No Reply From CDC’s Gerberding

FAN Bulletin #596

May 19, 2006

Dear All,
It only took the CDC six days to dismiss the findings of the 3-year, 450 page review by the NRC of fluoride’s toxicity, but the head of this same agency has failed - after six long weeks - to respond to my letter on this same matter.
In a statement it made on March 28 (see last item below), just six days after the 450 page NRC report was published, the CDC stated that:

 ”The findings of the NRC report are consistent with CDC’s assessment that water is safe and healthy at the levels used for water fluoridation (0.7 - 1.2 mg/L)… CDC’s recommendation remains the same - that community water fluoridation is safe and effective for preventing tooth decay. Water fluoridation should be continued in communities currently fluoridating and extended to those without fluoridation.”

To repeat what I wrote in bulletin # 553 (”CDC spins NRC report”), in the six days after the NRC report was released CDC scientists had had

 ”little time to digest this 450 page report,  let alone check the voluminous literature which was cited.  I doubt very much -  if the CDC was challenged to do so - it could produce anyone in their midst who could demonstrate that they have mastered even a fraction of the literature covered by this panel of 12 experts. “

Moreover, on what basis were they able to pre-judge the outcome of US EPA ’s health risk assessment to determine a new MCLG, as recommended by the NRC panel? Specifically, how was the CDC to know that with the NRC’s exposure analysis on the table, as well as with the NRC’s analysis of many serious end points, that the EPA would not be forced to come back with an MCLG which was less than 1  ppm? In my mind, this is what will happen if science not politics prevails at the EPA (with serious end points confirmed but with uncertainties about lowest observable adverse effect levels, any one of these health end points would force a much larger safety margin than the pathetic little safety factor of 2.5 used to establishe the current MCLG of 4 ppm). Why didn’t the CDC at least wait until this process had been completed? Well we know why, of course, the CDC - or rather the dental lobby within the CDC - is working backwards from their perceived need to protect this policy at all costs.
It is clearly difficult for Dr. Julie Gerberding to face up to the questions in my letter and email (see copies below). However, as a public servant it is her duty to do so. If, neither common courtesy, nor the need to maintain the notion that good science prevails at the CDC, can produce a timely reply, I think it is time we asked our legislative representatives for help.
Would you please write to your US Senator and US Representative and seek their help a) to get a reply to my letter and email and b) to secure their support in principle for a Congressional hearing which would force CDC officials to testify (and be cross-examined) under oath on their reasons for continuing to promote mandatory statewide fluoridation despite the damning evidence in the NRC report of fluoride’s dangers at low levels and their exposure analysis which shows many Americans are exceeding safe levels and without waiting for the US EPA to perform a new health risk assesssment to see what a new MCLG should be.
Key question: what is driving this agency’s reckless policy on this matter?
Thank you in advance of anything you can do in this respect. I would appreciate copies of your letters and any response that you get (emails to
hard copies to Paul Connett, 82 Judson Street, Canton, NY 13617).
Paul Connett
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email - April 5, 2006.

Dear Dr. Gerberding,

Since I emailed this to you last night, I have discovered that the CDC has issued a statement saying that, despite the NRC findings it believes that fluoridation is safe and effective and should continue. Were you aware  that this statement was being made? If you were not, it seems to me that you need to find out who in your agency is calling the shots on this matter.

I certainly find it extraordinary that the CDC has strongly relied on the NRC review from 1993 to support its claims of safety and, then despite the more recent NRC review, is still supporting fluoridation, even though the NRC has reversed its position on the safety of the MCLG at 4 ppm. Isn’t this a case of heads you win, tails we lose?

