Osmunson to HHS

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BILL OSMUNSON, DDS

9-13-14

TO: HEALTH AND HUMAN SERVICES

Dear Dr. Wanda Jones, Jonathan Beeton, Dinah Bembo, Oneika Gray and Liv Chanya,

We are encouraged by your professional attention to our visit with you last week regarding the lack of benefit and significant risks of excess fluoride exposure, including artificial fluoridation.

REQUEST:  As stakeholders in the health of the public, we are again making a formal request to be notified and invited to meetings, discussions, and deliberations regarding fluoride exposure and fluoridation.   FOIA documents reveal frequent communications between some stakeholders with exclusion of others.  When the American Dental Association (ADA) or other promoters of fluoridation are invited to the table, we are requesting an invitation to participate and be at that table.  

Dentists are not legally authorized or competent to diagnose diseases outside the mouth and tend to minimize medical risks. The FDA CDER has jurisdiction to evaluate the benefit/risks of substances used with the intent to prevent disease and needs to no longer defer regulatory action.

Contradictions within HHS make no sense.

HHS – FDA – CDER has repeatedly assured us that fluoride when used with the intent to prevent disease in man is an unapproved drug and “unapproved drugs are illegal.”

HHS – CDC – Dental Division has budgeted $31 million dollars over the next five years primarily for promoting and marketing even more fluoride.  The CDC Dental Division appears to ignore the excess fluoride exposure with the flawed assumption even more fluoride will reduce dental caries.

The fluoride is being dispensed without patient consent, purity, dosage, label, doctor or GMP. A medical or dental doctor doing what the CDC recommends with fluoridation would lose their license for malpractice. Most developed countries do not fluoridate public water and Israel has just stopped fluoridation. Police public health powers in the USA are being used to force all of us to ingest ever increasing amounts of fluoride even though dental fluorosis, a biomarker of excess fluoride ingestion, is increasing. The knee jerk reaction is being used for fluoride,  “if a little is good, more is better.”  Unfortunately, ever increasing amounts of fluoride exposure is not clinically reducing a life time of dental caries, and is causing harm.

Water districts and cities mistakenly look to the CDC and EPA for advice and evaluation of the complex scientific controversy of fluoridation when they should be looking to the FDA CDER.

In 2011, HHS asked for public input (we provided a great deal of science showing harm and lack of efficacy) on a proposed 0.7 ppm maximum artificial fluoridation concentration, confirming local government’s assumption HHS has jurisdiction.    In response, HHS for over 3 years has been silent, failing to make a recommendation.   States, such as Washington, are still fluoridating at 1 ppm waiting for HHS determination.  At a minimum, if HHS does not have jurisdiction over fluoridation, HHS needs to come clean and say so, or make a determination.  HHS can create an open scientific forum for all stakeholders.

Numerous excuses will undoubtably be raised by the American Dental Association, CDC dental division, and even the FDA CDER.  Meanwhile, the next generation of infants and children are being harmed.  The health and protection of the public requires HHS leadership.

The graph below was made from data published 2009, Journal of the American Dental Association. kumar-2009-association-between-enamel-fluorosis-and-dental-caries-in-us-schoolchildren-jada-140-855-862

The blue lines clearly show an undisputed increase in dental fluorosis with increased fluoride concentrations in water.  This research is consistent with many others.  Note the red lines with a slight, almost imperceptible, decrease in caries experience at about 0.7 ppm fluoride in water.  This very slight decrease in caries for school children is consistent with other studies reporting about half a tooth surface decrease out of 128 tooth surfaces, less than 1% decrease.   Confidence in a lifetime of caries reduction is very low.  Quality of research is low.

The possible decrease of less than 1% needs to be weighed against the possible decrease in IQ of about 7%, keeping in mind dental caries can be prevented with good diet and cleaning, and reasonably treated.  A reduction in IQ has no known treatment and appears to be genetically passed to at least 3 generations.   Also remember, total exposure in several IQ studies from China where they do not use fluoridated toothpaste is similar to the total exposure in the USA with fluoride toothpaste.   The brain is a terrible thing to waste.

Sincerely,

Bill Osmunson DDS, MPH

Fluoride Action Network, West Coast Representative

425.466.0100

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