The Recent Science, Chemistry & Ethics of Water Fluoridation

Research:
1.) National Research Council of the National Academies of Sciences, Systematic Scientific Review “Fluoride in Drinking Water,” 2006
2.) Dr. Paul Connett, Dr. James Beck, Dr. H.S. Micklem, The Case Against Fluoride, 2010
3.) Dr. Thomas Kuhn, The Structure of Scientific Revolutions, 1962
4.) Rachel Carson, Silent Spring, 1962

Abstract

En Vino Veritas, En Aqua Sanitas; In Wine, there is Truth, In Water, Health.
One may notice the word Sanitas, latin for Health, the etymological origin on the word Sanitary – that Health is intimately related to Clean Water. In the US, a chemical called Fluoride is intentionally added to the public drinking water for public health reasons, to reduce tooth decay. Several paradigm-shifting findings catalyzed my venture into the health effects of this chemical.

The first is the fact that the Center for Disease Control has found 41% of children1 have fluorosis. This is caused by ingesting too much fluoride. Further research will show that the World Health Organization defines Fluorosis as a “Water-Related Disease.”2 This disease is one of the public health implications of adding a chemical to the public drinking water.

Secondly, I found it concerning to find out that fluoride bioaccumulates3 in one’s body throughout life – in your teeth, your bones and your brain,4 yet neither the US nor the UK classify fluoride as an essential nutrient.5 So, if fluoride is not an essential nutrient, does this mean that you can be healthy without fluoride?

Thirdly, about ten potential health risks ranging from endocrine disruption6 to neurotoxicity7 to cancer8 discerned by a 2006 systematic review by the National Academy of Sciences, prompted three out of 12 members of the National Research Council to sign a “Professional Statement to End Water Fluoridation.”9

As a result, federal public health agencies reduced the “optimal” fluoride concentration promoted as “safe and effective” since the 1950s, by 42% in 2011.10

What is more is the fact that although this is a widespread public policy, there continues to be a lack of scientific consensus. For example, the Toxicologists, Biochemists and Risk Assessment Statisticians at the Environmental Protection Agency have publicly opposed water fluoridation as a policy, since at least 1998.11

This essay was written for the two hundred million American citizens who live downstream from fluoridation chemicals.12 The public has a right to know the health effects documented by recent science, and the public certainly ought to know what the 2006 NRC has concluded regarding such health effects. We need access to this information so we can have a public discussion about the ethics of risk as it relates to reverence of life.

Table of Contents

Section 1. Introduction.
I. Clean Water Essential for Health: En Aqua Sanitas, En Vivo Veritas
II. Fluoride Regulated as Pesticide, Air Pollutant, Water Contaminant,
Greenhouse Gas, & Hazardous Industrial Waste.
III. Public Water, Public Right to Know.
IV. Science Speaks for Itself: “Questions Unsettled…”

Section 2.
The Power & Nature of the Chemical Itself: Fluoride, Fluorine & Fluoridation.
I. FDA Approved Topical Use versus Non Approved Systemic Ingestion.
II. Fluoridation with Industrial By-Products.
III. Air Pollution Known to Cause Human Illness.
IV. Regulated as Hazardous Waste.
V. Contaminated Fluoridation Chemicals & Fluoride as Water Contaminant.
VI. Violation of the Safe Drinking Water Act.

Section 3.
Through a Narrow Window:
Dosage versus Concentration & Margin of Safety.

I. Dosage v. Concentration.
II. Vast Majority of Infants Exceed Minimum Adverse Dosage at “Optimal” Concentration.
III. Unknown Effect on the Individual & Uncontrollable Dosage.
IV. Inadequate Margin of Safety & The New “Optimal:” Feds Reduce Recommended Concentration.

Section 4.
The Science Itself: Recently Documented Health Effects:
The 2006 National Research Council’s Systematic Review, “Fluoride in Drinking Water.”
I. Bioaccumulation & Fluoride’s Affinity to Calcium: Dental Fluorosis, Bone Fracture & Skeletal Fluorosis.
II. Osteosarcoma: “Fluoride Appears to Initiate or Promote Cancers, Particularly of the Bone.”
III. Intelligence Quotient in Children: “It is Apparent that Fluorides have the Ability to Interfere with Brain Function.”

Section 5.
Risk, Reverence of Life & The Ethics of Water Fluoridation.
I. Over-Exposure, The Principle of Medical Consent & Dose Makes the Poison?
II. Calculated Risk & The Lack of Scientific Consensus.
III. Those Who Walk Away: Epistemic Uncertainty & Bioethics.
IV. “Legitimate Scientific Controversy,” says Chair of York Review.
V. The Other Road: Risk, Reverence of Life & The Precautionary Principle.
VI. The Notion of Balance.

Section 6. Conclusion.
I. Lack of Scientific Consensus: EPA Toxicologists versus CDC Dentists.
II. Science as Tentative: Scientific Revolution Throughout History.
III. Breaking Away from Consensus: Why Portland, Oregon Voted No in 2013.
IV. Living Downstream: “The Solution is Biological, Not Chemical.”

1 Center for Disease Control, “Prevalence and Severity of Dental Fluorosis in the United States, 1999-2004.” http://www.cdc.gov/nchs/data/databriefs/db53.htm

2 WHO, “Water-Related Diseases: Fluorosis,” http://www.who.int/water_sanitation_health/diseases/fluorosis/en/

3 World Health Organization, “Air Quality Guidelines for Europe,” 2000. Pg. 4, “The toxicity of fluorides is due to the toxicity of the fluoride ion, a direct cellular poison that binds calcium, interferes with enzymes and inhibits oxygen consumption.”
http://www.euro.who.int/__data/assets/pdf_file/0018/123075/AQG2ndEd_6_5Fluorides.PDF

4 World Health Organization, “Fluorides and Human Health,” Effect of Level of Fluoride Ingestion on Fluoride Uptake into Bones and Teeth.” http://whqlibdoc.who.int/monograph/WHO_MONO_59_%28part2%29.pdf
Also: J. Luke, “Fluoride Deposition in the Aged Human Pineal Gland,” Caries Research Vol.35, No. 2 (2001): 125–28. http://www.ncbi.nlm.nih.gov/pubmed/11275672

5 Panel on Nutrients and Allergies, Committee on the Status of Dietary Reference Values for Fluoride. European Union Commission. European Food Safety Authority Issue 11, No. 8 (Aug 2013). http://www.efsa.europa.eu/en/efsajournal/pub/3332.htm
See also: U.S. Federal Register, Volume 60, Number 249. 21 CFR, Part 101. Food and Drug Administration, “FDA Food Labeling: Reference Daily Intakes.” December 28, 1995. Last sentence of Section II: “Consistent with the vast majority of comments, FDA is adopting these values [Dietary Reference Intakes, for essential nutrients] except the value for fluoride, as explained below.” http://www.gpo.gov/fdsys/pkg/FR-1995-12-28/html/95-31197.htm

6 National Research Council, National Academies of Sciences, 2006. “Fluoride in Drinking Water: A Scientific Review of EPA’s Standards.” Available at: http://www.nap.edu/openbook.php?record_id=11571 “Fluoride is therefore an endocrine disruptor.” Pg. 266

7 Ibid. “Fluorides appear to have the ability to interfere with brain function,” Pg. 222

8 Ibid. “Fluoride appears to have the potential to initiate or promote cancer,” Pg. 336

9 Fluoride Action Network, http://fluoridealert.org/researchers/professionals-statement/

10 “EPA & DHHS Announce New Actions on Fluoride,” January, 2011. http://yosemite.epa.gov/opa/admpress.nsf/3881d73f4d4aaa0b85257359003f5348/86964af577c37ab285257811005a8417!OpenDocument

11 National Treasury Union 280, Environmental Protection Agency Union of Scientists, April 1998. http://www.nteu280.org/Issues/Fluoride/NTEU280-Fluoride.htm

12 Center for Disease Control, 200million, 74% of US population. http://www.cdc.gov/fluoridation/basics

The Recent Science, Chemistry & Ethics of Water Fluoridation

En Vino Veritas, En Aqua Sanitas; In Wine, there is Truth, In Water, Health.
One may notice the word Sanitas, latin for Health, the etymological origin on the word Sanitary – that Health is intimately related to Clean Water.  As for “Truth” it is “there for anyone to see.”1 This paper is about the health effects of a chemical. This chemical has a long history of being used as a pesticide2-4 sprayed on grapes, so pesticide residues are found in the Wine5-6 we drink. It is also regulated as an air pollutant,7-11 a water contaminant,12-3 banned by international treaty as a greenhouse gas;14 this chemical is also classified as “toxic,”15-6 “corrosive”17 hazardous industrial waste by the United Nations International Programme on Chemical Safety.15-7 What if I told you that this chemical is intentionally added into the public drinking water of 200 million Americans?18-23 When you drink this chemical, it is known to bioaccumulate in your body – your teeth and your bones,24-5 and your brain,26 yet public health authorities do not classify this chemical as an essential nutrient;27-9 rather, it is regulated as a drug for topical use, to be used on the surface of teeth30-2 yet it is not approved for systemic ingestion, to be swallowed.33-6 What if I told you the Center for Disease Control (CDC) has found 41%37 of youth have what the World Health Organization defines as a “water related disease”38 caused by ingesting too much of this chemical? It was at this point that I asked myself, having grown up in a community where the water was fluoridated; having grown up drinking fluoride in every single glass of water I drink – what are the public health implications of adding this chemical into our public drinking water?

“If we are to live so intimately with these chemicals – eating and drinking them, taking them into the very marrow our bones – we had better know something of their power and nature.”39 Today, we know health risks exist; a disease41 called fluorosis affects the teeth, our skeleton and increases bone fracture risk when we drink water with less than 4 parts per million of fluoride.42 This is the official conclusion of the 2006 National Research Council (NRC) of the National Academies of Sciences’ systematic review entitled, “Fluoride in Drinking Water.”42 Data published in this report also revealed the vast majority of infants43 exceed minimum adverse dosages of fluoride when drinking fluoridated water at the fluoride concentration recommended as “optimal” by the CDC.44 These findings catalyzed the parent of the CDC, the Department of Health & Human Services (DHHS) to reduce the “optimal” concentration by 42%.45 For decades, up to 1.2ppm was “safe and effective,”46 but now “safe and effective” is said to be 0.7ppm.47

Public Water, Public Right to Know

Since “it is the public that is being asked to assume the risks, the obligation to endure gives us the right to know.”48 This paper was written for the 200 million Americans who live downstream from fluoridation chemicals; the public has the right to know the health effects documented by recent science, and the public certainly ought to know what the 2006 NRC has concluded regarding such health effects.49

Questions Unsettled

The purpose of this essay is to allow the science to speak for itself; thus it is written de facto so as to allow the reader to determine whether recent science supports health risks because you have this authority as a rational being. As recent science will demonstrate, there is much epistemic uncertainty with safety; as the “whole situation is beset with questions for which there are at present no satisfactory answers.”50

What we do know is: “many of these questions are unsettled,” and “now we need to take a fresh look,” according to the Chairman of the 2006 NRC, Dr. John Doull, MD:

“What the committee found is that we’ve gone with the status quo regarding fluoride for many years – for too long really, and now we need to take a fresh look… In the scientific community, people tend to think this is settled, but when we looked at the studies, we found many questions are unsettled, and we have much less information than we should, considering how long this has gone on.”51

We Need To Take A Fresh Look

Beginning with the Chemical Itself, topical use of pharmaceutical grade fluoride in toothpaste is distinguished from water fluoridation, which is the systemic ingestion of fluoride industrial by-products,52 with known contaminants like lead and arsenic.53-5 Further discerned is that these by-products are otherwise fluorine air pollution56-61 known to cause human illness.62-7 Hence, this chemical is regulated as hazardous by the UN, US and EU.68 This is followed secondly by Dosage versus Concentration as it relates to Margin of Safety. This highlights the nuance between safe for all or adverse for some.

Thirdly, the Health Effects Documented by Recent Science are presented, with the 2006 NRC69 used as the arbiter of the Science Itself. First, bioaccumulation causes dental and skeletal fluorosis, increasing bone fracture. Second, since the NRC reported: “fluoride appears to initiate or promote cancers”70 and “fluorides have the ability to interfere with brain function,”71 we then go over its carcinogenicity and neurotoxicity in children.

Then, we postulate over the Ethics of Water Fluoridation: What if recent science supports the possibility of health risks? With 41% of youth diagnosed with fluorosis,72 a disease73 caused by ingesting too much fluoride, perhaps the issue lies in overexposure? Keep in mind this is a drug we otherwise have a choice to use with toothpaste or consume with a prescription; there is no choice when its in the public water. This leads to the principle of individual medical consent.74 Then, considering the WHO states on its website that “the toxicity of fluorides is due to the toxicity of the fluoride ion, a direct cellular poison,”75 we explore whether dose makes the poison? Or, is toxicity an inherent property?
Naturally, this transitions to the lack of scientific consensus: three out of 12 members of the 2006 NRC have signed a “Professional Statement to End Water Fluorid-ation.”76 Citing a “legitimate scientific controversy,”77 the Chairman of another systematic review from the UK has also signed. Perhaps epistemic uncertainty about risk warrants the precautionary principle? The Ethics section is then consummated with a question: Is it logically consistent to balance risk with reverence of life? Or, does this beg the question?

The Power and Nature of The Chemical Itself: Fluoride, Fluorine & Fluoridation
FDA Approved Topical Use vs. Non-Approved Systemic Ingestion

For most of us, when we hear fluoride, we think of toothpaste. This fluoride is distinct from water fluoridation in three respects: Food & Drug Administration (FDA) approval, purity of product, and means of consumption. Toothpaste and dentistry use FDA approved pharmaceutical grade sodium or stannous fluoride, which is regulated as a drug for topical use, on the surface of the teeth.1-3 On the back of all fluoride toothpaste, one will see words mandated by a federal drug labeling law: “Warning… if accidentally swallowed, call a poison control center right away.”4 Simple arithmetic proves the recommended “pea-size” amount of toothpaste and a glass of “optimally” fluoridated water both contain a dose of approximately 0.25mg of fluoride.5

Drinking a glass of fluoridated water and swallowing toothpaste are similar, in that both are systemic ingestion, however, systemic ingestion of fluoride is not FDA approved.6-8 When one uses fluoride toothpaste or when a dentist applies it to the surface of teeth, one is instructed to spit it out after use. This is FDA approved. On the other hand, fluoride intended for ingestion in the form of tablets prescribed by that dentist and those often distributed to children in public schools – this is not FDA approved.6-8 Nor have fluoridation chemicals – silicofluorides, ever been submitted for approval.9

  • Fluoridation with Industrial By-Products

The fluoride added to the public drinking water is an unpurified industrial by-product of the phosphate fertilizer industry.10-13 All of the fluorides used in water fluoridation: Sodium Fluoride as well as Silicofluorides like Fluorosilicic Acid or Sodium Fluorosilicate – all industrial by-products, however predominately Silicofluorides are added to our water, as only 9% of fluoridated communities ingest sodium fluoride.14

Air Pollution Known to Cause Human Illness

Fluorides are otherwise fluorine air pollution.15 Specifically, fluorine gases emitted from smokestacks, captured via water spray.16 Federal law requires mandatory reclamation17 as fluorine is known to harm ecosystems,18 farmers’ crops,19 the health of animals,20-1 and the health of humans22 “in low ambient concentrations.”23 During the Cold War, fluorine emissions were responsible for more litigation claims against uranium, phosphate, aluminum and other metal industries24 than all other regulated air pollutants combined.25-6 In 1955, a US district court in Oregon ruled for the first time that fluorine emissions from an aluminum plant caused illness to a farmer’s family, their animals and their farm.27

Regulated as Hazardous Waste

Fluorine-emitting industrial plants are also identified by published case studies as the cause of hundreds of cases of illness and dozens of deaths during “temperature inversions” in two valleys: Donora, Pennsylvania, 1948,29 and Meuse Valley, Belgium, 1930.30 Common dictionaries define fluorine as a “highly corrosive poisonous gas, the most reactive of all elements.”31 Hence, fluoride is regulated as air pollution. When this air pollution is captured in an aqueous solution, it is then regulated as hazardous materials by the UN’s International Programme on Chemical Safety,32-4 the European Union,35-7 and the US Environmental Protection Agency (EPA).38 Sodium Fluoride and Sodium Fluorosilicate are classified as “Toxic,” while Fluorosilicic Acid, “Corrosive.”32-34

Contaminated Fluoridation Chemicals & Fluoride as a Water Contaminant

Fluoride hazardous waste is also known to contain contaminants.39-41 Fluoride is thus more appropriately termed fluoridation chemicals. The CDC,39 National Sanitation Foundation40 and EPA41 cite traces of Arsenic and Lead as the primary contaminants. It should be noted that EPA has determined zero lead and arsenic as the maximum safe level in drinking water.42 This arsenic we intentionally add to our drinking water from fluoridation chemicals could potentially cause up to 4,100 cases of cancer per year.43 Moreover, there are a plethora44 of other contaminants like mercury, and radioactive chromium-6. In fact, fluoride itself is regulated by EPA as a water contaminant.45

Violation of the Safe Drinking Water Act

Community Water Fluoridation is therefore the addition of a chemical that is classified as toxic, corrosive, contaminated hazardous industrial waste to our public drinking water. Technically, this is what CDC’s Oral Health Division recommends as a “safe and effective” preventative health policy to reduce tooth decay.46 In addition, with fluoride technically a drug, we can clearly see water fluoridation violates the spirit of the Safe Drinking Water Act: “No national primary drinking water regulation may require the addition of any substance for preventative health care purposes.”47 For this reason, water fluoridation may be appropriately termed mass medication.

Through a Narrow Window:
Concentration versus Dosage & Margin of Safety

The Safe Drinking Water Act prohibits the addition of drugs to our public drinking water for two reasons. First, we do not know how an individual will respond to and therefore be affected as DHHS reports “subsets of the population may be unusually susceptible to the toxic effects of fluoride.”[i] Second, since we all drink different quantities of water, we cannot control dosage.[ii] Even if we all drink one concentration, at say 1ppm, we will nevertheless consume different dosages, since we all drink different quantities of water, for example. Consider 0.05mg/kg/day, the dosage “meant to protect against” a probable risk[iii] of dental fluorosis,4 or 0.06mg/kg/day for bone fracture,5 or 0.114mg/kg/day for crippling skeletal fluorosis. 6 These are minimum adverse dosages determined to cause health risks.

Vast Majority of Infants Exceed Minimum Adverse Dosage
at “Recommended” Concentration

This is precisely what the 2006 NRC found when infants drink water between 0.7ppm and 1.2ppm F.7 At 1.2ppm, infants consume fluoride up to 273 fold that of human breast milk and at 0.7ppm, it is 70 to 160 times greater.8 This is why the CDC issued a warning urging parents against using fluoridated water to reconstitute baby formula.9 In fact, the American Academy of Pediatrics10 and the National Institute of Health11 recommend zero fluoride, “none” for infants, as fluoride is not classified an essential nutrient.12-5
Out of the whole population, it is the infant who receives the highest dosage; compared to adults, infants consume more water per unit body weight and process i.e., excrete fluoride less efficiently and therefore absorb more than adults.16-7 There are many factors affecting dosage, namely body weight, water consumption and excretion ability,18 and if you factor sensitivity like health or nutrition into the equation; this can compound the response,19 e.g. fluoride can “exacerbate the effects of low iodine.”20 Thus, natural variation means humans drinking one concentration = many dosages, many responses.

Uncontrollable Dosage & Unknown Effect on the Individual

When a drug is in the public drinking water, we cannot control the dosage, and even if we could, we still cannot control the effect on the individual. A WHO report notes: “the principal health concern is the uncontrollable exposure to fluoride.”22 Water fluoridation inherently precludes controlling dosage, and since dosage determines the safety of a medication, we cannot control the safety of water fluoridation as a form of mass medication. Safety, therefore, is about dosage; dosage determines safety, not the concentration in water per se.

Inadequate Margin of Safety: Too Close for Comfort?

The fact that infants are consuming adverse dosages22 means the maximum dosage (infant) exceeds the minimum adverse dosage – there is no margin or “buffer zone” to protect safety. No space for comfort. This is a logical proof: the margin of safety is not only inadequate,23 but nonexistent at approximately 1ppm, the concentration recommended as “optimal” since 1945.24 Therefore, with 1ppm “adverse” for infants, DHHS reduced the “optimal” concentration by 42% in 2011, down to 0.7ppm.25 From the “adverse” 1ppm to 0.7ppm – this is a very narrow window of safety, given the issue is the risk of an adverse, i.e. a toxic dosage consumed by infants from simply drinking water. The point being: if the concentration we drink, 0.7ppm, is too close in proximity to a concentration associated with adverse risk, such as 0.9ppm for children with iodine deficiency,26 this leaves us with a logical possibility: the margin of safety may still be insufficient to protect individuals from risk.

The Science Itself: Recently Documented Health Effects
2006 National Research Council Systematic Review “Fluoride in Drinking Water”

What follows are the most significant peer-reviewed studies published on the health effects of drinking fluoride in water as well as the associated conclusions of the 2006 NRC’s systematic review of 1,100 “toxicologic, epidemiologic, and clinical data on fluoride, published since 1993.”1 Ultimately, three health risks were explicitly confirmed for water with less than 4ppm: severe dental fluorosis, bone fracture and stage II skeletal fluorosis.2

Bio-Accumulation & Fluoride’s Affinity to Calcium:
Dental Fluorosis, Bone Fracture & Skeletal Fluorosis

Fluorosis is “an abnormal condition”3 caused by excessive fluoride intake,4-6 taking three forms: Dental, Skeletal and Clinical.7 The CDC8 estimates that 41% of all adolescents in the US have dental fluorosis, predominately in its mild form, which appears as permanent opaque white spots on the teeth. 3% of all people have a moderate to severe form, marked by full discoloration to orange-brown mottling and pitting.

Given the teeth and bone are the principal sites of fluoride bioaccumulation,9 nineteen studies since 1990 have examined fluoride in water and hip fracture among the elderly, eleven of which found a positive correlation.10 The American Journal of Epidemiology11 and American Medical Journal12 recently published studies finding increased hip fracture risk, e.g. >1.5ppm.11 The WHO13 cited Li et al., 200114 as evidence of fluoride’s ability to increase bone fracture risk, and a 2001 published study reported a positive linear correlation between bone fracture and severity of dental fluorosis in both children and adults.15

Therefore, “dental fluorosis often occurs with skeletal fluorosis.”16 Skeletal fluorosis is defined as a “musculoskeletal disease”17 “characterized by pathological bone changes.”18 This disease is documented as endemic among two groups of people. First, industrial workers19-28 with occupational exposure to airborne fluoride emissions exhibit high prevalence of this disease, e.g. the United Steelworkers Union has called for an industry-wide ban on the use of hydrogen fluoride.29 Skeletal fluorosis is also endemic with high levels of naturally occurring calcium fluoride in water, studied mostly in Indian and Chinese communities.30-5 There are also recent studies published in US and EU journals.36-8 The Mayo Clinic36 for example, describes onset as “insidious” and highly susceptible to misdiagnosis because fluorosis “mimics”37 arthritis; as they are both musculoskeletal diseases with clinically identical symptoms. Fifty million Americans are diagnosed with arthritis, two-thirds of which are under age 65. Water fluoridation commenced exactly 64 years ago.

Many studies including four out of five common dictionaries I found at my local library39-47 define fluorosis as “chronic fluorine poisoning,” with dental fluorosis “the first visible sign of chronic fluoride toxicity.”48 What is more, is the fact that the WHO defines fluorosis as a disease,49 not simply a condition, and reports: “the toxicity of fluorides is due to the toxicity of the fluoride ion, a direct cellular poison that binds calcium.”50

Osteosarcoma in Children:

Fluoride Appears to Initiate or Promote Cancers, Particularly of Bone51

  • Although several studies52-4 have found null effect between water fluoridation and osteosarcoma across the whole population, several US studies55-9 found a correlation in young males. Of these four, Bassin et al, 200659 is the only one to examine prevalence in an age, sex, and exposure-specific research design. Bassin et al “quantified total fluoride intake at various stages of life preceding the onset of cancer.”60 From private wells vs. municipal water vs. bottled water, to tap water used to cook food, fluoride intake from water was quantified for each year of a boy’s life preceding his diagnosis. Results yielded a statistically significant correlation: male children who drank fluoride, during ages six to eight, were 550% more likely to develop osteosarcoma by age twenty.

The study was conducted at Harvard’s Dental School, the product of Elise Bassin’s doctoral dissertation work. When it was published, it catalyzed the EPA National Union of Scientists to publicly reaffirm their opposition to water fluoridation,61 as stated in an open letter sent to all members of Congress.62 This was seven years after the first call for an “immediate” “national moratorium,” still viewable on the EPA Union’s website, entitled “Why EPA Union of Scientists Oppose Water Fluoridation.”63

Conclusively, the 2006 NRC “was not able to rule out a carcinogenic effect of fluoride;”64 although “principles of cell biology indicate” support of carcinogenic plausibility,65 the “evidence to date is” nevertheless “tentative and mixed.”66

Intelligence Quotient in Children:
Fluoride’s Apparent Ability to Interfere with Brain Function67

In 2012, Harvard University researchers “found strong indications fluoride may adversely affect cognitive development in children,”68 based on a review of 27 studies that examined fluoride in water and children’s intelligence.69 Out of a total of 43 studies in this domain, 37 have found an inverse relationship, and in 31 of these studies, the predominant source of fluoride was water, with the other six from coal emissions.70 Thus, to date, 31 studies conducted in China,71-91 Mexico92 India93-7 and Iran98-100 associate fluoride in water to measurably lowered IQ among children.

There are also several studies on brain function recently published in US and EU journals. Two studies in the US journal Neurotoxicology link silicofluorides in water to increased uptake of lead into children’s blood assays, suggesting fluoride’s corrosive properties may leach lead from pipes.101-2 Another study found fluoride bioaccumulation in the brain, in the calcifying tissues of the human pineal gland.103 In addition, neurotoxic effects are documented in rats at levels equivalent to humans drinking 5 to 10ppm104 and 2.5ppm,105 both of which appear in the US journal, Neurotoxicology & Teratology. The former104 of which, also found fluoride in the hippocampus, the section associated with memory while another study, published in the US journal Brain Research reported fluoride increased aluminum uptake into the brains of rats, forming deposits linked to Alzheimer’s.106 Such results are replicated in many studies, the majority published outside the US.107-18

Lastly, to end on two reviews. “Chronic exposure to fluoride may be associated with cerebral impairment affecting particularly concentration and memory,” concluded a review in the US journal International Clinical Psychopharmacology.119 In 2014, fluoride was named among several newly confirmed “developmental neurotoxins” in a review conducted by Harvard researchers, published in the Lancet,120 the oldest, most prestigious medical journal in the UK.

Risk, Reverence of Life & The Ethics of Water Fluoridation

Over-Exposure, Individual Medical Consent & Dose Makes the Poison?

“Life,” Rachel Carson focused Silent Spring, “is a miracle beyond comprehension; we should reverence it.”1 What Reverence of Life is reflected in the fact that the CDC – the federal agency which promotes fluoridation, has found 41% of youth2 have what the WHO has defined as a disease3 caused by ingesting too much fluoride in the water? Two out of every five adolescents are diagnosed with fluorosis. The paramount issue is: we know “the first visible sign of chronic toxicity” is dental fluorosis.4 Therefore, public health implications are not about dosage, concentration, or science; it is the fact that our children are overexposed to a drug we otherwise would have a choice to use with toothpaste or consume with a prescription. Where is individual medical consent with fluoridation?

Fluoride medication in the form of tablets, are behind the counter at the pharmacy.5 The Greek origin of pharmacy – pharmacon – has a dual meaning: one substance, at the right dose, a medicine, at too high a dose, a poison. “As Paracelsus once wrote, ‘the right dose differentiates a remedy from a poison.’”6 This is true of essential nutrients, for instance but undoubtedly, it is false for “chemicals totally outside the limits of biologic life;”7 no dose of lead or arsenic is benign, nonetheless a remedy.8-9 Thus, for poisons per se, “toxicity is an inherent quality of the chemical itself.”10

“The toxicity of fluorides is due to the toxicity of the fluoride ion, a direct cellular poison” – this sentence appears on the WHO’s website.11 Whether lethal or non-lethal, too high a dose at one time causes acute poisoning, like swallowing toothpaste. On the other hand, chronic poisoning is non-lethal doses over a period of time. Ponder the mathematical proof mentioned earlier: pea-size toothpaste, a glass of fluoridated water – both, 0.25mg F.12 A federal law13 based in toxicology recommends you call poison control if you systemically ingest that toothpaste. Another federal policy14 based in dentistry, which treats oral health primarily on a topical basis, recommends you systemically ingest, in every glass of water you drink, for your entire lifetime, precisely the dose of fluoride the federal health law explicitly implies causes acute poisoning. How is water fluoridation not chronic poisoning? How can a Toxic Poison be Safe & Healthy? For everyone? For a lifetime?

Probably Safer & Healthier to Simply Drink Just Water:

Calculated Risk & The Lack of Scientific Consensus

Three out of twelve members of the 2006 NRC have signed Fluoride Action Network’s “Professional Statement to End Water Fluoridation.”15 One member of the NRC, Dr. Kathleen Thiessen, a Senior Risk Analysis Scientist, joins Dr. William Marcus, former Chief Risk Assessment Toxicologist at EPA’s Office of Water.16 To date, the most avidly and publicly outspoken scientists against water fluoridation have been the Toxicologists, Biochemists, and Risk Assessment Statisticians at the Environmental Protection Agency.17
Scientific opposition also extends to the dental profession. A second member of the NRC, Dr. Hardy Limeback, past president of the Canadian Association for Dental Research joins Dr. John Colquhoun, a former Chief Dental Officer in New Zealand – two former proponents who have since reversed their position.18 In addition, a Dr. David Kennedy of the International Academy of Oral Medicine & Toxicology has also signed.19
Lastly, Dr. Robert Isaacson, the third member of the NRC, is a Neuroscientist.20 Perhaps the most preeminent name on the list is a Pharmacologist, Dr. Arvid Carlsson, the 2000 Nobel Laureate in Physiology & Medicine.21 Logically, it is dissent from scientists in precisely these fields, which makes one question any claim about scientific “consensus.”

