Professional reviews by various authors on the
"Report of the Expert Panel for Water Fluoridation Review"

published by the City of Calgary, March 1998

Phyllis J. Mullenix, Ph.D.
Andover, Massachusetts 01810-3347

April 6, 1998

Alderman Bronconnier, Chairman
Operations and Environment Committee, City of Calgary

Dear Alderman Bronconnier:

The "Report of the Expert Panel for Water Fluoridation Review" contains such misleading and superficial statements that it is a recipe for disaster. The most egregious flaws are in the toxicology section, and the following discussion illustrates why there is cause for concern.

First, the report (p.20) starts with a simple mix of glittering generalities about dose making the poison. The presence of fluoride in the atmosphere, water, soil and biota is mentioned, but the focus is reduced to that which is ingested. Occupational exposures are a missing ingredient, one that is key to many adults in Alberta such as the petrochemical workers. Consider the plight of an individual repeatedly inhaling low levels of fluoride while working for a major oil company (see Clinical Toxicology, 13:391-402, 1978). His "total fluoride intake" would be grossly misrepresented if it was based solely on levels in drinking water, food or dental products. For this individual, water fluoridation switches from a preventive measure for tooth decay to "the straw that broke the camel's back."

Second, the report is unpalatable because of its haphazard blend of toxic doses. It gives (p 22) the estimated acute lethal dose for humans of 32-64 mg/kg. True this dose will kill, but so will the estimated dose of 17.9 mg/kg (see the New England Journal of Medicine, 330:95-99, 1994).

The point is that the acute lethal dose can be considerably lower especially if one considers the health of children, the elderly, or people with preexisting disease. The literature is replete with lower "estimated acute lethal doses", so why present only one number? The omission flags deception, especially when the number is juxtaposed with the statement "it would be impossible to drink enough at one time to absorb an acute amount of fluoride from fluoridated drinking water" (p.22). The one number presented in this report would provide little comfort to the people at Hooper Bay, Alaska. There, 296 were poisoned by drinking fluoridated water but none consumed as much as 32-64 mg/kg, not even the man that died.

Other ingredients contribute to the bitter taste of this report. On page 23, it is mentioned that "chronic (low dose) toxicity" is more relevant to the issue of water fluoridation. Yet, in the subsequent discussion of effects on the gastrointestinal system, the only dose, mentioned is "about 200 ppm." No references are given to support this threshold dose, clouding whether it refers to human or animal data. Human data is an unlikely source. nearly all of the people poisoned in Hooper Bay experienced nausea, vomiting and abdominal pain and they drank fluoridated water only up to 150 ppm. The 200 ppm level more likely came from animal data. However, in our experience (Neurotoxicology and Teratology 17:169-177, 1995, 175 ppm kills half the animals drinking it, leaving the question of stomach irritation rather moot.

Finally, such important details are missing or misrepresented in this report (pages 23-25) that it seems half-baked. No chronic, low dose is given for the development of skeletal fluorosis. No references support the comments about the gastrointestinal, immune or reproductive systems. The wrong doses are attributed to the one study (Mullenix et al., neurotoxic potential were completely ignored despite their being published in peer-reviewed journals (i.e., Clinical Toxicology, Brain Research, Confinia Neurologica, Journal of Applied Psychology, Acta Medica Scandinaviea, International Clinical Psychopharmacology, Communications in Psychopharmacology, Journal of Neuroscience, Journal of Neuroscience Methods and Fluoride).

In summary, this report does not appear to be a presentation of the science, but rather a presentation of prejudice against the science. Why does water fluoridation deserve such loyalty?

Phyllis J. Mullenix, Ph.D.

National Federation of Federal Employees, Local 2050
P.O. Box 76082, Washington, DC 20013
202-260-2383 (V) 202-401-3139 (F)

April 4, 1998
Standing Committee on Operations and Environment
City of Calgary

Dear Chairperson:

I would like to address the issue of the NTP bioassay on sodium fluoride and the manner in which this seminal study was treated by the Calgary study group. My comments are derived from the memorandum written May 1, 1990 by the Senior Science Advisor to the Director of the Criteria and Standards Division, Office of Drinking Water, U.S. Environmental Protection Agency. But first I would like to explain why I -- and the union of which I am an officer -- am interested in your activities and give you some background.

The union is comprised of and represents the scientists, lawyers and other professionals at Headquarters of the U.S. Environmental Protection Agency (USEPA) in Washington, D.C. The opinions expressed here are those of the union, and not of the USEPA.

The union has been interested in the matter of fluoride toxicity since 1985 as a matter of professional ethics. At that time, an EPA scientist came to the union complaining that was being ordered to write a regulation that implied the government thought it was O.K. for citizens to have teeth that looked like they had been chewing on rocks and tar balls because that result was not an adverse health effect. It was nothing more than a "cosmetic effect", so the government wouldn't take steps to protect against it. (The Safe Drinking Water Act requires the USEPA to protect against adverse health effects -- so the Agency could do its part in keeping up the fiction that fluoride has only beneficial effects on health by simply anointing dental fluorosis a "cosmetic", *rather than a health, effect.)

Last year union scientist and lawyers reviewed the toxicity data on fluoride that had been published since 1985, along with the wisdom of the public policy of mandatory water fluoridation. (You may not be aware of it, but in virtually every place where fluoride is put into the public water supply, citizens themselves have had no direct say in the matter. Interesting way to do business in a democracy.)

The most recent toxicity data demonstrate to us a causative link between fluoride exposures and neurotoxicity (including diminished I.Q. in children and hyperactivity), bone pathology (including increased rates of hip fracture in fluoridated cities), and cancer (including increased bone cancer in young men).

