In context with the scheduled fluoridation of Bunbury’s water supplies, we have asked WA Health some extremely important and relevant questions about the safety and effectiveness of water fluoridation. We eagerly await their response.
BUNBURY FLUORIDATION MENU
It appears that WA Health has a very clear strategy, as follows:
- Involve the community as little as possible, with minimal public consultation, interaction and meetings;
- Create minimal and obscure publicity for these meetings so that very few people attend;
- Say the poor attendance at convened public meetings is due to a lack of interest in fluoridation from the community, not a lack of publicity activities;
- Shield the public from the enormous body of toxicity science, especially the emerging, rigorous, neurotoxicity science, showing fluoride damages the developing brains of our young;
- Keep the public uninformed about the obvious lack of efficacy of fluoridation, including: i) the many large-scale, population-based studies – including extensive WHO dental data – clearly showing there is no difference in tooth decay rates between fluoridated and non-fluoridated countries, cities and regions; ii) Most European nations, representing 98 percent of Western Europe, have ceased, rejected or banned water fluoridation because it is not safe, not effective and not ethical; and iii) less than 5 percent of the world receives fluoridated water;
- Hide the fact that fluoridation chemicals are an extremely toxic, hazardous, acidic, contaminated waste product, a Schedule 7 Poison, from fertiliser manufacture that cannot legally be disposed of anywhere in the environment; and of course DO NOT reveal that this untreated raw hexafluorosilcic acid waste will come directly from the CSBP fertiliser factory in Kwinana and will be added to Bunbury’s drinking water without any treatment or processing.
- Conduct biased surveys by relying on a community that is largely unaware of the facts of fluoridation and by asking leading questions to obtain desired answers. In the last survey conducted by WA Health in 2018, 89 percent of respondents did not know if Bunbury’s water was fluoridated!
- Rely on extremely poor-quality efficacy studies to support fluoridation – studies that do not even control for all major confounding factors such as sugar consumption, dental hygiene, total dietary profile and socio-economic status and did not even meet the relaxed inclusion criteria for the comprehensive Cochrane Metta Review (2015).
- Rely on one particular very poor-quality study, commissioned and published by WA Health, that involves a weak study design and shows very little difference in tooth decay rates between fluoridated Perth children and non-fluoridated Bunbury children;
- Engage or encourage dentists or other health professionals in Bunbury and the South-West to promote fluoridation, who have always been pro-fluoride and who seem to be totally unaware of the science of fluoridation;
- Do not inform the public, media or anyone about the total capital and operating costs of this fluoridation project – one of the most expensive fluoridation projects in Australia. And DO NOT disclose that these costs will inevitably be passed on transparently to the end user, of course as fluoridation costs have in Perth and elsewhere in Australia;
- Protect this entrenched policy at all costs because it is popular and because they cannot admit they got it very wrong decades ago. As long as the public remain ignorant of the facts, this reckless policy will remain popular and our politicians will continue to add a toxic waste chemical to our drinking water that is NOT effective in reducing tooth decay and is only doing us harm!
Letter and questions for WA Health
To:
Hon Amber-Jade Sanderson BA MLA
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Dr. Andrew Robertson
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Dear Minister Sanderson and Dr Robertson
RE: Artificial fluoridation of Bunbury’s water supply
In relation to the scheduled fluoridation of Bunbury’s water supply, as announced by WA Department of Health (WA Health) in January 2021, Fluoride Free Australia Inc., Children’s Health Defense Australia Limited and Fluoride Free Western Australia Inc., require answers to several questions listed.
We understand these questions are extensive, however this scheduled fluoridation program will directly affect many people’s health and wellbeing and therefore the ramifications of this controversial subject are both very serious and important and also highly relevant to the people of Bunbury.
The format used involves a direct question or a brief background statement, followed by a question. There are 30 questions in total. Your response to each question is requested and will be greatly appreciated. Many of these questions will require only a brief answer.
We believe every statement contained in this letter can be justified with published material. We have provided some detailed references, however, please don’t hesitate to contact us should you require any clarification or any further references.
The underlying reason for this letter is the concerning results of many rigorous published studies and scientific findings about fluoridation – both its efficacy and potential toxicity – do not seem to be reaching the most important people such as yourselves, who are ultimately responsible for the decision to fluoridate.
Thank you in advance for your attention to what we are presenting, and your serious consideration of the questions being asked.
We look forward to hearing from you.
Sincerely,
Fluoride Free Australia Inc.