These are the ones Who Walk Away From Omelas,22 an allegory representing the inherent conflict between the utilitarian ideal of the greatest good for the greatest number and the deontological right of the individual, which in this case, is the principle of medical consent, freedom of choice, and freedom from an obligation to endure risk.

Those Who Walk Away: Epistemic Uncertainty & Bioethics

Omelas is the quintessential Utopia, albeit, with one caveat: it depends on the eternal suffering of a young boy, locked in a broom closet, with nothing beyond a paucity of food with fluoride pesticides residues and fluoridated water for subsistence. Everyone knows of the compromise; if the boy is loved or freed, the Utopia ceases. Those who walk away choose to do so as they are unable to justify sacrificing an Individual’s Health – their access to the Good Life, in exchange for their own. Fluoridation would be utopic if it effectively cured our cavities, but is it safe?
Dr. Colquhoun posed the ethical dilemma succinctly: “How many cavities would have to be prevented to justify the death of one man from osteosarcoma?” What reverence of life is posited in the justification of uncertain, perhaps seemingly small risks? One in a million? 200 million people + 550% possibility = 200 boys.23 If the Chair of the 2006 NRC says “questions are unsettled”24 after 69 years of water fluoridation, is anyone in a position to make truth claims about the magnitude of risk?

“The nature of uncertainties in the existing data could also be viewed as supporting a greater precaution regarding the potential risk to humans.”25 This was the conclusion of the NRC regarding fluoride and its statistically significant link to bone cancer in young boys.

Legitimate Scientific Controversy26

Three members of the 2006 NRC along with the Chair of another systematic review, Dr. Trevor Sheldon from the UK National Health Centre for Reviews and Dissemination all signed the “Professional Statement to End Water Fluoridation.”27 Why? Simply, because they are uncertain whether fluoride is safe for public health. Dr. Sheldon clarifies in an open letter: “until high quality studies are undertaken providing more definite evidence, there will continue to be a legitimate scientific controversy over the likely effects and costs of water fluoridation.”26 These scientists choose public opposition because they are unable to justify the possible risk to individual life, even if it may be for the greater good.

The Other Road: Risk, Reverence of Life & The Precautionary Principle

If the National Research Council of the National Academies of Sciences is “uncertain” about the “potential risk” of fluoride as a carcinogen to children, why should the public give fluoride the benefit of the doubt? We therefore find ourselves at an ethical juncture as it relates to Risk & Reverence of Life. One Road is to presume safety until we are certain studies have proven risk through finding harm. This is tantamount to the assumption that chemicals are innocent until proven guilty. Hence, we must wait for the public – us, to be harmed? At this point, is it reasonable to simply turn the knob off at the water treatment plant, to drink just water until we are 100% certain of safety?
This is the Other Road: to abide by the Precautionary Principle; in the presence of a preponderance of evidence to support the notion that water fluoridation may cause a risk of harm to public health, and in the absence of counter-evidence to warrant safety, the action to be taken is therefore twofold: we walk down the only road we know is safe: just drink water – clean water, then concomitantly ask for further research. Precaution is proactive; the public shouldn’t have to wait to be harmed, to prove fluoride guilty.

The Notion of Balance

“The conventional view that the ethical dilemmas posed by water fluoridation can be solved by balancing the benefits and harms actually begs the question, for it presumes such a balance can be achieved.”28 Is it logically consistent to view safety as an issue of concentration? Doesn’t this presume we can balance risk with reverence of life? This is akin to the policy of “tolerance” with pesticide residues. Even if fluoride is safe for most people, evidence supports fluoride may be harmful to infants and children, in particular. What about the possibility of risking an Individual’s Health – their access to the Good Life?

Reiterated, “How can it be ethical to be putting industrial waste in our drinking water?”29 Is it right to dose an infant with a chemical we know is not an essential nutrient,30 for a lifetime, through the public water, without consent? Can we justify this, knowing the vast majority will likely consume too much from drinking fluoridated water?31 Then, children brush with F toothpaste, twice a day, every day…32 and then eat insecticide on foods.33-9 6.8ppm in grape juice.36 A kiwi – 15ppm.40 No wonder two in five kids show the visible sign of over-exposure on their teeth.41 Why shouldn’t we add fluoride to the water? That is the question.

The Conclusion Speaks for Itself: Res Ipsa Loquitur
Clean Water Essential for Health; En Aqua Sanitas

After taking a fresh look at the recent science, chemistry and ethics of water fluoridation, would you consider fluoridated water, clean water? What of the public health implications? If we ask the Chairmen of recent systematic reviews, combined they say “questions are unsettled”1 due to a “legitimate scientific controversy…”2 after 69 years of water fluoridation.

The Lack of Scientific Consensus: EPA Toxicologists versus CDC Dentists

Consider both sides. The toxicologists, biochemists and statisticians at EPA report health risks are imminent: “Our opposition to drinking water fluoridation has grown, based on the scientific literature documenting… chronic toxic hazards of cancer… We looked at the cancer data with alarm… other incriminating cancer data.”3 This position statement is derived from expertise is the field of toxic chemical public health risk assessment. Notably, these scientists who publicly oppose water fluoridation – their job is to analyze the public health implications of science, to protect the public from the industries and entities who pollute our environment at our peril. On the other hand, dentists from the CDC, whose expertise pertains to the oral health of teeth and gums, who have publicly promoted this policy for half a century, report: “No credible evidence”4 links fluoride to cancer.
We find this sort of discrepancy between authorities from two vastly different domains, is akin to the case of DDT, as reported in Silent Spring:

“The citizen who wishes to make a fair judgment of the question
of wildlife loss is today confronted with a dilemma.
On the one hand, conservationists and many wildlife biologists assert that the losses have been severe and in some cases catastrophic.
On the other hand, the control agencies tend to deny flatly and categorically that such losses have occurred, or that they are of any importance if they have.
Which view are we to accept?”5
“The professional wildlife biologist on the scene is certainly best qualified
to discover and interpret wildlife loss.
The entomologists, whose specialty is insects, is not so qualified by training
and is not psychologically disposed to look for undesirable side effects
of his control programs.”6
“In spite of the assurances of the insecticide people
that their sprays were ‘harmless to birds,’
the robins were really dying of insecticidal poisoning.”7
“From all over the world come echoes of the peril facing birds.
The reports differ in detail, but always repeat the theme of death to wildlife
in the wake of pesticides.”8
“Yet it is the control men in state and federal governments
and of course the chemical manufacturers
who steadfastly deny the facts reported by the biologists
and declare they see little evidence of harm to wildlife.”9

The Paradigm Shift

At one point in time, the Principal Dental Officer of New Zealand, Dr. John Colquhoun, a self proclaimed former “fierce advocate” of fluoridation was asked to conduct a systematic review of fluoridation studies worldwide. The result, his essay: “Why I Changed My Mind on Water Fluoridation,”10 notes his PhD dissertation11 about water fluoridation was based on Thomas Kuhn’s The Structure of Scientific Revolutions,12 the book that coined the term “paradigm shift.” He found the history of science has a structure: “Normal Science” is bound by loyalty to a certain paradigm, a “worldview” inherited ideologically as a tradition by the previous generation, but “when the profession can no longer evade anomalies that subvert the existing tradition of scientific practice then begin the extraordinary investigations”13 that lead to the paradigm shift and ultimately “a scientific revolution, together with the controversies that almost always accompany them.”14

“Science has included bodies of belief quite incompatible with the ones we hold today.”15 This attests to a core tenet of science, according to Sir Karl Popper: that it is tentative, not absolute. At one point in history, “scientific” empirical observation reinforced the Ptolemaic geocentric model as the Truth, until Copernicus’ heliocentric model proved the Sun, the center of the universe. Galileo, who publicly embraced the Sun, rather than the Earth, as our center, was persecuted as a heretic by a trial of the educated elite. Today, we know that Truth does not revolve around our paradigms.

Historically, “Truth,” according to Schopenhauer, “goes through three stages. First, it is ridiculed. Second, it is violently opposed. Third, it is accepted as self-evident.” Any novel claim, whether truthful or otherwise, if contrary to the worldview of the consensus, will be resisted. Einstein said: “Consensus is abhorred by the genius because when it is reached, thinking stops.” “Historically, the claim of consensus is the first refuge to avoid debate by claiming the matter is already settled… The greatest scientists in history are great precisely because they broke with the consensus.”16

Breaking Away from Consensus: Why Portland, Oregon Voted No

Like Copernicus and Galileo, Silent Spring broke the consensus, causing a revolution. When it was published in 1962, Time magazine wrote a book review, entitled “Pesticides: The Price for Progress.”17 Rachel Carson’s “emotional and inaccurate outburst” was regarded as “hysterically over-empathetic.” DDT, then “so universally used [it took] on the harmless aspect of the familiar”18 was banned ten years later.19 Likewise, the last major city with fluoride-free drinking water broke with the consensus in 2013. Six months after Portland voted No,20 Harvard researchers published a review in The Lancet confirming fluoride a neurotoxin.21

As a whole, the No vote likely reflects a preference for choice, i.e. to use fluoride topically with toothpaste or consume systemically with a prescription. Thus, the principle of individual consent is fundamental to the debate22 because fluoride is a drug.23 Adding contaminated24-8 industrial waste,29-30 regulated as hazardous31-4 for its corrosive31 and toxic properties32-3 into the public drinking water to treat dental decay is mass medication, technically. Moreover, when we drink this drug, this is not FDA approved35-8 because, when its in the water, dosage is uncontrollable, so safety is uncontrollable. This is why the Safe Drinking Water Act prohibits adding drugs to the public drinking water.39

With 41% of youth diagnosed with fluorosis,40 it is evident from all the sources of fluoride how children consume too much. The vast majority of infants exceed safe dosages of fluoride from water alone,41 and then go on to ingest fluoride from toothpaste42 twice a day, every day, after eating all sorts of foods laced with fluoride pesticide residues.43 When authorities reduced the “optimal” concentration, recommended for over half a century, by 42% in 2011,44 this tacitly acknowledged an inadequate margin of safety with water fluoridation.
Portland also could “not evade the anomalies” in the science itself. The 2006 NRC explicitly confirmed fluorosis as a real health risk – this is a disease affecting the teeth and skeleton, and it makes the bones more susceptible to fracture.45 Implicitly confirmed is a possible risk of cancer,46 neurotoxicity,47 endocrine,48 thyroid49 and immune system50 disruption, Down’s syndrome,51 compounded risks to people with diabetes52 and kidney dysfunction.53 Perhaps the lack of scientific consensus about safety54 is due to epistemic uncertainty about risk, which may warrant precaution? The ethics of water fluoridation therefore beckons many questions about whether we can balance risk with reverence of life by simply adjusting the concentration.
“The balance of nature is not a status quo”55 – this is the conclusion put forth by Rachel Carson after presenting the recent science on DDT, in Silent Spring.
“We have gone with the status quo for too long”56 – this is the conclusion of the Chair of the 2006 NRC’s review of the recent science on “Fluoride in Drinking Water.”
Fluorosis is typical, but is it natural for 41% of children57 to have a disease58 caused by ingesting too much of a chemical we intentionally add to the public drinking water? Water fluoridation may be effective for the teeth, but is it safe for the body?

The Solution is Biological, Not Chemical”59

Although “many people believe [fluoride] is harmless since so many do not feel any immediate effect,”60 the conclusion of Silent Spring is cautionary: the “consequence” of ingesting non-essential61 chemicals that permanently bio-accumulate within our body,62 for a lifetime, “may be remote in time and place.”63 “That there are no immediate symptoms [therefore] is of little consequence, for the toxins may sleep long in the body, to become manifest years later in an obscure disorder impossible to trace to its origins.”64
Conclusively, this essay was an attempt to reconcile the following points in the water fluoridation debate. Firstly, the presence of lead, arsenic and other contaminants inherently precludes safety. Regarding fluoride itself, the pattern of results indicates health risks to the greater population, so this possibility invalidates the notion that the greater good justifies violating individual medical consent, a principle based unambiguously in deontological, universal reasoning. The most significant conclusion however is: one can justify ending water fluoridation on utilitarian grounds, and there is consequentialist reasoning behind the uncertainty of risk – the premise of the precautionary principle.

BIBLIOGRAPHY

INTRODUCTION

1.) Rachel Carson, Silent Spring, 1962. Boston, MA: Houghton Mifflin. Pg. 25.

2.) Environmental Protection Agency Pesticide Registration Review, ‘EPA Proposes to Withdraw Sulfuryl Fluoride Tolerances.’ http://www.epa.gov/pesticides/sulfuryl-fluoride/evaluations.html

3.) Pesticides on All Sorts of Foods. U.S. Department of Agriculture, “USDA National Fluoride Database of Selected Beverages and Foods,” 2004. Prepared by Nutrient Data Laboratory, Beltsville Human Nutrition Research Center, Agricultural Research Service, USDA; in collaboration with University of Minnesota, Nutrition Coordinating Center; University of Iowa, College of Dentistry; Virginia Polytechnic Institute and State University, Food Analysis Laboratory Control Center; National Agricultural Statistics Service, CSREES, USDA; and Food Composition Laboratory, Beltsville Human Nutrition Research Center, Agricultural Research Service. See: https://library.villanova.edu/Find/Record/817953/Details
See also: Federal Register Volume 67, Number 79 (Wednesday, April 24, 2002), Environmental Protection Agency, “Notice of Filing a Pesticide Petition to Establish a Tolerance for a Certain Pesticide Chemical in or on Food.” E.g., Fluoride Pesticide Residue Tolerance: 10ppm on Apricots, 15ppm on Kiwi, Up to 35ppm on Kale. http://www.gpo.gov/fdsys/pkg/FR-2002-04-24/html/02-9655.htm

4.) Fluorine in Agriculture, 1995. Edited by R. Banks, University of Manchester. Pg. 3, Shell trademarked a fluoride based insecticide and rodenticide. Dow has trademarked a fluoride based herbicide, and DuPont, fluoride fungicide. Google eBook.
5.) A. Burghstahler, “Fluoride in California Wines and Raisins,” Fluoride Vol. 30, No.3 (1997): 142-46. “Water-extractable F content of five brands of California raisins varied from 0.83 to 5.2 ppm (mean 2.71ppm). Elevated F levels in these wines and raisins appear to result from the pesticide use of cryolite (Na3AfF6) in the vineyards.”

6.) G. Ostrom, “Cryolite on Grapes/Fluoride in Wines—A Guide for Growers and Vintners to Determine Optimum Cryolite Applications on Grapevines,” CATI Viticulture and Enology Research Center, California State University, Fresno, published by the California Agricultural Technology Institute, CATI Publication #960601, June, 1996.

7.) D.F. Walters, “Regulatory, Economic, and Legal Aspects of Fluoride” presented at a conference, held at Utah State University in 1982, published in Fluorides: Effects on Vegetation, Animals and Humans (Salt Lake City, UT: Paragon Press, 1983). Authors: H.B. Peterson, N.C. Leone, Edited by: J.L. Shupe. Pg. 351-358, Fluoride is classified as a “welfare pollutant” under the Clean Air Act.
8.) U.S. Agency for Toxic Substances and Disease Registry, ‘Fluorides, Hydrogen Fluoride and Fluorine,’ Section 8: Regulations and Advisories. ‘Acute duration inhalation MRL of 0.01ppm has been derived for fluorine.’ http://www.atsdr.cdc.gov/toxprofiles/tp11-c8.pdf
9.) National Service Center for Environmental Publications. EPA document from December 1976: ‘Fluorine, Its Compounds and Air Pollution: Bibliography with Abstracts.’ Online. Go to Google.com, type in ‘fluorine EPA air pollutant,’ click on nepis.epa.gov link.
10.) EPA, National Research Council, Committee on Acute Exposure Guideline Levels, Committee on Toxicology, Environmental Criteria and Assessment Office. ‘Summary Review of Health Effects Associated with Hydrogen Fluoride and Related Compounds,’ Google eBook.
11.) EPA, ‘Fluorine, Its Compounds and Air Pollution: Bibliography and Abstracts,’ from the Office of Air Quality Planning and Standards, 1976. Google eBook.

12.) Environmental Protection Agency, List of Maximum Contaminant Levels in drinking water. http://water.epa.gov/drink/contaminants/upload/mcl-2.pdf

13.) United States Government Printing Office. Federal Register Volume 62, Number 234, Friday, December 5, 1997. 40 CFR Part 180. Environmental Protection Agency: ‘Fluorine Compounds; Time Limited Pesticide Tolerance.’ Pg. 64297, C. Exposures and Risks, Section 2, Part ii: ‘Fluoride levels in public drinking water are regulated under the Safe Drinking Water Act. EPA has established a Maximum Concentration Limit (MCL) at 4.0 mg/L 0.114 mg/ kg/day to protect against crippling skeletal fluorosis (April 2, 1986) (51 FR 11396).’ http://www.gpo.gov/fdsys/pkg/FR-1997-12-05/html/97-31920.htm

14.) United Nations Environment Program, Ozone Secretariat. Montreal Protocol. http://ozone.unep.org/new_site/en/montreal_protocol.php

15.) U.N. International Programme on Chemical Safety and European Commission classify Sodium Fluoride as Hazardous Waste: UN Hazard Class: 6.1 – Toxic substance. EC Classification: Symbol: T – Toxic substance. http://www.inchem.org/documents/icsc/icsc/eics0951.htm

16.) Ibid., Sodium Fluorosilicate as Hazardous Waste: UN Hazard Class: 6.1 – Toxic substance. EC Classification: Symbol: T – Toxic substance. Labeling: “Signal: Danger, Toxic if swallowed [skull and crossbones symbol].” http://www.inchem.org/documents/icsc/icsc/eics1243.htm

17.) Ibid. Fluorosilicic Acid as Hazardous Waste: UN Class 8 – Corrosive substance. EC Classification: Symbol: C – Corrosive substance Disposal: “Do NOT let this chemical enter the environment.” http://www.inchem.org/documents/icsc/icsc/eics1233.htm
See also: Environmental Protection Agency, Classifications of Hydrofluorosilicic Acid, Sodium Fluorosilicate, Sodium Fluoride: all fluorides are CERCLA Waste Substances from Superfund Sites: ‘severely harmful to human health and the environment.’ www.epa.gov/osweroe1/docs/er/302table01.pdf.
18.) National Research Council of the National Academy of Sciences, ‘Fluoride in Drinking Water,’ 2006. Washington DC, National Academies Press. Pg. 15, “The most commonly used [drinking water] additives are silicofluorides, not the fluoride salts used in dental products (such as sodium fluoride and stannous fluoride). Silicofluorides are one of the by-products from the manufacture of phosphate fertilizers.” http://www.nap.edu/catalog.php?record_id=11571

19.) Thomas G. Reeves, P.E., National Fluoridation Engineer, Program Services Branch Division of Oral Health, National Center for Chronic Disease Prevention and Health Promotion, Center for Disease Control and Prevention. Refer: FL-143, September 2000. “All of the fluoride chemicals used in the U.S. for water fluoridation, sodium fluoride, sodium fluorosilicate, and fluorosilicic acid, are useful byproducts of the phosphate fertilizer industry… These gases are captured by product recovery units (scrubbers) and condensed into 23% fluorosilicic acid. Sodium fluoride and sodium fluorosilicate are made from this acid.”

20.) Center for Disease Control. “Engineering Fact Sheet.” Click on ‘Types and Sources of Fluoride Additives.’ http://www.cdc.gov/fluoridation/fact_sheets/engineering/wfadditives.htm#2

21.) Petition to Environmental Protection Agency Administer Robert Perciasepe, from Dr. William Hirzy, on behalf of co-petitioners. Request for EPA to prohibit silicofluorides and unpurified sodium fluoride as fluoridating agents due to arsenic contamination; Request to mandate pharmaceutical grade sodium fluoride. April 22, 2013. Pg. 2, and 17. http://www2.epa.gov/aboutepa/hfsa-section-21-petition

22.) Department of Health and Human Services, PHS, CDC, ‘ National Center of Prevention Services, Division of Oral Health, 1993. Fluoridation Census (1992). Table VI, page xviii.
23.) Center for Disease Control, 200million, 74% http://www.cdc.gov/fluoridation/basics/

24.) H. Hodge, “Safety Factors in Water Fluoridation Based on the Toxicology of Fluorides,” The Proceedings of the Nutrition Society American Academy of Pediatrics Policy Statement American Academy of Pediatrics Policy Statement Vol. 22 (1963): 111-7http://journals.cambridge.org/action/displayFulltext?type=1&fid=784060&jid=PNS&volumeId=22&issueId=01&aid=784052

25.) Handbook of Nutritionally Essential Mineral Elements, 1997. Edited by B. O’Dell, R. Sunde. New York: Marcel Dekker Inc. Pg., 587, ‘At least 95% of total fluoride is found in bones and teeth.’ Note: Pg. 593, ‘Fluoride can only be classified as an essential nutrient if a broad definition is used.’ Google eBook.

26.) J. Luke, “Fluoride Deposition in the Aged Human Pineal Gland,” Caries Research Vol.35, No. 2 (2001): 125–28.
27.) European Union Panel on Dietetic Products, Nutrients and Allergies, Affiliated with the European Food Safety Authority, Scientific Committee on the Status of Dietary Reference Values for Fluoride. Requested by European Commission. EFSA Journal. Issue 11, No. 8 (Aug 2013). Pg. 3332. ‘Fluoride is not an essential nutrient.’ This sentence is viewable online: http://www.efsa.europa.eu/en/efsajournal/pub/3332.htm

28.) U.S. Federal Register, Volume 60, Number 249. Rules and Regulations, 21 CFR, Part 101. Docket NO. 90N-0134, RIN 0910-AA19. Department of Health and Human Services, Food and Drug Administration, “FDA Food Labeling: Reference Daily Intakes.” December 28, 1995. Last sentence of Section II: “Consistent with the vast majority of comments, FDA is adopting these values [Daily Values, i.e. Dietary Reference Intakes, for essential nutrients] except the value for fluoride, as explained below.”

See also: National Institute of Health’s “MedlinePlus Medical Encyclopedia.” Note: “Recommended Daily Dietary Intake of fluoride” is a distinct term from “Recommended Daily Allowance,” used with essential nutrients like calcium.   http://www.nlm.nih.gov/medlineplus/ency/article/002420.htm
29.) Letter by Dr. Bruce Albert, president of the National Academy of Sciences, and Dr. Kenneth Shine, president of the Institute of Medicine, to Dr. Albert W. Burgstahler and other scientists, November 20, 1998. “Contradictory results do not justify a classification of fluoride as an essential element, according to accepted standards. Nonetheless, because of its valuable effect on dental health, fluoride is a beneficial element for humans.’
See also: B.A. Burt, ‘The Changing Patterns of Systemic Fluoride Intake.’ Journal of Dental Research, Vol. 71, No. 5 (May 1992). Pg. 1228-1237. ‘Fluoride is not an essential nutrient due to a lack of studies.’

30.) Food and Drug Administration, “FDA Approved Drug Products Database.” http://www.accessdata.fda.gov/scripts/cder/drugsatfda/index.cfm Colgate total fluoride toothpaste was approved July 1997. Injectable sodium fluoride “fluorine f-18” was approved in 1972 – discontinued. Injectable “sodium fluoride f-18” was approved January, 2011 – discontinued. Then again, injectable “sodium fluoride f-18” was approved for two manufacturers, one in December 2012, the other June 2013.
31.) Canadian National Association of Pharmacy Regulatory Authorities. Search the National Drug Schedules for “sodium fluoride” or “fluoride and its salts.” http://www.napra.org/

32.) Letter to Honorable Ken Calvert, Chairman, Subcommittee on Energy and Environment, Committee on Science, US House of Representatives, regarding FDA’s response to a Congressional Investigation about fluoride and fluoridation, from Melinda K. Plaisier, FDA Associate Commissioner for Legislation. December 21, 2000. “Fluoride, when used in the diagnosis, cure, mitigation, or prevention, of disease in man or animal, is a drug that is subject to FDA regulation […] Several NDAs [New Drug Applications] have been approved for fluoride topical products such as dentrifices and gels.” http://www.keepersofthewell.org/gov_resp_pdfs/fda_response.pdf

33.) Letter to Commissioner Jane Henry, Food and Drug Administration, from John Kelly, New Jersey Assemblyman, 36th district, October 26, 2000. “I am petitioning the FDA to remove unapproved children’s fluoride supplements from the market… I filed a Freedom of Information Act request with the FDA to obtain copies of the studies the FDA had used in evaluating the safety and effectiveness of these products. I was shocked when the FDA informed me that the FDA had no such studies and that children’s fluoride supplements were not approved…. The last time the FDA reviewed an NDA for fluoride supplements was in 1975 and that NDA was rejected.”

34.) Citation #32: Letter to Honorable Ken Calvert, from Melinda K. Plaisier, Food & Drug Administration. “No New Drug Applications have been approved for fluoride drugs meant for ingestion… Fluoride products meant for ingestion were in use prior to the enactment [of the Kefauver-Harris Amendments (Drug Amendments of 1962) to the Food, Drug and Cosmetic Act [of 1938], in which efficacy in addition to safety became a requirement for drugs marketed in the U.S.”
See also: Approved Drug Products and Legal Requirements, Volume III of USP Dispensing Information, US Pharmacopeial Convention, 2004. 24th Edition. Tauton, MA: Quebecor World. ISBN 1-56363-465-1. Pg. III/1, “The Federal Food, Drug and Cosmetic Act of 1938 require that drugs be shown to meet certain safety requirements prior to their being marketed. Drugs that were already being marketed at that time were ‘grandfathered,’ and were allowed to remain on the market without further regulatory approval… The following listing identifies drug products that we believe were considered ‘pre-1938’ or ‘grandfathered’… Sodium Fluoride (Solution, Oral + Tablets).”

35.) Food and Drug Administration, “FDA Approved Drug Products Database.” Online. http://www.accessdata.fda.gov/scripts/cder/drugsatfda/index.cfm One will note there are no systemic approvals. See also: National Institute of Health’s “DailyMed Current Medication Information” Database of Currently Marketed Drugs, including whether or not a drug is FDA approved. http://dailymed.nlm.nih.gov/dailymed/search.cfm?startswith=fluoride&x=0&y=0

36.) D.W. Cross, R.J. Carton, “Fluoridation: A Violation of Medical Ethics and Human Rights,” International Journal of Occupational Environmental Health Vol.9, No. 1 (Jan-March 2003): 24-9. “Silicofluorides have never been submitted to the US FDA for approval as medications.”

37.) Center for Disease Control, “Prevalence and Severity of Dental Fluorosis in the United States, 1999-2004.” http://www.cdc.gov/nchs/data/databriefs/db53.htm#summary

38.) World Health Organization, ‘Water-related diseases: Fluorosis.’ Online. ‘Ingestion of excess fluoride, most commonly in drinking-water, can cause fluorosis which affects the teeth and bones.’ http://www.who.int/water_sanitation_health/diseases/fluorosis/en/

39.) Rachel Carson, Silent Spring, 1962. Boston, MA: Houghton Mifflin. Pg. 25.

40.) Ibid. Silent Spring, Pg. 28.

41.) National Academy of Sciences, National Research Council, ‘Fluoride in Drinking Water: A Scientific Review of EPA’s Standards.’ Washington, DC: National Academies Press, 2006. Pg. 170-71: “excessive intake of fluoride will manifest itself in a musculoskeletal disease with a high morbidity” i.e. skeletal fluorosis. http://www.nap.edu/openbook.php?record_id=11571 *This citation referred to herein, as NRC, ‘Fluoride in Drinking Water,’ 2006.
See also: World Health Organization, ‘Water-related diseases: Fluorosis.’ ‘Ingestion of excess fluoride, most commonly in drinking-water, can cause fluorosis which affects the teeth and bones.’ http://www.who.int/water_sanitation_health/diseases/fluorosis/en/

42.) Ibid. NRC, ‘Fluoride in Drinking Water,’ 2006. Pg. 2-3, “After reviewing the collective evidence, including studies conducted since the early 1990s, the committee concluded unanimously that the present MCLG of 4mg/L for fluoride should be lowered. Exposure at the MCLG clearly puts children at risk of developing severe enamel fluorosis, a condition that is associated with enamel loss and pitting. In addition, the majority of the committee concluded that the MCLG is not likely to be protective against bone fractures.” See also: Pg. 10, “Lowering the MCL will prevent children from developing severe dental fluorosis and will reduce the lifelong accumulation of fluoride into bone that the majority of the committee believes is likely to put individuals at increased risk of bone fracture and possibly skeletal fluorosis.”

43.) Ibid. NRC, ‘Fluoride in Drinking Water,’ 2006. Pg. 29, Infants with average water consumption: range of dosage is 0.042 to 0.072mg/kg/day. Infants with above average water consumption: range of dosage is 0.084 to 0.14mg/kg/day. http://www.nap.edu/openbook.php?record_id=11571 *This citation referred to herein, as NRC, ‘Fluoride in Drinking Water,’ 2006.

44.) Agency for Toxic Substances & Disease Registry, ‘Toxicological Profiles of Fluoride.’ Reference Dosage (RfD): Dental Fluorosis: 0.06mg/kg/day
Maximum Residue Limit (MRL): Bone Fracture: 0.05/mg/kg/day

www.atsdr.cdc.gov/toxprofiles/tp11-c8.pdf

Also viewable at EPA’s Integrated Risk Information System: http://www.epa.gov/iris/subst/0053.htm

45.) Department of Health and Human Services and Environmental Protection Agency, ‘News Release: EPA & DHHS Announce New Scientific Assessments and Actions on Fluoride.’ January 7, 2011. http://yosemite.epa.gov/opa/admpress.nsf/3881d73f4d4aaa0b85257

359003f5348/86964af577c37ab285257811005a8417!OpenDocument

46.) Center for Disease Control. ‘Community water fluoridation prevents tooth decay safely and effectively.’ http://www.cdc.gov/healthywater/drinking/public/water_treatment.html
See also: Center for Disease Control, ‘Fluoridation FAQ Sheet.’ ‘In 1962, based on scientific studies showing that fluoride reduces tooth decay, the U.S. Public Health Service recommended the amount of fluoride in drinking water range from 0.7 to 1.2 milligrams per liter.’ http://www.cdc.gov/fluoridation/faqs/#overview7
See also: NRC, ‘Fluoride in Drinking Water,’ 2006. Pg. 1, ‘Guidelines for that purpose (0.7 to 1.2 mg/L) were established by the U.S. Public Health Service more than 40 years ago.’

47.) Citation #45. See also: Center for Disease Control & Prevention, See under: ‘How is HHS developing new recommendations?’ ‘HHS has proposed changing the recommended level for community water fluoridation.’ ‘New proposed optimal fluoridation level.’ http://www.cdc.gov/fluoridation/faqs/#overview6
48.) Rachel Carson, Silent Spring, 1962. Pg. 23.

49.) NRC. “Fluoride in Drinking Water,” 2006.
Dental Fluorosis, Bone Fracture & Skeletal Fluorosis, Citation #42.

Bone Cancer: “Fluoride appears to have the potential to initiate or promote cancer, particularly of the bone,” Pg. 336. “Osteosarcoma is of particular concern as a potential effect of fluoride…” Pg. 336. “Bone is the most plausible site for cancer associated with fluoride,” Pg. 9.

Down’s Syndrome: “Down’s syndrome is a biologically plausible outcome of exposure,” Pg. 197.

Thyroid: “Several lines of information indicate an effect of fluoride exposure on thyroid function,” Pg. 234.

Endocrine Disruptor: “Fluoride is therefore an endocrine disruptor,” Pg. 266.

Neurotoxin: “It is apparent fluorides have the ability to interfere with the functions of the brain,” Pg. 222.

Diabetes: “Sufficient fluoride exposure appears to bring about increases in blood glucose or impaired glucose intolerance in some individuals and to increase the severity of some types of diabetes,” Pg. 260.

Kidney Dysfunction: “Portions of the renal system may therefore be at higher risk of fluoride toxicity than most soft tissues… The effect of low doses of fluoride on kidney… functions in humans needs to be carefully documented…” Pg. 303.

Immune System: “There is no question that fluoride can affect the cells involved in providing immune responses,” Pg. 295.

50.) Rachel Carson, Silent Spring, 1962. Pg. 139.
51.) J. Doull, interviewed by D. Fagin, “Second Thoughts on Fluoride,” Scientific American, 298, no. 1 (January 2008): 74-81. Pg. 80-1.View Preview: http://www.scientificamerican.com/article/second-thoughts-on-fluoride/

52.) Citation #15-22.
53.) National Sanitary Foundation International on documented impurities in fluoridation chemicals, as linked to by Center for Disease Control, “Fluoridation Fact Sheet.” “Fluoride additives are analyzed for impurities that have been identified as having the potential to occur. Those impurities include arsenic, lead and radionuclides.”   http://www.cdc.gov/fluoridation/factsheets/engineering/wfadditives.htm
54.) EPA Report: ‘1990 Report to Congress on Special Waste Mining.’ Office of Solid Waste to US Congress, July 23, 1990. www.epa.gov/compliance/resources/reports/…/1990rpttocongress.pdf
Petition to Environmental Protection Agency Administer Robert Perciasepe, from Dr. 54.) William Hirzy, on behalf of co-petitioners. Request for EPA to prohibit silicofluorides and unpurified sodium fluoride as fluoridating agents due to arsenic contamination; Request to mandate pharmaceutical grade sodium fluoride. April 22, 2013. Pg. 2, and 17. http://www2.epa.gov/aboutepa/hfsa-section-21-petition
55.) Center for Disease Control. “Engineering Fact Sheet.” Click on ‘Types and Sources of Fluoride Additives.’ http://www.cdc.gov/fluoridation/fact_sheets/engineering/wfadditives.htm#2
56.) U.S. Agency for Toxic Substances and Disease Registry, ‘Fluorides, Hydrogen Fluoride and Fluorine,’ Section 8: Regulations and Advisories. ‘Acute duration inhalation MRL of 0.01ppm has been derived for fluorine.’ http://www.atsdr.cdc.gov/toxprofiles/tp11-c8.pdf
57.) National Service Center for Environmental Publications. EPA document from December 1976: ‘Fluorine, Its Compounds and Air Pollution: Bibliography with Abstracts.’ Online. Go to Google.com, type in ‘fluorine EPA air pollutant,’ click on nepis.epa.gov link.
58.) EPA, National Research Council, Committee on Acute Exposure Guideline Levels, Committee on Toxicology, Environmental Criteria and Assessment Office. ‘Summary Review of Health Effects Associated with Hydrogen Fluoride and Related Compounds,’ Google eBook.
59.) EPA, ‘Fluorine, Its Compounds and Air Pollution: Bibliography and Abstracts,’ from the Office of Air Quality Planning and Standards, 1976. Google eBook.
60.) Environmental Protection Agency, ‘Summary of Mineral Processing: Fluorspar and Hydrofluoric Acid Wastewater.’ www.epg.gov, type in “fluorosilic acid mining,”
http://www.epa.gov/wastes/nonhaz/industrial/special/mining/minedock/id..
61.) Fluoride Industrial and Phosphate Research Institute. http://www.fipr.state.fl.us/research-area-public-health.htm

62.) D.F. Walters, “Regulatory, Economic, and Legal Aspects of Fluoride” presented at a conference, held at Utah State University in 1982, published in Fluorides: Effects on Vegetation, Animals and Humans (Salt Lake City, UT: Paragon Press, 1983). Authors: H.B. Peterson, N.C. Leone, Edited by: J.L. Shupe. Pg. 351-358, Fluoride is classified as a “welfare pollutant” under the Clean Air Act, which harms the welfare of people, plants, animals.
63.) Report of the Secretary of Health, Education, and Welfare to the 91st US Congress, March 1970, cited in a letter from Donald R. van der Vaart, P.E., Chief of Permits Section, North Carolina Department of Environment and Natural Resources, to Michael E. Johnson, Environmental Engineer, DuPont Fluoroproducts, July 17, 2008. “This report concluded that ‘inorganic fluorides are highly irritant and toxic gases’ which, in low ambient concentrations, damage plants and animals.” daq.state.nc.us/permits/psd/docs/NSR_Fluorides.pdf
64.) Martin versus Reynolds Metals Company, 1964. United States Court of Appeals Ninth Circuit, No. 19219. 336 F.2d 876 (1964). Judge’s verdict in favor of defendant for damage to crops, his farm animals and the health of his family. http://www.osbar.org/publications/bulletin/05augsep/martin.html
65.) EPA’s classifications of Hydrofluorosilicic acid, Sodium Fluorosilicate, Sodium Fluoride: all fluorides are CERCLA Waste Substances from Superfund Sites: ‘severely harmful to human health and the environment.’ www.epa.gov/osweroe1/docs/er/302table01.pdf. *Hydrofluoric acid is the aqueous form of hydrogen fluoride, which is the gaseous form; both are classified under the same CASRN number, 7664393.
66.) Philip Sadtler, Chemical and Engineering News (December 18, 1948). See American Society for Engineering Education, ‘Familiarizing the Unknown: Three Unusual Engineering Cases,’ Marilyn Dyrud, Oregon Institute of Technology. http://www.asee.org/public/conferences/1/papers/32/view

67.) K. Roholm, “The Fog Disaster in the Meuse Valley, 1930: A Fluorine Intoxication,” Journal of Hygiene & Toxicology (March 1936). Pg. 126.

68.) Citation #14-16.
69.) National Academy of Sciences, National Research Council, ‘Fluoride in Drinking Water: A Scientific Review of EPA’s Standards.’ Washington, DC: National Academies Press, 2006.
70.) NRC, ‘Fluoride in Drinking Water,’ 2006. Pg. 336.

71.) NRC, ‘Fluoride in Drinking Water,’ 2006. Pg. 222.
72.) Citation #24.

73.) Citation #25.
74.) D.W. Cross, R.J. Carton, “Fluoridation: A Violation of Medical Ethics and Human Rights,” International Journal of Occupational Environmental Health Vol.9, No. 1 (Jan-March 2003): 24-9.
See also: P. Clein, “How Can It Be Ethical To Be Putting Industrial Waste In Our Drinking Water?” Pharmaceutical Journal Vol. 271 (August 2003). Pg. 234.
75.) World Health Organization, ‘Air Quality Guidelines for Europe,’ 2000. Second Edition, WHO Regional Publications, No. 91. Pg. 4, “The toxicity of fluorides…”
http://www.euro.who.int/__data/assets/pdf_file/0018/123075/AQG2ndEd_6_5Fluorides.PDF
76.) Fluoride Action Network, “Professional Statement to End Water Fluoridation,” http://fluoridealert.org/researchers/professionals-statement/

77.) Open letter from Professor Trevor Sheldon, chair of the Advisory Group for the York Review, and founding director of the UK National Health Service’s Centre for Reviews and Dissemination at the University of York, Heslington, York, UK, January 3, 2001. http://www.appgaf.org.uk/archive/archive_letter_shel/


THE CHEMICAL ITSELF

1.) Food and Drug Administration, “FDA Approved Drug Products Database.” http://www.accessdata.fda.gov/scripts/cder/drugsatfda/index.cfm Colgate total fluoride toothpaste was approved July 1997. Injectable sodium fluoride “fluorine f-18” was approved in 1972 – discontinued. Injectable “sodium fluoride f-18” was approved January, 2011 – discontinued. Then again, injectable “sodium fluoride f-18” was approved for two manufacturers, one in December 2012, the other June 2013.
2.) Canadian National Association of Pharmacy Regulatory Authorities. Search the National Drug Schedules for “sodium fluoride” or “fluoride and its salts.” http://www.napra.org/

3.) Letter to Honorable Ken Calvert, Chairman, Subcommittee on Energy and Environment, Committee on Science, US House of Representatives, regarding FDA’s response to a Congressional Investigation about fluoride and fluoridation, from Melinda K. Plaisier, FDA Associate Commissioner for Legislation. December 21, 2000. “Fluoride, when used in the diagnosis, cure, mitigation, or prevention, of disease in man or animal, is a drug that is subject to FDA regulation […] Several NDAs [New Drug Applications] have been approved for fluoride topical products such as dentrifices and gels.” http://www.keepersofthewell.org/gov_resp_pdfs/fda_response.pdf

4.) U.S. Code of Federal Regulations, Title 21, Volume 5, Part 355, Subpart C: Warning Labeling. Online. Accessed September, 2013. http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfCFR/CFRSearch.cfm?fr=355.50

5.) An 11.5 fl. oz. glass of fluoridated water at the “optimal” level of 0.7ppm contains the exact same quantity of fluoride as the recommended “pea size” amount of fluoride toothpaste. FLUORIDATED WATER ratio — 0.7 units fluoride : 1,000,000 units water, or 0.7 parts per million, 0.7ppm

glass of water = about 11.5 fluid ounces (fl oz)

1 fl oz = about 30 milliliters (mL)

Distilled water at 40 degrees Fahrenheit: density of water is 1 gram/mL or 1 g/mL

\ 11.5 fl oz glass of fluoridated water x 30mL/fl oz x 1g/mL =
mass of glass of fluoridated water = about 345 grams = 345,000 milligrams (mg)

fluoridated water ratio is 0.7 units : 1,000,000 units

0.7/1,000,000 = x/345,000

x= ~0.25 mg fluoride

FLUORIDE TOOTHPASTE ratio — 1,000 units fluoride : 1,000,000 other toothpaste ingredients =1,000:1,000,000, which is 1,000ppm or, 1:1,000

Pea size amount of toothpaste is about 0.25 grams (g)

http://www.washington.edu/earlychildhood/faqs/childrens-oral-health-faqs

\ mass of pea size toothpaste = 0.25 g

1/1,000 = x/0.25

x= ~0.00025 g of fluoride

1,000 milligrams (mg) for every gram (g)

0.00025g x 1,000mg/g

x= ~0.25 mg fluoride

6.) Letter to Commissioner Jane Henry, Food and Drug Administration, from John Kelly, New Jersey Assemblyman, 36th district, October 26, 2000. “I am petitioning the FDA to remove unapproved children’s fluoride supplements from the market… I filed a Freedom of Information Act request with the FDA to obtain copies of the studies the FDA had used in evaluating the safety and effectiveness of these products. I was shocked when the FDA informed me that the FDA had no such studies and that children’s fluoride supplements were not approved…. The last time the FDA reviewed an NDA for fluoride supplements was in 1975 and that NDA was rejected.”

7.) Citation #3: Letter to Honorable Ken Calvert, from Melinda K. Plaisier, FDA. “No New Drug Applications have been approved for fluoride drugs meant for ingestion… Fluoride products meant for ingestion were in use prior to the enactment [of the Kefauver-Harris Amendments (Drug Amendments of 1962) to the Food, Drug and Cosmetic Act [of 1938], in which efficacy in addition to safety became a requirement for drugs marketed in the U.S.”
See also: Approved Drug Products and Legal Requirements, Volume III of USP Dispensing Information, US Pharmacopeial Convention, 2004. 24th Edition. Tauton, MA: Quebecor World. ISBN 1-56363-465-1. Pg. III/1, “The Federal Food, Drug and Cosmetic Act of 1938 require that drugs be shown to meet certain safety requirements prior to their being marketed. Drugs that were already being marketed at that time were ‘grandfathered,’ and were allowed to remain on the market without further regulatory approval… The following listing identifies drug products that we believe were considered ‘pre-1938’ or ‘grandfathered’… Sodium Fluoride (Solution, Oral + Tablets).”

8.) Food and Drug Administration, “FDA Approved Drug Products Database.” Online. http://www.accessdata.fda.gov/scripts/cder/drugsatfda/index.cfm One will note there are no systemic approvals. See also: National Institute of Health’s “DailyMed Current Medication Information” Database of Currently Marketed Drugs, including whether or not a drug is FDA approved. http://dailymed.nlm.nih.gov/dailymed/search.cfm?startswith=fluoride&x=0&y=0

9.) D.W. Cross, R.J. Carton, “Fluoridation: A Violation of Medical Ethics and Human Rights,” International Journal of Occupational Environmental Health Vol.9, No. 1 (Jan-March 2003): 24-9. “Silicofluorides have never been submitted to the US FDA for approval as medications,” in abstract.

10.) National Research Council of the National Academy of Sciences, ‘Fluoride in Drinking Water,’ 2006. Washington DC, National Academies Press. Pg. 15, “The most commonly used [drinking water] additives are silicofluorides, not the fluoride salts used in dental products (such as sodium fluoride and stannous fluoride). Silicofluorides are one of the by-products from the manufacture of phosphate fertilizers.” http://www.nap.edu/catalog.php?record_id=11571

11.) Thomas G. Reeves, P.E., National Fluoridation Engineer, Program Services Branch Division of Oral Health, National Center for Chronic Disease Prevention and Health Promotion, Center for Disease Control and Prevention. Refer: FL-143, September 2000. “All of the fluoride chemicals used in the U.S. for water fluoridation, sodium fluoride, sodium fluorosilicate, and fluorosilicic acid, are useful byproducts of the phosphate fertilizer industry… These gases are captured by product recovery units (scrubbers) and condensed into 23% fluorosilicic acid. Sodium fluoride and sodium fluorosilicate are made from this acid.”

12.) Center for Disease Control. “Engineering Fact Sheet.” http://www.cdc.gov/fluoridation/fact_sheets/engineering/wfadditives.htm#2

13.) Petition to Environmental Protection Agency Administer Robert Perciasepe, from Dr. William Hirzy, on behalf of co-petitioners. Request for EPA to prohibit silicofluorides and unpurified sodium fluoride as fluoridating agents due to arsenic contamination; Request to mandate pharmaceutical grade sodium fluoride. April 22, 2013. Pg. 2, and 17. http://www2.epa.gov/aboutepa/hfsa-section-21-petition

14.) Department of Health and Human Services, PHS, CDC, ‘ National Center of Prevention Services, Division of Oral Health, 1993. Fluoridation Census (1992). Table VI, page xviii. See also: Citation #10.

15.) D.F. Walters, “Regulatory, Economic, and Legal Aspects of Fluoride” presented at a conference, held at Utah State University in 1982, published in Fluorides: Effects on Vegetation, Animals and Humans (Salt Lake City, UT: Paragon Press, 1983). Authors: H.B. Peterson, N.C. Leone, Edited by: J.L. Shupe. Pg. 351-358, Fluoride is classified as a “welfare pollutant” under the Clean Air Act.
See also: U.S. Agency for Toxic Substances and Disease Registry, ‘Fluorides, Hydrogen Fluoride and Fluorine,’ Section 8: Regulations and Advisories. ‘Acute duration inhalation MRL of 0.01ppm has been derived for fluorine.’ http://www.atsdr.cdc.gov/toxprofiles/tp11-c8.pdf
See also: National Service Center for Environmental Publications. EPA document from December 1976: ‘Fluorine, Its Compounds and Air Pollution: Bibliography with Abstracts.’ Online. Go to Google.com, type in ‘fluorine EPA air pollutant,’ click on nepis.epa.gov link.
See also: EPA, National Research Council, Committee on Acute Exposure Guideline Levels, Committee on Toxicology, Environmental Criteria and Assessment Office. ‘Summary Review of Health Effects Associated with Hydrogen Fluoride and Related Compounds,’ Google eBook.
Also: EPA, ‘Fluorine, Its Compounds and Air Pollution: Bibliography and Abstracts,’ from the Office of Air Quality Planning and Standards, 1976. Google eBook.

16.) Environmental Protection Agency, ‘Summary of Mineral Processing: Fluorspar and Hydrofluoric Acid Wastewater.’ www.epg.gov, type in “fluorosilic acid mining,”
http://www.epa.gov/wastes/nonhaz/industrial/special/mining/minedock/id..

See also: Citation #11: ‘gases recovered from scrubbers.’

17.) Fluoride Industrial and Phosphate Research Institute. http://www.fipr.state.fl.us/research-area-public-health.htm

18.) Ibid. Citation #17. See also: #21.

19.) Ibid. Citation #17. See also: #22.

20.) Ibid. Citation #17. See also: #22.

21.) Report of the Secretary of Health, Education, and Welfare to the 91st US Congress, March 1970, cited in a letter from Donald R. van der Vaart, P.E., Chief of Permits Section, North Carolina Department of Environment and Natural Resources, to Michael E. Johnson, Environmental Engineer, DuPont Fluoroproducts, July 17, 2008. “This report concluded that ‘inorganic fluorides are highly irritant and toxic gases’ which, in low ambient concentrations, damage plants and animals.” daq.state.nc.us/permits/psd/docs/NSR_Fluorides.pdf

22.) Martin versus Reynolds Metals Company, 1964. United States Court of Appeals Ninth Circuit, No. 19219. 336 F.2d 876 (1964). Judge’s verdict in favor of defendant for damage to crops, his farm animals and the health of his family. http://www.osbar.org/publications/bulletin/05augsep/martin.html
See also: EPA’s classifications of Hydrofluorosilicic acid, Sodium Fluorosilicate, Sodium Fluoride: all fluorides are CERCLA Waste Substances from Superfund Sites: ‘severely harmful to human health and the environment.’ www.epa.gov/osweroe1/docs/er/302table01.pdf. *Hydrofluoric acid is the aqueous form of hydrogen fluoride, which is the gaseous form; both are classified under the same CASRN number, 7664393.

23.) Citation #21, Report of the Secretary of Health, Education, and Welfare.

24.) EPA Report: ‘1990 Report to Congress on Special Waste Mining.’ Office of Solid Waste to the US Congress, July 23, 1990. www.epa.gov/compliance/resources/reports/…/1990rpttocongress.pdf

25.) U.S. National Academy of Sciences Member, Edward Groth, “Air is Fluoridated,” Peninsula Observer, January 27-February 3, 1969. See also: Scott Dewey, “The Fickle Finger of Phosphate: Central Fluoride Air Pollution and the Failure of Environmental Policy, 1957-70.” Pg. 574. “Fluorine emissions were determined by Florida and Georgia University researchers, to be the cause of Fluoride’s Polk and Hillsborough counties depleted citrus yields and cattle sickened with symptoms typical of fluorosis.” Pg. 567, “The industries emissions produced air pollution severe and damaging enough to make the local atmosphere one of the most noxious and notorious in the US.”

26.) Former Professor at Cornell University’s Boyce Thompson Institute, L. H. Weinstein, “Effects of Fluorides on Plants and Plant Communities: An Overview,” presented at a conference, held at Utah State University in 1982, published in Fluorides: Effects on Vegetation, Animals and Humans (Salt Lake City, UT: Paragon Press, 1983). Editors: J.L. Shupe, H.B. Peterson, N.C. Leone. Pg. 54.
Also See: L. Weinstein, Fluoride in the Environment: Effects on Plants and Animals. 2004. Google eBook.

27.) Citation #22, Martin versus Reynolds Metals Company, 1964.

28.) “Intel will pay $143,000 penalty for fluoride violations,” The Oregonian, April 24, 2014. http://www.oregonlive.com/silicon-forest/index.ssf/2014/04/intel_will_pay_143000_penalty.html

29.) Philip Sadtler, Chemical and Engineering News (December 18, 1948). See American Society for Engineering Education, ‘Familiarizing the Unknown: Three Unusual Engineering Cases,’ Marilyn Dyrud, Oregon Institute of Technology. http://www.asee.org/public/conferences/1/papers/32/view

30.) K. Roholm, “The Fog Disaster in the Meuse Valley, 1930: A Fluorine Intoxication,” Journal of Hygiene & Toxicology (March 1936). Pg. 126.

31.) A.) The American Heritage College Dictionary, 2002. 4th edition, New York: Houghton Mifflin Company. Pg. 534. See also: The Reader’s Digest Great Encyclopedia Dictionary, Standard College Dictionary, 1966. Pleasantville, New York: Funk & Wagnalls. Pg. 513, Fluorine is ‘A corrosive and extremely reactive gaseous element.”
B.) Encyclopedia of Ecology and Environmental Management, 1998. Edited by Peter Calow. Osney Mead, Oxford: Blackwell Science Ltd. Pg. 284, Fluorine is ‘a poisonous gaseous halogen element.’

C.) Concise Encyclopedia Chemistry, 1993. Edited by H. Jakubke, H. Jeschkeit. Berlin, Germany: Walter de Gruyter. Pg. 418, ‘Fluorine is extremely poisonous and, among other things, burns the skin… highly caustic.’ Google eBook.

32.) U.N. International Programme on Chemical Safety and European Commission classify Fluorosilicic acid as Hazardous Waste: UN Class 8 – Corrosive substance. EC Classification: Symbol: C – Corrosive substance Disposal: “Do NOT let this chemical enter the environment.” http://www.inchem.org/documents/icsc/icsc/eics1233.htm

33.) Ibid., Sodium Fluorosilicate as Hazardous Waste: UN Hazard Class: 6.1 – Toxic substance. EC Classification: Symbol: T – Toxic substance. Labeling: “Signal: Danger, Toxic if swallowed [skull and crossbones symbol].” http://www.inchem.org/documents/icsc/icsc/eics1243.htm

34.) Ibid. Sodium Fluoride as Hazardous Waste: UN Hazard Class: 6.1 – Toxic substance. EC Classification: Symbol: T – Toxic substance. http://www.inchem.org/documents/icsc/icsc/eics0951.htm

35.) Citation #32.

36.) Citation #33.

37.) Citation #34.

38.) EPA’s classifications of Hydrofluorosilicic acid, Sodium Fluorosilicate, Sodium Fluoride: all fluorides are CERCLA Waste Substances from Superfund Sites: ‘severely harmful to human health and the environment.’ www.epa.gov/osweroe1/docs/er/302table01.pdf. *Hydrofluoric acid is the aqueous form of hydrogen fluoride, which is the gaseous form; both are classified under the same CASRN number, 7664393. EPA does not list Sodium Fluorosilicate as hazardous waste, however it is the salt form of fluorosilicic acid, see: nepis.epa.gov/Adobe/PDF/2000EDA9.PDF.

39.) National Sanitary Foundation International on documented impurities in fluoridation chemicals, as linked to by Center for Disease Control, “Fluoridation Fact Sheet.” “Fluoride additives are analyzed for impurities that have been identified as having the potential to occur. Those impurities include arsenic, lead and radionuclides.”   http://www.cdc.gov/fluoridation/factsheets/engineering/wfadditives.htm

40.) Ibid, Citation #39, NSF.

41.) EPA Report: ‘1990 Report to Congress on Special Waste Mining.’ Office of Solid Waste to US Congress, July 23, 1990. www.epa.gov/compliance/resources/reports/…/1990rpttocongress.pdf

42.) Environmental Protection Agency, List of Maximum Contaminant Levels in drinking water. http://water.epa.gov/drink/contaminants/upload/mcl-2.pdf

43.) J. Hirzy, R. Carton, C. Bonnani, C. Montanero, M. Nagle, “Comparison of hydrofluorosilic acid and sodium fluoride as fluoridating agents – A cost-benefit analysis,” Environmental Science & Policy, Vol. 29 (May, 2013): 81-6. Pg. 12. http://www2.epa.gov/aboutepa/hfsa-section-21-petition

44.) Citation #41, EPA Report on Special Waste Mining Processing.

45.) Citation #42, EPA List of MCL in drinking water.

46.) Center for Disease Control & Prevention, See under: ‘How is HHS developing new recommendations?’ ‘HHS has proposed changing the recommended level for community water fluoridation.’ ‘New proposed optimal fluoridation level.’ http://www.cdc.gov/fluoridation/faqs/#overview6 See also: ‘Community water fluoridation is a safe and effective method for reducing tooth decay.’ http://www.cdc.gov/fluoridation/safety/systematic.htm

47.) Safe Drinking Water Act, 42 US Code § 300g-1. Section 11. http://www.law.cornell.edu/uscode/text/42/300g-1
See also: D. Cross, R. Carton, “Fluoridation: A Violation of Medical Ethics and Human Rights,” International Journal of Occupational Environmental Health, Vol.9, No.1 (Jan-Mar 2003):24-9.

See also: Nuremberg Code of Medical Ethics: http://www.ushmm.org/information/exhibitions/online-features/special-focus/doctors-trial/nuremberg-code

See also: United Nation’s Council of Europe’s Biomedical Convention of 1999, http://conventions.coe.int/Treaty/en/Treaties/Html/164.htm

DOSAGE versus CONCENTRATION & MARGIN OF SAFETY

1.) US Department of Health and Human Services, Public Health Service and Agency for Toxic Substances and Disease Registry,‘Toxicological Profile for Fluorides, Hydrogen Fluoride and Fluorine.’ April 1993. TP-91/17, 4/93. Section 2.7 (Health Impacts), Pg. 112, ‘Existing data indicate subsets of the population may be unusually susceptible to the toxic effects of fluoride and its compounds. These populations include the elderly, people with deficiencies of calcium, magnesium, and/or vitamin C, and people with cardiovascular and kidney problems… Impaired renal clearance of fluoride has also been found in people with diabetes mellitus and cardiac insufficiency… People over the age of 50 often have decreased renal fluoride clearance.’ This is also cited on the EPA Union of Scientist’s website: nteu280.org, “Fluoridation: Recent History.”
Infants: Citation #16 & #17.
Kidney Dysfunction: NRC, ‘Fluoride in Drinking Water,’ 2006. Pg. 292, ‘Several investigators have shown that patients with impaired renal function, or on hemodialysis, tend to accumulate fluoride much more quickly than normal.’ Pg. 101, ‘severe renal insufficiency appears to increase bone fluoride concentrations, perhaps as much as twofold.’ See also: National Kidney Foundation, Official Position Statement Rescinding NKF’s 1981 Endorsement of Water Fluoridation, April 15, 2008. https://www.kidney.org/atoz/pdf/Fluoride_Intake_in_CKD.pdf
Iodine Deficiency: NRC, ‘Fluoride in Drinking Water,’ 2006. Pg. 88, regarding dietary iodine effect on dosage, and Pg. 234, ‘In animal studies, high fluoride intake appears to exacerbate the effects of low iodine concentrations.’
Thyroid: Pg. 262-3, “In humans, effects on thyroid function were associated with fluoride exposures of 0.05-0.13 mg/kg/day when iodine intake was adequate and 0.01-0.03 mg/kg/day when iodine intake was inadequate.”
See also: NAS, ‘Fluoride in Drinking Water,’ 2006. Pg. 23, “review acknowledged that ‘substantially’ higher intakes of fluoride from consumption of fluoridated water would result for individuals such as outdoor laborers in warm climates or people with high-urine-output disorders, but these intakes were not quantified.”

2.) World Health Organization Expert Committee on Oral Health Status and Fluoride Use “Fluorides and Oral Health,” WHO Technical Report Series 846, 1994. Pg. 34, “it is the uncontrollable exposure to fluoride that is the principal health concern.”
See also: Testimony Statement of Dr. J. William Hirzy, National Treasury Employees Union Chapter 280 aka ‘EPA Union of Scientists,’ Subcommittee on Wildlife, Fisheries and Drinking Water, U.S. Senate, June 29, 2000. Pg. 2, Section: ‘Fluoride Exposures Are Excessive and Un-controlled.’ Available on Union’s website: http://www.nteu280.org/Issues/Fluoride/629FINAL.htm or http://www.epw.senate.gov/107th/hir_0629.htm
See also: Citation #8: ‘Environmental Health Lecture: Principles of Exposure, Dose, and Response.’

3.) Agency for Toxic Substances & Disease Registry, ‘Minimum Risk Levels for Hazardous Substances.’ ‘Minimum Risk Limit (MRL): An MRL is an estimate of the daily human exposure to a hazardous substance that is likely to be without appreciable risk of adverse non-cancer health effects over a specified duration of exposure.’ http://www.atsdr.cdc.gov/mrls/index.asp

4.) Agency for Toxic Substances & Disease Registry, ‘Toxicological Profiles of Fluoride.’ Reference Dosage (RfD): Dental Fluorosis: 0.06mg/kg/day
Maximum Residue Limit (MRL): Bone Fracture: 0.05/mg/kg/day

www.atsdr.cdc.gov/toxprofiles/tp11-c8.pdf

Also viewable at EPA’s Integrated Risk Information System: http://www.epa.gov/iris/subst/0053.htm

5.) Ibid. Citation #4.