Furthermore, our review of the studies on the effect of fluoride on dental cavities, including the massive and comprehensive National Oral Health Survey 1986-1987 published by the National Institute of Dental Research, indicates that there is no detectable reduction in dental cavities resulting from drinking water fluoridation.

The result of these reviews of the most recent research findings on fluoride caused our union members to vote unanimously to join forces with California Citizens for Safe Drinking [Water] in their effort to stop fluoridation in their state. We have since helped other citizens' groups carry on similar activities.

Now, back to the memorandum written by the Office of Drinking Water Science Advisor, Dr. William Marcus. Dr. Marcus was at that time an Executive Board member and officer of this union. In his memorandum he points out several facts that the peer review panels commissioned by the U.S. Public Health Service, an organization that for decades has been in the business of promoting fluoridation, failed to take into account in making their finding of "equivocal" evidence for carcinogenicity of sodium fluoride in male rats regarding the NTP study. It appears that the Calgary study group likewise did not consider these points.

First, the historical control animals, whose incidence of osteosarcoma was used in part to sustain the peer panels' "equivocal" finding, were actually exposed to 0.7 to 1.2 mg/kg/day of fluoride through the feed. This exposure level was between the low- and mid-dose exposed animals in the NTP study. And when this exposure level is plotted on the same scale used for the NTP bioassay, along with the exposure and incidence data from that study, the incidence of osteosarcomas in the historical control group falls precisely on the same regression line as the NTP data. This is an extremely significant finding, given the very large number (ca. 6000) of historical control animal involved.

Second, upon comparison of the fluoride levels in the bones of high-dose animals in the NTP study (5,470 ppm) with levels found in humans (7,000) exposed to 4 mg/L fluoride in drinking water, Dr. Marcus noted that this was the first time in his memory that animals have lower levels of a carcinogen at the target organ site than do humans. An important toxicological consideration is that a toxic substance stores at the same place it exerts its toxic activity. This is true for benzene, a known human carcinogen that exerts its effect in bone tissue (marrow), and now is true also for fluoride. For fluoride, the concentration is ca. 1.5 times higher in humans than in rats, and for benzene the rat tissue contains 10 to 100 times the levels in human tissue. This also is an extremely significant point.

Dr. Marcus also pointed out in his memorandum that hepatocholangiocarcinomas, an extremely rare tumor, were probably improperly downgraded to hepatocarcinomas. This change was used as part of the justification for down grading the original classification of sodium fluoride's carcinogenicity to "equivocal". Also downgraded were originally reported adrenal pheochromocytomas and tumors, changed to hyperplasia, and other liver carcinomas were downgraded to foci by artificially defining a criterion of tumor compression for carcinomas.

In summary, the peer panel's downgrading of the carcinogenicity of sodium fluoride to "equivocal" appears to be a case of what might most euphemistically be called political science.

Given that the rats in the NTP study were exposed to fluoride levels that led to bone fluoride concentrations comparable to or below those observed in humans, and that these rats experienced statistically significant incidence of a rare bone tumor, the continuation of fluoridation of drinking water supplies -- at any level -- may well be considered a public health menace.

It appears to me that the Calgary study group merely adopted the opinions expressed by peer review panels staffed largely by pro-fluoride members and commissioned by an organization (U.S. Public Health Service) whose interest in the subject should have prompted the utmost scepticism by your experts, but seemingly did not.

Thank you for the opportunity to comment on the report at issue.

J. William Hirzy, Ph.D
Senior Vice-President

Opinion on March 1998 Expert Panel Report
City of Calgary Water Fluoridation Review

by David R. Hill, P.Eng., Professor Emeritus, U of Calgary, 8th April 1998

My initial impression is that, as always, medics closed ranks to defend a decision made by medics. The most honest, unbiassed opinion was that of the biostatistician on the panel whose professional field is collecting and assessing scientific evidence. I note that he basically thinks water fluoridation should be discontinued (and recommends a lower level than the others if is is continued).

As a matter of fact, given that the sources of Calgary water may contain as much as 0.35mg/L of fluoride, even the medics on the panel are recommending that water fluoridation be cut in half.

The report admits that total individual daily intake of fluoride from all sources to be in the range 3.28 to 9.24 mg per day (Note 1); let's average and say around 6 mg per day (Note 2), compared to 0.45 to 0.55 mg per day in the 1940's prior to water fluoridation (say 0.5 mg/L). Since the last figure was the basis on which the recommended water fluoridation concentration of 1 mg/L was made, I can only see water fluoridation as an unnecessary and wasteful expense at any level. In recommending a reduction from 1 mg/L to 0.7 mg/L, they are tinkering with about 10% of the total current fluoride intake (Note 3) when the total fluoride intake has increased by a factor of twelve times (1200%). On this basis, if they eliminated water fluoridation in Calgary altogether, the total fluoride intake for Calgarians would still far exceed (by a factor of 6 times or 600%) the total intake based on the concentration recommended by the "experts" who first introduced water fluoridation, and whose recommendations are the foundation of modern "public health" practice. In the old days, the recommended concentration was based on people drinking only 1 Litre a day. I think it is particularly outrageous to quote the "wasted" capital costs of fluoridation equipment as a reason for continuing water fluoridation, as occurs in the Commissioners' report to the SPC on Operations and the Environment. It is almost humorous that the cost of fluoridation is now added to the water rates. You pay for what you don't want or need!!