Children’s Health Defense Ltd.
Fluoride Free WA Inc.
SIX attachments accompanied this letter (see below)
Questions directed to Hon Amber J Sanderson and Mr Andrew Robertson
Health and safety first
A prime objective of the WA Health regarding water fluoridation should be the health of consumers and the genuine safe benefit to them.
Q 1: Do you agree, and if not why not?
Water fluoridation is forced by law onto whole communities, with no means of exit offered. Ethically therefore, special precaution should be taken by fluoridating authorities to ensure that fluoridation is of actual benefit to the consumer, and does not represent a significant risk to consumer health.
Q 2: Do you agree, and if not why not?
Fluorine is not biologically benign. Rather, it is “the most electronegative element, [and] is much more reactive than other elements. … Fluorine reacts virtually with every other element, including the helium group gases. … Because fluorine forms stable bonds, its compounds can be both stable and extremely reactive.” [Ref: Kirk Othner, Encyclopaedia of Chemical Technology, 1-8, 2000, or indeed any decent chemistry text].
Fluoride is NOT an essential nutrient, as some fluoridating agencies have misleadingly claimed in the past. It has no normal role or function in the body and, because of its extreme reactivity, can logically be expected to disrupt normal biological and biochemical processes, thereby risking bodily dysfunction.
Fluoride is frequently referred to as a ‘protoplasmic poison’, or general poison of cells (Reference for example, Journal of Toxicology, Volume 204, Issues 2—3, 15 November 2004, Pages 219-228’)
“Recently, epidemiological studies have suggested that fluoride is a human developmental neurotoxicant that reduces measures of intelligence in children, placing it into the same category as toxic metals (lead, methylmercury, arsenic) and polychlorinated biphenyls.”[1]
“The mechanism of fluoride toxicity can be broadly attributed to four mechanisms: inhibition of proteins, organelle disruption, altered pH, and electrolyte imbalance.”[2]
“The fluoride ion concentration, which builds up in the cells, has been described as a “general protoplasmic poison” that causes inhibition of both aerobic and anaerobic pathways.”[3]
Q 3: In view of those knowable biochemical risks from fluoride consumption, what precautionary measures has WA Health taken to (i) study and assess the potential for adverse health effects from fluoride consumption; and (ii) ensure the safety of lifetime fluoride consumption from fluoridation, for all sectors of the community?
The assessment of biological toxicity depends on knowing the exact dose consumed in relation to detected effects.
Q 4: What exact actions has WA Health undertaken (i) to measure (or have measured) daily consumer intake of fluoride under fluoridation, and (ii) to monitor any adverse effects?
Q 5: What is WA Health’s adopted oral reference dose for safe daily exposure to fluoride for a lifetime? On what data and endpoints was that reference dose calculated, and where is that information recorded?
Q 6: In calculating the oral reference dose, what safety factor was applied to account for variability in fluoride sensitivity across various sectors of the population (e.g. very young, iodine deficient, kidney or thyroid dysfunctional, high volume consumers etc.)?
Q 7: If no direct action has been taken to assess health risks based on actual consumption, by what other means has WA Health sought to assure itself of the safety of fluoride consumption and fluoridation?
NHMRC operating without safety data
The National Health and Medical Research Council (NHMRC) is Australia’s primary source of advice on fluoridation health safety, and has since 1953 endorsed fluoridation as unconditionally safe, offering no health warnings.
However, NHMRC appears never to have taken steps to actually assess the safety, or otherwise, of fluoride consumption and fluoridation.
Specifically:
- An examination of all fluoridation projects funded by NHMRC since 2000 reveals no projects funded by NHMRC except those designed to demonstrate the benefits of fluoridation, without ever investigating risks to general health;
- NHMRC funds projects based on requests received from research organisations and does not fund study projects from its own initiative for the purpose of, for instance, fulfilling its duty of care to the nation by proactively assessing whether or not fluoridation is actually safe;
- The NHMRC’s own fluoridation reports of 1991 and 1999, make extensive recommendations as to the need for general health safety studies (Attachment 1);
- A letter from NHMRC to NSW Health in 2005 states that all those previously recommended studies were cancelled in 2002 “due to insufficient resources,” with no intention to recommence (NHMRC to NSW Health, 24 February 2005, Attachment 2, page 1, 3rd paragraph);
- A 2016 letter from NHMRC to Port Macquarie-Hastings Council confirms that no health safety studies have ever been funded by NHMRC, saying: “Apart from this research on dental fluorosis, there have been no projects funded by NHMRC prior to or after 2000 that investigated potential negative effects from fluoride or fluoridation.” (NHMRC to PMHC, 29 April 2016, Attachment 3, page 1, 3rd paragraph).
