Richard D. Sauerheber, Ph.D.
(B.A. Biology, Ph.D. Chemistry, University of California, San Diego)
Palomar College, 1140 W. Mission Rd., San Marcos, CA 92078
January 17, 2012U.S. Food and Drug Administration Center for Drug Evaluation and Research Rockville, MD 20857
The following information should be of help in evaluating the fluoride water ban petition, FDA2007-P-0346.
As provided to the FDA earlier, detailed statistical analyses by Ziegelbecker  indicate a wide variation in teeth caries incidence among people in a large U.S. population that is unrelated to fluoride levels in drinking water. Vitamin D and calcium, rather than fluoride, is important for normal teeth health and development. Variation in caries incidence found among people may be explained by variation in vitamin D and dietary calcium.
It has long been known that vitamin D, necessary for the proper assimilation of dietary calcium through the intestines, decreases dental caries. [Dr. Anthony Norman, world expert on the mechanism of action of vitamin D, is a former colleague.] The late Dr. Linus Pauling, a former mentor, founded the Orthomolecular Medicine organization, and the following description is paraphrased from a published article by that organization. The U.S. Public Health Service in 1950 ignored well-published data and accepted the idea that fluoride added to water might fight tooth decay.
Orthomolecular Medicine News Service, February 19, 2009
Vitamin Deficiency Underlies Tooth Decay
There is especially strong evidence for a relationship between vitamin D deficiency and cavities. Dozens of studies were conducted in the 1930’s and 1940’s [1-11] that concluded that supplementing children with vitamin D prevents cavities. Between 5,000 and 15,000 IU of vitamin D may be obtained from modest exposure to sunshine in the middle of the day. Recommending that people regularly use the capacity of their skin to make vitamin D is common sense. 1,000 to 2,000 IU per day of vitamin D in supplemental form is safe to help prevent tooth decay.
 Tisdall, F.F. The effect of nutrition on the primary teeth. Child Development (1937) 8(1), 102-4.
 McBeath, E.C. Nutrition and diet in relation to preventive dentistry. NY J. Dentistry (1938) 8; 17-21.
 McBeath, E.C.; Zucker, T.F. Role of vitamin D in the control of dental caries in children. Journal of Nutrition (1938) 15; 547-64.
 East, B. R. Nutrition and dental caries. American Journal of Public Health 1938. 28; 72-6.
 Mellanby, M. The role of nutrition as a factor in resistance to dental caries. British Dental Journal (1937), 62; 241-52.
 His Majesty’s Stationery Office, London. The influence of diet on caries in children’s teeth. Report of the Committee for the Investigation of Dental Disease (1936).
 McBeath, F.C. Vitamin D studies, 1933-1934. American Journal of Public Health (1934), 24 1028-30.
 Anderson, P. G.; Williams, C. H. M.; Halderson, H.; Summerfeldt, C.; Agnew, R. Influence of vitamin D in the prevention of dental caries. Journal of the American Dental Association (1934) 21; 1349-66.
 Day, C. D.; Sedwick, H. J. Fat-soluble vitamins and dental caries in children. Journal of Nutrition (1934) 8; 309.
 Agnew, M. C.; Agnew, R. G.; Tisdall, F. F. The production and prevention of dental caries. Journal of the American Dental Association, JADA (1933) 20; 193-212.
 Bennett, N. G.; et al. The influence of diet on caries in children’s teeth. Special Report Series – Medical Research Council, UK (1931) No. 159, 19.
 Mellanby, M.; Pattison, C. L. The influence of a cereal-free diet rich in vitamin D and calcium on dental caries in children. British Medical Journal (1932) I 507-10.
12] Connett, P., et.al., The Case Against Fluoride, How Hazardous Waste Ended up in our Drinking Water and the Politics that Keep it There, Chelsea Green Publishing, White River Junction, Vermont, 2010.
Richard Sauerheber, Ph.D.