6.) United States Government Printing Office. Federal Register Volume 62, Number 234, Friday, December 5, 1997. 40 CFR Part 180. Environmental Protection Agency: ‘Fluorine Compounds; Time Limited Pesticide Tolerance.’ Pg. 64297, C. Exposures and Risks, Section 2, Part ii: ‘Fluoride levels in public drinking water are regulated under the Safe Drinking Water Act. EPA has established a Maximum Concentration Limit (MCL) at 4.0 mg/L 0.114 mg/ kg/day to protect against crippling skeletal fluorosis (April 2, 1986) (51 FR 11396).’ http://www.gpo.gov/fdsys/pkg/FR-1997-12-05/html/97-31920.htm

7.) National Academy of Sciences, National Research Council, ‘Fluoride in Drinking Water: A Scientific Review of EPA’s Standards.’ Washington, DC: National Academies Press, 2006. Pg. 29, Infants with average water consumption: range of dosage is 0.042 to 0.072mg/kg/day. Infants with above average water consumption: range of dosage is 0.084 to 0.14mg/kg/day. http://www.nap.edu/openbook.php?record_id=11571

8.) NRC, ‘Fluoride in Drinking Water,’ 2006. Pg. 33, ‘Mean concentration of fluoride in milk from mothers in fluoridated…’ [Tables on pg.34-5] Pg. 36, ‘communities (1mg/L in the water) was 0.0098mg/L; in nonfluoridated communities, the mean was 0.0044 mg/L.’ Summary in Table 2-6, pg. 40: “Summary of Typical Fluoride Concentrations of Selected Food and Beverages in the United States.”
1.2/ 0.0044 = 273.   1.2/ 0.0098 = 122.   0.7/0.0044 = 160.   0.7/0.01 = 70.

9.) American Dental Association e Gram, ‘Interim Guidance on Reconstituted Infant Formula,’ November 9, 2006.

10.) American Academy of Pediatrics, “Fluoride Supplementation for Children: Interim Policy Recommendations from Dietary Fluoride Workshop Committee on Nutrition, January, 1994.’ Pediatrics, Vol. 95, No. 5 (May 1998). Also published by Journal of the American Dental Association, Vol. 126, June 1995. See also: American Dental Association, “Fluoride Supplement Dosage Schedule.” http://www.ada.org/en/member-center/oral-health-topics/fluoride-supplements#dosage

11.) US National Institute of Health’s Online Library of Medicine: “Toxnet Toxicity Data Network: Fluorosilicic Acid.” http://toxnet.nlm.nih.gov/cgi-bin/sis/search/a?dbs+hsdb:@term+@DOCNO+2018

12.) E.U. Panel on Dietetic Products, Nutrients and Allergies, Affiliated with the European Food Safety Authority, Scientific Committee on the Status of Dietary Reference Values for Fluoride. Requested by European Commission. EFSA Journal. Issue 11, No. 8 (Aug 2013). Pg. 3332. ‘Fluoride is not an essential nutrient.’ This sentence is viewable online: http://www.efsa.europa.eu/en/efsajournal/pub/3332.htm

13.) U.S. Federal Register, Volume 60, Number 249. Rules and Regulations, 21 CFR, Part 101. Docket NO. 90N-0134, RIN 0910-AA19. Department of Health and Human Services, Food and Drug Administration, “FDA Food Labeling: Reference Daily Intakes.” December 28, 1995. Last sentence of Section II.: “Consistent with the vast majority of comments, FDA is adopting these values [Daily Values, i.e. Dietary Reference Intakes, for essential nutrients] except the value for fluoride, as explained below.” See also: National Institute of Health’s “MedlinePlus Medical Encyclopedia.” Note: “Recommended Daily Dietary Intake of fluoride” is a distinct term from “Recommended Daily Allowance,” used with essential nutrients like calcium.   http://www.nlm.nih.gov/medlineplus/ency/article/002420.htm
14.) Letter by Dr. Bruce Albert, president of the National Academy of Sciences, and Dr. Kenneth Shine, president of the Institute of Medicine, to Dr. Albert W. Burgstahler and other scientists, November 20, 1998. “Contradictory results do not justify a classification of fluoride as an essential element, according to accepted standards. Nonetheless, because of its valuable effect on dental health, fluoride is a beneficial element for humans.’
15.) B. Burt, ‘The Changing Patterns of Systemic Fluoride Intake.’ Journal of Dental Research, Vol. 71, No. 5 (May 1992). Pg. 1228-1237. ‘Fluoride is not an essential nutrient due to a lack of studies.’

16.) Agency for Toxic Substances & Disease Registry, ‘Toxicological Profile for Fluorides, Hydrogen Fluoride, and Fluorine,’ 2003. Atlanta, GA: U.S. Department of Health and Human Service. Pg. 157, ‘Fluoride retention appears to be higher in children than adults. Approximately 80% of an absorbed dose of fluoride is retained in young children compared to 50% in adults. This is supported by the finding that renal fluoride excretion rate is lower in children than adults.  This difference in fluoride retention is due to high fluoride uptake in developing bones.’ Viewable on Google eBooks.
17.) NRC, ‘Fluoride in Drinking Water,’ 2006. Pg. 3, ‘On per-body-weight basis, infants and young children have approximately three to four times greater exposure than do adults… Among individuals with an average water-intake rate, infants and children have the greatest total exposure to fluoride.’ See also: Pg. 29: One will note infants consume the highest dosages.

18.) See Citation #1: Kidney Dysfunction, “accumulate fluoride much more quickly than normal.”
19.) Environmental Protection Agency, ‘Dose-Response Assessment.’ ‘Both the dose at which response begin to appear and the rate at which it increases given increasing dose can be variable between different pollutants, individuals, exposure routes, etc.’

http://www.epa.gov/risk_assessment/dose-response.htm.

20.) See Citation #1: Iodine.
21.) Citation #2.
22.) Citation #4 + Citation #7

23.) Food and Nutrition Encyclopedia, 1994. 2nd edition: Vol. 1. Edited by M & A Ensminger. CRC Press. Pg.779, ‘Fluorine has a small safety range.’ Viewable on Amazon Books. See also: K. Thiessen, “Comments on: Prioritization of Chemicals for Carcinogen Identification Committee Review. Proposed Chemicals for Committee Consideration and Consultation. Proposition 65 Implementation, Office of Environmental Health Hazard Assessment, California Environmental Protection Agency,” May 5, 2009. http://www.oehha.org/prop65/public_meetings/052909coms/fluoride/SENESFluoride.pdf

“Water intake for a given age group varies substantially – around a factor of 100 between the highest and lowest consumption rates (discussed in the NRC report). The result of this is that for water fluoride at 1mg/L vs. water fluoride at 4 mg/L, there will be a huge overlap between the respective populations, with apparent differences only at the very highest water intakes. In other words, any effect seen at 4 mg/L is probably going to occur in some people at 1 mg/L (e.g., in the people with the highest water consumption or in people with impaired fluoride excretion), but this might easily be missed in the sample sizes typically used in studies.” See also: http://fluoridealert.org/content/kathleen-thiessen-phd/

24.) Center for Disease Control, ‘Recommendations for Using Fluoride to Prevent & Control Caries,’ 2001. http://www.cdc.gov/mmwr/preview/mmwrhtml/rr5014a1.htm ‘1 ppm fluoride was the optimal concentration in community drinking.’ [original emphasis]

See also: NRC, Fluoride in Drinking Water, 2006. Pg. 15. Artificial fluoridation began in 1945.
25.) Department of Health and Human Services and Environmental Protection Agency, ‘News Release: EPA & DHHS Announce New Scientific Assessments and Actions on Fluoride.’ January 7, 2011. http://yosemite.epa.gov/opa/admpress.nsf/3881d73f4d4aaa0b85257

359003f5348/86964af577c37ab285257811005a8417!OpenDocument

26.) F. Lin, Aihaiti, H. Zhao, et al., “The Relationship of a Low-Iodine and High-Fluoride Environment to Subclinical Cretinism in Xinjiang,” Iodine Deficiency Disorder Newsletter Vol. 7 (1991): 3. Xinjiang Institute for Endemic Disease Control and Research; Office of Leading Group for Endemic Disease Control of Hetian Prefectural; and County Health and Epidemic Prevention Station, Yutian, Xinjiang. See also: P. Connett, J. Beck, H. Micklem, The Case Against Fluoride, 2010. White River Junction, VT: Chelsea Green Publishing. Pg. 138, Pg. 202, this study was reviewed by the 2006 NRC.

THE SCIENCE ITSELF

1.) National Academy of Sciences, National Research Council, ‘Fluoride in Drinking Water: A Scientific Review of EPA’s Standards.’ 2006. Washington, DC: National Academies Press. Pg. 18.

2.) Ibid. NRC, ‘Fluoride in Drinking Water,’ 2006. Pg. 2, “After reviewing the collective evidence, including studies conducted since the early 1990s, the committee concluded unanimously that the present MCLG of 4mg/L for fluoride should be lowered.” See also: Pg. 10, “Lowering the MCL will prevent children from developing severe dental fluorosis and will reduce the lifelong accumulation of fluoride into bone that the majority of the committee believes is likely to put individuals at increased risk of bone fracture and possibly skeletal fluorosis.”

3.) The American Heritage College Dictionary, 2002. 4th edition. New York: Houghton Mifflin Company. Pg. 534, ‘abnormal condition caused by excessive intake of fluorine, characterized chiefly by mottling of the teeth.”
4.) NRC, ‘Fluoride in Drinking Water,’ 2006. Pg. 103, “Excessive intake of fluoride during enamel development can lead to enamel fluorosis.”

5.) “Fluoride Supplementation for Children: Interim Policy Recommendation,” American Academy of Pediatrics Policy Statement. Pediatrics Vol. 95, No.5 (May 1998).

6.) K. Heller, S. Eklund, B. Burt, “Dental Caries and Dental Fluorosis at Varying Water Fluoride Concentrations,” Journal of Public Health Dentistry Vol. 57, No. 3 (1997): 136-43.
7.) Environmental and Occupational Health, 2007. 4th Edition. Edited by William Rom, Steven Markowitz. Philadelphia, PA: Lippincott Williams & Wilkins. Pg. 1086-7, “Chronic fluorine poisoning results in a condition called fluorosis, and the toxic manifestations can take three forms: clinical, skeletal and dental (38).”
8.) Center for Disease Control, “Prevalence and Severity of Dental Fluorosis in the United States, 1999-2004.” http://www.cdc.gov/nchs/data/databriefs/db53.htm#summary
9.) H. Hodge, “Safety Factors in Water Fluoridation Based on the Toxicology of Fluorides,” The Proceedings of the Nutrition Society American Academy of Pediatrics Policy Statement American Academy of Pediatrics Policy Statement Vol. 22 (1963): 111-7http://journals.cambridge.org/action/displayFulltext?type=1&fid=784060&jid=PNS&volumeId=22&issueId=01&aid=784052

10.) P. Connett, J. Beck, H. Micklem, The Case Against Fluoride, 2010. White River Junction, VT: Chelsea Green Publishing. Pg. 172. Pg. 175. Appendix 2.
See also: Testimony of William Hirzy, National Treasury Employees Union Chapter 280, aka EPA Union of Scientists, before the Subcommittee on Wildlife, Fisheries and Drinking Water, US Senate, June 29, 2000. Pg., 2, “Few researchers, if any, are looking for the effects of excessive fluoride exposure on bone and other tissues in American children. What has been reported so far in this connection is disturbing…”

11.) P. Kurttio, N. Gustavsson, T. Vartiainen, and J. Pekkanen, “Exposure to Natural Fluoride in Well Water and Hip Fracture: A Cohort Analysis in Finland,” American Journal of Epidemiology Vol. 150, No. 8 (1999): 817–24.
12.) C. Danielson et al., “Hip Fractures and Fluoridation in Utah’s Elderly Population,” Journal of the American Medical Association, Vol. 268, No.6 (Aug 1992):746-8.

13.) World Health Organization, Fluorides, Environmental Health Criteria 227, International Programme on Chemical Safety, Geneva, Switzerland, 2002. http://www.inchem.org/documents/ehc/ehc/ehc227.htm
See also: J. Fawell, K. Bailey, J. Chilton, et al., World Health Organization, ‘Fluoride in Drinking-Water,’ 2006. London and Seattle: IWA Publishing, 2006.

14.) Y. Li, C. Liang, C. Slemenda, et al., “Effect of Long-Term Exposure to Fluoride in Drinking Water on Risks of Bone Fractures,” Journal of Bone and Mineral Research Vol. 16, No. 5 (2001): 932–39.

15.) M. Alarcón-Herrera, I. Martín-Domínguez, R. Trejo-Vázquez, et al., “Well Water Fluoride, Dental Fluorosis, Bone Fractures in the Guadiana Valley of Mexico,” Fluoride 34, no. 2 (2001): 139–49, http://www.fluoride-journal.com/01-34-2/342-139.pdf

16.) Environmental and Occupational Health, 2007. 4th Edition. Edited by William Rom, Steven Markowitz. Philadelphia, PA: Lippincott Williams & Wilkins. Pg. 1086-7, “Chronic fluorine poisoning results in a condition called fluorosis, and the toxic manifestations can take three forms: clinical, skeletal and dental (38).”

17.) Ibid. NRC, ‘Fluoride in Drinking Water,’ 2006. Pg. 170-71: “excessive intake of fluoride will manifest itself in a musculoskeletal disease with a high morbidity” i.e. skeletal fluorosis. See also: World Health Organization, ‘Water-related diseases: Fluorosis.’ Online. ‘Ingestion of excess fluoride, most commonly in drinking-water, can cause fluorosis which affects the teeth and bones.’ http://www.who.int/water_sanitation_health/diseases/fluorosis/en/

18.) Random House Webster’s Unabridged Dictionary, 1998. 2nd edition. New York: Random House. Pg. 739-40.

19.) K. Roholm, Fluorine Intoxication, 1937. London: H.K. Lewis Co., Ltd.

20.) D. Greenwood, “Fluorine Intoxication,” 1940. Physiological Review Vol. 20, No. 582. See also: B. Hileman, “Fluoridation of Water. Questions about Health Risks and Benefits Remain After More than 40 Years,” Chemical & Engineering News (August 1, 1988): 26–42.

21.) H. Hodge and F. Smith, “Occupational Fluoride Exposure,” Journal of Occupational Medicine Vol. 19, No. 1 (1977): 12–39.

22.) E. Czerwinski and W. Lankosz, “Fluoride-induced Changes in 60 Retired Aluminum Workers,” Fluoride Vol. 10, No. 3 (1977): 125–36
23.) E. Czerwinski, J. Nowak, D. Dabrowska, et al., “Bone and Joint Pathology in Fluoride-Exposed Workers,” Archives of Environmental Health Vol. 43, No. 5 (1988): 340–43.

24.) B. Carnow and S. Conibear, “Industrial Fluorosis,” Fluoride Vol. 14, No. 4 (1981): 172–81, http://fluoridealert.org/re/carnow.1981.pdf
25.) J. Shupe, “Fluorine Toxicosis and Industry,” American Industrial Hygiene Association Journal Vol. 31, No. 2 (1970): 240–47.
26.) M. Boillat, J. Garcia and L. Velebit, “Radiological Criteria of Industrial Fluorosis,” Skeletal Radiology Vol. 5, No. 3 (1980): 161–65.

27.) B. Carnow and S. Conibear, “Industrial Fluorosis,” Fluoride Vol. 14, No. 4 (1981): 172–81, http://fluoridealert.org/re/carnow.1981.pdf
28.) J. Franke, F. Rath, H. Runge, et al., “Industrial Fluorosis,” Fluoride Vol.8, No. 2 (1975): 61–83, http://www.fluoridealert.org/re/franke-1975.pdf
29.) United Steelworkers Union, The Oil Worker, Issue 12. http://www.usw.org/news/publications/oilworker/the-oil-worker-issue-12

See also: Environmental Protection Agency, Hydrogen Fluoride Information, ‘One of the strongest acids known,’ http://www.epa.gov/ttn/atw/hlthef/hydrogen.html#N_1_
See also: EPA’s CASRN number, 7664393 refers to both Hydrofluorosilicic acid, as is the aqueous form of Hydrogen Fluoride. Both are CERCLA Waste Substances from Superfund Sites: ‘severely harmful to human health and the environment.’ www.epa.gov/osweroe1/docs/er/302table01.pdf. *Hydrofluoric acid is the aqueous form of hydrogen fluoride, which is the gaseous form; both are classified under the same Chemical #.

30.) S. Bang, G. Boivin, J. Gerster, and C. Baud, “Distribution of Fluoride in Calcified Cartilage of a Fluoride-treated Osteoporotic Patient,” Bone Vol.6, No.4 (1985): 207–10.

31.) B. Bhavsar, V. Desai, N. Mehta, R. Vashi, K. Krishnamachari, “Neighborhood Fluorosis in Western India Part II: Population Study,” Fluoride Vol.18, No. 2 (1985): 86–92.
32.) J. Shupe, “Fluorine Toxicosis and Industry,” American Industrial Hygiene Association Journal Vol. 31, No. 2 (1970): 240–47.

33.) S. Singh, S. Jolly, and B. Bansal, “Skeletal Fluorosis and Its Neurological Complications,” The Lancet Vol. 1 (1961): 197–200.
34.) S. Teotia, M. Teotia, and N. Teotia, “Symposium on the Non-Skeletal Phase of Chronic Fluorosis: The Joints,” Fluoride Vol. 9, No. 1 (1976): 19–24, http://www.fluoridealert.org/re/teotia-1976.pdf

35.) A. Singh, S. Jolly, B. Bansal, and C. Mathur, “Endemic Fluorosis: Epidemiological, Clinical and Biochemical Study of Chronic Fluoride Intoxication in Punjab (India),” Medicine Vol. 42 (1963): 229–46.
36.) J. Hallanger Johnson, A. Kearns, P. Doran, et al., “Fluoride-Related Bone Disease Associated with Habitual Tea Consumption,” Mayo Clinic Proceedings 82, no. 6 (2007): 719–24. Note: Erratum on dosage error in article text in: Mayo Clinic Proceedings 82, no. 8 (2007): 1017, http://www.mayoclinicproceedings.com/content/82/6/719.full
37.) A. Gupta, N. Kumar, S. Bandhu, and S. Gupta, “Skeletal Fluorosis Mimicking Seronegative Arthritis,” Scandinavian Journal of Rheumatology Vol. 36, No. 2 (2007): 154–5.

38.) M. Whyte, W. Totty, V. Lim, and G. Whitford, “Skeletal Fluorosis from Instant Tea,” Journal of Bone and Mineral Research Vol.23, No. 5 (2008): 759–69.

39.) Taber’s Cyclopedic Medical Encyclopedia. Online. Accessed 2001. “Fluorosis is chronic fluorine poisoning.”

40.) Oxford English Dictionary, 2nd Edition, Vol. 5, 1989. Oxford: Clarendon Press. Pg. 1105, “Fluorosis: Path. Poisoning by fluorine or a fluorine compound; any condition caused by poisoning.”

41.) Testimony of William Hirzy, National Treasury Employees Union Chapter 280, aka EPA Union of Scientists, before the Subcommittee on Wildlife, Fisheries and Drinking Water, US Senate, June 29, 2000. Pg. 2, “According to a study by the National Institute of Dental Research, 66 percent of American children in fluoridated communities show the visible sign of over-exposure and fluoride toxicity, dental fluorosis. That result is from a survey done in the mid-1980’s and the figure today is undoubtedly much higher.” 42.) See also: Environmental and Occupational Health, 2007. 4th Edition. Edited by William Rom, Steven Markowitz. Philadelphia, PA: Lippincott Williams & Wilkins. Pg. 1086-7, “Chronic fluorine poisoning results in a condition called fluorosis, and the toxic manifestations can take three forms: clinical, skeletal and dental (38).”

43.) International Association of Oral Medicine & Toxicology, “Position on Fluoridation.” Online. Pg. 37. http://iaomt.org/iaomt-position-fluoridation/

44.) B. Bibby, “Effects of Topical Application of Fluorides on Dental Caries,” In Fluorine in Dental Public Health (New York Institute of Clinical Oral Pathology Inc., A Symposium, 1944). “Beyond certain limits, fluorides are toxic and the first evidence of toxicity manifests itself in the form of mottled enamel.”

45.) The Reader’s Digest Great Encyclopedia Dictionary, Standard College Dictionary, 1966. Pleasantville, New York: Funk & Wagnalls. Pg. 513, ‘Path., chronic poisoning with fluorine.’

46.) P. Denbesten, W. Li, “Chronic Fluoride Toxicity: Dental Fluorosis,’ Monographs in Oral Medicine, Vol. 22 (2011):81-96. http://www.ncbi.nlm.nih.gov/pubmed/21701193

47.) F. DeEds, “Fluorine in Relation to Bone and Tooth Development.” Journal of American Dental Association, Vol. 23, 1936. Pg. 574, “Fluorine is a general protoplasmic poison, but the most important symptoms of chronic fluorine poisoning known at present are mottling of the teeth and interference with bone formation.”
48.) National Treasury Employee’s Union 280, Coalition of Environmental Protection Agency Unions, ‘EPA Union of Scientists.’ “Why EPA Union of Scientists Oppose Water Fluoridation.”
49.) World Health Organization, ‘Water-related diseases: Fluorosis.’ Online. ‘Ingestion of excess fluoride, most commonly in drinking-water, can cause fluorosis which affects the teeth and bones.’ http://www.who.int/water_sanitation_health/diseases/fluorosis/en/
50.) World Health Organization, ‘Air Quality Guidelines for Europe,’ 2000. Second Edition, WHO Regional Publications, No. 91. Pg. 4, “The toxicity of fluorides…”
http://www.euro.who.int/__data/assets/pdf_file/0018/123075/AQG2ndEd_6_5Fluorides.PDF

51.) NRC, ‘Fluoride in Drinking Water,’ 2006. Pg. 336.

52.) National Cancer Institute, Fluoridation Fact Sheet, See under: Can fluoridated water cause cancer? http://www.cancer.gov/cancertopics/factsheet/Risk/fluoridated-water
“A possible relationship between fluoridated water and cancer risk has been debated for years. The debate resurfaced in 1990 when a study by the National Toxicology Program, part of the National Institute of Environmental Health Sciences, showed an increased number of osteosarcomas (bone tumors) in male rats given water high in fluoride for 2 years (4) [Citation #56, below]. However, other studies in humans and in animals have not shown an association between fluoridated water and cancer (57).”
See: E. Operskalski, S. Preston-Martin, B. Henderson, B. Visscher, ‘A case-control study of osteosarcoma in young persons.’ American Journal of Epidemiology, Vol.126, No.1 (July 1987):118-26.

53.) S. McGuire, E. Vanable, M. McGuire, J. Buckwalter, C. Douglass, ‘Is there a link between fluoridated water and osteosarcoma?’ Journal of the American Dental Association, Vol. 122, No.4 (April 1991):38-45.

54.) K. Gelberg, E. Fitzgerald, S. Hwang, R. Dubrow, ‘Fluoride exposure and childhood osteosarcoma: a case-control study.’ American Journal of Public Health, Vol. 85, No.12 (Dec 1995):1678-83.
55.) R. Hoover, S. Devsa, K. Cantor, J. Lubin, J. Fraumani; National Cancer Institute. ‘DHHS Review of Fluoride Benefits and Risks.’ US Public Health Service; 1990. Time trends for bone and joint cancers and osteosarcomas in the surveillance, epidemiology and end results (SEER) program; pp. F1–7. Unpublished; found in: Review of Fluoride: Benefits and Risks, U.S. Department of Health & Human Services, Public Health Service, Washington DC, February 1991. Appendix E. Cited in Connett, Case Against Fluoride, 2010, Pg. 185.

56.) P. Cohn, An Epidemiological Report on Drinking Water and Fluoridation, New Jersey Department of Health, Environmental Health Service, November 8, 1992. Note: The original title of this report was A Brief Report on the Association of Drinking Water Fluoridation and the Incidence of Osteosarcoma Among Young Males. Cited in Connett, Case Against Fluoride, 2010, Pg. 185.

57.) J. Yiamouyiannis, ‘Fluoridation and Cancer: The biology and epidemiology of bone and oral cancer related to fluoridation.’ Fluoride. Vol.26 (1993):83–96.
See also: K. Takahashi, K. Akiniwa, K. Narita, “Regression Analysis of Cancer Incidence Rates and Water Fluoride in the U.S.A. based in IACRI/IARC (WHO) data (1978-1992),” Journal of Epidemiology Vol.11, No.4 (July 2001):170-9. 63.9% of the sites of the body were “positively significant” associated with WF, including bone cancer among males. http://www.ncbi.nlm.nih.gov/pubmed/11512573
58.) Bucher JR, Hejtmancik MR, Toft JD, et al. Results and conclusions of the National Toxicology Program’s rodent carcinogenicity studies with sodium fluoride. International Journal of Cancer 1991; 48(5):733–737.
59.) E. Bassin, D. Wypij, R. Davis, M. Mittleman, “Age-Specific Fluoride Exposure in Drinking Water and Osteosarcoma (United States),” Cancer Causes and Control Vol.17, No.4 (May 2006): 281-82.

60.) Ibid. Pg. 6
61.) National Treasury Employee’s Union 280, Coalition of Environmental Protection Agency Unions, ‘EPA Union of Scientists.’ “Why EPA Union of Scientists Oppose Fluoridation,” 1998.http://www.nteu280.org/Issues/Fluoride/NTEU280-Fluoride.htm Pg. 4, “The implication for the general public of these calculations is clear. Recent, peer-reviewed toxicity data when applied to EPA’s standard method for controlling risks from toxic chemicals, require an immediate halt to the use of the nation’s drinking water reservoirs as disposal sites for the toxic waste of the phosphate fertilizer industry.”
See also: Testimony Statement of Dr. J. William Hirzy, before Subcommittee on Wildlife, Fisheries and Drinking Water, U.S. Senate, June 29, 2000. Pg. 3, ‘we believe that a national moratorium on water fluoridation should be instituted.’ Available on Union’s website: http://www.nteu280.org/Issues/Fluoride/629FINAL.htm or http://www.epw.senate.gov/107th/hir_0629.htm
62.) Ibid. Letter to members of U.S. Congress on Fluoride Regulation, “RE: Bone Cancer-Fluoridation Cover-Up,” August 5, 2005. http://www.nteu280.org/Issues/Fluoride/fluroride%20.unions.congress.htm
See also: NRC, “Fluoride in Drinking Water,” 2006.
Pg. 9, “Bone is the most plausible site for cancer associated with fluoride because of its deposition into bone and its mitogenic effects on bone cells in culture.” A mitogen is a cell divider, and bone cancer is caused by uncontrolled proliferation of osteoblasts, i.e., an abnormal rate of bone cell multiplication.
Pg. 222, “fluoride appears to have the potential to initiate or promote cancer, particularly of the bone,”
Pg. 336, ‘Osteosarcoma is of particular concern as a potential effect of fluoride…”
See: Rachel Carson, Silent Spring, Pg. 207, “Many of the most distinguished research men in this field look with suspicion on any agent that damages the chromosomes, interferes in cell division, or causes mutations. In the view of these men, any mutation is a potential cause of cancer.”

See: Google Scholar: 88,990 results for ‘fluoride mitogen.’
K. Farley, N. Tarbaux, S. Hall, D. Baylink, “Mitogenic Actions of Fluoride on Osteoblast line cells,” Journal of Bone Mineral Research, Vol.5, Suppl. 1: (March 1990): S107-13. http://www.ncbi.nlm.nih.gov/pubmed/2339619

See: Google Scholar: 36,000 results for ‘fluoride mutagenic.’
E. Zeigler, M. Shelby, K. Witt, “Genetic Toxicity of Fluoride.” Environmental & Molecular Mutagenesis, Vol. 21, No.4 (1993): 309-18. “Fluoride produces chromosome aberrations and gene mutations in cultured mammalian cells.”
http://www.ncbi.nlm.nih.gov/pubmed/8491210

63.) Citation #61.
64.) NRC, ‘Fluoride in Drinking Water,’ 2006 Panel member, K. Thiessen, Suggested Issues for Consideration: Water Fluoridation,’ December 13, 2006. http://fluoridealert.org/content/kathleen-thiessen-phd/

65.) NRC, ‘Fluoride in Drinking Water,’ 2006. Pg. 322 “principles of cell biology indicate that stimuli for rapid cell division increase the risks for some of the dividing cells to become malignant, either by inducing random transforming events or by unmasking malignant cells that previously were in non-dividing states (190).”
66.) NRC, ‘Fluoride in Drinking Water,’ 2006. Pg. 222. See also: Pg. 336, “Osteosarcoma is of particular concern as a potential effect of fluoride…”

67.) NRC, ‘Fluoride in Drinking Water,’ 2006. Pg. 222.