There is no other reasonable conclusion than that NHMRC have — in the entire past 70 years of fluoridation – ever actively or systematically investigated the potential negative effects of fluoride or fluoridation.
Without doubt then, NHMRC’s safety assurances about fluoridation cannot be reasonably relied upon due to their self-admitted failure ever to fund any health safety studies, even those its own reviews had recommended.
Q 8: Had you been previously aware that NHMRC has been endorsing the safety of fluoridation without ever having funded a single project designed to assess fluoridation health safety?
Q 9: Being now aware that NHMRC has never funded any fluoridation health safety studies, do you accept that therefore NHMRC cannot ‘reasonably’ be relied upon for evidence-based advice on the safety or not of fluoride consumption and fluoridation? If not why not?
Q 10: In the absence of any reason to trust NHMRC for fluoridation safety advice, will you now cease to support and enable water fluoridation? If not why not?
The need for proper assessments
Q 11: Will you please provide the following if this exists:
- The results of any chronic toxicity studies on which WA Health relies, which investigate the impact of long-term ingestion of fluoride through drinking water on the prevalence of: (i) dental fluorosis;
(ii) skeletal fluorosis; (iii) hip fractures; (iv) arthritic pain, and (v) fluoride hypersensitivity reactions. - The results of any randomised, double-blind, controlled trials on the alleged effectiveness of water fluoridation in substantially reducing dental caries/tooth decay in any age group.
- Any published scientific evidence showing that the significant mechanisms of action by fluoride in reducing tooth decay are ‘systemic’, requiring actual consumption, as opposed to ‘topical’, by external application.
- The results of any published studies or toxicological data or assessments designed to investigate the safety or otherwise of the use in drinking water of the fluoridation chemicals: hexafluorosilicic acid (H2SiF6) or sodium silicofluoride (NaSiF6).
- The results of any published toxicological dose-response risk assessments on human health from fetal life until the end of life, using measures of actual daily fluoride intake from any source (whether from fluoridated water or from food, beverages, medications, air pollution, pesticides etc.)?
- The results of any studies designed to measure and compare daily fluoride intake under fluoridated or non-fluoridated conditions?
Health safety — published evidence ignored by NHMRC
NHMRC’s fluoridation reports of 2007 and 2016 have deemed fluoridation to be unconditionally safe for all people. However, those reports were based on incomplete evidence, namely due to NHMRC actively excluding or dismissing high quality published research showing evidence of risks to health from fluoride and fluoridation that were actually available to NHMRC.
The by-passed studies are identified and described in Attachment 4. All are either higher quality single-studies, or meta-analyses of many separate studies which, had they been considered by NHMRC, would have offered significantly reliable evidence of potential risk to health from fluoridation. Had those studies been considered, it would have been unconscionable for NHMRC to conclude no risk to human health from fluoride and fluoridation.
Q 12: In view of the now readily-known potential risk from fluoride consumption under fluoridation, in many respects ignored by NHMRC, what action has or will WA Health take to independently assess the potential health risks from fluoride consumption under fluoridation?
Q 13: In view of the now readily-knowable potential risks from fluoride consumption under fluoridation, on what grounds can WA Health guarantee that fluoridated water is safe for all sectors of the population and is fit for purpose?
Q 14: To where or on whom in the Commonwealth does the liability fall should fluoridated water be found not to be fit for purpose or safe to consume for everyone for a lifetime? Does the liability fall to NHMRC for promoting fluoridation since 1953 as safe for all, despite never having funded any projects to investigate the safety or otherwise, or does the liability fall to WA Health and yourselves for not conducting any due diligence, risk assessment or safety studies, or to the CEO and Board of the water supplier?
Q 15: Do you agree it is reasonable for consumers to seek legal assurance of fluoridation safety, and a means to compensation in the event of harm from fluoridation? If not why not?
Q 16: Due to their fluoride sensitivity, or to bodily dysfunction such as of kidney or thyroid etc., some people already find themselves adversely affected by exposure to fluoridated water. To whom should those people apply for compensation for the cost of needing to install whole-of-house water filtration to protect themselves from the experienced adverse effects of state-imposed community-wide fluoridation?
