Response to Fluoridation Claims of Rick North

This opinion article has been submitted by the American Fluoridation Society.

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.

Petition

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.

Lancet Article

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

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)

Miscellaneous Claims

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)

References

(1) EPA Six-Year Review

US Environmental Protection Agency

https://www.epa.gov/dwsixyearreview/six-year-review-3-drinking-water-sta...

(2) CDC Letter on NTP Report

http://americanfluoridationsociety.org/wp-content/uploads/2016/07/CDC-le...

(3) NTP Report

https://ntp.niehs.nih.gov/ntp/ohat/pubs/ntp_rr/01fluoride_508.pdf

(4) Choi and Grandjean statement https://cdn1.sph.harvard.edu/wp-content/uploads/sites/21/2012/07/Media-S...

(5) Critique of Malin

------http://www.fluoridescience.org/articles/exposure-to-fluoridated-water-an...

(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

1532-3382

(7) Fluoride in Drinking Water: A Scientific Review of EPA's Standards

Committee on Fluoride in Drinking Water,

National Research Council

pp 352

(8) Doull Statement http://www.ilikemyteeth.org/wp-content/uploads/2013/03/Doull-Email-on-CW...

(9) EPA list of neurotoxins

http://americanfluoridationsociety.org/wp-content/uploads/2016/04/epa_mu...

(10) Landrigan Interview

http://www.theatlantic.com/features/archive/2014/03/the-toxins-that-thre...

(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.

News source: 

Comments

I can't prove connection to Big Business but everything he does screams that the connection is there. Spend some time on the www.fluoridealert.org website and get both sides of this argument before you agree to continue this incredibly dangerous dumping of industrial waste product in your water supply.
Paul Smith

But you can prove that Fluoride Alert - or the Fluoride Action Network is connected to big business - and financed by it. The Connetts receive monthly payments for their anti-fluoride activity from the "natural"/alternative health industry - particularly Mercola.com

there is no industrial waste product dumped in our water and the science shows that community water fluoridation is safe and effective. Have a read of:

Eason, C., & Elwood, JM. Seymour, Thomson, WM. Wilson, N. Prendergast, K. (2014). Health effects of water fluoridation : A review of the scientific evidence. Retrieved from http://www.royalsociety.org.nz/expert-advice/commissioned-reviews/yr2014...

Dr. Ken Perrott

Comparing to other commonly ingested NEUROTOXINS only reminds people that NONE of them should be added to public drinking water. Steven, I'm not surprised to see you again. Your tired arguments are no better than tobacco "science". Funny how you're in North Carolina and yet you stick your nose into Oregon public health policy. For the good of humanity, do us all a favor and quit peddling your snake oil. That goes for the ADA, too, who are not experts in neurotoxicology and they profit from fees from their monopoly of approviding fluoridated products. Lead was considered safe for SIX DECADES, too.

Kenric Ashe

 

Your tired red-herring arguments in your feeble attempt to link nearly 72 years experience of fluoridation and research to tobacco science and lead falls on deaf ears to only those who are science deniers.

You're concerend about the location of residence of Dr. Slott's; yet, you don't criticize the out-of-state comments which align with your opinion of fluoridation such as Paul Smith (California ?) and Karen Spencer of Massachucetts.  News to Kenric:  the internet is global.  If Rick North has his comments published on the internet, it's available worldwide.  Dr. Slott has every right to stick his nose in public health policy in Oregon.  

Fluoridation is a 20th Century adaptation of a naturally-occurring process.  ALL water has some fluoride ions in it, just not at the optimal level.  You've been drinking fluoride all your life.  I suspect it was at the optimal level back in Tennessee where you're from.

You mention "snake oil salesman".  You have to look no further for the #1 snake oil salesman in the U.S. than Joseph Mercola, who is a major funder of the Fluoride Action Network.

Dr. Kurt Ferre

Dr, Ferre, thank you for letting us know that the opposition to your position are "science deniers". I was disappointed that you didn't use the word "Luddite". 

Delores Porch

Delores, thank you for letting us know you reside in highly-educated, highly fluoridated Benton County, OR.  The largest city in Benton County, Corvallis, home of Oregon State University, has been fluoridated for over 50 years.

Would you please comment on how the Chinese IQ studies have any relevance to Benton County?  Where's the brain drain that the Fluoride Action Network, Paul Connett, and Rick North alledge is happening to our children who are born/raised with fluoridation throughout the United States?

Help me understand why since the beginning of fluoridation in the United States in 1945 (72 years on January 25th) that the IQ in the United States has risen an average of 3 points a decade or a total of 15 points.

Here's a nice analysis that most readers should be able to understand recently done by Snoopes.com on fluoridation and IQ.   www.snopes.com/water-fluoridation-reduces-iq/

Kurt Ferre 

Dr. Slott, I live in a highly educated part of Oregon, Benton County.  In this county we went through several political campaigns about what’s in the food we eat and how it affects the environment. Name calling was a highly used tactic. The minute you started referring to your opposition as “fringe” I tuned you out. It was like you brought a firearm to the discussion. Many of us view it as a form of intimidation.  It works in political campaigns, but The Lund Report doesn’t seem an appropriate venue to do so.  Furthermore, in my neck of the woods professional affiliations and research mean nothing unless we know the funding source of that organization or authors. You're welcome to try again.

