| WHY
EPA HEADQUARTERS UNION OF SCIENTISTS OPPOSES FLUORIDATION
The following documents why
our union, formerly National Federation of Federal Employees
Local 2050 and since April 1998 Chapter 280 of the National
Treasury Employees Union, took the stand it did opposing
fluoridation of drinking water supplies. Our union is
comprised of and represents the approximately 1500 scientists,
lawyers, engineers and other professional employees at EPA
Headquarters here in Washington, D.C.
The union first became
interested in this issue rather by accident. Like most
Americans, including many physicians and dentists, most of our
members had thought that fluoride's only effects were
beneficial - reductions in tooth decay, etc. We too believed
assurances of safety and effectiveness of water fluoridation.
Then, as EPA was engaged in
revising its drinking water standard for fluoride in 1985, an
employee came to the union with a complaint: he said he was
being forced to write into the regulation a statement to the
effect that EPA thought it was alright for children to have
"funky" teeth. It was OK, EPA said, because it
considered that condition to be only a cosmetic effect,
not an adverse health effect. The reason for this EPA
position was that it was under political pressure to set its
health-based standard for fluoride at 4 mg/liter. At that
level, EPA knew that a significant number of children develop
moderate to severe dental fluorosis, but since it had deemed
the effect as only cosmetic, EPA didn't have to set its
health-based standard at a lower level to prevent it.
We tried to settle this
ethics issue quietly, within the family, but EPA was unable or
unwilling to resist external political pressure, and we took
the fight public with a union amicus curiae brief in a
lawsuit filed against EPA by a public interest group. The
union has published on this initial involvement period in
detail.\1
Since then our opposition to
drinking water fluoridation has grown, based on the scientific
literature documenting the increasingly out-of-control
exposures to fluoride, the lack of benefit to dental health
from ingestion of fluoride and the hazards to human health
from such ingestion. These hazards include acute toxic hazard,
such as to people with impaired kidney function, as well as
chronic toxic hazards of gene mutations, cancer, reproductive
effects, neurotoxicity, bone pathology and dental fluorosis.
First, a review of recent neurotoxicity research results.
In 1995, Mullenix and
co-workers \2 showed that rats given fluoride in drinking
water at levels that give rise to plasma fluoride
concentrations in the range seen in humans suffer neurotoxic
effects that vary according to when the rats were given the
fluoride - as adult animals, as young animals, or through the
placenta before birth. Those exposed before birth were born
hyperactive and remained so throughout their lives. Those
exposed as young or adult animals displayed depressed
activity. Then in 1998, Guan and co-workers \3 gave doses
similar to those used by the Mullenix research group to try to
understand the mechanism(s) underlying the effects seen by the
Mullenix group. Guan's group found that several key chemicals
in the brain - those that form the membrane of brain cells -
were substantially depleted in rats given fluoride, as
compared to those who did not get fluoride.
Another 1998 publication by
Varner, Jensen and others \4 reported on the brain- and kidney
damaging effects in rats that were given fluoride in drinking
water at the same level deemed "optimal" by
pro-fluoridation groups, namely 1 part per million (1 ppm).
Even more pronounced damage was seen in animals that got the
fluoride in conjunction with aluminum. These results are
especially disturbing because of the low dose level of
fluoride that shows the toxic effect in rats - rats are more
resistant to fluoride than humans. This latter statement is
based on Mullenix's finding that it takes substantially more
fluoride in the drinking water of rats than of humans to reach
the same fluoride level in plasma. It is the level in plasma
that determines how much fluoride is "seen" by
particular tissues in the body. So when rats get 1 ppm in
drinking water, their brains and kidneys are exposed to much
less fluoride than humans getting 1 ppm, yet they are
experiencing toxic effects. Thus we are compelled to consider
the likelihood that humans are experiencing damage to their
brains and kidneys at the "optimal" level of 1 ppm.
In support of this concern
are results from two epidemiology studies from China\5,\6 that
show decreases in I.Q. in children who get more fluoride than
the control groups of children in each study. These decreases
are about 5 to 10 I.Q. points in children aged 8 to 13 years.
