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Monday, July 9, 2012

IRISH EXPERT BODY ON FLUORIDE AND HEALTH ON THE REPORT TITLED HUMAN TOXICITY, ENVIRONMENTAL IMPACT AND LEGAL IMPLICATIONS OF WATER FLUORIDATION

RESPONSE TO APPRAISAL BY
IRISH EXPERT BODY ON FLUORIDE AND HEALTH
ON THE REPORT
TITLED
HUMAN TOXICITY, ENVIRONMENTAL IMPACT AND
LEGAL IMPLICATIONS OF WATER FLUORIDATION
THOROUGHLY REFUTING THEIR CLAIMS
AND
PROVIDING FACTUAL EVIDENCE
DEMONSTRATING
THEIR
MISREPRESENTATION OF SCIENTIFIC FACTS
June 2012
Prepared by:
Declan Waugh B.Sc. C.Env. MCIWEM. MIEMA. MCIWM. Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Table OF Contents
Executive Summary.....................................................................................................1
INTRODUCTION.............................................................................................................2
HIDING THE FACTS........................................................................................................5
Contradictory Statements of Fact: Part 1 ................................................................7
NRC AND YORK REPORTS .............................................................................................
Contradictory Statements of Fact: Part 2 ................................................................8
Misrepresentation of WHO ...........................................................................................
Contradictory Statements of Fact: Part 3 ..............................................................16
SILICOFLUORIDE DISSOCIATION ...................................................................................
Contradictory Statements of Fact: Part 3 Continued ..........................................23
SILICOFLUORIDE DISSOCIATION ...................................................................................
Contradictory Statements of Fact: Part 4 ..............................................................24
FLUORIDE INTERACTION WITH CALCIUM.....................................................................
Contradictory Statements of Fact: Part 5 ..............................................................30
RISK TO BABIES ................................................................................................................
Contradictory Statements of Fact: Part 6 ..............................................................32
Legal Interpretation on Water Fluoridation................................................................
Contradictory Statements of Fact: Part 7 ..............................................................33
Environmental Impact ..................................................................................................
Contradictory Statements of Fact: Part 8 ..............................................................36
FLUORIDE AND BONE CANCER/OSTEOSARCOMA....................................................
Conclusion..................................................................................................................39
Appendix 1 Parliamentary Questions and Answers
Deputy Maureen O Sullivan T.D...................................................................41
Deputy Catherine Murphy T.D .....................................................................41
Appendix 2
Letter from Professor Trevor A. Sheldon Chair of the YORK Review........42
Appendix 3
Dr. Richard Sauerheber Supporting evidence ..........................................43
Appendiz 4
Independent Reviews of Report by Waugh ..............................................48
 Dr. Richard Sauerheber B.A. Biology, Ph.D. Chemistry
 Professor Roger Master PhD & Nelson A. Rockefeller Professor
 Dr. James S. Beck, M.D., Ph.D. Professor Emeritus of Medical Biophysics
 Prof. Peter L.D. Van Caulart, Executive Director, Environmental Training
Institute, Ontario, Canada
 Dr. Pierre Jean Morin, Ph.D former Director of Medical Research, Laval
University Hospital
 Giles Parent ND.A. AuthorPage 1
Executive Summary
The Department of Health in Ireland established the Irish Expert Body on
Fluorides and Health which is funded by the taxpayer who provide €400,000 in
public money annually for secretarial services for the organisation. The objective
of the organisation is to advise the Department and Minister for Health and
Children on all matters relating to water fluoridation to include risk
management, adverse health effects and protection of public health. The
administration and secretarial services for the Expert Body are provided by the
Dental Health Foundation, whose members largely represent the Expert Body
itself. To my knowledge there are no medical doctors, immunologists,
cardiologists, endocrinologists, epidemiologists, gastroenterologists, oncologists,
haematologists, nephrologists, neurologists, pathologists, paediatricians,
pharmacologists, radiologists, rheumatologists, toxicologists, urologists or
biologists, ecologists, environmental scientists, soil scientists, inland fisheries
experts or veterinary specialists on the Expert Body. The review by the Expert
Body of the report titled  Human Toxicity, Environmental Impact and Legal
Implication of Water fluoridation was undertaken by one individual Dr. Joe
Mullen, a public health dentist and representative of the Health Boards on the
Expert Body. Dr. Mullen was previously a member of the Forum for Fluoridation
who published a report on water fluoridation in 2002.  It should be noted that
this report was  severely criticised by a group of international scientists
1
for
producing what they claimed was a blatantly false report in which they stated
that the aim of the authors of the report was not to study the scientific
evidence, but to find ways to get around it.  In comparison to the
comprehensive review by Waugh examining human toxicity to silicofluoride and
fluoride compounds, the report of which Dr Mullen’s was a senior contributor
devoted only two pages to an independent analysis of specific health studies.
Dr. Mullen himself has publicly claimed that the effectiveness of water
fluoridation is beyond dispute and that it is his duty and responsibility to support
water fluoridation.
2
In the  July 17th 2001 issue of the Irish Medical News Dr.
Andrew Rynne, who testified before Dr. Mullen, expressed his concerns about
the bias of the members of this Forum. Given their record to date it is to be
expected that with such a long history of promoting fluoridation by members of
the Expert Body, that such an organisation will not in any way undertake a fair
and impartial assessment of a report which questions the very core of their
beliefs.  This should be of some concern to the Government of Ireland, public
representatives and taxpayers who fund this organisation and in particular to
consumers in Ireland who are left with no choice but to drink fluoridated water
or eat fluoridated food. Clearly the objective of such a body should be first and
foremost to be independent and from this position of independence provide
unbiased, impartial and truly independent advice.  The evidence presented
here will conclusively demonstrate in just a few examples how the Irish Expert
Body on Fluorides and Health have distorted and misrepresented current
scientific knowledge including Waugh’s report, to suit their beliefs in a manner
that is more like propaganda than fact, in order to support the continuation of
water fluoridation in Ireland at whatever cost.
                                               