Another point strikes me forcefully. The report exclude ethics from consideration (p 6), because ethics were not in their terms of reference (why not?). However, they defend issues relating to the claimed caries-reducing benefits even though these were not in their terms of reference either. This suggests bias. Ethics are an integral part of public health policy, and a key issue in the debate.

If you insist on asking the wrong questions, you will not get relevant information. I felt a lot of the written material provided by the Non-Dissenting (ND) panelists was, at best, designed to misdirect attention, and, at worst, irrelevant and misleading. [Of course, many people think that all the arguments are irrelevant to their personal needs because they don't drink much water. They ignore the fact that water is used in virtually all food and beverage preparation.]

As an example of the blatant misdirection, check page 6 where "Readers should become familiar with the units of concentration and dose, to understand the levels of exposure. ... One ppm is 0.0001%, which is equivalent to one minute in 2 years, one cent in $10,000 or one cm in 10 km." If this is not an attempt to trivialise the addition of fluoride to water, I don't know why it is put there. The same argument could be used to suggest that contamination by 1 mg of Plutonium per litre of water would have no effect (whereas it would actually be lethal to everyone drinking the original water, eating food processed using it, or drinking water supplies derived from the effluent products or eating food produced on farmland contaminated by the effluent products, and so on down the line).

In any case, if the concentration used in water fluoridation is so trivially small, are they saying it has no effect, or merely that it has beneficial effects, but cannot have harmful effects because there is so little of it. This is illogical -- and about as relevant as telling us (p 21) that sea water, which we don't drink, contains 0.8 to 1.4 mg/L of fluoride. Either 1 ppm of fluoride in drinking water is biologically active or it isn't. If it isn't, then there is no point in adding it to the water unless there is some other reason (which, of course, may be the whole point!). If it is biologically active, then we want to know if it may harm us, especially if we have no choice but to receive water from a fluoridated supply.

The paragraph goes on to say that the important measure is amount per unit weight, but does not elaborate. How about cumulative effects and a sensible discussion of the issues. The only real purpose of this paragraph seems to be to trivialise the amount of fluoride in the water. This trick has been used since the early days of water fluoridation, and was recommended by the arch promoter and spin doctor Frank Bull DDS (what an appropriate name!).

At the foot of the same page, the disagreement of the dissenting panel member is trivialised, saying " ..., The Panel is close to agreement." -- so close that a week of extra meetings and revisions were unable to resolve them!

On page 4, studies using high doses are declared irrelevant, as are other studies that raise issues. This again suggests a distinct bias. If you are adding some substance to the water supply on the grounds it provides benefits, it is up to you to prove beyond any doubt, that the substance is harmless. It is not scientific to say: 'Well, these studies have raised questions about safety, but since harm is not proven beyond all doubt we'll ignore them.' This is especially true when the very act of adding the substance reduces the statistical power of any subsequent investigations because it further contaminates any future data.

This brings me to another issue which is almost entirely glossed over, except where it is used to dismiss studies unfavourable to water fluoridation. Reference is made to the fact that certain types of study lack statistical power (e.g. page 13). But powerful tests reduce the chances of accepting a null hypothesis when there really is a difference (Note 4). Less powerful tests are less likely to come up with statistically significant results. To say that the statistically significant results from hip fracture studies can be ignored because they lack statistical power (for whatever reason), as one of the ND panelists does, suggests a lack of familiarity with statistics that is not acceptable in a panel judging scientific papers that use statistical analysis!

In the reviews written by panel members on studies of fluoride effects, results suggesting there is an adverse effect from fluoride are dismissed on the grounds (essentially) that there was a lack of "control", as in "controlled experiment". The claim is that uncontrolled factors may have been responsible for the results obtained and therefore the findings carry little weight. Unless the uncontrolled factors correlated quite strongly with the use of fluoridated water, which would be very surprising in so many studies under different conditions and in different places, uncontrolled factors would tend to hide any effect of fluoride. Obtaining a statistically significant result with less powerful statistics and with less well controlled conditions suggests that the underlying effect must be very strong.

I thought the submission by D. Hanley talked around issues without asking the right questions. Since fluoride is a bio-accumulator, his comparison of high-dose intake with fluoridation-dependent intake is misleading, to put it kindly. High doses are used in fluoride bone therapy to get results quickly. The same changes can be induced by lower doses over a longer period. This aspect is not addressed adequately. In the same vein, experiments on rats use high doses for the same reason, and the interchangeability of short term high dose with longer term lower dose is accepted as a valid basis for drawing conclusions and is standard practice in toxicological work. Of course, fluoride is sufficiently toxic that if you push the high dose regime to an extreme, you get acute poisoning (Note 5), which is another thing. In the context of chronic effects, Hanley's " ...would be the equivalent of drinking 18-34 litres of Calgary's water a day ..." is not only misleading, it is another old trick used by fluoridation promoters. I have analysed the true dose relationships involved in such situations in my paper, "Fluoride: Risks and Benefits? ...", published on the web at /calgaryh.htm, in Section 6.

The main thrust of Hanley's submission is directed at the "therapeutic" use of fluoride for increasing bone density in osteoporosis. In stating that he knows of "... no reported cases of skeletal fluorosis that can be related solely to the consumption of artificially fluoridated water at 1 mg/L or less." he is choosing his words very, very carefully. Are we to assume that: there are cases with naturally fluoridated water at these levels causing skeletal fluorosis; or with artificially fluoridated water above these levels causing fluorosis; or where artificially fluoridated water at 1 mg/L or less was not the only factor, but was one of the factors in skeletal fluorosis? When I see words of that kind chosen as carefully as they are, I wonder what is being hidden. Certainly reports from India indicate that skeletal fluorosis can occur at levels comparable to artificial fluoridation levels. Poor nutrition was identified as an important co-factor, which refutes the suggestion that water fluoridation is of particular benefit to poor people.

