FAN's response to the lowering of fluoride in drinking water to 0.7 ppm in the U.S.
January 8, 2011
The wheels of bureaucracy grind slowly. Fourteen years after public health dentists recommended that fluoride levels be reduced to 0.7 ppm (Heller et al.), the Department of Health & Human Services has officially recommended doing so.
Fluoride Action Network is concerned that this new level of fluoride in drinking water has been set too high. It neither protects teeth from dental fluorosis, the stated reason for the lowering, nor does it protect the baby's developing brain, an issue not even mentioned by either the CDC or the EPA.
- A recent government report estimated that 41% of adolescents aged 12-15 have dental fluorosis (Beltrán-Aguilar et al.). However, the government has not investigated if these adolescents have suffered any other effects from overexposure to fluoride.
- There have now been over 100 studies reporting that fluoride damages animal brain. There have also been 24 studies that have shown an association between exposure to moderate-to-high levels of fluoride and lowered IQ in children (Connett et al.). While some proponents have criticized the methodology of some of these studies, no fluoridated country (except for one small study in NZ) has attempted to repeat them. Ironically, the 24th IQ study (Xiang et al.) has just been pre-published online by Environmental Health Perspectives. This journal is published by the National Institute for Environmental Health Sciences (NIEHS) which is part of the DHHS. So the DHHS can hardly dismiss this study based upon a weak study design since it was peer-reviewed and deemed suitable for publication by one of its own agencies -- an agency, in fact, that specializes in environmental health research.
- An infant who receives formula reconstituted with fluoridated tap water at this new level (0.7 ppm), will receive approximately 175 times more fluoride than a breast-fed infant. These infants are not being protected with this new level and CDC, EPA and ADA must clearly inform parents, caregivers, and health providers that infant formula should only be reconstituted with non-fluoridated water. In fact, a failure to be aggressive with such warnings is tantamount to admitting that this apparent concern about dental fluorosis is a sham intended to deflect attention from other more serious health concerns.
- In its announcement, the DHHS made no mention of other adverse effects of fluoride in drinking water aside from dental fluorosis. The landmark report published by the National Research Council of the National Academies (NRC 2006) noted three adverse health effects that warranted lowering of the current Maximum Contaminant Level allowed for fluoride in drinking water (currently set at 4 ppm). The following two adverse health effects were not mentioned by DHHS: bone fractures and pre-clincical stages of skeletal fluorosis, which manifests with symptoms identical to arthritis (stiffness of the joints and pain in the joints and bones).
- When EPA Assistant Administrator for the Office of Water Peter Silva stated, “EPA’s new analysis will help us make sure that people benefit from tooth decay prevention while at the same time avoiding the unwanted health effects from too much fluoride” (DHHS 2011) he was violating the mandate of the EPA in determining water standards. The EPA regulates contaminants not additives to water. It has no role to play in assessing the purported benefits of additives. Moreover, when determining the maximum contaminant level for contaminants that determination should be based entirely on what is deemed safe. This determination should not be tainted by concerns about purported benefits. Thus this collaboration between the DHHS (actually the oral health division of the CDC) is undermining the EPA's procedures and represents a clear conflict of interest. The CDC is actively involved in the promotion of water fluoridation and the EPA's Office of Drinking Water is supposed to be setting water standards which are protective of the whole population, including vulnerable subsets, from known and reasonably anticipated adverse health effects.
The EPA must tell us what is safe and use the best science to do it. Accommodating the CDC's desire to protect the water fluoridation program at all costs, is a betrayal of the American public’s trust in the EPA. That betrayal is best observed in the willingness of the EPA to do away with a margin of safety in determining a safe reference dose (RfD). The reasoning they used for eliminating a safety factor (or in their jargon, choosing an “uncertainty factor” of 1) was as follows:
"In establishing an estimated oral RfD for fluoride, data on nutritional benefit were assessed in combination with the data on severe dental fluorosis to define a level that provides anticaries protection without causing severe dental fluorosis when consumed daily for a lifetime. Conventional application of uncertainty factors is not always appropriate when carrying out a risk assessment for nutrients and other beneficial substances, especially when there is a relatively small difference between the levels that satisfy need and those that cause adverse effects. For this reason the total uncertainty factor applied was 1." (US EPA, 2010).
