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"From the outset the Draft is riddled with misinformation and omissions," said environmental writer George Glasser. "They've been cookin' the books for fifty years . . . burying all the negatives in a mountain of conflicting studies."

The Fluoride Game - "They're still cookin' the books."

(Comment on the Toxicological Profile for FLUORIDES, Draft Profile for Public Comment, September 2001)

T.J. Greene

"If you shut up the truth and bury it under the ground, it will but grow and gather to itself such explosive power that the day it bursts through it will blow up everything in its way." - Zola

A package arrived at my home containing a crimson tome entitled "Toxicological Profile for Fluorides - Draft for Public Comment (Update)". This document was released by the US Department of Health and Human Services. As a dutiful member of the Public, I read the 232-page text and the accompanying 70 pages of references.

When presented with a plethora of conflicting and unsubstantiated statements, the attention of the enquiring mind is generally aroused. One might reasonably expect the Reference section of a document of this importance to deliver enlightenment. Alas, the references are inconveniently presented in alphabetical order, effectively defying any attempt to reconcile them with the text. This official Draft Profile should be considered essential reading by all students of logic.

Critics of water fluoridation science are familiar with such devices. In typical down-home style, one acerbic observer (Glasser) commented: "It's the fluoride game. They've been cookin' the books for fifty years. They accentuate the positive by burying all the negatives in a mountain of conflicting studies."

This blunt remark sparked my curiosity. Preliminary searches for "fluoride" netted a variety of literature, almost all of it was focused on water fluoridation. Among the cache I found that scientific papers on toxicological effects are routinely denounced as quackery by scientific gentlemen with different views. Internet chat boards are littered with interminable, frequently insulting and sometimes comical exchanges between dentists and citizens. Implacable armies holding contrary views on this topic have waged virtual war on each other for more than fifty years. A succession of leaders on both sides have died at their posts, leaving fresh lieutenants to lead the charge.

From my position in No Man's Land I embarked on a quest for reasonable, understandable science before addressing the USDHHS Toxicological Profile. My searches yielded very surprising results.

The Draft Profile rigidly adheres to scientific dogma, deftly seasoned with incomplete fact. In their review of the document, three expert ATSDR committees failed to correct elementary errors and omissions.

On page 2, paragraph 1, the Draft Profile categorically states: "Sodium fluoride is often added to drinking water supplies . . . "

The use of sodium fluoride for water fluoridation has been almost entirely phased out in the United States.

For nearly thirty years more than 90% of all artificial fluoridation schemes in the United States have dispensed industrial grade fluorosilicic acid to the Public. Smaller schemes use industrial grade disodium fluorosilicate. (1)

Certified laboratory analyses show that these "dirty" fluorosilicates are highly contaminated. Fluorosilicic acid contains cancer-causing Arsenic and Beryllium, together with Aluminium, Lead and Mercury which cause brain damage. Other suspect companions include Cadmium, Silica, Vanadium and radionuclides. The authors do not mention the presence of these contaminants which are known to interact in combination with each other in the presence of fluoride. Thus do they divest themselves of any obligation to explain what happens to these substances when they enter the human body.

An alert, dedicated reader, on reaching page 60 of the Draft Profile, would learn that

"Fluoride is often added to the water in the form of hydrofluosilicic acid, so exposure to this chemical is included in some epidemiological studies."

(Note that the international term for hydrofluosilicic acid is 'fluorosilicic acid').

This brief mention that hydrofluosilicic acid is "often" added to water is an obfuscation. The substance has been the primary fluoridation chemical since the 1970s. Exhaustive searches reveal no evidence that safety testing has ever been conducted with "dirty" fluorosilicates.

The authors of the Draft Profile accept a universal form of clinical safety testing, which employs a pharmaceutical grade of sodium fluoride. The chemical is dissolved in double-distilled, de-ionised water and fed to healthy laboratory rats. These pristine ingredients, used within a sterile laboratory setting, are deemed to provide a suitable substitute for all "dirty" (industrial waste) fluorides used in public water fluoridation schemes. The Draft Profile offers no logical explanation for this substitution.

Over the decades, epidemiological papers have been published showing that significant numbers of a variety of cancers, and damage to the brain, kidney, thyroid, etc. correlate with water fluoridation. These important findings are frequently dismissed with claims that such adverse results could not be replicated in the laboratory (by tests performed with a pharmaceutical grade of sodium fluoride.). Logic dictates that as the results were not caused by laboratory ingredients, new tests, using "dirty" fluorosilicates might be in order.

Occasionally, novel papers are dismissed because "no other studies could be found" to substantiate the findings!

