Richard Sauerheber, Ph.D.
B.A. Biology, Ph.D. Chemistry, University of CA, San Diego
Palomar College, 1140 W. Mission Rd., San Marcos, CA 92069
January 14, 2012
U.S. Food and Drug Administration Center for Drug Evaluation and Research Rockville, MD 20857
This information is in support of the FDA petition 2007-P-0346.
I mailed the following letter to local city officials who recently were forced by State officials, at the request of Federal officials from the OHD of the CDC, to begin industrial fluosilicic acid injections into all San Diego city water supplies in spite of two city elections voting otherwise.
Dear San Diego City Council and Public Utilities Officials,
As you know, the intent of the U.S. Safe Drinking Water Act is to prohibit any requirement for the addition of substances into water other than to sanitize it. You are now adding fluosilicic acid diluted hazardous waste into water to treat teeth, and you say CA State law forces you to do so in spite of wording in the SDWA.
Could you then at the very least honor the mission of that State law, to improve teeth, by considering getting at the root of the problem of cavity causation, for example by providing calcium nutrition and counseling for residents with any calcium deficiency and high dental caries incidence (see graph below) — instead of broadly treating everyone with synthetic industrial fluoride through public water? This way calcium can be provided to help build strong teeth where it is actually needed.
Fluoride has side effects including tooth fluorosis and bone weakening that calcium does not cause. After 30 years of detailed studies on four hundred thousand children  it was published that dental caries increase a massive 16 times higher in incidence in children with calcium-deficient diets, which occurs whether water contains appreciable fluoride or not. The authors concluded:
“The only practical and effective public health measure for the prevention and control of dental canes is the limitation of the fluoride content of drinking water to < 0.5 ppm, and adequate calcium nutrition (dietary calcium > 1 g/day).”
 S P S Teotia and M Teotia, Dental Caries: A Disorder of High Fluoride and Low Dietary Calcium Interactions (30 Years of Personal Research), Fluoride 1994; 27(2): 59-66.
Caries Incidence % vs. Low or Normal Calcium and Low or 1 ppm Fluoride
The percentage of dental caries are graphed as a function of the presence of dietary calcium deficiency (blue bars), accompanied with either low fluoride (left) or approximately 1 ppm fluoride levels in drinking water (right), and normal dietary calcium (red bars) accompanied with either low fluoride (left) or 1 ppm fluoride in drinking water (right). The data are from Teotia and Teotia for a 30 year study of 400,000 children. Notice that the highest incidence of caries was found in children with a calcium deficient diet where water was approximately 1 ppm fluoride. The lowest caries incidence was found in children with low fluoride water while also having adequate dietary calcium.
The reason for these results are obvious. Calcium is the chief ingredient in normal teeth enamel, and normal crystalline hard enamel that resists cavities can only form in children in the absence of fluoride-induced enamel fluorosis. Fluoride is unable to counter increased caries incidence from calcium dietary deficiency, and in fact fluoride contributes to caries incidence in this case. Fluoride also causes tooth fluorosis in children, whether on calcium-deficient or normal calcium diets (not shown for brevity).
Doesn’t it make sense to use the best available mineral to help teeth? If you are planning to continue disseminating a substance to be taken internally to affect teeth, then shouldn’t it be a substance like calcium, that is a normal dietary component, has a daily dietary requirement, is a mineral nutrient and an essential body component required for teeth enamel formation, and its deficiency causes conditions favorable to formation of caries? Fluoride is not a mineral nutrient according to the U.S. Food and Drug Administration, has no daily dietary requirement, from the bloodstream can cause tooth fluorosis, and after ingestion produces only 0.02 ppm fluoride ion in saliva  unable to affect teeth topically.
 National Research Council Report on Fluoride in Drinking Water, A Scientific Review of EPA’s Standards, Washington, D.C., 2006.
Calcium supplementation corrects calcium deficiency, that causes inadequate enamel formation and conditions that lead to dental caries. Let’s treat the causes, insufficiently developed enamel and not brushing after eating sugary foods, rather than after-the-fact attempts to treat the symptom, cavities, with fluoride in drinking water where dosage cannot be controlled, and that is of no significant value as observed in large numbers of studies , where the absence of fluoride in drinking water does not itself cause dental caries. Caries are caused by acid secretions from S. mutans metabolizing sugars, where insufficient enamel covering teeth dentyne is the most readily breeched.
 Connett, P., et.al., The Case Against Fluoride, How Hazardous Waste Ended up in our Drinking Water and the Politics that Keep it There, Chelsea Green Publishing, White River Junction, Vermont, 2010.
Thank you again for your attention on this matter,
Richard Sauerheber, Ph.D. [Enclosure on calcium deficiency and enamel hypoplasia]
Hypocalcaemia is a specific cause of tooth enamel hypoplasia. Recently evidence has suggested that the etiology of enamel hypoplasia is highly specific. Enamel hypoplasia is seen in children having disorders of calcium homeostasis. Low calcium level in serum is one of the major causes of enamel hypoplasia.
Enamel Hypoplasia and Caries. Enamel hypoplasia is clinically significant not only because it is disfiguring and the restorative treatment costly, but because it may affect caries susceptibility. There was a strong correlation between hypoplasia in the teeth of British schoolchildren and caries susceptibility. Out of a collection of 1,500 extracted teeth, 74% of very hypoplastic teeth were carious, whereas 80% of the nonhypoplastic teeth were caries–free. Caries has also been associated with hypoplasia in many parts of the Third World. There is no information about the chemical composition of hypoplasia enamel so the exact reason for its greater proneness to caries is uncertain, but it is possible that its irregularity and pits may favor the development of more plaque compared with smooth well-formed enamel.
Enamel hypoplasia is due to many causes. It can be due to high fluoride level or due to some medicines or if the child becomes ill when the teeth which are affected by enamel hypoplasia are being formed. The treatment depends on degree of hypoplasia. Intially the composite restorations are done and if it is more (ie whole of enamel is hypoplastic) then veneers or crowns are indicated in later age when the teeth are fully formed.