1 Dr Hardy Limeback, Head of Preventative Medicine at the University of Toronto in
Canada; Dr C. Vyvyan Howard of the Department of Human Anatomy and cell biology
at the University of Liverpool in Britain and Dr A K Susheela, Executive Director of the
Fluorosis Research and Rural Development Foundation in Dehli, India.
2
Sligo Champion and Irish Medical Journal.Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 2
INTRODUCTION
It is perhaps worth noting at the beginning some of the alarming health
statistics relevant for Ireland.  Fluoride is now known to be a risk factor in
developing many of the most serious health problems prevalent in the
population of Ireland today. This includes neurological and cardiovascular
disease, type ii diabetes, osteoporosis, hypercalcemia, hypothyroidism,
dental fluorosis, skeletal muscular disorders and chronic pain. The incidence
of these diseases in Ireland is far above the global average and continues to
rise.
It has been medically documented that at a minimum 1% of the population
may be hypersensitive to exposure to fluoride. Documented reactions under
clinical observation include some of the following symptoms: gastrointestinal
upsets, skin rashes, mouth sores, migraine like headaches, arthritic-like pains,
dryness of the throat, excessive water consumption, frequent need to urinate,
chronic fatigue, depression, nervousness and respiratory difficulties. This latter
observation means that in Ireland, around 46.000 people at a minimum may
evidence some sensitivity or ill-health in one way or another to drinking
fluoridated water or consuming tainted foodstuffs contaminated with
fluoridated water in the processing or cooking of foodstuffs. The ill-health may
be representative in any of the conditions listed above.
The symptoms may include for example depression, which was one of the
clinically observed reactions to exposure to fluoride. It should be noted that it
is now estimated that in the region of 400,000 people in Ireland currently suffer
from depression.  These figures do not reflect however the enormous
prevalence of general ill-health as documented for Ireland. According to the
World Health Organisation the global average for neurological disease is 6.3
percent of the population, yet according to the Department of Health’s own
statistics the prevalence of neurological disease in Ireland is now at 17.3 per
cent of the population. That represents a truly astonishing 770,000 people who
have been diagnosed with some form of neurological illness in Ireland.
Astonishingly  the health consequences of ingesting fluoride have never been
examined in Ireland, this is truly remarkable given that Ireland is perhaps the
most fluoridated country in the world. This fact itself is astounding, especially
when you look at the health statistics for Ireland compared to any other
country in the world. Apart from neurological illness Ireland also has twice the
level of osteoporosis found in other countries including northern Ireland and
the UK. Ireland also has one of the highest levels in the world of epilepsy, as
well as certain type of cancers associated with the digestive tract, including
cancer of the liver, kidney, stomach, bowel and intestinal cancer. On top of
this the number of adults under 65 years of age with cardiovascular disease
has increased dramatically (due in part to calcification of arteries to which
Fluoride is now known to be a major contributor and risk factor). In addition
Ireland has one of the highest levels of cardiovascular disease overall in the
world. Add to this the fact that some 400,000 people in Ireland are now
estimated to be diabetic and  noting in particular  that the WHO have
identified such sensitive subgroups as having a lower margin of safety to
fluoride than normal individuals. Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 3
This is extremely alarming given that the World Health Organisation (WHO)
itself has warned that patients with kidney dysfunction may be particularly
susceptible to fluoride toxicity in the body.
3
According to the World Health organisation
4
“It is known that persons suffering
from certain forms of renal impairment have a lower margin of safety for the
effects of fluoride than the average person.”.
Yet incomprehensively, the safety margins for high risk subgroups of the
population is the same in Ireland as that for normal healthy individuals.
In addition to diabetics, it is now known that a further 300,000 people in
Ireland over the age of 50 have osteoporosis. The recently published Irish
Longitudinal Study of Ageing, by Trinity College Dublin, found that
musculoskeletal pain involving bones, muscles, ligaments, tendons, and
nerves was the most widely reported condition amongst the wider Irish
population with a prevalence of 40%.  Remarkably, it is estimated that there
are approximately 585,000 people in Ireland who suffer from chronic pain
representing 36% of all households in Ireland. Musculoskeletal pain is one of
the most easily recognisable symptoms of overexposure to fluoride brought
on from excessive quantities of fluoride deposited in the skeleton and soft
tissues.
This is particularly disturbing for future generations as it is now known that 1 in 3
children have dental fluorosis exhibiting a visible sign of chronic overexposure
to fluoride in their bodies at an early stage in life. It is now known as reported
by the European Food Safety Authority that 90% of fluoride in babies and
infants is absorbed into bone. Even more worrying is the fact that all bottle
fed infants in Ireland fed infant formula with fluoridated water  exceed the
maximum recommended daily tolerable intake for fluoride with long-term
medical consequences for their health.
All of this has grave implications for public health, society and the economy
as the younger generation ages in future decades.
What is particularly disturbing is that the appraisal by the Expert Body actually
did was to totally ignore all of this information which clearly as a matter of
urgency should be examined urgently by such an organisation and the HSE in
general. In regard to international studies noted in the report by Waugh the
Expert Body ignored completely the most recent study by Valdez-Jimenez, et
al.5 published in the Journal Neurologia, which reported that "the prolonged
ingestion of fluoride may cause significant damage to health and particularly
to the nervous system”. This study observed that chronic exposure to, and
ingestion of, the synthetic fluoride chemicals added to water supplies can
cause serious brain and neurological damage.
                                               
3
International Programme on Chemical Safety. (1984). Environmental Health Criteria
36: Fluorine and Fluorides. Geneva, Switzerland: World Health Organization.
4 WHO Fluoride in Drinking Water 2004
5 Valdez-Jiménez L, Soria Fregozo C, Miranda Beltrán ML, Gutiérrez Coronado O,
Pérez Vega MI. Neurologia 2011 Jun;26(5):297-300. Epub 2011 Jan 20.Effects of the
fluoride on the central nervous system,Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 4
The fact that the Expert Body also chose to ignore the significant finding by
Mehali et al. and Liu et al. which found that fluoride inhibits AdoHydrae and
homocysteine metabolism, when it is now known that elevated homocysteine
levels are linked to cardiovascular disease, atherosclerotic disease,
congenital heart defects, Down Syndrome, neurodegenerative disorders
including depression, schizophrenia, bi-polar disorder, epilepsy and
behavioural disorders, as well as many other medical conditions, is equally
disturbing.
This also applies to the most recent research by Li Y et al. published in the
journal Nuclear Medicine Communications, which found that fluoride may be
associated with an increased cardiovascular risk as it causes hardening of
your arteries. The significance of this finding cannot be overstated given that
it is the leading lethal disease in Ireland. A disease that has seen a fourfold
increase in primary care for cardiovascular conditions in recent years.
It is truly astonishing that the Expert Body failed to even mention these
established facts in their review. The Irish Expert Body has not commented on
any of these statistics, perhaps because many come from the HSE itself.  So
what exactly was noted in their report and what was the objective and aim
of the ‘appraisal ‘by the Expert Body?
From the evidence presented in their appraisal of the Waugh  report it is
obvious that the review clearly had one task, which was to discredit the
research and the author rather than objectively research any of the
information provided. In their review the Expert Body have demonstrated their
own ability to misread scientific research, which will be conclusively
demonstrated with illustrated examples in this rebuttal.  Overall the Expert
Body have sought to undermine in a disturbingly inadequate &
disproportionate response the quality of research undertaken and
information presented by the Author of the report titled Human Toxicity,
Environmental Impacts and Legal Implications of Water fluoridation, a report
which represents the most comprehensive study and research on water
fluoridation ever undertaken in the history of the State. A study that was
undertaken voluntarily by the Author.
When one looks at the huge amount of scientific information presented in the
review examining over 1200 peer reviewed studies many highlighting the
associated risk of silicofluorides and fluoride to illhealth and environmental
harm, it is no wonder that the Ministries for Health in every other European
Country have followed the precautionary approach to preventative
healthcare and avoided implementing or ended water fluoridation
altogether.
What is perhaps most interesting overall however, is that the
Expert Body have also declined to comment on the evidence
presented in the Waugh report examining the known
geographic disease hotspots in Ireland and the correlation of
disease incidence for certain cancers, cardiovascular disease,
hypothyroidism and neurological illness, with geographic areas
where the fluoridated drinking water is very soft. Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 5
As noted in the report  Human Toxicity, Environmental impact and Legal
Implications of Water Fluoridation, It is clearly time for Irish citizens to have the
same standard of care and legal protection as other European citizens. To
this end, the Government must urgently adopt a precautionary approach to
risk prevention and in doing so harmonise its public health and water
management policies with those of all other EU Member States by ending its
policy of water fluoridation immediately.
HIDING THE FACTS
There are a number of examples where the Irish Expert Body  appear to have
deliberately ignored published peer reviewed scientific findings  or
intentionally misrepresented scientific facts in general to support their stated
position and biased beliefs in artificial fluoridation of drinking water. In doing
so, as a publicly funded organisation they have induced the Government of
Ireland to continue with a policy that is based on a representation of science
that is clearly untrue. Whilst there are a number of specific examples that may
be drawn upon to illustrate this behaviour, perhaps the most important
examples are examined herein, which clearly demonstrates the mindset that
exists within the Irish Expert Body on Fluoride and Health  and which clearly
demonstrates a lack of credibility that reflects poorly on the  nature and
quality of governance within the organisation.
Probably the most significant finding is that the Irish Expert Body have
consistently and repeatedly stated that  hydrofluorosilicic acid (HFSA) poses
no risk to consumers based solely on their unqualified opinion that the
chemical dissociates completely in drinking water into harmless fluoride ions
and that consumers never come in contact with silicofluorides or any other
potentially toxic metal silicofluoride complexes. For this sole reason, the Irish
Expert Body have determined, in their wisdom, that there is no need for the
Government of Ireland to undertake toxicological testing on the synthetic
chemicals used for artificial fluoridation.  Such testing that would ensure the
health and wellbeing of Irish citizens as well as protect its natural heritage and
biodiversity.
The Information presented herein  will show how the Irish Expert Body  have
deliberately misrepresented scientific facts to support their personal profluoridation beliefs and in doing so have misplaced the trust placed in them
to protect the health and welfare of Irish citizens.  Rather than ensuring that
decisions are based on valid and scientifically sound facts I will demonstrate
how they are instead based on a clear  misrepresentation of scientific facts.
Following publication of the report titled  Human Toxicity, Environmental
impact and Legal Implications of Water Fluoridation and subsequent to
numerous written questions to the Minster for Health by elected public
representatives, seeking clarification on various matters raised in the
aforementioned report,
6
it has now come to light that the Irish Expert Body on
Fluorides and Health have repeatedly  and deliberately misinformed the
Minister for Health & Children and the Irish public on critical matters relating to
                                               
