Dr. Tony Holohan,
Chief Medical Officer
Cc: Mr. Enda Kenny T.D.
Department of Taoiseach
Dr. James Reilly T.D. Minister for Health
Mr. Phil Hogan T.D. Minister of Environment
Mr. Simon Coveney T.D. Minister Agriculture Food and Marine
Mr. Cathal Magee, CEO Health Service Executive
Professor Kieran Murphy, President Irish Medical Council
Ms Francis Fitzgerald T.D. Minister for Children
Ms Laura Burke, Director General, Environmental Protection Agency
Dr. Philip Michael, Chairperson, Irish Doctors Environmental Association
Ms. Emily O Reilly, Ombudsman for Children
Re: Fluoridation of
Public Drinking Water Supplies and Report on Human Toxicity, Environmental
impact and Legal Implications on Water Fluoridation
12th April 2012
Dear Dr. Holohan
I wish to thank you for
your letter of March 27th regarding my report on the Human
Toxicity, Environmental impact and Legal Implications of Water Fluoridation. There are a number of
critically important issues that need to be addressed in regard to information
provided in your letter. I
apologize for the length of this reply but given the seriousness of the subject
and the misconceptions regarding water fluoridation
that have unfortunately entered the mainstream in Ireland, it is necessary to
address some of these points in detail within this correspondence. I would, however, ask that
you please find the time to examine my report where the medical and scientific
findings are discussed in detail and scientific references are provided.
It is perhaps
most appropriate to begin by examining the incorrect belief that the assessment
of water fluoridation demonstrates that it is safe and effective for all age
groups and does not cause any ill effects. For your information Dr. Howard Koh, Assistant
Secretary for Health, U.S. Department of Health and Human Services (HHS) confirmed in 2011 that in
fluoridated communities in the U.S. all infant formulas are contaminated with
fluoride from fluoridated water and that fluoride in infant formula presents a
toxic threat to babies who are exclusively bottle-fed with formula milk
constituted from fluoridated water.
The exact same risk applies in Ireland, however,
the risk factor is much greater in this country due to the extraordinarily high
prevalence of non-breastfed babies in Ireland.
At the most
basic level of medical diagnosis an assessment of fluoride intake is paramount
in understanding the mechanisms of fluoride metabolism, specifically the
prevention of dental caries, dental fluorosis, and skeletal fluorosis. The 1971 World Health
Organization International
Standards for Drinking-water explicitly state 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. Apart from variations in climatic conditions, it is well known that
in certain areas, fluoride-containing foods form an important part of the diet.
The facts should be borne in mind in deciding the concentration of fluoride
to be permitted in drinking water."
As with any
medical or nutritional examination the daily fluoride intake of an individual
can only be accurately carried out based on an individual’s age, weight, fluid
intake, dietary preferences, level of exercise and nutritional needs and
through the availability of up to date fluoride concentrations in beverages and
foodstuffs. Fluoride levels in foodstuffs will vary from country to country and
according to the source of supply of food products. In order to establish
accurate dietary fluoride exposure levels, there is a requirement for national
databases to be established to monitor products sold and consumed within
individual countries.
No such database
for fluoride exists in Ireland. To suggest in the absence of this information
that the artificial fluoridation of water is safe and effective is beyond
comprehension.
DIETARY EXPOSURE TO FLUORIDES
It is now
absolutely clear from a vast amount of published scientific information,
supported by my own research data, that the ingestion of excessive amounts of
fluoride has become a serious public health problem, particularly in
fluoridated communities. This is largely a consequence of dietary intake from
fluoridated water as well as processed food, cooked food and beverages which
are made up from fluoridated water in addition to other anthropogenic sources
of fluoride in foodstuffs from residues of fluoridated pesticides, herbicides,
fumigants and fluoride-based fertilizers and other major sources of fluoride
from dental hygiene products such as toothpaste or mouthwashes to
fluoride-based pharmaceutical medication.
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With regard to dietary exposure to fluoride and
public health risks, it is generally accepted that the amount needed to cause
crippling fluorosis in a 45- to 100-kg person is 10 to 20 mg per day for 10 to
20 years. Since it is accepted that fluorides accumulate in a linear fashion,
the crippling dosage of 10 mg per day for 10 years is the same as 5 mg per day
for 20 years, and so on.
The Institute of Medicine has determined that an
adequate intake (AI) of fluids for men is roughly 3 litres (about 13 cups) of
total beverages a day. The AI for women is 2.2 litres (about 9 cups) of total
beverages a day. If we extrapolate this to a person consuming fluoridated water
as the only form of fluids this would equate to 2.4mg ingested per day from
water at current optimal levels. This does not take into account other dietary
exposure from toothpaste, processed foods or beverages such as tea or wine
which are known to contain high levels of fluoride. The average individual in
Ireland consumes four cups of tea a day.
Normal tea sold in Ireland constituted with fluoridated water may
contain up to 26.5mg/l fluoride.[1] If an adolescent or
adults were to consume 4 cups of tea a day combined with 1.5 litres of drinking
water (equal to the recommended daily fluid intake) the total liquid dietary
intake would be in the region of 28mg day.
In reality, however, for many individuals in
Ireland the major portion of fluid intake is from consumption of tea not drinking
water. It is not uncommon for many individuals to consume up to eight cups of
tea a day. Add to this the dietary intake from foodstuffs processed in
fluoridated water (which will contain additional fluorides than foodstuffs
processed in non-fluoridated water), the residues of fluoride based pesticides,
herbicides and fumigants that are present in foodstuffs and the total exposure
level further increases. For many
individuals therefore their dietary fluid intake of fluoride could be far in
excess of 50mg per day.
This would equate for an average-sized woman to a
risk level of 1.36mg/Fluoride/per kg/day which is 27 times the recommended
daily standard as calculated by the U.S. Agency for Toxic Substance and Disease
Registry.
One must add that this figure does not include
other dietary sources of fluoride which depending on diet may be considerable.
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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. In every respect these 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.
The amount of fluoride individuals are exposed to
in Ireland today may explain the prevalence of diagnosed chronic
musculoskeletal pain within the population of Ireland.
Clearly, one must agree that it is evident that
there is therefore no safe limit for fluoride in drinking water and that every
effort must be made by regulatory authorities to immediately reduce the level
of exposure to this toxic both in drinking water and foodstuffs. The
Government of Ireland should act on this as a national health emergency.
FOOD SAFETY STANDARDS
As Chief Medical Officer, I would naturally expect that you would also
accept the findings of the European Food Safety Authority[2]
who found that “excessive intake of fluoride during enamel maturation before
tooth eruption from birth to eight years of age, when enamel formation is
complete, can lead to reduced mineral content of enamel and to dental fluorosis
of deciduous but predominantly of permanent teeth.”
You may not be aware that for bottle fed infants the EU Scientific
Committee recommended a maximum fluoride level below the current standard
applied for water fluoridation in Ireland. In Ireland this standard is clearly exceeded for
bottle fed-babies and as such contributes to increased prevalence of dental
fluorosis as well as the risk of fracture and skeletal fluorosis in later life.
This is clearly contrary to any observation or statement that the “policy of
fluoridation of public water supplies (which) continues to make an effective
contribution to oral health in Ireland”.
As you will know from reading the
SCHER assessment, their scientific committee documented that infants solely fed
with a baby formula diluted with water containing 0.8 mg F/L ingest, at a
minimum, 0.137 mg F/kg/day compared with 0.001
mg F/kg/day for an infant, who is solely breastfed.