Paul Connett

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 Letter to Dr. Julie Gerberding, Director of the CDC, April 4, 2006.
 Dr. Julie Gerberding,
Centers for Disease Control and Prevention,
1600 Clifton Road,
Atlanta, GA 30333.
April 4, 2006.
Dear Dr. Gerberding:
Since at least 1999, and possibly before, the CDC has based its oft-repeated assertion that water fluoridation is safe on a 1993 National Research Council (NRC) review of the literature on fluoride’s toxicity. This review was done at the request of the US EPA, which wanted to know if the science up to 1993 supported its safe drinking water standard for fluoride, i.e. the Maximum Contaminant Level Goal (MCLG) of 4 ppm.
Another distinguished panel appointed by the NRC has just completed (March 22) its 3-year review of the same question and concluded that the science published since 1993 shows that the 4 ppm standard is not protective of human health; specifically it does not protect against severe dental fluorosis in children nor does it protect against bone fracture, and possibly stage II skeletal fluorosis, in the general population.  In light of these clear findings, will the CDC now be reassessing its position on fluoridation and will CDC immediately cease active support for mandatory fluoridation throughout the country as it re-evaluates its own position?
While some pro-fluoridation commentators have said that the NRC findings are irrelevant to water fluoridation at 1 ppm, a careful review of the full report does not support such a position. In a separate memo, I discuss other health effects covered in the 450 page NRC report.
There is no doubt that the new report is highly relevant to the deliberate addition of fluoride to the drinking water.  The NRC report concluded that the MCLG should be lowered, but did not specify to what level.  However, the report’s exposure analysis indicates that some population subsets may exceed the existing  “safe” doseage limit (let alone a lowered one) by drinking water at 1 ppm fluoride.  Subsets in this category include children and people who drink larger quantities of water such as diabetics, outdoor laborers, athletes, and certain military personnel. Also, people with thyroid disorders may be more susceptible to fluoride’s toxicity at 1 ppm.  Thus, there is virtually no margin of safety for these people drinking water at concentrations used for water fluoridation.
To this evidence, we must now add the publication of Dr. Elise Bassin’s research in which she found an increased risk for developing osteosarcoma in young boys consuming fluoridated water at 1 ppm or lower during their 6th, 7th and 8th years (See the May issue ofthe journal  Cancer Causes and Control).  So, in addition to there being a vanishing margin of safety for fluoridation in general, there is now peer-reviewed evidence that one of the risks being faced is life threatening to children. For this there is absolutely no margin of safety for children drinking water at 1 ppm.
While we realize that it will be difficult for members of the dental profession to reverse their position on a practice for which they have long claimed a great benefit to children’s teeth, the CDC, a government agency charged with protecting the entire nation’s health, should no longer endorse such a dangerous risk/benefit calculation.
As the CDC has itself reported, leading dental researchers now concede that the predominant benefit of fluoride comes from topical exposure, not systemic ingestion. (CDC, 1999, 2001).  Thus, it is no longer necessary to swallow fluoride in water to receive whatever benefits it may provide. While not free of some systemic risk, toothpaste offers a far more rational way of delivering fluoride to the tooth enamel for individuals with a normal swallow reflex.  Young children are well known to have poor swallow control; additionally, some adults with health problems, including stroke, also have swallowing disorders and they should be encouraged to use non-fluoridated toothpaste (http://www.asha.org/public/speech/swallowing/Swallowing-Disorders-in-Adults.htm).
This topical effect mechanism may partially explain why, according to WHO figures available online, children’s teeth in largely unfluoridated Europe are as good, if not better than, children’s teeth in the US, and why the largest NIDR survey of tooth decay in the US found very little difference in the permanent teeth of children who had lived all their lives in fluoridated, as opposed to non-fluoridated, communities (Brunelle and Carlos, 1990).