6 Appendix 1. Parliamentary Questions on Fluoridation Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 6
public safety. In doing so they have created a false and misleading
impression of the safety of chemical compounds used for artificial fluoridation
of drinking water in Ireland.
This is nothing short of deliberate media and government misinformation by a
body that has been entrusted to protect public interest and raises serious
questions regarding the motivation, professional judgement and abilities of
the body to undertake its work in the interests of consumers and public health
in a transparent and objective manner.
In response to parliamentary questions raised by Deputies Maureen O Sullivan
T.D. and Catherine Murphy T.D as well as other Oireachtas members seeking
evidence to demonstrate that  the silicofluoride compounds used for water
fluoridation have been tested for human safety and environmental toxicity,
the Expert Body has falsely stated that when hydrofluorosilicic acid (HFSA) is
added to water a complete reaction occurs producing only hydrogen ions,
silica (sand) and fluoride ions to which consumers would only be exposed.
Furthermore the Expert Body falsely stated that since consumers do not come
into contact with HFSA as water from the tap contains fluoride, not HFSA or
fluorosilicates, there is no need for the State to demonstrate the safety of the
chemical for human consumption. The Expert Body believe, incorrectly and in
violation of a European Court ruling, that it is unnecessary for the State to
undertake toxicological testing, as would be required  legally  for any such
chemical compound  variants in structure consumed by the public for the
purpose of medical intervention.
The evidence to support such a position by the Expert Body was established in
correspondence by The Irish Expert Body to Dr Kevin Kelleher, Asst National
Director- ISD-Health Protection, Health Service Executive regarding their
appraisal of the main themes of the report  titled  Human Toxicity,
Environmental impact and Legal Implications of Water Fluoridation in which
Dr Joe Mullen, Chair of the New and Emerging Issues Sub Committee of the
Irish Expert Body on Fluorides alleged how the scientific evidence contained
in the report, is in the opinion of the Irish Expert Body both unreliable and
unscientific.
Given such grave allegations it is necessary to examine in detail the evidence
provided by the Expert Body.
Prior to doing so it is however important to put the quality if the review into
context, the review was undertaken by one individual. To counter balance
Dr. Mullen’s opinion, Appendix 4 provides additional third party comments
from International Academics in science, medicine and chemistry in support
of the report.Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 7
Contradictory Statements of Fact: Part 1
NRC AND YORK REPORTS
The Expert Body claim that Waugh has misreported scientific literature by
misquoting the York review and referencing the NRC study which they claim is
not relevant to Ireland.
The Expert Body repeatedly claim that the York Review found water
fluoridation to be safe and effective for all ages. This is an entirely false and
untrue statement and a gross misrepresentation of scientific facts. Professor
Sheldon the Chair of the NHS York Review published a public letter
7
in 2001
stating that the results of the review have been widely misrepresented by
certain bodies in support of water fluoridation. Prof Sheldon stated
categorically that:
“the review found water fluoridation to be significantly associated with high
levels of dental fluorosis which was not characterised as "just a cosmetic issue"
and “ the review did not show water fluoridation to be safe”.
In regard to the Expert Body allegation that the author misrepresented the
NRC Report. The NRC report did not have the objective of evaluating water
fluoridation  per se and did not have the original intent of examining data
published on safety and effectiveness, or lack thereof, for water fluoridation
levels at the widely used concentration of 1 ppm compared to lower levels.
However,  it is false to claim the analysis and data reviewed only apply to
persons exposed to concentrations far higher than used in water fluoridation.
Much of the data in the NRC report published since 1993 were reviewed
relevant to fluoridation, at 1 ppm, as controls to compare effects found at 2–4
ppm and higher.
It is also incorrect to claim that the NRC report only applied to natural fluoride
in drinking water. Both natural and artificial fluoride in water were thoroughly
investigated (NRC, 2006, pp. 14-15).
The committee intention was to  mainly  evaluate whether the EPA  primary
and secondary Maximum Contaminant  Level interim assignments from 1984
were achieving their stated purpose in the U.S. NRC concluded
                                               
7
Professor Trevor A. Sheldon Head of Department Of Health Studies, York University,
Chairman of the York Review. Appendix 2
It is clearly evident therefore that the Irish Expert Body
have inaccurately interpreted and continue to
deliberately misrepresent scientific facts to suit their
own goals in support of water fluoridation.Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 8
UNANIMOUSLY, that the MCL and SMCL must be lowered because current
allowed levels are not protective of human health.
This is because of the widely and conclusively documented adverse
pathology in those exposed to 2 and 4 ppm fluoride in water, compared to
lower levels (NRC, 2006, p. 6). Vast data in  the scientific literature, some
reviewed in the NRC Report, prove that fluoride consumed long-term in
humans at 1 ppm causes pathology.
In full agreement with the NRC committee consensus, the U.S. Health and
Human Services recommended in January, 2012 that water fluoride levels not
exceed 0.7 ppm fluoride as a temporary measure until official regulations can
be established.  The limit for Ireland is 0.8ppm.
The motivation for this change is the glaring fact that as of 2004, 41% of U.S.
children aged 12-15 (similar to Ireland) have permanent abnormal tooth
fluorosis. Further information is kindly provided in Appendix 3 by Dr. Richard
Sauerheber (B.A. Biology, Ph.D. Chemistry, University of California, San Diego,
CA)  in his personal response to the Irish Expert Body’s review of the Waugh
Report.
Contradictory Statements of Fact: Part 2
Misrepresentation of WHO
The Irish Expert Body on Fluorides and Health have stated in their appraisal of
my report that the Author had made several misrepresentation of the views of
the World Health Organisation.
It is important to note that there were in total over 1200 peer reviewed studies
noted in the report. Despite the extensive reference by the author to WHO
information in the Expert Body’s appraisal of my report they were only able to
provide two examples to support such a claim, both of these examples are
addressed in detail here and demonstrate clearly that the Author did not
misrepresent the WHO as was alleged by the Expert Body.
The Expert Body make reference to the report by the World health
Organisation (WHO) titled Calcium and Magnesium in Drinking Water; Public
Health Significance dated 2009 which was noted extensively in the report.
Therefore it is clear once again that the Irish Expert
Body have falsely accused the author of deliberately
misrepresented scientific facts in this regard.Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 9
The goal of this report as stated by the WHO in the preface was to:
“elucidate the role of drinking-water as a contributor to total daily intake of
calcium and magnesium and to determine whether there is a plausible case
that drinking-water could be an important health factor, especially for
cardiovascular disease mortality, at least for people whose dietary intake is
deficient in either of those nutrients.”
The WHO continues in the preface of the report would that the goal was to:
“provide background information on the scientific, nutritional and
technological issues that were discussed by the meeting of experts and the
symposium participants and that contributed to the report of the meeting of
experts. Among the numerous issues addressed were the concentrations and
distributions of minerals in drinking-water worldwide, nutritional
requirements, biochemical and biomedical aspects of minerals in the body,
technologies such as water softening and desalination that significantly alter
the mineral composition of drinking-water, the desirability and feasibility of
remineralization for stabilization and potential benefits, and the availability
of information on water composition so that the public can make informed
judgements with respect to their options for bottled water, softened water and
naturally soft water.”
The Introduction to the Expert Consensus of the report
8 begins with the
following statement:
“Both calcium and magnesium are essential to human health. Inadequate
intake of either nutrient can impair health”.
The WHO goes on to say that:
“Individuals vary considerably in their needs for and consumption of these
Elements. Available evidence suggests that, because of food habits, many
people in most countries fail to obtain from their diets the recommended
intakes of one or both of these nutrients.”
The WHO continues
9 with:
“while the concentrations of calcium and magnesium in drinking-water
vary markedly from one supply to another” and note in particular how
“water treatment processes can affect mineral concentrations and, hence,
the total intake of calcium and magnesium for some individuals”
                                               
