Monday, May 28, 2012

Environmental Impact of Fluoride on Freshwater and Terrestrial Ecosystems

Its not often one finds any international study that examines the environmental impact of fluorides from water fluoridation on the environment so its perhaps worthy to make the findings of this study available for the public to access.

While this report was undertaken in 1997, the findings of the study are still valid. The study was undertaken for a Task force established by the Mayor of Brisbane to review water fluoridation. The task force voted against commencing water fluoridation and recommended that before any such policy was commenced detailed environmental impact assessments should be undertaken to establish the environmental impact on terrestrial and freshwater ecosystems.

Here are the main findings:

The Taskforce accepted that there had been little examination of the environmental effects of water fluoridation world-wide.

The Taskforce accepted that the environmental impact of fluoride has never been fully considered in the debate about whether or not to fluoridate a public water supply.

The Task force accepted that consideration does need to be given to the impact of fluoride on the biological (plants and animals) and the physical environment (waterways, soil and air) of a community.

The Taskforce accepted the findings of Dr Miller’s study of the environmental impact of a fluoridated water supply.

The Review found that Fluoride has a long term, persistent, toxicological effect on the environment.

The Review found that Fluoride is a chemical element and the introduction of any fluoride will produce a toxic response in the environment.

The Review found that fluoride would affect some species and at different stages of their life cycle e.g. an adult form of a species may be more sensitive that the juvenile (e.g. rainbow trout).

The Review found some species of freshwater fish would be at an increased risk of biological harm from exposure to fluorides.

The Review found that fisheries, especially the juvenile species would be at some risk from the introduction of fluoride. In salt water, some species of adults would be more tolerant, however, juveniles (which live in bracken water) would be more susceptible. Within a sensitive species, part of the population, that is, the ‘sensitive within sensitive’ part of the population, maybe eliminated.

The Review found that some urban vascular plants, vegetables and crops were likely to be sensitive to elevated soluble fluoride from watering or irrigation. Freshwater ecosystems were also likely to be vulnerable.

The Review found that there is a higher level risk for terrestrial and agricultural plants.

The Review found that livestock and domestic animals would ingest higher levels of fluoride from drinking fluoridated water, fluoride watered forage and local feed.

The Review recommended that prior to any decision for the release of long-term additional fluoride into Brisbane’s environment experimental studies and other environmental and biological impact assessments should be conducted on sensitive plant and animal species that reflect the region’s biodiversity,

The Review concluded that there were some sensitive species that would be affected by the introduction of fluoridated water to the environment, including terrestrial and marine species.

The Review recommended that the impact of overall total fluoride emissions into receiving ecosystem must be considered given that fluoride was a persistent toxin that bio-accumulates in the environment.

The Review found that longer term environmental effects need to be examined and concluded that areas within a limited radius of discharge points would definitely be affected by fluoride pollution.

The Review found that some marine species may decrease.

With regard to implications for human health two of the main findings were:

There was considerable concern amongst many Taskforce members that water fluoridation could increase the total intake of fluoride in excess of a safe level for babies and young children.

There was also concern about the lack of scientific research on the lifetime effects of an accumulation of fluoride in the body.

Since then nothing much has changed, except that in 2009 under a new administration  Brisbane commenced water fluoridation at a cost of $35 million undertaking any environmental impact assessment of the policy. It was notable that in there first year the population were exposed to massive concentrations of fluoride due to repeated operator errors including one instance when fluoride concentrations were administered at >30mg/l in drinking water, 30 times the acceptable standard.

Thursday, May 24, 2012

Fluoride toxicity, its interaction with calcium and increased risk of heart disease

Professor Sabine Rohrmann from the University of Zurich recently published a report on the effects of the Calcium pill on cardiovascular health, which has been widely reported in the media today including the Irish Times and Irish Examiner. It appears that what Professor Rohrmann is suggesting is that calcium taken in supplement form will rapidly elevate calcium in the blood serum causing changes that may produce hard calcium deposits on the walls of arteries and therefore increasing your risk of having a heart attack.  I would have some queries regarding this as I myself take a calcium and magnesium supplement to counteract the fact that Iive in a geographic area in West Cork where there is very low natural calcium  or magnesium present in the drinking water. The concentration of calcium in drinking water in West Cork is < 20mg/l. In comparison in the province of Leinster the concentration may be as high as 250mg/l. The World Health organisation have reported that if you live in a geographic area with low calcium in drinking water you are more at risk of developing cardiovascular disease, cancer and neurological illness. So I take calcium and magnesium supplement that provides an extra 600mg calcium and 400mg magnesium daIly.  That’s equivalent to less than an extra glass of milk a day. From what Professor Rohramm is suggesting if you were to drink a glass a milk  a day or use the equivalent amount for your breakfast cereal you would be at an even greater increased risk of having a heart attack given that this one instant source contains more calcium than a single calcium supplement pill, which will take some time to be digested in your stomach.