Another troubling brain
effect has recently surfaced: fluoride's interference with the
function of the brain's pineal gland. The pineal gland
produces melatonin which, among other roles, mediates the
body's internal clock, doing such things as governing the
onset of puberty. Jennifer Luke\7 has shown that fluoride
accumulates in the pineal gland and inhibits its production of
melatonin. She showed in test animals that this inhibition
causes an earlier onset of sexual maturity, an effect reported
in humans as well in 1956, as part of the Kingston/Newburgh
study, which is discussed below. In fluoridated Newburgh,
young girls experienced earlier onset of menstruation (on
average, by six months) than girls in non-fluoridated Kingston
\8.
From a risk assessment
perspective, all these brain effect data are particularly
compelling and disturbing because they are convergent.
We looked at the cancer data
with alarm as well. There are epidemiology studies that are
convergent with whole-animal and single-cell studies (dealing
with the cancer hazard), just as the neurotoxicity research
just mentioned all points in the same direction. EPA fired the
Office of Drinking Water's chief toxicologist, Dr. William
Marcus, who also was our local union's treasurer at the time,
for refusing to remain silent on the cancer risk issue\9 . The
judge who heard the lawsuit he brought against EPA over the
firing made that finding - that EPA fired him over his
fluoride work and not for the phony reason put forward by EPA
management at his dismissal. Dr. Marcus won his lawsuit and is
again at work at EPA. Documentation is available on request.
The type of cancer of
particular concern with fluoride, although not the only type,
is osteosarcoma, especially in males. The National Toxicology
Program conducted a two-year study \10 in which rats and mice
were given sodium fluoride in drinking water. The positive
result of that study (in which malignancies in tissues other
than bone were also observed), particularly in male rats, is
convergent with a host of data from tests showing fluoride's
ability to cause mutations (a principal "trigger"
mechanism for inducing a cell to become cancerous) e.g.\11a,
b, c, d and data showing increases in osteosarcomas in young
men in New Jersey \12 , Washington and Iowa \13 based on their
drinking fluoridated water. It was his analysis, repeated
statements about all these and other incriminating cancer
data, and his requests for an independent, unbiased evaluation
of them that got Dr. Marcus fired.
Bone pathology other than
cancer is a concern as well. An excellent review of this issue
was published by Diesendorf et al. in 1997 \14. Five
epidemiology studies have shown a higher rate of hip fractures
in fluoridated vs. non-fluoridated communities. \15a, b, c, d,
e. Crippling skeletal fluorosis was the endpoint used by EPA
to set its primary drinking water standard in 1986, and the
ethical deficiencies in that standard setting process prompted
our union to join the Natural Resources Defense Council in
opposing the standard in court, as mentioned above.
Regarding the effectiveness
of fluoride in reducing dental cavities, there has not been
any double-blind study of fluoride's effectiveness as a caries
preventative. There have been many, many small scale,
selective publications on this issue that proponents cite to
justify fluoridation, but the largest and most comprehensive
study, one done by dentists trained by the National Institute
of Dental Research, on over 39,000 school children aged 5-17
years, shows no significant differences (in terms of decayed,
missing and filled teeth) among caries incidences in
fluoridated, non-fluoridated and partially fluoridated
communities.\16. The latest publication \17 on the fifty-year
fluoridation experiment in two New York cities, Newburgh and
Kingston, shows the same thing. The only significant
difference in dental health between the two communities as a
whole is that fluoridated Newburgh, N.Y. shows about twice the
incidence of dental fluorosis (the first, visible sign of
fluoride chronic toxicity) as seen in non-fluoridated
Kingston.
John Colquhoun's publication
on this point of efficacy is especially important\18. Dr.
Colquhoun was Principal Dental Officer for Auckland, the
largest city in New Zealand, and a staunch supporter of
fluoridation - until he was given the task of looking at the
world-wide data on fluoridation's effectiveness in preventing
cavities. The paper is titled, "Why I changed My Mind
About Water Fluoridation." In it Colquhoun provides
details on how data were manipulated to support fluoridation
in English speaking countries, especially the U.S. and New
Zealand. This paper explains why an ethical public health
professional was compelled to do a 180 degree turn on
fluoridation.
Further on the point of the
tide turning against drinking water fluoridation, statements
are now coming from other dentists in the pro-fluoride camp
who are starting to warn that topical fluoride (e.g. fluoride
in tooth paste) is the only significantly beneficial way in
which that substance affects dental health \19, \20, \21.