In summary, Hanley says the issue of fracture risk "deserves further attention" but also says that the major weakness of the studies is [1] "their inability to assess other environmental sources of fluoride" and [2] "their inability to control for other potential causes of hip fracture." Given the increasingly wide-spread use of fluoride, thanks to the efforts of promoters, [1] will increasingly be true. I repeat that, in the absence of tight experimental control and powerful statistics, to be able to show a statistically significant effect is more difficult, not easier!

He concludes by saying he is "not convinced that there is a clinically verifiable association between water fluoridation at or below 1.0 mg/L and risk of fractures." I take it this means he thinks there may be an association. Otherwise, he'd have said he was convinced there wasn't a clinically verifiable association. So what is the prudent course of action? Discontinue fluoridation in Calgary!

The NTP study was one of the documents that fell within the mandate of the committee. However, S. Roth states flatly that fluoride is not mutagenic even though three of the four tests for mutagenicity in the NTP study showed fluoride is mutagenic. The inventor of the fourth (negative) test for mutagenicity used in the NTP study was on record as stating that the test was not applicable to fluoride, for technical reasons. Fluoride is mutagenic in all applicable tests used in the NTP study. Based on these findings, I have to conclude that S. Roth is simply wrong. He dismisses the Mullenix research showing fluoride is a neurotoxin on the specious grounds that the dose was too high (Note 6). In my opinion, there are other serious errors/omissions in S. Roth's written account. It all raises questions in my mind as to whether S. Roth fully understands accepted protocols for testing potentially biologically active substances in animals, and whether he actually read the NTP Study Report that he reviews, or, for that matter, other material that should have rendered him better informed.

The report section by the chairman, D. Thompson, admits that fluoride is toxic to aquatic organisms -- even in hard water -- but otherwise has little to say. Arguments that fluoride is not an environmental problem in Calgary are, of course, based upon assumptions. There have been many fluoride spills. To take a fairly local example, in August 1990 56,000 litres of hydrofluosilicic acid were spilt into the N. Saskatchewan river at Edmonton (Calgary Sun 90-08-23 page 34). If the city had not been fluoridated, this environmental insult would not have occurred. As with fire precautions, you don't base plans on the normal situation to decide what is safe and what is not, when using hazardous chemicals (Note 7). You base plans on known risk factors -- such as what is liable to cause spills, or oversupply, etc. It is not that long ago that one person was killed and many others made seriously ill by a malfunctioning water fluoridation system at Hooper Bay in Alaska (Anchorage Daily News 1992 Vol: XLVII, part 149, page A1). Again, if the water had not been artificially fluoridated, this serious hazard and associated death and illness would have been avoided. These days, people who advocate the initiation or continuation of fluoride supposedly do so on the basis of a risk/benefit analysis. Since the benefits are questionable or more likely non-existent, as many reputable studies have shown by well-founded statistical tests based on large samples, then even small risks are questionable. However, the evidence suggests that the risks are not small and are certainly not acceptable.

The report then reviews dental "benefits", despite the fact this topic was outside the committee's mandate. It is a pity there was not a review of ethics instead. Knowing Dr. Colquhoun's work and research results, I do not believe the section was presented in an unbiassed manner. The concluding section, in my opinion, clearly reveals the ND panel member's bias: "The Panel agreed that some studies showed that dental health was improving in areas not receiving fluoridated water or that dental health continued to improve after fluoridation of water supplies was stopped. However, we believe that to conclude that water fluoridation is ineffective or unnecessary is an oversimplification. Much more detailed, statistically sound studies of total fluoride intake, dental practices, etc. must be done to reach such a conclusion with confidence." This is a standard approach amongst fluoride promoters. When the evidence is against you, demand more and better studies. When the evidence is in your favour, adopt it unquestioningly. It causes me to wonder if the ND members of the panel could perhaps be fluoride promoters. I think it could be worth asking what part they may have taken in the run-up to the 1989 Calgary water fluoridation plebiscite. Another example of bias in this section is the decision to treat Calgary children as "fluoridated", prior to fluoridation, to explain why there was no difference in dental caries measures between unfluoridated Calgary and fluoridated Edmonton at the time (1984). As a corollary to this, if the children were already effectively "fluoridated", why the push to fluoridate them again?

Some excellent, well substantiated points are made in the dissenting panel member's submission based on the statistical analyses in a number of papers. Considerable evidence of ill-effects from fluoride is presented. I find it hard to believe that the "evidence supporting health concerns" in that section could be considered "weak", as is asserted in the executive summary of the Expert Panel's Report. The attempt to downgrade the dissenting opinion suggests the author(s) of the main report were biassed towards a pro-fluoridation conclusion. The dissenting panel member's recommendations make it clear that his opinion is that fluoridation should be discontinued altogether.

The overall report summary is also weasel-worded (p 41, first paragraph). The dissenting panel member felt the level of water fluoridation should be lowered because of the risks, not because the general fluoride intake has increased over the last 40 years. I then find it incredible that, on the next page (p 42), the authors of the main report state categorically that "There is no need for or value in further studies which attempt to relate water fluoridation per se to adverse health effects." This from panel members who are supposed to be objective and who, despite their readily apparent pro-fluoridation bias, admit there are adverse effects needing further study! It is the attitude of an ostrich.