68.) “Impact of fluoride on neurological development in children,” Harvard School of Public Health Press Release, July 25, 2012. http://www.hsph.harvard.edu/news/features/fluoride-childrens-health-grandjean-choi/

69.) A. Choi, G. Sun, Y. Zhang, P. Grandjean, “Development Fluoride Neurotoxicology: A Systematic Review and Meta-Analysis.” Environmental Health Perspective, Vol.120, No.10 (Oct 2012): 1361-1368. http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3491930/

70.) Fluoride Action Network, “Fluoride & Intelligence: the 37 studies.” Online. http://www.fluoridealert.org/studies/brain01/
71.) G. Wang et al., “Total intake of fluorine content and children’s IQ,” Southeast University Medical Sciences. Available at: http://www.cnki.com.cn/Article/CJFDTOTAL-NJTD201206020.htm

72.) S. Wang, Z. Wang, X. Cheng, et al., “Arsenic and Fluoride Exposure in Drinking Water: Children’s IQ and Growth in Shanyin County, Shanxi Province, China,” Environmental Health Perspectives Vol.115, No. 4 (2007): 643–47, http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1852689/

73.) L. Zhao, G. Liang, D. Zhang, and X. Wu, “Effect of High-Fluoride Water Supply on Children’s Intelligence,” Fluoride Vol.29, No. 4 (1996): 190–92, http://fluoridealert.org/scher/zhao-1996.pdf

74.) G. Wang, D. Yang, F. Jia, and H. Wang, “A Study of the IQ Levels of Four- to Seven-Year-Old Children in High Fluoride Areas,” Fluoride Vol.41, No. 4 (2008): 340–43 (originally published in 1996 in Endemic Diseases Bulletin [China]), http://www.fluorideresearch.org/414/files/FJ2008_v41_n4_p340-343.pdf

  1. Ren, K. Li, and D. Liu, “A Study of the Intellectual Ability of 8–14 Year-Old Children in High Fluoride, Low Iodine Areas,” Fluoride Vol.41, No. 4 (2008): 319–20 (originally published in 1989 in Chinese Journal of Control of Endemic Diseases), http://www.fluorideresearch.org/414/files/FJ2008_v41_n4_p319-320.pdf
    75.) L. Qin, S. Huo, R. Chen, et al., “Using the Raven’s Standard Progressive Matrices to Determine the Effects of the Level of Fluoride in Drinking Water on the Intellectual Ability of School-Age Children,” Fluoride Vol.41, No. 2 (2008): 115–19 (originally published in 1990 in Chinese Journal of the Control of Endemic Disease), http://www.fluorideresearch.org/412/files/FJ2008_v41_n2_p115-119.pdf

76.) Y. Lu, Z. Sun, L. Wu, et al., “Effect of High-Fluoride Water on Intelligence in Children,” Fluoride Vol.33, No. 2 (2000): 74–78, http://www.fluorideresearch.org/332/files/FJ2000_v33_n2_p74-78.pdf

77.) S. Liu, Y. Lu, Z. Sun, et al., “Report on the Intellectual Ability of Children Living in High-Fluoride Water Areas,” Fluoride Vol.41, No. 2 (2008): 144–47 (originally published in 2000 in Chinese Journal of Control of Endemic Diseases), http://www.fluorideresearch.org/412/files/FJ2008_v41_n2_p144-147.pdf

78.) F. Lin, F. Aihaiti, H. Zhao, et al., “The Relationship of a Low-Iodine and High-Fluoride Environment to Subclinical Cretinism in Xinjiang,” Xinjiang Institute for Endemic Disease Control and Research; Office of Leading Group for Endemic Disease Control of Hetian Prefectural Committee of the Communist Party of China; and County Health and Epidemic Prevention Station, Yutian, Xinjiang, Iodine Deficiency Disorder Newsletter Vol.7, (1991): 3, http://fluoridealert.org/scher/lin-1991.pdf -also see http://www.fluoridealert.org/IDD.htm

79.) X. Li, J. Zhi, and R. Gao, “Effect of Fluoride Exposure on Intelligence in Children,” Fluoride Vol. 28, No. 4 (1995): 189–92, http://fluoridealert.org/scher/li-1995.pdf

80.) Y. Ding et al., “The relationships between low levels of urine fluoride on children’s intelligence, dental fluorosis in endemic fluorosis areas in Hulunbuir, Inner Mongolia, China,” Journal of Hazardous Materials Vol.186, No.2-3 (2011):1942-46.

81.) Y. Li, X. Jing, D. Chen, L. Lin, and Z. Wang, “Effects of Endemic Fluoride Poisoning on the Intellectual Development of Children in Baotou,” Fluoride Vol.41, No. 2 (2008): 161–64 (origi­nally published in 2003 in Chinese Journal of Public Health Management), http://www.fluorideresearch.org/412/files/FJ2008_v41_n2_p161-164.pdf

82.) F. Hong, Y. Cao, D. Yang, and H. Wang, “Research on the Effects of Fluoride on Child Intellectual Development Under Different Environmental Conditions,” Fluoride Vol.41, No. 2 (2008): 156–60 (originally published in 2001 in Chinese Primary Health Care), http://www.fluorideresearch.org/412/files/FJ2008_v41_n2_p156-160.pdf

83.) Y. Chen, F. Han, Z. Zhou, et al., “Research on the Intellectual Development of Children in High Fluoride Areas,” Fluoride Vol.41, No. 2 (2008): 120–24, (originally published in 1991 in Chinese Journal of Control of Endemic Diseases), http://www.fluorideresearch.org/412/files/FJ2008_v41_n2_p120-124.pdf

84.) Q. Xiang, Y. Liang, L. Chen, et al., “Effect of Fluoride in Drinking Water on Children’s Intelligence,” Fluoride Vol.36, No. 2 (2003): 84–94, http://www.fluorideresearch.org/362/files/FJ2003_v36_n2_p84-94.pdf – Also see Q. Xiang, Y. Liang, M. Zhou, and H. Zang, “Blood Lead of Children in Wamiao -Xinhuai Intelligence Study” (letter), Fluoride Vol. 36, No. 3 (2003): 198–99, http://www.fluorideresearch.org/363/files/FJ2003_v36_n3_p198-199.pdf
85.) M. Sun, et al., “Measurement of intelligence by drawing test among the children in the endemic area of Al-F combined toxicosis,” Journal of Guiyang Medical College Vol.16, No. 3 (1991): 204-06.

86.) Q. Shao, et al., “Study of Cognitive Function Impairment Caused by Chronis Fluorosis,” Chinese Journal of Endemiology Vol. 22, No.4 (2003): 336-8.
87.) J. An, S. Mei, A. Liu, et al., “Effect of High Level of Fluoride on Children’s Intelligence” (article in Chinese), Zhong Guo Di Fang Bing Fang Zhi Za Zhi (Chinese Journal of Control of Endemic Diseases) Vol.7, No. 2 (1992): 93–94.
88.) Z. Fan, H. Dai, A. Bai, et al., “Effect of High Fluoride Exposure on Children’s Intelligence” (article in Chinese), Huan Jing Yu Jian Kang Za Zhi Vol.24, No. 10 (2007): 802–3.
89.) Y. Xu, C. Lu, and X. Zhang, “Effect of Fluoride on Children’s Intelligence” (article in Chinese), Di Fang Bing Tong Bao Vol.9 (1994): 83–84.

90.) L. Yao, Y. Deng, S. Yang, et al., “Comparison of Children’s Health and Intelligence Between the Fluorosis Area with Altering Water Source and Those without Altering Water Source” (article in Chinese), Yu Fang Yi Xue Wen Xian Xin Xi Vol.3, No. 1 (1997): 42–43.
91.) J. Zhang, H. Yao, and Y. Chen, “Effect of High Level of Fluoride and Arsenium on Children’s Intelligence” (article in Chinese), Zhong Guo Gong Gong Wei Sheng Xue Bao Vol.17, No. 2 (1998): 119.

92.) M. Rocha-Amador, M. Navarro, L. Carrizales, et al., “Decreased Intelligence in Children and Exposure to Fluoride and Arsenic in Drinking Water,” Cadernos de Saúde Pública Vol.23, Suppl. 4 (2007): S579–87.

93.) P. Shivaprakash et al., “Relation between dental fluorosis and intelligence quotient in school children of Bagalkot district,” Journal of Indian Society Pedodontics & Preventative Dentistry Vol.29, No.2 (2011): 117-20.

94.) P. Eswar et al., “Intelligent quotients of 12-14 year old school children in a high and low fluoride village in India,” Fluoride Vol.44 (2011): 168-72.

95.) M. H. Trivedi, R. J. Verma, N. J. Chinoy, et al., “Effect of High Fluoride Water on Intelligence of School Children in India,” Fluoride Vol.40, No. 3 (2007): 178–83. http://www.fluorideresearch.org/403/files/FJ2007_v40_n3_p178-183.pdf

96.) M. Trivedi et al., “Assessment of groundwater quality with special reference to fluoride and its impact on IQ of schoolchildren in six villages of the Mundra Region, Kachchh, Gujurat, India,” Fluoride Vol.45, No.4 (2012): 377-83.

97.) S. Saxena, et al., “Effect of fluoride exposure on the intelligence of school children in Madhya Pradesh, India,” Journal of Neurosciences in Rural Practice Vol.3, No.2 (2012): 144-49.

98.) H. Poureslami et al, “Intelligence quotient of 7 to 9 year-old children from an area with high fluoride in drinking water,” Journal of Dentistry and Oral Hygiene Vol.3, No.4 (2011): 61-64.

99.) B. Seraj et al., “Effect of high water fluoride concentration on the intellectual development of children in Makoo/Iran,” Journal of Dentistry, Tehran University of Medical Sciences Vol.9, No.3 (2012): 221-29.

100.) B. Seraj, M. Shahrabi, M. Falahzade, et al., “Effect of High Fluoride Concentration in Drinking Water on Children’s Intelligence,” Journal of Dental Medicine 19, no. 2 (2007): 80–86. Note: English translation forwarded by lead author (B. Seraj, department of pediatric dentistry, faculty of dentistry, Tehran University of Medical Sciences), http://fluoridealert.org/scher/seraj-2007.trans.pdf
101.) R. Masters, M. Coplan, B. Hone, and J. Dykes, “Association of Silicofluoride Treated Water with Elevated Blood Lead,” Neurotoxicology Vol.21, No. 6 (2000): 1091-99.

102.) ‘M. Coplan, S. Patch, R. Masters, M. Bachman, “Confirmation of and Explanations for Elevated Blood Lead and Other Disorders in Children Exposed to Water Disinfection and Fluoridation Chemical.” Neurotoxicology Vol. 28, No. 5 (2007): 1032-42.
103.) J. Luke, “Fluoride Deposition in the Aged Human Pineal Gland,” Caries Research Vol.35, No. 2 (2001): 125–28.

104.) P. Mullenix, P. Denbesten, A. Schunior, and W. Kernan, “Neurotoxicity of Sodium Fluoride in Rats,” Neurotoxicology and Teratology Vol.17, No. 2 (1995): 169–77.

See also: Fluoride Action Network, “Fluoride & the Brain: An Interview with Dr. Phyllis Mullenix; http://www.fluoridealert.org/content/mullenix-interview/

105.) Z. Guan, Y. Wang, K. Xiao, et al., “Influence of Chronic Fluorosis on Membrane Lipids in Rat Brain,” Neurotoxicology and Teratology Vol.20, No. 5 (1998): 537–42.
See also: Q. Gao, Y. Liu, and Z. Guan, “Decreased Learning and Memory Ability in Rats with Fluorosis: Increased Oxidative Stress and Reduced Cholinesterase Activity,” Fluoride Vol.42, No. 4 (2009): 277–85, http://www.fluorideresearch.org/424/files/FJ2009_v42_n4_p277-285.pdf.
See also: Y. Liu, Q. Gao, C. Wu, and Z. Guan, “Alterations of nAChRs and ERK1/2 in the Brains of Rats with Chronic Fluorosis and Their Connections with the Decreased Capacity of Learning and Memory,” Toxicology Letters Vol.192, No. 3 (2010): 324–29.

106.) J. Varner, K. Jensen, W. Horvath, and R. Isaacson, “Chronic Administration of Aluminum-Fluoride or Sodium-Fluoride to Rats in Drinking Water: Alterations in Neuronal and Cerebrovascular Integrity,” Brain Research Vol.784, No. 1–2 (1998): 284–98. Excerpts at http://www.fluoride-journal.com/98-31-2/31291-95.htm

107.) J. Zhai, Z. Guo, C. Hu, et al., “Studies on Fluoride Concentration and Cholinesterase Activity in Rat Hippocampus” (article in Chinese), Zhonghua Lao Dong Wei Sheng Zhi Ye Bing Za Zhi Vol.21, No. 2 (2003): 102–4.

108.) I. Inkielewicz and J. Krechniak, “Fluoride Content in Soft Tissues and Urine of Rats Exposed to Sodium Fluoride in Drinking Water,” Fluoride Vol.36, No. 4 (2003): 263–66, http://www.fluoride-journal.com/03-36-4/364-263.pdf

109.) A. R. Kay, R. Miles, and R. K. Wong, “Intracellular Fluoride Alters the Kinetic Properties of Calcium Currents Facilitating the Investigation of Synaptic Events in Hippocampal Neurons,” The Journal of Neuroscience Vol.6, No. 10 (1986): 2915–20, http://www.jneurosci.org/cgi/reprint/6/10/2915

110.) M. Bhatnagar, P. Rao, J. Sushma, and R. Bhatnagar, “Neurotoxicity of Fluoride: Neurodegeneration in Hippocampus of Female Mice,” Indian Journal of Experimental Biology Vol.40, No. 5 (2002): 546–54.

11.) Z. Zhang, X. Shen, and X. Xu, “Effects of Selenium on the Damage of Learning-Memory Ability of Mice Induced by Fluoride” (article in Chinese), Wei Sheng Yan Jiu Vol.30, No. 3 (2001): 144-46.

112.) G. van der Voet, O. Schijns, and F. de Wolff, “Fluoride Enhances the Effect of Aluminium Chloride on Interconnections Between Aggregates of Hippocampal Neurons,” Archives of Physiology and Biochemistry Vol.107, No. 1 (1999): 15–21.

113.) Z. Zhang, X. Xu, X. Shen, and X. Xu, “Effect of Fluoride Exposure on Synaptic Structure of Brain Areas Related to Learning-memory in Mice,” Fluoride Vol.41, No. 2 (2008): 139–43 (originally published in 1999 in Journal of Hygiene Research [China]), http://www.fluorideresearch.org/412/files/FJ2008_v41_n2_p139-143.pdf

114.) W. Zhu, J. Zhang, and Z. Zhang, “Effects of Fluoride on Synaptic Membrane Fluidity and PSD-95 Expression Level in Rat Hippocampus,” Biological Trace Element Research, March 2010.

115.) M. Pereira, P. Dombrowski, E. Losso, et al., “Memory Impairment Induced by Sodium Fluoride Is Associated with Changes in Brain Monoamine Levels,” Neurotoxicity Research, December 2009.

116.) M. Zhang, A. Wang, T. Xia, and P. He, “Effects of Fluoride on DNA Damage, S-phase Cell-cycle Arrest and the Expression of NF-KappaB in Primary Cultured Rat Hippocampal Neurons,” Toxicology Letters Vol.179, No. 1 (2008): 1–5.

117.) T. Xia, M. Zhang, W. He, et al., “Effects of Fluoride on Neural Cell Adhesion Molecules mRNA and Protein Expression Levels in Primary Rat Hippocampal Neurons” (article in Chinese), Zhonghua Yu Fang Yi Xue Za Zhi Vol.41, No. 6 (2007): 475–78.

118.) M. Zhang, A. Wang, W. He, et al., “Effects of Fluoride on the Expression of NCAM, Oxidative Stress, and Apoptosis in Primary Cultured Hippocampal Neurons,” Toxicology Vol.236, No. 3 (2007): 208–16.

119.) B. Spittle, “Psychopharmacology of Fluoride: A Review,” International Clinical Psychopharmacology Vol.9, No. 2 (1994): 79–82.

120.) P. Grandjean, P. Landrigan, ‘Neurobehavioural Effects of Developmental Toxicity,’ The Lancet Neurology Vol. 13, No. 3 (March 2014):330-8.
http://www.thelancet.com/journals/laneur/article/PIIS1474-4422%2813%2970278-3/abstract

See also: P. Grandjean and P. Landrigan, “Developmental Neurotoxicity of Industrial Chemicals,” The Lancet Vol.368, No. 9553 (2006): 2167–78.

RISK, REVERENCE OF LIFE & ETHICS

1.) Rachel Carson, Silent Spring, 1962. Pg. 243.
2.) Center for Disease Control, “Prevalence and Severity of Dental Fluorosis in the United States, 1999-2004.” http://www.cdc.gov/nchs/data/databriefs/db53.htm#summary

3.) World Health Organization, ‘Water-related diseases: Fluorosis.’ Online. ‘Ingestion of excess fluoride, most commonly in drinking-water, can cause fluorosis which affects the teeth and bones.’ http://www.who.int/water_sanitation_health/diseases/fluorosis/en/
4.) National Treasury Employee’s Union 280, Coalition of Environmental Protection Agency Unions, ‘EPA Union of Scientists.’ “Why EPA Union of Scientists Oppose Water Fluoridation.”
5.) Approved Drug Products and Legal Requirements, Volume III of USP Dispensing Information, US Pharmacopeial Convention, 2004. 24th Edition. Tauton, MA: Quebecor World. ISBN 1-56363-465-1. Pg. III/1, “The Federal Food, Drug and Cosmetic Act of 1938 require that drugs be shown to meet certain safety requirements prior to their being marketed. Drugs that were already being marketed at that time were ‘grandfathered,’ and were allowed to remain on the market without further regulatory approval… The following listing identifies drug products that we believe were considered ‘pre-1938’ or ‘grandfathered’… Sodium Fluoride (Solution, Oral + Tablets).”
6.) “Dose-Response Relationships in Toxicology,” Pesticide Information Project, Extension Toxicology Network. http://pmep.cce.cornell.edu/profiles/extoxnet/TIB/dose-response.html

7.) Rachel Carson, Silent Spring, 1962. Pg. 18
8.) EPA Report: ‘1990 Report to Congress on Special Waste Mining.’ Office of Solid Waste to US Congress, July 23, 1990. www.epa.gov/compliance/resources/reports/…/1990rpttocongress.pdf

9.) National Sanitary Foundation International on documented impurities in fluoridation chemicals, as linked to by Center for Disease Control, “Fluoridation Fact Sheet.” “Fluoride additives are analyzed for impurities that have been identified as having the potential to occur. Those impurities include arsenic, lead and radionuclides.”   http://www.cdc.gov/fluoridation/factsheets/engineering/wfadditives.htm
10.) Citation #6

11.) World Health Organization, ‘Air Quality Guidelines for Europe,’ 2000. Second Edition, WHO Regional Publications, No. 91. Pg. 4, “The toxicity of fluorides…”
http://www.euro.who.int/__data/assets/pdf_file/0018/123075/AQG2ndEd_6_5Fluorides.PDF
12.) An 11.5 fl. oz. glass of fluoridated water at the “optimal” level of 0.7ppm contains the exact same quantity of fluoride as the recommended “pea size” amount of fluoride toothpaste. FLUORIDATED WATER ratio — 0.7 units fluoride : 1,000,000 units water, or 0.7 parts per million, 0.7ppm

glass of water = about 11.5 fluid ounces (fl oz)

1 fl oz = about 30 milliliters (mL)

Distilled water at 40 degrees Fahrenheit: density of water is 1 gram/mL or 1 g/mL

\ 11.5 fl oz glass of fluoridated water x 30mL/fl oz x 1g/mL =
mass of glass of fluoridated water = about 345 grams = 345,000 milligrams (mg)

fluoridated water ratio is 0.7 units : 1,000,000 units

0.7/1,000,000 = x/345,000

x= ~0.25 mg fluoride

FLUORIDE TOOTHPASTE ratio — 1,000 units fluoride : 1,000,000 other toothpaste ingredients =1,000:1,000,000, which is 1,000ppm or, 1:1,000

Pea size amount of toothpaste is about 0.25 grams (g)

http://www.washington.edu/earlychildhood/faqs/childrens-oral-health-faqs

\ mass of pea size toothpaste = 0.25 g

1/1,000 = x/0.25

x= ~0.00025 g of fluoride

1,000 milligrams (mg) for every gram (g)

0.00025g x 1,000mg/g

x= ~0.25 mg fluoride
13.) U.S. Code of Federal Regulations, Title 21, Volume 5, Part 355, Subpart C: Warning Labeling. Online. Accessed September, 2013. http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfCFR/CFRSearch.cfm?fr=355.50
14.) Center for Disease Control, see “Fluoridation Policy Tool.” http://www.cdc.gov/fluoridation/index.htm
15.) Fluoride Action Network, “Professional Statement to End Water Fluoridation,” http://fluoridealert.org/researchers/professionals-statement/
16.) Ibid. Citation #15.
17.) National Treasury Employee’s Union 280, Coalition of Environmental Protection Agency Unions, ‘EPA Union of Scientists.’ “Why EPA Union of Scientists Oppose Water Fluoridation.” www.nteu280.org

18.) Citation #15.
19.) International Academy of Oral Medicine & Toxicology, http://iaomt.org/wp-content/uploads/article_IAOMT-Fluoridation-Position.pdf

20.) Citation #15.
21.) Citation #15.
22.) Ursula K. LeGuin, “Those Who Walk Away From Omelas,” Short Story, 1973.
23.) E. Bassin, D. Wypij, R. Davis, M. Mittleman, “Age-Specific Fluoride Exposure in Drinking Water and Osteosarcoma (United States),” Cancer Causes and Control Vol.17, No.4 (May 2006): 281-82.
24.) J. Doull, interviewed by D. Fagin, “Second Thoughts on Fluoride,” Scientific American, 298, no. 1 (January 2008): 74-81. Pg. 80-1.View Preview: http://www.scientificamerican.com/article/second-thoughts-on-fluoride/
See also: NRC, “Fluoride in Drinking Water,” 2006. Pg. 336, ‘Osteosarcoma is of particular concern as a potential effect of fluoride…”
25.) NRC, “Fluoride in Drinking Water,” 2006. Pg. 317.

26.) Open letter from Professor Trevor Sheldon, chair of the Advisory Group for the York Review, and founding director of the UK National Health Service’s Centre for Reviews and Dissemination at the University of York, Heslington, York, UK, January 3, 2001, [bold in original] http://www.appgaf.org.uk/archive/archive_letter_shel/.
See also: “What the ‘York Review’ on the Fluoridation of Drinking Water Really Found,” University of York Centre for Reviews & Dissemination, October 28, 2003. http://www.york.ac.uk/inst/crd/fluoridnew.htm
27.) Citation #15.
28.) D. Locker, M. McNally, J. Downie, H. Cohen, “The Science and Ethics of Water Fluoridation,” Journal of the Canadian Dental Association, Vol.67, No.10 (2001):578-80. http://cof-cof.ca/wp-content/uploads/2012/02/Cohen-and-Locker-The-Science-And-Ethics-Of-Water-Fluoridation-Journal-Canadian-Dental-Association-2001-6710578-80.pdf
29.) P. Clein, “How Can It Be Ethical To Be Putting Industrial Waste In Our Drinking Water?” Pharmaceutical Journal Vol. 271 (August 2003). Pg. 234.

30.) European Union Panel on Dietetic Products, Nutrients and Allergies, Affiliated with the European Food Safety Authority, Scientific Committee on the Status of Dietary Reference Values for Fluoride. Requested by European Commission. EFSA Journal. Issue 11, No. 8 (Aug 2013). Pg. 3332. ‘Fluoride is not an essential nutrient.’ This sentence is viewable online: http://www.efsa.europa.eu/en/efsajournal/pub/3332.htm

See also: U.S. Federal Register, Volume 60, Number 249. Rules and Regulations, 21 CFR, Part 101. Docket NO. 90N-0134, RIN 0910-AA19. Department of Health and Human Services, Food and Drug Administration, “FDA Food Labeling: Reference Daily Intakes.” December 28, 1995. Last sentence of Section II: “Consistent with the vast majority of comments, FDA is adopting these values [Daily Values, i.e. Dietary Reference Intakes, for essential nutrients] except the value for fluoride, as explained below.”
31.) Agency for Toxic Substances & Disease Registry, ‘Toxicological Profiles of Fluoride.’ Reference Dosage (RfD): Dental Fluorosis: 0.06mg/kg/day
Maximum Residue Limit (MRL): Bone Fracture: 0.05/mg/kg/day

www.atsdr.cdc.gov/toxprofiles/tp11-c8.pdf

Also viewable at EPA’s Integrated Risk Information System: http://www.epa.gov/iris/subst/0053.htm

See also: National Academy of Sciences, National Research Council, ‘Fluoride in Drinking Water: A Scientific Review of EPA’s Standards.’ Washington, DC: National Academies Press, 2006. Pg. 29, Infants with average water consumption: range of dosage is 0.042 to 0.072mg/kg/day. Infants with above average water consumption: range of dosage is 0.084 to 0.14mg/kg/day. http://www.nap.edu/openbook.php?record_id=11571

32.) NRC, “Fluoride in Drinking Water,” 2006. Pg. 23, “The National Research Council’s (NRC’s) 1993 review of the health effects of ingested fluoride reported estimates of average daily fluoride intake from the diet of 0.04-0.07 milligrams per kilogram (mg/kg) of body weight for young children in an area with fluoridated water (fluoride concentration in drinking water, 0.7-1.2 mg per liter [L]; NRC 1993)…. The fluoride intake from toothpaste or mouth rinse by children with good control of swallowing, assuming twice-a-day use, was estimated to equal the intake from food, water, and beverages.”
33.) Environmental Protection Agency Pesticide Registration Review, ‘EPA Proposes to Withdraw Sulfuryl Fluoride Tolerances.’ http://www.epa.gov/pesticides/sulfuryl-fluoride/evaluations.html

34.) U.S. Department of Agriculture, “USDA National Fluoride Database of Selected Beverages and Foods,” 2004. Prepared by Nutrient Data Laboratory, Beltsville Human Nutrition Research Center, Agricultural Research Service, USDA; in collaboration with University of Minnesota, Nutrition Coordinating Center; University of Iowa, College of Dentistry; Virginia Polytechnic Institute and State University, Food Analysis Laboratory Control Center; National Agricultural Statistics Service, CSREES, USDA; and Food Composition Laboratory, Beltsville Human Nutrition Research Center, Agricultural Research Service. See: https://library.villanova.edu/Find/Record/817953/Details

35.) Fluorine in Agriculture, 1995. Edited by R. Banks, University of Manchester. Pg. 3, Shell trademarked a fluoride based insecticide and rodenticide. Dow has trademarked a fluoride based herbicide, and DuPont, fluoride fungicide. Google eBook.
36.) Carbonated Beverages and Fruit Juices, especially Grape

A.) J. Heilman, M. Kiritsy, S.M. Levy, J.S. Wefel, “Assessing Fluoride Levels of Carbonated Soft Drinks,” Journal of the American Dental Association, Vol. 130, No.11 (Nov 1999): 1593-95. 332 soft drinks, ranged from 0.02ppm to 1.28, with mean of 0.72. “Fluoride levels exceeded 0.6ppm for 71% of the products.”
B.) J. Shannard, Y. Shim, M. Kritsineli, P. Labropoulou, A. Tsamtsouris, “Fluoride Levels and Fluorides Contamination of Fruit Juices,” Journal of Clinical Pediatric Dentistry, Vol. 16, No.1 (Fall 1991): 38-40. 42% of 43 samples had more than 1ppm fluoride. “Since it is a common practice to use fluoride-containing insecticide in growing grapes, it is believed that contamination of these juices is occurring.” Abstract. Range from 0.15 to 6.8ppm. Top three highest fluoride juices: Welch’s brand 100% grape juice 2.6ppm, Minute Maid brand white grape, 3, Gerber brand white grape, 6.8.

37.) Teas, for some reason, take in and store more fluoride than other plants.

A.) M. Whyte, “Fluoride Levels in Bottled Teas,” The American Journal of Medicine Vol. 119, No. 2 (2006): 189–90.

B.) M. Whyte, W. Totty, V. Lim, and G. Whitford, “Skeletal Fluorosis from Instant Tea,” Journal of Bone and Mineral Research Vol. 23, No. 5 (2008): 759–69.

C.) J. Hallanger Johnson, A. Kearns, P. Doran, et al., “Fluoride-Related Bone Disease Associated with Habitual Tea Consumption,” Mayo Clinic Proceedings Vol. 82, No. 6 (2007): 719–24. Note: Erratum on dosage error in article text in: Mayo Clinic Proceedings 82, no. 8 (2007): 1017 http://www.mayoclinicproceedings.com/content/82/6/719.full

38.) Chicken: N. Fein, F. Cerklewski, “Fluoride Content of Foods Made with Mechanically Separated Chicken,” Journal of Agricultural Food Chemistry Vol. 49, No.9 (Sept 2001): 4284. “A single serving of chicken sticks alone would provide about half of a child’s upper limit of safety for fluoride.”

39.) Infant Food

  1. Heilman, M. Kiritsy, S. Levy, J. Wefel, “Fluoride Concentrations of Infant Foods,” Journal of the American Dental Association, Vol. 128 (July 1, 1997): 857-863. 0.01 to 8.38 micrograms per gram, with highest fluoride concentrations found in infant foods containing chicken.

40.) Federal Register Volume 67, Number 79 (Wednesday, April 24, 2002), Environmental Protection Agency, “Notice of Filing a Pesticide Petition to Establish a Tolerance for a Certain Pesticide Chemical in or on Food.” E.g., Fluoride Pesticide Residue Tolerance: 10ppm on Apricots, 15ppm on Kiwi, Up to 35ppm on Kale. http://www.gpo.gov/fdsys/pkg/FR-2002-04-24/html/02-9655.htm

41.) Center for Disease Control, “Prevalence and Severity of Dental Fluorosis in the United States, 1999-2004.” http://www.cdc.gov/nchs/data/databriefs/db53.htm#summary


CONCLUSION

1.) J. Doull, interviewed by D. Fagin, “Second Thoughts on Fluoride,” Scientific American, 298, no. 1 (January 2008): 74-81. Pg. 80-1.View Preview: http://www.scientificamerican.com/article/second-thoughts-on-fluoride/
2.) Open letter from Professor Trevor Sheldon, chair of the Advisory Group for the York Review, and founding director of the UK National Health Service’s Centre for Reviews and Dissemination at the University of York, Heslington, York, UK, January 3, 2001, [bold in original] http://www.appgaf.org.uk/archive/archive_letter_shel/.

3.) National Treasury Employee’s Union 280, Coalition of Environmental Protection Agency Unions, ‘EPA Union of Scientists.’ “Why EPA Union of Scientists Oppose Water Fluoridation.” www.nteu280.org

4.) National Cancer Institute, http://www.cancer.gov/cancertopics/factsheet/Risk/fluoridated-water [emphasis added]
5.) Rachel Carson, Silent Spring, 1963. Pg. 83.
6.) Pg. 84.

7.) Pg. 100.
8.) Pg. 114.

9.) Pg. 86.

10.) J. Colquhoun, “Why I Changed My Mind About Water Fluoridation,” Perspectives on Biological Medicine, Vol.41, No.1 (Autumn 1997):29-44. Available at: http://www.fluoridation.com/colquhoun.htm
11.) J. Colquhoun, “Education and Fluoridation in New Zealand: An Historical Study,” Ph.D. Dissertation, University of Auckland, New Zealand, 1987.
12.) Thomas Kuhn, “Structure of Scientific Revolutions,” 1962. Second Edition. Chicago, IL: University of Chicago Press.
13.) Ibid. Pg. 6.
14.) Ibid. Pg. 6.

