Response to Fluoridation Claims of Rick North
OPINION -- In a recent anti fluoridation article in the Lund Report, Rick North expresses numerous misconceptions, misrepresentations, and errors. As is always the case, it takes far more time and space to properly address such misrepresentations, than it does to express them in the first place. The following is a detailed explanation of the fallacies of North's claims.
North refers to a petition which has been widely promoted on the internet by fluoridation opponents. This petition was signed by New York antifluoridationist faction, "Fluoride Action Network", the antifluoridationist group, "Mom's Against Fluoridation", the fringe activist group, "IAOMT", a fringe environmental group, and a consumer group.
As with the 2014 petition to the EPA from personnel of the "Fluoride Action Network", this current one has no merit. In a recently released "Six-Year Review 3 of Water Standards", the EPA has fluoride in the category of "Low priority and/or no meaningful opportunity". There is nothing in this current petition that would justify changing that classification. (1)
The petition lists a litany of animal studies on the effects on rats exposed to high levels of fluoride. These studies bear no relevance to the effect of optimal level fluoride on humans. The US National Toxicology Program recently released its findings of a review of pertinent fluoride animal studies. As explained in a CDC statement on these findings:
" Researchers concluded that there was a low level-of-evidence for learning and memory effects on rats or mice treated during gestation through adulthood. “Low level-of-evidence” reflects NTP’s limited confidence in the apparent relationship between fluoride and learning and memory and a probability that the true effect may be substantially different from the apparent relationship." (2)(3)
The other aspect was 59 human studies of the effects of naturally occurring fluoride on residents in rural areas of China, India, Mongolia, and Iran, areas with the highest amount of environmental fluoride pollution in the world. In most cases, the water fluoride levels in these studies were far too high to be of any relevance to water fluoridated at 0.7 mg/liter in the US. This aside, attempting to equate the total fluoride intake of people constantly engulfed in abnormally high levels of fluoride from coal burning and other sources of fluoride pollution, with the fluoride intake of those living in fluoridated areas of the United States is an obvious exercise in futility.
Nearly half of the human studies were the Chinese studies of the meta-analysis of Choi and Grandjean. By the admission of Choi and Grandjean, themselves, the studies of their review had missing key information, inadequate control for confounders, and questionable methodologies. These studies were so seriously flawed that Choi and Grandjean were led to issue the following statement in 2013:
"These results do not allow us to make any judgment regarding possible levels of risk at levels of exposure typical for water fluoridation in the U.S. On the other hand, neither can it be concluded
that no risk is present. We therefore recommend further research to clarify what role fluoride exposure levels may play in possible adverse effects on brain development, so that future risk assessments can properly take into regard this possible hazard."
--Anna Choi, research scientist in the Department of Environmental Health at HSPH, lead author, and Philippe Grandjean, adjunct professor of environmental health at HSPH, senior author. (4)
Given that Choi and Grandjean state that these studies do not allow for judgment of fluoridated water in the US, it is a mystery why these petitioners would expect the EPA to do so anyway.
The remaining two human studies were the Malin ADHD and Peckham hypothyroid studies. Both of these studies have been widely discredited in the peer-reviewed literature for their inadequate control for confounders, poor methodologies, and reaching conclusions not supported by the scientific literature. (5)(6)
2006 NRC Report
The report of the 2006 NRC Committee on Fluoride in Drinking Water has been misrepresented by fluoridation opponents since its release a decade ago. By plucking out-of-context statements from this report, as did North, opponents have repeatedly misrepresented this study to have supported their position.
In reality, the 2006 NRC Committee was charged to evaluate the adequacy of the EPA primary and secondary MCLs for fluoride, 4.0 ppm and 2.0 ppm respectively, to protect against adverse effects. The final recommendation of this Committee was for the primary MCL to be lowered from 4.0 ppm. The sole reasons cited by the Committee for this recommendation were the risk of severe dental fluorosis, bone fracture, and skeletal fluorosis, with chronic ingestion of water with a fluoride content of 4.0 ppm or greater. Nothing else. Had this Committee deemed there to be any other concerns with fluoride at this level, it would have been responsible for stating so and recommending accordingly. It did not. (7)
The 2006 NRC Committee stated no concerns with neurotoxicity of fluoride at the level of 4.0 ppm or below, when making its final recommendation.
In March of 2013, Dr. John Doull, Chair of the 2006 NRC Committee on Fluoride in Drinking Water made the following statement:
"I do not believe there is any valid, scientific reason for fearing adverse health conditions from the consumption of water fluoridated at the optimal level”
---John Doull, MD, PhD, Chair of the National Academy of Sciences, National Research Council 2006 Committee Report on Fluoride in Drinking Water. (8)
On that NRC Committee were three long time fluoridation opponents, Robert Isaacson, Hardy Limeback, and Kathleen Thiessen. These 3 signed off on the final recommendation of this committee along with the other 9 members.