The last paragraph on the same page subtly begs the question. It states that some adverse effects would surely have been found, if there were any, because the many issues have been articulated and studied over the last 50 years, then further states that no substantial effects have been found. This one paragraph clearly indicates a serious bias, since in a few words, it ignores or downgrades all the studies that have found substantial results by effectively asserting that either they don't exist or the results are not substantial -- by definition! This is also a long-standing tactic of fluoridation promoters -- from the notorious Dr. Frank Bull, DDS, in 1951, to those who "massaged" the results of the NTP study in 1990-92 and then presented only those parts they felt comfortable with, in light of the establishment intention to continue supporting water fluoridation. This is not science, it is disgraceful politics!

1. Depending on which figures you take, and which end of the ranges quoted. (Back to main text)

2. Which agrees with Rose & Marier's 1977 figure (Environmental Fluoride NRCC Report # 16081, Ottawa) (Back to main text)

3. Taking their own 2 litres of water a day intake figure. (Back to main text)

4. A null hypothesis would assert: "There is no difference between two or more populations" -- in the present case no difference in health effects with or without fluoride. A statistically significant rejection of the null hypothesis would assert that the hypothesis is wrong, and the fluoridation status of a particular group does have a particular health effect with (typically) only a 1% chance of being wrong. Accepting a false null hypothesis (saying there is no effect when there is) is known as a Type II error, and is less likely with more powerful tests. (Back to main text)

5. As opposed to chronic effects. (Back to main text)

6. Specious for reasons already mentioned -- high doses are accepted standard experimental methodology. (Back to main text)

7. Otherwise you might assume there would be no fires, and lock your fire exits to prevent people getting into your movie theatre without paying, as has happened -- with disastrous consequences. (Back to main text)

Dr. Paul Connett,
82 Judson Street, Canton, NY 13617,

April 7, 1998

Alderman David Bronconnier,
Chairman, Standing Policy Committee
on Operations and Environment
City of Calgary

Dear Mr. Bronconnier,

I have been asked to comment of the "Report of the expert panel for water fluoridation review", published in March, 1998. I am happy to do so. 1. Quite frankly I was more impressed with the minority report than the majority report. I think it is interesting that the former comes from a member of the Faculty of Sciences, whereas the four members of the majority report come from the Faculty of Medicine [see note]. In my experience the medical community in North America (and particularly the dental community) has a bias towards the "status quo" of fluoridation. There may be many reasons for this, but one of them is the persistent promotion of fluoridation by the US Public Health Service. Many researchers know that they are more likely to receive funding for their work if it is likely to support the continued fluoridation of water supplies. Conversely, those researchers like Dr. Phyllis Mullenix, who published work which challenges this status quo position, end up losing their funding and sometimes their jobs. A clear indication of the way funding has been kept away from "dangerous areas" is how little information we have in the US about the accumulation of fluoride in our bones even though the fluoridation experiment has continued for over 50 years! By this time an elementary pursuit of science should have given us data on bone fluoride levels for every conceivable geographic area and fluoride exposure. Instead, lead authors have to resort to data collected by Roholm in 1937!

2. Evidence of bias in this case is apparent when the majority report claims that their conclusion that the City of Calgary "reduce the concentration of fluoride in treated water to 0.7 ppm" is "basically compatible with the similar recommendation in the dissenting section". In actual fact that minority report conclusion was worded as follows: "Should it continue at all, then the fluoride concentration in drinking water should decrease to at most .5 to .7 ppm" (my emphasis). The minority report then went on to discuss other more appropriate means of improving dental care. Unfortunately, the majority report would suggest that difference was one of degree, when it was in effect a difference in kind.

3. I find it interesting that if the criteria for what studies were acceptable for the purposes of this report (page 4 and 5) had been used for the literature prior to 1989 it would have eliminated most, if not all, the pioneering studies which purported to show that fluoridation of the water supplies improved the quality of children's teeth! Thus as far as the majority authors are concerned, it would seem that one set of criteria is acceptable for launching this experiment, but quite another is necessary to shut it down.

4. I also find it interesting that when the majority authors found any evidence of problems associated with the use of fluoride they were very quick to blame sources of fluoride other than the drinking water. Unfortunately, one cannot segment the effect of putting fluoride in the drinking water from some of these other sources. For example, when the water is fluoridated it increases fluoride intake via the consumption of processed food and beverages made from this water. This can be particularly severe where the processing involves the evaporation of water or dehydration. In both cases the fluoride is left behind in the food. Nor should one neglect the fact that animals such as calves or cows may consume the fluoridated water. A milk cow can consume up to 50 gallons of water per day. much of this fluoride can end up in it bones and be passed onto the customer via bones (broths, soups and stews) or in hamburger and sausage meat if the meat is stripped off the bone mechanically, rather than by hand (little bone chips end up in the meat). Moreover, many citizens water their garden from their tap and can thus introduce fluoride into their fruit and vegetables via root uptake.

5. The minority author rightly stressed the total intake of fluoride via all sources, not jus the 0.7 mg from consuming one liter of fluoridated water. The fact that the range of intake is now much higher than anticipated in 1945, should give us pause especially when we consider our total body burden after a lifetime of exposure. If indeed people are getting an intake of 3 -9 mg/day (from a combination of fluoridated water, food and dental products) then we are precariously close to lifetime body burdens where we can expect bone abnormalities.

6. Three authors reviewed the various studies on increase in hip fractures, but only the minority author referred to the study by Jacqmin-Gada (1995). Why was this? This study showed a significant correlation with fluoride concentration above 0.1 ppm and hip fracture. Moreover, this study unlike some of the others controlled for many potential confounding variables.

