Richard D. Sauerheber, Ph.D.
Palomar Community College
1140 W. Mission Rd., San Marcos, CA 92069
E-mail: richsauerheb@hotmail.com   Phone: 760-402-1173

July 26, 2012

Dear sirs,

Toothpaste contains 1,500 ppm fluoride, argued to be an effective decay-preventing dentifice. On the other end of the spectrum, fluoride in saliva from ingested industrial fluoride in treated water supplies is only 0.02 ppm (NRC, 2006 p.81), which although unable to enter teeth enamel is also claimed by dental officials at OHD to prevent teeth decay by topical means.

Questions:

1) If 1,500 ppm fluoride acts topically to prevent teeth decay during teeth brushing, then how does fluoridated water prevent tooth decay when ingested fluoride is present in saliva at 75,000 times lower concentration than in toothpaste?  Could you please provide the data that prove 0.02 ppm fluoride bathing teeth is superior to 0.01 ppm or less that is typically found in saliva in non-fluoridated cities, that would justify the U.S. to continue spending over 300 million dollars annually to adjust fluoride levels in most all U.S. water supplies?

On the other hand:

2) If 1 ppm fluoridated water that produces 0.02 ppm fluoride in saliva can act topically to reduce decay as many dental officials argue, with only 0.02 mg available per 24 hour day, then why does toothpaste need to be 75,000 times more concentrated than this to be effective at treating teeth to prevent decay? Where is the data that proves a need for 1,500 ppm fluoride in toothpaste, when 0.02 ppm for a 24 hour period between brushings contains only 0.02 mg fluoride total available (1 liter of saliva daily) while a tooth brush would contain 1.5 mg, 75 times more than in 24 hours worth of saliva, a 75 day supply?

Please respond to these questions at your earliest convenience with data from these studies for all to see and analyze. The usual claim that ‘fluoride is a great public health achievement’ or that ‘fluoride decreases decay’ do not suffice, since no mention is made of the amounts of fluoride required to achieve these claims. Indeed, the CDC publication in Morbidity and Mortality Weekly, August, 2001 stated that systemic fluoride from ingestion does not decrease teeth caries, and fluoride is only believed to act topically (i.e. presumably from toothpaste).

We have city Council members from many U.S. and Canadian cities needing answers to these questions, before deciding to continue infusing industrial fluorosilicic acid/caustic soda materials into drinking water to treat citizens for the purpose of taking fluoride internally, all without FDA approval for ingestion. Cities infusing industrial fluoride into water to treat citizens are fully liable and know full well that the FDA ruled in 1963 that fluoride is not a mineral nutrient and when injected into water is an uncontrolled use of an unapproved (1993) drug.

The U.S. Health and Human Services request in 2011, that fluoride in water not exceed 0.7 ppm until updated guidelines are developed, addressed the problem that 41% of U.S. teens as of 2003 have permanent fluorotic teeth with abnormal enamel hypoplasia and ugliness. Colgate toothpaste manufacturers have written that water districts are at fault for this endemic (Los Angeles Times, Jan., 2011) by allowing fluoride to be swallowed– toothpaste is not to be swallowed, but applied directly to teeth. On the other hand, water district officials argue that toothpaste manufacturers are at fault for the endemic, because fluoridated water began in 1945 and toothpaste use followed many years afterward, so water fluoridation was set in place prior to the pervasive use of concentrated toothpastes. The FDA would argue that both contributors are at fault, since the NRC 2006 report clarified that 55% of fluoride in the bloodstream is that ingested from treated water, and 35% is from toothpaste use.

Currently there are no city officials who obtain measurements of blood fluoride or saliva in treated citizens to ensure that infused industrial fluoride from fluorosilicic acid/caustic soda mixtures is either safe or effective, in spite of vast data indicating that soft water allows blood fluoride levels to accumulate to 4 times higher concentrations than fluoride present from ingesting treated hard water containing sufficient calcium to minimize assimilation of fluoride from the GI tract.

Richard Sauerheber, Ph.D.

Copy sent to U.S. Food and Drug Administration, Center for Drug Evaluation and Research, Rockville, MD 20857 (in care of petition FDA-2007-P-0346)

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Response from the CDC, admitting that they have no answer to this important question: