An abridged version of an open letter and further correspondence to Dr Harry Comber, Director, National Cancer Registry Ireland.

Cc: An Taoiseach Enda Kenny; Dr James Reilly, Minister for Health; Simon Coveney, Minister For Agriculture, Food and Fisheries; Phil Hogan, Minister for Environment, Community and Local Government; Dr Tony Holohan, Chief Medical Officer, HSE; Dr Ivan Perry, Professor of Public Health Department of Epidemiology and Public Health, University College Cork; and Laura Burke, Director General, Environmental Protection Agency.

Dear Sirs and Madam,

I am writing regarding the information provided in the National Cancer Registry Ireland (NCRI) cancer statistics maps, reported in  ‘Water fluoridation-cancer link is ‘improbable’’ (IMT, November 2, http://bit.ly/XxrgYa), in particular the comments by the NCRI and Northern Ireland Cancer Registry (NICR), as quoted “that the maps did not show a clear difference between Northern Ireland (NI) and Ireland”.

This is quite remarkable, as you are contradicting the stated findings as noted in the Cancer Atlas report, which clearly states the following regarding the results of the mapping exercise: “The risk of developing many of the cancers presented was higher in RoI than in NI. The risk of non-melanoma skin cancer, melanoma, leukaemia, bladder, pancreas and brain/central nervous system cancers was significantly higher for both sexes in RoI. For men, the risk of prostate cancer was higher in RoI and, for women, cancer of the oesophagus and cervix.” Furthermore, the report concluded that “there was a marked geographical variation in the risk of some common cancers… the most consistent geographical distribution of cancer risk was seen for three cancers (pancreas, brain/central nervous system and leukaemia), which showed an increasing gradient of risk from North-East to South-West”.

The All Ireland Cancer Atlas report documents that the risk for bladder cancer was up to 14 per cent higher in the Republic of Ireland (RoI), leukaemia up to 23 per cent, pancreatic cancer up to 22 per cent, skin cancer up to 18 per cent, prostate cancer 29 per cent, oesophageal cancer up to 8 per cent, brain cancer up to 20 per cent and cancer of the cervix and uterotis up to 11 per cent higher compared to NI.

Coincidentally, this also follows the variation in osteosarcoma, an often fatal childhood cancer for which the incidence is also known to be higher in the RoI compared to the North. The peer-reviewed journal Cancer Causes and Control published a study by Harvard University in 2006 in which it was stated that fluoride in drinking water significantly increased the risk of developing this disease in teenage boys.

More recently, in 2012, the Russian Academy of Sciences documented that toxic fluoride effects include an induction of inflammatory reactions, cell contractile responses, inhibition of protein synthesis and cell cycle progression, oxidative stress and DNA damage.

The Academy reported that fluoride has been found to alter critical physiological and pathological processes for the body’s defence and repair mechanisms, reducing the body’s antioxidative defence mechanism and impairing the ability of the body to eliminate free radicals and fight disease — all of which are clearly relevant to cancer disease.

Contrary to your claims that most of the geographic areas on the maps are not fluoridated, there are 270 water fluoridation plants located across the Republic, ensuring that the vast majority of the population are exposed to fluoride compounds in drinking water.

Furthermore, as I have previously highlighted to your offices and other State Departments, when it comes to fluoride, the single biggest factor that influences its toxicity is water chemistry — or water hardness, to be precise — followed by the chemical nature of the fluoride compound, i.e. naturally-occurring calcium fluoride or synthetic liquid-based silicofluorides, which are known to be far more toxic.

Regarding water chemistry, it has been known for decades that the softer the water, the greater the toxicity of fluoride on biological systems.

Some of the cancer maps illustrate this quite alarmingly, with the geographic regions with the softest water having the highest risk factor for many of the cancer diseases.

Interestingly, the maps also illustrate that for some of the few non-fluoridated communities in the Republic, the risk factor of developing disease is similar to that of NI, which overall is identified as predominantly the lowest risk area for developing cancer diseases throughout the 32 counties of Ireland, and is also the only geographic region where water is not fluoridated.

From the position of identifying potential risk factors that may contribute to this notable phenomenon, it is noteworthy in its absence that the influence of exposure of a population to a highly toxic chemical (hexafluorosilicic acid) and its various derivative compounds through drinking water was not included as a factor that may contribute to disease burdens. This is particularly remarkable, as the only known difference in population exposures to known environmental toxins between NI and Ireland is that the NI drinking water supply is not fluoridated.

Water chemistry plays an enormous role in disease prevalence; fluoride strongly inhibits calcium and magnesium metabolism in biological systems, and the softer the water, the greater the bioavailability of fluoride compounds in humans and animals, yet — as noted in the Waugh report on water fluoridation — this has never been examined in Ireland.

In fact, not one epidemiological study to investigate the potential human health impacts that may be associated with fluoride toxicity has ever been conducted in Ireland since fluoridation began in the 1960s. Returning to the topic of cancer incidence and fluoride, as I have highlighted to your offices in 2006, the scientific committee of the National Research Council (NRC) of the National Academy of Sciences in the US unanimously concluded that “fluoride appears to have the potential to initiate and promote cancers”.  It is extremely worrying therefore to note that while the NRC listed over 50 additional epidemiology, toxicology, clinical medicine and environmental exposure assessments required to be undertaken on fluoride, not one of these studies has ever been undertaken in Ireland — the only EU country to support mandatory fluoridation.

It is also noteworthy that three US courts have found water fluoridation to be injurious to human health, specifically that it may cause or contribute to the cause of cancer and genetic damage, while the US National Toxicology Programme in 1990 found “equivocal evidence” in animal experiments that fluoride was carcinogenic.

In addition, epidemiological studies both undertaken and resurfaced by Dr Dean Burk, former head of the Cytochemistry Section at the US National Cancer Institute, determined that fluoridation increased the incidence of cancer deaths immediately in as little as a year.

Given the lack of appropriate human health risk assessments and the complete lack of toxicological information on silicofluoride chemicals used for water fluoridation, and considering the remarkable increase in disease burden amongst the population of Ireland in recent years, it is not inconceivable that fluoride may play a significant role in the development of many diseases.

In such circumstances, it is clearly incumbent on the Government to uphold its moral and legal obligation, to comply with the ‘precautionary principle’ and to call for an immediate cessation of this policy in line with other EU Member States, thereby providing the entire population of the island of Ireland with non-fluoridated drinking water, a basic legal right provided to the remaining 98 per cent of the population of Europe.

*References available on request

Declan Waugh,
EnviroManagement Services,
Risk Management, Environmental Auditor and Environmental Consultant,
Bandon, Co Cork.

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