7. I found it unacceptable that (page 14) one of the reviewers (H. Moghadam) when examining the NTP study on cancer in rats, should twice site reviewers who concluded 1) that "water fluoridation was both effective and safe" and 2) "human epidemiological evidence on human health effects of fluoride do not support changes in community fluoridation programs". These conclusions, valid or not, do not spring from the issue at hand which was, "was there an increase in cancer in the rat studies?" Adding these conclusions at this point, derived from other considerations (and biases?) only muddy the water of the primary analysis. They do however, illustrate the eagerness of the author to persuade us that water fluoridation is okay.

8. I found it extraordinary that when H. Moghadam discussed Cohn's work with an increase in osteosarcoma in New Jersey (page 15) he failed to acknowledge that the large increase in osteosarcoma occurred with young males but not with young females, which is a striking finding considering that in the NTP rat studies the increase in osteosarcoma also occurred in the male rats and not in the females.

9. In reviewing a Japanese study on uterine cancer, this same author, H. Moghadam, states that "it cannot be concluded that the association is one of cause and effect." It is my understanding that a correlation, no matter how strong, can never prove cause and effect.

10. I found it regrettable that the review on toxicology did not discuss the biochemical mechanisms whereby fluoride exerts its toxic effects. There was no discussion of the inhibition of enzymes, fluoride's amazing ability to form complex ions with nearly every metal ion other than sodium and other group I metals (of the periodic table) and its ability to form a very strong hydrogen bond with the amide function in both proteins and nucleic acids.

11. The conclusion on page 29:

"The panel agreed that some studies showed that dental health was improving in areas not receiving fluoridated water or that dental health continued to improve after water fluoridation of water supplies was stopped. However, we believe that to conclude that water fluoridation is ineffective or unnecessary is an over simplification. Much more detailed, statistically sound studies of total fluoride intake, dental practices, etc. must be done to reach such a conclusion with confidence."

In my view, this passage clearly underlines the "momentum" of the status quo. Imagine trying to use this same argument to get the water fluoridated in a community which is not currently doing so!

12. In its final conclusion (page 42) the majority four authors write:

"The fact that these issues have been articulated for more than 50 years, and have received a good deal of study, suggests that if there are cause and effect relationships between water fluoridation and adverse health effects, they are small and very complex. Otherwise, more substantial results would have been achieved by the studies undertaken to date. Although there are recommendations for further research, the results of which would have made this Panel's work easier, the absence of that work did not substantially affect the Panel's conclusions."

In my view a similar statement could have been made in the early 70's about the effect of sub-clinical lead exposure. It took very subtle experiments by Needleman in 1979, to tease out the subtle effects of low levels of lead exposure on the child's developing brain. The problem with a toxicant. that exerts subtle effects, is that the impact on the average person is hardly noticeable. However, when you expose a whole population to a toxicant it is the impact on the two tails of your normally distributed population which can be devastating. For example, consider lead. At the height of the exposure of American's child population (largely via leaded gasoline) the average IQ was lowered by about 5 IQ points. Such a lowering is hardly noticeable, but applied to the whole population, it meant that we halved the number of children with an IQ in the genius category, and doubled the number with an IQ in the severely mentally handicapped category. The two tails.

13. Let us consider some of the research which is absent- which the four majority authors may not have considered:
14. In the absence of such studies do we continue this experiment, with the confidence that the majority authors communicate? The problem of conducting an experiment on a whole population over an extended period of time, is that if your are wrong, if your confidence is misplaced, then by the time your experiments have teased out the subtle effects (assuming the US PHS and others agree to fund the studies!) it will be too late for thousands of people -- especially for those who lie within the two tails of the normally distributed trait in question.

15. It is precisely because in the past we have got into serious environmental health problems when we have proceeded with a use of a chemical before its effect on health had been comprehensively studied, that scientists, regulators and citizens in Europe introduced the "precautionary principle".

Simply put: if in doubt, keep it out! If the majority authors are aware of this principle they clearly chose not to apply it here. On the other hand, the minority author did. On page 39 he writes:

"However prudence dictates that potential risks cannot be disregarded either. Unfortunately there is no actual data available at this time to critically assess the effect of water fluoridation on general health in Calgary."

and concludes on page 40, "it may be more appropriate to provide required dental benefits using other means...."

16. Clearly, Mr. Bronconnier, the decision maker is presented with a tricky, but not impossible choice in this matter. You have two constituencies, one constituency wants you to continue to put fluoride in, the other wants you to take it out. The status quo provides a momentum to keep it in. They say "Don't rock the boat". Their four experts conclude that we don't have all the research in, but they are confident that new research will pan out in their favor. What you don't know, can't hurt you! The minority expert disagrees. He says be prudent, look for alternative ways of protecting teeth. I say, consider what happens if each side is wrong. If the pro-fluoridation side is wrong both our children and our elderly could pay a heavy price with their brains and bones respectively. If the anti-water fluoridation side is wrong, Calgary will be in the same boat as the vast majority of countries in the world which do not fluoridate their water. No study indicates that these countries have children whose teeth have been seriously compromised because of a lack of water fluoridation. This may mean, as some would claim, that the benefits of fluoride for teeth protection have been overblown, or it may simply mean that the little fluoride which is necessary to provide protection is widely available from other sources.

17. Finally, I urge you to consider the disparate inconvenience your decision will cause your two constituencies. if you take the fluoride out, those who want it can get it simply by using (or continuing to use) the toothpaste available at any pharmacy or supermarket. If you keep it in, those who don't want it have to go to the expense of purchasing same distillation units, reverse osmosis equipment or purchase bottled water. What happens if they seek financial relief from their taxes for this imposition? Another approach would be to follow the early Dutch example and lay on water taps in town with water which has not been fluoridated. In my view, keeping the fluoride out imposed the least inconvenience to the most people, as well as protecting important rights for those who no want to be forced to take this substance into their bodies.