8 World health Organisation (WHO) document titled Calcium and magnesium in
Drinking Water; Public HEALTH significance 2009.
9 Calcium and Magnesium in Drinking Water, Public Health Significance,
World Health Organisation, 2009, Pages1-2.Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 10
In section 1.2 of the report the WHO reports the following:
“Over 99% of total body calcium is found in bones and teeth, where it
functions as a key structural element. The remaining body calcium functions in
metabolism, serving as a signal for vital physiological processes, including
vascular contraction, blood clotting, muscle contraction and nerve
transmission. Inadequate intakes of calcium have been associated with
increased risks of osteoporosis, nephrolithiasis (kidney stones), colorectal
cancer, hypertension and stroke, coronary artery disease, insulin resistance
and obesity.”
In  Section 1.3 of the report the WHO report the following regarding
Magnesium.
“Magnesium is a cofactor for some 350 cellular enzymes, many of which are
involved in energy metabolism. It is also involved in protein and nucleic acid
synthesis and is needed for normal vascular tone and insulin sensitivity. Low
magnesium levels are associated with endothelial dysfunction, increased
vascular reactions, elevated circulating levels of Creactive protein and
decreased insulin sensitivity. Low magnesium status has been implicated in
hypertension, coronary heart disease, type 2 diabetes mellitus and metabolic
syndrome.”
And Section 8.1 the WHO report that
“Calcium and magnesium play important roles in bone structure, muscle
contraction, nerve impulse transmission, blood clotting and cell signalling.” And
“It is clear that very large numbers of people consume levels of magnesium and
calcium that are insufficient to support even the most conservative estimates of
their physiological needs.”
The WHO continues in Section 3.8 of the report by reporting:
“In some geographical areas, the magnesium and calcium contents of drinking
waters (including tap and bottled waters) are extremely low and may provide
little supplementation towards a person’s daily requirement. Physiologically,
waterborne minerals are in ionic form, which tend to be easily absorbed by the
human gastrointestinal tract; thus, water can be an important source of mineral
intake.”
The importance of these facts were examined in some detail in  Waugh’s
Report  (for the first time in Ireland) given that large geographic areas of the
country and their  respective  populations  who consume low calcium and
magnesium waters such as found in Counties Cork, Kerry, Mayo and Donegal,
where the calcium levels may be as low as <20mg/L in comparison to other
geographic areas  in the country such as in the Leinster, where the calcium
level may  be  in excess of 300mg/l in drinking water. Representing a very
significant difference in water chemistry that would influence fluoride
bioavailability and toxicity.
The bioavailability of calcium and magnesium were addressed by the WHO in
their report when they stated that:Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 11
"The bioavailability of calcium from water is likely to be influenced by the
same factors that affect calcium bioavailability from food, which has been
reviewed. The presence of anions in certain waters can influence the
bioavailability of calcium from either water or other sources in the diet."
Nevertheless the Irish Expert Body allege that my reporting is unreliable and
unscientific because Dr Mullen’s of the Expert Body claims I misrepresent the
WHO in not stating the following section from their report:
"Treatment and stabilization practices should ensure that the overall
process does not significantly reduce total intake of nutrients such as
calcium, magnesium, fluoride and others below recommended values.
Based on local circumstances, water suppliers and public health
authorities may wish to further modify final drinking-water composition
in light of overall mineral nutrition"
10
This statement was not included in my report as it is clearly incorrect and not
scientifically accurate.
Calcium and Magnesium are essential nutrients however it must be noted
that fluoride is not a nutrient. This has been clearly stated as a scientific fact
by the European Food Safety Authority
11 or other bodies.
12
The issue of fluoride in drinking water was not discussed at all within the main
WHO report; the only reference noted was in section 1.6 FLUORIDE IN
REMINERALIZED DRINKING-WATER where the following text is provided.
                                               
10 Calcium and Magnesium in Drinking Water, Public Health Significance, World
Health Organisation, 2009, Page 9.
11
European Food safety authority, Opinion of the Scientific Panel on Dietetic
Products, Nutrition and Allergies on a request from the Commission related to the
Tolerable Upper Intake Level of Fluoride, (Request N° EFSA-Q-2003-018), (adopted on
22 February 2005), The EFSA Journal (2005) 192, 1-65
12 Opinion of the EU Scientific Panel on Dietetic Products, Nutrition and Allergies
related to the Tolerable Upper Intake Level of Fluoride, 2005
Current scientific knowledge clearly accepts that
Fluoride can and does influence the bioavailability of
calcium in drinking water. The WHO report however
did not however examine any of these matters in any
detail. It is clear that nowhere in my report have any of
these scientific facts been in any way misrepresented
as alleged by the Expert Body on Fluoride and HealthMisrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 12
“The recommended value for artificial fluoridation of water supplies is
generally between 0.5 and 1.0 mg/l and depends upon the volume of
drinking water consumed daily and the uptake of and exposure to fluoride
from other sources. The WHO drinking-water guideline value for fluoride
is 1.5 mg/l. Where dental caries risk is high or increasing, authorities may
consider addition of fluoride to the demineralized public water supply to
between 0.5 and 1.0 mg/l, but other factors should also be considered. In
countries where dental health awareness in the public is very high and
alternative vehicles for fluoride (e.g. fluoridated toothpaste) are widely
available and widely used, a decision to not fluoridate the water would
likely be of little consequence. On the other hand, in developing and
developed countries where public dental health awareness in some
population groups (e.g. lower income) might be much lower, drinking
water containing fluoride at concentrations of 0.5–1.0 mg/l would be
important for dental health.”
In examining this statement it is also important to note that the WHO have
consistently and correctly stated in their Drinking Water Guidelines that
"in the assessment of the safety of a water supply with respect to the
fluoride concentration, the total daily fluoride intake by the individual
must be considered."
The WHO Guidelines for Drinking Water similarly recommend that:
“when setting national standards for fluoride that it is particularly important
to consider volume of water intake and intake of fluoride from other
sources.”
Unfortunately as noted in the Authors main  report these recommendation
were not applied by the Health Authority or the Expert Body in Ireland when
considering water fluoridation in Ireland.
Without following the WHO guidelines and recommendations the Expert Body
continue to misrepresent the  WHO recommendations by stating that the
WHO have found fluoridation of drinking water to be safe in Ireland, without
acknowledging that the WHO also clearly state that this cannot be found as
fact unless the total daily fluoride intake by the individual is first considered.
The Irish Expert Body or HSE do not know what the total fluoride intake is of
consumers in Ireland and have never undertaken a comprehensive dietary
survey of foods, medication or beverages in this country.
The Expert Body have further failed to acknowledge the findings of both the
WHO which found that subgroups of the population remain susceptible to the
toxic effects of fluoride, even at relatively low concentrations. Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 13
The WHO have elsewhere highlighted13
that in countries where public dental
awareness is very high and alternative vehicles for fluoride (e.g. fluoridated
toothpaste) are widely available and widely used, public authorities do not
fluoridate drinking water.
In Ireland fluoride intake is from BOTH water fluoridation and the use of
fluoridated toothpaste, which were introduced into Ireland in the late 1960‘s
after water fluoridation began.
What my report attempted to highlight was that through pursuing both public
health policies, the HSE and Expert Body is placing a wide sector of society at
risk from over-exposure to fluoride.
The Expert Body further alleged that I have misrepresented the WHO by
referencing this statement.
“Where the risk for skeletal and dental fluorosis is high as a consequence of
excess fluoride intake from drinking water, fluoride levels in drinking-water
should be reduced to safe levels, or a lower  - fluoride source used,
especially for young children.”
This is in fact a direct quotation from the WHO report.
14
It does not in
any way misrepresent what the WHO stated.
My contention was that given that dental fluorosis had now reached
endemic proportions in Ireland with approximately forty percent of children
now presenting with dental fluorosis and given that citizens in Ireland are
exposed to fluoride systemically from fluoridated water in addition to fluoride
based toothpastes and other dietary sources with high fluoride content such
                                               
13 Nutrients in Drinking Water, Water, Sanitation and Health Protection and the
Human Environment World Health Organization, Geneva, 2005.
14 Nutrients In Drinking Water, Potential Health Consequences Of Long-Term
Consumption Of Demineralized, Remineralized And Altered Mineral Content Drinking
Water, Expert Consensus, Meeting Group Report, WHO. Page 9.
http://www.who.int/water_sanitation_health/dwq/nutrientschap1.pdf
What is at issue however, is that the Expert Body have
alleged that by the Author referencing this document,
with regard to the importance of calcium and
magnesium in drinking water and its implications for
human health, that he misrepresented the findings of
the WHO. This WHO document was clearly not about
fluoride at all and the only reference to fluoride was in
regard to FLUORIDE IN REMINERALIZED DRINKING-WATER.
Therefore it can be clearly seen that the allegation by
the Expert Body is entirely false and misleading. Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 14
as teas, and the lack of available information on total fluoride dietary intakes
in Ireland that is was time to reconsider the issue of water fluoridation.
It is important to note however this report
15 also noted that
“Formula-fed infants are also a group at risk for excess intake of
potentially toxic elements in drinking water.”
It is a scientific fact that silicofluorides and fluoride are toxic substances.
Fluoride has been shown to be toxic, not only to the skeletal tissues, but also
to the non-skeletal tissues such as the brain, liver, pancreas, endocrines and
the kidney.
16
,
17
Fluoride is a neurotoxin and it makes a serious adverse impact on the
developing brain.
18
,
19
Fluoride exerts its toxic effects on the brain by multiple
mechanisms; the primary phenomenon which is involved in the neurotoxicity
of fluoride appears to be oxidative stress.
20
Importantly the report also stated21
that
“Consumption of moderately hard water containing typical amounts of
calcium and magnesium may provide an important incremental percentage
of the daily dietary requirement. Inadequate total dietary intakes of calcium
and magnesium are common worldwide, therefore, an incremental
contribution from drinking water can be an important supplement to
approach more ideal total daily intakes.  If low mineralized water were used
for food and beverage production, reduced levels of Ca, Mg, and other
essential elements would also occur in those products. Low intakes would
                                               
