3 Oct 2014

My last letter to the Environmental Agency and their reply - robotic answer.

The SHA/PHE intended to pour in 200 tonnes of the stuff per annum and 2% impurities is a lot.

Dear Bill

As I said in my previous email, we assess each application to discharge mercury individually, and we take a number of site-specific factors into account. I am sorry I cannot be of any more assistance on this issue.



Gill Bellamy
Technical Advisor - Water Quality
E&B, Land and Water Quality
Environment Agency, Richard Fairclough House, Knutsford Road, Warrington, WA4 1HG

From: bill [mailto:bill@edmunds92.freeserve.co.uk]
Sent: 30 September 2014 12:33
To: Bellamy, Gill
Subject: Re: 140925/TB14 - PREVIOUS: 140924/RML02 - 140923/keh08

Did you know the impurities present in the fluoridation chemicals hexafluorosilicic acid? See below. The contents include mercury and even radioactive elements but as long as they are within the 2% limits no one cares including your department apparently.
Safety of water fluoridation
The UK's Water (Fluoridation) Act 1985, since incorporated into the 1991 Water Industry Act, allows hexafluorosilicic acid (H2SiF6) and disodium hexafluorosilicate (Na2SiF6) to be used to increase the fluoride content of water. The published Code of Practice on Technical Aspects of Fluoridation of Water Supplies (Department of the Environment, 1987) gives specifications for these substances and states that 'the product. ..must not contain any mineral or organic substances capable of impairing the health of those drinking water correctly treated with the product'. For H2SiF6, limits are given for a number of possible impurities, including for iron, heavy metals, sulphate, phosphate, and chloride. The specification for Na2SiF6 powder requires a minimum of 98% m/m of the pure chemical, and gives maximum limits for impurities, including heavy metals (as lead) and iron. No other substances are allowed to be used in the fluoridation process, other than an anti-caking agent (the identity of which must be disclosed) in the case of Na2SiF6. Synthetic detergents are not permitted.
Thus there is no likelihood, in normal operation, for any fluoridation plants to introduce other compounds into the drinking water supply (other than approved anti-cakinq aqents and any impurities present in the fluoridation chemicals).

1 comment:

Cllr Chris said...

Bill, I'm not at all sure we should accept this 2% impurities thing. This is how I put it in a recent letter to my Water Company (South Staffs Water).

"1. 2% heavy metal and other contaminants. BS EN 12175:2006 does not appear to be the protection SSW claims. Within its own text one can find these statements.

a) "This publication does not purport to include all the necessary provisions of a contract. Users are responsible for its correct application. Compliance with a British Standard cannot confer immunity from legal obligations." (Their emboldening)

b) "In respect of potential adverse effects on the quality of water intended for human consumption, caused by the product covered by this document: a) this document provides no information as to whether the product may be used without restriction in any of the Member States of the EU or EFTA ;"

c) "NOTE Conformity with this document does not confer or imply acceptance or approval of the product in any of the Member States of the EU or EFTA. The use of the product covered by this document is subject to regulation or control by National Authorities."

d) "NOTE Users of this product should check the national regulations in order to clarify whether it is of appropriate purity for treatment of water intended for human consumption, taking into account raw water quality, required dosage, contents of other impurities and additives used in the products not stated in this document."

e) "The marking shall include the following:
1. name "hexafluorosilicic acid", trade name and grade;" (My emboldening)

It also says on Spillage "Do not empty into drains". But it is put into our water all the same. But we'll let that one go for now.

The question here is what authority or direction is there in law to allow / require / direct the fluoridating water company into relying on this BS? Where is the requirement in law to allow this grade of acid which is used? As far as I can see the law only allows the pure acid - no impurities. That said I know the law would look to reasonableness in such things. Therefore I would expect a pharmaceutical grade to be used (+ 1% impurities as a maximum). The BS mentions grading. What is supplied to you by YARA industries may be a commercially viable industrial waste product grading, but it is not of pharmaceutical grade. This is after all being used for a medicinal purpose - to treat the human (and not the water as the BS keeps misleadingly saying). When the BS refers to the "dose" it refers to what "dose" the water is getting. It cannot possibly know what dose people may get as that would depend heavily on how much people drink, bathe, their methods of cooking and general exposure to the water.

There is therefore, as far as I can see, no law that allows the water company to drip feed impurities minute after minute, year after year, into the water supply alongside the fluoridation chemical. The cumulative amounts are serious and such toxic dumping would be stringently prosecuted if anybody else did it. It is irrelevant that the water that eventually issues from consumers' taps may keep below any set legal maximum impurities standards.

Can you show me the law that says that all this is not so?"

South Staffs Water refuse to respond. However, Severn Trent have similar information and I'm hoping they might give a response.