By Professor C. Vyvyan Howard. MB. ChB. PhD. FRCPath.

Professor Vyvyan Howard is a medically qualified toxico-pathologist and is an expert on
effects of toxic substances on the fetus and infant during the developmental period of life.
He is currently the President of the International Society of Doctors for the Environment
which is a World Health Organisation and United Nations recognised NGO representing
some 30,000 medical doctors around the world. He has served on UK Government
regulatory committees and is currently Professor of Bioimaging at the University of Ulster.

21st January 2009

1) The opinion does not address the safety of fluoride nor the amount of fluoride
that can be safely consumed, these topics being deemed to be outside the remit of
the Panel.

2) The fact that socium monofluorophosphate is being considered by a Panel that
addresses nutrient sources added to food is a tautology. By definition, if a nutrient
is withdrawn from the diet, a deficiency condition will emerge. This is the way
most of the vitamins were discovered. If fluoride is completely excluded from the
human diet no deficiency condition emerges. There is no nutritional requirement
for fluoride.

3) The Panel makes absolutely no reference to the growing literature on: IQ loss
following foetal exposure in fluoridated areas; increased osteosarcoma incidence
in young males in fluoridated areas; increased fracture rates on fluoridated areas.
It maintains that dental fluorosis is the most sensitive endpoint although the
current literature would suggest that exposure during development that is not the
case.

4) The Panel concedes that in children the potential fluoride contribution from
sodium monofluorophosphate ‘supplementation’ would cause ‘tolerable upper
intake levels to be exceeded in most cases’. This is the time of life when one is
most vulnerable to developmental toxicity from fluoride.

5) A recent paper describes the findings of a longitudinal study which has been
running for 16 years and shows that cavity free status has little to do with fluoride
intake (Warren JJ, Levy SM, Broffitt B, Cavanaugh JE, Kanellis MJ, Weber-
Gasparoni K. Considerations on Optimal Fluoride Intake Using Dental Fluorosis
and Dental Caries Outcomes – A Longitudinal Study. J Public Health Dent. 2008
ov 21 (ahead of print).

6) In conclusion the opinion stated by the Panel should not, in my opinion, be used to
argue that fluoride supplementation of food or water is safe. Exactly the opposite
appears to be the case.

In reference to: Commentary on the Scientific Opinion of the Panel on Food Additives and Nutrient Sources added to Food concerning sodium monofluorophosphate as a source of fluoride added for nutritional purposes to food supplements. Adopted on 27th November 2008.

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