Neurodevelopmental toxicity
There is a rapidly growing body of published scientific evidence associating fluoride exposure with damage to the developing brain of the fetus, infant and child.[4]
The ground-breaking Grandjean study, published in 2021 in the journal Risk Analysis, employed the US EPA’s preferred Benchmark Dose Analysis method (BMD), and confirmed that even very low fluoride exposure of the mother during pregnancy impairs brain development in the fetus. The study concluded that fluoride consumption may be causing more damage to our population than lead, mercury, or arsenic?[5]
Grandjean 2021 reports that maternal urine-fluoride concentration of 0.2 mgF/L, was associated with a 1-point reduction in IQ of the child. That fluoride concentration in urine equates to around only one- quarter what can be expected from fluoridation under WA regulations.
By extrapolation from Grandjean’s findings, WA Health and Aqwest can be expected to be causing through fluoridation a lowering of around 5 IQ points on average per child, thereby shifting the intelligence bell curve leftwards, toward significantly fewer geniuses and significantly more mentally challenged children. We are confident you understand the bell curve and specifically the economic consequences of such a reduction in IQ across a whole population, but this short video[6] will help explain the ramifications clearly. Then please seriously consider the next question:
Q 17: In light of the Bell Curve and the effect of fluoridation over a whole population, do you consider the lowering of 5 IQ points amongst Bunbury’s population to be significant to continue defending fluoridation?
The US National Toxicology Program (NTP) is in the process of an ongoing systematic review of the effects of fluoride exposure.[7] Their most recent report, at this stage a 2019 pre-print monograph, identified 149 relevant human fluoride peer-reviewed studies on that topic.
NTP identified 27 of these studies as being of higher quality, and therefore worthy of closer analysis.
Granted, this monograph is not yet peer-reviewed and has not been adopted as NTP policy – the final NTP report is due in the second half of 2022. However, the final report is not expected to change in any great extent, which makes their preliminary finding worthy of discussion.
The 2019 NTP monograph reports that “fluoride is presumed to be a cognitive neurodevelopmental hazard to humans” (page 8), which is the strongest possible conclusion of risk based on epidemiological studies. One could wait until the final NTP report comes out confirming that conclusion.
However, what will not change in the final report is that of 27 studies identified by NTP as being of higher-quality, and 25 of them found a statistically significant adverse neurological effect from fluoride consumption. (Two found no effect, and none found any beneficial effect).[8]
That is not a wholly unexpected finding, as it is well known that growing bodies are very susceptible to chemical disruption because of the rate of growth and the permeability of the immature blood-brain barrier.
Despite the weight of evidence, NTP nevertheless decided to further clarify the findings regarding an ‘inconsistency’ in the degree of adverse effect between fluoride exposure at lower and higher levels. We can expect the final NTP review to clarify that inconsistency. But there is no evident reason to expect a different direction in the final findings, especially as there is an explanatory mechanism.
Q 18: Would the findings of Grandjean 2019 and 2021, plus the other 25 higher-quality studies reporting potential neurological damage from fluoridation, be enough to make you question the presumed safety of fluoridation? If not, how many such studies would be needed to make you doubt the claims of unconditional fluoridation safety and institute health warnings?
One of the studies considered by the NTP review, Green 2019, is a U.S. government-funded study linking exposure to 0.7 mgF/L fluoridated water during pregnancy to lowered IQ in the child. It was published in the highly reputable JAMA Pediatrics.
The Green study does not help determine the safe levels of fluoride in drinking water, but conversely it does offer highly reliable evidence that fluoride is not safe for the developing brain, even at a level of 0.7 mgF/L – which is lower than the 0.8mg/L ideal concentration stipulated by WA Health and 30% lower than the maximum 1 mgF/L.
Following here is a link to a podcast issued by the Editors of JAMA, discussing their surprise at the findings of the Green 2019 study, and the extent of scrutiny it was subject to before the decision to publish. We urge you to listen to these invaluable recordings here. A detailed response to the criticisms of the Green 2019 study is available here.
In order to determine the ‘safe’ level of fluoride, one must first assess a dose-response by examining many related studies, and determine the lowest level of exposure where there appear to be ‘no observable adverse effects level’ (NOAEL). The NOAEL for fluoridation in terms of adverse effects on the growing fetus appears to be less than 0.7 mgF/L, and very much less than the WA fluoridation level of 1 mgF/L.