The "Lancet" did not publish a study by Grandjean and Landrigan as North claimed. It published an article co-authored by Grandjean and Landrigan in which it was briefly mentioned that fluoride was a neurotoxin. This is not news now, nor was it then. Fluoride has been on the EPA list of neurotoxins for the past decade. On that same list are such commonly ingested substances as aspartame (sweetener), ethanol (beer and other alcoholic beverages), salicylate (aspirin), caffeine, and nicotine. (9)
It is of note that in an article in "the Atlantic" on March 18, 2014, Dr. Philip Landrigan, co-author of the "Lancet" article with Grandjean, stated:
“Fluoride is very much a two-edged sword,” Landrigan said. “There’s no question that, at low doses, it’s beneficial.” Flouride has been shown to prevent dental cavities and aid skeletal growth. At higher levels, though, it causes tooth and bone lesions. The epidemiologic studies cited by Grandjean and Landrigan, which came from China, imply that high fluoride exposure has negative effects on brain growth.
“Are the exposure levels in China comparable to what we have in our drinking water and toothpaste?” I asked.
“No, they’re probably higher,” Landrigan said. “In some places in China, there are naturally high levels of fluoride in the groundwater, which picks it up because it’s water-soluble.”
“So your advice isn’t to take it out of our toothpaste?”
“Not at all,” Landrigan said. “I think it’s very good to have in toothpaste.” (10)
Margin of Safety
Fluoridation opponents constantly attempt to declare optimal level fluoride in drinking water to be a drug, and to apply unrealistic, unnecessary testing and standards to it. It is not, as the courts have repeatedly ruled. No court of last resort has ever ruled in favor of this argument of opponents. Fluoride is simply an ion which has always existed in water, and always will, fluoridated or not. Humans have been ingesting it in their water since the beginning of time. In the entire 71 year history of fluoridation, there have been no proven adverse effects. There can be no more conclusive evidence of the adequacy of the existing margin than this. This is precisely why the FDA grandfathered in such substances as aspirin and fluoride supplements when it began its stringent testing protocols. The long record of use and safety of such substances rendered it unnecessary to subject them to lengthy, expensive testing protocols, only to determine what is already known. There are no safety issues with these substances when utilized in the proper use levels.
Dose is another issue attempted to be trumped up into an area of concern by fluoridation opponents. The reality is that when the maximum amount of a substance which can be ingested falls below the threshold of adverse effects, as is the case with fluoride and other routine water additives, dose is not an issue of concern.
Water is fluoridated at 0.7 mg/liter. Thus, for every liter of fluoridated water consumed, the "dose" of fluoride is 0.7 mg. The US CDC estimates that of the total daily intake, or "dose", of fluoride from all sources including dental products, 75% is from the water.
The US Institute of Medicine established daily upper limit for fluoride intake from all sources, for adults, before adverse effects will occur, short or long term, is 10 mg. As can be noted from a simple math equation, before the daily upper limit of fluoride intake could be attained in association with optimally fluoridated water, water toxicity would be the concern, not fluoride.
The range of safety between the minuscule few parts per million fluoride that are added to existing fluoride levels in your water, is so wide that "dose" is not an issue. (11)
In regard to North's naive claim that "other sources of fluoride are ignored" when assessing effects of fluoride, there is no credible individual, or organization associated with fluoridation which does not consider total fluoride from all sources, when determining thresholds of adverse effects. The EPA most certainly considered fluoride intake from all sources when it set the MCL for fluoride, as did the US Department of Health and Human Resources in setting the optimal fluoride level recommendation, as does the WHO when making its recommendations, as does any credible entity when considering fluoridation issues. To claim otherwise, as does North, is ludicrous.
The "precautionary principle" applies when there is not scientific consensus of the safety of an issue under consideration. The benefits of the public health initiative of water fluoridation are fully recognized by the US CDC, the US Institute of Medicine, the American Dental Association, the American Medical Association, the World Health Organization, the American Academy of Pediatrics, those such as the past 6 US Surgeons General, the Deans of the Harvard Schools of Medicine, Dentistry, and over 100 more of the most highly respected healthcare and healthcare-related organizations in the world. Obviously, there is scientific consensus of the safety of water fluoridation. The "Precautionary Principle" does not apply. (12)
(1) EPA Six-Year Review
US Environmental Protection Agency
(2) CDC Letter on NTP Report
(3) NTP Report
(4) Choi and Grandjean statement https://cdn1.sph.harvard.edu/wp-content/uploads/sites/21/2012/07/Media-S...
(5) Critique of Malin
(6) No Evidence Supports the Claim That Water Fluoridation Causes Hypothyroidism
JJ Warren, Maria C.P. Saraiva
J Evid Base Dent Pract 2015;15:137-139
(7) Fluoride in Drinking Water: A Scientific Review of EPA's Standards
Committee on Fluoride in Drinking Water,
National Research Council
(8) Doull Statement http://www.ilikemyteeth.org/wp-content/uploads/2013/03/Doull-Email-on-CW...
(9) EPA list of neurotoxins
(10) Landrigan Interview
(11) IOM Upper Limits http://iom.edu/Activities/Nutrition/SummaryDRIs/~/media/Files/Activity%2... DRIs/ULs%20for%20Vitamins%20and%20Elements.pdf
(12) precautionary principle https://en.m.wikipedia.org/wiki/Precautionary_principle
Steven D. Slott, DDS, is a general dentist in practice in North Carolina. He is the Communications Officer for the American Fluoridation Society, a recently formed non-profit organization which provides accurate information and assistance, free of charge, to communities undergoing efforts from antifluoridationists to undermine fluoridation for their citizens. The AFS is composed entirely of healthcare professionals who volunteer their time, knowledge, and efforts with no remuneration.