When critics refuse to be silenced, they are subjected to grandstand put-downs - "the researchers did not account for cigarette smoking (or passive smoking) or sexual activity." These criticisms were used to dismiss a paper on uterine cancer. (2)

Exhaustive searches on Pubmed failed to elicit any studies linking smoking or sexual activity with uterine cancer.

Thomas Reeves holds the title of "US National Fluoridation Engineer." He is based at the Centers for Disease Control and Prevention in Atlanta. This official CDC spokesman offered the following explanation on why pharmaceutical grade chemicals are not used in drinking water:

"Pharmaceutical grade fluoride compounds are not appropriate for water fluoridation, they are used in the formulation of prescription drugs."

(The Manufacture of the Fluoride Chemicals, CDC Statement, 2000).

Logic dictates that pharmaceutical grade fluoride compounds are considerably less toxic than the "dirty" fluorides used to fluoridate drinking water.

Contrast Reeves' statement with that of senior EPA scientist, Bill Hirzy, PhD, who wrote:

"When a chemical manufacturer wants to make a new chemical to use, for example, as an additive in motor oil, all existing toxicological data must be presented to the Environmental Protection Agency for review of potential risks before manufacture and use can begin. In the DRI we see risk assessment principles as applied to a major public policy issue flouted - even the existence of a massive body of information on adverse effects of fluoride is ignored, let alone discussed. And this for a chemical the National Academy recommends we purposely add to our diets, not our motor oil. . . . In summary, our union members' review of the literature over the last 11 years has led us to conclude that a causal link exists between fluoride exposure and cancer, increased risk of hip fracture, and damage to the central nervous system. For the National Academy of Sciences to attempt to anoint this substance an 'essential nutrient' is a travesty and a matter of shame for the US science community."

(Press Release dated 23 September 1997 issued by the Union of government employees - NFFE, Local Branch 2050 - at the US Environmental Protection Agency HQ, Washington, DC.).

Is the Public protected by public health officials?

In response to the US House Subcommittee on Energy and the Environment, Charles Fox, Assistant Administrator USEPA, conceded that after more than five decades of fluoridation tens of millions of Americans are at risk from exposure to fluoridated drinking water. (3)

Fox referred to the statement on page 112 of the 1993 edition of the Toxicological Profile, which reads:

POPULATIONS THAT ARE UNUSUALLY SUSCEPTIBLE":

Existing data indicate that subsets of the population may be unusually susceptible to the effects of fluoride and its compounds. These populations include the elderly, people with deficiencies of calcium, magnesium and vitamin C, and people with cardiovascular and kidney problems . . . Poor nutrition increases the incidence and severity of dental fluorosis and skeletal fluorosis."

The following statistics, compiled for the US House Committee on Science Inquiry, reveal the numbers of Americans who make up the 'subsets' which the EPA considers to be at risk from artificial water fluoridation:

· 55 years and older

52,000,000

· People with Cardiovascular disease

22,000,000

· People with Kidney (renal) disorders

2,000,000

· People with Vitamin C deficiency - EPA figure: 27% of the population

[75,600,000 , based on total population of 280M]

· People with Magnesium deficiency - EPA figure: 37% of the population

[ 103,600,000, based on total population of 280M ]

· People with Calcium deficiency - 44% of the population

[ 123,200,000, based on population of 280M ]

In the 2001 Draft Profile, the paragraph on "susceptible populations" has been extended to include the following sentence:

"However, these effects would not be expected at typical exposure levels (1 ppm fluoride)."

There is no explanation or citation to justify this addition.

Burying science?

Since the previous Toxicological Profile was published in 1993, work by Varner, et al, (4) Tohyama, et al, (see ref. 2) Takahashi, et al, (5) and many others, raise new and disturbing concerns about the practice of artificial water fluoridation. The Draft Profile omits the work of the Japanese scientists. However, it does include a brief mention of the latest Varner study, noting only the results which they obtained with sodium fluoride.

The Varner, et al findings on aluminium fluoride in drinking water were completely ignored in the Draft Profile, presumably because the results did not comply with the accepted laboratory test criteria. However, the US EPA and the US National Institutes of Environment Health Sciences were so concerned that they asked the National Toxicology Program to commission long-term drinking water studies to address pharmacokinetics, neurotoxicity, bone development, and reproductive and developmental toxicity. (6)

The Draft Profile states that 20% of children are affected by dental fluorosis.

