Dear readers,
Today the U.S. Department of Health & Human Services (DHHS) published their recommendation for lowering the level of fluoride to 0.7 parts-per-million for all public drinking water that is artificially fluoridated. Their proposal appeared in the Federal Register and is available at
http://origin.www.gpo.gov/fdsys/pkg/FR-2011-01-13/html/2011-637.htm
Public comments on the recommendation can be submitted by email on or before February 14 toCWFcomments@cdc.gov
For those who want to sign-on to FAN's comments, we will provide that option once our submission is complete.
The basis of the DHHS recommendation to set the lower level is that children are being overexposed to fluoride (as seen in the rocketing rates of dental fluorosis) and that fluoridation is still necessary for reducing dental caries.
The rationale they use is very weak. Had FAN produced such argumentation we would be laughed at by CDC, EPA, FDA, ADA and everyone else!
According to the notice today, the new recommendation
replaces the one made in 1962, which set the "optimal level" for fluoride in drinking water at a range of 0.7 to 1.2 ppm. As this is the first change in the standard in nearly 50 years, the Secretary of the DHHS, Kathleen Sebelius, deserves kudos for doing so.
However, Secretary Sebelius has been taken for a ride if she has been convinced that the only harm that fluoride causes is dental fluorosis. She needs to seek independent advice on the dangers posed by fluoride to other tissues, and not rely on the CDC's Oral Health Division. It is well known that this CDC Division (with little expertise beyond teeth) have a conflict of interest in the matter: their jobs and reputation. She has to decide whether her job is protecting this outdated practice or protecting the health of Americans.
Simply reading the National Research Council of the National Academies 2006 fluoride report should convince Secretary Sebelius and independent advisors that fluoride causes more harm than dental fluorosis. The risks to other tissues make the attempt to secure miniscule benefits to teeth from swallowing fluoride via drinking water an absurd proposition.
According to a news report today, "... while the department has recommended the limit, nothing can be legally set as a standard unless it's approved by the EPA."
And that is correct. It is up to EPA's Office of Drinking Water to set a Maximum Contaminant Level Goal (MCLG) which is the level at which no known or reasonably anticipated health effects occur with a reasonable margin of safety adequate to protect everyone including vulnerable subsets of the population. The MCLG is science based and any purported benefit or economic burden must not interfere with EPA's assessment. The current MCLG is set at 4 ppm. This was based on the science EPA chose to use in 1985 and only included one adverse effect: crippling skeletal fluorosis.
The wisest approach that DHHS could have taken - and still can - was to end fluoridation as a precautionary approach for avoiding not only dental fluorosis but the many other adverse effects that are being related to fluoride exposure today.
FAN will include in its submission:
· 0.7 ppm is too high. It neither protects teeth from dental fluorosis, the stated reason for the lowering, nor does it protect the baby's developing brain, an issue not even mentioned in today's announcement.
· An infant who receives formula reconstituted with fluoridated tap water at this new level (0.7 ppm), will receive approximately
175 times more fluoride than a breast-fed infant. These infants are not being protected with this new level.
· In its announcement, DHHS made no mention of other adverse effects aside from dental fluorosis. The report published by the NRC in 2006 noted three adverse health effects that warranted the lowering of the current MCLG. DHHS chose to cite one and ignore the other two which are: bone fractures and the pre-clincical stage of crippling skeletal fluorosis, which manifests with symptoms identical to arthritis (stiffness of the joints and pain in the joints and bones).
· The current EPA revised health risk assessments which underpin DHHS' decision are designed not to eliminate severe dental fluorosis, but only to limit it to no more than 0.5% of the population. 1 in 200 children getting severe fluorosis is way too many, especially considering 2/3rds of the US population receives fluoridated water. So, even if severe dental fluorosis were truly the only adverse effect EPA and DHHS feel it necessary to protect against, they have not achieved a reasonable goal of a virtually 0% rate, even by lowering the recommended level to 0.7 ppm.
We encourage those of our supporters who have a good grasp of this issue to submit their comments explaining why DHHS should end fluoridation now. For others, FAN will be submitting a comprehensive response and at that point we will invite all our readers to add their support to FAN's analysis in an online submission to DHHS, to which you can add comments. We'll keep you posted.
Paul Connett, Director
Fluoride Action Network
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