Delores Porch

 

I’ll respond directly to the critics of my January 11 column, but first the quick story of how I got into all this.

 

Like many people, I once believed that fluoridation wouldn’t harm anyone. I thought this because the two chief promoters, the U.S. government and American Dental Association, plus other groups that followed them, said so. They’re the experts, right?

 

Well, not always. We’ve seen this before when the government and medical establishment have accepted a substance as safe for decades, only to finally accept a growing body of scientific evidence that they were wrong and change their position. (Up until 1953, doctors were still advertising cigarettes in the Journal of the American Medical Association.) Leaded gas and paint, asbestos, DES and DDT are other familiar examples.

 

The very same thing is happening with fluoridation as new science keeps accumulating against it, as documented by the EPA petition.

 

It all changed for me eight years ago when a friend asked me to actually research the subject. When I did, I was amazed and very concerned. The scientific and historical evidence was so compelling that it was easy to change my mind and oppose the practice. I got interested in the issue and have worked on it as a volunteer ever since.

 

The single most authoritative source was the 2006 NRC report, compiled by a well-balanced group of 12 scientists, some proponents, some opponents, and some with no confirmed opinions. Promoters’ implication that the committee’s only charge was to assess whether 4.0 ppm was safe is incorrect. The EPA, in asking for this review, knew concentration in water was only part of the story. The NRC scientists were also looking for fluoride’s effects on numerous diseases, identifying subgroups more susceptible to harm than the average person, quantifying other sources of fluoride, and finding gaps in the scientific research (p. 20-22).

 

In addition to its unequivocal conclusion that fluorides “interfered with the functions of the brain,” (p. 222), the committee also linked fluoride to diabetes (p. 260) and kidney disease (p. 303). It also said “Fluoride is therefore an endocrine disruptor . . .” (p. 266) and “The chief endocrine effects of fluoride include decreased thyroid function. . .” (p. 8)

 

(I was accused of taking quotes out of context. This report is online and I’m including the page numbers. Readers can decide for themselves.)

 

As much as anything, the NRC committee stated clearly that more research was necessary, regarding all the diseases cited above and more.

 

My second major source was Christopher Bryson’s book, The Fluoride Deception, which examined the history and politics of how fluoridation began. Bryson formerly worked for the BBC and NPR and has won numerous awards for investigative reporting.  Exhaustively documented, it chronicled the influence of the aluminum and nuclear industries, which used fluoride, to whitewash its harm to health. Moreover, slanted, corporate-funded studies unduly influenced the U.S. government to endorse the practice.

 

 Bryson also exposed the disturbing pattern of personal and professional attacks on scientists and physicians who opposed fluoridation, which continues today. Several scientists who produced studies finding dangers of fluoride were cut off from government research funding or fired. This wasn’t science, it was intimidation. (Government or corporate, I’ve never liked bullies.)

 

My third revelation was the chasm between the U.S. and most of the rest of the nations of the world. Out of 196 countries, only 25 have any artificial fluoridation at all. In Europe, 44 out of 48 nations have none. Most never started, but seven that did stopped, including Germany, Sweden, Switzerland, Netherlands, Finland, the Czech Republic and Northern Ireland.

 

Promoters often cite geography, preference for bottled water or fluoridated salt for Europeans’ rejection of fluoridation. Quotes from government health officials tell a far different story. The full statements, plus many more, are at http://fluoridealert.org/content/europe-statements/ :

 

France: “Fluoride chemicals are not included in this list (of approved chemicals). This is due to ethical as well as medical considerations.”

 

Austria: “. . . toxic fluorides have never been added to the public water supplies of Austria.”

 

Sweden: “Drinking water fluoridation is not allowed in Sweden…New scientific documentation or changes in dental health situation that could alter the conclusions of the Commission have not been shown.”

 

Czech Republic: “Since 1993, drinking water has not been treated with fluoride . . . because this form of supplementation is considered:

 

  • Uneconomical
  • Unecological
  • Unethical (forced medication)
  • Toxicologically and physiologically debatable”

 

Somehow, in the face of all this, Dr. Slott continues to insist “Obviously, there is scientific consensus of the safety of water fluoridation.” Readers can decide for themselves.

 

I can’t cover all the misleading statements, but here are a few specific rebuttals that are representative:

 

Marginalizing me and anyone daring to oppose fluoridation is typical (“really surprised” the Lund Report prints my columns, “fringe,” etc.). During the 2013 Portland campaign, the Oregonian editorial board accused us of “crackpottery,” which I didn’t even know was a word.