Furthermore, several recent studies from Finland, the former East Germany, Cuba and British Columbia have shown that where fluoridation has been halted, it has not led to an increase in tooth decay. This, along with the general experience in Europe, indicates that there are other ways of protecting children’s teeth without resorting to randomly medicating people with fluoride for a lifetime through the use of the public water supply.
Assuming that your agency believes in exercising prudence in this matter, we would expect the CDC to immediately cease its aggressive national campaigning for fluoridation - even if only temporarily - while your scientific staff carefully considers the more recent evidence that the NRC reviewed in its new report.  While EPA has announced it will do its own health risk assessment for fluoride in drinking water, the Chairman of the NRC panel, Dr. Doull, stated at the March 22 press conference that no further research is needed to lower the MCLG. The CDC surely does not have to wait for EPA to do its risk assessment; your staff is highly qualified to do its own evaluation forthwith in the interests of protecting the nation’s health.  Preferably you will use scientists outside the Oral Health Division who, unfortunately, are heavily biased in this matter.
I also ask you consider the following: since the NRC has made a great many suggestions for research to clarify many unanswered questions on serious health issues related to fluoride ingestion, is that not tantamount to acknowledging that adding fluoride to water is an ongoing human experiment?  How can we continue fluoridating with so many unanswered questions on its human health effects?
If, indeed, this research means that US authorities are conducting a massive experiment on the American people, it is in violation of the Nuremberg code, which strictly forbids human experimentation on individuals without their informed consent.  While some may have given their consent in the form of local referenda, the majority has not. Most frequently, the decision to fluoridate is made by largely unqualified elected municipal entities. Moreover, as the NRC report has made clear, there are far more health questions in play now than have been considered in the past. Thus, how many of the 160 million people drinking fluoridated water in the US today would you consider to be fully informed on the potential side effects of fluoride ingestion described by the NRC report at levels very close to 1 ppm?
If, despite all of the above arguments, your agency continues to support the practice of water fluoridation and continues to aggressively campaign for it, at the very least you should bifurcate your staff on this. By this, I mean you should assign a number of scientists in your agency, who hitherto have had no allegiance to the fluoridation promotion, to a separate division which would evaluate the health concerns identified by the NRC and other new research as it comes out.  This staff should be free to do its work independent of the Oral Health Division, which sees its role primarily as promoting fluoridation, and not with objectively examining its potential dangers.
Indeed, it is most unseemly that staff members who actively support fluoridation are the very same people charged with analyzing health findings that may threaten the same program for which they work and on which they have staked their reputations. Such a conflict of interest is obvious and should be eliminated (ideally, from CDC in its entirety).  However, it is essential that personnel evaluating the scientific literature relating to fluorides have a strong background in medicine, toxicology and epidemiology and do not bring a pro-fluoridation bias to their analysis. In other words, assign one division to deal with fluoride’s dental effects and create another to evaluate fluoride’s impacts on all other tissues and organ systems in the body.
Meanwhile, you should know that we intend to do everything we can to have you and key CDC staff involved in this matter brought to testify and be cross-examined under oath in a full Congressional inquiry into fluoridation at the earliest possible time. 
 
