Minister of State Deputy Róisín Shortall T.D.
CC: Department
of Taoiseach
Minister for
Health
Minister
For Agriculture, Food and Fisheries
Minister
for Environment
Minister
for Justice, Equality and Defence
Deputy
Dessie Ellis T.D.
Deputy Emmet
Stagg T.D.
23rd
March 2012
Response to Parliamentary
Question 681 and 706 dated 21ST March 2012
Dear Minister,
I note your response to
parliamentary questions by Deputy Ellis’s T.D., (ref:681/706) and further to my
correspondence of 21st March in respect of parliamentary question
(ref: 14533/12) by Deputy Stagg T.D., regarding my report on the Human
Toxicity, Environmental impact and Legal Implications of Water Fluoridation.
I respectfully advise the Minister that in quantifying the potential
public health risk from fluoridation of drinking water, in excess of fifty
comprehensive epidemiological, toxicological, clinical medicine, and
environmental exposure assessments were identified by the U.S. National
Research Council (NRC) and the European Commission‘s Scientific Committee on
Health and Environmental Risks (SCHER). The undertaking of these studies is
regarded as of paramount importance for the protection of public health in
communities where water fluoridation in practised, the details of which have
been examined in my report.
In response to
the parliamentary question by Deputy Ellis T.D., the Minister has confirmed the
findings of my report, which are that the Department of Health has no
information on the mutagenic, teratogenic, developmental neurotoxicity,
cytotoxicity, carcinogenic effects, cogenotoxicity, short-term and sub-chronic
exposures or synergistic/antagonistic effects of fluoride or Hexafluorosilicic
acid or silicofluoride compounds on human beings despite the numerous
recommendations from scientific bodies that efforts be made to determine the
toxicity of fluoride and silicofluoride products.
Furthermore, the
Department of Health confirms that no human or animal health risk assessments
have ever been completed on its behalf on silicofluorides and that the
biological or toxicological impacts have never been fully examined by the
Department. In addition, the Department of Health confirms that no studies have
been undertaken examining the interactive co-toxicity public health risks
associated with silicofluoride compounds when mixed with other water treatment
chemicals such as aluminium compounds. As a consequence, despite the clear
recommendations of international scientific bodies, the Government of Ireland
through the Department of Health continues to use untested products without
undertaking the necessary precautions to protect public health, consumers and
the environment.
The Minister is
to be advised that the dental epidemiological research studies noted in her response
do not qualify in any scientific capacity as studies that examine or determine
the overall human health and toxicological risks associated with the ingestion
of silicofluoride compounds in drinking water.
These dental
studies merely examine the prevalence of dental caries within society. In
contrast, the latest studies by O Mullane et al.[1] (2003) Browne et al.[2] (2005) and Verkerk et al.[3] (2010) find that the prevalence of dental fluorosis, representing
chronic overexposure of the population to fluoride, has now reached endemic
proportions in Ireland and that water fluoridation is the principle cause of
the increased incidence. The
Minister is advised that the study by O Mullane et al. identified that the
prevalence of dental fluorosis in communities with no fluoridated water was as
low as 1.5% compared to 37% in fluoridated communities. It was also documented
that no children were observed with moderate or severe dental fluorosis in
non-fluoridated communities.
For a better
understanding of the international findings with respect to dental health
worldwide the Minister is requested to review Chapter 9 of my report which
highlights how the decline in dental caries prevalence has been reported in all
non-fluoridated communities worldwide and that this has been identified as due
to the use of fluoridated toothpaste and other factors such as nutrition and
not the use of fluoridated water.
The Minister is
also advised that the recommendations of the World Health Organisation[4]
and UNICEF Report on feeding and nutrition of infants[5]
noted that while there appears to be general consensus that an optimal fluoride
intake should be secured through either water fluoridation, fluoride
supplements or the use of fluoridated toothpaste, this recommendation is based
on one of the above intake pathways not both. In other words, if you use fluoridated toothpaste you do not need
fluoridated water. In other
jurisdictions, parents are also advised not to use fluoridated water in the
preparation of formula-feed for babies. It is accepted that in countries where
alternative vehicles for fluoride such as fluoridated toothpaste are widely
available and widely used, public authorities do
not need to fluoridate drinking water.
In light of the
information provided to you and your Department, and given that the Minister
has determined that the Department of Health intends to continue with the
policy of water fluoridation despite the clear lack of scientific data to
demonstrate that it is safe; the Minister, in the interests of public safety
and the most vulnerable in our society, is requested to reconsider this
position. Failure to protect
consumers and enforce EU law may result in legal action in an Irish or European
Court for negligent conduct or actions or systemic negligence in addition to
administrative, civil and criminal liabilities against Ministers who are
responsible not only for the conduct of the Government but the functions of
their Departments.
If the
government is to continue with the policy of mandatory fluoridation of drinking
water supplies, a thorough examination of the scientific recommendations
requiring further study must be undertaken immediately demanding comprehensive
and costly research, as outlined in my report. In the interim, it is clear that
in the absence of any such data or completion of the required toxicological
assessments a moratorium on water fluoridation must be put in place to protect
consumers. It is simply unacceptable that the State would continue to allow
untested chemicals to be added to public drinking water supplies.
Good governance demands that you respect the rights of
consumers and citizens and parents to safeguard their personal health and
protect their children’s wellbeing. Good governance should enhance human rights
as provided in the Charter for Fundamental Rights of the European Union, the EU
Treaty of Europe and United Nations’ Treaties mandating that all signatory
states, which include the Government of Ireland, comply with the ‘Precautionary
Principle‘. Failure to do so, in light
of the findings in this report, would represent a gross failure of
responsibility and political leadership.
The Minister is
also advised that contrary to the Minister’s statement, the majority of
scientific organisations advising national governments worldwide have
determined that the policy of water fluoridation is not safe. As it currently
stands, the following western European countries have rejected water
fluoridation: Austria, Belgium, Denmark, Finland, France, Germany, Iceland,
Italy, Luxembourg, the Netherlands, Norway, Sweden, Spain, Portugal,
Switzerland and the United Kingdom. In addition, most other non-EU countries
similarly support this position including China, Japan, Czech Republic and many
other nation states. There is only one other country in the world that supports
Ireland’s position on mandatory fluoridation of public water supplies. That
country is Singapore.
Yours sincerely
Declan Waugh
[1] O'Mullane DM,
Harding M, Whleton HP, Cronin MS, Warren JJ. Dental Fluorosis in Primary Teeth
of 5-year-olds in Ireland. Paper presentation
at American Association for Dental Research conference, San Antonio, USA in
March 2003.
[2] Browne D, Whelton
H, O‘ Mullane D, Oral Health Services Research Centre, University Dental
School, Cork. Fluoride metabolism and fluorosis, Journal of Dentistry, Volume
33 Issue 3, March 2005, Pages 177-186
[3] Verkerk, Robert
H.J. The paradox of overlapping micronutrient risks and benefits obligates
risk/benefit analysis, Journal of Toxicology, Feb 2010.
[4] Nutrients in Drinking
Water, Water, Sanitation and Health Protection and the Human Environment World
Health Organization, Geneva, 2005.
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