Dr. Paul Connett,
Professor of Chemistry,
St. Lawrence University,
Canton, NY
and Co-editor of Waste Not

[Note: there were three members from the Faculty of Medicine, not four. Back to main text]

REPORT OF Expert Panel on Water Fluoridation Review
to the City of Calgary, April 1998

by: Richard G. Foulkes, B.A., M.D.

Overall Impression
The recommendation contained in the report prepared by the Expert Panel on Water Fluoridation review for the City of Calgary to continue fluoridation, even at a lower level of 0.7 ppm is not supported by its own published review. Both the majority and the minority documents show quite conclusively that water fluoridation does not reduce or prevent tooth decay. The minority report, to give it its due respect implies that fluoridation cease but opts for 0.5 to 0.7 ppm (mg /L), if it is continued.

This makes it clear that the choice to continue fluoridation was made before the review and that the report is a diversionary tactic. The report is an attempt to allay the fears of a public growing increasingly aware of serious adverse health effects being reported almost daily as possibly resulting from environmental pollutants of which fluoride is one of the most important. There is evidence that fluoride, along with PCB's, DDT, dioxins and other synthetic chemicals used as herbicides and pesticides may act in a similar fashion to lower fertility and damage the fetal brain to produce low IQ and behavior problems. Studies, of which the public are becoming aware, link residence in a fluoridated areas with such adverse health effects as dental fluorosis, increased hip fractures in the elderly, chromosomal abnormalities such as Down's Syndrome, immune deficiency and some types of cancer. A number of these concerns are addressed by the Panel.

The reduction of the level of fluoridation to 0.7 or 0.5 ppm from its present 1 ppm will not decrease the rising rate of dental fluorosis, the most visible sign of fluoride poisoning. Only by allowing the water supply to return to its natural level of <0.3 ppm and also controlling fluoride intake from dental products and food prepared in fluoridated water elsewhere will a reduction take place. Continued fluoridation, even at the recommended lower level will not change the suggested relationship between residence in a fluoridated area and such adverse effects as hip fracture in the elderly. It will also permit the City of Calgary to continue to add fluoride to the environment at hundreds of tonnes a year thereby contributing to what Environment Canada admits is a threat to the ecosystem. All of these suspected and known risks are being taken at present for no "benefit" in terms of reduction/prevention of tooth decay as both the majority and minority reports show quite conclusively.

Problems in the Report
The report has serious deficiencies and problems. These are too numerous to refute line-by -line. The report fails to consider the ethics of adding a toxic waste product of industry to the community drinking water - not to make it pure and wholesome, but because some persons believe that it medicates the body to reduce/prevent tooth decay. Medicates is the correct word as it has been shown conclusively that fluoride is not essential for growth and development and that lack of fluoride does not cause tooth decay. The report does not touch on the economics of fluoridation. It fails to touch on either the direct or the indirect costs of the procedure. There is no attempt to find answers to relevant questions. Does fluoridation reduce the need for dentists? Does it reduce the accelerating costs of dental care?

Overall, the majority report is repetitious, especially with regard to the evaluation of the positive and negative studies that deal with the relationship between residence in a fluoridated area and hip fracture in the elderly. Several important studies that have been reported in peer-reviewed journals (Cooper, 1991. Jaqmin-Gadda, 1995 ) were omitted in the majority report. The minority report referred to Jaqmin-Gadda. In the majority report, the rigid standards for scientific evidence demanded of the positive studies did not appear to be demanded of those on the negative side. There is no question that the findings of those researching the therapeutic effect of fluoride for osteoporosis with regard to the incidence of non-spinal fractures are important. But, the recording of this aspect in the majority report was out of proportion to its relevance to water fluoridation. With an overwhelming majority of studies showing a positive relationship (i. e, residence related to hip fracture), even though this may he described as "weak", the weight-of-evidence or the Precautionary Principle should have prevailed. In the words of a recent statement from the Wingspread Conference (Jan 1998):

"When an activity raises threats to harm human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically."

Other relationships that are either omitted or passed over relate to possible chromosomal effects (Down's Syndrome) and increased deaths from cancer of all types found by Burk and Yiamouyiannis (1977) in a study of the 10 largest fluoridated and 10 largest non-fluoridated cities in the U.S..It was this study that prompted the U.S. Congress to order the National Toxicology Program (NTP) study. The full data of the NTP study, rather than the biased conclusions of the USPHS referred to by the Panel, pointed to the importance of the dove-related relationship between fluoride and osteosarcoma in male rats and to the presence of multiple cancers, including an extremely rare cancer of the liver. It was the sum of all findings that led to the debate as to whether fluoride should be termed a probable cause of cancer rather than an equivocal cause.

A disappointing aspect of the report were the sections on toxicology and on the environment. The toxicology section exhibited a lack of familiarity with the literature on fluoride. Serious errors were made in the presentation on such aspects as the lethal dose and in the interpretation of studies showing genetic and gastric toxicity of fluoride. The cavalier dismissal of the possible effect of fluoride on fertility and the brain showed a lack of knowledge of past and current research and a mind-set paralyzed by linear thinking. Any discussion of infertility, behavior disorder and low IQ as an adverse effect of fluoride and other chemicals is incomplete without discussing the Paradoxical Effect in which small doses of toxic chemical passes the placenta and causes damage to the developing fetus while not having an observable adverse effect on the pregnant female.