 

Promoters are especially contemptuous towards the Fluoride Action Network, which has led the charge against fluoridation. I encourage you to take five minutes and decide for yourself how FAN’s professional examination of neurotoxicity (http://fluoridealert.org/studies/brain01/ ) compares to ADA’s “Fluoridation Facts,” (http://www.ada.org/~/media/ADA/Member%20Center/FIles/fluoridation_facts.ashx), (p. 36) which has remained virtually unchanged since it was written in 2005 (before the 2006 NRC report). It becomes immediately apparent who has done their homework and why I lost all confidence in ADA’s statements on fluoridation.

 

Other statements are simply untrue, such as saying fluoride used to prevent cavities isn’t a drug. Of course it is. The FDA both defines and regulates it (although certainly not enough). FDA regulation is why you’ll see the warning label on fluoridated toothpaste about kids’ swallowing it and why you need to have a prescription to buy fluoride tablets.

 

Then there’s the reference to the Chinese IQ studies to “people constantly engulfed in abnormally high levels of fluoride from coal burning and other sources of fluoride pollution.” In reality, virtually all the studies compared rural villages, so industrial pollution wasn’t a factor. Also, Choi’s analysis included two studies comparing villages with significant differences in coal burning. Like the water, the higher the coal (and fluoride), the lower the IQ.

 

Finally, one sample half truth. Incredibly, the section on dose concludes that it’s “not an issue,” using the Institute of Medicine’s safety dose of maximum of 10 mg per day. What is not said is that the IOM’s dose level, highly questionable itself, only refers to fluorosis. It doesn’t even deal with neurotoxicity, the entire subject of the EPA petition and my column.

 

To me this is obvious:  If leading scientists cite hundreds of studies on fluoride finding harm and/or lack of evidence, and government health ministries all over the world don’t support fluoridation, there is certainly no “consensus.”

 

To repeat the wisdom of “First do no harm,” “Better safe than sorry,” the Precautionary Principle, etc.: If there’s reasonable doubt if a substance is safe, the public shouldn’t be intentionally exposed to it. We’re far beyond reasonable doubt. The EPA should do its job and end this most ill-advised experiment.

Rick North

 

 

 

 

Rick North states that the American Dental,Association is not an expert on a dental/healthcare issue such as water fluoridation.  Rick North states that he doesn't trust the opinions of the American Dental Association on a dental/healthcare issue, and bases his opposition to fluoridation on out-of-context information plucked from the 2006 NRC report on fluoride in drinking water, a non peer-reviewed book of conspiracy nonsense by an "investigative reporter", and some "chasm" involving healthcare policies of other countries.  

And Rick North can't understand why intelligent people call his views, as he put it, "crackpottery"?  Seriously??


Rick North states that he "can't cover all the misleading statements".  Why? Because there are no "misleading statements" in my posts.  On the other hand, I can "cover" all his misinformation, misleading claims, and fabrications.  Why?  Because I understand the issue of fluoridation, have spent countless hours over the past several years reviewing the scientific evidence from primary sources, reading scientific studies in their entirety from their primary sources, and discussing the issue with the authors of many of these studies and with other highly knowledgeable individuals.....as opposed to relying on misinformation,  out-of-context quotes, and misrepresented science, appearing on activist websites and in non peer-reviewed little books.

So....

1.   The American Dental Society is indeed the expert in regard to dental healthcare issues, of which fluoridation is one. The courts, as well as respected science and healthcare, fully recognize this obvious fact.......North’s personal opinion to the contrary notwithstanding.

2.  There is no “growing body of scientific evidence” that fluoridation is, in any manner “wrong”  There are only the irrelevant studies, misinformation, and misrepresented science constantly disseminated by fluoridation opponents.  Those who don't limit their  "research" to perusal of biased little antifluoridationist websites, understand this.

3.  Advertisements in the 1953 Journal of the AMA, cigarettes, leaded gas and paint, DES, and DDT….have no relevance whatsoever to the public health initiative of water fluoridation.

4.  As I clearly demonstrated, the petition sent by the “fluoride action network” and the “mom’s against fluoridation” is  based on irrelevant studies from China, India, Iran, and Mongolia, the most highly environmentally fluoride polluted region  in the world.  The petition has no merit.

5.  Proper research of fluoridation, and all other scientific issues consists of obtaining accurate information from respected, reliable sources.  It does not consist of perusing misinformation posted on biased activist websites.  Proper research involves reading entire studies from their primary sources, and critical evaluations of them from those qualified to render appropriate ones.  It does not consist of copy/pasting titles of irrelevant studies from  activist websites, and relying on out-of-context blurbs from those studies, posted on those activist websites.

6.  North’s personal opinion to the contrary, notwithstanding, the charge to the 2006 NRC Committee on Fluoride in Drinking Water was indeed to assess the adequacy of the EPA primary and secondary MCLs for fluoride, 4.0 ppm and 2.0 ppm respectively, to protect the public from adverse effects.   Over a 3 year period, this committee did an exhaustive review of the pertinent scientific literature on fluoride.  In its final report, the committee dutifully reported what was in the literature, and what it deemed to be of relevance to water at the 4.0 ppm level it was charged to evaluate.  The final report listed but 3 concerns of fluoride at the level of 4.0 ppm or below, which it believed to be of importance….severe dental fluorosis, increased bone fracture, and skeletal fluorosis.  That was it.  Had this committee had any concerns with neurotoxicity or any other aspects of fluoride at this level, it would have been responsible for so stating and recommending accordingly.  It did not.  