As you may already know an infant who is bottle-fed formula milk made from
fluoridated water consumes at a minimum 137 times the total fluoride intake of
that of a breastfed baby. The U.S. National Research Council (NRC) of the
National Academies has found that when body weight
is taken into account, non-nursing infants receiving formula made with water
fluoridated who are less than one year old are exposed to a fluoride intake
which is about three times that of adults.
As Chief Medical Officer, I am
certain that you will concur that this level of exposure is extraordinarily
high and poses immediate and far-reaching consequences for the nation‘s health.
Unexplainably, however, public health authorities in Ireland have failed to
warn healthcare practitioners and parents of any risk associated with water
fluoridation and contamination of infant formula feed. As outlined in Chapter 8 of my report
the level of fluoride in formula milk reconstituted with fluoridated water
could be deemed critical regarding the potential for developing dental and
skeletal fluorosis that may result from high concentrations of dietary fluoride
for infants in later life.
While it is most welcome that you
have acknowledged in your letter that you accept the findings of the SCHER
review, you may be unaware that another EU Scientific Committee found that a
daily intake as low as 0.020 mg F-/kg body weight may result in mild forms of fluorosis in the permanent dentition.[3],[4],[5],[6]
As with the SCHER review the SCCNFP review provided recommendations and
observations regarding exposure to fluoride. As Chief Medical Officer I would
expect that you would acknowledge and accept their findings in regard to
fluoride with particular reference to exposure risks of children this toxin. I
would also like to highlight that as far back as 2006 the U.S. Centres for
Disease Control and Prevention (CDC) and the American
Dental Association (ADA) advised that using fluoridated
water to mix formula could cause infants to develop fluorosis. The ADA report stated that “infants
could receive a greater than optimal amount of fluoride through liquid
concentrate or powdered baby formula that has been mixed with water containing
fluoride during a time that their developing teeth may be susceptible to enamel
fluorosis." The ADA warned that, in order
to prevent tooth damage, fluoridated water should not be mixed into formula or
foods intended for babies aged one and younger. You may be aware that no such
warning has ever been issued in Ireland.
As Chief Medical Officer, you may
already be aware that the chronic maximum recommended limit (MRL) for fluoride
as established by the U.S. Department of Health and Human Services Public Health
Service Agency for Toxic Substances and Disease
Registry (ASTDR) is 0.06mg/kg/day, which is based
on chronic human data examining the most sensitive known endpoint of fluoride
toxicity. In regard to renal effects, an MRL value of 0.06 mg/kg/day was adopted
as the Target Organ Toxicity Dose (TTD)RENAL for fluoride. In regard
to reproductive effects, an MRL value of 0.06 mg/kg/day was adopted as the TTDREPRO for fluoride.
In regard to neurological effects, an MRL value of 0.06 mg/kg/day was adopted
as the TTDNEURO for fluoride. It is
clearly evident that in Ireland all infants bottle-fed formula feed
constituted with using fluoridated water exceed the chronic MRL noted above by
multiples of the recommended levels. It is clearly
therefore a matter of scientific fact, that the current levels of exposure of
infants to fluoride in Ireland presents an immediate health risk, not just for
dental fluorosis, but for much wider health risks over the lifetime of
individuals.
In regard to infants, I can only presume that you
are unaware that the European Food Safety Authority (EFSA) recommended
optimal fluoride intake level for infants above 6months of age is 0.05mg/kg
body weight/day. This is even more stringent than the level recommended by the ATSDR. One can conclude that the scientific facts and evidence are
abundantly clear, that fluoridation of water supplies is not ‘safe’ for every
age group or sector of society and that all previous assumptions regarding
water fluoridation, as presented by the Forum for Fluoridation or the Irish
Expert Body on Fluorides and Health, are ill-founded and not based on current
scientific knowledge. It is for that purpose I forwarded my report to your
offices for your personal review. In light of the recommendations by
international scientific bodies, it is somewhat incredible that it is now
acknowledged that the long-term medical consequences (separate from dental
fluorosis, which is now endemic in Irish society) of fluoride exposure in
children have never been studied in Ireland. Similarly, despite the obvious and
clear dangers to public health and the dramatic rise in documented dental
fluorosis amongst the public, it is astonishing that to date no bio-monitoring
study has been undertaken.
MONEY BETTER SPENT
It is obvious that the overall finances needed to
cover the operational budget and management of water fluoridation could be
better directed to support preventative healthcare or emergency services and to
achieving greater success in behavioural change within society on dental
hygiene that would be far more effective, safer, sustainable and beneficial in
the long-term. The annual budget for secretarial services for the Forum for
Fluoridation (€400,000) combined with the cost of silicofluoride chemicals
(€4,700,000), supervision, training and auditing costs (estimated at
€10,000,000), combined with equipment maintenance, overheads, insurance and
pollution prevention costs (€30 million for 235 water treatment plants with
water fluoridation infrastructure) could be most obviously redirected to
providing more public health dentists for those in most need of dental
treatment especially in socially-deprived areas and, in particular, to
supporting breastfeeding initiatives for mothers and babies within these
communities, which would go a long way to reducing the prevalence of dental
fluorosis amongst children. For example in 2008, it was estimated by the UK
Department of Health (DOH) that the cost of implementation of fluoridation of
water for the greater Manchester area alone would be up to £100million. Ultimately the DOH in
England did not pursue this policy as it was not deemed to be cost effective.
The financial
costs associated with fluoridation of water do not take into account the cost
for treatment of dental fluorosis amongst the wider population as a direct
consequence of dietary overexposure to fluoride. It is a fact that up to 40% of
children under 18 years of ages suffer form dental fluorosis in Ireland with 1%
in the category of severe dental fluorosis and 1% in the moderate category.
That means that up to 40,000 children or youths are known to have severe dental
fluorosis requiring extensive dental surgery. It is particularly interesting to
note therefore the statement of Professor Hardy Limeback, the Head of the
Department of Preventative Dentistry, University of Toronto and President of
the Canadian Association for Dental Research, when he stated that “ in Canada we are now spending more money treating dental
fluorosis (the damage caused by fluoride) than we do treating cavities.” What is now
becoming apparent is that this "cosmetic" defect actually predisposes
to tooth decay. There are numerous peer-reviewed published international
studies to support this. Consequently there is no question therefore but that the
prevalence of overexposure to fluoride in Ireland is of major public health
significance and must be addressed immediately.
It is uncertain
if any study has been undertaken in Ireland to examine the cost benefit of
water fluoridation and to determine the costs to consumers for attempting to
repair the damage caused by dental fluorides resulting from such a policy.
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REVIEW OF RISKS
For over 50 years, Department of Health officials
have confidently and enthusiastically claimed that fluoridation is "safe
and effective" despite the lack of scientific data to support such claims.
Even worse, the relentless promotion of fluoride as a
"dental benefit" is responsible for the huge neglect in proper
assessment of its toxicity, an issue that has become a major concern for many
nations. As there is no substance as biochemically active in the human organism
as fluoride, excessive total intake of fluoride compounds might well be
contributing to many diseases currently afflicting mankind, particularly those
most prevalent in Ireland today as highlighted in my report.
In Ireland,
citizens are kept entirely ignorant of any adverse effect that might occur from
exposure to fluorides. Ireland wishes to present itself as a science- based economy yet for
some reason refuses to accept scientific facts associated with this unnecessary
practice. Dental fluorosis, the first visible sign that
fluoride poisoning has occurred, is still declared a mere "cosmetic effect"
by the Irish Expert Body on Fluorides. This interpretation is no longer
supported by other international scientific committees, either in the U.S.A. or
Europe.
