Below, I have interpolated my specific comments on the CDC statement below in blue (and bold for those who don’t receive messages in color), but first let me make some general comments.

1) In my view, the gap between the CDC’s so-called beneficial level of fluoride in water at 1 ppm (1 mg per liter) and the current 4 ppm, at which the EPA requires fluoride’s removal, offers no adequate margin of safety to protect all members of society.

2) Now that the NRC has recommended lowering the 4 ppm, the margin of safety goes from inadequate to indefensible.

3) For the CDC to come to its conclusions before it had time to thoroughly digest the 500 page report (let alone the 1000 references) and perform (let alone publish and defend) its own health risk assessment is a massive failure of due diligence in its mandate to protect the health of the American people. As Dr. Carton makes clear, if the mandates of the Safe Drinking Water Act are followed, the new MCLG for fluoride would have to be set at zero.

4) To have done their own health risk assessment using the evidence provided by the NRC, would have required going outside the Oral Health Division, because it is clear that within this division they do not have the expertise, let alone the objectivity, to perform this task. There is no evidence they did this.

5) Taking 1, 2, 3, and 4 into account, the CDC’s “rush to dismissal” is yet another very clear example of their need to protect their fluoridation program at all costs – which include the costs to public health.

6) Throughout their short analysis the CDC continues to conveniently confuse the difference between concentration and dose. Concentration of fluoride in water is measured in milligrams of fluoride per liter. The dose is measured in mg/day. This difference is key in discussions of safety. Engineers can control the concentration of fluoride they add to water (barring accidents), but public health officials cannot control the dose that people get in mg/day, because they cannot control how much water people drink or the dose of fluoride that people get from many other sources.

7) What the CDC needed to be able to say, if it wished to justify their continued promotion of water fluoridation, was “We are satisfied that no member of society drinking water fluoridated at 1 ppm, and consuming fluoride from other sources, will receive a combined total dose of fluoride in mg/day, which will cause any short term or long term health problems, regardless of their age, their health status and regardless of how much water they drink.” Of course, thy cannot say that and they know they cannot say that, so they do what they are best at: they spin and obfuscate.

8) It is absolutely essential for maintaining whatever withering trust the public may have left in the US Public health system, and in the ability of Congress to force our health agencies to do the job for which they are funded by the US taxpayer, that the CDC be forced to present its defense of this practice under oath before a Congressional hearing. Short, self-serving unscientific statements on the internet just don’t cut it.

Paul Connett

PS Robert Pocock has referred me to an article: CDC To Hire Ombudsman To Address Low Morale Among Employees
< http://www.medicalnewstoday.com:80/medicalnews.php?newsid=61525&nfid=al> which documents a growing loss of morale among scientists at the CDC. One can’t help wondering whether the continued betrayal of both scientific integrity and the public’s trust by the CDC Oral Health Division may not have something to do with this. A bona fide scientist working at the CDC – especially one trained in toxicology – must be appalled at the CDC’s irrational and unscientific promotion of water fluoridation in the face of the NRC (2006) review and the science it referenced.

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. This is certainly the position they are hell bent to defend. Similar to many vitamins and minerals we consume for our health, fluoride should be taken in the proper amount. There is huge slight of hand here. There is absolutely no credible evidence that fluoride is a nutrient needed for healthy development. If it were then the CDC would have to explain how nature completely screwed up by putting such a low level (0.004 ppm) in baby’s first meal. Past comprehensive reviews of the safety and effectiveness of fluoride in water have concluded that water fluoridation is safe and effective. Why is the CDC citing past reviews here when the NRC has put the latest primary literature on the table? It is these studies which the CDC needed to cite and examine very, very carefully before it rushed to judgment on safety. 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 (much higher is a vague term and needs defining) 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 (again this is a vague and loaded term. For some 4 ppm is not much higher than 1 ppm, especially when you cannot control the amount of water people drink) levels of fluoride in water that occur naturally, and does not question the use of lower levels of fluoride to prevent tooth decay. There are three things which make this comment invalid. First, the NRC panel was not asked to consider the benefits of fluoridation and thus did not get involved with a risk-benefit calculation. Second, in chapter 2, in an exposure analysis they it is clear that some people are drinking such large quantities of water fluoridated at 1 ppm that they might be at risk for some of the health risks they discuss. Third, in the chapter on endocrine disruption they provide data to suggest that some people, especially those with borderline iodine deficiency, even when drinking normal amounts of water, will exceed levels which have caused lowered thyroid function in some published studies.

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’s regulations. There currently are 96 contaminants that are regulated under the Safe Drinking Water Act; fluoride is included as a naturally occurring mineral. That certainly does not make it benign. Arsenic too is a naturally occurring mineral, and the MCLG for this mineral is set at zero, and the MCL is 0.01 ppm, which is 400 times lower than the current MCL for fluoride. This is why scientists have to be very careful when they use the words “high” and “low” when talking about toxic substances. What is low for one substance is very high for another. Some people think that 1 ppm is low for fluoride; however, it is 250 times the level in mothers milk (0.004 ppm, Table 2-6, page 40, NRC, 2006).

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 (there are those two loaded words again) fluoride levels. The report recommended that the EPA update its risk assessment in order to determine the appropriate level for the MCLG. Correct. So why is the CDC not waiting for the EPA to do this new health risk assessment? Why are they pre-judging the result and assuming that the new MCLG will leave them with an adequate margin of safety for water fluoridation? If they did their own health risk assessment (hard to believe they did a thorough one in such a short time), why did they not present it, or even mention it?

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. The early symptoms of skeletal fluorosis are identical to arthritis, which is not a rare disease in the US. CDC admits that 68 million American adults have this condition. Agencies of the US Public Health Service have never sought to investigate a possible relationship between over-exposure to fluoride and arthritis. They haven’t even taken the first sensible step of performing a comprehensive analysis of fluoride bone levels in the American population.

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 whole discussion in the above paragraph might be relevant if one could limit everyone’s consumption of water fluoridated at 1ppm to a fixed amount of say, 2 liters per day. But we can’t, nor can we control how much fluoride people get from other sources. It is the combined total of fluoride from all sources which might pose a risk. Limiting the discussion to merely the concentration of fluoride in water is unscientific. No bona fide toxicologist would confuse concentration and dose in this way.

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). Again, we see the deliberate confusion between concentration and dose. What they needed to be able to say at this juncture is that “we are satisfied that no member of society drinking water fluoridated at 1 ppm, and consuming fluoride from other sources, will receive a combined total dose of fluoride in mg/day which will cause any short term or long term health problems, regardless of their age, their health status and regardless of how much water they drink.” Of course, thy cannot say that and they know they cannot say that, so they do what they are best at: they spin and obfuscate. CDC reviews the latest scientific literature on an ongoing basis (Do they now? Where are these reviews? When the CDC published its infamous 1999 report, it did not cite its own reviews but an NRC review which was already six years out of date at the time of citation) and maintains an active national community water fluoridation quality assurance program. (such programs may control water concentrations but they cannot control the dose that people get) CDC promotes research on the topic of fluoride and its effect on the public’s health (unfortunately, it is not financing the most basic health studies, many of which should have been done years ago). 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. Surprise, surprise!

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>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 < http://apps.nccd.cdc.gov/MWF/Index.asp>My Water’s Fluoride section of the CDC Web site.

Date last reviewed: 03/28/2006
Content source: < http://www.cdc.gov/oralhealth/>Division of Oral Health, < http://www.cdc.gov/nccdphp/>National Center for Chronic Disease Prevention and Health Promotion

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