15 Nutrients In Drinking Water, Potential Health Consequences Of Long-Term
Consumption Of Demineralized, Remineralized And Altered Mineral Content Drinking
Water, Expert Consensus, Meeting Group Report, WHO. Page 6.
http://www.who.int/water_sanitation_health/dwq/nutrientschap1.pdf
16 WHO. Fluorides and oral health. Technical Report Series-846. WHO,Geneva 1984.
17
Zhavoronkov AA. Non-skeletal forms of fluorosis. Arch Pathol 1977; 39: 83-91.
18
Spittle B. 2011. Neurotoxic effects of fluoride. Fluoride 44(3):117-124.
19
P Grandjean, PJ Landrigan, Developmental neurotoxicity of industrial chemicals,
The Lancet, Volume 368 November 8, 2006
20
Shivarajashankara Y.M., Shivashankara A.R.. Neurotoxic Effects Of Fluoride In
Endemic Skeletal Fluorosis And In Experimental Chronic Fluoride Toxicity. Journal of
Clinical and Diagnostic Research [serial online] 2012 May [cited: 2012 Jun 13 ]; 6:740-
744.
21 Nutrients In Drinking Water, Potential Health Consequences Of Long-Term
Consumption Of Demineralized, Remineralized And Altered Mineral Content Drinking
Water, Expert Consensus, Meeting Group Report, WHO. Page 8.
http://www.who.int/water_sanitation_health/dwq/nutrientschap1.pdf
How these facts can be presented by the Expert Body
as a deliberate misrepresentation of scientific facts is
clearly not factual or correct and without any basis.Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 15
occur not only because of the lower contribution of these minerals from
water used in beverages, but also possibly because of higher losses of the
minerals from food products (e.g., vegetables, cereals, potatoes or meat)
into water during cooking”
The report attempted to address some of these important issues and the
interaction and bioavailability of fluoride in soft water given the large
numbers of consumers who are provided with very low calcium and
magnesium drinking water in Ireland. All of these matters have been dealt
with scientifically and accurately within the report by the Author and in no
way misrepresent scientific facts. Furthermore it should be noted that peer
reviewed sources have been provided to support any claims within the
report.
It is important to note the following information from the WHO which the Irish
Expert Body has declined to acknowledge regarding the safety of Fluoride for
all sectors of society, including sensitive subgroups of the population.
The WHO have clearly stated22
that
“Patients with kidney dysfunction may be particularly susceptible to
fluoride toxicity.”
And further the WHO has stated23
that:
“It is known that persons suffering from certain forms of renal
impairment have a lower margin of safety for the effects of fluoride
than the average person.”
Alarming there is no safety margin provided for the estimated 400,000 people
in Ireland who suffer from diabetes within the population.
                                               
22
International Programme on Chemical Safety. (1984). Environmental Health
Criteria 36: Fluorine and Fluorides. Geneva, Switzerland: World Health
Organization.
23 WHO Fluoride in Drinking Water 2004Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 16
Contradictory Statements of Fact: Part 3
SILICOFLUORIDE DISSOCIATION
As noted under the heading Alleged Toxicity of the Fluoridating Agent HFSA,
Dr Mullen stated the following:
This statement is entirely false and misleading. The ‘definite’ work of Urbansky
and Schock described by Dr Mullen is not a peer reviewed scientific paper.
If the Irish Expert body on Fluorides undertook their responsibilities properly
and objectively they would have referenced the correct and only peer
reviewed and ‘definite’ scientific paper by Urbansky on silicofluorides which
was published in 2002.
This latter scientific paper correctly represents the official scientific position of
the U.S EPA. It is obvious that Irish Expert Body on Fluorides did not reference
this ‘definite’ peer reviewed scientific study as it entirely contradicts
everything that the Irish Expert Body on Fluorides have stated, a fact that will
be dealt with in greater detail later. Why the Irish Expert body on Fluoride
choose to ignore this particular study as well as many other credible scientific
peer reviewed research studies raises the most serious questions of
accountability for such a publicly funded body.
It represents the systematic and abject failure of the organisation to report
science objectively and accurately and seriously jeopardises their scientific
credibility.
The report by Urbansky and Schock (2000) is a “work product” produced by
the U.S. EPA detailing why the fluorosilicic acid (SiF) used for water fluoridation
“almost completely” dissociates at 1 ppm F-. Why the Irish Expert Body on
Fluoride and Health would refer to this as the definite work on fluoride is
entirely incomprehensible. It is interesting to note, though not reported by the
“The author (Waugh) repeatedly makes the point that the fluoridating
agent hydrofluorosilicic acid (HFSA) has never been tested for
toxicological effects on humans. He goes on to contend that there is a
complex chemistry involved in the addition of HFSA to water and that
this results in the creation of toxic by-products.
We now know from the definite work on this carried out initially by
Urbansky and Schock (2000) and developed by Finnery (2006) that
this theory has no balance.  There is complete  and rapid reaction
between HFSA and water. The consumer is presented at the tap
with fluoride, not with HFSA or other fluorosilicates. The
Toxicology of HFSA is clearly not an issue of concern for the
consumer as they do not come in contact with it.”Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 17
Irish Expert Body, that in this report  Urbansky and Schock found  that
consumers are actually presented with “concentrations of hexafluorosilicic acid
present in the gastrointestinal tract  after consumption of fluoridated drinking
water”.
This fact was also noted24 by the  EU Scientific Committee on Health and
Environmental Risks (SCHER), when it published its ‘Opinion on critical review
of any new evidence on the hazard profile, health effects, and human
exposure to fluoride and the fluoridating agents of drinking water’  – 16 May
2011.
Following completion of this initial work in 2001, U.S. EPA research managers
concluded it was necessary to clarify SiF dissociation.  This was outlined  in a
letter
25
from the Director of the EPA Water Supply and Water Resources
Division dated March 15, 2001 summarizing the position of the highest
scientific authorities of the EPA reached in January 2001 which noted the
following:
“Several fluoride chemistry related research needs were identified
including; (1) accurate and precise values for the stability constants of
mixed fluorohydroxo complexes [read “silicofluoride dissociation
residues”] with aluminum (III), iron (III) and other metal cations likely to
be found under drinking water conditions and (2) a kinetic model for the
dissociation and hydrolysis of fluosilicates and stepwise equilibrium
constants for the partial hydrolysis products.”
In this communication the EPA senior management admitted that they were
are not satisfied with assurances given by their own technical staff of the
health and safety of SiFs on two counts:
 possible formation of toxic complexes with aluminium, iron and other
cations commonly present in water plant water and
 potential toxic effects from SiF dissociation residues in municipal
drinking water that may be present despite predictions made by EPA
and others for SiF dissociation.
Following this in 2002, the U.S. EPA issued a “Request for Assistance,” (RFA)
inviting research proposals on methods to detect and measure SiF
dissociation products.  For the benefit of prospective bidders Urbansky wrote
                                               
24
Scientific Committee on Health and Environmental Risks, SCHER, Critical review of
any new evidence on the hazard profile, health effects, and human exposure to
fluoride and the fluoridating agents of drinking water. May 2011, Page 11
25
Letter dated March 15, 2001 from Sally C. Gutierrez, Director, Water Supply and
Water Resources Division, US EPA National Risk Management Laboratory, to Roger D.
Masters, Dartmouth College.
This entirely contradicts what the Irish Expert Body have
advised the HSE, Minister for Health and Elected Public
Representatives and the public in general.Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 18
an extensive peer reviewed published scientific paper of SiF dissociation
studies (Urbansky 2002).
26
In this extensive study Urbansky concluded that hydroxo-fluoro SiF derivatives
could survive  in drinking water, entirely contradicting what the Irish Expert
body on Fluorides have advised the HSE and Minister for Health.
Importantly  Urbansky further stated the following recommending that
scientific authorities should cease using certain qualified expressions that
remarkable the Irish Expert body On Fluoride still continue to use a decade
later.:
                                               