Scientific findings by the NHS, the U.S. National
Research Council, the Irish Expert Body on Fluorides and European Commission
have all found that there still remains a lack of credible scientific data to
clearly demonstrate that fluoridation is safe, while conclusively finding that
systemic fluoridation results in overexposure to fluoride amongst the
population and that the topical application of fluoride onto the tooth via
toothpaste (not systemic-via drinking water) is the most effective manner to
reduce dental caries. These are undisputed scientific facts. As I have outlined
in my report, within Europe water fluoridation is a peculiarly Irish
phenomenon. It started at a time when Asbestos lined our pipes, Lead was added
to gasoline and paint, Polychlorinated biphenyls (PCBs) filled our
transformers, Dichlorodiphenyltrichloroethane (DDT) was deemed "safe and
effective", Chlorofluorocarbons (CFCs) were believed to be the wonder chemicals of the 20th
century and many fluoride-based pesticides or fumigants such as Sulfuryl Fluoride
were all considered safe and effective but are now effectively banned. In
February 2012 the U.S.A. EPA proposed to ban Sulfuryl Fluoride because of
fluoride contamination of foods and beverages from this chemical and its direct
health implications for consumers.
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The International Society of Doctors for the
Environment and the Irish Doctors Environmental Association are both strongly
opposed to water fluoridation. You may be unaware that thousands of scientists,
dentists, doctors, academics and other professionals worldwide have signed a
petition to end what they regard as an unnecessary and dangerous practice.
No other European nation, including their health
or environmental authorities, supports the mandatory fluoridation of drinking
water supplies. Yet fluoridation of drinking water supplies not only remains
enforced in Ireland but the health authority and local government continue to
misrepresent both the dangers and degree of international support associated
with such a controversial policy.
At a most basic level it is unconscionable how the
Department of Health could continue to support such a policy when there is a
complete lack of accurate data or scientific evidence to support its continued
use, as has been demonstrated in the findings of the NHS York Review, the National
Research Council of the United States of America Review and the various and
numerous scientific committees of European member states, in addition to the
most recent findings of the European Commission and its agencies.
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The 1971 WHO Drinking Water Standards noted 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." It
is truly disturbing therefore that the HSE have now acknowledged that they have
never undertaken such a study in the 45 years since commencement of this
policy. Such a basic oversight is completely unacceptable by any modern
standards of healthcare.
As I discussed in my report, a legal court in
Europe has already found that water fluoridation is defined as medication. I would hope and believe that no competent
physician would prescribe for a person he has never met, whose medical history
he does 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 regardless of that individual’s health
status or possible sensitivity to fluoride compounds and regardless of other
medications they may be taking or their total daily fluoride intake exposure from
other sources, and that they continue to self administer for the rest of their
lives, because some children suffer from tooth decay. Every right-minded
individual would accept that this is a preposterous notion. Yet this is exactly
what the support for this policy entails. I would earnestly hope that the
standards and guidelines of medical training, education and ethics in Ireland
would ensure that this will stop to protect the personal welfare of individuals
and their right to limit their bodily exposure to this toxin which cannot be
achieved by mandatory artificial fluoridation of public drinking water supplies
without offering alternative non-fluoridated public water to each household in
Ireland.
Consumers and parents have a legal right to
informed choice and bodily integrity; such a right is currently denied in
Ireland.
One would hope and believe that given the enormous
potential implications for public health of using untested chemicals for the
systemic medication of a population that the Health Authorities would err on
the side of caution and follow a precautionary approach rather than wait to have
the risks confirmed which is the approach the HSE is currently following.
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One must believe that the precautionary approach
is the most appropriate course of action to follow, until comprehensive
scientific toxicological and ecological risk assessments are completed, as
recommended by the U.S. National Research Council (NRC) and other scientific
bodies (details provided in my report) and accurate health surveillance
epidemiological studies examining the total dietary fluoride intake of the
population are undertaken as recommended by the WHO. Without this information
one cannot determine with any accuracy an individual’s exposure to fluorides.
No toxicological assessment would be complete without examining the co-toxicity
of fluorides with other known contaminants such as aluminium and lead.
Undisputed
documentary evidence exists regarding health concerns associated with
artificial fluoridation of drinking water. I would draw to your attention the findings of the U.S.
National Research Council (NRC) Scientific Committee and their comprehensive
report on fluoridation published in 2006, which highlighted an alarming number
of potentially adverse public health risks associated with water fluoridation.
A summary of just some of their findings are presented below. I would ask that
you review their report in full.
SUMMARY OF
NATIONAL RESEARCH COUNCIL FINDINGS
Furthermore, the
NRC documented the growing weight of toxicological and epidemiological evidence
identifying clear public health risk associated with the addition of fluoride
to public drinking water supplies. Some of the findings and observations of the
Research Council included:
- The NRC reported that the nature of uncertainties in the existing data could also be viewed as supporting a ‘greater precaution‘ regarding the potential risk to humans of water fluoridation.
- The NRC found that “it is apparent that fluorides have the ability to interfere with the functions of the brain and the body by direct and indirect means”.
- The NRC of the United States of America reported an association of uterine cancer (combination of cervical and corpus uteri) with fluoridation.
- The NRC reported a similar association with oral-pharyngeal cancers among females.
- The NRC warned that from an immunologic standpoint, individuals who are immuno-compromised (e.g. AIDS, transplant and bone marrow- replacement patients) could be at greater risk of the immunologic effects of fluoride.
- The NRC reported how cancer registries indicated a consistent trend of kidney cancer incidence with duration of fluoridation.
- The NRC reported that fluoridated water is known to elicit acute gastrointestional systems affecting the liver, kidney & immune system.
- The NRC reported how scientific studies[7] have demonstrated that at least 1% of the population complains of GI symptoms after fluoridation is initiated.
- The NRC reported that fluoride exposure appears to bring about increases in blood glucose or impaired glucose tolerance in some individuals and to increase the severity of some types of diabetes.
- The NRC highlighted the increased health risk to diabetic individuals who will often have higher than normal water intake, and consequently, will have higher than normal fluoride intake for a given concentration of fluoride in drinking water.
- The U.S. National Toxicology Program (NTP) found that there is a "biological plausibility" of a link between fluoride exposure and osteosarcoma. They reported that this biological plausibility centers around three facts: 1) bone is the principal site of fluoride accumulation, particularly during the growth spurts of childhood; 2) fluoride is a mutagen when present at sufficient concentrations, and 3) fluoride can artificially stimulate the proliferation of bone cells (osteoblasts).
REVIEW OF INTERNATIONAL GUIDELINES AND
SCIENTIFIC OBSERVATIONS
The U.S.
National Cancer Institute Toxicology Program determined, based on limited
available studies, that fluoride is an equivocal carcinogen.[8] This risk association was based
on the chemical sodium fluoride. No toxicological studies have ever been
undertaken on silicofluoride chemicals that are used in artificially
fluoridating drinking water.
While this has
been repeatedly raised as a concern no action has been taken to rectify the
lack of data by Authorities in Ireland
In addition and without exception the following
distinguished scientific bodies have all clearly identified that infants and
in particular babies under 12 months of age are the most at risk from the potential health
impacts of fluoride in drinking water. The learned scientific bodies include:
- The European Food Safety Authority,
- The US National Cancer Institute of Toxicology,
- The European Commission’s Scientific Committee on Cosmetic Products
and non-Food Products intended for Consumers,
- The U.S. Public Health Service,
- The Canadian Association of Dental Research,
- The American Dental Association,
- The Scientific Committee of the National Research Council of the
National Academy of the United States of America,
- The U.S. Department of Health and Human Services Public Health
Service Agency for Toxic Substances and Disease,
- The U.S. Centre for Disease Control and Prevention,
- The European Commission’s Scientific Committee on Health and
Environmental Risks,
- The United Kingdom Expert body on Vitamins and Minerals and
- The British Medical Research Council
While clearly identifying the most sensitive risk
group to fluorides, these scientific bodies also established in accordance with
internationally accepted scientific standards, tolerable upper limits of human
exposure to the toxin fluoride in food.