"The Safe Drinking Water Act requires that EPA periodically review existing standards for water contaminants. Because of that requirement and new research on fluoride, EPA’s Office of Water requested that the NRC reevaluate the adequacy of the MCLG and SMCL for fluoride to protect 
public health. The NRC assigned this task to the standing Committee on Toxicology, and convened the Committee on Fluoride in Drinking Water. The committee was asked to review toxicologic, epidemiologic, and clinical data, particularly data published since 1993, and exposure data on orally ingested fluoride from drinking water and other sources (e.g., food, toothpaste, dental rinses). On the basis of those reviews, the committee was asked to evaluate independently the scientific basis of EPA’s MCLG of 4 mg/L and SMCL of 2 mg/L in drinking water and the adequacy of those guidelines to protect children and others from adverse health effects. The committee was asked to consider the relative contribution of various fluoride sources (e.g., food, dental-hygiene products) to total exposure. The committee also was asked to identify data gaps and make recommendations for future research relevant to setting the MCLG and SMCL for fluoride. Addressing questions of economics, risk-benefit assessment, and water-treatment technology was not part of the committee’s charge."

-----Fluoride in Drinking Water: A Scientific Review of EPA's Standards
http://www.nap.edu/catalog/11571.html
pp 18-20


Regarding the final recommendation of the 2006 Committee:

Severe dental fluorosis is rare in the United States and, as stated by the 2006 Committee, it does not occur in communities with a water fluoride content of 2.0 ppm or below.  
Skeletal fluorosis is so rare in the United States so as to be nearly non-existent.  
Bone fracture has been demonstrated to not be of concern in association with water with a fluoride content of 2.0 ppm or below.  Water is fluoridated at 0.7 ppm.

In plucking quotes from the 2006 NRC report without noting that the committee duly reported what it found in the scientific literature, regardless the source and quality of that literature, and what of those findings  the committee deemed to be of importance at the level of 4.0 ppm, North and other fluoridation opponents are indeed misusing this report out-of-context.  Once again, from the chair of this 2006 NRC report:


"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

http://www.ilikemyteeth.org/wp-content/uploads/2013/03/Doull-Email-on-CW...

7.  Given that North’s “ single most authoritative source”, did not deem neurotoxicity, or any adverse  effects on the endocrine system,  of any sufficient concern at the water fluoride concentration of 4.0 ppm or below, it is a mystery why North continues to attempt to mislead the public with his out-of-context quotes from this report.

10.  Christopher Bryson is an “investigative reporter”.  That North believes Bryson’s non peer-reviewed book of conspiracy nonsense to be a credible source of information on a science/healthcare issue such as water fluoridation, is of no surprise.

11.  North’s attempt to play “follow-the-leader” with other countries in regard to healthcare policies, as opposed to recognizing that what one country deems to be in the best interests of its citizens is of no real relevance to that which other countries so deem for their citizens...... is typical of fluoridation opponents.  With nearly 75% of the US fluoridated, the only counter to that I suppose is to declare healthcare professionals, experts, and authorities in the US to be incompetent, and to list what other countries do, as if this has any relevance, whatsoever to water fluoridation in the US.

12.  Uncited personal opinions purported to be from this country or that, are obviously meaningless.

13.  “Fluoridealert” is the biased website of “fluoride action network”.  I fully concur with North that readers should compare the filtered and edited nonsense posted on that site with the ADA "Fluoridation Facts".  Attempting to compare filtered and edited junk on  “fluoridealert” with information from the American Dental Association, on a dental/healthcare issue, is akin to comparing the website of a little astrology group with the opinions and recommendations of NASA, on an issue of space exploration.  While North has certainly made a litany of ridiculous claims, few are any  more ludicrous than this whopper of his.

14.  The FDA has no jurisdiction or relevance to fluoride in public water systems. This jurisdiction falls entirely under the EPA.   North’s personal opinion that fluoride at the optimal level in water is a drug of some sort has been continually ruled to the contrary by the courts, every time fluoridation opponents have attempted it.  

Fluoride has existed in water forever.  To suddenly proclaim this ion to be a drug, could not be any more absurd.

15.  Toothpaste contains fluoride in a concentration 1200-1500 times that in optimally fluoridated water.  That is the reason for the warning on the tube.

16.  The reason that fluoride supplements require prescription is to ensure as best as possible that there is accountability for checking the existing level of fluoride in the patient’s primary water source prior to dispensing these supplements.  That  same safeguard exists with fluoridated water.  Prior to fluoridating a public water system, the existing fluoride level is determined.  Once done, only that amount of fluoride ions is added which will bring the total fluoride concentration up to the optimal level of 0.7 ppm.