However, if the concentrations of fluoride in the oral cavity
are sufficient to inhibit bacterial enzymes and cause other
bacteriostatic effects, then those concentrations are also
capable of producing adverse effects in mammalian tissue,
which likewise relies on enzyme systems. This statement is
based not only on common sense, but also on results of
mutation studies which show that fluoride can cause gene
mutations in mammalian and lower order tissues at fluoride
concentrations estimated to be present in the mouth from
fluoridated tooth paste\22. Further, there were tumors of the
oral cavity seen in the NTP cancer study mentioned above,
further strengthening concern over the toxicity of topically
applied fluoride.
In any event, a person can
choose whether to use fluoridated tooth paste or not (although
finding non-fluoridated kinds is getting harder and harder),
but one cannot avoid fluoride when it is put into the public
water supplies.
So, in addition to our
concern over the toxicity of fluoride, we note the
uncontrolled - and apparently uncontrollable - exposures to
fluoride that are occurring nationwide via drinking water,
processed foods, fluoride pesticide residues and dental care
products. A recent report in the lay media\23, that, according
to the Centers for Disease Control, at least 22 percent of
America's children now have dental fluorosis, is just one
indication of this uncontrolled, excess exposure. The finding
of nearly 12 percent incidence of dental fluorosis among
children in un-fluoridated Kingston New York\17 is another.
For governmental and other organizations to continue to push
for more exposure in the face of current levels of
over-exposure coupled with an increasing crescendo of adverse
toxicity findings is irrational and irresponsible at best.
Thus, we took the stand that
a policy which makes the public water supply a vehicle for
disseminating this toxic and prophylactically useless (via
ingestion, at any rate) substance is wrong.
We have also taken a direct
step to protect the employees we represent from the risks of
drinking fluoridated water. We applied EPA's risk control
methodology, the Reference Dose, to the recent neurotoxicity
data. The Reference Dose is the daily dose, expressed in
milligrams of chemical per kilogram of body weight, that a
person can receive over the long term with reasonable
assurance of safety from adverse effects. Application of this
methodology to the Varner et al.\4 data leads to a Reference
Dose for fluoride of 0.000007 mg/kg-day. Persons who drink
about one quart of fluoridated water from the public drinking
water supply of the District of Columbia while at work receive
about 0.01mg/kg-day from that source alone. This amount of
fluoride is more than 100 times the Reference Dose. On the
basis of these results the union filed a grievance, asking
that EPA provide un-fluoridated drinking water to its
employees.
The implication for the
general public of these calculations is clear. Recent,
peer-reviewed toxicity data, when applied to EPA's standard
method for controlling risks from toxic chemicals, require an
immediate halt to the use of the nation's drinking water
reservoirs as disposal sites for the toxic waste of the
phosphate fertilizer industry\24.
This document was prepared
on behalf of the National Treasury Employees Union Chapter 280
by Chapter Senior Vice-President J.
William Hirzy, Ph.D. For more information please call Dr.
Hirzy at 202-260-4683.
END NOTE LITERATURE
CITATIONS
1.Applying the NAEP code of
ethics to the Environmental Protection Agency and the fluoride
in drinking water standard. Carton, R.J. and Hirzy, J.W.
Proceedings of the 23rd Ann. Conf. of the National Association
of Environmental Professionals. 20-24 June, 1998. GEN
51-61.
2.Neurotoxicity of sodium
fluoride in rats. Mullenix, P.J., Denbesten, P.K., Schunior,
A. and Kernan, W.J. Neurotoxicol. Teratol. 17 169-177
(1995)
3. Influence of chronic
fluorosis on membrane lipids in rat brain. Z.Z. Guan, Y.N.
Wang, K.Q. Xiao, D.Y. Dai, Y.H. Chen, J.L. Liu, P. Sindelar
and G. Dallner, Neurotoxicology and Teratology 20
537-542 (1998).
4. Chronic administration of
aluminum- fluoride or sodium-fluoride to rats in drinking
water: alterations in neuronal and cerebrovascular integrity.
Varner, J.A., Jensen, K.F., Horvath, W. And Isaacson, R.L. Brain
Research 784 284-298 (1998).