Moreover, once the NOAEL is established one cannot determine toxicological ‘safety’ without first applying a certain dilution to the NOAEL, in order to account for the natural variability in the human population. The most common NOAEL for that purpose is ten-fold. That means that if the NOAEL for fluoridation was determined to be 0.7 mgF/L, the safe level could be 1/10 (or 10%) of that, namely 0.07 mgF/L.
Q 19: There is now strong evidence associating fluoride consumption with adverse neurodevelopmental effects in the fetus at levels of around 0.7 mgF/L, which is itself lower than applies to fluoridation in Western Australia and is expected for Bunbury – even before allowing for a safety margin. With that information in mind, do you still stand by the claim that fluoridation at 0.6 to 1 mgF/L (and probably around 0.8mg/L for Bunbury) is unconditionally safe for everyone?
Q 20: Are you prepared to give your personal assurance and guarantee that fluoridation at 0.8 mgF/L is safe for every person in Bunbury? If not, why not?
Q 21: Will you act to ensure that warnings are issued to inform expectant mothers not to consume fluoridated water, and to inform parents not to reconstitute baby formula using fluoridated water? If not, why not?
Biological toxicity
The findings to date from the NTP review are not the only reliable data available on fluoridation risk. The US National Research Council’s Fluoride in Drinking Water: A Scientific Review of EPA’s Standards (2006) is a three-year multi-disciplinary assessment of published studies investigating the effect of fluoride consumption on human biology.[9] The NRC 2006 report found that the US assumed 4 mgF/L safe level of fluoride in water is not safe and should be lowered.
The report identified risks to various organs, including: bone; tooth; brain; endocrinal system; thyroid; pineal gland; insulin secretion; immune system; gastrointestinal system, and kidney, as well as exacerbation of the effects of iodine deficiency. In many instances, those risks appeared in association with fluoride consumption much lower than a water concentration of 4 mgF/L, and even lower than 1 mgF/L, down to 0.2 mgF/L in the case of iodine deficient individuals.
The NRC report, combined with the studies being analysed by the NTP review, offer a treasure-trove of existing studies upon which to conduct a dose-response analysis, to ascertain a reliable NOAEL for fluoride consumption.
As fluoridation is forced on basically the entire community, and as the emerging evidence is strongly suggestive that fluoride consumption is not safe for all the population, fluoridating authorities such as yourselves would appear beholden, under your legal duty of care, not to continue fluoridating without properly assessing fluoride toxicity and applying an appropriate safety factor.
Q 22: Are you still confident of the safety of fluoridation? If so, please will you provide the published evidence upon which you rely for your conclusion, and which of course must be of higher quality than that provided by the 2006 NRC report and the 2019 NTP review collectively?
Upper levels of intake for infants
We are very concerned about the apparently careless approach being adopted regarding fluoridation and infants. It seems critical first to recognise that human milk typically contains very little fluoride (typically under 0.005 mgF/litre), meaning that infants have evolved consuming very little fluoride, and there is no normal biological function known to require the involvement of fluoride. All attempts to demonstrate a normal biological purpose for fluoride have failed.
That fact has long been recognised, and historically the recommended upper limit for fluoride consumption by infants has been either zero or very low. We will willingly provide a host of historical fluoridation reports to confirm.
Infants who are breastfed are not so much at risk. But infants who are bottle-fed are at distinct risk from both the fluoride in formula and the make-up water. In 2006, the American Dental Association recognised the problem and publicly warned parents saying, “If using a product that needs to be reconstituted, parents and caregivers should consider using water that has no or low levels of fluoride.” Similar statements and warnings appeared in Australia, but soon disappeared.
Contrary to historic wisdom, and despite a growing body of evidence associating fluoride ingestion with damage to the developing brain, in November 2016 NHMRC substantially INCREASED its recommended Upper Level of Intake for infants and children up to 8 years of age, as shown in the following table.
Australia’s recommended upper fluoride intake limits for infants and children are now significantly higher than or double the upper limits used in the United States and elsewhere.
The “Expert Working Group” (EWG) within NHMRC, who reviewed and changed these Upper Levels in 2016, admitted that, based on the original Upper Levels determined by the US Institute of Medicine in 1997, most Australian infants would exceed those consumption limits.
In particular, the Working Group recognised that bottle-fed babies fed using fluoridated make-up would likely exceed the Upper Limits.
Alarmingly, rather than reducing the limits and taking appropriate steps to warn parents of the possible risks and need to reduce fluoride consumption, the Working Group simply doubled the upper levels without special notice to the community. Such action seems to be an egregious assault on human health and safety and must be explained.