What independent observers would conclude based on this tortuous logic is that there is an unacceptable safety margin between a so-called beneficial level and the level that causes harm and that this makes the fluoridation program untenable. Moreover, such analysis only considers the damage to teeth (dental fluorosis)– and doesn’t even begin to address the issue of how small the margin of safety is between the level that purportedly reduces tooth decay and the levels that may cause a lowering of IQ.
- According to Kathleen Thiessen, PhD, one of the authors of the NRC 2006 report:
"[W]hile the proposed recommendation for a lower national fluoride level in drinking water is a step in the right direction, and a quiet admission that some people are ingesting too much fluoride, a number of concerns are not yet addressed. Infants fed reconstituted formula, people with high water consumption (e.g., athletes, laborers, persons with medical conditions such as diabetes insipidus), persons with impaired kidney function (and consequent reduced excretion of fluoride), and persons with a hypersensitivity to fluoride will continue to have fluoride intakes in excess of a safe level, even when the new recommendation is implemented. These people also deserve to be protected." (Thiessen, 2011)
- No mention has been made by the HHS or EPA that the chemicals used to fluoridate drinking water in the US are hazardous waste byproducts of the phosphate fertilizer industry. This is the first time in the history of mankind that highly hazardous waste has been shown to have health benefits, yet no toxicological studies have been performed on them.
Note: The EPA released many pages of analysis that will contribute to a risk assessment to establish a new safe drinking water standard. We have not had time to examine these in detail but we will be responding to those later. The alarming thing to note now is that the EPA water division has clearly signaled its intention to produce (or engineer) an MCLG that avoids challenging the safety of the water fluoridation program. Once again politics has triumphed over science.
References
Beltrán-Aguilar ED, et al. 2010. Prevalence and Severity of Dental Fluorosis in the United States, 1999-2004. NCHS Data Brief Number 53, November. Online at http://www.cdc.gov/nchs/data/databriefs/db53.htm
Connertt P, Beck J and Micklen HS. 2010. The Case Against Fluoride: How Hazardous Waste Ended Up in Our Drinking Water and the Bad Science and Powerful Politics That Keep It There. Chelsea Green. Appendix 1, Fluoride and the Brain, online at http://fluoridealert.org/caseagainstfluoride.appendices.html
DHHS (Department of Health and Human Services). 2011. HHS and EPA announce new scientific assessments and actions on fluoride. Press release. January 7. Online at http://www.hhs.gov/news/press/2011pres/01/20110107a.html
Heller KE, Eklund SA, and Burt BA. 1997. Dental caries and dental fluorosis at varying water fluoride concentrations. Journal of Public Health Dentistry 57(3):136-43. Abstract at http://www.ncbi.nlm.nih.gov/pubmed/9383751
National Research Council of the National Academies. 2006. Fluoride in Drinking Water: A Scientific Review of EPA's Standards. Online.
Thiessen K. 2011. Thiessen on new 0.7 ppm level of fluoride in drinking water in the U.S. January 7. Online at http://fluoridealert.org/thiessen.jan.7.2011.html
U.S. Environmental Protection Agency. 2010. Fluoride: Dose-Response Analysis For Non-cancer Effects. Report 820-R-10-019. Health and Ecological Criteria Division, Office of Water. Page 105. December. Online at http://water.epa.gov/action/advisories/drinking/upload/Fluoride_dose_response.pdf
Xiang Q., et al. 2010. Serum Fluoride Level and Children’s Intelligence Quotient in Two Villages in China. Environmental Health Perspectives. Online December 17. Online at http://www.fluoridealert.org/re/xiang-dec.17.2010.ehp.pdf
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