s tooth.

Over 99.5% of that fluoridated water never even touches a person’s tooth – instead it ends up on lawns, down shower drains, toilets, laundry etc.   We put about 3,000 gallons/yr  of HYDROFLUOROSILICIC ACID into the public water system and more than 99% of that just goes down the drain polluting the environment (given it is a toxic hazardous material – more toxic then lead!) (note: we were putting about 5,000 gallons/yr  when it was at concentration of 1ppm).  We drink the other 0.5% and therefore, it pollutes us.  About half of the fluoride we take in our bodies gets stored in our bodies – bones, pineal gland, etc.).

Tax dollars spent on Fluoride from 2009 thru 2016 (8 yrs) =  $124,950

  • Taxes spent on Fluoride that never touched a citizen’s tooth  ($124,950 * 99.5%) = $124,325
  • Taxes spent on Fluoride that may have actually touched teeth ($124,950 * 0.5%) =  $625
 Fiscal Year Expended
2018   $25,000 (recommended)
2017  $25,000 (requested)
2016  $8,192
2015 $12,671
2014 $13,185
2013 $13,644
2012 $19,710
2011 $13,664
2010 $21,488
2009 $22,396

Massachusetts General Laws

Water Fluoridation in MA: A thirty year review

The compulsory referendum law on fluoridation was enacted in 1958. This law required a public referendum before a local Board of Health could order fluoridation.   Coupled with the self-governing autonomy of each of the 351 communities in Massachusetts, the law allowed the anti-fluoridationists to be successful in stopping fluoridation from being implemented.

In 1966, the Special Legislative Commission on the Condition of Dental Health was established by the Massachusetts legislature to study the prevalence of dental disease and ways to improve the dental health of school age and preschool age children.  The Special Commission advised that the compulsory referendum law of 1958 be repealed and water fluoridation be ordered by the local Board of Health on the recommendation of the State Commissioner of Public Health.  The Legislative Commission filed this recommendation as a bill in 1967.  After an arduous, successful educational campaign by the dental and public health community, the bill passed in the state legislature and Governor John Volpe signed the new fluoridation law in 1968.

This new law allowed a local Board of Health to order fluoridation based on the recommendation of the State Commissioner of Public Health.  If 10 percent of a community’s registered voters signed a petition within 90 days of the publication of the order, the fluoridation order had to be placed on the ballot for a vote at the next city, town, or district election.


Section 8C Fluoridation of public water supplies by local boards; advice of commissioner; election; discontinuance

Section 8C. The department in taking cognizance of the dental health of the people in the commonwealth shall recommend such methods as in its opinion are advisable to reduce or limit the prevalence of dental caries and other dental diseases and defects. If the commissioner determines that the fluoride content of the public water supply for domestic use in any city, town or district is not at optimum level for sound dental health, he shall so notify the local board of health of his findings. Such board of health, after making such inquiry and other use of the consulting services of the department or elsewhere as it chooses, shall, if it considers doing so in the best interest of the inhabitants of the city, town or district within its jurisdiction, order the upward adjustment of the fluoride content of the water supply available for domestic use in that city, town or district. No such order shall be effective until ninety days after it has been published in a newspaper having a general circulation in such city or town, or until favorable vote has been taken in accordance with the provisions of this section, whichever occurs later.

The provisions of this section shall not apply if two or more cities or towns are supplied water from the same source, if such supply to each city or town cannot be treated independently and if the majority of the boards of health representing such cities and towns have voted not to accept such recommendation; provided, however, that any such city or town desiring to adjust upward the fluoride content of the water consumed within its own jurisdiction may comply with the order by the installation of proper equipment that will comply therewith if it does not interfere with the water supply of said other cities or towns.

In any city, town or district where the board of health has ordered the upward adjustment of the fluoride content of the water supply under the provisions of this section, upon petition of ten per cent of the registered voters of said city, town or district, filed in the office of the city or town clerk, as the case may be, within ninety days of the publication of such order, the following question shall be placed upon the official ballot to be used at the next regular city election or for the election of town officers at the next annual town meeting or at a biennial state election, whichever occurs first, but not earlier than sixty days following the date of filing the petition with the city or town clerk:?”Shall the public water supply for domestic use in (this city) (this town) be fluoridated?”, or in such district the following question shall be placed before the next annual meeting of the inhabitants of the district:?”Shall the public water supply for domestic use in this district be fluoridated?” If the majority of votes in answer to said question is in the negative, the water supply of such city, town or district shall not be fluoridated, and the fluoridation of such water supply shall not be ordered again by the board of health for a period of at least two years from the date of such vote.

U.S. Department of Health and Human Services (HHS) – Office of Disease Prevention and Health Promotion (ODPHP) – Healthy People 2020 – Oral Health Goals

OH-13 – Increase the proportion of the U.S. population served by community water systems with optimally fluoridated water
Baseline: 72.4 percent of the U.S. population served by community water systems received optimally fluoridated water in 2008
Target: 79.6 percent
Target-Setting Method: 10 percent improvement
  • Massachusetts is at 70.4% as of 2014




Council on Advocacy for Access Prevention (CAAP) Fluoridation Report by State – December 2016

Communities/water districts voting to reject fluoridation since 2000.

  • Amesbury 2011
  • Littleton 2008
  • Yarmouth 2008
  • Methuen 2002
  • Plainville 2002
  • Worcester 2001
  • Brewster 2001
  • Wilmington 2000

Communities/water districts voting to initiate or retain fluoridation since 2000.

  • Shrewsbury 2016
  • Duxbury 2016
  • Brockton 2015
  • Concord 2015
  • Gloucester 2015
  • Newburyport 2015
  • Oak Bluffs 2015
  • Rockport 2015
  • Shrewsbury 2015
  • Templeton 2015
  • Topsfield 2015
  • Duxbury 2013
  • Templeton 2013
  • Woodland 2013
  • Groveland 2011
  • Templeton 2011
  • Athol 2009
  • North Attleboro 2007
  • Long Meadow 2007
  • New Bedford 2006
  • North Attleboro 2005
  • Woburn 2002
  • North Attleboro 2000

City of Amesbury Water Department Fluoride Statement

The City of Amesbury is currently not fluoridating the drinking water and has not been doing so since February of 2009. Fluoridation was stopped due to a poor quality and inconsistent supply of sodium fluoride.

Fluoridation was implemented by using an upflow saturator. This is a simple process where granular sodium fluoride is added to a tank with water and the sodium fluoride dissolves. Laws governing chemistry yield a set saturated solution of fluoride ions. This solution is then added to the drinking water to deliver a concentration of 1 part per million (ppm) of fluoride. The system is extremely simple and requires little maintenance. Increasingly, over the years poorer quality of sodium fluoride was finding it’s way into Amesbury. The material would dissolve insufficiently plugging the suction screen in the saturator. The result was an erratic level of fluoride. At the beginning of 2009 supplies of “good” sodium fluoride were not available. It was decided then to discontinue fluoridation till further notice due to the fact that a dependable level of fluoride could to be delivered to residents.

NH State-wide Fluoride Warning Law – Passed 2012

Example NH Water Confidence Report with Fluoride Warning

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