5. Effect of high fluoride
water supply on children's intelligence. Zhao, L.B., Liang,
G.H., Zhang, D.N., and Wu, X.R. Fluoride
29 190-192 (1996)
6.. Effect of fluoride
exposure on intelligence in children. Li, X.S., Zhi, J.L., and
Gao, R.O. Fluoride 28 (1995). 7. Effect of fluoride on the
physiology of the pineal gland. Luke, J.A. Caries Research 28
204 (1994).
8. Newburgh-Kingston
caries-fluorine study XIII. Pediatric findings after ten
years. Schlesinger, E.R., Overton, D.E., Chase, H.C., and
Cantwell, K.T. JADA 52 296-306 (1956).
9. Memorandum dated May 1,
1990. Subject: Fluoride Conference to Review the NTP Draft
Fluoride Report; From: Wm. L. Marcus, Senior Science Advisor
ODW; To: Alan B. Hais, Acting Director Criteria &
Standards Division ODW.
10. Toxicology and
carcinogenesis studies of sodium fluoride in F344/N rats and
B6C3F1 mice. NTP Report No. 393 (1991).
11a. Chromosome aberrations,
sister chromatid exchanges, unscheduled DNA synthesis and
morphological neoplastic transformation in Syrian hamster
embryo cells. Tsutsui et al. Cancer Research 44 938-941
(1984).
11b. Cytotoxicity,
chromosome aberrations and unscheduled DNA synthesis in
cultured human diploid fibroblasts. Tsutsui et al. Mutation
Research 139 193-198 (1984).
11c. Positive mouse lymphoma
assay with and without S-9 activation; positive sister
chromatid exchange in Chinese hamster ovary cells with and
without S-9 activation; positive chromosome aberration without
S-9 activation. Toxicology and carcinogenesis studies of
sodium fluoride in F344/N rats and B6C3F1 mice. NTP Report No.
393 (1991).
11d. An increase in the
number of Down's syndrome babies born to younger mothers in
cities following fluoridation. Science and Public Policy 12
36-46 (1985).
12. A brief report on the
association of drinking water fluoridation and the incidence
of osteosarcoma among young males. Cohn, P.D. New Jersey
Department of Health (1992).
13. Surveillance,
epidemiology and end results (SEER) program. National Cancer
Institute in Review of fluoride benefits and risks. Department
of Health and Human Services. F1-F7 (1991).
14. New evidence on
fluoridation. Diesendorf, M., Colquhoun, J., Spittle, B.J.,
Everingham, D.N., and Clutterbuck, F.W. Australian and New
Zealand J. Public Health. 21 187-190 (1997).
15a. Regional variation in
the incidence of hip fracture: U.S. white women aged 65 years
and older. Jacobsen, S.J., Goldberg, J., Miles, ,T.P. et al.
JAMA 264 500-502 (1990)
15b. Hip fracture and
fluoridation in Utah's elderly population. Danielson, C.,
Lyon, J.L., Egger, M., and Goodenough, G.K. JAMA 268 746-748
(1992).
15c. The association between
water fluoridation and hip fracture among white women and men
aged 65 years and older: a national ecological study.
Jacobsen, S.J., Goldberg, J., Cooper, C. and Lockwood, S.A.
Ann. Epidemiol.2 617-626 (1992).
15d. Fluorine concentration
is drinking water and fractures in the elderly [letter].
Jacqmin-Gadda, H., Commenges, D. and Dartigues, J.F. JAMA 273
775-776 (1995).
15e. Water fluoridation and
hip fracture [letter]. Cooper, C., Wickham, C.A.C., Barker,
D.J.R. and Jacobson, S.J. JAMA 266 513-514 (1991).
16. Water fluoridation and
tooth decay: Results from the 1986-1987 national survey of
U.S. school children. Yiamouyannis, J. Fluoride 23 55-67
(1990).
17. Recommendations for
fluoride use in children. Kumar, J.V. and Green, E.L. New York
State Dent. J. (1998) 40-47.
18. Why I changed my mind
about water fluoridation. Colquhoun, J. Perspectives in Biol.
And Medicine 41 1-16 (1997).