15.) Ibid. Pg. 2.
16.) Michael Crichton, https://www.cfa.harvard.edu/~scranmer/SPD/crichton.html

17.) “How Silent Spring Ignited the Environmental Movement,” Bryan Walsh, Time Magazine, September 25, 2012. http://science.time.com/2012/09/25/how-silent-spring-became-the-first-shot-in-the-war-over-the-environment/

18.) Rachel Carson, Silent Spring, 1962. Pg. 29.

19.) Environmental Defense Fund, “25 Years After DDT, Bald Eagles, Osprey Numbers Soar; Ban Credited with Resurgence in Nation’s Symbol,” June 13, 1997. http://www.edf.org/news/25-years-after-ddt-ban-bald-eagles-osprey-numbers-soar

20.) Scientific American, May 2013. http://blogs.scientificamerican.com/but-not-simpler/2013/05/22/why-portland-is-wrong-about-water-fluoridation/

21.) P. Grandjean, P. Landrigan, ‘Neurobehavioural Effects of Developmental Toxicity,’ The Lancet Neurology Vol. 13, No. 3 (March 2014):330-8.
http://www.thelancet.com/journals/laneur/article/PIIS1474-4422%2813%2970278-3/abstract

See also: P. Grandjean and P. Landrigan, “Developmental Neurotoxicity of Industrial Chemicals,” The Lancet Vol.368, No. 9553 (2006): 2167–78.

See also: Fluoride Action Network, “IQ: The 39 Studies.” http://fluoridealert.org/studies/brain01/

22.) D.W. Cross, R.J. Carton, “Fluoridation: A violation of Medical Ethics and Human Rights,” International Journal of Occupational Environmental Health 9, no. 1 (Jan-March 2003): 24-9.
23.) Letter to Honorable Ken Calvert, Chairman, Subcommittee on Energy and Environment, Committee on Science, US House of Representatives, regarding FDA’s response to a Congressional Investigation about fluoride and fluoridation, from Melinda K. Plaisier, FDA Associate Commissioner for Legislation. December 21, 2000. “Fluoride, when used in the diagnosis, cure, mitigation, or prevention, of disease in man or animal, is a drug that is subject to FDA regulation […] Several NDAs [New Drug Applications] have been approved for fluoride topical products such as dentrifices and gels.” http://www.keepersofthewell.org/gov_resp_pdfs/fda_response.pdf

24.) Petition to Environmental Protection Agency Administer Robert Perciasepe, from Dr. William Hirzy, on behalf of co-petitioners. Request for EPA to prohibit silicofluorides and unpurified sodium fluoride as fluoridating agents due to arsenic contamination; Request to mandate pharmaceutical grade sodium fluoride. April 22, 2013. Pg. 2, and 17. http://www2.epa.gov/aboutepa/hfsa-section-21-petition

25.) National Sanitary Foundation International on documented impurities in fluoridation chemicals, as linked to by Center for Disease Control, “Fluoridation Fact Sheet.” “Fluoride additives are analyzed for impurities that have been identified as having the potential to occur. Those impurities include arsenic, lead and radionuclides.”   http://www.cdc.gov/fluoridation/factsheets/engineering/wfadditives.htm

26.) EPA Report: ‘1990 Report to Congress on Special Waste Mining.’ Office of Solid Waste to US Congress, July 23, 1990. www.epa.gov/compliance/resources/reports/…/1990rpttocongress.pdf

27.) Center for Disease Control. “Engineering Fact Sheet.” http://www.cdc.gov/fluoridation/fact_sheets/engineering/wfadditives.htm#2

28.) Petition to Environmental Protection Agency Administer Robert Perciasepe, from Dr. William Hirzy, on behalf of co-petitioners. Request for EPA to prohibit silicofluorides and unpurified sodium fluoride as fluoridating agents due to arsenic contamination; Request to mandate pharmaceutical grade sodium fluoride. April 22, 2013. Pg. 2, and 17. http://www2.epa.gov/aboutepa/hfsa-section-21-petition

29.) National Research Council of the National Academy of Sciences, ‘Fluoride in Drinking Water,’ 2006. Washington DC, National Academies Press. Pg. 15, “The most commonly used [drinking water] additives are silicofluorides, not the fluoride salts used in dental products (such as sodium fluoride and stannous fluoride). Silicofluorides are one of the by-products from the manufacture of phosphate fertilizers.” http://www.nap.edu/catalog.php?record_id=11571

30.) Thomas G. Reeves, P.E., National Fluoridation Engineer, Program Services Branch Division of Oral Health, National Center for Chronic Disease Prevention and Health Promotion, Center for Disease Control and Prevention. Refer: FL-143, September 2000. “All of the fluoride chemicals used in the U.S. for water fluoridation, sodium fluoride, sodium fluorosilicate, and fluorosilicic acid, are useful byproducts of the phosphate fertilizer industry… These gases are captured by product recovery units (scrubbers) and condensed into 23% fluorosilicic acid. Sodium fluoride and sodium fluorosilicate are made from this acid.”

31.) U.N. International Programme on Chemical Safety and European Commission classify Fluorosilicic acid as Hazardous Waste: UN Class 8 – Corrosive substance. EC Classification: Symbol: C – Corrosive substance Disposal: “Do NOT let this chemical enter the environment.” http://www.inchem.org/documents/icsc/icsc/eics1233.htm

32.) Ibid., Sodium Fluorosilicate as Hazardous Waste: UN Hazard Class: 6.1 – Toxic substance. EC Classification: Symbol: T – Toxic substance. Labeling: “Signal: Danger, Toxic if swallowed [skull and crossbones symbol].” http://www.inchem.org/documents/icsc/icsc/eics1243.htm

33.) Ibid. Sodium Fluoride as Hazardous Waste: UN Hazard Class: 6.1 – Toxic substance. EC Classification: Symbol: T – Toxic substance. http://www.inchem.org/documents/icsc/icsc/eics0951.htm

34.) EPA’s classifications of Hydrofluorosilicic acid, Sodium Fluorosilicate, Sodium Fluoride: all fluorides are CERCLA Waste Substances from Superfund Sites: ‘severely harmful to human health and the environment.’ www.epa.gov/osweroe1/docs/er/302table01.pdf. *Hydrofluoric acid is the aqueous form of hydrogen fluoride, which is the gaseous form; both are classified under the same CASRN number, 7664393.

35.) Letter to Commissioner Jane Henry, Food and Drug Administration, from John Kelly, New Jersey Assemblyman, 36th district, October 26, 2000. “I am petitioning the FDA to remove unapproved children’s fluoride supplements from the market… I filed a Freedom of Information Act request with the FDA to obtain copies of the studies the FDA had used in evaluating the safety and effectiveness of these products. I was shocked when the FDA informed me that the FDA had no such studies and that children’s fluoride supplements were not approved…. The last time the FDA reviewed an NDA for fluoride supplements was in 1975 and that NDA was rejected.”

36.) Letter to Honorable Ken Calvert, from Melinda K. Plaisier, FDA. “No New Drug Applications have been approved for fluoride drugs meant for ingestion… Fluoride products meant for ingestion were in use prior to the enactment [of the Kefauver-Harris Amendments (Drug Amendments of 1962) to the Food, Drug and Cosmetic Act [of 1938], in which efficacy in addition to safety became a requirement for drugs marketed in the U.S.”
See also: Approved Drug Products and Legal Requirements, Volume III of USP Dispensing Information, US Pharmacopeial Convention, 2004. 24th Edition. Tauton, MA: Quebecor World. ISBN 1-56363-465-1. Pg. III/1, “The Federal Food, Drug and Cosmetic Act of 1938 require that drugs be shown to meet certain safety requirements prior to their being marketed. Drugs that were already being marketed at that time were ‘grandfathered,’ and were allowed to remain on the market without further regulatory approval… The following listing identifies drug products that we believe were considered ‘pre-1938’ or ‘grandfathered’… Sodium Fluoride (Solution, Oral + Tablets).”

37.) Food and Drug Administration, “FDA Approved Drug Products Database.” Online. http://www.accessdata.fda.gov/scripts/cder/drugsatfda/index.cfm One will note there are no systemic approvals. See also: National Institute of Health’s “DailyMed Current Medication Information” Database of Currently Marketed Drugs, including whether or not a drug is FDA approved. http://dailymed.nlm.nih.gov/dailymed/search.cfm?startswith=fluoride&x=0&y=0

38.) D.W. Cross, R.J. Carton, “Fluoridation: A Violation of Medical Ethics and Human Rights,” International Journal of Occupational Environmental Health Vol.9, No. 1 (Jan-March 2003): 24-9. “Silicofluorides have never been submitted to the US FDA for approval as medications.”

39.) Safe Drinking Water Act, 42 US Code § 300g-1. Section 11. http://www.law.cornell.edu/uscode/text/42/300g-1
See also: D. Cross, R. Carton, “Fluoridation: A Violation of Medical Ethics and Human Rights,” International Journal of Occupational Environmental Health, Vol.9, No.1 (Jan-Mar 2003):24-9.

See also: Nuremberg Code of Medical Ethics: http://www.ushmm.org/information/exhibitions/online-features/special-focus/doctors-trial/nuremberg-code

See also: United Nation’s Council of Europe’s Biomedical Convention of 1999, http://conventions.coe.int/Treaty/en/Treaties/Html/164.htm

40.) Center for Disease Control, “Prevalence and Severity of Dental Fluorosis in the United States, 1999-2004.” http://www.cdc.gov/nchs/data/databriefs/db53.htm#summary

41.) NRC, “Fluoride in Drinking Water,” 2006. Pg. 29, Infants with average water consumption: range of dosage is 0.042 to 0.072mg/kg/day. Infants with above average water consumption: range of dosage is 0.084 to 0.14mg/kg/day. http://www.nap.edu/openbook.php?record_id=11571

See also: Agency for Toxic Substances & Disease Registry, ‘Toxicological Profiles of Fluoride.’ Reference Dosage (RfD): Dental Fluorosis: 0.06mg/kg/day
Maximum Residue Limit (MRL): Bone Fracture: 0.05/mg/kg/day

www.atsdr.cdc.gov/toxprofiles/tp11-c8.pdf

Also viewable at EPA’s Integrated Risk Information System: http://www.epa.gov/iris/subst/0053.htm

42.) NRC, ‘Fluoride in Drinking Water,’ 2006. Pg. 23, ‘The fluoride intake from toothpaste or mouth rinse by children with good control of swallowing, assuming twice-a-day use, was estimated to equal the intake from food, water, and beverages.’ [emphasis added]. See also: Dental Products E. Bentley, R. Ellwood, and R. Davies, “Fluoride Ingestion from Toothpaste by Young Children,” British Dental Journal 186, no. 9 (1999): 460–62.

43.) Pesticides on All Sorts of Foods. U.S. Department of Agriculture, “USDA National Fluoride Database of Selected Beverages and Foods,” 2004. Prepared by Nutrient Data Laboratory, Beltsville Human Nutrition Research Center, Agricultural Research Service, USDA; in collaboration with University of Minnesota, Nutrition Coordinating Center; University of Iowa, College of Dentistry; Virginia Polytechnic Institute and State University, Food Analysis Laboratory Control Center; National Agricultural Statistics Service, CSREES, USDA; and Food Composition Laboratory, Beltsville Human Nutrition Research Center, Agricultural Research Service. See: https://library.villanova.edu/Find/Record/817953/Details

44.) Department of Health and Human Services and Environmental Protection Agency, ‘News Release: EPA & DHHS Announce New Scientific Assessments and Actions on Fluoride.’ January 7, 2011. http://yosemite.epa.gov/opa/admpress.nsf/3881d73f4d4aaa0b85257

359003f5348/86964af577c37ab285257811005a8417!OpenDocument

45.) NRC, ‘Fluoride in Drinking Water,’ 2006. Pg. 2, “After reviewing the collective evidence, including studies conducted since the early 1990s, the committee concluded unanimously that the present MCLG of 4mg/L for fluoride should be lowered.” See also: Pg. 10, “Lowering the MCL will prevent children from developing severe dental fluorosis and will reduce the lifelong accumulation of fluoride into bone that the majority of the committee believes is likely to put individuals at increased risk of bone fracture and possibly skeletal fluorosis.”
46.) NRC. “Fluoride in Drinking Water,” 2006.

Bone Cancer: “Fluoride appears to have the potential to initiate or promote cancer, particularly of the bone,” Pg. 336. “Osteosarcoma is of particular concern as a potential effect of fluoride…” Pg. 336. “Bone is the most plausible site for cancer associated with fluoride,” Pg. 9.

47.) Ibid. Neurotoxin: “It is apparent fluorides have the ability to interfere with the functions of the brain,” Pg. 222.
48.) Endocrine Disruptor: “Fluoride is therefore an endocrine disruptor,” Pg. 266.

49.) Thyroid: “Several lines of information indicate an effect of fluoride exposure on thyroid function,” Pg. 234.
50.) Immune System: “There is no question that fluoride can affect the cells involved in providing immune responses,” Pg. 295.

51.) Down’s Syndrome: “Down’s syndrome is a biologically plausible outcome of exposure,” Pg. 197.

52.) Diabetes: “Sufficient fluoride exposure appears to bring about increases in blood glucose or impaired glucose intolerance in some individuals and to increase the severity of some types of diabetes,” Pg. 260.

53.) Kidney Dysfunction: “Portions of the renal system may therefore be at higher risk of fluoride toxicity than most soft tissues… The effect of low doses of fluoride on kidney… functions in humans needs to be carefully documented…” Pg. 303.

54.) Fluoride Action Network, “Professional Statement to End Water Fluoridation,” http://fluoridealert.org/researchers/professionals-statement/

55.) Silent Spring, 1962. Pg. 246.

56.) J. Doull, interviewed by D. Fagin, “Second Thoughts on Fluoride,” Scientific American, 298, no. 1 (January 2008): 74-81. Pg. 80-1.View Preview: http://www.scientificamerican.com/article/second-thoughts-on-fluoride/

57.) Center for Disease Control, “Prevalence and Severity of Dental Fluorosis in the United States, 1999-2004.”

58.) World Health Organization, ‘Water-related diseases: Fluorosis.’ Online. ‘Ingestion of excess fluoride, most commonly in drinking-water, can cause fluorosis which affects the teeth and bones.’ http://www.who.int/water_sanitation_health/diseases/fluorosis/en/
59.) Silent Spring, 1962. Pg. 278.
60.) Ibid. Pg. 29.
61.) European Union Panel on Dietetic Products, Nutrients and Allergies, Affiliated with the European Food Safety Authority, Scientific Committee on the Status of Dietary Reference Values for Fluoride. Requested by European Commission. EFSA Journal. Issue 11, No. 8 (Aug 2013). Pg. 3332. ‘Fluoride is not an essential nutrient.’ This sentence is viewable online: http://www.efsa.europa.eu/en/efsajournal/pub/3332.htm
62. J. Luke, “Fluoride Deposition in the Aged Human Pineal Gland,” Caries Research Vol.35, No. 2 (2001): 125–28.

Ibid. Pg. 32.
63.) Ibid. Pg. 4.

64.) Ibid. Pg. 278.

65.) CDC, Morbidity & Mortality Weekly Report, 1999. Vol. 48: 933-40. “Fluoride’s caries-preventative properties initially were attributed to changes in enamel during tooth development… However, laboratory and epidemiological research suggests fluoride prevents dental caries predominately after eruption of the tooth, and its action primarily are topical for both adults and children.”
See also: http://www.cdc.gov/Mmwr/preview/mmwrhtml/rr5014a1.htm

66.) Bryson, Christopher, “Fluoride Deception,” 2004. New York, NY: Seven Stories Press.

67.) U.N. International Programme on Chemical Safety classify Sodium Fluoride as Hazardous Waste: UN Hazard Class: 6.1 – Toxic substance. EC Classification: Symbol: T – Toxic substance. Labeling: “Signal: Danger, Toxic if swallowed [skull and crossbones symbol].” http://www.inchem.org/documents/icsc/icsc/eics1243.htm

68.) Ibid. Disposal: “Do NOT let this chemical enter the environment.”
69.) Silent Spring, 1962. Pg. 278.

Table of Contents


Introduction
I. Clean Water For Health: En Vivo Veritas, En Aqua Sanitas,
II. Fluoride as a Pesticide, Air Pollutant, Water Contaminant, Greenhouse Gas & Regulated as Hazardous Industrial Waste,
III. Fluoride as a Drug: Not FDA Approved for Ingestion, Not Essential Nutrient & Bio-accumulative in Body,
IV. Public Water; Public Right to Know,
V. Science Speaks For Itself: “Questions Unsettled; We Need to Take a Fresh Look,”
Thesis: “The purpose of this research is to allow the science to speak for itself; thus it is written de facto so as to allow the reader to determine whether recent science supports health risks because you have this authority as a rational being.”


Section 1. The “Power and Nature” of The Chemical Itself: Fluoride, Fluorine & Fluoridation
I. Fluoride Classified as a Drug: Pharmaceutical Grade Fluoride in Toothpaste,
II. FDA Approved Topical Use versus Non-Approved Systemic Ingestion,
III. Fluoridation with Industrial By-Products,
IV. Otherwise Air Pollution Known to Cause Human Illness,
V. Regulated as Hazardous Waste,
VI. Contaminated Fluoridation Chemicals & Fluoride as Water Contaminant,
VII. Violation of the Safe Drinking Water Act: Prohibition of Drugs in Public Water,


Section 2. Through a Narrow Window:
Concentration versus Dosage & Margin of Safety
I. Dosage versus Concentration,
II. When a Drug is in the Water, Dosage Varies,
III. Response Effect Varies due to Sensitivity,
IV. The Concept of Range from Natural Variation,
V. Unknown Effect on the Individual & Uncontrollable Dosage,
VI. Range Per Concentration Level & Margin of Safety,
VII. Concern for the Most Sensitive Individual: The Infant,
VIII. Margin of Safety as a Metaphor,
IX. Infants Exceed Minimum Adverse Dosages at the “Recommended” “Optimal” Concentration,
X. No Space for Comfort: Inadequate Margin of Safety,
XI. The New “Optimal:” Feds Reduce the “Recommended” Concentration,
XII. Too Close for Comfort: How Much Space for Safety?


Section 3. The Science Itself: Recently Documented Health Effects
2006 National Research Council Systematic Review “Fluoride in Drinking Water”
I. NRC Recommends EPA Reduce Maximum Contaminant Level of Fluoride, Known Adverse Health Risks,
II. Bio-Accumulation & Fluoride’s Affinity to Calcium: Dental Fluorosis, Bone Fracture & Skeletal Fluorosis,
III. Osteosarcoma: “Fluoride Appears to Initiate or Promote Cancers, Particularly of Bone,”
IV. The Bassin Study: Water Fluoridation & Osteosarcoma in Young Male Children,
V. Intelligence Quotient: “Fluoride’s Apparent Ability to Interfere with Brain Function,”


Section 4. Risk, Reverence of Life & The Ethics of Water Fluoridation
I. Reverence of Life, Individual Medical Consent & Dose Makes the Poison?
II. Calculated Risk & The Lack of Scientific Consensus: Probably Safer & Healthier to Simply Drink Clean Water,
III. Those Who Walk Away: Epistemic Uncertainty, Bioethics & Care Duty,
IV. The Other Road: Risk, Reverence of Life & The Precautionary Principle,
V. “Legitimate Scientific Controversy,” Says Chairman of “York Review,”


Conclusion Speaks for Itself: Res Ipsa Loquitur
Clean Water is Healthy, Safe & Effective
I. The Lack of Scientific Consensus: EPA Toxicologists versus CDC Dentists,
II. Truth & Human Motivation,
III. Scientific Revolution & Science as Tentative,
IV. The Paradigm Shift: Breaking Away from Consensus: Why Portland, Oregon Voted No,
V. Living Downstream: “The Solution is Biological, Not Chemical,”


Bibliography
I. Introduction,
II. The Chemical Itself,
III. Dosage versus Concentration & Margin of Safety,
IV. The Science Itself,
V. The Ethics of Water Fluoridation,
VI. Conclusion.

Preface: Paradigms

“‘Paradigms,’ a term that relates closely to ‘Normal Science…’
Normal Science is predicated on the assumption
that the scientific community knows what the world is like.
Much of the success of the enterprise
derives from the communities willingness to defend the assumption,
if necessary at considerable cost.
No part of the aim of normal science is to call forth new sets of phenomena;
Indeed, scientists are often intolerant of new theories that do not fit the box.
Normal science, for example, often suppresses novelties
because they are necessarily subversive of its basic commitments.
Nevertheless, so long as those commitments
retain an element of the arbitrary,
the very nature of normal science
ensures novelty shall not be suppressed for very long…

History suggests the road to a firm research consensus is extraordinarily arduous… And History, we too often say, is a purely descriptive discipline…

This essay attempts to show that
we have been misled by them in fundamental ways.
Its aim is a sketch of a quite different concept of science
that can emerge from the historical record of the research activity itself…

To desert the Paradigm is to
cease practicing the science it defines.
We shall see that such desertions do occur…”

Dr. John Colquhoun,
Former Proponent of Water Fluoridation,
Former Principle Dental Officer of Auckland, New Zealand,
Author of “Why I Changed My Mind on Water Fluoridation,”
Wrote his PhD Dissertation about Water Fluoridation based on…

–The Structure of Scientific Revolutions by Dr. Thomas Kuhn,
Volume I-II of the Encyclopedia of the Foundations of the Unity of Science.
(the book that coined the term ‘paradigm-shift’)

The Recent Science, Chemistry & Ethics of Water Fluoridation

There is a reason why the Latin word for Health, Sanitas, is the etymological origin of the word Sanitary: En Vivo Veritas, En Aqua Sanitas; In Wine, there is Truth, In Water, Health. “The Truth,” Rachel Carson wrote in the introduction of Silent Spring, “seldom mentioned, but there for anyone to see,”1 is that one particular chemical is not only found as Pesticide Residues2-4 in the wine5-6 we drink… It is also regulated as an Air Pollutant,7-11 a Water Contaminant,12-3 banned by international treaty as a Greenhouse Gas;15 this chemical is classified as “toxic”15-6 and “corrosive”17 Hazardous Industrial Waste by the United Nations International Programme on Chemical Safety.15-7 What if I told you this chemical is intentionally added to the public drinking water of over 200 million Americans?18-23 What if I told you the Center for Disease Control (CDC) has found 41% of Children24 in this country have what the World Health Organization (WHO) has defined as a Disease25 caused by ingesting too much of this chemical in drinking water?

This chemical is neither related to disinfection of water nor is it classified as an essential nutrient;26-8 this chemical is regulated as a Drug for topical use,29-31 but it is not approved for systemic ingestion.32-5 When we ingest this chemical via food, water or wine, it is known to permanently bind with the calcium in our bodies, ultimately bio-accumulating in our teeth, bone,36-7 and other calcifying tissues like the pineal gland,38 located in the center of the brain. What are the public health implications of adding this chemical to the public drinking water of 200 million American Citizens?

“If we are to live so intimately with these chemicals – eating and drinking them, taking them into the very marrow our bones – we had better know something of their power and nature.”39 “The obligation to endure gives us the right to know.”40

Today, we know there are Health Risks related to bone fracture and a disease41 affecting the teeth and bones, called Fluorosis – both are associated with drinking water with less than 4 parts per million of fluoride.42 This is the official conclusion of the 2006 National Research Council (NRC) of the National Academies of Sciences’ systematic review entitled, “Fluoride in Drinking Water.”42 As such, the NRC recommended the Environmental Protection Agency (EPA) reduce the Maximum Contaminant Level of fluoride in drinking water. 42 Data published in this report also revealed the vast majority of infants43 exceed minimum dosages of fluoride associated with a risk of adverse health effects44when drinking water at concentrations “recommended45 as “optimal”46 by federal public health agencies since the 1950s.47 The NRC findings catalyzed the Department of Health and Human Services (DHHS) to reduce the “optimal” concentration of water fluoridation by 40%.48 For decades, up to 1.2ppm of fluoride was promoted as “safe and effective,”49 but now “safe and effective” is said to be 0.7ppm.50

Public Water, Public Right to Know

Since “it is the public that is being asked to assume the risks, the obligation to endure gives us the right to know.”51 The public has a right to know the “power and nature” of the chemical itself. We have a right to know the health effects documented by the most recent science, and the public certainly ought to know what the 2006 National Research Council of the National Academies of Sciences has concluded regarding such health effects.52 This is why this research thesis was written.

Science Speaks For Itself: “Questions Unsettled”

The purpose of this essay is to allow the science to speak for itself; thus it is written de facto so as to allow the reader to determine whether recent science supports health risks because you have this authority as a rational being. As such, this paper lacks a formal thesis structure per se, as there are no grounds for a conclusion on this matter and if there is one, the purpose is to instill a paradigm based in the humility of the precautionary principle. Therefore, this paper is not concerned with whether water fluoridation is “safe and effective.” No one cares for the fallacy of asking questions no one knows the answer to; as will be demonstrated through the science itself, there is much epistemic uncertainty with the safety of fluoridation as this “whole situation is beset with questions for which there are at present no satisfactory answers.”53

What we do know is: “many of these questions are unsettled,” and “now we need to take a fresh look,” according to the chairman of the 2006 NRC, Dr. John Doull:

“What the committee found is that we’ve gone with the status quo regarding fluoride for many years – for too long really – and now we need to take a fresh look… In the scientific community people tend to think this is settled. When the U.S. Surgeon General comes out and says this is ‘one of the top ten 10 greatest achievements of the 20th century,’ that’s a hard hurdle to get over. But when we looked at the studies that have been done, we found that many of these questions are unsettled and we have much less information than we should, considering how long this has been going on.”54 Interview in Scientific American, 2008

“We Need To Take A Fresh Look”

The whole methodology of this essay is to disseminate information; it is thus written de facto in the sections devoted to The Chemical Itself, and The Science Itself. The only exception will be the explication of Dosage versus Concentration & Margin of Safety – here, it will be self evident why the writer uses the words “suggests” or “implies.” Likewise, “should” or “ought” will certainly appear in the Ethics of Water Fluoridation section, primarily in the form of questions rather than assertions. Otherwise, this essay is intentionally devoid of such words. This is noteworthy as keeping the facts separate from commentary is the first principle of journalistic integrity. As Rachel Carson wrote: “Humbleness is in order; there is no excuse for scientific conceit here,”55 just an honest concern for public health. As such, this research thesis is an inquiry towards a matter-of-fact compendium of recent science and chemistry to inform individual knowledge, so as to engender ethical discourse related to the Common Good.

Beginning with the Chemical Itself: Fluoride, Fluorine & Fluoridation, this paper will be ordered as follows. To introduce The Chemical Itself, we shall begin by distinguishing fluoride in toothpaste from water fluoridation by Food & Drug Administration approval as it relates to topical fluoride use versus systemic ingestion as well as the purity of the fluoride product itself, as toothpaste is pharmaceutical grade, while water fluoridation is an unpurified industrial by-product.56 Given these by-products contain contaminants like lead and arsenic,57-60 fluoride is more appropriately termed fluoridation chemicals. Further discerned is that fluoridation chemicals are otherwise fluorine air pollution61-6 known to cause human illness.67-72 Hence, regulation as hazardous by the UN International Programme on Chemical Safety.73
This is followed secondly, by the conceptual foundation of a scientific paradigm based in calculated risk assessment, and so the distinction between Dosage versus Concentration as it relates to Margin of Safety is then discussed. This is intended to highlight the nuance between safe for all or adverse for some. Thirdly, the Health Effects Documented by Recent Science are presented. Specifically, the most significant findings and conclusions of the 2006 National Research Council’s systematic review, “Fluoride in Drinking Water”74 is used as the arbiter of The Science Itself.
First, the concept of Bioaccumulation is presented through Dental Fluorosis, Bone Fracture & Skeletal Fluorosis. Then, since the 2006 NRC concluded “fluoride appears to initiate or promote cancers, particularly of the bone,”75 Osteosarcoma research follows. Given, in addition, that the 2006 NRC also concluded “it is apparent that fluoride has the ability to interfere with the functions of the brain,”76 the section ends on the most recent research published on fluoride’s affects on Intelligence Quotient in children.

With the Science left to Speak for Itself, we postulate over the Ethics of Water Fluoridation in relation to reverence of life with the question: What if recent science may support the possibility of health risks? Given 41% of youth77 have fluorosis, a disease78 caused by ingesting too much fluoride, it is speculated that public health implications should be framed in terms of overexposure to a drug we would otherwise have a choice to use with toothpaste or consume with a prescription. This will lead to the principle of individual medical consent.79 Then, considering the World Health Organization states on its website that “the toxicity of fluorides is due to the toxicity of the fluoride ion, a direct cellular poison,”80 we explore the notion of whether dose makes the poison? Or, is toxicity an inherent property of the chemical itself?
Naturally, this transitions to the Lack of Scientific Consensus: Three out of 12 members on the 2006 NRC have signed Fluoride Action Network’s “Professional Statement to End Water Fluoridation.”81 Is it epistemic uncertainty about the possibility of health risks? Do they feel obligated out of a sense of Care Duty? Perhaps they believe its probably safer and healthier to simply drink clean water? This is all explored through the Precautionary Principle, which posits that we need not be 100% certain of risk, to warrant turning the knob off at the water treatment plant; for 100% certainty means we must wait to find proof of risk through finding harm. Then it is too late.

We then ponder why the Chair of another systematic review called the “York Review,” Dr. Trevor Sheldon – why has he also signed the “Professional Statement to End Water Fluoridation?”81 Why does he publicly claim a “legitimate scientific controversy” persists to this day, after 69 years of water fluoridation?82
The Ethics of Water Fluoridation is then consummated with a question:
Is it logically consistent to balance Risk with Reverence of Life? Or does this beg the question, presuming such a balance can be achieved?