It is now clearly documented and an accepted fact
that all bottle-fed infants in Ireland under the age of 12 months who are fed formula milk
made up with fluoridated water at the current optimal levels exceed the
maximum upper safety limits for toxic exposure to fluoride, by multiples of
these recommended standards. These are all undisputed
scientific facts. For your
information, a similar finding was observed for fluoridated communities in the
U.S.A by Dr. Howard Koh, Assistant Secretary for Health, U.S. Department of
Health and Human Services (HHS) who recently confirmed that in fluoridated communities in the U.S. all
infant formulas are contaminated with fluoride from fluoridated water and
present a toxic threat to babies and infants.[9]
It is obviously not the case, as presented by
certain officials representing the HSE, that water fluoridation continues to be
safe and effective in protecting oral health of all ages. There is absolutely no credible
scientific evidence to support this and any suggestion otherwise would be a
clear misrepresentation of scientific facts. It is unfortunate that the primary aim of water fluoridation
was to improve social inequalities in dental health. I say unfortunate because
with fluoridation of water supplies what is actually happening is a widening of
social inequalities. According to the WHO, children from socially-deprived
areas are most likely to be bottle-fed, consequently, they are also most at
risk of developing dental fluorosis.
The prevalence of dental fluorosis disease amongst
the population in fluoridated communities has become so endemic that in the
United States of America, where the policy originated, that it is now the
stated 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 from 6
months up to 3 years of age should be <0.25 mg/day. As far back as 1999, the U.S. Institute
of Medicine
(IOM, 1997) specified Adequate Intakes (AI) of 0.01 mg/day for infants through
6 months and 0.05 mg/kg/day beyond 6 months of age to prevent dental caries.
It is perhaps
appropriate to mention also Professor Hardy Limeback, BSC.,PhD in
Biochemistry, D.D.S. Head of the Department of Preventative Dentistry,
University of Toronto and President of the Canadian Association for Dental
Research,
regarded as the leading Canadian Dental Health Expert and until
recently, the country’s primary promoter of fluoride. Professor Limeback has now
withdrawn his long standing support for fluoridation based on current
scientific findings and stated[10]
on record both within the University and publicly the following, “children
under three should never use fluoridated toothpaste or drink fluoridated water
and baby formula must never be made up using fluoridated water.” Professor Limeback went on to say “residents of cities that
fluoridate have doubled the fluoride in their hip bones compared to the balance
of the population. Worse, we discovered that fluoride is actually altering the
basic architecture of human bones, skeletal fluorosis is a debilitating
condition that occurs when fluoride accumulates in bones, making them extremely
weak and brittle. In Canada we are now spending more money treating dental
fluorosis (the damage caused by fluoride) than we do treating cavities. Here in
Toronto we’ve been fluoridating for 36 years. Yet, Vancouver, which has never
fluoridated, has a cavity rate lower than Toronto’s. Cavity rates are low all
across the industrialized worlds, including Europe, which is 98% fluoride free.
Your well-intentioned dentist is simply following 50 years of misinformation
from public health organizations and the dental association.” This is a truly astonishing statement by a leading international
dental health professional, however Professor Limeback must be admired for
having the strength of character to admit he was wrong, something that I am
sure you will agree scientists and academics are very slow to do.
I believe that
it is appropriate as Chief Medical Officer, that you are correctly informed of
any misrepresentation of scientific research that you may be unaware of, in
particular, the findings of the United Kingdom’s NHS York Review of Water
Fluoridation or the SCHER Review both of which appear to have been interpreted incorrectly by the
Irish Expert Body on Fluorides. This misrepresentation has now unfortunately
entered the mainstream.
It is
particularly worrying, as expressed by the Chairperson of the NHS Scientific
Review Committee himself, that opinions continue to
be made which clearly mislead the public about the findings of scientific
reviews on fluoridation.
If I may explain
further, in regard to the NHS
York Systematic Review on the Effects of Water Fluoridation, I would ask that
you read the personal statement by Professor Trevor Sheldon, Chair of the
scientific committee who undertook the research which is provided in Appendix 2
of my report.
I am sure you will agree that the opening comments are deeply disturbing,
as they demonstrated a deliberate misrepresentation and distortion of
scientific findings by pro-fluoridation groups, a fact found by the Chairman of
the scientific review body who undertook the UK study.
Professor Sheldon
clearly states that “(t)he review found water fluoridation to be significantly
associated with high levels of dental fluorosis which was not characterised as
just a cosmetic issue" and that “the review did not show water
fluoridation to be safe.” This is
a very significant fact and coming from the Chairman of the NHS Scientific
Review Committee it clearly cannot be overlooked, as it was, in the Forum for
Fluoridation Report in 2002 or subsequently the Irish Expert Body on Fluorides.
Similarly the stated observation of fact as expressed by Professor
Limeback cannot be
disregarded ether. I am sure therefore that you would agree that it is
inappropiate to remark “that the balance of scientific evidence
worldwide confirms that water
fluoridation…does not cause any ill effects and continues to be safe and
effective…” when a
substantial body of peer-reviewed scientific evidence clearly demonstrates that
this is not the established scientific fact.
This information is provided in greater detail in my report. It is unfortunate that the Department
of Health continue to repeat this statement adlib perhaps in the hope that if
it is stated enough times it will become fact. It is not fact and it is
entirely incorrect.
HUMAN HEALTH IMPLICATIONS OF WATER FLUORIDATION
In regard to examining the human health implications of water
fluoridation there is no doubt that the most comprehensive human health effects
study undertaken to date is the United States National Research Councils
(NRC) Scientific Committee on Fluoride in Drinking Water Review 2006. This study is discussed and
summarized in detail within my own report. As you may be aware the NRC
Scientific Committee members are drawn from the councils of the National
Academy of Sciences, the National Academy of Engineering and the Institute of
Medicine in the United States of America. The NRC report is the least biased,
most authoritative and widest-ranging review of the toxic effects of fluoride
anywhere. I think it is by far the best summation of the evidence available
notwithstanding recent scientific discoveries, which have been included in my
report. It is apparent from your letter that you have not had the opportunity
to examine this report. In the interests of protecting public health in your
position as Chief Medical Officer, I would ask that you please review this
critically important report which highlights the urgent need for appropriate
human risk assessments to be undertaken in order to examine the toxicological
impact of silicofluorides on human health, none of which have been undertaken
to date by the HSE.
While I appreciate the demands on your time, as a starting
point, I would ask that you read Chapters 5 to 8 of my own report which include
some of the findings of the NRC review along with more recent scientific
research that is also of great importance. While you may not have time to review the NRC report in
full, may I suggest that you read Chapter 14 of my report, which summarises the main findings of the NRC study.
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It is clearly not accepted by the scientific
committees established by the United States, Russia, Canada, the United
Kingdom, the European Commission or those of any other nation state within
Europe that water fluoridation does not cause any ill effects and is safe. As
Chief Medical Officer I am truly shocked that you would make such a statement
in your letter.
As you are fully aware, no medication or drug is
allowed to enter the market and be used by the public unless it has been tested
for human toxicity. The same basic principle should apply to injecting
silicofluoride chemical compounds into drinking water that is consumed by the
population as a whole.
How can you in your role as Chief Medical Officer
state that this chemical is safe when every international scientific committee
established to examine the potential impacts of fluoride, clearly determines
that no human health risk assessment has ever been undertaken on this chemical?