Q 23: All efforts by others to secure an explanation from NHMRC as to the justification for doubling the allowable upper intake limit for infants and children have failed. Do you personally feel that this doubling of upper limits for infants and children is justified? And do you still support fluoridation despite the known risk to bottle-fed infants if fed with baby formula reconstituted with fluoridated water? If so, why?
Damage to the bones
The potential for adverse effects of fluoride on our skeletal system was acknowledged nearly 90 years ago, and since then multiple studies have confirmed that potential.[10]
NHMRC’s 1991 fluoridation report, The Effectiveness of Water Fluoridation, appropriately recommended a precautionary approach. Namely that measurements of fluoride levels in bone to be collected at specific autopsies, so as to monitor fluoride accumulation if any, and possible damage being done from fluoride ingestion over time. (See Attachment 1 for the recommendation}. That action was deemed especially important for certain population sectors, such as high-volume water consumers, or whose renal function may be impaired. Thirty years later, despite the original strong recommendation, and despite continuing emerging evidence of fluoride’s damage to bones, no studies of this nature have been conducted by NHMRC.
New studies regularly emerge concerning the association between fluoride ingestion and bone health. Most recently, a Swedish study, Helte et al (2021)[11] reported at least 50 percent higher rates of hip bone fractures in post-menopausal women who consumed drinking water containing up to 1 mg/L of fluoride.
Helte 2021 concerns a large, high-quality, longitudinal study with a cohort of in excess of 4,000 older Swedish women and extended for 13 years from 2004 to 2017. The largest source of exposure was from naturally occurring fluoride in drinking water, at concentrations at or below 1 mg/L, and therefore within the range of Australia’s fluoride concentration under water fluoridation. Their total exposures also fell within the same range as women living in fluoridated parts of Australia.
The Helte finding of more than 50% higher rates of hip bone fracture – in conditions basically mirroring WA levels of fluoridation – should be cause for grave concern.
Q 24: With decades of substantial scientific evidence demonstrating fluoride’s damage to our bones over time, do you accept or condone NHMRC’s failure to implement its own relevant recommendations to monitor the bone-fluoride relationship?
Q 25: If yes, please explain why you think bone health should be considered an acceptable cost in exchange for the mere possibility of marginal (if any) improved dental health in children, the benefit of which has never been demonstrated to last into adulthood?
Bioaccumulation
NHMRC steadfastly declines to acknowledge that, like lead, ingested fluoride is only partly excreted, and builds up and accumulates in the body. Please see this article.
There is, however, strong evidence that fluoride does accumulate. References include:
European Food Safety (EFSA) Panel on Dietetic Products, Nutrition and Allergies. Scientific opinion on Dietary Reference Values for fluoride. 2013.
“Absorbed fluoride which is not deposited in calcified tissue is mainly excreted via the kidney (around 60% in adults, 45% in children) (Villa et al., 2010). The percentage of absorbed fluoride excreted via the kidney in infants and young children can be as low as 10-20 % because of a higher capacity of bone to accumulate fluoride.” (Section 2.3.5 on Elimination (page 13)
National Research Council. Fluoride in Drinking Water: A Scientific Review of EPA’s Standards. Washington, DC: The National Academies Press. 2006.
“Fluoride is readily incorporated into the crystalline structure of bone and will accumulate over time.” (p 4)
“The models estimated that bone fluoride concentrations resulting from lifetime exposure to fluoride in drinking water at 2 mg/L (4,000 to 5,000 mg/kg ash) or 4 mg/L (10,000 to 12,000 mg/kg ash) fall within or exceed the ranges historically associated with stage Il and stage III skeletal fluorosis (4,300 to 9,200 mg/kg ash and 4,200 to 12,700 mg/kg ash, respectively).” (p 5)
“Chronic dosing leads to accumulation in bone and plasma” (p 76)
“Bone fluoride concentrations increase with both magnitude and length of exposure.” (p 82)
“Hence, it is reasonable that 99% of the fluoride in humans resides in bone and the whole body half-life, once in bone, is approximately 20 years (see Chapter 3 for more discussion of pharmacokinetic models).” (p 108)
Scientific Committee on Health and Environmental Risks (SCHER). Opinion on critical review of any new evidence on the hazard profile, health effects, and human exposure to fluoride and the fluoridating agents of drinking water. May 2011.
