NPWA's standpoint is that due consideration must be accorded to present-day requirements of scientific investigations into exposure risk assessment. Even today's epidemiology studies require more stringent criteria: "Given the issues, the next generation of drinking water epidemiologic studies should include a multidisciplinary team beyond traditional epidemiologists and statisticians. Study teams will require toxicologists, chemists, engineers and exposure assessors." (1)

Currently, international scientists and government agencies are abandoning the long-held, simplistic notions of most dental researchers that the fluoride ion exists exclusively as a "free ion" in water. Modern researchers are concerned to identify the toxicity and pharmacokinetics of minerals and substances occurring in actual drinking water, as indicated, for example, in studies by Varner, et al, who found paradoxical effects at the lower end of exposure, (2) and Aswathanarayana, who wrote: "A metabolic model involving synergism between F and As is proposed, to account for the concurrent endemicity of fluorosis and arseniasis in northern Tanzania"(3).

The standard laboratory testing methods for fluoride-related health effects are unacceptable because a pharmaceutical grade of sodium fluoride added to double distilled de-ionised water is not a suitable surrogate for artificially fluoridated water drawn from the tap.

Drinking water is artificially fluoridated with industrial (commercial) grade sodium fluorosilicate (Na₂SiF₆) or fluorosilicic acid (H₂SiF₆) of 23% purity. Virtually all chemicals used in artificial fluoridation schemes are waste by-products (fluorosilicates) derived from phosphoric acid production pollution scrubbers. These chemicals (H₂SiF₆) contain numerous contaminants, which are captured hazardous air pollutants, including arsenic, mercury, lead, phosphoric acid, sulphides, silica, etc.

Past research has never addressed the health impacts of these toxic waste products on humans or animals.

The two studies on fluorosilicate dissociation, by Urbansky and Schock,(4) and Crosby (5), suggest that the existence of the SiF₆^2- radical is dependent on the pH of the water. However, the researchers did not acknowledge that alkaline solutions of sodium fluoride etch glass. Fluoride interacts with the silica, forming an aqueous fluorosilicate in the vessel, as stated by Guy, Taves, et al: "Plasticware (Falcon Plastics) was used for all analytical procedures to avoid contamination by fluoride from glass."(6).

NB: Hydrofluororic acid, HF(aq), is the only substance that is known to readily attack glass, forming SiF₄(g) or H₂SiF₆ .

The Merck Index monograph (1996) on Sodium Fluoride states that the interaction between silica and the "fluoride ion" occurs independently of the water pH. Consequently, information on product packages states that sodium fluoride and fluoride-containing vitamin supplements should not be stored in glass. In the presence of ambient moisture the fluoride will react with the glass to form fluorosilicates.

Urbansky and Schock state: "There are many metal cations competing for the fluoride; therefore, the free fluoride available to complex with the lead (II) ion is very small. In addition, most, if not all, of the competing metal cations are in greater abundance than the lead (II) by orders of magnitude . . . That drinking water contains a substantial fraction of fluoroaluminum complexes rather than free fluoride was highlighted by Pitter [1985] as a concern because free fluoride is more effective in protecting against tooth decay." (4) Many other papers acknowledge fluoride complexing and the toxicity of fluoride complexes in drinking water. (9) (10) (11) (12) (13) (14)

Concern over the known complexing of aluminium and fluoride in drinking water has caused the United States Environmental Protection Agency and the US National Institute of Environmental Health Sciences to request the National Toxicology Program to commission long-term drinking water studies. These will address pharmacokinetics, neurotoxicity, bone development, and reproductive and developmental toxicity. Such testing will also investigate neurodegenerative disease in transgenic animal models exposed to drinking water contaminants with a high health research priority, i.e. known neurotoxicity of aluminium. The EPA and NIEHS further acknowledge the urgent need for better understanding of pharmacokinetics and toxicity of aluminium species occurring in drinking water. (2) (15).(16) (17)

Furthermore, "The potential relevance of such Al complexes derives from the observation that under slightly acidic source water conditions organic Al complexes and Al-F complexes predominate, and these can persist to a significant degree through drinking water treatment. The absorption and toxicity vary by species of Al." Note also that the effects of the fluoride ion on aluminium cookware cause leaching of aluminium at levels exceeding 100 ppm.

(http://ntp-server.niehs.nih.gov/htdocs/Chem_Background/ExSumPdf/Aluminumalt.pdf).

These acknowledgements that fluoride speciation occurs in drinking water raises serious concerns, since the bio-toxicity and bio-availability of the fluoride species is dependent upon the complex. (18).

It is essential that in determining health effects of fluoride exposures, a multidisciplinary approach be employed. This must extend beyond previous narrowly-focused studies on the fluoride ion alone.

Dr. Author Gregory in his peer reviewer comments (dated 21 May, 1992) from the Peer Review of the Toxicological Profile for Fluorides, Hydrogen Fluoride and Fluorine (1993) wrote: "The term 'fluoride' is used throughout the Profile as if it were a specific entity. It is not. The McGraw Hill Dictionary of Science and Technology defines fluoride as a compound derived from hydrofluoric acid. 'Fluoride' does not exist by itself."

In his paper, "Exposure to high fluoride concentrations in drinking water is associated with decreased birth rates" (J. of Toxicology and Environmental Health, 42:109-121, 1994), Stan C. Freni wrote: "The study results and wealth of animal data do raise the question whether public health concerns and toxicologic research should not shift their focus from fluoridated water to the potential toxicity of the total fluoride intake."

In light of all the foregoing, NPWA hereby requests the MRC to include the following recommendations in their report to Government:

1. Identify the sources of exposures to fluoride species from, e.g., environment, drinking water, medicaments, dental products, pesticide residues, foods, and airborne fluorides.

2. Determine exposures via ingestion, transdermal absorption and inhalation.

3. Conduct animal tests to determine neurological, reproductive, degenerative, renal, bone, thyroid, carcinogenic or other adverse effects, by using:

(a) The same industrial grade fluorosilicate chemicals (H₂SiF₆) as are used in artificial fluoridation schemes in typical tap water;

(b) A pharmaceutical grade of sodium fluoride and double-distilled, de-ionised water;

(c) Representative non-fluoridated, typical tap water as the control.

4. Determine the synergistic actions of fluoride with minerals and other co-contaminants in typical tap water.

5. Because the product used to fluoridate drinking water is a concoction of fluorosilicates, research is also needed to determine the presence of silica in the brain, its effects on kidneys, reproductive processes and metabolism. (19) (20) (21) (22)

I wish to emphasise that we see the issue of total fluoride intake and of fluoride speciation to be the paramount matters for further research.

Please copy to members of the Group. We welcome your comments and look forward to receiving your assurances that your work will address these concerns.

Yours faithfully,

Dr P.M. McCormick,
President.

c.c.
Lord Baldwin
Sir Richard Body, MP
Dr Sheila Gibson
Cllr E.M. Vaughan
David Hinchliffe, MP
Jimmy Wray, MP
Bill Etherington, MP
Sir Iain Chalmers
Professor Trevor Sheldon
Professor Jos Kleijnen

References:

(1) Calderon RL, The epidemiology of chemical contaminants of drinking water. Food Chem Toxicol 2000;38(1 Suppl):S13-20.

(2) Varner, J.A. et al (1998). Chronic Administration of Aluminum-Fluoride and Sodium-Fluoride to Rats in Drinking Water: Alterations in Neuronal and Cerebrovascular Integrity. Brain Research, 784, 284-298.

(3) Concurrent endemicity of fluorosis and arseniasis in the Kilimanjaro region of Northern Tanzania. Aswathanarayana, D.Sc., Adviser on Environment & Technology, Maputo.