26
Edward Todd Urbansky, Fate of Fluorosilicate Drinking Water Additives
United States Environmental Protection Agency, Office of Research and
Development, National Risk Management Research Laboratory, Water Supply and
Water Resources Division, Received January 29, 2002, Chem. Rev. 2002, 102, 2837-
2854.
Urbansky wrote that “there is considerable debate over the
composition and even the existence of some homo- and heteroleptic
aquo-, fluoro-, and hydroxo complexes of silicon- (IV), which makes
it impossible to predict what species might be found in real potable
water supplies that are fluoridated or those that naturally contain
fluoride and silicates as background ions.”
“it is probably best to stop  using qualified expressions such as
‘virtually complete’ or ‘essentially complete’ in favor of more
rigorous and quantitative descriptions  [of SiF dissociation] even if
that hinders communication with the lay public.”Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 19
Once again this entirely contradicts what the Irish Expert Body on Fluorides
have advised the HSE and Minister for Health and Children where they
continue to claim complete dissociation of hexafluorosilicic acid when
added to drinking water.
Urbansky also raised concerns regarding the ability of current scientific
instrumentation to accurately measure the presence of
“fluorosilicates compounds that may be present in drinking water when he
stated “Whether residual fluorosilicates or fluorosilicon(IV) complexes will
be detectable with current instrumentation is debatable. Accordingly, there is
a need for further study of heteroleptic fluoride complexes (especially with the
common anions in drinking water) of aluminum(III) and possibly other metal
cations.”
Urbansky went on to say:
“It is not clear if current analytical techniques are capable of detecting
whatever  species exist under actual drinking water conditions, and such
knowledge is critical for the formulation of sound policy and regulation.
Table 6 lists species that may exist in fluoridated water systems.”
Source:  Fate of Fluorosilicate Drinking Water Additives, Chemical Reviews, 2002, Vol. 102, No. 8
The scientific facts regarding incomplete dissociation as noted by Urbansky
are further supported by published peer reviewed research by Crosby
(1969)
27
, Westendorf (1975)
28
, Busey et al (1980)
29 and Rajković et al (2007).
30
It
                                               
27 Crosby NT; "Equilibria of Fluosilicate Solutions with Special Reference to The
Fluoridation of Public Water Supplies"; J Appl Chem; v19; pp 100-102, 1969.Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 20
is evident that the Irish Expert Body does not acknowledge or accept the
findings of any of this peer reviewed and published scientific research as it
contradicts their stated opinions.
In regard to measuring such chemical species in drinking water Urbansky
added:
“Ideally, we would like to be able to measures or at least calculate the
concentrations of those species that do exist and rule out those that do not.
Accomplishing this will be no small task, When metal cations are thrown into the
mix (as would be the case in a real drinking water matrix), the problem becomes
even more difficult.  In the meantime, we must try to make the best use of the
information available to us and focus on the consistencies  as well as what is
unequivocally established as chemical fact.”
Urbansky further noted that:
“The kinetics of the dissociation and hydrolysis of hexafluorosilicate are
poorly understood from a mechanistic or fundamental perspective. Most of the
studies have been rather crude, simply adding a certain amount of the material
to water (deionized) and waiting a set time. The analytical tools applied have
not necessarily been chosen for their optimal performance on such a task. The
stability of silicon tetrafluoride in water, the formation of aquo (or other)
adducts, and the rate of SiF4 hydrolysis have been studied in a very cursory
fashion and barely at all. Accelerative effects expected from various metal
cations or hydrogen ion have not been fully probed.”
Finally Urbansky noted that:
“natural waters contain a number of metallic cations that can be ligated by
fluoride.  Fluoride binds to trivalent metal cations, such as iron(III) and
aluminum, as well as divalent metal cations, such as  calcium and
magnesium.”
The interaction of fluoride with calcium was examined in some detail within
the report  Human toxicity, Environmental Impact and Legal implications of
Water fluoridation.
                                                                                                                                         
28 Westendorf J, The Kinetics of Acetylcholinesterase Inhibition and the Influence of
Fluoride and Fluoride Complexes on the Permeability of Erythrocyte Membranes,
Dissertation to receive Ph.D. in Chemistry from the University of Hamburg, 1975.
29 Busey RH et al; "Fluosilicate Equilibria in Sodium Chloride Solutions from 0 to 60
o C";
Inorg. Chem V 19; pp 758-761, 1980.
30 M. B. Rajković and Ivana D. Novaković. Determination Of Fluoride Content In
Drinking Water And Tea Infusions Using Fluoride Ion Selective Electrode. Journal of
Agricultural Sciences Vol. 52, No 2, 2007, Pages 155-168
Clearly the Irish Expert body on Fluoride do not agree
and prefer to accept conjecture and untruths rather
than established chemical and scientific facts.Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 21
Astonishingly the Irish Expert Body without providing any scientific evidence
or published scientific studies, have stated that any such ‘theories’ on
fluorides effect on calcium are, in their opinion, ‘conjecture and untruths’. This
is a very serious accusation and requires a detailed response which will be
addressed later in this report.
The interaction of fluoride with aluminium is also examined with in some detail
within this report. It is now well documented that toxicity  of aluminium is
potentiated by fluoride which promotes its absorption in the gastrointestinal
tract and accumulation in bone.
31
In regard to fluoride complexes present in drinking water Urbansky (2002)
noted that in artificially fluoridated drinking water:
“much of the fluoride is in fact present as metal complexes, depending on the
concentrations of the metal cations, the fluoride anion, and the hydrogen ion.”
This is important as such complexes would not show up in current standard
laboratory measurements where Ion chromatography is used for the
measurement of fluoride levels in treated drinking water. Current Ion
chromatography methods used for the measurement of fluoride in drinking
water do not measure total fluoride levels but rather measure free fluoride
levels in water, the measured fluoride level could therefore significantly
underestimate the true concentration of fluoride that consumers are exposed
to when they consume artificially fluoridated water.
Current scientific knowledge clearly shows that Fluorosilicates are
emphatically not identical to ‘fluorides’ yet this argument continues to be
used to mislead  the public into believing that fluorosilicates are chemically
interchangeable with true fluorides, and that adding fluorosilicate to drinking
water is merely a ‘topping up’ process to augment fluoride concentrations
below the ‘optimal’ level for preventing tooth decay.
32
The dissociation, bioavailability and potential toxicity of silicofluoride and
fluoride compounds must examined not just in light of normal pH of water. At
the acidity of the human stomach - pH2 to 3 the proportion of fluorine atoms
that are present as fluoride ions changes dramatically
33, at pH 3, 50% of
fluoride is in the form of Hydrofluoric acid, the remainder being free fluoride or
fluoride complexes.
Urbansky himself reported in his study34
that the hexafluorosilicate anion is
most stable around pH 2.6, the acidity level found in the human stomach.
                                               
31 Dai GY, Gai OH, Zhou LY, Wei ZD, Zhang H. Experimental study of combined effect
with fluoride and aluminium. Proceedings of the XXth Conference of the International
Society for Fluoride Research; 1994; Beijing, China.
32 R.D.Masters, M,J,Coplan, B.T.Hone, J.E. Dykes, Association of silicofluoride treated
water with elevated blood lead. Neurotoxicology 21(6) 1091-1100, 2000.
33 R.D.Masters, M,J,Coplan, B.T.Hone, J.E. Dykes, Association of silicofluoride treated
water with elevated blood lead. Neurotoxicology 21(6) 1091-1100, 2000.
34
Edward Todd Urbansky, Fate of Fluorosilicate Drinking Water Additives 2002, Chem.
Rev. 2002, 102, 2837-2854.Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 22
It is also now hypothesized that incomplete dissociated SiF residues may reassociate  both at intra-gastric pH around 2.035
(thereby exposing the
consumer to  toxic  harm) and during food preparation (low pH soft drinks)
producing SiF species including silicon tetrafluoride, (SiF4), a known
toxin.
36,37,38,39,40,41  
It is also believed that commercial SiFs are likely to be
contaminated with fluosiloxanes.
42
Both Urbansky (2002) and Morris (2004)
43
indicate that at pH < 5, silicofluoride
(SiF6 2–) would be present, so it seems reasonable to expect that some SiF6 2–
would be present in acidic beverages such as soft drinks (i.e. Coke, Pepsi and
7Up have a pH < 3; most fruit drinks have a ph < 4.
As noted by the National  Research Council
44
of the Academy of Sciences,
Medicine and Engineering of the United States of America, consumption rates
of these beverages are high for many people, and therefore the possibility of
biological effects of SiF6 2–, as opposed to free fluoride ion, should be
examined.
However as noted in the report by Waugh in his report no toxicological studies
have ever been undertaken to examine the toxicity of silicofluorides on
human health.
                                               
