Richard Sauerheber, Ph.D.
Palomar College
1140 Mission Rd.
San Marcos, CA 92069
April  9, 2011

Dear U.S Environmental Protection Agency,

Please re-examine the pdf report published by the EPA recently on non-cancer effects of water fluoride consumption. Understand for example that the Taiwan study (Chen, 1989) detected significant tooth fluorosis in children raised on water with fluoride ion between 0.4 – 0.7 ppm, with incidences ranging from 14 to 33% (100 – 86 = 14% and 100 – 68 = 32%). This is consistent with the best data we have from our most massive study (described in Connett, et. al. “The Case Against Fluoride”, 2010), where any water level from 0.3 ppm or higher usually causes significant tooth fluorosis (which is abnormal enamel caused, we now believe, by fluoride inhibition of the required enzymatic removal of protein from sites of enamel hardening), the first visible sign of fluoride overdose (Groth, E., World Book; Connett, 2010).


Any recommendation from the EPA to allow or promote injections of synthetic water soluble fluorides (all with low LD50 single doses in experimental animals of 125 ppm, blood lethal level of 3-5 ppm, compared to natural insoluble calcium fluoride with a safe high oral acute LD50 of 3,000 ppm) into public water supplies to 0.7 ppm will increase the incidence of tooth fluorosis in resident children.  Such a recommendation represents a complete reversal of the original mission of the U.S. EPA, which is to protect the public from environmental harm. It is also a violation of the original Congressional approved mandates of the U.S. Safe Drinking Water Act, which prohibits any Federal requirement of an amount of any substance to treat water (whether a beneficial food, or a drug with potential side effects) other than to sanitize the water. The addition of fluorides into water, which purposes to treat human tissue, is thus illegal and the EPA should be ashamed of investigating such a possibility.


Fluoridation has been allowed by the EPA in recent times and has caused the inclusion of added regulations, not approved by the U.S. Congress, into the SDWA to prevent punative measures against States that treat their citizens with this substance in water. It is time to end these allowances, rather than to extend even further from the law and actually recommend a Federal level of this agent as a tissue treatment that has never been approved for oral ingestion by the U.S. FDA.


For modern data see the report from Dr. Kathleen Thiessen, Oak Ridge Laboratories (see reference below) and data from the Adelaide Dental research group in Australia (enclosed). These data all confirm conclusively that fluoride consumption from water at 0.3 ppm or above DOES NOT reduce dental caries, but instead causes significant abnormal dental fluorosis. The notion of the EPA presented in the introduction of its pdf report is false, that the old Dean study “proved” there is a dose at which caries are reduced from oral ingestion of fluorides. This myth has been widely parroted but never actually found by experiment. In fact quite the contrary. The data from NIDR (Hileman, Chemical and Engineering News, 1985; Connett, 2010), from Osmunson (Spittle, Fluoride Fatigue; FDA petition 2007-P-0346 attached), from Australia and Thiessen, and many other sources prove cavity incidence is not significantly lowered in children raised with fluoridated water (


Finally, in a most stunning finding, the NRC Report (2006) found that fluoride in saliva from water containing 1 ppm fluoride is present as a blood filtrate at only 0.02 ppm, unable to influence teeth topical surfaces–period. High levels of topical fluoride are now argued still to be effective when present at 1,500 ppm in toothpastes and other external topical prophylactics not to be swallowed, but the old idea that ingested fluoride may have such effects, based on the original Dean data in communities with NATURAL (not injected synthetic) fluoride, is discredited (CDC, Morbidity and Mortality Weekly Report, Aug. 19, 2001).


It is long past time to ban artificial injections of unnatural synthetic fluoride compounds, in particular the highly water soluble diluted hazardous waste fluosilicic acid, into public water supplies, as has been requested in petitions to the FDA, EPA and CDC. The injections are harmful, do not decrease caries incidence (see FDA petition P2007-0346 please see attachment), are illegal and costly. If there is any Government program that should be listed for funding cuts to minimize our current financial debt crisis, toxic calcium-chelating synthetic fluorides being used as though they are useful drugs must be on top of that list. Taxpayers pay for health and normal regular drinking water without injected drugs or unnecessary substances, and expect the EPA to provide assistance. This request is fully consistent with and backed up by Section 101a of the Federal Water Pollution Control Act, with the stated mission to maintain the natural chemistry of U.S. water supplies. This act was first conceived by our late President John F, Kennedy, and it has now become necessary, due to widespread false information to the contrary, for the EPA to actively help the country follow this true environmental principle.


Thank you for your attention,


Richard Sauerheber, Ph.D., Chemistry, University of CA, San Diego

currently Palomar College, San Marcos, CA

1. Dr. Thiessen data proving fluoride ingestion from water does not decrease caries but instead increases tooth fluorosis to varying degree (depending on prevailing calcium content in the water that is not regulated when fluorides are injected).