17.  People in rural areas of China, India, and Iran, are subjected to abnormally high fluoride intake from the pollution of the air from coal burning in homes and businesses, as well as from fluoride polluted streams, rivers, and ground water.  They eat food grown on land subject to that fluoride pollution, with  water from rivers and streams polluted with high levels of fluoride.  Again attempting to equate total fluoride intake of the residents of these areas with that of residents of fluoridated areas of the US is futile.

18.  Severe dental fluorosis is rare in the United States, and as stated by the 2006 Committee, it does not occur in communities with a water fluoride content of 2.0 ppm or below.  Skeletal fluorosis is so rare in the United States so as to be nearly non-existent.  Bone fracture has been demonstrated to be of no concern in association with water with a fluoride content of 2.0 ppm or below.  Water is fluoridated at 0.7 ppm.

The prevalence of severe enamel fluorosis is close to zero in communities at all water fluoride concentrations below 2 mg/L."

-----Fluoride in Drinking Water: A Scientific Review of EPA's Standards
http://www.nap.edu/catalog/11571.html
pp 114


19.  North's claim that "What is not said is that the IOM’s dose level, highly questionable itself, only refers to fluorosis. It doesn’t even deal with neurotoxicity, the entire subject of the EPA petition and my column.".......is pure fabrication on his part.

A.  The US Institute of Medicine established daily upper limit of fluoride intake does not "refers to fluorosis".  This daily upper limit is that level below which adverse effects are not known to occur.  This includes neurotoxicity and all other ridiculous claims of disorders North and other fluoridation opponents attempt to associate with optimally fluoridated water. 
                     
"A tolerable upper intake level (UL) is the highest level of daily  nutrient intake no risk of adverse health effects to almost all individuals in the general population.  Unless otherwise specified, the UL represents total intake from food, water, and supplements."

http://www.nationalacademies.org/hmd/~/media/Files/Activity%20Files/Nutr...

B.  Readers are free to judge for themselves as to which is "questionable in itself":
    1) the unsubstantiated personal opinion of Rick North, or
    2) the recommendations of the United States Institute of Medicine, a division of the         National Academies of Science.

It is interesting that one arm of NAS (NRC) is deemed by North to be "The single most authoritative source" on fluoride in drinking water, while he deems another (IOM) to be of "highly questionable" credibility.  Hmmm, wonder if his blatant confirmation bias could have something to do with this.....

20.  The lack of relevance of the "hundreds of studies" North claims are cited by "leading scientists, aside, there are 53,000 studies on fluoride indexed on PubMed.  The 300 studies claimed by North and "FAN" constitute a whopping 0.57% of these studies.  That means that 
99.43% do not support their position.  Hmmm, seems like consensus to me.

Even if we only use  the number of fluoride studies considered by the recent Cochrane Review, 4,600, this 300 studies of North and "FAN" still only constitute 6.5%.  That leaves 93.5% which do not support their position.  

Clearly, there is scientific consensus of the safety of fluoridation. 

The "precautionary principle" does not apply.


Steven D. Slott, DDS
Communications Officer
American Fluoridation Society

 

 

Bill. Osmunson DDS, MPH

Fluoride Action Network, Director  

 

Steven Slott expresses misconceptions and bias of science and law.

 

  1. Attacking the messenger rather than the message.

 

Instead of presenting quality science such as prospective randomized controlled trials on the efficacy, safety, dosage and label of ingesting fluoride to the FDA CDER (US Food and Drug Administration Centers for Drug Evaluation and Research) for their review and approval, promoters choose personal attacks.  Why?  There are no RCT (prospective randomized controlled trials) studies on the efficacy of fluoridation. The FDA CDER has rejected the ingestion of fluoride due to lack of evidence of efficacy. 

 

Promoters have not convinced the FDA CDER and many quality scientists, health departments or governments.  Without adequate science, promoters use personal attacks, endorsements, coercion and policy.

    2.   Fluoride ingestion is an unapproved, illegal, misbranded and adulterated legend [prescription] drug. 

Drugs are defined as “articles intended for use in the . . . prevention of disease” [FD&C Act, sec. 201(g)(1)].     “Intended use may be established in a number of ways.  Among them are:. . . .Consumer perception . . . .  Ingredients . . .  have a well known (to the public and industry) therapeutic use.”

 For example, fluoride toothpaste is FDA CDER approved as a drug with label including, “Do Not Swallow.”  The FDA CDER has not approved the ingestion of fluoride at any dosage with the intent to prevent dental caries.   

 

Another example is fluoride supplements, pills, are drugs.  Pharmacies require a doctor’s prescription to purchase fluoride pills.  The FDA CDER rejected fluoride supplements due to incomplete evidence of effectiveness.

 

The FDA sent letters to the Boards of Pharmacy, stating: “Manufacturers of unapproved drugs are usually fully aware that their drugs are marketed illegally, yet they continue to circumvent the law and put consumers’ health at risk.”[1]

 

    3.   Without FDA CDER approval, fluoride ingestion will remain controversial.

 

Promoters have attempted to turn the tables and expect patients, recipients, those opposed to mass medication to provide high quality science and “proof” of harm.  In fact, the law requires the final manufacturers prior to marketing to gain approval and the FDA CDER judges the evidence; is it effective at a specific dosage, safe at that dosage, and a label is required to protect those at high risk. 