35 Ciavatta L, et al; “Fluorosilicate Equilibria in Acid Solution”; Polyhedron Vol 7
(18);1773-79;1988
36 Gabovich RD; "Fluorine in Stomatology and Hygiene"; translated from the original
Russian and published in Kazan (USSR); printed by the US Govt Printing Office on
behalf of the Dept of Health Education and Welfare. US Public Health Service,
National Institute of Dental Health; DHEW pub no (NIH) 78-785, 1977.
37 Roholm K; "Fluorine Intoxication; A Clinical-Hygiene Study"; H. K. Lewis & Co. Ltd,
London; 1937.
38
Lewis RJ, jr.; "Hazardous Chemicals Desk Reference": Van Nostrand Reinhold; Fourth
Edition.
39 Matheson Gas Products; 30 Seaview Drive, Secaucus, NJ; "Effects of Exposure to
Toxic Gases" and MSDS for CAS # 7783-61-1; created 1/24/89.
40 Voltaix, Inc.; Material Safety Data Sheet for Silicon Tetrafluoride (SiF4).
41 Rumyantseva GI et al; "Experimental Investigation of The Toxic Properties of Silicon
Tetrafluoride"; Gig Sanit ;(5):31-33, 1991.
42 Ricks GM et al; "The Possible Formation of Hydrogen Fluoride from the Reaction of
Silicon Tetrafluoride with Humid Air": Am. Ind. Hyg. Assoc. J. (54); 272-276, 1993.
43 Morris, M.D. 2004. The Chemistry of Fluorosilicate Hydrolysis in Municipal Water Supplies. A
Review of the Literature and a Summary of University of Michigan Studies. Report to the National
Academy of Science, by M.D. Morris, University of Michigan, Ann Arbor, MI. January 23, 2004.
44 USA National Research Council, Fluoride in Drinking Water: A Scientific Review of
EPA‘s Standards, Committee on Fluoride in Drinking Water, (2006), Page 53.
What has been presented herein are the established facts
and current worldwide knowledge regarding silicofluorides
and drinking water. There is a very obvious gap in knowledge
between the established science and what the Irish Expert
Body on Fluorides present to the Department of Health, the
Government of Ireland, elected public representatives and
the public at large. Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 23
Contradictory Statements of Fact: Part 3 Continued
SILICOFLUORIDE DISSOCIATION
In regard to the second report referenced as Finney 2006
45 and noted by the
Irish Expert Body as ‘definite work’ disproving the theory of complex
silicofluoride reactions in drinking water, this work was funded pursuant to the
EPA 2002 RFA cited previously. The aim was to find better ways to quantify SiF
dissociation end-products and possibly to challenge Westendorf
46
results
which showed incomplete dissociation (67%) of silicofluoride acids in water
and furthermore to attempt to disprove his findings that SiF residues caused
inhibition of the enzyme acetylcholinesterase (AChE).
The EPA contracted for work to be performed in the laboratory of an expert in
Raman spectroscopy, but the published report does not mention the use of
Raman spectroscopy. Instead,
19
F NMR spectroscopy was employed, but this
methodology could not detect SiF hydrolysis intermediates because SA
oligomers formed and interfered with the measurement.
Finney reported that
“while our results at low pH values (<3.5) are in good agreement with
previous studies and  confirm the presence of a hydrolysis intermediate
consistent with the pentafluorosilicate ion, very different results were
obtained from investigation of solutions at pH 4 or higher.”
Finney/Morris had an easier way to refute Westendorf.
47 As reported by
Masters et al. they could have tried his way of measuring F
-
released by [SiF6]
2-
without the use of TISAB to see whether 67% dissociation was correct or not.
They didn’t, but in the course of their NMR experiments, they had
                                               
45
Finney WF, Wilson E, Callender A, Morris MD, Beck LW. 2006 Reexamination of
hexafluorosilicate hydrolysis by 19F NMR and pH measurement. Environmental
science & technology ;40:2572-7.
46 Westendorf, J. 1975. The Kinetics of Actylcholinesterase Inhibition and the Influence
of Fluoride and Fluoride Complexes on the Permeability of Erythrocyte Membranes [in
German]. Ph.D. Thesis, University of Hamburg, Hamburg, Germany (as cited in Masters
et al. 2000).
47 Coplan J, Masters R, Patch S, Bachman M, Confirmation of And Explanations for
Elevated Blood Lead And Other Disorders in Children Exposed to Water Disinfection
and Fluoridation Chemicals, NeuroToxicology 28 (2007) 1032–1042
What the Irish Expert Body have not reported or acknowledged is that
Finney’s limited and incomplete  research found an intermediate
silicofluoride ion present in water, a fact that contradicts the very
foundation of their argument. Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 24
inadvertently confirmed the formation of SA oligomers during [SiF6]
2-
dissociation.  In presenting their results Finney
(a)  miss-interpreted Westendorf’s experimental results;
(b)  didn’t try to measure free F
- by ISE without TISAB to break up fluoride
complexes, as Westendorf did;
(c)  didn’t measure SiF derivatives by Raman spectroscopy;
(d)  tried NMR spectroscopy without success; and
(e)  measured pH as a secondary attribute of SiF dissociation, producing
data that do not support their claims about AChE inhibition.
Contradictory Statements of Fact: Part 4
FLUORIDE INTERACTION WITH CALCIUM
The Irish Expert Body on Fluorides, have  stated that any ‘theories’ presented
by Waugh in his report examining fluoride and its effect on calcium are in
their opinion conjecture and untruths. They have provided no evidence or
scientific studies to support such claims. Accordingly I have referenced and
quoted here some of the scientific published facts demonstrating the effect of
fluoride on calcium in humans. I challenge the Irish Expert body on Fluoride to
dispute these published findings.
It has been well documented by the most authoritative peer reviewed
scientists
48
that:
For the Expert Body to suggest that the injection of silicofluorides into soft
water with a calcium level of < 20ppm will have the same bioavailability and
effect on humans as that for hard water with a calcium level of 250-350ppm is
profoundly inaccurate and unscientific. This matter was discussed in some
detail in the Waugh report.  No studies have ever been undertaken in Ireland
to examine the bioavailability of fluoride in natural waters of various hardness.
                                               
48 USA National Research Council, Fluoride in Drinking Water: A Scientific Review of
EPA‘s Standards, Committee on Fluoride in Drinking Water, (2006), Page 251
“Fluoride clearly has the effect of decreasing serum
calcium and increasing the calcium requirement in some or
many exposed persons.”
Despite the evidence to the contrary, the Irish Expert
Body have somehow presented this work as conclusively
demonstrating that there are no complex reactions in the
dissociation of silicofluoride acid in drinking water and no
intermediate compounds that humans could come in
contact with.  This itself as has been demonstrated here is
a grossly inaccurate representation of scientific facts.Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 25
Fluoride interaction with calcium was  noted by Masters et al
49 when they
reported that
“apart from the possibility of direct toxicity the dissociated fluoride ions is
known to bind calcium. If diets are low in calcium the products of
silicofluoride dissociation can exacerbate the competition between calcium
and lead for bone and soft tissue sites.”
It is widely known that dietary calcium severely restricts fluoride assimilation
from the GI tract into the bloodstream.
50
,
51
That is to say diets high in calcium
lower blood plasma fluoride levels from drinking fluoride water. In the same
manner it is now known that diets low in calcium enhances the effects of
fluoride on total plasma calcium.
52
,
53
,
54
,
55
Teotia et al.
56
reported that fluoride appears to exaggerate the metabolic
effects of calcium deficiency on bone.
The work of Tiwari et al.
57
provides an initial description of a mechanism by
which fluoride exposure in the presence of a calcium deficiency further
increases the dietary requirement for calcium, namely by altering the
expression of genes necessary for calcium absorption from the
gastrointestinal tract.
The indirect action of fluoride induces a net increase in bone formation
58
and
also decreases calcium absorption from the gastrointestinal tract
59
,
60
,
61
both of
                                               
