Assessment of Forum on Fluoridation 2002 (Ireland)

[Roger.D.Masters@Dartmouth.EDU (Roger D. Masters) (by way of Keith Whyte <keith@tbmc.ie>)]

Assessment of Forum on Fluoridation 2002 (Ireland)
by Roger D. Masters (Research Professor and President, Foundation for Neuroscience and Society, Department of Government, Dartmouth College, Hanover, NH 03755, USA)


Recommendations

Recommendation 1, p. 15: There is no reference to research on the different effects of topical application of a fluoride compound and ingestion of fluorides (notably Dr. Hardy Limeback’s analysis showing that swallowing fluoride has little effect on dental caries;  benefits come from topical contact with tooth surface).  See comment on p. 54 below.

Recommendation 2, p. 16:  Despite the reference to the need for “great care and suitable safety precautions among those handling” hydrofluosilicic acid (p. 29), there is no reference to the dangers of these compounds to workers in water plants.   Indeed, for this reason water plant managers in Fort Collins, CO (where HFSA is now added to water) indicated to the City Manager that they would welcome ending the process of fluoridating with this compound.

Recommendation 5, p. 18: In the relevant text of the report (p. 133), there is no reference to the possible chemical effects of boiling water treated with HFSA compared to boiling the same water if not treated.

Recommendation 6, p. 19: Here as elsewhere in the recommendations, the text refers to “fluoride” not HSFA.  THERE IS NO REFERENCE TO THE ABSENCE OF ANY TESTING OF HFSA FOR SAFETY (AS ADMITTED BY THE U.S. ENVIRONMENTAL PROTECTION AGENCY).   Since sodium fluoride has been tested, this view assumes the chemical equivalence of all chemicals used for “fluoridation”  (especially since the presumed beneficial effects of water fluoridation are cited without reference to the specific chemicals used).  The assumption of chemical equivalence is empirically false and extremely dangerous, as demonstrated by the action of the National Toxicology Program in the U.S., which recently nominated silicofluorides (hydrofluosilicic acid and sodium silicofluoride) for toxicological study.  (see below, comment on pages 29-30).

Body of Report

Chapter 1  Effect of HSFA in Water

p.29: Chemical contaminants in fluoride additives.   The analysis here is generally reasonable (with the possible exception of radioactive elements, which some critics have cited).  The essential point is, as noted, the actual level of toxic contaminants in the finished water supply.  The only empirical evidence of monitoring these toxins which I have seen is from Fort Collins. Colorado, where the levels of toxins after HSFA dilution were generally either below detection or well below U.S. Maximum Contaminant Limit.  The principal exception is aluminum, but this may be a problem due to the risk of the formation of Aluminum fluoride, a compound that has been suspected of playing a role in the formation of the plaques in Alzheimer’s Disease.    This point, however, is primarily relevant to Recommendation 6 on research needs.

p. 30, multiplicity of toxins now measured in water.  The point in the text is basically sound though it fails to emphasize chemical interactions among elements and compounds either in the cooking process or after water ingestion.    Again, however, this point is primarily relevant to Recommendation 6.

pp. 29-30: This entire section ignores the central issue: incomplete dissociation of HFSA after injection and its biological effects.  : Sodium fluoride dissociates into its constituents (sodium and fluoride) and, in 1950 when silicofluorides were first being introduced, McClure took the position that it could be “assumed” that HFSA would also dissociate completely.    Experimental evidence in Germany by the chemists Westendorf (1975) and Rastädter (1978) contradicted this assumption.  Not only did they find that not all of the fluoride in the compound failed to be released as free fluoride, but there appeared to be “residual species” (Westendorf’s phrase) that, as Rastädter found, were in the general class of siloxanes.that could form low molecular weight fluorine-bearing polysilicic acid oligomers. 

That such residual compounds are bioactive was demonstrated by Westendorf’s finding that silicofluoride treated water inhibits cholinesterase enzymes in vivo.   Until recently, other biological measures have been limited because silicofluorides have never been properly tested for safety, but some studies have shown differences in the amounts of fluoride excreted from water treated with either sodium fluoride or a silicofluoride (HFSA or sodium silicofluoride).

Our research over the last four years has focused on two consequences of the use of silicofluorides in American public water supplies.  First, using geographic data, we have found that where these chemicals are used, uptake of lead from environmental sources (such as lead paint in old housing) is significantly higher than in communities using sodium fluoride, naturally fluoridated water or non-fluoridated water.  Second, because lead is a neurotoxin that lowers dopamine function and behavioral inhibition, we also studied the epidemiology of relevant behaviors.  Controlling for as many as 12 risk factors, silicofluoride usage makes a statistically significant additional contribution to rates of violent crime (measuring rates in all U.S. counties for the years 1985 and 1991).  Data for U.S. rates of murder, rape, and other violent crimes by city in 2000 and 2001 are consistent with this finding.  Other behaviors that are more frequent where silicofluorides are in use include an NIJ study of substance use by violent offenders at time of arrest and, where available, rates of learning disabilities.