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In addition,
you may not be aware that further research was also
recommended by these organisations and other national bodies in assessing the
health and environmental risks that may be associated with the use of the most
common drinking water fluoridation agents like silicofluorides, taking into
account their hazard profiles, their mode of use in water fluoridation, their
physical chemical behaviour when diluted in water and the possible adverse
effects they may have in exacerbating fluoride health effects as reported in
some scientific studies.
In response to
parliamentary questions on my behalf, 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
silicofluoride compounds on human beings. This is despite the numerous
recommendations from scientific bodies that efforts be made to determine the
toxicity of fluoride and silicofluoride products.
As Chief Medical
Officer, I wish to inform you that the Minister confirmed on behalf of the
Department of Health 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 Minister confirmed on
behalf of the Department of Health, 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.
Where it is established that there is a lack of
adequate scientific data to demonstrate that a chemical is safe, it is deeply
worrying that a position is presented which claims that ‘the balance of
scientific evidence confirms water fluoridation to be safe’, especially when the body
charged with protecting public health and ensuring compliance with EU Law in
Ireland has never undertaken any human health risk assessments on the products
used for water fluoridation.
Simply put, because there is a lack of credible scientific evidence,
this does not mean water fluoridation is safe.
I can only accept that the views you have
expressed are informed by officials within the Department and are not your
personally-informed interpretation. The views expressed in your letter are not
supported by scientific or expert groups advising any other European country
and do not support the latest EU scientific assessments, which are detailed in
my report, including the European Commission’s
Scientific Committee on Cosmetic Products and Non-Food Products (SCCNFP)
intended for consumers, who undertook a study of the safety of fluorine
compounds for children under 6 years of age and the European Commission’s
Scientific Committee on Health and Environmental Risks (SCHER), who were unable
to demonstrate the benefit of fluoridation of drinking water for dental health, while at the same time finding that systemic fluoridation leads
to overexposure of the population to fluoride which is clearly now evident in
Ireland.
To understand
the significance of this health risk I would draw to your attention the latest
studies by O Mullane et al.[11] (2003) Browne et al.[12] (2005) and Verkerk et al.[13] (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 is the
principle cause of the increased incidence. Remarkably 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. Remarkably in comparison
to evidence of severe and moderate dental fluorosis in fluoridated communities
it was also found that no children were observed with either condition in
non-fluoridated areas. The damage that dental fluorosis causes to the teeth is
permanent and irreversible and is not just cosmetic as expressed by the Irish
Expert Body on Fluoridation. Unfortunately the long-term damage to internal
organs of the body or to the physical or mental well-being of an individual is
not as visible as dental fluorosis therefore making its impacts more difficult
to diagnose.
The report attempts to address the long-term exposure of the population
to the health effects of silicofluoride compounds used in drinking water, as
well as their co-toxicity with other compounds such as aluminium and lead. It
is important that you are aware, that the health hazards, as noted by
scientific findings, associated with the enhanced incorporation of lead and
aluminium, are increased by the addition of silicofluorides to our drinking
water supplies. None of these hazards have been previously examined by the
Irish Expert Body on Fluorides.
It is also important as Chief Medical Officer that you are aware of the
findings of the WHO[14]
regarding the link between low calcium and magnesium in drinking water and
human health and disease. Of particular concern to any environmental scientist,
water manager or public health official are the serious health implications of
adding a silicofluoride chemicals to ‘soft’ drinking water that results in
further removing or inhibiting the metabolism of these essential compounds in
the human body (a concern noted[15]
by the UK British Medical Research Council as far back as 2002). Any such
action may be seen to be regarded clearly as a contributing factor to increasing
the risk of heart disease, diabetes, neurodegenerative
diseases and certain cancers, as previously documented by the WHO.
Where I live in County Cork drinking
water is extremely soft with a calcium level of < 20mg/l and a magnesium
level of < 5mg/l. Similar
levels are to be found in many parts of Ireland as has been detailed in my
report. As
Chief Medical Officer, you may be aware that the WHO have found[16] that low calcium and
magnesium drinking waters are associated with neurodegenerative disease, certain
cancers, hypocalcaemia, as well as cardiovascular mortality from
cardiovascular, ischaemic heart and hypertensive heart disease and increased
risk of sudden death syndrome. As Chief Medical Officer, I expect that you
would accept that adding a silicofluoride chemical to low calcium and magnesium
drinking waters that will ultimately result in directly removing or inhibiting
the metabolism of these essential compounds in the human body, is not to be
recommended.
It is obvious that injecting such compounds into soft drinking water is
not a safe practice and may be potentially dangerous. To do so in the absence
of any human health risk assessments to prove beyond reasonable doubt that it
is safe is entirely inappropriate, most likely illegal and not an action that
any responsible health authority should accept in the interest of safeguarding
public health and consumers. Clearly, the support of such an unsound policy
would result in fluoridation of water being a contributory risk factor to
developing heart disease, diabetes, neurodegenerative
diseases and certain cancers amongst the population, given the previously
documented findings of the WHO and the UK Medical Research Council.
As Chief Medical Officer, you are probably aware that the UK Medical Research Council found that “fluoride seeks out essential elements such as calcium and magnesium and binds with them, thereby interfering with their capacity to fulfill important metabolic processes in the body.” It is inconceivable therefore how the Department of Health can continue to insist on adding a chemical compound to drinking water that is now known to further reduce the bioavailability of both calcium and magnesium as well as contribute to other health risks and health consequences. That this would occur at all is alarming and that it would occur in high risk areas with ‘soft’ water is deeply disturbing. It is interesting, therefore, that these same geographic areas with known soft waters, as outlined in my report, have been found to be the very medical hotspots for cancer, neurological disease and cardiovascular disease in Ireland.
Within my report
there is much more detailed information and examination of the impacts of
silicofluorides on human health and the environment. I would ask that you please take the time to read this
report in order to assist you in developing appropriate public health policy in
the interests of public health and safety. The report includes published studies from over two hundred
and twenty separate peer-reviewed international scientific journals covering
every aspect of medicine and environmental assessment from dental health to
biochemistry, toxicology, metabolism, the blood, bone research, the brain,
metabolism, epidemiology, pharmacology, neurotoxicology, molecular neurobiology
and environmental toxicology. In total over twelve hundred scientific published
papers and references are provided in the report allowing the health, legal and
environmental impacts to be examined in some detail alongside associated risks
that have not yet been previously examined elsewhere. All of the evidence is
clearly convergent and demonstrates that silicofluoride compounds should not be
added to public water supplies; when examined collectively the evidence clearly
demonstrates that fluoridation of drinking water supplies is both unsafe and is
having significant negative health implications for human health, society and
the natural environment.
You may not be
aware but legal precedence exists in Europe establishing clearly that
fluoridated water is defined as a medicinal product. Further details of this are provided in Chapter 10 of my report.
Within the European Community the primary legislation governing fluoridation of
water supplies is the European Council Directive on Medicinal Products for
Human Use (2004/27/EC). The State is required under EU Law - 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
legal requirement, as noted previously in this letter and in my report, the
Government of Ireland or its agencies have not undertaken risk assessments on
the fluoridation products in use in Ireland. This constitutes a flagrant and serious violation of
Directive 2001/83/EC.
In respect of EU
Food Law, the EU Commission and expert scientific
bodies have found that fluoridated drinking water is not safe for consumption
by infants, as it results in contamination of baby infant formula milk with fluoride levels far in excess of recommended safety standards.
This is a deeply
disturbing fact, one that is well-documented within the SCHER report as well as
other scientific publications including the UK Expert Group on Vitamins and
Minerals[18] that are
noted and referenced within my report.
REVIEW OF EU COMMISSION SCIENTIFIC REVIEW ON WATER
FLUORIDATION.
