On January 7, 2011, the U.S. Department of Health and Human Services (HHS) announced its recommendation to reduce the level of fluoride added to drinking water based on national survey data showing that 41% of American adolescents (ages 12-15)  now have dental fluorosis (a tooth defect caused by excess fluoride consumption during childhood). On January 13, 2011, the HHS published a Federal Register notice proposing to reduce the recommended fluoride level from the existing range of 0.7 to 1.2 parts per million (ppm) to 0.7 ppm. HHS solicited public comments on their recommendation. The Fluoride Action Network’s submission to HHS is reproduced in full below. Over 18,000 emails were sent to HHS in support of FAN’s submission.

Fluoride Action Network
February 4, 2011

To HHS and Honorable Secretary Sebelius

In response to your request for comments on the recent change in your recommended level of fluoride added to community drinking water, I respectfully submit the following points supporting the stance that a reduction in fluoride levels is not sufficient, and that the United States should follow the approach of western Europe and end water fluoridation completely:

• Fluoride is not a nutrient, nor is it essential for healthy teeth. No study has ever revealed a diseased state resulting from lack of fluoride, including dental caries. (1,2) No American is, or ever was, “fluoride deficient.”
• Using the water supply to mass medicate the population is unethical. The public water supply should not be used as a drug-delivery system without regard for an individual’s age, weight, health status, or knowledge of how fluoride will interact with other drugs they are taking. No informed consent is requested or given, and no medical follow-up is offered.
• The benefit and safety of ingested fluoride has never been proved by accepted medical standards. The HHS has failed to inform the public that there is not a single randomized controlled trial (the gold standard of medical research) that demonstrates the effectiveness of water fluoridation. (3) HHS has also failed to inform the public that the Food and Drug Administration has never studied, or approved, the safety of fluoride supplements and continues to classify all fluoride supplements as “unapproved new drugs.” (4, 5) Lastly, HHS has failed to inform the public that tooth decay rates have declined at the same general rate in all western, industrialized countries, irrespective of water fluoridation status. (6)
• Any benefits of fluoride are primarily topical, not systemic. The CDC has acknowledged this for over a decade (7). The Iowa Fluoride Study, funded by HHS, has reported little, if any, relationship between individual fluoride intake and caries experience. According to the study (the largest of its kind): “achieving a caries-free status may have relatively little to do with fluoride intake, while fluorosis is clearly more dependent on fluoride intake.” (8)
• Americans will still be over-exposed to fluoride at 0.7 ppm. According to EPA’s recent documents “it is likely that most children, even those that live in fluoridated communities, can be over-exposed to fluoride at least occasionally. (9) At present, nearly 41% of American adolescents aged 12-15 have some form of dental fluorosis (10), an outwardly visible sign of fluoride toxicity. Reducing the fluoride levels to 0.7 ppm will not remedy this problem as national statistics clearly show that dental fluorosis remains significantly elevated at 0.7 ppm. (11) Drinking water is just one source of ingested fluoride; others include foods, beverages, dental products and supplements, pesticides and pharmaceuticals. For communities that practice artificial water fluoridation, this is the easiest source of fluoride to remove.
• Infants will not be protected. Infants fed formula made with fluoridated tap water—at the reduced level of 0.7 ppm—will still receive up to 175 times more fluoride than a breast-fed infant. In their supporting documents, EPA has not calculated the risks to the bottle-fed infant. In fact, infants from birth to six months of age were completely excluded from any consideration by EPA, despite HHS’s own admission that “The period of possible risk for fluorosis in the permanent teeth…extends from about birth through 8 years of age.” (12) As the most susceptible subpopulation, the potential for long-term, irreparable damage to developing infants must be seriously considered, and should extend beyond just their teeth.
• African-American children and low-income children will not be protected. HHS’s reference (p. 2386) to the study by Sohn et al. (13) failed to mention that African-American and low-income children were found to consume significantly more total fluids and plain water, and thus receive more fluoride from drinking water, than white or higher-income children. African-Americans have been shown to have an increased risk of developing dental fluorosis, and are at higher risk for suffering from the more severe forms of this condition. (14) Despite receiving high intakes of fluoride, low-income and minority children living in fluoridated communities continue to suffer from rampant and severe dental decay (15-18)—undermining the common premise that fluoridation will prevent these problems. Additionally, low-income children have a greater risk for suffering from all forms of fluoride toxicity, as poor diet exacerbates the detrimental effects of fluoride. This is clearly, therefore, an environmental justice issue.