Dr. Gerberding, please do not refer this to Dr. William Maas, or anyone at the Oral Health Division, for a reply to me.  This letter is concerned with the total health of our citizens, not just the dental effects of fluoride. Dr. Maas’ response is totally predictable. It would reflect his own long-standing pro-fluoridation bias, which is, unfortunately, set in stone.
When lives are at stake from a policy your agency actively pursues, you - the  Director of the CDC - must bear ultimate responsibility for the consequences of continuing this policy in light of new evidence of its harmfulness.
I will appreciate and look forward to an early reply.
Sincerely,
Dr. Paul Connett 
Professor of Chemistry,
St. Lawrence University,
Canton, NY 13617.
315-229-5853
pconnett@stlawu.edu
Executive Director,
Fluoride Action Network
315-379-9200
http://www.FluorideAction.Net
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CDC Statement on the 2006 National Research Council (NRC) Report on Fluoride in Drinking Water
CDC recommends community water fluoridation as a safe, effective, and inexpensive way to prevent tooth decay (dental caries) among populations living in areas with adequate community water supply systems. Similar to many vitamins and minerals we consume for our health, fluoride should be taken in the proper amount. Past comprehensive reviews of the safety and effectiveness of fluoride in water have concluded that water fluoridation is safe and effective. Fluoride is present naturally in most water at a very low level, and more than 170 million people on public water systems in the United States enjoy the benefits of having their water adjusted to the optimal level (0.7 - 1.2 mg/L, or 0.7 - 1.2 parts per million [ppm]) for preventing tooth decay.
Some water has naturally occurring fluoride at levels much higher than the optimal. A recent report, Fluoride in Drinking Water: A Scientific Review of EPA’s Standards from the National Research Council (NRC), released on March 22, 2006, addresses safe maximum fluoride levels. The report addresses the safety of high levels of fluoride in water that occur naturally, and does not question the use of lower levels of fluoride to prevent tooth decay.
This new report was prompted as part of a routine, periodic review by the Environmental Protection Agency (EPA), the federal agency that is responsible for all regulated contaminants in drinking water, including fluoride. As part of its congressionally authorized mission, to protect the health of the public, the EPA sets standards for safe drinking water. Drinking water can contain many minerals, compounds, and organisms, some of which are considered “contaminants” under EPA’Äôs regulations. There currently are 96 contaminants that are regulated under the Safe Drinking Water Act; fluoride is included as a naturally occurring mineral.
The purpose of the review of fluoride was to determine the adequacy of current guidelines set by the EPA on the maximum allowable concentration of fluoride in drinking water to protect children and others from adverse health effects. The National Research Council (NRC) Committee found that the current EPA maximum contaminant level goal (MCLG) of 4 milligrams of fluoride per Liter (mg/L) of drinking water should be lowered to better protect people from health risks associated with high natural fluoride levels. The report recommended that the EPA update its risk assessment in order to determine the appropriate level for the MCLG.
The NRC Committee evaluated many health effects that have the potential to be associated with fluoride in drinking water. The NRC concluded that only three adverse health effects warranted consideration in developing regulatory standards for high levels of fluoride in drinking water’ severe enamel fluorosis from exposure to these high levels between birth to 8 years of age, and the potential risk for bone fractures and the more severe forms of skeletal fluorosis after lifetime exposure. Severe skeletal fluorosis is a rare condition in the United States.
This report is important for people living in areas with high concentrations of natural fluoride greater than 2 mg/L or 2 ppm. This represents approximately one half of one percent of the U.S. population. The EPA estimates that approximately 220,000 Americans receive water from public water systems with fluoride levels that are equal to or exceed 4 mg/L. The Committee concluded that people who consume water with this high fluoride content over a lifetime, when compared to people consuming water with 1 mg/L, are likely to be at increased risk for bone fractures. Another 1.4 million people in the United States drink water from community water supplies that have a natural fluoride level ranging from 2.0 mg/L to 3.9 mg/L. The Committee found that water at 2 mg/L or greater may put children 8 years old and younger at increased risk for severe enamel fluorosis, a condition that causes staining and pitting of the enamel surface of teeth. In communities with fluoride levels greater than 2 mg/L, CDC recommends that parents and caregivers of children 8 years and younger should provide children with drinking water from an alternative water source. At levels less than 2 mg/L (equivalent to 2 ppm), the committee found that the prevalence of severe enamel fluorosis was very low (near zero).
The findings of the NRC report are consistent with CDC’s assessment that water is safe and healthy at the levels used for water fluoridation (0.7 - 1.2 mg/L). CDC reviews the latest scientific literature on an ongoing basis and maintains an active national community water fluoridation quality assurance program. CDC promotes research on the topic of fluoride and its effect on the public’s health. CDC’s recommendation remains the same - that community water fluoridation is safe and effective for preventing tooth decay. Water fluoridation should be continued in communities currently fluoridating and extended to those without fluoridation.
CDC has previously recommended steps to prevent moderate and severe enamel fluorosis. These recommendations were made in the August 17, 2001, MMWR report, Recommendations for Using Fluoride to Prevent and Control Dental Caries in the United States and can be found at http://www.cdc.gov/OralHealth/waterfluoridation/guidelines/index.htm.  In addition to using an alternate water source for children 8 years and younger if the primary drinking water source has naturally occurring fluoride above 2 mg/L, these recommendations include: seeking professional advice on use of fluoride toothpaste for children younger than 2 years; using a pea-sized amount of fluoride toothpaste and supervising toothbrushing for children younger than age 6; prescribing fluoride supplements judiciously; and using fluoride mouth rinses appropriately.
Consumers wishing to know the fluoride concentration in their water can contact their local water utility, or local, county or state health department. Currently, 32 states provide information on water systems that is available to the public through the My Water’s Fluoride section of the CDC Web site.
Date last reviewed: 03/28/2006
Content source: Division of Oral Health, National Center for Chronic Disease Prevention and Health Promotion