(4) Edward T. Urbansky and Michael R. Schock; Can Fluoridation Affect Water Lead(II) Levels and Lead(II) Neurotoxicity? United States Environmental Protection Agency (EPA), Office of Research and Development, National Risk Management Research Laboratory, Water Supply and Water Resources Division, Cincinnati, Ohio 45268 USA. Undated. 2000.

(5) Crosby, N.T.; Equilibria of Fluorosilicate Solutions with Special Reference to the Fluoridation of Public Water Supplies. J. Appl. Chem., 1969, 19(4), 100.

(6) Guy WS, Taves DR, Brey WS, Organic Fluorocompounds in Human Plasma: Prevalence and Characterization, ACS symposium series, Washington, Symposium Series, No. 28 117 - 134.

(7) Especial Gas Inc., Abilene, Texas. http://www.c-f-c.com/specgas_products/fluorine.htm

(8) Ambient Water Quality Criteria for Fluoride Overview Report, Water Management Branch, Ministry of Environment, British Columbia, Canada.

(9) Brudevold F, Moreno E, Bakhos Y; Fluoride complexes in drinking water. Arch Oral Biol 1972 Aug;17(8):1155-63.

(10) Chermette, H., Martelet, C., Sandion, D., Benmalek, M., and Tousset, J.; Separation and Measurement of Traces of Fluorides in Aqueous Solutions. Anal. Chim. Acta, 1972, 59(3), 373.

(11) Review of Water Fluoridation and Fluoride Intake from Discretionary Fluoride Supplements Review for NHMRC Melbourne, 1999.

(12) Mesmer, R.E., and Baes, C.F.; Fluoride Complexes of Beryllium(lI) in Aqueous Media. Inorg. Chem., 1969, 8(3), 618.

(13) Bond, A.M., and Hefter, G.; Use of the Fluoride Ion-Selective Electrode for the Detection of Weak Fluoride Complexes. J. lnorg. Nucl. Chem., 1971, 33(2), 429.

(14) Bond, A.M., and Hefter, G.; Use of Ion-Selective Electrodes in the Evaluation of Stability Constants of Sparingly Soluble Salts. Application to the Lead(II)-Fluoride System in Aqueous Solution. Inorg. Chem., 1970, 9(5), 1021.

(15) Varner, Jenson, Horvath and Isaacson. The Abstract from Neurotoxicological Evaluation of the Chronic Administration of Aluminum Fluoride and Sodium Fluoride, Society for Neural Science, 1995.

(16) Federal Register: December 4, 2000 (Vol. 65, No. 233)] [Notices] [Pages 75727 - 75730].

(17) van der Voet, G. B., Schijns, O. &de Wolff, F. A. (1999). Fluoride enhances the effect of aluminum chloride on interconnections between aggregates of hippocampal neurons. Arch. Physiol. Biochem. 101(1): 15-21.

(18) Roholm K [1937]. Fluorine intoxication: A clinical hygiene study with a review of the literature and some experimental investigations, London, England: H.K. Lewis & Co.

(19) C.H. Kick, Et Al, Fluorine in Animal Nutrition, Ohio Agricultural Experiment Station, Bulletin 558, Nov. 1935.

(20) Candy JM, Oakley AE, Klinowski J, Carpenter TA, Perry RH, Atack JR, Perry EK, Blessed G, Fairbairn A, Edwardson JA. Aluminosilicates and senile plaque formation in Alzheimer's disease, Lancet 1986 Feb 15;1(8477):354-7.

(21) Hershey CO, Hershey LA, Varnes A, Vibhakar SD, Lavin P, Strain WH, Cerebrospinal fluid trace element content in dementia: clinical, radiologic, and pathologic correlations, Neurology 1983 Oct;33(10):1350-3.

(22) Hadfield MG, Adera T, Smith B, Fortner-Burton CA, Gibb RD, Mumaw V, Human brain tumors and exposure to metal and non-metal elements: a case-control study, J Environ Pathol Toxicol Oncol 1998;17(1):1-9.

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