 

In 1975 Drug Therapy reported the FDA CDER had rejected fluoride supplements because of a lack of evidence of efficacy.  In 2016, the FDA CDER confirmed fluoride supplements are not approved.  The FDA has testified to Congress that fluoride is a drug.

 

If promoters are correct and the evidence is strong for both efficacy and safety, certainly promoters could take the evidence of the last 70 years to the FDA CDER and gain approval for fluoridation and/or fluoride supplements.   FDA was notified of fluoride water bottle claims, but the manufacturers never went through the FDA CDER approval process and evaluation.

 

Promoters sometimes argue that fluoride is NOT a drug and does not need FDA CDER approval.  However, fluoride is highly toxic, more toxic than lead and less than arsenic. Fluoride toxicity fits within state and Federal laws as a “poison” and has been used as a poison.[2] Poisons are exempt from poison laws when regulated under drug or pesticide laws.  Therefore, IF fluoride is NOT a drug (no intent to prevent disease), ingesting fluoride is not exempt from poison laws.  Poison laws are strict and there is no approval process or minimal concentration for ingesting or dispensing poisons. Promoters must follow the approval process laid out by Congress and gain FDA CDER approval.

 

I promoted fluoride ingestion for the first 25 years of dental practice.  Several of my family members have dental fluorosis to prove it.  Indeed, about 60% of the USA children now have dental fluorosis, a biomarker of excess fluoride exposure, with 2% showing severe dental fluorosis a known adverse effect.  

 

Listening to my patients, I finally read both sides of the research.  The evidence is like a knee in the gut.  Many are ingesting too much fluoride.  Benefit is not supported by good science. The evidence of serious risk is rapidly growing.  My professions cherry pick the evidence supporting policy rather than people.

 

Promoters have not determined an “optimal” fluoride concentration for the tooth.  Both caries and caries free teeth have a similar range of fluoride concentrations.  Nor do we have an “optimal” serum or urine fluoride concentration.  To suggest  an “optimal” water fluoride concentration when we don’t know the desired serum or tooth concentration is fake science.

 

Mother’s milk contains no detectible fluoride in most samples and is optimal for the developing brain. Formula made with fluoride water is excessive.  And to protect the fetus, mothers should lower their fluoride intake.[3]

 

We should warn our patients not to swallow toothpaste, especially children, use a tiny smear on a brush for children, pregnant mothers to be especially careful not to swallow fluoride or fluoride products, and infants should not have formula made with fluoridated water.

 

Gaining FDA CDER approval while carefully instructing our patients with balanced evidence will raise everyone’s confidence in our professions.

 

 

 

 

 

[1] Compliance News, July 2008 Washington State Board of Pharmacy News Letter at http://www.doh.wa.gov/hsqa/professions/pharmacy/documents/July2008.pdf

 

[2] Some states define a poison as a substance which causes violent sickness or death in humans with 60 grains (3,889 mg).  Others define a poison as a substance which causes  death with less than 50 mg/kg bw for white rats.  Fluoride is considered lethal for humans at more than 5 mg/kg bw.

[3] Valdez Jime ́nez L, Lo ́pez Guzma ́n OD, Cervantes Flores M, Costilla-Salazar R, Caldero ́n Herna ́ndez J, Alcaraz Contreras Y, Rocha-Amador D.O. In utero exposure to fluoride and cognitive development delay in infants. Neurotoxicology http://dx.doi.org/10.1016/j.neuro.2016.12.011

Bill Osmunson


Bill, seriously?  You present this mess of your usual misunderstanding and garbling of facts and law, and, with a straight face, claim that I "express misconceptions and bias of science and law?  Does it ever enter into the minds of you "FAN" guys that intelligent people usually want valid evidence to support claims.....of which you provide none?  Contrary to your belief, your personal opinion does not qualify as valid evidence of anything.

Sigh....

1.  Attacking.....otherwise known as exposing the fallacies of.....the message is precisely what I have done.  

 
2.  As has been made abundantly clear to you, ad nauseum:

 The FDA has no jurisdiction over the contents of public drinking water supplies.  That jurisdiction falls entirely under  the EPA.  Fluoride ions have existed in water forever.  Attempts by antifluoridationists to suddenly proclaim these fluoride ions to be a "drug", and subject it to unnecessary testing procedures is ludicrous.

B.  Does the following  look like the FDA has "rejected the ingestion of fluoride"? 


"The allowable level for added fluoride in bottled water in FDA’s bottled water regulations was based on the previous PHS recommendation. We intend to revise the quality standard for fluoride added to bottled water in 21 CFR 165.110(b)(4)(ii) to be consistent with the updated PHS recommendation. In the interim, we recommend that bottled water manufacturers do not add fluoride to bottled water at concentrations greater than a maximum final concentration of 0.7 mg/L."

---Letter to Manufacturers, Distributors, or Importers of Bottled Water with an Update on Fluoride Added to Bottled Water
US Food and Drug Administration
http://www.fda.gov/food/guidanceregulation/guidancedocumentsregulatoryin...

