Richard Sauerheber, Ph.D.
Palomar College
1140 W. Mission Rd.
San Marcos, CA 92069
U.S. Food and Drug Administration
Center for Drug Evaluation and Research
Statements in support of FDA-2–7-P-0346 petiton to ban synthetic fluoride compounds for human ingestion
The recent recommendation, from the Department of Health and Human Services, to lower fluoride levels in U.S. drinking water supplies, and the press release from the U.S. Environmental Protection Agency, on the same day January 7, 2011 concluding that fluoride injected into water is “not a useful therapeutic”, are important steps in the right direction. We applaud anyone from the FDA who may have participated in this action. The reduction from 1.2 to 0.7 ppm is a provisional request level and it must be emphasized is insufficient to substantially improve tooth fluorosis in U.S. children. For example, the 41% fluorosis incidence in 12-15 year olds reported represents an underestimate of the actual level today, as these children are now 20 years old and fluorosis has been progressively increasing during that time. This means that lowering the fluoride from 1.0 to 0.7 will merely slightly slow the increasing incidence rate.
The most accurate studies on the incidence of tooth fluorosis in children as a function of water fluoride level, that were well controlled, are those published by Ziegelbecker (‘Fluoridated Water and Teeth”, Fluoride 14, no.3, 123, 1981; http://fluoridealert.org/re/ziegelbecker-1981.pdf). Detectable significant tooth fluorosis incidence progressively increases in populations as a direct function of prevailing fluoride content in the water during teeth development in childhood. Fluorosis incidence increases from 0.3 to 0.7 ppm fluoride with a slope comparable to that between 0.7 – 1.3 and also from 1.3-6.0 ppm fluoride. Further studies (“Dental Caries and Dental Fluorosis at Varying Water Fluoride Concentrations”, Journal of Public Health Dentistry 57, no 3:136, 1997) also indicate linear progressive increases in fluorosis from 0.3 to 1.2 ppm fluoride in water. These studies taken together prove that even ‘low’ levels of 0.3 ppm fluoride in water are insufficient to protect childhood residents from tooth fluorosis (as reviewed in Connett, et.al. the Case Against Fluoride, Chelsea Green Publishing, White River Junction, Vermont, 2010). Many cities in the U.S. are now therefore already naturally ‘fluoridated’ to a maximum level at which fluorosis occurence is beginning.
Fluorosis is the first visible sign of fluoride poisoning and fluoride overdose (National Research Council, Report on Fluoride in Drinking Water, 2006; ), and fluorotic enamel is more subject to tooth decay and requires greater dental repair work. All cities that inject synthetic fluorides have higher fluorosis incidence rates; there are no execeptions, which means the act itself is overuse of the agent as a putative drug. It is necessary to eliminate water fluoride injections into drinking water altogether. The allowed added level of fluoride into drinking water in the U.S. must be zero.This is consistent with the EPA reports requesting they be halted.
The Los Angeles Times Jan 7, 2011 reported that some officials now argue that tooth fluorosis is ‘not the fault of water fluoride, but rather is the fault of fluoridated toothpaste’. Colgate Palmolive however on their public website argues that children develop tooth fluorosis by drinking fluoridated water along with fluoride toothaste use, essentially placing indirect ‘blame’ on the children for drinking the fluoridated water. It must be emphasized that half of the fluoride ion in the bloodstream of consumers in fluoridated cities comes from toothpaste use and the remaining half from the water (NRC, 2006). Both fluoride sources are equally at fault, and together produce the permanently abnormal fluorohydroxyapetite enamel. When the abnormal enamel is sufficient to be observed with the naked eye, these visible fluorotic teeth are an embarrasing disfigurement for children and it is permanent, lifetime.
There is no dose of fluoride that eliminates fluorosis from all consumers (obviously below 0.3 ppm) that does not also cause pathologic accumulation of the ion permanently into bone. At only 1.0 ppm fluoride in drinking water, bone fluoride accumulates to 4-5,000 ppm lifetime which weakens bone (NRC, 2006), increasing tendency of hip fractures. We now have an epidemic of hip fractures in the U.S. elderly (New Eng J. Med) with 1/3 million cases annually that costs approximately 19 billion dollars yearly for convalesence (Stevens, CDC publication) waiting for bone to heal, all while 65% of U.S. water districts now have gradually become fluoridated.
The original bsis for fluoridaiotn was that at 1 ppm a cavity reduction was thought to take ploace while fluorosis incidence was an accepted ‘side effect’. We now know from the Ziegelbecker comprehensive data set that tooth decay varies among communities, producing a significant level of background noise that was originally coincidentally perceived as a cavity-reducing effect, that is most likely due to variation in calcium content of the water, while the fluoride only causes tooth fluorosis adverse effects. There is no effect on teeth cavities above background noise over a wide range of fluoride concentrations in water, while at the same time tooth fluorosis incidence significantly increases progressively in a concentation dependent manner with increasing fluoride level in the water above 0.3 ppm (Connett, 2010).
It is necessary to halt all fluoride injections into public water supplies without further delaly. This is a National emergency. There is ample proof that swallowed fluorides do not decrease teeth cavities systemically from the blood (CDC, Morbidity and Mortaility Weekly Report, Aug 17, 2001), and the NRC (2006) reported that fluoride in saliva from ingested 1 ppm fluoride water averages only 0.02 ppm, incapable of affecting teeth, all consistent with epidemiologic studies indicating that cavities do not decrease in fluoridated cities (Hileman, B., Chemical & Engineering News, 1985), or increase when fluoridation is halted (Connett, 2010). Only toothpaste with 1,500 ppm fluoride can decrease bacterial growth and can affect teeth topically; ingested fluoride water cannot.
Richard Sauerheber, Ph.D., Chemistry; University of CA, San Diego; currently Palomar College, 1140 W. Mission Rd., San Marcos, CA 92069, 760-744-2547
Richard, Thank you for your post. I wear different hats, depending upon whom I am addressing. I was intrigued by your mention of the 0.02 mg/l levels in saliva. Are you familiar with the concept of hormesis and the threshold for fluorine whereby it begins to act at this level through LT and NLT mechanisms? Of course I am not advocating fluoridation by any means, for varied and obvious reasons, but this is an area that needs to be explored. The work of E.J. Calabrese at U Mass is elucidating in this regard. Your comments would be appreciated.
thanks,
John