19. A re-examination of the
pre-eruptive and post-eruptive mechanism of the anti-caries
effects of fluoride: is there any anti-caries benefit from
swallowing fluoride? Limeback, H. Community Dent. Oral
Epidemiol. 27 62-71 (1999).
20. Fluoride supplements for
young children: an analysis of the literature focussing on
benefits and risks. Riordan, P.J. Community Dent. Oral
Epidemiol. 27 72-83 (1999).
21. Prevention and reversal
of dental caries: role of low level fluoride. Featherstone,
J.D. Community Dent. Oral Epidemiol. 27 31-40 (1999).
22. Appendix H. Review of
fluoride benefits and risks. Department of Health and Human
Services. H1-H6 (1991).
23.Some young children get
too much fluoride. Parker-Pope, T. Wall Street Journal Dec.
21, 1998.
24. Letter from Rebecca
Hanmer, Deputy Assistant Administrator for Water, to Leslie
Russell re: EPA view on use of by-product fluosilicic (sic)
acid as low cost source of fluoride to water authorities.
March 30, 1983.
OTHER CITATIONS (This short
list does not include the entire literature on fluoride
effects)
a. Exposure to high fluoride
concentrations in drinking water is associated with decreased
birth rates. Freni, S.C. J. Toxicol. Environ. Health 42
109-121 (1994)
b. Ameliorative effects of
reduced food-borne fluoride on reproduction in silver foxes.
Eckerlin, R.H., Maylin, G.A., Krook, L., and Carmichael, D.T.
Cornell Vet. 78 75-91 (1988).
c. Milk production of cows
fed fluoride contaminated commercial feed. Eckerlin, R.H.,
Maylin, G.A., and Krook, L. Cornell Vet. 76 403-404 (1986).
d. Maternal-fetal transfer
of fluoride in pregnant women. Calders, R., Chavine, J.,
Fermanian, J., Tortrat, D., and Laurent, A.M. Biol. Neonate 54
263-269 (1988).
e. Effects of fluoride on
screech owl reproduction: teratological evaluation, growth,
and blood chemistry in hatchlings. Hoffman, D.J., Pattee, O.H.,
and Wiemeyer, S.N. Toxicol. Lett. 26 19-24 (1985).
f. Fluoride intoxication in
dairy calves. Maylin, G.A., Eckerlin, R.H., and Krook, L.
Cornell Vet. 77 84-98 (1987).
g. Fluoride inhibition of
protein synthesis. Holland, R.I. Cell Biol. Int. Rep. 3
701-705 (1979).
h. An unexpectedly strong
hydrogen bond: ab initio calculations and spectroscopic
studies of amide-fluoride systems. Emsley, J., Jones, D.J.,
Miller, J.M., Overill, R.E. and Waddilove, R.A. J. Am. Chem.
Soc. 103 24-28 (1981).
i. The effect of sodium
fluoride on the growth and differentiation of human fetal
osteoblasts. Song, X.D., Zhang, W.Z., Li, L.Y., Pang, Z.L.,
and Tan, Y.B. Fluoride 21 149-158 (1988).
j. Modulation of
phosphoinositide hydrolysis by NaF and aluminum in rat
cortical slices. Jope, R.S. J. Neurochem. 51 1731-1736 (1988).
k. The crystal structure of
fluoride-inhibited cytochrome c peroxidase. Edwards, S.L.,
Poulos, T.L., Kraut, J. J. Biol. Chem. 259 12984-12988 (1984).
l. Intracellular fluoride
alters the kinetic properties of calcium currents facilitating
the investigation of synaptic events in hippocampal neurons.
Kay, A.R., Miles, R., and Wong, R.K.S. J. Neurosci. 6
2915-2920 (1986).
m. Fluoride intoxication: a
clinical-hygienic study with a review of the literature and
some experimental investigations. Roholm, K. H.K. Lewis Ltd
(London) (1937).
n. Toxin-induced blood
vessel inclusions caused by the chronic administration of
aluminum and sodium fluoride and their implications for
dementia. Isaacson, R.L., Varner, J.A., and Jensen, K. F. Ann.
N.Y. Acad. Sci. 825 152-166 (1997).
o. Allergy and
hypersensitivity to fluoride. Spittle, B. Fluoride 26 267-273
(1993)
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