Does the following look like the FDA CDER has " rejected the ingestion of fluoride due to lack of evidence of efficacy"? :

"According to the June 16 notification and the letter to FDA dated October 13, the food eligible to bear the claim is bottled water meeting the standards of identity and quality set forth in 21 CFR 165.110, containing greater than 0.6 and up to 1.0 mg/L total fluoride, and meeting all general requirements for health claims (21 CFR 101.14) with the exception of minimum nutrient contribution (21 CFR 101.14 (e)(6)). The claim language is: 'Drinking fluoridated water may reduce the risk of [dental caries or tooth decay].' In addition, the health claim is not intended for use on bottled water products specifically marketed for use by infants."

--Health Claim Notification for Fluoridated Water and Reduced Risk of Dental Caries
http://www.fda.gov/food/ingredientspackaginglabeling/labelingnutrition/u...

 C.   RCTs are infeasible for large, population-based public health initiatives such as water fluoridation, and will never be performed for fluoridation.  Both the 2000 York Review and its update, the 2015 Cochrane Review fully recognized this fact.  It is a mystery why you and your "FAN" still attempt to mislead the public with ridiculous clamoring for RCTs on a fluoride ion which humans have been ingesting in water since the beginning of time.

"However, there has been much debate around the appropriateness of GRADE when applied to public health interventions, particularly for research questions where evidence from randomised controlled trials is never going to be available due to the unfeasibility of conducting such trials. Community water fluoridation is one such area."

---Water fluoridation for the prevention of dental caries
(Review)
Iheozor-Ejiofor Z, Worthington HV, Walsh T, O’Malley L, Clarkson JE, Macey R, Alam R,
Tugwell P, Welch V, Glenny AM
The Cochrane Collaboration 2015

3.  If the FDA had not approved fluoride for ingestion, there would be a large amount of empty shelves in retail stores where currently reside FDA regulated products such as fluoridated toothpastes, fluoridated mouth rinses, and other dental products.

4.  You are welcome to make your argument in court that Bill Osmunson has personally deemed  optimal level fluoride in drinking water to be a drug.  However, given that the courts have rejected this nonsense each and every time antifluoridationists have wasted court time and resources trotting it in.....I don't much like your chances with that.

5.  Toothpaste has a fluoride concentration 1200-1500 times that of fluoride in optimally fluoridated water.  That is the reason for the warning on the tubes.

6. See my item #2B in regard to your claim as to what you personally deem FDA CDER to have not approved.

7.  Fluoride supplements require prescription in order to ensure, as much as is possible, accountability for determining the existing fluoride content of the patient's primary water source, prior to dispensing the supplements.  The same safeguard exists for fluoridation.  Prior to fluoridating a water system, the existing fluoride level of that water is determined.  Once determined, only that amount of fluoride is added which will bring the total concentration to the optimal level. 

 FDA CDER did not reject fluoride supplements.  Substances such as fluoride supplements , aspirin, and others, which have a long record of safety and effectiveness, were grandfathered in under FDA regulations in order to not subject such substances to extensive, expensive, and unnecessary testing only to determine exactly what is already known about such substances......they are safe and effective.  There is no valid, peer-reviewed scientific evidence that in any manner contradicts this decision.
   
8. What letters the FDA has sent to anyone, anywhere, are irrelevant to optimally fluoridated water.  The FDA has no jurisdiction over, or relevance to, optimally fluoridated water.

 9.  There is nothing "controversial" about water fluoridation.  There are simply the peer-reviewed scientific evidence which clearly supports the initiative, and the false statements, unsubstantiated claims, misrepresented science, and utter nonsense of antifluoridationists and their organizations.

10.  As the FDA has no jurisdiction over the contents of drinking water supplies, what its policies require for the substances over which it does have jurisdiction....are of no relevance to optimally fluoridated water.

11.  Antifluoridationists are requesting  the sudden cessation of a public health initiative which has provided a very valuable health benefit to hundreds of millions of people over the past 71 years, with no proven adverse effects. It is therefore incumbent upon them to provide valid evidence to support this request, not the other way around.  It is not the responsibility of anyone to disprove the constant flow of unsubstantiated claims of antifluoridationists. 

12.  The relative toxicity argument constantly attempted by antifluoridationists has no merit.  This toxicity is in regard to amount of a substance required to reach the threshold of toxicity.  That it takes less fluoride to teach toxicity than it does for plain water to reach toxicity simply means that the amounts of each must be monitored to avoid crossing that threshold.  So what?  

If you want to fear-monger about relative toxicities, then you better be leery of  your morning cup of coffee.  Caffeine is more toxic than arsenic.

13.  The only dental fluorosis which may be attributable to optimally fluoridated water is mild to very mild, a barely  detectable effect which causes no adversity on cosmetics, form, function, or health of teeth.  As peer-reviewed science has demonstrated mildly fluorosed teeth to be more decay resistant, many consider this effect to not even be undesirable, much less adverse.  