It is well established that the substance which most effects calcium in the human body and in your blood serum is fluoride, which is consumed by individuals who drink fluoridated water such as provided to consumers in Ireland. As far back as 1993 the U.S. Agency for Toxic Substances and Disease Registry reported on the toxicological profile of fluorides and stated “because fluoride interacts with calcium ions needed for effective neurotransmission, fluoride can affect the nervous system."

In addition the Journal of Biological Chemistry found that fluoride not only inhibits enzymatic metabolism but that it also functions to prevent vital calcium and magnesium reactions as well as dramatically destabilising calcium binding in the body. Furthermore the Journal Environmental Toxicology and Chemistry, found that systemic calcium and magnesium levels in the human body are depleted as a result of fluoride intoxication. The bio-availability of fluoride and the role of calcium were also reported as a matter of some concern by the UK Medical Research Council (MRC) in 2002. They raised serious questions as to the health risks of water fluoridation in geographic areas with low calcium and magnesium levels such as  found in large areas of Ireland, particular Cork, Kerry. Limerick, Mayo and Donegal. Areas which also have an increased level of hypothyroidism most likely brought on from the increased bio-availability of fluoride in soft waters. 

Fluoride is known to be capable of inhibiting a number of important enzymes in the human body, including preglycolytic enzymes, phosphatases, and cholinesterase. In addition, it is reported by the United States National Library of Medicine, that inhibition of one or more enzymes controlling cellular glycolysis may result in binding or precipitation of calcium as calcium fluoride. Perhaps one of the most alarming potential consequences of fluoride exposure, as highlighted in the Journal of Nuclear Medicine in January of 2012 (titled: Association of vascular fluoride uptake with vascular calcification and coronary artery disease.) is that a significant correlation exists between fluoride uptake and calcification of the major arteries, including coronary arteries. 

That is, you are at a higher risk of having a heart attack with increased exposure to fluoride, for example by consuming fluoridated water.

It is interesting that Ireland has the highest incidence of cardiovascular illness in the world and coincidentally we are also the most fluoridated society in the world. Yet sadly most of our politicians who we elected to protect public interest and health bureaucrats in the HSE refuse to acknowledge the risk or do anything to minimize this risk for consumers. This could stop tomorrow if politicians and health professionals did their job properly.

Thursday, May 17, 2012

Key Questions for Environmental Health Officers and other Public Health officials Promoting Fluoridation

1.    Do you agree that while engineers can control the concentration of fluoride at the public water works, no one can control the dose of fluoride that people get because we can’t control how much water they drink? Or the fluoride they get from other sources?
2.    Do you know of any other medicine in which we don’t bother about controlling dose?
3.    Do you know of any other medicine that can be given to everyone—including babies, infants, children, adults and seniors, people who are not well and people who have poor nutrition?
4.    There is no other medicine we put in the drinking water. Why is this do you think?
5.    Do you agree that subsets of the population drink much more water than others? What are those subsets?
6.    Are you aware of the influence of fluoride on enzyme systems?
7.    Given that is accepted that fluoride acts as an enzymatic inhibitor what is the safe level for blood fluoride serum in humans taking into consideration adequate safety precautions for the most high risk subgroups?
8.    Are you aware that the World Health Organization has stated that patients with kidney dysfunction may be particularly susceptible to fluoride toxicity in the body?
9.    The World Health Organization have stated that It is known that persons suffering from certain forms of renal impairment have a lower margin of safety for the effects of fluoride than the average person. Have you undertaken any quantitative evaluation of the increased sensitivity to fluoride toxicity of such persons?
10.    Are you aware that it has been documented (United States National Research Council Fluoride in Drinking Water: A Scientific Review of EPA's Standards 2006) that children and others with poor control of swallowing (Down syndrome, Autistic children) could have intakes of fluoride from dental products that exceed the dietary intakes? Have you quantified the total dietary exposure for such risk sub groups?
11.    Do you agree that a bottle-fed baby using fluoridated to make up formula milk can get 150 times more fluoride than a breast-fed one, since the level of fluoride in mothers’ milk in a non-fluoridated community is 0.003-0.004 ppm (European Food Safety Authority)
12.    Do you agree with the American Dental Association, the American Academy of Pediatric Dentistry, the American Academy of Pediatrics and the Canadian Pediatric Society that fluoride should not be given to infants under 6 months?

13.    Do you agree that Irish children are getting too much fluoride today as evidenced by high dental fluorosis rates?
14.    Are you aware of the studies by O Mullane et al.  (2003) Browne et al.  (2005) and Verkerk et al.  (2010) who found 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 has been found to be a principle cause of the increased incidence.