• HHS has failed to consider fluoride’s impact on the brain. Over 100 animal studies have observed fluoride-induced brain damage (19), 24 human studies have reported lowered IQ in children exposed to various levels of fluoride (20), and at least 6 other studies have found non-IQ neurological effects such as impaired visuo-spatial organization. (21-26) One study of 500 children in China observed reduced IQ at a water fluoride level of 1.9 ppm (27, 28) and another reported a reduction in IQ at even lower (mean=1.3 ppm) water fluoride levels. (29) HHS’s new recommendation of 0.7 ppm offers no adequate margin of safety to protect all of our children, including those with iodine deficiencies (30-32), from experiencing similar neurological damage.
• HHS has failed to consider fluoride as an endocrine disruptor. The 2006 NRC report (33) states that fluoride is an endocrine disruptor, and even at low levels can be detrimental to the thyroid gland. Pre- and post-natal babies, people with kidney disease, and above-average water drinkers (including diabetics and lactating women) are especially susceptible to the endocrine disrupting effects of fluoride in drinking water.
• HHS has failed to consider or investigate current rates of skeletal fluorosis in the U.S. According to EPA’s supporting document (34), there is a general lack of information on the prevalence of stage II skeletal fluorosis in the U.S. Yet, many of the symptoms of stage II skeletal fluorosis (e.g. sporadic pain, stiffness of the joints) are identical to arthritis (35-40), which affects at least 46 million Americans. People with renal insufficiency are known to be at an elevated risk for developing skeletal fluorosis (33), as crippling stage III skeletal fluorosis with renal deficiency has been documented in the U.S. at water fluoride levels as low as 1.7 ppm. (41) Since skeletal fluorosis in kidney patients has been detected in small case studies, it is likely that systematic studies would detect skeletal fluorosis at even lower fluoride levels.
• HHS has failed to consider fluoride as a potential carcinogen. Bassin et al. (42) reported a significantly elevated risk of osteosarcoma in boys living in fluoridated communities, and thus fluoride may be a carcinogen. Chester Douglass, who has serious conflicts-of-interest concerning fluoride research, has stated that a subsequent study will refute these findings (43), but no publication has appeared in the five years since he made this claim. As EPA has still not completed carcinogenicity testing for fluoride, HHS should not support the addition of a potential carcinogen to our drinking water.
• HHS has failed to consider fluoride as a potential carcinogen. Bassin et al. (42) reported a significantly elevated risk of osteosarcoma in boys living in fluoridated communities, and thus fluoride may be a carcinogen. Chester Douglass, who has serious conflicts-of-interest concerning fluoride research, has stated that a subsequent study will refute these findings (43), but no publication has appeared in the five years since he made this claim. As EPA has still not completed carcinogenicity testing for fluoride, HHS should not support the addition of a potential carcinogen to our drinking water. HHS has failed to consider or investigate current rates of skeletal fluorosis in the U.S. According to EPA’s supporting document (34), there is a general lack of information on the prevalence of stage II skeletal fluorosis in the U.S. Yet, many of the symptoms of stage II skeletal fluorosis (e.g. sporadic pain, stiffness of the joints) are identical to arthritis (35-40), which affects at least 46 million Americans. People with renal insufficiency are known to be at an elevated risk for developing skeletal fluorosis (33), as crippling stage III skeletal fluorosis with renal deficiency has been documented in the U.S. at water fluoride levels as low as 1.7 ppm. (41) Since skeletal fluorosis in kidney patients has been detected in small case studies, it is likely that systematic studies would detect skeletal fluorosis at even lower fluoride levels.
• HHS has failed to confirm the safety of silicofluorides. Despite being used in more than 90% of artificial water fluoridation schemes, no chronic toxicity testing of silicofluorides has ever been completed: “No short-term or subchronic exposure, chronic exposure, cytotoxicity, reproductive toxicity, teratology, carcinogenicity, or initiation/promotion studies were available” for the toxicological summary for silicofluorides, as prepared for the National Institute of Environmental Health Sciences. (44) However, recent epidemiological research has found an association between the use of silicofluoride-treated community water and increased blood lead concentrations in children (45) – a link that is consistent with recent laboratory findings. (46) HHS has failed to inform the American public that the fluoridating agent used in drinking water is a hazardous waste product from the phosphate fertilizer industry, and can be laced with arsenic and radionuclides, (47, 48) which are known carcinogens. HHS should not support the addition of a non-tested substance to our drinking water.

Most of the arguments listed above are covered in far more detail in the recently published book “The Case Against Fluoride” by Connett, Beck and Micklem (Chelsea Green, 2010). We urge director Sebelius to appoint a group of experts from HHS, who have not been involved in promoting fluoridation, to provide a fully documented scientific response to the arguments and evidence presented in this book. Were director Sebelius to do this we strongly believe that neither she nor these experts will want to see the practice of water fluoridation continue. The practice is unnecessary, unethical and hitherto the benefits have been wildly exaggerated and the risks minimized. A scientific response to this book from a HHS team would allow the public to judge the cases both for and against fluoridation on their scientific and ethical merits.

References:

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