2. FDA petition response attachment (one section in this detailed response to the FDA was not intended for the general public and is here included out of necessity, thank you).

3. Media Release: Brisbane, Australia 4th April  2011

Merilyn Haines, the director of the newly formed group FAN-Australia (Fluoride Action Network Australia), has found some startling statistics buried deep in official research material by ARCPOH (The Australian Research Centre Population Oral Health at the Adelaide Dental School) that could scuttle the water fluoridation program once and for all.

Haines has found in the ARCPOH statistics that the permanent teeth of children in largely unfluoridated  (<5% before 2009) Queensland were erupting on average two years earlier than the children in the rest of Australia, which is largely fluoridated (see the figure below). A two-year delay would negate all the small reductions in tooth decay claimed by dental researchers since 1990. In other words fluoridation doesn’t work. Any difference in tooth decay claimed to be due to fluoride is simply an artifact of the delayed eruption caused by fluoride.


Source – Published and unpublished data from 2003- 2004 Australian Child Dental Health Surveys
(unpublished data obtained by Freedom of Information application)

According to Professor Paul Connett, director of the Fluoride Action Network, who is currently on a fluoride-tour of New Zealand, “Critics of fluoridation, like Dr. Hardy Limeback in Toronto, have long pointed out that any reduced tooth decay touted by promoters could easily be accounted for by the delayed eruption of the teeth. Even when this argument received strong experimental support from Komarek et al. in 2005, this has still has been ignored by those promoting fluoridation. But they cannot ignore it any longer: the figures of the dental department research team most associated with the promotion of fluoridation in Australia (and beyond) demonstrate that this delay is real.”

Less teeth erupted for any given age would mean less surfaces available for tooth decay to have taken place. A delayed eruption of one – two years would account for the small reductions claimed in ALL the US and Australian studies published since 1990 (Brunelle and Carlos, 1990; Slade et al., 1996; Spencer et al., 1996; Armfield et al., 2009; Armfield, 2010). These studies have found reductions ranging from 0.12 of one permanent tooth surfaces saved in Western Australia (Spencer et al., 1996) to 0.6 permanent tooth surface saved in the largest survey ever conducted in the US (Brunelle and Carlos, 1990). This is not very much when you consider that there are five surfaces to the chewing teeth and four to the cutting teeth, and by the time all the child’s teeth have erupted there are a total of 128 tooth surfaces. One tooth surface saved amounts to less than 1% of all the surfaces in a child’s mouth. Now even this small benefit has evaporated.

More on the history.

In 1999, the National Health and Medical Research Council, Australia’s peak Medical Research body, stated that, “evidence exists that tooth eruption is delayed in fluoridated areas. It has been suggested that a proper comparison of caries rates should involve children one year older in fluoridated areas than in non- fluoridated areas.”

In 2000, the York Review pointed out that none of the studies that they had reviewed had controlled for “the number of erupted teeth per child” (McDonagh et al., 2000, p.24).

In 2005, Komarek et al.  did control for eruption of teeth and reported no difference in decay between children living in Belgium receiving fluoride supplements (and those who weren’t) that was relatable to fluoride exposure (as measured by the severity of dental fluorosis).

In 2009, Peiris et al. reported that children in largely fluoridated Australia had a delay in “dental age” of 0.82 years compared to children in largely unfluoridated UK. However, the authors did not discuss the possible reasons for this delay and the number of children involved in the study (about 80 in each country) was not very large.

2011. Now the bombshell – the delay has been found and it is in the official statistics. ARCPOH has failed to respond to several inquiries on this matter.  According to Haines, “Surely, this must end water fluoridation. If it doesn’t work what’s the point of putting this toxic substance into the drinking water and what reason can they possibly have for forcing it on people who don’t want it?”

However, this isn’t just about teeth. The finding could be even more significant than that. If fluoride causes a delayed eruption of the teeth then the most likely mechanism for doing so is fluoride’s ability to lower thyroid function (see chapter 8 in the 2006 National Research Council review, “Fluoride in Drinking Water.” According to Connett,  “Lowered thyroid function in infants would mean slower growth of their tissues and could explain the 24 studies that have found an association between lowered IQ in children and exposure to moderate levels of fluoride in China, India, Iran and Mexico.”

It also raises the possibility that millions of people in fluoridated countries suffering from hypothyroidism have had this condition caused, or exacerbated, by exposure to fluoridated water.  Haines’ asks “If ingesting fluoride delays tooth eruption for 1 to 2 years what other effects is it having on our bodies?”

Meanwhile, if swallowing fluoride does not reduce tooth decay, why would any reasonable person, decision maker or regulatory official continue to sanction adding fluoride to the public water supply?

Australian  media contacts   mobiles  –  0418 777 112 and 0403029077

Media Release sent by Queenslanders For Safe Water on behalf of Fluoride Action Network Australia Inc