Attorney Jim Love explains why the Fawer study is not appropriate for basis of EPA’s RfC or ATSDR”s MRL. Both ATSDR and EPA have developed health guidance values (HGVs) for inhaled mercury vapors, based on a 1983 study of workplace exposures [Fawer 1983]. The workers in the Fawer cohort came from three different types of workplaces: fluorescent tube manufacture; chloralkali plants; and acetaldehyde production. These workers were exposed to both chlorine and mercury. Chlorine gas has been shown to inhibit the absorption of mercury by the body, thus it will take more mercury to induce the onset of symptoms, something not taken into account by either EPA or ATSDR when developing their health guidance values. The FDA also relied on these HGV’s when assessing if mercury from amalgam exceeded safety levels.

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The document below is not the entire Petition for Reconsideration submitted to the FDA, but a shortened version for this lesson topic with highlights about the deficits of the EPA’s RfC and ATSDR’s MRL and how FDA misused those levels to claim the safety of amalgam.

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