The Relevance Of The NRC Report To Fluoridation

FAN Bulletin #541

March 29, 2006

Dear All,

Some have questioned the relevance of the NRC Report to water fluoridation. This bulletin summarizes the NRC recommendations, the spin that some (especially the ADA) have put on their recommendations and the reasons why the NRC recommendations and their full report are very relevant to water fluoridation.
The NRC panel recommendations.  
 
The NRC recommended a lowering of the MCLG (maximum contaminant level goal) for fluoride in drinking water. The MCLG is the public health goal based on what the science tells us is safe for the population, including vulnerable subgroups, but it is not enforceable.  The MCL is the enforceable level, which is based as close as is technically and economically feasible to the MCLG.  Currently, the MCLG and the MCL are the same for fluoride: both are set at 4 ppm or 4 mg/liter.  The NRC committee said the MCLG is too high and has asked EPA to perform a risk assessment to determine what it should be.
The ADA spin.
A great deal of the commentary to date on the 450 page NRC report on fluoride’s toxicity has been based on a 4-page press handout and a 50 minute press conference. This, coupled with a self-serving press release from the ADA,  has led some to conclude that the NAS report has no relevance to water fluoridation. Nothing could be further from the truth.
The NRC report.
Those who read the whole report will discover that the findings are extremely relevant to water fluoridation. Here are some of the reasons:
 
1) The very small gap. The gap between the level at which fluoride is added to water, ostensibly to protect teeth (1 ppm), is already very close to the level at which the EPA requires fluoride to be removed (MCL = 4 ppm). The recommended lowering of MCLG should make this gap even smaller and thus relevant to water fluoridation at 1 ppm.
 
2) Dose cannot be controlled. This very small gap becomes even more significant when one recognizes that while engineers can usually control the level of fluoride added to water (although there have been accidents), they cannot control how much water people drink. Nor can they control the fluoride that people get from other sources.
 
3) Exposure analysis.  The NRC was tasked with finding out how much fluoride people are actually getting, based on the wide variations in water, food, and dental product intakes. Their exposure analysis (see Chapter 2) indicates that some people will exceed a “safe” level, even when drinking water at 1 ppm. See graphic at: http://www.fluoridealert.org/health/epa/nrc/intake1ppm.html>.
 This “safe” level is derived from the 4 ppm standard, either expressed as a dose of 8 mg per day for an adult or expressed as a dosage of 0.114 mg/kg/day (milligrams per kilogram of bodyweight per day). The latter biometric is necessary to take into account infants, children and others with lower bodyweights. These people will require far less fluoride to exceed this “safe” limit (see FAN bulletin #440B).
4) The NRC recommends the EPA’s safe limit be lowered. If this limit is lowered then even more people - consuming water at 1 ppm and fluoride from other sources - will exceed a level deemed “safe”. Such a change then is very relevant to water fluoridation at 1 ppm
5) Effects at low exposures. In the body of their report the panel reviewed many animal and human studies where effects on a variety of tissues have been observed at relatively low exposures.  See FAN bulletin # 438 for an extensive list of quotes from the report, which illustrate some of these. Some of the effects were observed at lower water concentrations than 4 ppm, or lower doses than 8 mg per day or lower dosages than 0.114 mg/kg/day. These included increased uptake of aluminum in rats exposed to fluoride at 1 ppm; lowered IQ in Chinese studies at 2.5-4.0 ppm; increased hip fracture rates in the elderly at levels between 1 and 4 ppm and lowered thyroid function at levels as low as 0.01 mg/kg/day. With our inability to control dose all of these studies become relevant for water consumption at 1 ppm. Now we will consider two of these end points: bone fractures and thyroid function.
6) Bone fractures. Hip fractures in the elderly were observed a) in Finland at water levels at or greater than 1.5 ppm (Kurtio, 1999);  b) increasing in what appears a linear fashion between 1 ppm and 4.3 ppm in China (Li et al., 2001) and c) (bone fractures) increasing between 1.5 and 5.5 ppm in Mexico (Alarcon-Herrera et al., 2001). While the panel did not feel they had enough data to state at what level hip fractures would increase they did describe both the Kurtio and the Li studies as good studies. They write:

“Overall, the committee finds that the available epidemiologic data for assessing bone fracture risk in relation to fluoride exposure around 2 mg/L is suggestive but inadequate for drawing firm conclusions about the risk or safety of exposures at that concentration.  There is only one strong report to inform the evaluation, and, although that study (Kurttio et al. 1999) indicated an increased risk of fractures, it is not sufficient alone to base judgment of fracture risk for people exposed at 2 mg/L.  It should be considered, however, that the Li et al. (2001) and Alarcon-Herrera et al. (2001) studies reported fracture increases (although imprecise with wide confidence intervals) between 1 and 4 mg/L, giving support to a continuous exposure-effect gradient in this range.” (p 138)

When the EPA does a health risk assessment on this issue they will have to take these studies into account. Because of the uncertainties involved they will have to apply a suitable “uncertainty factor”, at which point the 1 ppm “barrier” is very vulnerable. What the NRC panel did was merely to point out that 4 ppm is not protective against bone fractures for a lifetime exposure. They did not indicate what level is protective against bone fractures for a lifetime exposure.
7) Thyroid function. Even more serious is the discussion the NRC provided on fluoride’s impacts on the thyroid and the brain. For the thyroid gland (chapter 8) the NRC authors write:
 