“Concerns regarding the potential carcinogenic effect of fluoride have been focused on bone cancer due to the known accumulation of fluoride in bones. Osteosarcoma is a rare form of cancer making it difficult to analyse risk factors using epidemiology.” (p 16)
Whitford GM (1996). The metabolism and toxicity of fluoride. Monograph Oral Science. 1996.
“The quantitatively important fates of absorbed fluoride are uptake by calcified tissues and excretion in the urine. Roughly 50% of an absorbed amount will be excreted in the urine during the following 24hrs. while most of the remainder will become associated with calcified tissue. These fractions, however, can vary widely depending on several variables as will be discussed later.” (p 1)
“The peak level usually occurs during the first hour after ingestion. After the bulk of the dose has been absorbed, the plasma levels show a rapid decline due to the continuing uptake by bone and urinary excretion.” (p 3)
Fluoride accumulates in bodies at different rates in different people and at different times, based on bodily condition and rates of ingestion. The phenomenon has a long research history.
Fluoride accumulation is biologically significant because of the implications for physiological dysfunction in consequence. Those known to be most susceptible to fluoride accumulation include: the young, the elderly, diabetics, people with impaired kidney function, those with pre-diabetic or pre-renal-function impairment, those with poor nutritional status or who suffer from malnutrition (e.g. deficient in iodine, magnesium, vitamin C, vitamin D), those with heightened sensitivity to fluoride, and high level fluoridated water consumers, such as sportspeople, outdoor labourers and the heat affected.
Q 26: Does it concern you that NHMRC appears not to recognise fluoride accumulates in the body, thereby causing various bodily dysfunctions?
Q 27: Does it concern you how important bodily accumulation must be over a lifetime consumption of fluoride from fluoridation, and therefore how importantly misleading and incomplete NHMRC’s fluoridation health safety advice must be because NHMRC ignores that factor?
Dental issues – decay reduction
Fluoridation is endorsed, promoted and compelled on the promise that it helps reduce tooth decay, especially for lower socio-economic groups.
However, the claim of dental benefit now fails on several fronts, based on the latest or emergent evidence.
Cochrane review 2015 and other dental studies
The Cochrane Review 2015 is a meta-analysis of relevant fluoridation dental studies undertaken globally since the advent of fluoridation many decades ago. It is generally regarded as being of high quality and reliable and representing the best available evidence of the status of fluoridation regarding its dental effects.
Although the Cochrane Review is often cited as supporting fluoridation, an actual reading of the review shows otherwise.
In its Main and Key Findings, Cochrane 2015 reports that:
- Decay reduction from fluoridation appears to be in the order of 1-2 cavities per child on average, but the quality of evidence is low and the few available fair-quality studies are old, being conducted before wide-spread tooth brushing and use of toothpaste;
- There is no reliable evidence of any dental benefit into adulthood;
- There is no reliable evidence of any benefit to lower socio-economic groups, and
- Drinking fluoridated water is associated with damage to teeth in the form of dental fluorosis, and being of more than merely cosmetic concern in around 10% of children.
Attachment 5 contains the first six pages direct from the Cochrane Review, including its Main and Key findings, accompanied by some relevant commentary by Ms Lisa Intemann (Port Macquarie-Hastings Councilor).
Attachment 6 provides a wide range of other sources of fluoridation dental evidence from large scale studies, which collectively report little difference in tooth decay rates between fluoridated and non-fluoridated regions.
All the studies have weaknesses, deriving from their essentially epidemiological nature, and inability to account for various confounding factors. But the same may be said of every dental study purporting to demonstrate dental benefit from fluoridation. However, the weight of evidence especially from the Cochrane Review 2015 but also many other studies and statistics, now falls clearly on the side indicating minimal to no dental benefit from fluoridation.
Q 28: Would you continue to support forced fluoridation if it was shown to you by weight of evidence that there is no demonstrable correlation between water fluoridation and reduced dental decay across life stages? If yes, could you please explain why?
Q 29: Taking into account the studies and information provided here, regarding the lack of significant proven dental benefit from fluoridation, could you please advise on what evidential and/or explanatory basis WA Health could justifiably continue to force lifelong fluoridation on entire communities?
Alternatives
Sugar consumption without accompanying oral hygiene is more likely the predominant cause of dental decay. The vast majority of countries do not fluoridate, but manage oral care in a variety of other ways. Scotland, for instance, has had remarkable success with its early school tooth brushing and oral hygiene program: Child Smiles — Caring for Smiles program.