I
acknowledge that you have stated that you accept the findings of the SCHER
scientific committee on water fluoridation. As you may be aware SCHER itself
acknowledged that limited evidence from epidemiological studies points towards
adverse health effects following systemic fluoride consumption, e.g.,
carcinogenicity, developmental neurotoxicity and reproductive toxicity and
requested more detailed studies to be undertaken in the interests of public
safety.
As
you are aware Ireland is the only EU member state that has a legislative policy
requiring fluoridation of its water supplies, unlike the remaining 98% of
Europe, therefore the onus of responsibility lies with the Department of Health
to undertake any research necessary to prove without doubt that the chemicals
used are safe for human consumption and the environment. This has already been
addressed elsewhere.
As
you may be aware SCHER found that the toxicology of Hexafluorosilicic acid
and hexafluorosilicictes compounds is incompletely investigated. These are the chemicals
agent in drinking water fluoridation that the Department of Health insist on
injecting into public water supplies, despite not having been tested for human
or environmental toxicity. Naturally you will understand that this is illegal
and violates EU and National Law.
You
will no doubt also be aware that SCHER observed that water fluoridation was
intended to have a beneficial effect on caries prevention but could also induce
fluorosis with a very narrow margin of exposure and that there is a risk of
dental fluorosis in children in EU countries with systemic fluoride exposure.
Within the EU this risk only applies to Ireland. As previously noted dental
fluorosis affects over 30% of children in communities with fluoridated water.
In
this regard you will also note that, in addition to finding that the systemic
exposure to fluoride in drinking water is associated with an increased risk of
dental and bone fluorosis, it noted that exposure to fluoride levels during
tooth development can result in dental fluorosis. It was also observed that
excess systemically absorbed fluoride may impair normal development of enamel
in the pre-eruptive tooth. Again all of this is clearly evident in Ireland.
SCHER
found that enamel fluorosis seen in areas with fluoridated water has been
attributed to inappropriate high fluoride intake. This observation is once
again confirmed by studies in Ireland where dental fluorosis has been found to
now affect over 30% of children.
Importantly
SCHER found that the tolerable Upper intake Level (UL),is exceeded for infants
whose diet consists of formulated food products made up with fluoridated water.
Unfortunately Ireland has by far and away the highest prevalence of bottle-fed
infants in Europe and as the only country with systemic water fluoridation this
risk only applies to Irish citizens.
You
may also be aware that SCHER found that there is slight evidence that
high-level occupational exposure to fluoride affects male reproductive hormone
levels and that a few studies on human populations have suggested that fluoride
might be associated with alterations in reproductive hormones and fertility.
You may also note that SCHER observed that most of the animal studies on the
reproductive effects of fluoride exposure deal with the male reproductive
system of mice and rats and that little or no data is available for human studies. SCHER acknowledged that
animal studies consistently show an effect on spermatogenesis or male
fertility.
Of concern also are the findings of one of
the most recent neurotoxicity studies undertaken by Rocha-Amador et al. (2007) and noted in the SCHER review, which reported that the findings of
this study established “an inverse association between fluoride in drinking
water and IQ after adjusting for relevant confounding variables”.
You
may also be aware that SCHER accepted that some epidemiological studies seem to
indicate a possible link between fluoride in drinking water and osteosarcoma
(childhood bone cancer) disparities and that fluoride can weaken bone and
increase the risk of bone fractures.
You
may also be aware that SCHER acknowledged that their environmental review was simplistic and based on just one
published paper. It is noted in particular that the observations and conclusion of the
reference study[19] on which the review
itself observed that “the toxic action of fluoride resides in the fact
that fluoride ions act as enzymatic poisons, inhibiting enzyme activity and,
ultimately, interrupting metabolic processes such as glycolysis and synthesis
of proteins.” Or
that scientific study has clearly found that fluoride
is an endocrine disruptor in the aquatic environment or that the critical level for salmon in freshwater was
found to be as low as 0.2 mgF/L. while levels as low as 0.1 mgF/L were shown to be lethal to the Daphnia magna, the main food source of
both freshwater fish. These levels
are far below that discharged from urban wastewater treatment plants and may
explain the decline in Irish freshwater fisheries in recent decades since
commencement of water fluoridation. These are scientific facts completely
opposite to the scenario expressed continuously by the HSE in any
correspondence regarding water fluoridation.
You
will also be aware that SCHER concluded that topical
application of fluoride (not water fluoridation) was the most effective method
for preventing tooth decay.
Since
you have stated in your letter that you accept the findings of the SCHER review
then there is no doubt that you also accept the observations of the SCHER
scientific committee as outlined above. It is obvious therefore that your
statement suggesting that ‘fluoridation of water supplies continues to make
an effective contribution to oral health in Ireland’ is misinformed and not
based on the latest scientific evidence.
Clearly,
If you accept the findings of the SCHER review you cannot accept the
continuation of fluoridation of drinking water supplies in Ireland. Despite the fact that the physical, chemical and toxicological
properties of all of these compounds have not been thoroughly investigated
silicofluorides continue to be used in drinking water in clear violation of the
precautionary principle which in enshrined in European law.
LACK OF SCIENTIFIC DATA TO PROVE
THAT WATER FLUORIDATION IS SAFE
Any exposure assessment for
fluorides should examine the toxicological impact of ‘fluoride’ and
‘silicofluorides’ compounds as well as its co-toxicity with other compounds in
drinking such as Aluminium Fluoride (AlF3) and Lead Fluoride (PbF2). For
further information I would ask that you read the statement by Professor
Robert Isaacson, member of the National Research
Council NRC Scientific Committee for the evaluation
of possible hazards of fluoride in drinking water, which is provided in pages
298-303 of my report.
As Chief Medical Officer you may
also be aware that certain additional health risks have clearly been identified
by both the EU Commission (SCHER) and U.S. National Research Council (NRC)
scientific committees requiring further study as noted in my report (pages 263-281).
In particular you should be aware that infants who are fed formula milk
constituted with fluoridated water, individuals with diabetes have also been
identified by both these distinguished bodies as the most at risk of negative
health impacts from exposure to fluoridated water.
You may be
aware also that both the SCHER and NRC Scientific
Reviews identified additional epidemiology, toxicology, clinical medicine,
and environmental exposure assessments that need to be undertaken in order to
fill data gaps in the hazard profile, the health effects and the exposure
assessment of silicofluoride compounds.
For your
information Chapter 16 of my report lists a minimum of fifty-nine
recommended studies required to be undertaken on
fluoridation compounds to quantify the public health risks from fluoridation
of drinking water supplies as recommended by
international scientific bodies.
None of these
studies have been undertaken by the regulatory authorities in Ireland.
SCIENTIFIC CONSENSUS SHOWS THAT
WATER FLUORIDATION IS NOT SAFE
Apart from the two European bodies
already mentioned (SCHER and EFSA), you may also be aware that another European
Commission Scientific Committee was established to examine Cosmetic Products
and Non-Food Products (SCCNFP) intended for
consumers.
The SCCNFP observed that systemic
exposure to fluoride, resulting from fluoridation of drinking water supplies
not only contaminates infant formula food but may impair normal development of
enamel in the pre-eruptive tooth and cause fluorosis.
I would also direct your offices to the report by the Russian Academy of
Sciences
which has also extensively documented the toxicological effects of fluorides.
[20]
In regard to ill
health effects associated with fluorides, you may not be aware but the United
States Public Health Service have stated that
“(s)egments of the population are unusually susceptible to the toxic effects of
fluoride. They include "postmenopausal women and elderly men, pregnant
woman and their foetuses, people with deficiencies of calcium, magnesium and/or
Vitamin C, and people with cardiovascular and kidney problems." [21]
With respect to
health protection for infants, and in particular dental health, you may be
unaware that the President of the Canadian Association of Dental Research, Professor Hardy Limeback, B.Sc., Ph.D., D.D.S., and Head of the
Department of Preventive Dentistry for the University of Toronto has stated
that ”children under three should never use fluoridated toothpaste or drink
fluoridated water. And baby formula must never be made up using fluoridated
water.” Similarly you may be unaware that the Journal
of American Dental Association has stated that “the
current reported decline in caries tooth decay in the US and other Western
industrialized countries has been observed in both fluoridated and
non-fluoridated communities, with percentage reductions in each community
apparently about the same".
You may also be
unaware that Dr. Simon Beisler, Chief of Urology,
Roosevelt Hospital, and Past President of the American Urological Association,
stated that "it is now clear that fluoride is a potentially harmful
substance when present in the drinking water in any amount” or that that Dr. Arvid Carlsson, Pharmacologist and Nobel Laureate in
Medicine (2000) stated that the practice of
fluoridation “is against all principles of modern pharmacology. It's really
obsolete. No doubt about that…those nations that are using it should feel
ashamed of themselves. It's against science. If
you drink it (fluorine), you are running the risk of all kinds of toxic
actions. And, of course, there are such actions. This is something you
shouldn't expose citizens to. I would advise against fluoridation”.
Likewise you may
be unaware of the recently published paper by Dr. Valdez-Jimenez, et al.[22] which found that “the prolonged ingestion of fluoride may cause
significant damage to health and particularly to the nervous system." The study examined how “fluoride induces changes in the brain's
physical structure and biochemistry which affects the neurological and mental
development of individuals including cognitive processes, such as learning and
memory. It
further observed that the effects…are not immediate and that it can take 20
years or more for its toxic effect to become evident.” I
would also wish to bring to your attention a recent paper published in the Lancet
which found that “fluoridated water may be
having its most devastating effects on the most vulnerable, those in utero and
infants less than one year old, whose brains are most sensitive to
developmental neurotoxins such as fluoride.” [23]
Of enormous public health importance, as noted in
my report, are the scientific studies, which have found that fluoride inhibits
homocysteine metabolism.[24]
As you are no doubt aware, homocysteine metabolism is associated with
neurological diseases including neural tube defect, schizophrenia, bipolar
disorder, depression, Parkinson‘s disease and epilepsy as well as cognitive
aging and dementia, all of which are on the increase in Ireland. This is
addressed in more detail in pages 74-80 of my report with appropriate
scientific references.
As Chief Medical Officer, you are fully aware that
Ireland sadly has one of the highest incidences of neurological and
cardiovascular disease in Europe, if not the world. It may be coincidental that
we are also the most fluoridated community in Europe if not the world, being
one of two countries with mandatory fluoridation of public water supplies with
over 75% of the population consuming fluoridated water at levels twice the
recommended limits in Singapore. It is obvious given the internationally
published research highlighting the link between prevalence of neurological
disease and overexposure to fluorides that this association cannot be
discounted as a contributory factor to this disease prevalence in Ireland.
As Chief Medical Officer I would also like to draw
to your attention scientific studies[25] that have found that “the
human pineal gland contains the highest concentration of fluoride in the body.
Fluoride is associated with depressed pineal melatonin synthesis”. In regard to the pineal gland you may be aware that the U.S. National
Research Council scientific committee, examining fluoride in drinking water,
previously stated “recent information on the role of the pineal organ in
humans suggests that any agent that affects pineal function could affect human
health in a variety of ways, including effects on sexual maturation, calcium
metabolism, parathyroid function, postmenopausal osteoporosis, cancer, and psychiatric
disease”. [26]
As I have
previously outlined in my report and in accordance with legislation[27],[28],[29],[30]
the Health Service Executive is required to establish testing protocals
to ensure that adequate epidemiology, toxicology,
clinical medicine and environmental exposure assessments are undertaken to
protect the consumer as well as determine the environmental impact from
exposure to silicofluorides.
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In the
development of human risk assessment testing programmes, such programmes must
be undertaken in conjunction with other Departments and State Agencies
including the Department of Environment, Department of Agriculture and Food and
Fisheries, the Food Safety Authority and the EPA.
As Chief Medical
Officer, you should be aware that no such testing protocols currently exist.
Furthermore I wish to advise you that water fluoridation results in
contaminated foodstuffs in violation of EU Law, in particular, the European
Council Regulation (852/2004/EEC) on the Hygiene of Foodstuffs and the European Council Regulations (S.I. No. 243/1998) for
Infant Formulae and Follow-On Formulae. The
contamination of infant formula food with fluoride from fluoridated water has been examined extensively by the
European Food Safety Authority and the UK Expert body on Vitamins and Minerals.
The risk for infants who consume fluoridated formula feed was acknowledged by
the Assistant
Secretary for Health, U.S. Department of Health and Human Services (HHS) in 2011.
COMPLIANCE
WITH MINIMUM SAFETY STANDARDS OF GOVERANCE
If as you
advise, the HSE is to continue with the policy of mandatory fluoridation of
drinking water supplies, a thorough examination of the scientific
recommendations requiring further study should 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. 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 officials
who are responsible for implementation of such policy where they are found in
breach of EU Law.
Contrary to what you suggest in your
letter, 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 and their
scientific advisors have rejected fluoridation of drinking water completely as
a public health policy: Austria, Belgium, Croatia, Czech Republic, Denmark,
Finland, France, Germany, Hungary, Iceland, Italy, Luxembourg, the Netherlands,
Norway, Sweden, Spain, Portugal, Switzerland and the United Kingdom. Contrary
to your statement the UK does not fluoridate all its water supplies. No water
supplies are fluoridated in Northern Ireland, Scotland, or Wales, less than 10%
of the water supplies in the England are fluoridated despite the fact that
their own internal review by the NHS found that the practise was unsafe. Most
recently, in 2008, the Test Valley Borough Council in the UK ended its policy
of fluoridation of water supplies while the last city in mainland Europe to
terminate fluoridation of water was the city of Basel, Switzerland, in 2003.
In addition, the majority of non-EU
countries similarly support this position including India, China, Egypt, South
Africa, Japan and many other nation states. It is a fact that there is only one
other country in the world that supports Ireland’s position on mandatory
legislative fluoridation of public water supplies and that country is
Singapore. It is worthy to note that the statutory level in Singapore and in
Hong Kong is considerably less than that applied in Ireland. In Hong Kong, the
level of fluoride in drinking water is set at 0.49mg/l considerably less than
the 0.8mg/l standard applied in Ireland.
Contrary to what you have suggested in
your letter, Canada as a country does not fluoridate all its public water
supplies neither does the United States of America nor New Zealand. In each of
these countries it is undertaken by local health authorities and by local
government and almost equal percentages of the population do not consume
fluoridated water.
Clearly, you are not aware that on health
concerns alone over 300 cities and communities in the USA, Canada and New
Zealand have successfully ended the policy of water fluoridation since
1990.
You may also be unaware of a recent
European study undertaken within 16 countries in Europe examining citizen’s
opinions on water fluoridation.[31]
This study clearly found that the vast majority of people are opposed to water
fluoridation. It is a sad reflection of our democracy that the public in
Ireland were never consulted on this policy,
either prior to its implementation or subsequently and that to this day no
environmental impact assessment has been undertaken
examining how fluoride emissions into the environment may have impacted on our
protected habitats and fisheries and sensitive ecosystems . It is even more
disturbing that the public have deliberately not been informed of the potential
health risks associated with fluoride exposure, in particular, for bottle-fed
infants or high-risk sectors of the population such as diabetics. As a parent,
consumer and scientist I find this totally unacceptable.