15.    Do you know what the average level of fluoride is in the urine, blood, bone and hair of people in this state?
16.    Have any attempts been made to collect such values on a systematic or comprehensive basis? If not, why not?


17.    What primary published peer-reviewed studies have convinced you that it is safe to ignore the findings of international peer reviewed studies that have found fluoride to be a neurotoxin and that modest exposure lowered IQ in children in geographic areas with endemic fluorosis?

18.    Considering that most dental researchers now concede as did the European Commission scientific assessment on fluoride in 2010 that the major benefit of fluoride, if one exists, is TOPICAL not SYSTEMIC, why do you feel justified in forcing people to be exposed systemically through their drinking water?
19.    Why expose every tissue in the body including the bones, the brain and the endocrine system to a toxic substance when its benefit can be achieved topically via fluoridated toothpaste?

20.    Are you aware of any randomized clinical trial (the gold standard for epidemiological studies) that has demonstrated fluoridation’s effectiveness at reducing tooth decay?
21.    What primary published peer-reviewed studies (as opposed to reviews) have most convinced you that swallowing fluoride actually reduces tooth decay by a significant amount?
22.    What confounding variables did these studies control for?
23.    Did these studies control for possible delayed eruption of teeth?


24.    Would you agree that tooth decay is concentrated largely in families of low income? Would you agree that it would make more sense to target children from low-income families with education for better dental hygiene and better diet rather than forcing them to drink a toxic substance they can’t avoid?
25.    Would not a campaign to get children to consume less sugar have the combined benefit of helping to fight tooth decay AND obesity and diabetes?

26.    Are you aware, according to the European Commission, that the toxicological characteristics of the chemicals used to fluoridate public water systems are inappropriately known?
27.    Based on numerous MSDS (material safety data sheets) it is clear that one of the contaminants of these fluoridating chemical is arsenic. Are you aware that the US EPA considers that there is no safe level of exposure to arsenic (or any other cancer-causing chemical) because it is a known human carcinogen?
28.    Would you agree that inevitably means that by using these arsenic- contaminated industrial grade chemicals we are knowingly increasing the cancer rates in this country?
29.    Do you think it is justifiable to increase cancer rates in order to possibly reduce tooth decay by a very small amount via ingestion when topical treatment with fluoridated toothpaste can achieve the same result?

30.    Are you aware that fluoride has been used as a successful drug to treat overactive or hyperthyroid conditions because it suppresses thyroid function?
31.    Can you show us research that the accumulative effect of fluoride ingestion over many years is not a factor in lowering thyroid function?
32.    Are you aware that extremely high levels of hyperthyroidism have been found in geographic locations with very soft drinking water that is fluoridated?
33.    Are you aware that the bioavailability of fluoride increases with reduction in water hardness.

34.    Are you aware that the first symptoms reported in skeletal fluorosis cases in countries that have high natural levels of fluoride in their water are identical to the symptoms of arthritis (stiff and painful joints and pains in the bones)?
35.    Do you know what the arthritis rates are in this country?
36.    Do you know if there have been any studies to investigate a possible relationship between arthritis, musculoskeletal pain and consumption and dietary exposure to fluoride from drinking fluoridated drinking water?


37.    Are you aware that 99.5% of all fluoridated water is not used for the purposes it was intended and is discharged directly into the environment, via discharges from waste water treatment plants and the application of urban waste water biosolids onto agricultural land?
38.    Are you aware of any environmental or ecological study that has been undertaken examining the environmental impact of fluoride emissions on inland fisheries in Ireland?
39.    Are you aware of the toxicity of fluoride to freshwater fisheries such as Salmon or Trout?
40.    Are you aware that aquatic organisms living in soft waters with low ionic content are more adversely affected by fluoride pollution and that levels as low as 0.2ppm have been found to be detrimental to inland fisheries?
41.    Are you aware that fluoride is regarded as a persistent, bio-accumulative toxin in the environment?

Friday, May 4, 2012

Water Fluoridation letter to Director General of European Commission Scientific Committee on Health and Environmental Risks

Mr. John Dalli
Director General of SANCO

Mr. David Lowe
European Parliaments Petitions Committee Secretariat

Human Toxicity, Environmental Impact and Legal Implications of Water Fluoridation
Public Health Risks from Dietary Overexposure to Fluoride Compounds.

4h May 2012
Dear Sirs

I previously forwarded you a report entitled The Human Toxicity, Environmental Impact and Legal implications of Water Fluoridation.  I await an acknowledgement that you have received my report and letter post-dated the 8th March 2012.