There are other ways besides fluoridation to ensure good oral health, especially as it is now well recognised that if fluoride has a beneficial effect on teeth then the mechanism for that effect is fluoride applied topically, not systemically ingested complete with all the adverse risks to health that accompany fluoride ingestion.
Q 30: Would you support a national dental insurance program for Australia, like dental Medicare?
Thank you!
Attachments
Attachment 1: NHMRC needs safety data
Attachment 2: studies stopped – NHMRC to NSW Health
Attachment 3: never funded studies – NHMRC to PMH
Attachment 4: excluded studies – NHMRC 2006 and 2017
Attachment 5: Cochrane 2015 – opening with commentary
Attachment 6: large-scale fluoridation dental studies
References
[1] Sabine Guth, et al, “Toxicity of fluoride: critical evaluation of evidence for human developmental neurotoxicity in epidemiological studies, animal experiments and in vitro analyses.” Published online 2020 May 8. doi: 10.1007/s00204-020-02725-2. Full study available here.
[2] Johnston N, and Scott A; “Principles of fluoride toxicity and the cellular response: a review. Published online 2020 Mar 9. doi: 10.1007/s00204-020-02687-5. Full study available here.
[3] Barsky C, Landes F. Hydrogen fluoride. In: Viccellio P, ed. Emergency Toxicology. 2nd edn. Philadelphia: Lippincott-Raven, 1998:325–34. 13. || Brush DE, Aaron CK. Hydrogen fluoride and ammonium fluorides. In: Dart RC, ed. Medical Toxicology. 3rd edn. Philadelphia: Lippincott Williams & Wilkins; 2003:1352–7. 14. || Mark SU. Hydrofluoric acid and fluorides. In: Goldfrank LR, Flomenbaum M, Hoffman RJ, Howland M-A, Lewin NA, Nelson LS, eds. Goldfrank’s Toxocologic Emergencies. 8th edn. USA: McGraw-Hill Companies; 2002:1417–22.
[4] Grandjean P. “Developmental fluoride neurotoxicity: an updated review”; published 19 December 2019 in Environmental Health. https://ehjournal.biomedcentral.com/articles/10.1186/s12940-019-0551-x#citeas
[5] Grandjean P. et al “A Benchmark Dose Analysis for Maternal Pregnancy Urine-Fluoride and IQ in Children”; Published 8 June 2021 in Risk Analysis. https://pubmed.ncbi.nlm.nih.gov/34101876/
[6] The impact of fluoride on the developing brain; published Oct 7 2020: https://youtu.be/hI4kpvW760M
[7] NTP 2019. “Draft NTP monograph on the systematic review of fluoride exposure and neurodevelopmental and cognitive health effects.” https://www.asdwa.org/wp-content/uploads/2019/10/draft fluoride monograph 20190906 5081.pdf
[8] The 25 studies are:
- 11 studies at or below water concentration 0.7 mgF/L: Barberio 2017, Bashash 2017, Bashash 2018, Ding 2011, Green 2019, Riddell 2019, Sudhir 2009, Till 2020, Yu 2018, Zhang 2015, Zhou 2019;
- 4 studies at or below water concentration 1.5 mgF/L: Cui 2018, Valdez Jimenez 2017, Wang 2012, Wang 2020; and
- 10 studies above water concentration 1.5 mgF/L: Choi 2015, Li 2004 (translated in Li 2008), Rocha Amador 2007, Rocha Amador 2009, Saxena 2012, Seraj 2012, Trivedi 2012, Wang 2020, Xiang 2003, Xiang 2011.
[9] National Research Council. 2006. Fluoride in Drinking Water: A Scientific Review of EPA’s Standards. Washington, DC: The National Academies Press
https://www.nap.edu/catalog/11571/fluoride-in-drinking-water-a-scientific-review-of-epas-standards
[10] “Fluoride in water and bone fracture”, Michael Connett — Fluoride Alert 2012; https://fluoridealert.org/studies/bone12/ and “The relationship between, bone density and bone strength”, Michael Connett — Fluoride Alert April 2012; https://fluoridealert.org/studies/bone04/
[11] Helte E, et al “Fluoride in Drinking Water, Diet, and Urine in Relation to Bone Mineral Density and Fracture Incidence in Postmenopausal Women,” published 6 April 2021, in Environmental Health perspectives. https://ehp.niehs.nih.gov/doi/10.1289/EHP7404