The Power and Nature of the Chemical Itself: Fluoride, Fluorine & Fluoridation

Fluoride Classified as a Drug: Pharmaceutical Grade Fluoride in Toothpaste

For most of us, when we hear fluoride, we think of toothpaste. This fluoride is distinct from water fluoridation in three aspects: Food & Drug Administration (FDA) approval, purity of product, and means of consumption. Toothpaste and dentistry use FDA approved pharmaceutical grade sodium or stannous fluoride, which is regulated as a drug for topical use, meaning it works on the surface of the teeth.1-3 On the back of all fluoride toothpaste, one will see words mandated by a federal labeling law: “Warning… if more than is used for brushing is accidentally swallowed, call a poison control center right away.”4 Simple arithmetic demonstrates a “pea-size” amount of toothpaste and a glass of “optimally” fluoridated water both contain approximately 0.25mg of fluoride.5

FDA Approved Topical Use versus Non-Approved Systemic Ingestion

            Drinking a glass of fluoridated water and swallowing toothpaste are similar, in that both are systemic ingestion, however, systemic ingestion of fluoride is not FDA approved.6-8 When one uses fluoride toothpaste or when a dentist applies it to the surface of teeth, one is instructed to spit it out after use. This is FDA approved. On the other hand, fluoride intended for ingestion in the form of tablets prescribed by that dentist and those often distributed to children in public schools – this is not FDA approved.6-8 Nor have the main fluoridation chemicals – silicofluorides, ever been submitted for approval.9

Fluoridation with Industrial By-Products

Water fluoridation also does not involve pharmaceutical grade fluoride; the source of the fluoride that is added to the public drinking water is an unpurified industrial by-product of the phosphate fertilizer industry.10-13 All of the fluorides used in water fluoridation: Sodium Fluoride as well as Silicofluorides like Fluorosilicic Acid or Sodium Fluorosilicate – all industrial by-products, however predominately Silicofluorides are added to our water, as only 9% of fluoridated communities ingest sodium fluoride.14

Air Pollution Known to Cause Human Illness

Fluorides are otherwise Fluorine Air Pollution.15 Specifically, fluorine gases emitted from smokestacks, captured via water spray.16 Federal law requires mandatory reclamation17 because fluorine gases are known to harm ecosystems,18 farmers’ crops,19 the health of animals,20-1 and pose health risks to humans22 “in low ambient concentrations.”23 During the Cold War, fluorine emissions were responsible for more litigation claims against uranium, phosphate, aluminum and other metal industries24 than all other regulated air pollutants combined.25-6 At the same time, in 1955, a US district court in Oregon ruled for the first time in US history that fluorine emissions from an aluminum plant caused illness to a farmer’s family.27. In 2013, the Oregon Department of Environmental Quality fined Intel for emitting fluorine air pollution without reporting.28

Regulated as Hazardous Waste

Fluorine-emitting industrial plants have also been identified by published case studies as the cause of hundreds of cases of illness and dozens of deaths during “temperature inversions” in two valleys, in Donora, Pennsylvania, 1948,29 and in the Meuse Valley, Belgium, 1930.30 Common dictionaries define fluorine as a “highly corrosive poisonous gas, the most reactive of all elements.”31 Hence, regulation and mandatory reclamation of fluorine as air pollution. When this air pollution is captured in an aqueous solution, it is then regulated as hazardous waste by the United Nation’s International Programme on Chemical Safety,32-4 the European Union,35-7 as well as the US EPA.38 Sodium Fluoride and Sodium Fluorosilicate are both classified as “Toxic,” while Fluorosilicic Acid is classified as “Corrosive.”32-34

Contaminated Fluoridation Chemicals & Fluoride as a Water Contaminant

Fluoride Hazardous Waste is also known to contain “impurities” as Contaminants.39-41 Fluoride is thus more appropriately termed fluoridation chemicals. The CDC,39 National Sanitation Foundation40 and EPA41 cite traces of arsenic and lead as the primary contaminants. It should be noted that EPA has determined zero to be the maximum safe level of arsenic and lead in drinking water.42 According to the research of two former EPA Risk Assessment Toxicologists, the arsenic that we add to our drinking water from fluoridation chemicals could potentially cause up to 4,100 cases of cancer per year.43 In addition to lead and arsenic, there are a plethora44 of other contaminants in fluoridation chemicals; noteworthy are mercury, and radio-active substances like chromium-6. In fact, Fluoride Itself is regulated by EPA as a Water Contaminant.45

Violation of the Safe Drinking Water Act

Community Water Fluoridation is therefore the addition of a chemical that is classified as toxic, corrosive, contaminated hazardous industrial waste to our public drinking water. Technically, this is what the Oral Health Division of the Center for Disease Control “recommends” as a “safe and effective” preventative health policy to reduce tooth decay.46 Moreover, since water fluoridation is also, technically, the addition of a drug to the public drinking water, we can clearly see this policy violates the spirit of the Safe Drinking Water Act: “No national primary drinking water regulation may require the addition of any substance for preventative health care purposes.”47 For this reason, water fluoridation may also be appropriately termed mass medication.

Through a Narrow Window: Concentration versus Dosage & Margin of Safety

The Safe Drinking Water Act prohibits the addition of drugs to our public drinking water for two reasons. First, we do not know how an individual will respond to and therefore be affected as DHHS reports “subsets of the population may be unusually susceptible to the toxic effects of fluoride.”[i] Second, since we all drink different quantities of water, we cannot control dosage.[ii] Water fluoridation is either safe for all or adverse for some, and this nuance is introduced in the fact that data published by the 2006 NRC shows the vast majority of infants exceed[iii] minimum dosages of fluoride associated with a risk of adverse health effects[iv] when drinking water between 0.7 to 1.2ppm, which were the “recommended”[v] concentrations for 50+ years, until DHHS reduced the “optimal” concentration to 0.7ppm in 2011.[vi] By extension, this suggests an inadequate Margin of Safety,[vii] a term derived from Toxicological Risk Assessment. To grasp the significance of this term, one must first comprehend the distinction between concentration and dosage.

“Typically the distinction between exposure [at a certain concentration] and dose is blurred, although in reality, significantly different doses can result from the same exposure.”[viii] Consider the current “optimal” concentration of water fluoridation, at 0.7ppm. Even if we all drink water at the same concentration, we will nevertheless consume difference doses (mg/day) and hence difference dosages. Dosage is the dose per unit body weight (mg/kg/day), such as the minimum dosages “meant to protect against” a probable risk of known adverse health effects.[ix] According to the EPA and Agency for Toxic Substances & Disease Registry, beyond the “Minimum Risk Level,”[x] of 0.05mg/kg/day, there is an increased risk for bone fracture,[xi] 0.06mg/kg/day, dental fluorosis,[xii] and 0.114mg mg/kg/day, the disease[xiii] crippling skeletal fluorosis.[xiv] For the sake of clarity, these are to be termed hereafter as the minimum adverse dosage.

When a Drug is in the Water, Dosage Varies

            Dosage is based on many factors. First and foremost, is body weight and water consumption. We know variation exists naturally between different individuals in terms of body weight as well as water consumption, and so, from infants to adults to the elderly, the dosage of fluoride will vary. If an infant and an adult drink a glass of fluoridated water, the infant consumes the highest dosage of fluoride. Compared to adults, infants consume more water per unit body weight and process i.e., excrete fluoride less effectively and therefore absorb more, than adults.[xv] For this reason, infants receive the highest dosage out of the whole population.[xvi]

Infants are therefore the most sensitive members of our society due to their weight and the excretion ability of their bodies.[xvii] Likewise, people with impaired excretion like kidney dysfunction are also known to “accumulate fluoride much more quickly than normal.”[xviii] Excretion ability is therefore one of several sensitivity factors, which can increase the rate of fluoride bioaccumulation and therefore augment dosage.[xix]

Response Effect Varies due to Sensitivity

Plus, other sensitivity factors like health, nutrition and the particular biochemistry and physiology of one’s body, can compound the response effect.[xx] For instance, fluoride can “exacerbate the effects of low iodine.”[xxi] This is to say, two otherwise seemingly similar individuals can therefore respond in dissimilar ways to the same dosage.[xxii]

The Concept of Range from Natural Variation

Body weight, water consumption, as well as sensitivity – all of these factors vary between each individual. In biology, this is termed “intra-species variation.” If body weight and water consumption vary, so will dosage. If sensitivity varies, dosage and response effect will vary. Thus, even if we all drink water at one concentration, at say 1ppm, it is precisely this natural variation, which necessitates one concentration to equal many responses and many dosages. As the Graph shows, there is a range of dosage per concentration level, which also represents response effect.

Unknown Effect on the Individual & Uncontrollable Dosage

This is why the Safe Drinking Water Act prohibits adding drugs to the public drinking water: Firstly, the only certainty we have, is that we are essentially uncertain as to how a drug will effect the individual. Secondly, although we can control concentration in water, all of these other variables, which also determine dosage, are beyond our control. A WHO report notes it is “the uncontrollable exposure to fluoride that is the principal health concern.”[xxiii] What follows from this is that administering a drug to everyone through the public drinking water precludes controlling the dosage received by any one individual. When the drug is in the water, we therefore cannot control dosage, and since dosage determines the safety of a medication, we cannot control the safety of water fluoridation as a form of mass medication.

 Range Per Concentration Level & Margin of Safety

The safety of water fluoridation, therefore, is to be viewed not so much in terms of concentration in water per se, so much as the range of individual dosages which result from the concentration, because dosage, not concentration, determines safety.

Concern for the Most Sensitive Individual: The Infant

Toxicological risk assessment can measure the probable safety of water fluoridation at a certain concentration, by the extent the maximum end of the range of dosage will overlap into, or be spaced apart from, the minimum adverse dosage. That is, safety depends on whether the individuals who naturally receive the highest dosages actually consume too high a dosage when drinking water at a certain concentration. Specifically, we are concerned with the most sensitive individuals in our society, namely infants, but also people with poor health, chemical sensitivities, or greater than average water consumption – all are naturally predisposed to the highest dosages out of all people. This makes the dosage of the most sensitive fall towards the maximum end of the range, with the infant receiving the maximum dosage out of the whole population.[xxiv]

Hence, the safety of water fluoridation depends on whether or not the infant surpasses the minimum adverse dosage when drinking water at a certain concentration. Phrased in technical terms, safety is measured by the window or distance between the maximum dosage and the minimum adverse dosage. This is the margin of safety.

Margin of Safety as a Metaphor
Diagram

            We are wondering if the tallest person in the world can fit comfortably in a room, in which there is a floor and a ceiling. The height of this person represents the maximum dosage of the whole population, which, as was mentioned, is the maximum dosage of the infant. The floor is the concentration of fluoride in drinking water as it affects the maximum dosage, while the ceiling is the minimum adverse dosage.

For the person to fit comfortably in the room, when they are standing upright on the floor, their height must not exceed, i.e., should be lower than, the ceiling. That is, there must be space between the person’s head and the ceiling.

For water fluoridation to be safe, when the infant drinks water at a certain concentration of fluoride, the maximum dosage of the infant must not exceed, that is, should be well below the minimum adverse dosage. That is, there should be space between the maximum dosage and the minimum adverse dosage. This space is the margin of safety. The more space, the more comfort, the greater the probability that infants will be safe and therefore be far away from an adverse dosage.
Now, think of the adverse dosage as a cliff, because this metaphor is the difference between a safe versus the risk of an adverse, i.e., a toxic dosage of fluoride, consumed by infants, from simply drinking water. The infant ought to be as far away from that cliff as possible, for precaution sake. If infants consume dosages higher than the minimum adverse dosage when drinking water at the concentration recommended in drinking water, this is equivalent to the infant falling off the cliff.

Infants Exceed Minimum Adverse Dosages at the “Recommended” “Optimal”

This is precisely what the 2006 NRC data reveals: The vast majority of bottle fed infants exceed the 0.05mg/kg/day dosage associated with a risk of bone fracture, and a very small minority, the 0.114mg/kg/day dosage linked to the disease, crippling skeletal fluorosis.[xxv] For decades, fluoridation was “recommended” between 0.7 to 1.2ppm.[xxvi] At 1.2ppm, infants consume fluoride up to 273 fold that of human milk and at 0.7ppm, it is 70 to 160 times greater.[xxvii] This is why the American Dental Association[xxviii] and the CDC[xxix] issued a public statement warning parents to not use fluoridated water to reconstitute baby formula. In fact, the American Academy of Pediatrics[xxx] and the Toxicology division of the National Institute of Health[xxxi] recommend zero fluoride, “none” for infants, as fluoride is not classified as an essential nutrient,32-5 but rather, as a toxin.36

Thus, it is known that infants consume dosages associated with adverse risk at approximately 1ppm37 as this was the “recommended” “optimal” concentration for 71 years. 38 The 2006 NRC also acknowledged that people with above average water consumption, kidney dysfunction, or iodine deficiency could also exceed minimum adverse dosages from water alone.39 Keep in mind, there are a myriad of fluoride sources. Fluoride is also in/on all sorts of foods as pesticide residues:40 wine,41 fruit juices,42 teas,43 chicken,44 infant foods,45 and Teflon,46 the coating on the pots and pans we use to cook – all, sources of fluoride. And “fluoride intake from toothpaste… is estimated to equal intake from food and water.”47 And don’t forget medications like Prozac.48

No Space for Comfort: Inadequate Margin of Safety

Nevertheless, from water alone, some exceed dosages associated with adverse risk, and so this means the range of dosage overlaps into the adverse range. This is to say, the maximum dosage exceeds the minimum adverse dosage.49 There is no space here for comfort; the person is taller than the room. Hence, it’s a logically warranted conclusion that the margin of safety is not only inadequate, but nonexistent at approximately 1ppm, which was the concentration promoted as “optimal”50 for 71 years.51 Therefore water fluoridation is not safe for some individuals at 1ppm.

This nuance between safe for all or adverse for some, at a certain concentration, is the paramount issue here; they are mutually exclusive. Safe concentrations should mean safe dosages for all, right? Adverse concentrations are adverse in the sense that at least some individuals are at risk. If we are to define our terms accordingly, 1ppm is an adverse concentration because it yields adverse risk among a minority of individuals.52

DHHS reduced the “recommended” “optimal” concentration of water fluoridation by 40% in 2011, down to 0.7ppm,53 from the previous “recommended” of up to 1.2ppm, with 1ppm promoted as “optimal.”54 Will this protect sensitive individuals like infants? Whereas the person could not fit in the room when the floor was 1ppm, will they fit with the floor reduced to 0.7ppm? This is logically possible, only if the ceiling stays in the same place. However, in 2006, the NRC recommended this ceiling be reduced.55

To conceptualize the significance of this, whereas the ceiling represented the minimum adverse dosage, now regard the ceiling as the minimum adverse concentration. EPA risk assessment determined this concentration to be 4ppm in 1985.56 This is known as the Maximum Contaminant Level (MCL).57 Beyond 4ppm, there is an increased risk associated with the disease,58 crippling skeletal fluorosis.59 In 2006, the NRC concluded 4ppm “is not likely to be protective against bone fracture” as well as fluorosis and so recommended EPA reduce it.60 As of August 2014, EPA is still re-assessing the MCL.61

Too Close for Comfort: How Much Space for Safety?

With the floor as well as the ceiling both lowered in our room, we simply do not know if the person will fit, because we only know the ceiling is less than 4ppm. Reducing water fluoridation from the “adverse” 1ppm, to 0.7ppm, leaves how much space for comfort? This is a de facto unknown; considering the summary of evidence.

We know the range of dosage at 1ppm probably overlaps into the minimum adverse range centered at 4ppm.62 This is possible: As was shown, the same concentration can equal different dosages but different concentrations can also equal the same dosage. For example, the dose of 4 glasses of water at 1ppm equals 1 glass of water at 4ppm.
We know EPA toxicological risk assessment arrived at a probable causative risk associated with the disease, crippling skeletal fluorosis when drinking water beyond 4ppm.63 We know the 2006 NRC data shows some infants exceed the dosage associated with the risk of crippling skeletal fluorosis, at about 1ppm.64 So perhaps it is cogent to speculate that the margin of safety, that is, the ceiling, must be greater, than the floor, by at least a factor of 3? Between 0.7ppm and less than 4ppm – this is far too close for comfort given we’re talking about the risk of an infant consuming an adverse, i.e., a toxic dosage from simply drinking water. This is a very narrow window of safety.

The point being: If the concentration we drink, 0.7ppm, is too close in proximity to a greater concentration which a study finds is associated with adverse health effects, such as 0.9ppm for children with iodine deficiency,65 1.5 for hip fractures among the elderly,66 1.9 for lowered IQ, 67 2.3 for lowered thyroid function68 – all of which were reviewed by the 2006 NRC.69 This leaves us with a logically plausible possibility to keep in mind as one reads through The Science Itself: If those concentrations are too close, the margin of safety may still be insufficient to protect individuals from health risks.

The Science Itself: Recently Documented Health Effects

What follows are the most significant peer-reviewed studies published on the health effects of drinking fluoride in water as well as the associated conclusions drawn from the 2006 National Research Council (NRC) of the National Academies of Sciences’ systematic review of the “toxicologic, epidemiologic, and clinical data on fluoride, particularly data published since 1993.”1 About 1,100 studies were reviewed.

Ultimately, the 2006 NRC panel cited three specific adverse health effects from drinking water with less than 4ppm: the risk of severe dental fluorosis, bone fracture, and clinical stage II skeletal fluorosis.2 This section will summarize the 2006 NRC findings related to Dental Fluorosis, Bone Fracture, and the Disease3 Skeletal Fluorosis. In addition, since the NRC concluded: “fluoride appears to have the potential to initiate or promote cancer, particularly of the bone,”4 and “it is apparent that fluorides have the ability to interfere with the functions of the brain,”5 research findings regarding bone cancer, i.e., osteosarcoma, and intelligence quotient in children are presented thereafter.

Bio-Accumulation & Fluoride’s Affinity to Calcium:
Dental Fluorosis, Bone Fracture & Skeletal Fluorosis

Fluorosis is “an abnormal condition”6 caused by excessive fluoride intake7-9 and it takes three forms: Dental, Skeletal and Clinical.10 In the US, the prevalence of fluorosis has been rising, in both fluoridated as well as unfluoridated areas.11-6 The CDC17 estimates that 41% of all adolescents in the US have dental fluorosis, predominately in its mild form, which appears as permanent opaque white spots on the teeth. 3% of all people have a moderate to severe form, marked by full discoloration to orange-brown mottling and pitting. For adults, about half of all ingested fluoride permanently bio-accumulates in the body,18 of which ~95% binds with calcium in the teeth and bones.19

Given the teeth and bone are the principal sites of fluoride bioaccumulation,19 there are nevertheless few published studies that examine fluoride’s effects on teeth as well as bone health.21 “What has been reported so far,” testified Dr. William Hirzy, an EPA toxicologist before a Senate Subcommittee on Drinking Water, “has been disturbing.”20 Eleven out of nineteen studies since 1990 have found a positive correlation between fluoride in water and hip fracture among the elderly.21 The American Journal of Epidemiology recently published a study finding increased hip fracture risk at >1.5ppm.22 The World Health Organization23 cited Li et al., 200124 as evidence of fluoride’s ability to increase bone fracture risk. A 2001 published study reported a positive linear correlation between severity of dental fluorosis and bone fracture in both children and adults.25

“Dental fluorosis,” reports a textbook titled Environmental & Occupational Health, “often occurs with skeletal fluorosis.”26 Skeletal Fluorosis is defined as a “musculoskeletal disease”27 “characterized by pathological bone changes.”28 This disease is documented as endemic among two groups of people. First, industrial workers29-31 with occupational exposure to airborne fluoride emissions exhibit high prevalence of this disease. For example, the United Steelworkers Union called for an industry-wide ban on the use of hydrogen fluoride.32 According to EPA, Hydrogen Fluoride is “one of the strongest acids known,” and it is classified under the exact same Chemical ID Number as Fluorosilicic Acid, both of which are found at Superfund Sites.33

In addition to industrial workers, skeletal fluorosis is endemic in communities with high levels of naturally occurring calcium fluoride in water, which has been studied mostly in India and China. Indian researchers34-5 as well as US researchers at the Mayo Clinic36 have described onset of this disease as “insidious.” Clinically, skeletal fluorosis “mimics”37 arthritis; which renders skeletal fluorosis easily misdiagnosed as nearly identical symptoms seen with arthritis are consistently reported with skeletal fluorosis.37-53 Recent studies published in US and EU journals suggest how susceptible this disease is to misdiagnosis.54-6 In sum, the 2006 NRC concluded:

“Lowering the MCL [of 4ppm] will prevent children from developing severe dental fluorosis and will reduce the lifelong accumulation of fluoride into bone that the majority of the committee believes is likely to put individuals at increased risk of bone fracture and possibly skeletal fluorosis.”57

The truth about fluorosis is this: virtually all of the common dictionaries at my local library define fluorosis as “chronic fluorine poisoning.”58-65 Dental fluorosis therefore “is the first visible sign of chronic fluoride toxicity.”66 Ten out of twelve members of the 2006 NRC judged severe dental fluorosis as a “toxic effect.”67 The World Health Organization defines Dental as well as Skeletal Fluorosis as a Disease, and reports: “The toxicity of fluorides is due to the toxicity of the fluoride ion, a direct cellular poison that binds calcium, interferes with enzymes, and inhibits oxygen consumption.”68

Osteosarcoma:
“Fluoride Appears to Initiate or Promote Cancers, Particularly of Bone”

            Fluoride in drinking water was first linked to osteosarcoma in the published case studies of the first scientifically controlled fluoridation trials, 1945-55. Male children exhibited “statistically significant”69 “bone defects,”70 of which the “age, sex, and statistical distribution”71 of these findings, published after the Public Health Service endorsed water fluoridation in 1950,72 were “‘strikingly’ similar to that of osteosarcoma.”71 Researchers from the first trials thus recommended further studies: “it would be important to have direct evidence that osteosarcoma rates in males under 30 have not increased with fluoridation.”71 Such direct evidence arose nearly fifty years later in 2006, when a study conducted by a Dr. Elise Bassin was published in Harvard’s journal, Cancer Causes and Controls. 73

The Bassin Study: Water Fluoridation & Osteosarcoma in Young Male Children

Although many studies74-6 have not found any correlation between water fluoridation and osteosarcoma in humans across the whole population, four77-80 have found a correlation in young males. Of these four, Bassin et al., 200680 is the only one to examine osteosarcoma prevalence in an age, sex, and exposure-specific research design. For a research methodology to address whether exposure to water fluoridation causes osteosarcoma in young males, “one must be able to quantify total fluoride intake at various stages of life preceding the onset of the cancer.”81

This was precisely the aim of Bassin’s doctoral dissertation research.82 From the levels of fluoride in private wells and municipal water, to tap water used to cook foods, to bottled water, Bassin meticulously quantified fluoride intake from water, for each year of a boy’s life preceding his diagnosis of cancer. Results found a statistically significant correlation: male children exposed to fluoride in water, during the ages of six to eight, were 550% more likely to develop osteosarcoma by age twenty.80

When Bassin’s research was published, a letter83 appeared alongside the study by a Dr. Charles Douglass, who was the academic supervisor of Bassin’s dissertation work and then Chair of Harvard’s Dental School.84 In this letter, Douglass urged precaution with interpretation as “premature” with a promise of his own larger study.

Whereas Bassin’s study tested whether exposure to fluoride in water preceding onset of osteosarcoma correlates to prevalence among young males, Douglass’ study85 tested the concentration of fluoride in bone among both sexes after onset. After adjusting for age and sex, null effect was concluded because results showed “no significant difference in bone fluoride levels between cases and controls.”85

For Bassin’s study, 103 cases of osteosarcoma among young males under 20 years were juxtaposed against 215 controls, with about half under age 30 – this was enough to acquire statistical significance. For Douglass’ study, 142 cases of osteosarcoma among both sexes, with a median age of 18 years, was compared to 20 controls under age 20 years. As such, it was reported that the study “did not have sufficient power”86 to achieve statistical significance. In mathematical terms, this means the number of osteosarcoma cases or controls, i.e. the sample, is too small to statistically warrant confidence in the results; if the sample is too small, probability is that random error may creep in. The authors of Douglass’ study therefore acknowledged the parameters were not adequate to analyze young males under age 20, whereas Bassin designed her study specifically with this goal in mind.87

Bassin and Douglass’ studies are therefore incommensurate in several pertinent respects. Primarily, it is the fact that testing the correlation of exposure, prior to onset, in relation to prevalence, is not the same as testing concentration in bones after onset; these are two different proxies. Logic suggests this precludes the ability of Douglass’ study to counter the results of Bassin’s. When Bassin’s study was accepted for publication in 2005, this catalyzed the EPA National Union of Scientists to publicly reaffirm their opposition to water fluoridation;88 as stated in an open letter sent to all members of congress.89 This came seven years after The Union first called for an “immediate” “national moratorium” on water fluoridation in a 1998 public statement titled: “Why EPA Union of Scientists Oppose Water Fluoridation.”88 Shortly thereafter, Douglass was investigated for allegedly misrepresenting her results under oath, and it was discovered that Douglass had ties to Colgate, a manufacturer of fluoride toothpaste.89

In 2006, the NRC “committee was not able to rule out a carcinogenic effect of fluoride.”90 It was concluded that while “fluoride appears to have the potential to initiate or promote cancers, particularly of the bone,”91 given that “principles of cell biology indicate” the carcinogenic plausibility of fluoride,92 the “evidence to date is” nevertheless, “tentative and mixed.”93

In addition to cancer data, the 2006 NRC also reviewed several other health effects, concluding: 1) “Down’s syndrome is a biologically plausible outcome of exposure,”94 2) “Several lines of information indicate an effect of fluoride exposure on Thyroid function,”95 3) “Fluoride is therefore an Endocrine Disruptor,”96 and lastly, 4) “It is apparent fluorides have the ability to Interfere with the Functions of the Brain.”97

Intelligence Quotient:
“Fluoride’s Apparent Ability to Interfere with Brain Function”

In 2012, Harvard University researchers “found strong indications fluoride may adversely affect cognitive development in children,”98 in a review of 27 studies examining fluoride in water and children’s intelligence.99 A total of 43 studies have researched fluoride’s affects on human intelligence, 37 of which have found an inverse relationship between fluoride in water and measurably lower IQ, and in 31 of these studies, the predominant source of fluoride was water, with the other six from coal emissions.100 Thus, to date, 31 studies conducted in China,101-21 Mexico122 India123-7 and Iran128-30 demonstrate an association between fluoride in water and lowered IQ among children. One of the researchers from the “Harvard IQ Review,” Dr. Phillippe Grandjean stated: “fluoride seems to fit in with lead, mercury, and other poisons that cause chemical brain drain.”131 The 2006 NRC extensively examined five of these studies, concluding “the consistency of the results appears significant enough to warrant additional research.”132 In another review on this subject called “Toxic Threats to Child Development” by Physicians for Social Responsibility, the authors opined that “perhaps the most surprising is the relative sparseness of data” in this domain.133

Despite the sparseness of data, several studies on fluoride’s effects on brain function have been recently published in US and EU journals. Two studies published by the US journal Neurotoxicology, link silicofluorides in water to increased uptake of lead into children’s blood assays.134-5 Several studies have also found fluoride accumulation in the brain. One of which, conducted at the University of Surrey, and published in the UK, found fluoride in the center of the brain in humans, in the calcifying tissues of the pineal gland.136 Neurotoxic effects are documented in rats at levels equivalent to humans drinking 5 to 10ppm137 and 2.5ppm,138 both of which appear in the US journal, Neurotoxicology & Teratology. The former137 also found accumulation in the hippocampus, the section of the brain associated with memory. Another US study published in the US journal Brain Research, reported fluoride increased aluminum uptake into the brains of rats, forming deposits typically linked to Alzheimer’s.139 Such results are replicated in many studies, the majority published outside the US.140-51

Lastly, to end on several reviews in this domain. One review published in the US journal International Clinical Psychopharmacology, concluded “chronic exposure to fluoride may be associated with cerebral impairment affecting particularly concentration and memory.”152 In 2014, fluoride was named among several newly confirmed “developmental neurotoxicants” in a review conducted by Harvard University researchers, and published by the prestigious journal, Lancet Neurology.”153

 

Risk, Reverence of Life & The Ethics of Water Fluoridation

Over-Exposure to Chemicals, Individual Medical Consent & Dose Makes the Poison?

“Life,” Rachel Carson wrote at the end of Silent Spring, is indeed “a miracle beyond our comprehension; and we should reverence it…”1 What Reverence of Life is reflected in the fact that the Center for Disease Control – the agency which actively promotes water fluoridation, has found that 41% of Our Nation’s Youth2 have what the World Health Organization has defined as a Disease3 caused by ingesting too much fluoride in the water? Two out of every five adolescents have fluorosis in this country. The paramount issue is: it is known that fluorosis is caused by excessive-exposure to fluoride and we can see “the first visible sign of chronic toxicity” on the teeth of our children.4
Therefore, the public health implications of water fluoridation do not reside in the concentration, the dosage, or even the science of health effects; when its in the water, dosage is inherently uncontrollable, and we can clearly see our youth are consuming too much of a drug that we would otherwise have a choice to use with toothpaste or consume with a prescription from a doctor. Moreover, like any other drug, the doctor would prescribe the dosage relative to the individual patient. In all likelihood, it is a safe assumption there is probably no drug safe for all, at one or any dosage, and especially if dosage is uncontrollable, because medicine is relative, not universal. Water fluoridation is premised on the erroneous notion of a “one size fits all” medical treatment. So, where is an individual’s medical consent with fluoridation?

Ingesting fluoride, in the form of tablets, is not even FDA approved, due to a loophole in the Food, Drug & Cosmetic Act of 1939.5 Being on the market prior to this Act, fluoride tablets are still marketed and they are found behind the counter at the pharmacy. This word – pharmacy – is derived from an ancient Greek word, pharmacon, which has a dual meaning: One substance, at the right dose can be medicine and virtue, at too high a dose, a poison and vice. “As Paracelsus once wrote, ‘the right dose differentiates a remedy from a poison.’”6 This is true of some chemicals like essential nutrients or wine, for instance, but it is undoubtedly false for other chemicals, like Lead and Arsenic, the two primary contaminants in fluoridation chemicals.7-8 No dose of lead or arsenic is a remedy; any dose is toxic because lead and arsenic are poisons per se. No threshold of safety exists for “chemicals totally outside the limits of biologic life.”9 Thus, for some, “the toxicity of a chemical is an inherent quality of the chemical itself.”10

One can see the following sentence on the World Health Organization’s website: “The toxicity of fluorides is due to the toxicity of the fluoride ion, a direct cellular poison that binds calcium.”11 We should therefore wonder if there is a spectrum between poison and medicine for fluoride, or are the properties mutually exclusive? A medicine can be a poison at a high dose, but can a poison be a medicine? Actually, Yes; Radiation epitomizes this ambiguity; it is a poison known to cause cancer, and it is used to treat cancer.12 Radiation may be an effective treatment to cure cancer in some but not all, however, it is poisonous to the body of all. “It must not be overlooked that many chemicals are the partners of radiation producing precisely the same effects.”13 In the opinion of this author, fluoride is an effective topical medication for the average person, and fluoride may be beneficial to teeth, in the average person, if ingested in naturally occurring trace amounts, like in teas and most water, but what about the body? Naturally occurring minerals like calcium fluoride, 14 sounds healthy, but lets not equivocate terms; arsenic is also a naturally occurring mineral. Is arsenic therefore healthy to ingest?