"Recent studies have found small white spots in about 20% of the children exposed to water containing 1ppm fluoride; [less than] 1% may have brown spots. Mild dental fluorosis is considered a cosmetic effect; it is not necessarily a precursor to skeletal fluorosis but may be a clinical indicator of exposure of children to excess fluoride."

The Draft Profile authors and reviewers appear to have missed an important item which appeared in Pediatric Dentistry, (pp 17-19) Jan/Feb 1995. The report stated that in a study of 708 children living in a city with fluoridated water, three out of every four had dental fluorosis. The report declared that fluorosis also occurred in children who did not drink the local water. Many were given fluoride supplements, fluoride toothpaste and food and drinks prepared with fluoridated water.

The Draft Profile authors also missed a main feature in the Journal of the American Dental Association, in December 1995, which stated that up to 80% of children living in fluoridated areas of the United States and Canada have dental fluorosis.

The Draft Profile omitted any reference to the UK Government's systematic scientific review of water fluoridation (2000) (7) which showed that 48% of people living in fluoridated areas have dental fluorosis to some degree. The UK scientific team found that 12.5% had dental fluorosis "of concern."

The Chairman of the Review's Advisory Group, Professor Trevor Sheldon, expressed concern when the British Fluoridation Society, the British Dental Association and the British Medical Association misrepresented the results of this systematic review. In a Statement dated 3 January 2001, he chastised these 'august bodies'.

In my capacity of chair of the Advisory Group for the systematic review on the effects of water fluoridation recently conducted by the NHS Centre for Reviews and Dissemination the University of York and as it founding director, I am concerned that the results of the review have been widely misrepresented. The review was exceptional in this field in that it was conducted by an independent group to the highest international scientific standards and a summary has been published in the British Medical Journal. It is particularly worrying then that statements which mislead the public about the review's findings have been made in press releases and briefings by the British Dental Association, British Medical Association, the National Alliance for Equity in Dental Health and the British Fluoridation Society. I should like to correct some of these errors.

1 Whilst there is evidence that water fluoridation is effective at reducing caries, the quality of the studies was generally moderate and the size of the estimated benefit, only of the order of 15%, is far from "massive".

2 The review found water fluoridation to be significantly associated with high levels of dental fluorosis which was not characterised as "just a cosmetic issue".

3 The review did not show water fluoridation to be safe. The quality of the research was too poor to establish with confidence whether or not there are potentially important adverse effects in addition to the high levels of fluorosis. The report recommended that more research was needed.

4 There was little evidence to show that water fluoridation has reduced social inequalities in dental health.

5 The review could come to no conclusion as to the cost-effectiveness of water fluoridation or whether there are different effects between natural or artificial fluoridation.

6 Probably because of the rigour with which this review was conducted, these findings are more cautious and less conclusive than in most previous reviews.

7 The review team was surprised that in spite of the large number of studies carried out over several decades there is a dearth of reliable evidence with which to inform policy. Until high quality studies are undertaken providing more definite evidence, there will continue to be legitimate scientific controversy over the likely effects and costs of water fluoridation. [Emphasis added].

(Signed) T.A. Sheldon,
Professor Trevor Sheldon, MSc, MSc, DSc, FMedSci.

Summary

The current Draft appears to have been crafted to overwhelm and confuse the lay reader

  • by concealing the nature of the fluorosilicates used in water fluoridation;
  • by deflecting concern about adverse health effects;
  • by minimising the incidence of dental fluorosis, which is a manifestation of systemic fluoride toxicity

    in order to justify and protect the practice of artificial water fluoridation.

    References:

    1. http://www.npwa.freeserve.co.uk/pollution.htm

    2. Tohyama E., Relationship between fluoride concentration in drinking water and mortality rate from uterine cancer in Okinawa prefecture, Japan, J Epidemiol 1996 Dec;6(4):184-91, Erratum in: J Epidemiol 1997 Sep;7(3):184 (Japan Association of Epidemology),

    Abstract:
    The Okinawa Islands located in the southern-most part of Japan were under U.S. administration from 1945 to 1972. During that time, fluoride was added to the drinking water supplies in most regions. The relationship between fluoride concentration in drinking water and uterine cancer mortality rate was studied in 20 municipalities of Okinawa and the data were analyzed using correlation and multivariate statistics. The main findings were as follows. (1) A significant positive correlation was found between fluoride concentration in drinking water and uterine cancer mortality in 20 municipalities (r = 0.626, p < 0.005). (2) Even after adjusting for the potential confounding variables, such as tap water diffusion rate, primary industry population ratio, income gap, stillbirth rate, divorce rate, this association was considerably significant. (3) Furthermore, the time trends in the uterine cancer mortality rate appear to be related to changes in water fluoridation practices.

