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

 April 4, 2012

U.S. Food and Drug Administration
Center for Drug Evaluation and Research
Rockville, MD 20857

Dear reviewers,

This letter is in support of the petition to ban the addition of synthetic industrial fluoride compounds into public drinking water supplies, original petition FDA-2007-P-0346, formerly 2007P-0400.

The France 24 international television news broadcast entitled ‘In Deep Water’ (aired March, 2012, interviewed Dr. Kennedy, myself, and Mr. Stewart, general manager of Metropolitan Water District, Los Angeles on water treated with industrial fluoride.

According to Stewart, the entire Los Angeles basin and also the North San Diego County region of Southern California began injecting fluorosilicic acid/caustic soda into all human drinking water a few years ago because of health agency recommendations that MWD entrusts. Previously, Jeff Kightlinger, MWD President, stated that Federal officials from the EPA instruct MWD on procedures and dosages of industrial fluoride to administer to consumers through public water supplies. Taken together, it is clear that MWD officials and employees themselves do not understand the biologic effects of fluorosilicic acid in humans, and instead rely on Federal agencies other than the FDA to determine treatment protocols with fluorides used as though they are safe and effective when taken internally.

In fact, the original plan to use toxic hazardous waste fluorosilicic acid, that the EPA classes as hazardous waste, was delineated by Rebecca Hamner of the EPA years ago. She wrote that a solution to the disposal of toxic hazardous waste fluorosilicic acid is to allow it to be injected into public water supplies as a source of fluoride (see petition and Connett,, The Case Against Fluoride, how Hazardous Waste ended up in our Drinking Water and the Bad Science and Politics that Keep it There, Chelsea Green Publishing, White River Junction, VT, 2010).

The U.S. Safe Drinking Water Act forbids any Federal requirement for any substance added into water other than to sanitize water. The U.S. Surgeon General’s announcement in past years that fluoridation is a public health achievement begs the question of why chemicals that contain fluoride are allowed to violate the SDWA. Placing calcium fluoride, a nontoxic material, into water supplies does not compare with adding hazardous waste industrial fluorides lacking calcium, which the EPA Hamner decision authorized. The CDC recommends the injections, the EPA and CDC overlook SDWA statutes, and both allow hazardous industrial waste injections into public water supplies, advise, encourage and in fact orchestrate dosages and mechanisms.

It is commendable in the TV interview that Stewart admits that science about fluoridation is changing and that a public discussion of the injections is good to have.  Indeed, Dr. Kennedy, D.D.S. was able to point out that the ingestion of industrial fluoride represents a poisoning, where tooth fluorosis permanent abnormal enamel hypoplasia occurs when systemic ingested fluoride is present when teeth develop under the gums at ages 5-8. Abnormal dental fluorosis is exclusively caused by consumption of fluorides, including sodium fluoride and fluorosilic acid fluoride, and the chief source of fluoride in the bloodstream of consumers in a fluoridated water region is from ingestion of fluoride water (National Research Council, 2006, Washington, D.C.). Fluorosis  afflicts approximately 5 million teenagers aged 12-15 in the U.S.  In 2004, 41% of 12-15 years olds had tooth fluorosis according to published figures from the CDC.  Government statistics indicate there are 13 million teens today in the 12-15 year age group. Those teens in 2004 are now in their 20’s, still with the permanent abnormality except for those who have paid large sums for tooth restorations. The next population of children are now developing fluorosis, since 70% of all water districts continue to inject fluorosilicic acid (and, as well, toothpaste with industrial fluoride intended for topical treatment only is not declining in use).

Dosage instructions for, and handling procedures for, hazardous toxic waste fluorosilicic acid is provided to water districts by the CDC and now also the EPA (see previous letters #6 and #18). In the U.S., neither of these Federal agencies has authority to regulate, request, recommend, promote, advertise, require or provide dosage and treatment instructions for any substance intended to be taken internally to affect human tissue. Such Federal actions lie only within the purview of the U.S. FDA. For example, the EPA Maximum Contaminant Level for fluoride at which water becomes non-potable is not an invitation to inject fluoride on purpose to that level, and certainly is not a ‘dosage’ obtained from clinical trials. The MCL does not take into account that people vary widely in daily water consumption and health conditions. Those with tooth fluorosis in particular are not candidates for further, continuous lifelong fluoride ingestion, nor individuals who have been fluoride poisoned in industry or through intentional ingestion of fluoride toothpaste or other sources. Injection of chemical treatments for internal ingestion on a mass scale are based on a theoretic average, healthy person, when no additional sources of fluoride other than from drinking water are available. No person in such a situation in the heavily fluoridated U.S. is known to exist.

The FDA is commended for requesting recently that fluoride mouthwash advertisers cease from claiming that fluoride taken topically promotes gum health, as there is no evidence in support of this. It is now time to also order water districts, industrial fluorosilicic acid chemical suppliers, and CDC and EPA officials to stop advertising that the ingestion of fluoride from industrial compounds decreases teeth caries, as this gives the impression that no adverse health effects of any kind occur along with its ingestion by all consumers, even diabetics (who drink twice normal water volumes daily) and kidney disease patients with impaired ability to eliminate the fluoride ion. And it further continues the myth that industrial fluoride taken internally can decrease caries, when the CDC published that systemic fluoride does not do so (in: Morbidity and Mortality Weekly Report, August, 2001).

A disturbing N.Y. Times article last week went so far as to reprimand parents for providing bottled regular water to children who developed cavities, when in fact normal water without fluoride does not cause cavities. Caries are caused by sugars in the mouth that are not brushed away after eating that S. mutans metabolizes to acid that can degrade enamel. Fluoride, in the bloodstream systemically at 0.2 ppm or in saliva at 0.02 ppm, after ingestion from fluoridated water does not prevent caries (see letters #9, #13). The accusation that normal drinking water is suddenly now unhealthy, and that parents using it should be denounced, is false. It is an extension of much incorrect information provided by the Oral Health Division of the CDC (see letter #6) that is also supported by certain officials in the EPA. One is free not to oppose fluoride injections, but no one has a moral right to make false claims of effectiveness or safety of its long-term consumption by humans, particularly the infirmed. Natural God-given pristine drinking water (without injected synthetic industrial fluoride) is not to be denigrated, but in fact must be valued and protected.



Richard Sauerheber, Ph.D.