One of the main concerns expressed in this report was the overexposure of large portions of the population to fluoride from silicofluoride chemicals used for the artificial fluoridation of drinking water. This is particularly the case for sensitive subgroups of the population especially babies and diabetics, nothwithstanding the aggregate health risks posed to the wider community from cumulative fluoride overexposure from fluoridated water in addition to other dietary sources of fluoride.   The report highlighted many important issues including how fluoridation of public water supplies combined with other dietary exposure is resulting in systemic toxicity to fluoride amongst the wider population.

It is evident that the concerns of the scientific community regarding exposure to fluoride are similar to those expressed by healthcare professionals and environmentalists regarding metal contaminant levels for other parameters such as lead, cadmium or arsenic or indeed from the overuse of antibiotics or prescribed medication which is now also systemic amongst populations especially, in developed countries. It is acknowledged and accepted that fluoride is a contaminant of not just water but food and beverages such as rice or tea. 

It is also a major component in many pharmaceutical drugs. Recent scientific studies have confirmed that fluoride contamination of foodstuffs has reached a critical tipping point for consumer safety. This is due to a combination of sources including fluoride-based pesticides (there are over one hundred and fifty fluoridated pesticides), herbicides and fumicants such as Sulfuryl Fluoride, in addition to airborne fluoride from industrial atmospheric pollution and the application of certain phosphate-based fertilisers which can also contain high levels of fluoride, in combination with anthropogenic fluoride from artificially fluoridated drinking water which contaminates any food which it comes in contact with. As a consequence, fluoride is now ubiquitous in food and water, and the potential for human exposure is substantial.

While it is now acknowledged by scientific bodies including the U.S. Agency for Toxic Substances and Disease Registry (ATSDR) and the U.S. National Research Council (NRC) that subsets of the population including the elderly, people with deficiencies of calcium, magnesium, and/or vitamin C, and people with cardiovascular and kidney problems may be unusually susceptable to the toxic effects of fluoride, these very individuals cannot limit their exposure to this toxin if they live in a geographic areas where public water supplies are artifically fluoridated.

The WHO have stated that elevated fluoride intakes can have serious effects on skeletal tissues. The WHO Guidelines for Drinking Water 2004 found that there is a clear excess of adverse skeletal effects for an individual with a total intake of 14 mg/day and suggestive evidence of an increased risk of effects on the skeleton at total fluoride intakes above 6 mg/day.

As with antibiotics, it is now acknowledged that widespread overexposure to the toxin fluoride is now occuring at dangerously high levels that are clearly impacting negatively on the health and wellbeing of consumers as well as natural ecosystems. While the recent public statement of warning by the Chief Executive of WHO on the overuse of antibiotics is to be welcomed, as is the WHO concern about the future mental health crisis regarding the increased prevalence of dementia within the population, it is now also absolutely clear from the vast amount of published scientific information readibly available, that overexposure to fluoride has also become a serious public health problem. This is particularly the case in countries such as Ireland and the USA where there is systemic fluoridation of drinking water supplies. The exposure of the population to dangerously high levels of fluoride compounds from fluoridated drinking water combined with dietary intake from processed food, cooked food, beverages and pharmaceutical medications, as well as other major sources of fluoride in dental hygiene products such as toothpaste or mouthwashes must be urgently addressed in order to prevent a further crisis in healthcare at an international level.

The WHO have consistently and correctly stated that "in the assessment of the safety of a water supply with respect to the fluoride concentration, the total daily fluoride intake by the individual must be considered."  The WHO Guidelines for Drinking Water similarly recommend that “when setting national standards for fluoride that it is particularly important to consider volume of water intake and intake of fluoride from other sources.” Unfortunately these recommendation were never applied by the Health Authorities in Ireland. The Department of Health continue to misrepresent the WHO recommendations by stating that the WHO have found fluoridation of drinking water to be safe, without acknowledging that the WHO also clearly state that this cannot be found as fact unless the the total daily fluoride intake by the individual is first considered. The Health Authority have further failed to acknowledge the findings of both the ATSDR and the NRC which found that subgroups of the population remain susceptable to the toxic effects of fluoride, even at relatively low concentrations. In the interests of public health and safety it is necessary for the WHO to reafirm these facts.

Unlike other countries no dietary fluoride assessment of foodstuffs has ever been undertaken in Ireland. No data is available for consumers or healthcare practioners to accurately calculate total dietary exposure. In the absence of such necessary information it is clearly an unacceptable practice to continue to impose mandatory fluoridation of all public water supplies, it is evident that to support such a policy would not only be inappropiate but potentially dangerous but must be discouraged by the WHO. Continuation of mandatory systemic fluoridation of public water supplies in the absence of necessary epidemiological, toxicologial or environmental exposure data cannot be recommended as a safe preventative health policy.