    3. tp://www.citizens.org/Food_Water_Safety/Fluoridation/Materials/EPA_response2.pdf

    4. Varner JA, Jensen KF, Horvath W, Isaacson RL., Chronic administration of aluminum-fluoride or sodium-fluoride to rats in drinking water: alterations in neuronal and cerebrovascular integrity, Brain Res 1998 Feb 16;784(1-2):284-98 (Also see: http://www.npwa.freeserve.co.uk/aluminium.html )

    Abstract:
    This study describes alterations in the nervous system resulting from chronic administration of the fluoroaluminum complex (AlF3) or equivalent levels of fluoride (F) in the form of sodium-fluoride (NaF). Twenty seven adult male Long-Evans rats were administered one of three treatments for 52 weeks: the control group was administered double distilled deionized drinking water (ddw). The aluminum-treated group received ddw with 0.5 ppm AlF3 and the NaF group received ddw with 2.1 ppm NaF containing the equivalent amount of F as in the AlF3 ddw. Tissue aluminum (Al) levels of brain, liver and kidney were assessed with the Direct Current Plasma (DCP) technique and its distribution assessed with Morin histochemistry. Histological sections of brain were stained with hematoxylin & eosin (H&E), Cresyl violet, Bielschowsky silver stain, or immunohistochemically for beta-amyloid, amyloid A, and IgM. No differences were found between the body weights of rats in the different treatment groups although more rats died in the AlF3 group than in the control group. The Al levels in samples of brain and kidney were higher in both the AlF3 and NaF groups relative to controls. The effects of the two treatments on cerebrovascular and neuronal integrity were qualitatively and quantitatively different. These alterations were greater in animals in the AlF3 group than in the NaF group and greater in the NaF group than in controls. Copyright 1998 Elsevier Science B.V.

    5. Takahashi K, Akiniwa K, Narita K., Regression analysis of cancer incidence rates and water fluoride in the U.S.A. based on IACR/IARC (WHO) data (1978-1992). International Agency for Research on Cancer, J Epidemiol 2001 Jul;11(4):170-9 (Japan Association of Epidemiology).

    Abstract:
    Age-specific and age-standardized rates (ASR) of registered cancers for nine communities in the U.S.A. (21.8 million inhabitants, mainly white) were obtained from IARC data (1978-82, 1983-87, 1988-92). The percentage of people supplied with "optimally" fluoridated drinking water (FD) obtained from the Fluoridation Census 1985, U.S.A. were used for regression analysis of incidence rates of cancers at thirty six sites (ICD-WHO, 1957). About two-thirds of sites of the body (ICD) were associated positively with FD, but negative associations were noted for lip cancer, melanoma of the skin, and cancers of the prostate and thyroid gland. In digestive organs the stomach showed only limited and small intestine no significant link. However, cancers of the oral cavity and pharynx, colon and rectum, hepato-biliary and urinary organs were positively associated with FD. This was also the case for bone cancers in male, in line with results of rat experiments. Brain tumors and T-cell system Hodgkin's disease, Non-Hodgkin lymphoma, multiple myeloma, melanoma of the skin and monocytic leukaemia were also correlated with FD. Of the 36 sites, 23 were positively significant (63.9%), 9 not significant (25.0%) and 4 negatively significant (11.1%). This may indicate a complexity of mechanisms of action of fluoride in the body, especially in view of the coexisting positive and negative correlations with the fluoridation index. The likelihood of fluoride acting as a genetic cause of cancer requires consideration.

    6. http://ntp-server.niehs.nih.gov/htdocs/Chem_Background/ExSumPdf/Aluminum.pdf

    7. McDonagh MS, Whiting PF, Wilson PM, Sutton AJ, Chestnutt I, Cooper J, Misso K, Bradley M, Treasure E, Kleijnen J., Systematic review of water fluoridation , BMJ. 2000 Oct 7;321(7265):855-9. http://bmj.com/cgi/content/full/321/7265/855?view=full&pmid=11021861

    Make your own Comment. To obtain your free copy of the Toxicological Profile for FLUORIDES, Draft Profile for Public Comment , write to

    Agency for Toxic Substances and Disease Registry,
    Division of Toxicology/Toxicology Information Branch
    1600 Clifton Rd NE, E-29
    Atlanta, GA 30333.

    You can email them at atsdric@cdc.gov

    or telephone (888) 42 ATSDR or (404) 498 0110
    or Fax (404) 498 0057

    NOTE: The Period for Comment ends February 22, 2002.



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