These findings have been published since 1999 in peer reviewed publications and presented to meetings of professional associations in the U.S. and Canada.    The failure to cite any of the research on differences between HFSA (or silicofluorides generally) and other means of fluoridating public water supplies is scientifically and ethically astounding.  

Ch. 2: Consultation
        p. 34: scientific methods of consultation.  The fact that public opinion polling (“consultation”) was “not a scientifically designed and controlled survey” may well be reasonable given the limited knowledge of biochemistry, health and behavior in the general public.  What is difficult to understand, however, is the concern for scientific method on this point whereas the methodology of surveying published literature on the chemical properties and biological risks of HFSA would not meet the standards of a rigorous undergraduate course in science and public policy.    Not only is there no reference on pp. 29-30 to the literature mentioned in the comments on those pages, but at no times were the authors contacted in the process described on p. 22.    Since use of a computer search engine (e.g. www.google.com) would have identified us, there can be no conceivable scientific excuse for this failure.

Ch. 3. Dental Decay
p. 47: In the U.S. today, there is evidence of the absence of a difference in rates of dental caries in communities that are or are not fluoridated.  In some cases, moreover, dental health is actually worse where water is fluoridated.    This is particularly striking among Blacks in Harlem.   (Increased uptake of lead may, incidentally, be a factor in this outcome).

P 54: fluoride rinsing: Here, there is no reference to the scientific studies comparing the effects of topical contact of fluoride on tooth surfaces with ingesting fluoride or fluoride compounds.   Research by Dr.Hardy Limeback, a distinguished Canadian dentist, has shown that only topical contact is effective in lowering caries.  While fluoridating water will produce some contact between fluoride and the tooth surface, either fluoride rinsing or brushing teeth with fluoridated toothpaste is obviously much more effective for this purpose.   Indeed, there seem to be few controlled experiments of the relative effects of frequent tooth-brushing with non-fluoridated and fluoridated toothpaste.  

        The underlying issues here are twofold.  FIRST, the dangers of injecting an untested fluoride compound (HFSA) in public water supplies are more evident when the potential benefits are doubtful whereas the statistically significant evidence of harm has never been refuted with data analysis or experimental study.  SECOND, one wonders about the costs and benefits of public health education and increasing individual responsibility for dental health.  Whatever the monetary costs, the benefits to consumers would be enormous.  Some critics have wondered whether the dental profession has a contrary interest in this matter.

Ch. 5: Provision of Oral Health Care Services
pp. 61-62: Dental Treatment Service Scheme (DTSS) and Dental Treatment Benefit Scheme: these “schemes” provide more dental care for poor older citizens, and hence greater income for dentists since government pays part of cost.  
        If HSFA increases uptake of lead which increases tooth decay, theresult might be a net benefit for dentists.
        Why should this hypothesis be considered?  In 1998, average rate of DMFT among 12 year old children in Ireland (1.10) was lower than in all European countries except Netherlands (0.6), Sweden (1.00), Denmark (1.01), and was the same as in Finland (1.10).   At the same time, the percentage of gross domestic product (% gdp) expended on dental health in Ireland (0.50%) is already among the highest in Europe: only countries that are higher are Denmark (0.56%) and Germany (0.90%).   In contrast, overall expenditures on health as % gdp is relatively low in Ireland (6.8%), which is the same as Italy and Luxemberg; only countries with lower % gdp spent on health are Denmark (6.5%) and England (5.8%).  By way of contrast, the highest health expenses in Europe are in Germany (10.4%). 

Ch. 6:  History
p. 67: Puzzling passage: “In 1942, Dean demonstrated…. This was followed by extensive epidemiological surveys .. during the late 1930’s…”     How could events in the late 1930’s FOLLOW an event in 1942?  Is there a typographical error?  Other sloppiness?

p. 68: Decline of caries throughout the U.S. said to be due to the “halo effect” of fluoridation (e.g., effects in food).   Attributing the lack of persisting difference between fluoridated and non-fluoridated communities to water from fluoridated food is highly dubious without data.  A more obvious hypothesis would be fluoridated toothpaste especially since the primary role of fluoride in saliva and topical contact (p. 104).

Ch. 7: Fluoridation Status Worldwide:
        Fluoridated salt  seems to be used in countries with lower levels of DMFT.