In complete contrast, for example in North
America[32]
the American Academy of Pediatrics recommends no
fluoride supplements before the age of 6 months and not more than one cup of
fluoridated water (0.25mg) from 6 months to 3 years of age. In Canada[33]
parents are similarly advised not to prepare
infant formula feed with fluoridated water in order to reduce the amount of systemically ingested fluoride.
Likewise in Denmark, the Public Health Authority[34]
recommends that “a major effort should be used to avoid the use of fluoridated
water for dilution of formula powders. In addition when economically feasible
young infants fed formulas prepared from concentrated liquids should have these
formulas made up with non fluorinated water.”
Yet astonishingly, in Ireland we have the
lowest prevalence of breastfeeding in the world resulting in the highest number
of bottle-fed babies, all of which are innocently consuming fluoridated water
at levels far exceeding the recommended maximum tolerable safety levels, no
warnings by the Health Authority or Food Safety Authority have been provided at
all to the public. This is completely unacceptable.
As Chief Medical
Officer, I believe on behalf of the public interest it is incumbent upon you to
raise these concerns with the Minister for Health.
I also request,
in the interests of public health and safety and in accordance with the
precautionary principle that is enshrined in European law, as well as in
accordance with appropriate EU Directives, that you seek an immediate cessation
to the water fluoridation policy, until human health risk assessments have been
completed by the Irish Authorities to demonstrate that the chemical compounds
used for fluoridation of water are safe for human consumption for all sectors
of our community particularly the most sensitive groups which include infants
and diabetics.
Furthermore I
ask that in accordance with EU Law and as directed by the Minister for health
in Chile tat you demand of the regulatory authorities that they must clearly
demonstrate that the anthropogenic fluoride emissions from wastewater treatment
plants resulting from artificial water fluoridation do not impact on the
environment, food safety or fisheries and comply with all relevant EU
legislation.
Evidence to
demonstrate this must be provided by the regulatory authorities in accordance
with EU Law.
I would add, that I have not, as you
implied, raised any concern in my report regarding fluoridated toothpaste. I
have however as previously noted in this letter and within my report, advised
that the scientific consensus worldwide is that where fluoridated toothpaste is
widely available, as in Ireland and elsewhere in Europe, that there is no
requirement for fluoridation of water supplies. This is the current position as
I have already noted of every other European country as that of the WHO. I
would respectfully ask therefore that you read my report especially given the
cost in time, resources and personal commitment to complete this endeavour, all
of which was undertaken at no cost to the exchequer. It is logical that by
Ireland following the example of the rest of Europe and terminating the policy
of water fluoridation is would help the exchequer and allow much need funds to
be directed to essential front line services elsewhere.
Finally may I reflect on
the advice of your office last year regarding the health risks posed by
radiofrequency electromagnetic fields from mobile phones for children as they are
obviously relevant to the matter of health protection for children in general.
In June 2011, in your position as Chief Medical Officer you advised that, given
there is general consensus that children are more vulnerable to radiation from mobile
phones than adults that “therefore the sensible thing to do is to adopt a
precautionary approach rather than wait to have the risks confirmed." You further advised, “given the
scientific uncertainty regarding mobile phone-related cancer risks many
countries including Germany, France, Austria, the UK and Russia have taken a
precautionary stance regarding cell phone use, particularly by children
and recommend that the risk of exposure to children from mobile phone should be
limited by restricting their use of mobile phones for essential purposes only.” While your statement of warning to the press regarding the
health concerns is admirable, it is evident that unless the HSE follow in the
footsteps of the NHS in the UK and publish information leaflets to be distributed
to households warning parents of these concerns, parents will remain unaware of
the risks and no action will be taken to minimize the health risk or change
behavioral patterns. As with
fluoride contamination of baby food, parents are not aware of the health
concerns regarding mobile phones and children. The prevalence of mobile phone
use by children in both primary and secondary schools in Ireland clearly
demonstrates this. In my community a considerable number of children attending
fifth grade in primary school have a mobile phone.
It is logical, that the same principles of good
governance that you applied as Chief Medical Officer to raising concerns
regarding exposure of children to mobile phone radiation should also be applied
to known health risks, as well as potential health risks from toxins such as
fluorides, in particular the exceedance of any tolerable upper exposure limits
which have been set for the protection of children and which are exceeded by
infants who consume fluoridated baby food in Ireland.
Finally, I
request that as Chief Medical Officer for the Department of Health you may
advise me of the following;
I am aware of my
own fluoride dietary intake and that of my dependents and know the fluoride
added to our drinking water supply, under the regulations established by the
HSE and implemented by my local authority, is contributing to unsafe levels of
dietary fluoride intake for both me and my family. I have established these
facts based on a scientific assessment and examination of the fluoride content
in beverages and food using an accredited laboratory. As the responsible
regulatory authority for the contamination of my drinking water supplies,
please advise how I may remove these unwanted toxins from my water supply ?
I require a reply
from you to this last question as it is a necessary preventative health measure
to limit the exposure of my family to fluoride, in order that we comply with
the recommended standards of dietary exposure to this dangerous toxin.
From the
research I have undertaken it is not possible to remove this contaminant using
typical water filters and it is acknowledged by the WHO that purified water
from reverse osmosis water purifier systems is not safe for human consumption.
I look forward
to your reply.
Yours
sincerely
Declan
Waugh
[1] EnviroManagement
Services independent accredited laboratory analysis of beverage samples tested
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[2] European Food Safety Authority, Opinion of
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[7] Feltman, R., and
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[8] NTP (National
Toxicology Program) (1990). Technical Report on the toxicology and
carcinogenesis studies of sodium fluoride in F344/N rats and B6C3F1 mice
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[9] Government
Perspectives on Healthcare, HHS: Proposed Guidelines on
Fluoride in Drinking Water. A Commentary By Howard K. Koh, MD, MPH
[11] 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
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[12] Browne D, Whelton
H, O‘ Mullane D, Oral Health Services Research Centre, University Dental
School, Cork. Fluoride metabolism and fluorosis, Journal of Dentistry, Volume
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[13] Verkerk, Robert
H.J. The paradox of overlapping micronutrient risks and benefits obligates
risk/benefit analysis, Journal of Toxicology, Feb 2010.
[14] Calcium and Magnesium in Drinking-water Public health
Significance, World Health Organization, 2009.
[15] UK Medical
Research Council Working Group Report: Water Fluoridation and Health, September
2002
[16] Calcium and Magnesium in Drinking-water
Public health Significance, World Health Organization, 2009.
[17] UK Medical
Research Council Working Group Report: Water Fluoridation and Health, September
2002
[18] EVM/01/03/P United
Kingdom’s Expert Group On Vitamins And Minerals, Review of Fluoride, May 2001
[20] Molecular mechanisms of cytotoxicity and cell death
induced by inorganic fluoride, Sechenov
Institute of Evolutionary Physiology and Biochemistry, Russian Academy of
Sciences
[22] Valdez-Jiménez L,
Soria Fregozo C, Miranda Beltrán ML, Gutiérrez Coronado O, Pérez Vega MI.
Neurologia 2011 Jun;26(5):297-300. Epub 2011 Jan 20.Effects of the fluoride on
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[23] Grandjean P,
Landrigan PJ. Developmental neurotoxicity of industrial chemicals. Lancet
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[24] Mehdi S, Jarvi ET,
Koehl JR, McCarthy JR, Bey P. The mechanism of inhibition of
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aged human pineal gland. School of Biological Sciences, University of Surrey,
Guildford, UK, Department of Obstetrics and Gynaecology, The Royal London
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[26] National Research Council. (2006). Fluoride
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