“In humans, effects on thyroid function were associated with fluoride exposure of 0.05 - 0.13 mg/kg/day when iodine intake was adequate and 0.01 - 0.03 mg/kg/day when iodine was inadequate.” (P. 218)

These exposures are up to 10 times lower than the dosage associated with the 4 ppm standard (0.114 mg/kg/day) and are exceeded by millions of American children and adults drinking water at 1 ppm. See: >
Thus, the fact that this NRC review did not recommend a safe level of fluoride lower than 1 ppm (which if heeded would have forced the end of water fluoridation) hangs on the slenderest of threads: namely, that there is a chance that these findings on thyroid function in the peer reviewed and published literature in Europe, Russia, and China may not apply to people in the US. However, the lack of research on these matters in the US should not leave us with any confidence in this situation. It should be a matter of grave concern that this research not been done here, even though the artificial fluoridation program has been going on now for 60 years and as early as the 1930’s researchers were writing about fluoride’s impact on the thyroid gland (DeEds 1940).
8) Huge data gaps. The NRC panel make many research recommendations (see FAN bulletin #439) which reveal huge data gaps in basic research on fluoride’s toxicity in the US. What they didn’t say, but we can, is that the US Public Health Service’s 56 year-old adherence to the water fluoridation program has hitherto limited meaningful research into fluoride’s health effects. Most of the research money has been siphoned off into dental research with little attention to other tissues. On the rare occasions other tissues are examined the clear intention is to find another benefit of fluoridation. For example, it is not a coincidence that some NIDR funded studies
Moreover, as the NRC panel’s research recommendations indicate, no significant efforts have been made in the US to track the levels of fluoride in urine, plasma or bones of the American people. Such basic baseline research is critical if one wishes to seriously explore whether there is a connection between fluoride exposure and hypothyroidism, neurological effects, arthritis or other serious end points afflicting millions of people. We have been flying blind on these matters. Hopefully, the NRC’s review will stimulate some serious research by independent scientists (not those chosen to support the interests of the fluoridation program) in the future. Sadly, it may be rather late for some.
9) Uncertainties. The NRC panel has strongly recommended that the US EPA conduct a health risk assessment in order to ascertain a new MCLG which is protective of the American people - and that includes vulnerable subsets not just the average person. Because the NRC report has shown that the foreign literature indicates very serious concerns and uncertainties, when the EPA does an updated health risk assessment on these endpoints, the uncertainties alone should force a margin of safety which will produce a new MCLG lower than 1 ppm.
Conclusion: On many fronts, this NRC report is very relevant to water fluoridation.
 Postscript: However, so much of this is written as if “science” ruled the world. It does not. Both industrial and political interests have a way of marginalizing scientific findings when it suits their purposes. Once again we can expect politics to take over.  We can anticipate that the EPA will be reluctant to do the health risk assessment recommended by the NRC panel and drag out the process as long as it can. The EPA probably will not want to offend the US PHS, which has a huge interest in keeping its policy of water fluoridation on track, nor will the EPA pesticide divison want to disappoint its corporate client Dow Agrosciences in its efforts to use sulfuryl fluoride as a fumigant on food. This is why it remains critically important that we get more involvement and oversight in this matter from the US Congress and orgnizations than can put pressure on Congress. Now that we have some important science on the table we have to fight politics with politics to see that that the health of the American people is properly protected.  The EPA must not be allowed to duck or drag its feet on this matter. Their mandate is to protect our health and the environment - it is not to run interference for the US Public Health Service or Dow.
The US Congress should also shine a spotlight on the CDC, which in 1999 claimed that fluoridation was one of the top 10 public health achievements of the twentieth century and based its claims for safety on the previous NRC review from 1993. This is what the CDC wrote in 1999, a position it has continued to re-iterate until 2005:

 Since 1950, opponents of water fluoridation have claimed it increased the risk for cancer, Down Syndrome, heart disease, osteoporosis and bone fracture, acquired immunodeficiency syndrome, low intelligence, Alzheimers disease, allergic reactions, and other health conditions (24).


The safety and effectiveness of water fluoridation have been re-evaluated frequently, and no credible evidence supports an association between fluoridation and any of these conditions (25). (reference 25 is the NRC, 1993 review)

Now that the NRC has changed its position on the adequacy of the MCLG of 4 ppm, and provided enormous amount of documentation and discussion backing up some of these listed concerns, what will the CDC now say about the safety of water fluoridation?
At the very least we would hope that the US Congress would insist that the same people who enthusiastically promote fluoridation at the CDC - who even go as far as making personal appearances in front o State legislatures to promote mandatory fluoridation - are not the same people who keep track of the health issues. This is clearly a conflict of interest and does not serve the American people very well.
This week Bassin’s research on osteosarcoma will be published. If she confirms her thesis findings that showed a relationship between the consumption of fluoridated water by young boys in their mid-childhood and this frequently fatal bone cancer we will be one step closer to the end of water fluoridation.
Paul Connett
PS I hope that readers will draw from these arguments material for letters to the editors of your local papers as well as your Congressional representatives. If you do so would you be kind enough to send us a copy so that we can share them with others.
For those who have the necessary equipment I will be on a 30 minute radio show tomorrow at 11:00 am EST. The show is Building Healthy Bodies, heard on www.homegrownradionj.com