Ch. 8:  Public Water Supplies in Ireland
        p. 87: the conclusion of this chapter is that “From a consideration of the above data it is clear that it would be technically impossible (if not incredibly expensive) to facilitate local authority implementation/non-implementation of fluoridation policy at a local level.”   On the surface, is this contradicted by the experience in the U.S.?

Ch. 9: European monitoring of fluoridation
        pp. 90-92: discussion of level of chemicals in water limited to amount of fluoride added (level 1.0 mg/L for any added fluoride compound except for 1.5 mg/L if naturally fluoridated).  Although in Ireland fluoridation uses HFSA rather than other compounds, only 2 paragraphs concern this compound’s levels and contaminants.  There is no mention of incomplete dissociation of HFSA, the character of “residual species” found by Westendorf and Rastädter in German experiments, and no measure of effects such as acetylcholinesterase inhibition (Westendorf) or enhanced lead uptake from environmental exposure to lead (Masters & Coplan).

Ch. 10: Application of Fluoride  HFSA
p. 94: The description of the history of the shift from sodium fluoride to HFSA makes no mention of the absence of any tests or evidence of the safety of HFSA (e.g., the EPA admission that “they were unable to find any information on the effects of silicofluorides on health and behavior” in letter of Nov. 16, 2000 available on internet (

http://www.dartmouth.edu/~rmasters/ahabs/).

p. 95: There is an unusual limitation in the description of the source of HFSA and mode of delivery and storage as well as quality control at treatment plant.   Nothing is said on the procedures to protect safety of personnel (a topic explicitly included in U.S. manuals for plant personnel).

Ch. 11: Benefits and Risks
p. 100: benefits for tooth debay.  Table 11-4 on adult tooth decay shows lower differences between fluoridated and non-fluoridated communities than data on children in Tables 11-1 through 11-3, but none of these tables indicate potential covariates of other risk factors for poor dental health in fluoridated and non-fluoridated communities.  Compare remarks on p. 108 below.

p. 104: Mechanism of benefits from fluoride “almost exclusively, but not entirely, topical.”   This crucial point, which has been emphasized by Dr. Hardy Limeback of Canada, is simply never considered seriously in assessing the limited effectiveness of swallowing fluoridated water whenever a large number of children brush their teeth with fluoridated toothpaste.   In many other places in the report, ingestion is treated as if it is either as effective or more effective than topical contact.

pp.105-107:  The only risks discussed are “fluorosis and general health risks” (p. 105).  Despite the empirical evidence that HFSA is associated with enhanced uptake of lead from the environment and with behavioral dysfunctions linked to lead neurotoxicity (such as violent crime, substance abuse, and learning disabilities), there is no mention of these effects.  There is no justification for failure to refer to effects of HFSA that are prominently listed in a web-based search engine like “www.google.com”.   Given the enormous difference in social costs between higher rates of violent crime (never mentioned) and higher rates of dental fluorosis (which are discussed extensively on pp. 105-107), it is hard to explain this coverage.   Is it incompetence or an intentional cover-up  or is there another reason?

p. 108: General health effects.  The text asserts that the value of studies of “human populations is limited due to lack of quantitative information on concentrations to which people are exposed.”   This limitation is of course also present for human data on the benefits of fluoridation.  Moreover, the text asserts that animal studies are needed, but there have been no animal tests of the safety of HFSA.   Hence the criticism of data on “health effects”  ignores the fact that our publications on lead uptake and behavior include more multivariate analyses than the Fluoride report’s analysis of benefits, which are subject to all the criticisms in this chapter.  In other words, this report uses totally different methodological standards for benefits (any numbers are acceptable if they show benefits) and for risks (analyses using similar methods are inadequate).    Since studies of risks associated with HFSA include precisely the methods recommended, this is yet another unscientific passage in the Fluoride Forum’s report.

pp. 108-110: discussion merely refers to fluoride, without consideration of water treated with HFSA or sodium silicofluoride.   See especially the comment on Westendorf’s evidence of inhibition of cholinesterase (below, p. 115).

p. 111: Discussion of acute toxicity makes no reference to hydrogen fluoride, aluminum fluoride, and other highly toxic compounds that may form under some circumstances.

p. 113: Discussion of chronic toxicity once again ignores the absence of data on effects of chronic exposure to water treated with HFSA, even though this lack of evidence has been admitted by the U.S. Environmental Protection Agency and National Toxicology Program..

p. 115: The assertion that there is no evidence of effects of fluoridation on enzymes ignores Westendorf’s finding that hexafluorosilicates inhibit cholinesterases.   Both acetylcholinesterase and butyrlcholinesterase play important roles in many organic functions.   Given the availability of an English translation of this research  this is once again a seriously incomplete review of science.