The discussion of the environmental impact of fluoridation both generally in Canada and the U.S. and in Calgary short-changed the reader. Every year Calgary deposits an alleged 755 tonnes of hydrofluosilicic acid into its drinking water. Most of the fluoride in this is discharged on land as surface water and into the Bow and Elbow rivers. Since fluoride is more toxic to plants and animals than lead and is only slightly less toxic than arsenic, it deserves more attention. The figures given in the section on environment for river concentrations down stream from the effluent outfall do not agree with those found elsewhere in the literature.

The Dissenting Report
Of all sections of the report, the dissenting opinion is best organized and fair. It leads clearly to the conclusion that the money spent currently for fluoridation should go to dental care programs rather than continue fluoridation. In addition, the author of the dissenting report leans heavily toward the view that although many of the adverse health effects, other than dental fluorosis, can not be attributed to fluoride ingestion with 100% certainty, the principle of precautionary action should be applied. This reader was disappointed to find that the author of the dissenting report did not end his excellent review with the unqualified statement that fluoridation should be stopped rather than making this vital point by implication.

This report is more a political than a scientific document, although it has the trappings of the latter with its noble intentions being expressed from the outset. With the knowledge that only about 20% of the procedures carried out in medical practice are verified by controlled clinical trials and that we must strive for evidence-based activities, these noble intentions strike a sympathetic chord. Unfortunately, this document fails the test. By its own words, the authors can not rationalize the continuation of fluoridation in Calgary. But recommends, nevertheless, continuation of the process, albeit at a lower concentration. The majority report attempts to down-play the relationship between fluoridation and adverse effects, including dental fluorosis.

Perhaps, the motivation for recommending continuation is an attempt to mitigate the inevitable legal consequences. Could it be that discontinuation of this Public policy is seen as an "admission of guilt"? At a time of class action suits on such areas as tainted blood, silicone implants and, soon, mercury amalgam some may think that such action is warranted. Or could it be the case that after over 50 years of fluoridation, inability to change overrules common sense and fiduciary responsibility?

Elke M. Babiuk, author of calgaryb.htm and editor of this Web Site

Professor Roth's Section -- "TOXICOLOGY OF FLUORIDE"
"Gastrointestinal System"
Despite proponents' claims to the contrary, the scientific literature shows that gastrointestinal symptoms occur in some people at very low fluoride concentrations. In 1989, the Canadian Compendium of Pharmaceuticals and Specialties contained this quote in the "Sodium Fluoride" section: "Adverse Effects: Reports include skin rash, gastrointestinal upsets and headache. These usually disappear when administration is discontinued." The doses were 0.55-2.21 mg NaF, which is equivalent to 0.25-1.0 mg fluoride ion.

The Spittle review was flagged for panelists to read. They were given all the FLUORIDE Journals from 1990 to 1997. They obviously didn't read any of them. Gastrointestinal irritation was reported as a prevalent side-effect in at least 1/3 of the osteoporosis-fluoride trials -- about 18-50 mg of fluoride ion per day, significantly lower than 200 ppm! Fluoridation accidents (<200 ppm) have also proven that gastrointestinal symptoms in those poisoned occur in a significant proportion of victims. Changes to the gastric and intestinal mucosa have been reported in skeletal fluorosis patients exposed to water containing 2.5 ppm fluoride or more. See also Dr. Mullenix's comments on gastrointestinal effects.

"Toxicity of Fluoride"
The man who died from fluoride poisoning in Hooper Bay, Alaska received about 17.9 mg fluoride ion per kg body weight. This panel was provided with and informed of the importance of the 1990 article by Gary Whitford, The Physiological and Toxicological Characteristics of Fluoride. It clearly spells out that the lethal dose of fluoride ranged from "less than 5 mg F/kg to approximately 30 mg F/kg." It also stated that fluoride's "Probably Toxic Dose" which "should trigger therapeutic intervention and hospitalization -- is 5 mg/kg of bodyweight." This means that many dental products found at home contain more than enough fluoride to kill or seriously harm a small child if ingested. See also Dr. Mullenix's comments above: "The literature is replete with lower "estimated acute lethal doses", so why present only one number? The omission flags deception, especially when the number is juxtaposed with the statement "it would be impossible to drink enough at one time to absorb an acute amount of fluoride from fluoridated drinking water". Please see poison.htm for more information.

"Reproductive System"
Together with all the FLUORIDE Journals, this panel was also provided with the article by Stan Freni, Exposure To High Fluoride Concentrations In Drinking Water Is Associated With Decreased Birth Rates. Please also see sperm.htm for more information.

In the reference used by Professor Roth, this is what the authors actually said about the in vivo studies in their Summary: "Although some of the studies were performed at toxic levels of F-, other studies, including those that showed positive results, were at F- concentrations (1-5 ppm) equivalent to human exposure levels." [emphasis added] The abstract is available at cancer.htm. See also Professor Hill's comments above about fluoride's mutagenicity.

back to TOXICOLOGY OF FLUORIDE by Professor Roth

Professor Moghadam's section -- "DEFINITION OF EPIDEMIOLOGY"
Professor Roth says fluoridation may be responsible for 40% of fluorosis prevalence and 60% to other fluoride sources. He refers to studies which confirm this. Professor Moghadam refers to one of these same studies (Pendrys, 1995) and says that 25% of fluorosis in fluoridated areas is attributed to the inappropriate use of supplements and about 71% to the inappropriate use of fluoridated dentifrices (leaving only 4% to be caused by fluoridation and other fluoride sources). How does this compute?

back to Definition of epidemiology by Professor Moghadam


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