It is evident that no competent physician would prescribe for a person they have never met and whose medical history they do not know, a substance which is intended to create bodily change, with the advice that they take as much as they like with no prescription, medical checkup or ongoing medical surveillance and continue to do so regardless of that individual’s health status or their possible sensitivity to fluoride compounds; furthermore that they would do so regardless of the individual’s total fluoride dietary exposure, while demanding that the patient must continue to self administer this medication for the rest of their lives, because some children may suffer from tooth decay. Every right-minded individual would accept that this is a preposterous notion especially as both the NHS York Review and the EU SCHER Review among others found fluoridation of drinking water to be of questionable benefit to anyone, while also observing as fact that it is a harmful toxin that causes bodily harm. Yet ironically this is exactly what the policy of artificial  fluoridation of drinking water entails.

As with the threat posed by over medication of prescription drugs or antibiotics it is now well-established that overexposure to fluoride is endemic in society, especially in countries where systemic fluoridation of public water supplies continues to be practised. Sensitive subgroups of the population who are at risk of developing skeletal or dental fluorosis and who have no requirement or need for additional exposure to this toxin by consumption of artifically fluoridated drinking water nevertheless are unnecessarily placed in harms way and exposed to additional fluoride that they have no manner or means of removing safely from their drinking water supply.

It has been found and accepted that the topical application of fluoride with toothpaste, not the systemic fluoridation of drinking water, is the most efficient and beneficial mode for preventing dental caries. In communities where children use fluoridated toothpaste in addition to consuming fluoridated water they are unnecessarily put in harm’s way of developing harmful, permanent and potentially crippling health effects. Some of the public health implications relating to systemic water fluoridation are well documented, for example, it is now generally accepted worldwide that babies under twelve months of age should never be exposed to fluoride or consume fluoridated water with formula milk. Yet, this practice is endemic in some countries especially Ireland, which has the lowest level of breastfeeding of any country in the world. Incredibly the Health or Food Safety Authorities in Ireland have never raised any concerns nor informed parents of the potential health risks associated with using fluoridated water to feed infants, a practice that is now universally regarded as  unsafe.  Consequently some 75%  of infants, representing 50,000 babies in 2012 alone, are exposed to excessive levels of fluoride daily, at a time when their kidneys are not fully functioning. Recent scientific studies have warned that it could take twenty years or more for the toxicological effects of this to become evident in humans. The WHO may be aware  that the Department of Biomedical science, College of Veterinary Medicine in Cornell University an ivy leaggue top five world university found that horses fed fluoridated water from community water schemes at fluoride levels ranging from 0.3-1.3mg/L developed chronic fluoride poisoning that resulted in crippling skeletal fluorosis and other diseases. It is interesting to note that the most prevelant medical condition for people living in Ireland over fifty years of age has been found to be muscloskeletal chronic pain.

After over forty years of water fluoridation it is therefore deeply disturbing to discover that no comprehensive human health risk assessment has ever been undertaken to examine the toxicological or human health impacts of fluoridation of drinking water on children or amongst the wider population. It is equally disturbing that both the NHS, the European Commission and the U.S. National  Research Council have all noted that the silicofluoride chemical used for water fluoridation has never been tested for human toxicology.

In total more than fifty-nine epidemiology, toxicology, clinical medicine and environmental exposure assessments have been identified as necessary to be undertaken in order to fill data gaps in the hazard profile, the health effects and the exposure assessment of silicofluoride compounds. Not one of these studies has yet been undertaken by the responsible Regulatory Authorities in Ireland or anywhere else. The attitude appears to be, better to leave alone rather then to further incriminate those that may be held responsible and open the risk of litigation. The potential risks posed for society of using an untested chemical compound to artificially fluoridate water supplies are enormous and may yet reflect the enormous level of ill health which is present within the Irish population as a whole compared to non-fluoridated communities.

In the context of existing EU and national regulatory legislation concerning the environment, health and food, it has been found that the policy of water fluoridation contravenes thirteen EU Directives, three EU Food Regulations, four Statutory Regulatory Instruments, one EU Medical Directive, one EU Product Directive, seven international Treaties, three European Conventions and six European Action Policies, totalling thirty-eight separate acts of legislation or common policy.

It is now certain that in countries where fluoridated toothpaste is widely available that the majority of individuals do not benefit or require fluoride in their drinking water. It is evident that the majority of individuals already have adequate if not excessive fluoride dietary levels in the absence of fluoridated water. Fluoridated drinking water acts as a tipping point for many individuals that can and does result in them having harmful and permanent health effects.