As clearly stated in the report of the 2006 NRC Committee on Fluoride in Drinking Water, severe dental fluorosis does not occur in communities with a fluoride concentration of 2.0 ppm or less....and this most certainly takes into account fluoride intake from all sources.

If I recall correctly, you have indicated in the past that you have have charged thousands of dollars to treat dental fluorosis resultant of optimally fluoridated water.  As mild dental fluorosis requires no treatment....is your state dental board aware of these unnecessary and highly expensive treatments you've performed?

14.  Personal anecdotes about some  knee hitting you in the gut, and unsubstantiated claims about the effectiveness of fluoridation....are obviously meaningless.

15.  The optimal level of fluoride is not a suggestion, it is, by definition, that concentration of fluoride in drinking water at which maximum dental decay prevention will be obtained, with no adverse effects.  This optimal level is an official recommendation of the United States Department of Health and Human Services.  The optimal level is 0.7 mg/liter.  You are certainly free to argue with DHHS your personal opinion that an optimal concentration has not been determined.....but....alas.....I don't much like your chances with that.

16. "Mother's milk" is of no relevance to optimally fluoridated water.  "Mother's milk" is deficient in iron, Vitamin K and Vitamin D to the point of requiring supplementation for breast-fed infants..  By your "logic", nature intends for infants to be anemic free-bleeders who develop rickets.

17.  There is no credible organization or authority which states that "pregnant mothers" should not swallow fluoride, or that "infants should not have formula made with fluoridated water".  These claims are nothing but your own, skewed personal opinion which have no foundation in science, or reality.


Steven D. Slott, DDS
Communications Officer
American Fluoridation Society
   
 
 

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Many do not and should not trust the American Dental Association for scientific information.  Good scientists do not "trust," but ask for measured evidence.

The ADA exists to protect dentists, and so it should.  The ADA did not write the position on fluoride ingestion.  The fluoridation evidence is about a decade old and seriously biased, presenting only the evidence which supports policy and those funding the ADA.  The dental association is a union of like minded individuals.   The evidence they publish must be sanitized to support their source of income.  

Science should not be a "faith based" club and our current understanding of nature should constantly be reviewed and challenged.  Name calling and attacking individuals is not scientific.

Years ago, my mentor reminded me that I would have to learn 80% of what was taught in dental school and 50% of what we were taught is wrong. . . we just don't know which 50%.  We should all have a healthy respect for the unknown and be open to discovering more rather than trying to prove our bias.  

I find the attacks above degrading and are not productive to learning and exploring what science has to offer, hard cold measured evidence.  In the end, we do need to make a judgment on the evidence.  

In my opinion, the USA will slowly gravitate to the high standards of the Europeans and most of the world, providing freedom of choice without mass medication of an unapproved highly toxic substance.

Bill Osmunson

 

 

 

My summary of Dr. Slott’s comments:

Science favoring fluoridation is good; science opposing fluoridation is bad

Scientists favoring fluoridation are right; scientists opposing fluoridation are wrong or ignored

Websites favoring fluoridation are unbiased; websites opposing fluoridation are biased

Quotes favoring fluoridation are in context; quotes opposing fluoridation are taken out of context

The opinion of the U.S. government is always right; the opinions of numerous other nations’ health ministries mean nothing

If leading scientists say more research is needed on numerous health risks of fluoridating water, that also means nothing – just keep fluoridating

How much fluoride you consume – the dose - is not an issue. (I’m not making this up)

Actually, Dr. Slott and I agree on one thing – people should compare the Fluoride Action Network’s website (http://fluoridealert.org/studies/brain01/) with the American Dental Association’s (http://www.ada.org/~/media/ADA/Member%20Center/FIles/fluoridation_facts....) (p. 36) on neurotoxicity.

Dr. Slott refers to ADA’s website as “information” comparable to NASA, while calling FAN’s “filtered and edited nonsense,” comparable to “a little astrology group.” (It’s pretty hard to take these quotes out of context)

If you don’t have five minutes to check these out, here’s a quick comparison:

The ADA’s website:

• Has six paragraphs on neurotoxicity, with no more recent references than 1995 • Mainly criticizes the 1995 Mullenix rat study that found neurotoxic harm from fluoridated water (45 other animal studies finding fluoride’s neurotoxic effects were not mentioned)

One paragraph cited a 1986 study finding no harm

In contrast, Fluoride Action Network’s website has:

• Detailed summaries of 50 IQ studies from 1989 to 2016 showing links between higher fluoride and lower IQ; they include location, size, age of subjects, confounding factors, and other information

• Full explanation of methodological limitations of studies

• Discussion of 7 studies that didn’t find a lowering of IQ from fluoride; abstracts are provided for each

• Summaries and links to abstracts of 45 animal studies on neurotoxicity

• The actual 1995 Mullenix study in its entirety and a full review

• Full interview with Mullenix on her study – (she was fired after she announced the results)

• Over 1,100 references to studies or articles on neurotoxicity – FAN’s website has the world’s largest online database for toxicity of fluoride

As I said, you can make up your own mind which website, which writer and which stance toward fluoridation is more credible.