pp. 117, 120: once again, the report dismisses ecological data as being of limited value without realizing that this criticism applies to the data presented on benefits of water fluoridation.  Moreover, this puzzling duality of methodological rigor ignores the extensive multivariate tests used to confirm that the harmful effects of silicofluorides in the U.S. are not due entirely other risk factors.  For example, in the Masters-Coplan analysis of children’s blood lead levels in New York (published in Neurotoxicology in 2000) included logistic regression of odds-ratios of higher blood lead levels in silicofluoride treated versus non-silicofluoride treated communities when these communities are divided into those above and below average on seven different risk factors.  Since odds of higher children’s blood lead are significantly above 50;50 (odds ratio of 1.0) for all seven variables, and no similar assessment has been presented for the purported benefits of fluoridation, the discussion in this chapter lacks scientific rigor

Ch. 12: Controlling Dental Fluorosis
        This chapter is not relevant to a scientific analysis of the most serous risks of adding HFSA to a public water supply.
 
Ch. 13: Ethical and Legal Dimensions
        As written, this chapter ignores the most likely sources of harm.  Apart from the ethical questions that could be raised about such a discussion of ethics, the most relevant legal dimension is indicated in the comment on Appendix 7.

Ch.14: Monitoring use of Fluoride Modalities.
There is no adequate discussion of HFSA in this chapter.

Appendices

Appendices 1-5: Consultation
        These Appendices are not relevant to a scientific analysis of the most serous risks of adding HFSA to a public water supply.

Appendix 7: The Fluoridation Act, 1960, and Sepcimen Regulation, 1965.

p. 168, Section 6 (1-4):        Under this provision of the law, there is a  high priority for immediate action:  Independent researchers should conduct extensive and comprehensive epidemiological surveys, comparing fluoridated and non-fluoridated communities for potential harmful effects of HFSA.   The principal risks to study are rates and levels of uptake of lead or other heavy metals and toxins from environmental exposures.  In addition, there is an urgent need for epidemiological surveys of violent crime, substance abuse, learning disabilities, IQ, and other behavioral traits subject to harm from uptake of lead or other neurotoxins.  Since these harmful effects have been associated with HFSA use in the United States, continued use of HFSA in Ireland not to mention its expansion should be contingent on convincing demonstrations that none of these harmful effects occur.   To achieve objectivity in such assessments, those responsible should be scientists without commitments for or against the fluoridation of public water supplies.   In the case of findings that HFSA has no harmful effects in Ireland, an explanation of the differences between findings in the U.S. and Ireland also need to be explained.

Overall assessment of Forum on Fluoridation 2002

        The scientific and methodological flaws of the analysis of HFSA and its risks of harm are obvious throughout the text of Forum on Fluoridation 2002.  Research on the effects of this compound in the United States has led to the proposal of an immediate moratorium on its use pending testing that demonstrates without doubt the lack of harmful effects and explains contrary findings to date.  Absent a convincing explanation of the failure to conduct a minimal check of the internet (e.g.,www.google.com) or other means of checking the literature on harmful effects on HFSA, it is difficult to exclude the charges that have been leveled against the report as either an intentional cover-up or scientifically incompetent. 

SPAM: -------------------- Start SpamAssassin results ----------------------
SPAM: This mail is probably unsolicited commercial email, a.k.a. "SPAM".
SPAM: The original message has been tagged so you can recognise or block
SPAM: similar unwanted mail in future.
SPAM: 
SPAM: Talk to Keith to find out how. If this mail is not SPAM, please
SPAM: let Keith know, so he can tweak the rules to get it right next time.
SPAM: 
SPAM: Content analysis details:   (5.50 hits, 10 required)
SPAM: SEARCH_ENGINE_PROMO (2.9 points)  BODY: Discusses search engine listings
SPAM: HTML_FONT_FACE_ODD (-0.7 points) BODY: HTML font face is not a commonly used face
SPAM: BALANCE_FOR_LONG_20K (-0.1 points) BODY: Message text is over 20K in size
SPAM: HTML_FONT_COLOR_BLUE (0.8 points)  BODY: HTML font color is blue
SPAM: SPAM_PHRASE_00_01  (0.6 points)  BODY: Spam phrases score is 00 to 01 (low)
SPAM:                    [score: 0]
SPAM: MIME_LONG_LINE_QP  (2.0 points)  RAW: Quoted-printable line longer than 76 characters
SPAM: 
SPAM: -------------------- End of SpamAssassin results ---------------------