In addressing the concerns expressed in my report one would hope that Health Authorities would eer on the side of caution and follow a precautionary approach rather than wait to have the risks confirmed which is the approach that the Health Authority in Ireland is pursuing. Given the scientific uncertainties presented by international scientific committees regarding the health risks from fluoridation of water, in particular the acknowledged inadequate toxicological  risk assessments, I request that the WHO recommend in the interest of public safety that artifical fluoridation of drinking water using silicofluoride based chemicals cease until all the necessary epidemiology, toxicology, clinical medicine and environmental exposure assessments have been completed. It is extremely alarming that despite the repeated concerns raised by international  scientific bodies there is still no information available 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 silicafluoride compounds on human beings.

In 2007 the (BMJ) Review of Fluoridation found that “if fluoride is a medicine, evidence on its effects should be subject to the standards of proof expected of drugs, including evidence from randomized trials” the BMJ also found that “there have been no randomized trials of water fluoridation.”

Surely the only appropriate course of action to take must be to await the findings of comprehensive scientific toxicological and ecological risk assessments, as recommended by the U.S. National Research Council (NRC) and other scientific bodies including the EU Commission, the NHS and British Medical Journal. Furthermore that the completion of accurate health surveillance epidemiological studies examining the total dietary fluoride intake of the population, as recommended by the WHO, must be undertaken before any national health authority or Government may endorse the systematic fluoridation of public water supplies.

While already highlighting the lack of toxicological data for silicofluoride chemicals it is necessary to also highlight the co-toxicity risks posed from fluoride with other toxins such as lead or aluminium both of which are present in drinking water and foodstuffs. For example, it is now known that fluoride binds with alumimium to form aluminium fluoride, a compound that is ten times more soluble in the human body that aluminium on its own. This may have major implications for the increased prevalance of neurological disorders now present in society generally. The dramatic rise in dementia is a health concern that the WHO have recently raised warning of a global crisis for health authorities in addressing this disease in the future. The precautionary approach must be to limit any potential environmental toxin that may contribute to neurological disease, clearly therefore fluoridation of drinking water must be discontinued in the interests of public safety.

It is now absolutely certain that the ingestion of excessive amounts of fluoride has become a serious public health problem, particularly in fluoridated communities such as in Ireland. This is largely due to the exposure of infants to fluoride from contaminated formula feed constituted with fluoridated tap water.  It is now known that up to 400,000 youths under the age of 18 years have dental fluorisis with 1% exhibiting severe dental fluorosis requiring extensive dental surgery. In Ireland this amounts to 40,000 children. In any context this is completely unacceptable. Within the wider community the degree of dietary exposure to fluoride by individuals clearly explains the prevalence of diagnosed chronic musculoskeletal pain and osteoporosis within the population as a whole.

For example Ireland per capita is the largest consumer of tea in the world. In analytical testing of beverage samples which I recently commissioned an accreditated analytical laboratory to undertake the concentration of fluoride was found to be in excess of 25 mg/l in one of the most popular tea beverages sold in Ireland. That represents in excess of 30 times the current maximum recommended level of fluoride in drinking water. This level of fluoride from one source alone represents dangerously high exposure levels for the population far in excess of the 14 mg/day and 6 mg/day levels noted by the WHO that would cause adverse skeletal effects.

For many individuals in Ireland the major portion of fluid intake is not by consumption of drinking water but by consumption of tea followed by beer, wine or other beverages. It is not uncommon for many individuals to consume up to six to eight cups of tea per day all made up from boiled fluoridated tap water. Add to this an extraordinarly high dietary intake of fluoride, the additional dietary exposure from foodstuffs processed in fluoridated water (which contain more fluoride than foodstuffs processed or cooked in non-fluoridated water) and further significant exposure from residues of fluoride pesticide, herbicides and fumigants in foodstuffs and the total exposure level is truly alarming.  For many individuals their dietary fluid intake of fluoride could easily be in excess of 50 mg per day, multiples of the WHO guidelines to prevent chronic fluoride poisoning. In every respect such levels of dietary exposure to fluoride represent a clear public health risk for the development of crippling musculoskeletal fluorosis, with chronic joint pain and arthritic symptoms – with or without osteoporosis.  It is important to note that, for persons with kidney disease such as diabetics, the health risks are much greater because the majority of fluoride will not be eliminated from the body due to malfunctioning kidneys.

Even in the United States of America, where the policy originated, the problems of chronic overexposure of the population in particular of infants has become so endemic that it is now the policy since 2006 of the American Dental Association, the American Academy of Pediatric Dentistry, and the American Academy of Pediatrics that fluoride should not be given to infants under 6 months, in any circumstance, and that the limit for children up to 3 years of age should be <0.25 mg/day for children from 6 months to 3 years of age. Dr. Howard Koh, Assistant Secretary for Health, U.S. Department of Health and Human Services (HHS) recently confirmed that in fluoridated communities all infant formulas are contaminated with fluoride from fluoridated water at levels that present a toxic threat to babies and infants.