The whole of the body is affected by ingestion of a chemical, nonetheless “a direct cellular poison.” The dose of this poison can be lethal or non-lethal, but nevertheless too high a dose at one time can cause acute poisoning, like swallowing toothpaste. On the other hand, chronic poisoning is consuming non-lethal doses over a period of time. Think about the mathematical proof mentioned earlier: the “optimal” pea-size toothpaste and a glass of “optimally” fluoridated water; both equal a 0.25mg dose of fluoride.15 A federal health law16 based in toxicology recommends you call poison control if you systemically ingest that toothpaste because the Human Toxicity Level of fluoride is between 4 (Very) to 5 (Extremely Toxic).17 Another federal policy18 based in dentistry, which treats oral health primarily on a topical basis, recommends you systemically ingest, in every glass of water you drink, for your entire lifetime, precisely the dose of fluoride the federal health law explicitly implies causes acute poisoning. How is water fluoridation not chronic poisoning? How can a Toxic Poison be Safe & Healthy? For Everyone? Over a Lifetime? Fluoridation means you wash your face with fluoride?

Probably Safer & Healthier to Simply Drink Clean Water:
Calculated Risk & The Lack of Scientific Consensus

            Three out of twelve members of the 2006 NRC have signed a “Professional Statement to End Water Fluoridation.”19 One member of the NRC, Dr. Kathleen Thiessen, a Senior Risk Analysis Scientist, joins Dr. William Marcus, former Chief Risk Assessment Toxicologist at EPA’s Office of Water.20 To date, the most avidly and publicly outspoken scientists against water fluoridation have been the Toxicologists, Biochemists, and Statisticians at EPA,21 as well as a former Professor Emeritus in Environmental Chemistry, Dr. Paul Connett, founder of Fluoride Action Network.22
Scientific opposition also extends to the dental profession: a second member of the NRC, Dr. Hardy Limeback, past president of the Canadian Association for Dental Research joins Dr. John Colquhoun, a former Chief Dental Officer in New Zealand – two former proponents of water fluoridation who have since reversed their position.23 See Colquhoun’s publication: “Why I Changed My Mind About Water Fluoridation.”24 Both publicly oppose water fluoridation alongside a Dr. David Kennedy,25 a past president of the International Academy of Oral Medicine and Toxicology.26
Lastly, the third member of the NRC is Dr. Robert Isaacson, a Neuroscientist and Professor Emeritus of Psychology.27 Out of the 4,000 scientists, medical doctors, PhD’s and dental professionals who have signed Fluoride Action Network’s “Professional Statement to End Water Fluoridation,”28 perhaps the most preeminent name on the list is a Pharmacologist, Dr. Arvid Carlsson, the 2000 Nobel Laureate in Physiology or Medicine,29 who, in the 1970s, advised the Swedish Parliament to successfully reject water fluoridation for going “against all principles of modern pharmacology.”30 Logically, it is dissent from scientists in precisely these fields, which impugns any claim of scientific consensus about the safety of water fluoridation.

These are the ones Who Walk Away From Omelas,31 an allegory representing the inherent conflict between the utilitarian ideal of the greatest good for the greatest number and the deontological right of the individual, which in this case, is the principle of medical consent, freedom of choice, and freedom from an obligation to endure risk.

Those Who Walk Away: Epistemic Uncertainty, Bioethics & Care Duty

Omelas is the quintessential Utopia, albeit with a caveat, one condition: it depends on the eternal suffering of a young boy, locked in a broom closet, with no window, no human affection, nothing beyond a paucity of food [with fluoride pesticide residues] and [“optimally” fluoridated] water for subsistence. Everyone is aware of the compromise; if the boy is loved or freed, the Utopia ceases. Those Who Walk Away choose to do so voluntarily because they find themselves unable to justify sacrificing an Individual’s access to the Good Life, in exchange for their own.
Water fluoridation parallels this allegory in that it would be utopic if water fluoridation was the ultimate “safe and effective” panacea, to cure us all of our cavities. However the comparison may be somewhat incommensurate, as our access to the good life is debased by the fact that fluoride is not an essential nutrient.32 Nevertheless, assuming efficacy, this paper calls into question the issue of safety as it relates to the Health of the Individual. Dr. Colquhoun posed the ethical dilemma succinctly: “How many cavities would have to be prevented to justify the death of one man from osteosarcoma?” What Reverence of Life is posited in the justification of uncertain, perhaps seemingly small risks? One in a million? 200 million people means a 550% possibility that 200 young boys who drink fluoridated water between ages 6 to 8, may develop osteosarcoma by age 20.33 If the 2006 NRC report concludes “bone cancer is a particular concern,”34 and the chair of the NRC says “questions are unsettled”35 after 71 years of water fluoridation, is anyone in a position to make truth claims about the extent of this possibility, the magnitude of risk? This is a de facto unknown.

The whole ethical conflict of the allegory is based on whether the Life of a Child – a Supreme Value, can be compromised. In this case, can we justify the possibility of risking Life? Children are dependent on us for protection; their life is in our hands. This is Care Duty: an affirmative ethical obligation to acquire knowledge requisite to ascertain potential risk, so as to inform our actions to avoid or prevent Harm, and therefore to ensure safety and protect Life. Thus care duty means one actively seeks out knowledge so as to assess risk, and if potential risk is found, takes actions to minimize the potential. Likewise, a breach of care duty is either failing to seek out such knowledge, or, being knowledgeable of potential risk, but failing to act. Either way, this is Negligence; through “unreasonable carelessness,” one exposes Life to the Risk of Harm, and hence, is subject to moral culpability and liability. As such, the “Hippocratic Oath” affirmed by medical doctors upon initiation to their profession, begins with: “First, Do No Harm.”
Essentially, whether public health implications exist therefore depends on our knowledge of risk. If your rationality judges the recent science presented in this essay to be a fair preponderance of evidence to maybe support the possibility of health risks, then this constitutes knowledge of potential risk. The only certainty, therefore, is uncertainty:

“To know we do not know what we do not know,
and to know that we know we know,
that is true knowledge.” –Henry David Thoreau

The Scientists Who Publicly Oppose Water Fluoridation choose do so voluntarily because they know they are uncertain if water fluoridation is safe; they find themselves unable to justify the possibility of risking the Life of an Individual, even if it may be for the greater good. This choice is premised on the fact that our freedom is dependent on the freedom of others – as each individual has a Right to Life. This right is sourced from an inherent dignity, which springs from our rationality as an end in and of itself. This is why the debate regarding water fluoridation ought to be refined down to the issue of choice; this is your life, your health, and your body. Fluoridation is a violation of the principle of informed medical consent, as it is unambiguously and indubitably mass medication.
Nevertheless, “The nature of uncertainties in the existing data could also be viewed as supporting a greater precaution regarding the potential risk to humans.”36 This was the conclusion of the 2006 NRC regarding the cancer-fluoride evidence. They were certainly referring to the Bassin study, i.e., bone cancer in young boys.

The Other Road: Risk, Reverence of Life & The Precautionary Principle

If the National Research Council of the National Academies of Sciences is “uncertain” about the “potential risk” of fluoride as a carcinogen to children, why should the public give fluoride the benefit of the doubt? We therefore find ourselves at an ethical juncture as it relates to Risk & Reverence of Life. One Road is to give fluoride the benefit of the doubt. This is tantamount to the assumption that chemicals are innocent until proven guilty; and so we presume safety until we are certain studies have proven risk through finding harm. Hence, we must wait for the public ­– us – who were never asked for our consent, and obligated to endure an uncertain risk, to be harmed? If the only study of its kind,37 conducted at38 and published39 by Harvard University, finds a 550% statistically significant probability that fluoride in water may cause bone cancer in young boys, why would it not make sense to speculate that this chemical may be guilty? Is it not reasonable to simply turn the knob off at the water treatment plant, and drink just clean water until we are 100% certain fluoridation chemicals are safe?

This is the Other Road: We know there is no risk from drinking clean water. This is to abide by the Precautionary Principle; in the presence of a preponderance of evidence to support the notion that water fluoridation may cause a risk of harm to public health, and in the absence of counter-evidence to warrant safety, the action to be taken is therefore twofold: we walk down the only road we know is safe: just drink clean water, and then concomitantly ask for more knowledge via further research, with the burden of proof falling on those who endorse and actively promote water fluoridation. Precaution is proactive; the public shouldn’t have to wait to be harmed, to prove fluoride guilty.

Thus, federal public health agencies as well as dental associations are therefore obligated to prove fluoride innocent; and solely critiquing the methodology of studies that find harm, is not equivalent to proof of safety. Studies must try to replicate results, i.e., look for harm in all sorts of individuals, in all systems and organs of the body, account for confounding variables, in randomized, double-blind trials, over a long period of time. This is the criterion for a Grade A Study, according to the UK’s National Health Service Centre for Reviews and Dissemination at York University.40

In 2001, the “York Review” systematically reviewed epidemiological studies41 examining the safety and efficacy of artificial water fluoridation. This is unlike the 2006 NRC, which examined safety based on recent toxicological, epidemiologic, and clinical data,42 both in vitro and in drinking water, which consequently included studies on naturally occurring fluoride in water. The “York Review” found Zero Grade A Studies.43 “What the ‘York Review’ on the Fluoridation of Drinking Water Really Found,”44 is published on the University’s website:

“We were unable to discover any reliable good-quality evidence in the fluoridation literature world-wide… The evidence about reducing social inequalities in dental health was of poor quality, contradictory and unreliable.”

The Chair of the “York Review,” Professor Trevor Sheldon, in an open letter:
“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 a legitimate scientific controversy over the likely effects and costs of water fluoridation…”45 [dearth in original]

“Legitimate Scientific Controversy”

Dr. Trevor Sheldon has also signed Fluoride Action Network’s “Professional Statement to End Water Fluoridation.”46 If there is “legitimate scientific controversy,” the Precautionary Principle sides with epistemic uncertainty, humility, and ignorance, as “ignorance is preferable to error; he is less remote from the truth who believes nothing, than he who believes what [may be possibly] wrong,” Thomas Jefferson. Furthermore, “the conventional view that the ethical dilemmas posed by water fluoridation can be solved by balancing the benefits and harms actually begs the question, for it presumes that such a balance can be achieved.”47 For example, how can a balance be achieved if the 2006 NRC says: “fluoride has an effect on thyroid?”48 What kind of effect? Why would 0.7ppm of fluoride not effect thyroid, for at least some people?
“Many people believe that since so many people do not feel any immediate effect, [fluoride] must therefore be harmless,”49 however continuously ingesting non-essential50-3 chemicals into our bodies, permanently bio-accumulating within calcifying tissues54 like teeth, bone55 and the pineal gland in our brain56 – this may have “consequences remote in time and place.”57 “That there are no immediate symptoms [therefore] is of little consequence to this issue, for the toxins may sleep long in the body, to become manifest months or years later in an obscure disorder almost impossible to trace to its origins.”58

The ethical conclusion we arrive at is: one exception, one counter-example, will refute the theory of water fluoridation as safe for all, for a lifetime, in its entirety. If there is a possible risk that fluoridation chemicals may adversely affect the health of at least one person, then it is not safe for all. If it touches all, it should be safe for all, right? Thus, concerning the notion of balance, is it logically consistent to balance Reverence of Life with the possibility of Risk to an Individual? The Risk is: one’s access to the Good Life.
Plus, “How can it be ethical to be putting industrial waste in our drinking water?”59 Is it right to dose someone, nay – an infant, with a chemical that we know is not an essential nutrient, indefinitely, for a lifetime, with medication, through the public water, without their consent? Infants cannot even give consent; and so we have a Duty to Care for them. Can we justify this, knowing we do not know how much they will ingest into their body from drinking water? What about toothpaste, twice a day, every day? Insecticide residues on food? 6.8ppm in Gerber Grape Juice?60 8.38 micrograms per gram in infant foods?61 A kiwi – 15ppm?62 What about boiling food in fluoridated water, in a pot with Teflon coating? Food is carbon-based and the C-F bond is the strongest bond in organic chemistry because fluorine is the most electro-negative element and hence the most reactive chemical in the periodic table.63 What about bathing in fluoride? Is fluoridation an efficient means to an end, knowing 99% of it goes down the drain…?

The Conclusion Speaks for Itself: Res Ipsa Loquitur

En Aqua Sanitas: Clean Water: Healthy, Safe & Effective
The reason why the Latin word for Health is the origin of the word Sanitary is this: Clean Water is Essential for Health. A fetus is about 90% water, an adult, 70%. It is therefore safe to assume that any medical doctor would “recommend” clean water as an “optimal” effective preventative health measure. After taking a fresh look at the chemistry, recent science and ethics of adding fluoridation chemicals to public drinking water as a preventative health policy to reduce tooth decay, what of the public health implications? Why, after 71 years of fluoridation, has the Chair of the National Research Council stated Questions Remain Unsettled?1 Why has the Chair of the “York Review” asserted A Legitimate Scientific Controversy continues to this day?2
Both statements imply a lack of scientific consensus, i.e., disagreement among authorities; but the significant feature is: the Chairmen of systematic reviews on the subject regard the side, which questions safety as legitimate. Consider both sides.

Lack of Scientific Consensus: EPA Toxicologists versus CDC Dentists

            The Toxicologists, Biochemists and Statisticians at the Environmental Protection Agency report health risks are imminent: “Our opposition to drinking water fluoridation has grown, based on the scientific literature documenting… chronic toxic hazards of cancer… We looked at the cancer data with alarm… other incriminating cancer data.”3 This position statement is derived from expertise in the field of toxic chemical health risk assessment. On the other hand, Dentists from the Oral Health Division of the CDC, whose expertise pertains to teeth and gums, report: “No credible evidence”4 associates fluoridation with cancer. In addition, the EPA Union of Scientists report on their website, under “Scarcity of Environmental Impact Studies:” “This is of deep concern to us. Studies that do exist indicate damage to salmon and to plant ecosystems.”5 By contrast, under “Health Effects and Environmental Impact,” on the “Fluoridation Safety” page of the CDC’s website: “Scientists have found a lack of evidence to show an association between water fluoridation and a negative impact on people, plants, or animals.”6
This sort of discrepancy between authorities is precisely what happened with DDT, which was then “so universally used that in most minds the product [took] on the harmless aspect of the familiar.”7 As reported by Rachel Carson in Silent Spring:

“The citizen who wishes to make a fair judgment of the question
of wildlife loss is today confronted with a dilemma.
On the one hand, conservationists and many wildlife biologists assert that the losses have been severe and in some cases catastrophic.
On the other hand, the control agencies tend to deny flatly and categorically that such losses have occurred, or that they are of any importance if they have.
Which view are we to accept?8
“The credibility of the witness is of first importance.
The professional wildlife biologist on the scene is certainly best qualified
to discover and interpret wildlife loss
.
The entomologists, whose specialty is insects, is not so qualified by training
and is not psychologically disposed to look for undesirable side effects
of his control programs.”9
In spite of the assurances of the insecticide people
that their sprays were ‘harmless to birds,’
the robins were really dying of insecticidal poisoning;
they exhibited the well known symptoms of loss of balance,
followed by tremors, convulsions and death.” 10
“From all over the world come echoes of the peril facing birds.
The reports differ in detail, but always repeat the theme of death to wildlife
in the wake of pesticides
.”11
“Yet it is the control men in state and federal governments
and of course the chemical manufacturers
who steadfastly deny the facts reported by the biologists
and declare they see little evidence of harm to wildlife.”12

“It is widely believed that since so many people feel no immediate effect, DDT must therefore be harmless. One part per million sounds like a very small amount – and so it is. But such substances are so potent that a minute quantity can bring about vast changes in the body.”13 Since 1945, “1 ppm of fluoride was the optimal concentration in community drinking,” until DHHS, the parent of CDC, reduced the “optimal” down to a new “optimal” of 0.7ppm in 2011.15 0.7ppm is approximately 70 to 160 times greater than the fluoride found in human breast milk: Mother Nature’s “optimal” formula for Life.16 The CDC used to “recommend” up to 1.2ppm of fluoride.17 This is the same 1.2ppm that is up to 273 fold that of breast milk.18 This is the same CDC, which issued a Public Warning solely on their website, prevaricating Against Using Fluoridated Water to Reconstitute Infant Formula, four years after the 2006 NRC data was published:19

Yes, you can use fluoridated water for preparing infant formula.
However, if your child is exclusively consuming infant formula reconstituted with fluoridated water, there may be an increased chance for mild dental fluorosis. Parents can use low-fluoride bottled water some of the time.”19

Note how the language is evading the fact that zero fluoride – “none” is recommended for infants under six months20 since fluoride is not an essential nutrient.21 This is called circumlocution. George Orwell said: “The greatest enemy of clear language is insincerity.” Sources of information, which prove to be inaccurate in the past, should generally be regarded with skepticism as sources of accuracy in the future. This comes to show that authorities in one field are not necessarily authorities in another.

Truth & Human Motivation

            Sources of information should further be evaluated in terms of human motivation for acquiring and telling truth. The Scientists at EPA, whose job is to protect public health by regulating the chemical industries who pollute our environment for the profit of a few shareholders – is there any benefit to these scientists, if local municipalities cease adding (and hence buying) fluoridation chemicals from an industry who would otherwise be required by law, to pay to properly dispose of this hazardous waste? On the other side, the Dentists at CDC – their job has been the active promotion of water fluoridation for over half a century. We simply cannot expect people, whose entire profession is based on a worldview that water fluoridation is safe, to give us information that would destroy their position, writes the author of a book called Logic & Contemporary Rhetoric.22

“Habit is Stronger than Reason,” says George Santayana, who also famously wrote: “Those who do not study history are doomed to repeat it.” We all know the history and fate of DDT; thanks to Rachel Carson. In 1962, Silent Spring asked us to imagine a silent world devoid of birdsong. When it was published, Time wrote a book review in which Carson’s “emotional and inaccurate outburst” was regarded as “hysterically overempathetic.” The title of the book review: “Pesticides: The Price for Progress.” 23 Apparently, back in the day, “the Department of Agriculture advise[d] us to spray our clothing with DDT…”24 until it was banned in 1972.25 In 2001, DDT was officially banned by international treaty.26 Rachel Carson did not live to see the fruit of her labor, as she died in 1964 from a long battle with breast cancer. And the Bald Eagle, the quintessential symbol of the inter-connection between American Life and Our Environment, etymologically derived from the Sanskrit word “environ,” meaning “Home,” has been recovering ever since.27 This is the price of progress? DDT is why the Precautionary Principle exists; we should prove a synthetic chemical safe, before we exposed it to Life as we know it.
Should fluoridation chemicals prove unsafe, there is reputation at stake, and liability because 200 million people live downstream from fluoridation chemicals. EPA scientists are concerned about public health, and therefore are more motivated to tell the truth and less highly motivated to conceal it. “The vast majority of people see no clear motive for what opposition implies.”28 This is for you to decide as a rational being.

We do have the authority to seek out truth, to set up our own inquiry towards knowledge to inform the Common Good. Become our own expert. Undoubtedly, the most reliable information is gained from science, albeit the caveat is that science is only reliable if the scientific method is successfully applied. The “York Review” reports on its website: “we were unable to find any reliable, good quality evidence in the fluoridation literature worldwide.”29 No Grade A Studies.30 Virtually all artificial fluoridation studies have been conducted by dental researchers.31 None of the 214 studies included in the “York Review” were randomized.32 What is going to happen when children are told a researcher will be periodically checking their teeth for signs of cavities? This bias is controlled with a case-control design. Out of 214 studies, seven were case-controls.32

Scientific Revolution & Science as Tentative

            Dr. John Colquhoun, a dental researcher himself and former Principal Dental Officer of Auckland, New Zealand was a former proponent of water fluoridation until he was asked to conduct a systematic review of artificial fluoridation worldwide. Then he wrote: “Why I Changed My Mind on Water Fluoridation.” His PhD dissertation33 about fluoridation was based on Thomas Kuhn’s The Structure of Scientific Revolutions.34

from the Introduction of Scientific Revolutions:
“History, if viewed as a repository for more than anecdote or chronology
could produce a decisive transformation in the image of science
by which we are now possessed.
That image of science has been previously drawn
by scientists themselves,
mainly from the finished scientific achievements of their predecessors,
as these are recorded in the classics and,
more recently, in the textbooks from which
each new scientific generation learns to practice its trade.
Inevitably however, the aim of such books is persuasive and pedagogic,
a concept of science drawn from them.
The texts have, for example, often seemed to imply that the content of science is uniquely exemplified by the observations, laws, and theories described in their pages.
Almost as regularly, the same books… are simply the ones illustrated by
logical operations together with the manipulative techniques used in gathering data.”
“This essay attempts to show we have been misled by them in fundamental ways.”
“Normal science is predicated on the assumption
that the scientific community knows what the world is like.
Much of the success of the enterprise derives from the communities’ willingness to defend the assumption, if necessary at considerable cost…
Normal science, for example, often suppresses novelties.
Indeed, scientists are often intolerant of new theories that do not fit the box.”35
“In these and other ways besides, normal science repeatedly goes astray.
And when it does – when, that is, the profession can no longer evade anomalies that subvert the existing tradition of scientific practice –
then begin the extraordinary investigations
that lead to a new set of commitments,
a new basis for the practice of science…”36
Each scientific revolution was precipitated by a crisis
within the existing paradigm, which
“Necessitated the communities rejection of one time-honored scientific theory, with one incompatible with it.”
Scientific revolutions are the ‘tradition shattering’ complements
of the ‘tradition bound’ activity of normal science…”
“Such changes, together with the controversies
that almost always accompany them,
are the defining characteristics of scientific revolutions.”
Science,” therefore, “has included bodies of belief quite incompatible
with the ones we hold today…”37

A core tenet of Science, according to Sir Karl Popper is that it is Tentative. At one point in time, virtually all of academia asserted the universe revolved around the Earth – this was the Truth because the Ptolemaic geocentric model was consistent with “scientific” empirical observation. When Copernicus proved the universe heliocentric, revolving around the Sun, Galileo publicly embraced this theory. Ultimately, a trial of the educated elite found Galileo guilty of Heresy. Today, we all know the Truth: the universe does not revolve around us. Historically, “Truth,” according to Schopenhauer, “goes through three stages. First, it is ridiculed. Second, it is violently opposed. Third, it is accepted as self-evident.” Any novel claim of knowledge is initially resisted if it is contrary to the “worldview” of the consensus. “Consensus,” to Einstein, “is abhorred by the genius because when it is reached, thinking stops.” That is, “Historically, the claim of consensus is the first refuge to avoid debate by claiming the matter is already settled… the work of science has nothing to do whatsoever with consensus… The greatest scientists in history are great precisely because they broke with the consensus.”38

Breaking Away from Consensus:
The Paradigm Shift: Why Portland, Oregon Voted NO

            Like Copernicus and Galileo, Silent Spring broke the consensus, causing a revolution. When Carson was asked about her position on water fluoridation, she was a precautious skeptic: “Prior to a high level research program into all its potential hazards to people of all ages – and, also into its residual effects, her inclination is to be against it.”39 Carson was quoted in a 1963 article in the Palm Beach Post, which called for volunteers to collect signatures for a referendum, to put the public water, up for a public vote. Evidently, the city council voted fluoridation chemicals into the water. We are left with the question: Should 51% of your neighbors who actually vote decide whether your child consumes a drug, for a lifetime?

In 2013, 61% of Portland, Oregon voted for Clean Water by voting No to Fluoridation Chemicals, for the fourth time in history. With very high voter turnout, Portland broke the consensus of the nation, being the last major city to not fluoridate its public water. The paradigm shift that took place in Portland is what inspired this research thesis. This inquiry attempted to answer the question of public health implications. This is why Portland, Oregon voted No…What we found is that the power and nature of the chemical itself is unlike that of toothpaste. Whereas this topical use of pharmaceutical grade fluoride is an FDA approved drug,40-2 water fluoridation is unapproved42-6 systemic ingestion of industrial waste.47-50 Voters were concerned with the fact that this industrial waste is contaminated50-2 with lead, arsenic, radioactive substances and is regulated as hazardous53-6 for its corrosive53 and toxic properties.54-5 Further along our road of inquiry was the fact that fluoridation chemicals are otherwise air pollution.57-60 We were left with the ultimate realization that water fluoridation could be appropriately termed mass medication, given fluoride is technically a drug.61 Likewise, this renders water fluoridation a violation of the spirit of the Safe Drinking Water Act.62
Why prohibit adding drugs to the public water? Some may wonder. Thus, we walked through this line of reasoning: Basically, since dosage, not concentration, determines safety, we cannot control the safety of water fluoridation; because when a drug is in the public water, natural variation among people ensures dosage will vary, which means safety is essentially beyond our control. Moreover, since some of us are simply more sensitive than others, we realized the effect upon the individual is beyond our knowledge as well. Thus, we examined the margin of safety through the notion of range per concentration level. With our concern focused on the infant who naturally consumes the highest dosage out of the whole population, it was discovered that water fluoridation is not safe for all because infants exceed the minimum dosage associated with a risk of adverse health effects.63-5 Specifically, the maximum of the infant at 0.14mg/kg/day63 is more than double the minimum adverse dosage at 0.05mg/kg/day.64 By extension, this logically proved there is no margin of safety at the “recommended” “optimal” concentration. Perhaps this is why DHHS reduced the “recommended” “optimal” by 40%, down to a new, lower “optimal” concentration.67
With this reduction ever so slight, there was a sense of too-close-for-comfort, given the minimum adverse concentration is still very close in proximity to the new “optimal” concentration. This showed “the range of estimated average intake associated with a number of adverse effects is in the range of intakes expected with fluoridated drinking water.”67 Voters wondered how much space, if any, exists for safety?

Then voters initiated a risk assessment. After reviewing health effects documented by the most recent science published in peer-reviewed journals, a definitive aspect influencing the vote was the 2006 NRC. It was recommended that EPA reduce the 4ppm MCL of fluoride due to several explicitly confirmed adverse health effects, namely, the disease fluorosis, which affects teeth, the skeleton, and increases risk of bone fracture.68 Logically, this meant health risks are associated with concentrations of fluoride lower than 4ppm. Other adverse health effects were also implicitly confirmed as a possible risk, such as cancer: “it is apparent that fluoride has the ability to initiate or promote cancer, particularly of bone.”69 Ultimately, the Harvard IQ Review validated the findings of dozens of IQ studies.70 Portland’s No vote proved wise, when fluoride was named a newly confirmed neurotoxin in a review published in 2014 by the prestigious journal, The Lancet.71 In sum, the impression was: too many recent, credible studies have found too many adverse health risks at concentrations too close to the “optimal” 0.7ppm.
The Science Speaks for Itself: and so with voters entertaining the notion that recent science may support the possibility of Health Risks, we explored Reverence of Life as it relates to the Ethics of Water Fluoridation. Given 41% of youth72 have a disease73 caused by ingesting too much fluoride, it was speculated that public health implications shouldn’t be framed so much in terms of dosage, concentration or science, so much as the fact that children are overexposed to a drug we would otherwise prefer to have a choice to consume topically, with toothpaste or systemically, with a prescription. Water fluoridation was thus regarded as a clear violation of the deontological principle of individual medical consent.74 Many called this freedom of choice, or freedom from the obligation to endure an uncertain risk from exposure to a chemical, whose toxicity is an inherent property of the chemical itself, rather than a property of the relative dose.75

It was further surmised that perhaps it is this epistemic uncertainty, i.e., of the safety of water fluoridation and the risk to Life, combined with Care Duty, which may warrant Precaution. Hence, the lack of scientific consensus. With many reputable names signing Fluoride Action Network’s “Professional Statement to End Water Fluoridation,”76 perhaps it may be safer and healthier to simply drink clean water? Portland voters were left to contemplate the Ethics debate in one question: can we balance Risk with Reverence of Life? Or does this beg the question, presuming a balance can be achieved?
Conclusively, Portland realized “The Balance of Nature is Not a Status Quo”77 – this is one of the conclusions put forth by Rachel Carson after presenting the recent science on DDT, in Silent Spring. “We have gone with the status quo for too long” 78 – this is the conclusion of the Chair of the 2006 NRC’s systematic review of the recent science on “Fluoride in Drinking Water.”
Ponder how we apply the Scientific Method to discern Nature’s laws and systems.

The word physics, comes from the ancient Greek word for nature, physis.
Is Fluorosis Natural? Is it natural for 41% of children to have a disease caused by ingesting too much of a chemical we intentionally add to the public drinking water?

Living Downstream: “The Solution is Biological, Not Chemical”82

            Children are clearly enduring too much fluoride. “In having endured much, we have at least asserted ‘our right to know,’ and if in knowing, we have concluded that we are being asked to take senseless and frightening risks, we should no longer accept the counsel of those who tell us that we must fill our world with poisonous chemicals; we should look about and see what other course is open to us.”79 Like mass applications of DDT insecticide, with “no oasis of safety” for wildlife, the mass medication that is water fluoridation flows through our public waterways directly into our private homes, and thus, into our bodies to permanently take its place within our bones,80 and brain,81 without the consent of all, and for far too many of us, without our knowledge.

In conclusion, this essay demonstrated firstly, that violating individual consent in the name of the greater good is debased by the pattern of results: credible studies support health risks to the greater population. Second, these risks warrant precaution. Third, the presence of lead, arsenic and other contaminants inherently precludes safety. And lastly, “laboratory and epidemiological research has led to a better understanding” of how fluoride prevents cavities or caries, as stated on the CDC’s website: “fluoride prevents dental caries predominately after eruption of the tooth, and its action primarily topical.”83 Therefore, with topical fluoridated toothpaste and dental treatments being more effective than water fluoridation. Dental health is about nutrition, access to dental care, and educating youth to cultivate healthy hygiene habits.