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Dr. Richard D. Sauerheber

Palomar Community College

1140 W. Mission Rd., San Marcos, CA 92069

E-mail:   Phone: 760-402-1173

June 8, 2012

Department of Health and Human Services
Public Health Service
U.S. Food and Drug Administration
Center for Drug Evaluation and Research
Office of Regulatory Policy
Rockville, MD 20857

Dear FDA Project Reviewers,

I write this letter in support of the petition to ban fluoridation, that is adding synthetic industrial fluoride compounds into public drinking water supplies, FDA-2007-P-0346, formerly 2007P-0400.


The Everett, Washington city council is currently conducting public hearings on water fluoridation. The key witness for the city in favor of fluoridation is a Dr. Goldblum who presented arguments that fluoride in public water supplies is “safe” and “natural.”  Each contention made by Goldblum is addressed in the letter below for the benefit of the FDA.


Secondly, the country of Southern Ireland accepted and published a treatise on water fluoridation by Chartered Environmental Scientist Declan Waugh, a 360 page document with 1,216 scientific references that request an immediate halt to water fluoridation. The document was also submitted to the European Union. A health professional offered several arguments against the document that were incorrect. A letter was written to Declan Waugh by request that addresses each point, and a copy is enclosed here for information in support of the ban petition to the FDA.


Again, if a ban cannot be instituted for any reason, then:


1)      Federal officials must be told to cease requesting or recommending synthetic industrial fluoride compounds be taken internally through ingestion since no such compound has been approved by the FDA for ingestion and only sodium fluoride is allowed as an unapproved drug to be taken internally by prescription only;

2)      a moratorium on synthetic industrial fluoride infusions into public human water supplies may be issued until controlled clinical trials data are submitted on human volunteers to the FDA for a new drug application, particularly for HF-containing fluorosilicic  acid;

3)      or letters from the FDA to fluoride chemical suppliers (currently about 49 such suppliers exist in the U.S.) requesting data in their possession demonstrating safety and effectiveness for those ingesting their product;

4)      or FDA could request that fluoride compounds only be added into water that is rich in calcium, to maintain the original 200 to 1 divalent cation to fluoride ion ratio present in  Hereford, Texas water where the idea of water fluoridation actually first began;

5)      or  calcium chloride could be added to water which is known to strengthen teeth and  to build strong enamel in childhood growth years, rather than systemic ingested fluoride ion, which is ineffective for this purpose and is unsafe long-term.  Foods rich in calcium may be suggested as fluoride water substitutes, including spinach (595 mg calcium per 100 grams), onions (135 mg per 100 grams) and broccoli (160 mg per 100 grams).


Thanks much,


Richard Sauerheber, Ph.D.


Letter in response to Dr. Goldblum

Letter to Declan Waugh in response to Dr. Leland