It is now evident due to the systemic fluoridation of drinking water supplies in Ireland combined with the widespread contamination of the human foodchain with fluorides that there is clearly now no safe limit for fluoride in drinking water and the artficial fluoridation of drinking water must cease immediately. To protect public health and the environment every effort must be made by regulatory authorities to immediately reduce the level of exposure to this toxic in both drinking water and foodstuffs.  This can only be effectively achieved by ending the policy of fluoridation of drinking water supplies. It is also evident based on current exposure levels, that the WHO and the European Commission must act urgently to limit the exposure of citizens to fluoride in food (drinking water is classified as a food in EU Law). Furthermore the WHO and EU Commission must recommend that the implementation and continuation of  systemic fluoridation of public water supplies cannot continue without the Health Authorities undertaking public health screening of the population to establish accurate dietary exposure levels as already recommendd by the WHO.

To support this I would ask the EU Commossion require immediately National Health Authorities to establish a database for fluoride in beverages and foods consumed within their country. Such action must be undertaken urgently as a preventative health policy for protection of human health in order that consumers and medical practitioners may be more knowledgeable on dietary fluoride exposure.

In ending, I request that the EU Commossion issue new policy advice or safety guidelines for the fluoridation of drinking water supplies that will address the concerns expressed in this letter and additional concerns including environmental toxicity as documented in my report. I look forward to your considered reply to this letter and my report.

In closing I will end with the following statement from the World’s leading expert in Public health and developmental neurotoxicity Dr Philippe Grandjean Adjunct Professor of Environmental Health - Department of Environmental Health - Harvard School of Public Health who confirmed to me in writing that the exposure of children to fluoride in early life exposes them to a neurotoxin with unforeseen consequences.

The Health Authority in Ireland have been and remain entirely negligent in not accepting the international scientific findings that  high risk individuals such as bottle fed infants should not be exposed to fluoridated water, Ireland has the highest prevlance of bottle fed infants in the world and the highest incidence of neurological disease.

Yours sincerely

Declan Waugh

Thursday, May 3, 2012

Water Fluoridation and the UN Convention on the Rights of the Child

The UN Convention on the Rights of the Child and Water Fluoridation

Ireland ratified the UN Convention on the Rights of the Child in 1992. The Convention is essentially a ‘bill of rights’ for all children, outlining rights relating to every aspect of children’s lives such as the right to survival, development, protection and participation. The principles of the Convention include:
• Non-discrimination – All rights apply to all children.
• The best interests of the child – All actions concerning the child shall take account of his or her best interests.
• Survival and development – Every child has the inherent right to life, and the state has an obligation to ensure the child’s development.
• The child’s opinion – The child has the right to express his opinion and have it taken account of in any matter or procedure affecting him or her.

In addition, the Convention recognises the critical role of the family in the life of the child.

The mandatory systemic fluoridation of drinking water supplies violates each of these stated principles as outlined in the UN Convention on the Rights of the Child. It is now scientifically  accepted that infants are the most at risk from the toxic effects of fluoride. Water Fluoridation discriminates against subsectors of the population in particular young children. Water fluoridation is not in the best interest of every child and the state has a righ not to inhibit their neurological development by introducing a known neurotoxin into their food supply. Water Fluoridation does not recognise the role of the family in the protection of the child and the right of parents to safeguard their children from exposure to known toxins.

Pretty clear cut case if you ask me. Pity I didnt see it before now.

The Role of EPA in Provision of Safe Drinking Water

The Role of EPA in Provision of Safe Drinking water and Environmental Protection
Mr. Dara Lynott
Director-Office of Environmental Enforcement, Environmental Protection Agency

CC:      Department of Taoiseach
Minister for Health
            Minister For Agriculture, Food and Fisheries
            Minister for Environment, Community and Local Government

26th March 2012

Response to my Report on Human Toxicity, Environmental impact and Legal Implications of Water Fluoridation.
Dear Sir,
I wish to acknowledge your reply to my letter and submission of my report to the Environmental Protection Agency.
As you have noted the Environmental Protection Agency (EPA) are the supervisory authority over water services in respect of the quality of drinking water and the role of the EPA is to ensure that the Irish fluoride drinking water standard of 0.8mg/l is adhered to and where it is breached that appropriate corrective action is taken.
As I have outlined in my report, the legislation relating to water fluoridation predates Ireland joining the European community. As you may be aware there is no EU legislation or policy that supports the fluoridation of drinking water supplies. As I have noted in my report, Ireland is the only country in Europe that accepts and pursues this policy. That is, the Government of Ireland accepts this position, not the citizens of Ireland, as they were never consulted on this policy.
It is evident the environmental impact of such a policy has not been adequately considered in examining the environmental impacts of fluoride emissions on the environment.  It is apparent that the intended public health benefits of fluoridation, which have been found to be negligible by the EU Commission, continue for some reason to be regarded as sacrosanct by Irish Authorities. Yet the direct and indirect environmental consequences of this policy human health on the environment remain uninvestigated. It is clearly evident that the impact of water fluoridation is unsustainable and not without consequence. In any matters addressing this subject local authorities and the Department of Environment pass the responsibility onto the Department of Health as the Department with responsibility for Fluoridation Regulations, yet the Department of Health are not the regulatory authority with responsibility to safeguard the environment or prevent pollution.

My report details the various legal and environmental policy violations that exist regarding water fluoridation. From your response to me and noted above, it appears that you infer that the only responsibility the EPA have, in this respect, is to ensure that the drinking water standard is enforced.  I believe that I am correct in stating, that primarily the Agency is the competent authority for the protection of the environment - as noted in the Protection of the Environment Act, 2003.  As you are aware, this includes the prevention, limitation, elimination, medium and abatement or reduction of environmental pollution and the preservation of the quality of the environment as a whole. The Agency are responsible for the management of environmental pollution, including any anthropogenic discharges of fluoride compounds from wastewater treatment plants or from sewage sludge disposal as well as the protection of consumers from contamination of drinking water with any substances that may be harmful to human health or the environment. 

For example, the EPA is concerned with the long-term exposure of the population to the health effects of trihalomethanes and monitors drinking water for these compounds. Similarly the Agency has issued guidance and enforcement proceeding on local authorities with respect to lead contamination in drinking water.  I would assume that the Agency is likewise concerned about the long-term exposure of the population to silicafluoride compounds used in drinking water, as well as their co-toxicity with other compounds such as aluminum and lead. It is important that the agency are aware, as noted in my report, that the health hazards associated with the enhanced incorporation of lead and aluminum are increased by the addition of silicafluorides to our drinking water supplies.

Within Europe the Agency are advised legal precedence exists establishing clearly that fluoridated water is defined as a medicinal product. The State is required under EU law-  European Council Directive on Medicinal Products for Human Use (2004/27/EC) to undertake detailed risk assessment and performance of tests and clinical trials including toxicological and pharmacological tests to demonstrate the effectiveness and risks associated with water fluoridation for the protection of public health. Despite this, the Government of Ireland or its agencies have never undertaken risk assessments on the fluoridation products in use in Ireland.

This would constitute a flagrant and serious violation of Directive 2001/83/EC.

In respect of EU Food law the Agency are advised that fluoridated drinking water is not safe for consumption for infants, as it results in contamination of baby infant formula milk with fluoride levels far in excess of recommended safety standards.

While my report addresses these concerns and much more in detail, I look forward to any recommendations the Agency may make to address these issues.

In relation to chemical compounds used for drinking water, as the supervisory authority over water services, I wish for clarification from the agency on the following. 

In quantifying the potential public health risk from fluoridation of drinking water, the Agency may be aware that in excess of fifty comprehensive epidemiological, toxicological, clinical medicine, and environmental exposure assessments were identified requiring further testing 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. The completion of these studies are also a requirement of EU law, as noted previously.
In response to parliamentary questions the Minister for Primary Health Care Deputy Shortall T.D. has confirmed the findings of my report, 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 silicafluoride compounds on human beings. This is despite the numerous recommendations from scientific bodies that efforts be made to determine the toxicity of fluoride and silicafluoride products. 

As the supervisory agency over water services, can the EPA advise that they have such information on file ?

Furthermore, the Department of Health have confirmed 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.

As the supervisory agency over water services, can the EPA advise that they have such information on file ?

In addition, the Department of Health have confirmed that no studies have been undertaken examining the interactive co-toxicity public health risks associated with silicafluoride compounds when mixed with other water treatment chemicals such as aluminium compounds.

As the supervisory agency over water services, can the EPA advise that they have such information on file?

If the Agency does not have this information, then it is clear that the State is continuing to use untested chemical compounds without undertaking the necessary precautions to protect public health, consumers or the environment.

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 and the environment.

It is simply unacceptable that the State or the EPA would continue to allow untested chemicals to be added to public drinking water supplies.

Finally can the Agency advise as the regulatory authority with responsibility for environmental protection, how the Agency may support, in violation of EU law, any policy that results in the indirect release of significant quantities of fluoride (a persistent toxic bio-accumulative environmental pollutant) into soils, groundwater and surface waters, with little or no controls at concentrations that have been found to be harmful to ecosystems, protected fisheries as well as a potential risk to human health (as identified by the U.S.A EPA)?

I look forward to your reply

Yours sincerely

Declan Waugh