49 R.D.Masters, M,J,Coplan, B.T.Hone, J.E. Dykes, Association of silicofluoride treated
water with elevated blood lead. Neurotoxicology 21(6) 1091-1100, 2000.
50 USA National Research Council, Fluoride in Drinking Water: A Scientific Review of
EPA‘s Standards, Committee on Fluoride in Drinking Water, (2006)
51 Whitford. G.M, Effects of plasma fluoride and dietary calcium concentrations.
Calcified Tissue International, Volume 54, Number 5 (1994), 421-425,
52 M. Joost Larsen, A. Richards and O. Fejerskov, Calcified Tissue International Volume
33, Number 1 (1981), 541-544, DOI: 10.1007/BF02409486
53
Teotia, M., S.P. Teotia, and K.P. Singh. 1998. Endemic chronic fluoride toxicity and
dietary calcium deficiency interaction syndromes of metabolic bone disease and
deformities in India: Year 2000. Indian J. Pediatr. 65(3):371-381.
54 Gupta, S.K., T.I. Khan, R.C. Gupta, A.B. Gupta, K.C. Gupta, P. Jain, and A. Gupta.
2001. Compensatory hyperparathyroidism following high fluoride ingestion—a clinicoBiochemical correlation. Indian Pediatr. 38(2):139-146.
55 Krishnamachari, K.A. 1986. Skeletal fluorosis in humans: A review of recent progress
in the understanding of the disease. Prog. Food Nutr. Sci. 10(3-4):279-314.
56 Rosenquist, J.B., P.R. Lorentzon, and L.L. Boquist. 1983. Effect of fluoride on
parathyroid activity of normal and calcium-deficient rats. Calcif. Tissue Int. 35(4-
5):533-537.
57
Tiwari, S., S.K. Gupta, K. Kumar, R. Trivedi, and M.M. Godbole. 2004. Simultaneous
exposure of excess fluoride and calcium deficiency alters VDR, CaR, and Calbindin D
9 k mRNA levels in rat duodenal mucosa. Calcif. Tissue Int. 75(4):313-320.
58 Chavassieux, P., P. Pastoureau, G. Boivin, M.C. Chapuy, P.D. Delmas, and P.J.
Meunier. 1991. Dose effects on ewe bone remodeling of short-term sodium fluoride
administration—a histomorphometric and biochemical study. Bone 12(6):421-427.
59 Krishnamachari, K.A. 1986. Skeletal fluorosis in humans: A review of recent progress
in the understanding of the disease. Prog. Food Nutr. Sci. 10(3-4):279-314.
60
Stamp, T.C., M.V. Jenkins, N. Loveridge, P.W. Saphier, M. Katakity, and S.E. Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 26
these effects lead to an increase in the body’s calcium requirement.
62
,
63
If
dietary calcium is inadequate to support the increased requirement, the
response is an increase in secondary hyperparathyroidism.
64
This view is
supported by  Krishnamachari in his review
65
when he found that In the
presence of inadequate calcium, fluoride directly or indirectly stimulates the
parathyroid glands, causing secondary hyperparathyroidism leading to bone
loss.
It is also now known that secondary hyperparathyroidism in response to
calcium deficiency may contribute to a number of diseases, including
osteoporosis, hypertension, arteriosclerosis, degenerative neurological
diseases, diabetes mellitus, some forms of muscular dystrophy, and colorectal
carcinoma.
66
It is also further known that calcium deficiency induced or exacerbated by
fluoride exposure may contribute to other adverse health effects.
67
For
example, Goyer
68
indicates that low dietary calcium increases the
concentration of lead in critical organs and the consequent toxicity.
A recent increase in the number of cases of nutritional rickets in the United
States appears to suggest the possibility that fluoride exposure, together with
increasingly calcium-deficient diets, could have an adverse impact on the
health of some individuals..69
Fluoride has been implicated in disturbing the functionality of calcium, both
directly
70 and indirectly in interaction with Vitamin D.
71
    Ahmad and
                                                                                                                                         
MacArthur. 1988. Fluoride therapy in osteoporosis: Acute effects on parathyroid and
mineral homoeostasis. Clin. Sci. 75(2):143-146.
61 Ekambaram, P., and V. Paul. 2001. Calcium preventing locomotor behavioral and
dental toxicities of fluoride by decreasing serum fluoride level in rats. Environ. Toxicol.
Pharmacol. 9(4):141-146
62 Pettifor, J.M., C.M. Schnitzler, F.P. Ross, and G.P. Moodley. 1989. Endemic skeletal
fluorosis in children: Hypocalcemia and the presence of renal resistance to
parathyroid hormone. Bone Miner. 7(3):275-288.
63 Ekambaram, P., and V. Paul. 2001. Calcium preventing locomotor behavioral and
dental toxicities of fluoride by decreasing serum fluoride level in rats. Environ. Toxicol.
Pharmacol. 9(4):141-146
64 USA National Research Council, Fluoride in Drinking Water: A Scientific Review of
EPA‘s Standards, Committee on Fluoride in Drinking Water, (2006), Page 250
65 Krishnamachari, K.A. 1986. Skeletal fluorosis in humans: A review of recent progress
in the understanding of the disease. Prog. Food Nutr. Sci. 10(3-4):279-314.
66
Fujita, T., and G.M. Palmieri. 2000. Calcium paradox disease: Calcium deficiency
prompting secondary hyperparathyroidism and cellular calcium overload. J. Bone
Miner. Metab. 18(3):109-125.
67 USA National Research Council, Fluoride in Drinking Water: A Scientific Review of
EPA‘s Standards, Committee on Fluoride in Drinking Water, (2006), Page 251
68 Goyer, R.A. 1995. Nutrition and metal toxicity. Am. J. Clin. Nutr. 61(3 Suppl.):646S
69 DeLucia, M.C., M.E. Mitnick, and T.O. Carpenter. 2003. Nutritional rickets with normal
circulating 25-hydroxyvitamin D: A call for reexamining the role of dietary calcium
intake in North American infants. J. Clin. Endocrinol. Metab. 88(8):3539-3545.
70 ATSDR, Toxicologial Profile for fluorides, Hydrogen Fluoride, and Fluorine (F)
Wastington: US. Department of Health and Human Services (TP-91/17), 1993Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 27
Hammond
72
found that any cause of hypocalcemia or vitamin D deficiency can
lead to secondary hyperparathyroidism (elevated PTH) in an attempt by the body to
maintain calcium homeostasis.
As noted in the report titled Human Toxicity, Environmental Impact and Legal
Implications of Water Fluoridation  the interaction of fluoride and calcium is
matter of some concern to the British Medical Research Council who believe
that:
“the question of the bioavailability of ingested fluoride is important,
especially with respect to the possible influence of water hardness on uptake
and differences between naturally fluoridated and artificially fluoridated
water.”
73
The British Medical Research Council has also stated that:
“a major area of uncertainty concerns the bioavailability of fluoride. This is
particularly important with respect to the possible differential absorption of
fluoride from naturally and artificially fluoridated water and the role of
water hardness (calcium levels).”74
The British Medical Research Council has further stated75
in this regard that:
“If the bioavailability of ingested fluoride can vary significantly, this might
need to be taken into account in the interpretation of epidemiological
studies.”
As noted in the report titled Human Toxicity, Environmental Impact and Legal
Implications of Water Fluoridation no such studies have ever taken place in
Ireland. However a recently published study
76
found that the prevalence of
hypothyroidism in women was twice the national average in one geographic
                                                                                                                                         
71
Bayley TA, Harrison JE, Murra VM, Josse RG, Sturtridge w, Pritzker KP, Strauss a, Vieth
R, Goodwin s. Fluoride-induced fractures: Relation to osteogenic effect: J Bone Miner
Res. 1990 Mar; 5 Suppl 1:S217-22.
72 Ahmad, R., and J.M. Hammond. 2004. Primary, secondary, and tertiary
hyperparathyroidism.
Otolaryngol. Clin. N. Am. 37(4):701-713.
73 UK Medical Research Council Working Group Report: Water Fluoridation and
Health, September 2002, Page 11.
74 UK Medical Research Council Working Group Report: Water Fluoridation and
Health, September 2002, Page 15.
75 UK Medical Research Council Working Group Report: Water Fluoridation and
Health, September 2002, Page 11.
76 Bonar BD, McColgan B, Smith DF, Darke C, Guttridge MG, Williams H, Smyth PP.
Hypothyroidism and aging: the Rosses' survey. Thyroid. 2000 Sep;10(9):821-7.
It is apparent however that the Irish Expert Body on Fluoride refuse to
even acknowledge that any of this peer reviewed research exists
and instead remarkably believe that the effect of fluorides on
calcium are based on conjecture and untruths. Clearly this is both
incorrect and a complete misrepresentation of scientific facts.Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 28
area in Ireland where the  drinking water is soft with low calcium
concentrations and artificially fluoridated, thereby increasing the
bioavailability and toxicity of fluoride compounds in consumers.
The potential of silicofluoride and fluoride compounds to influence subclinical
hypothyroidism cannot be overestimated.  In humans, effects on thyroid
function were associated with fluoride exposures of 0.05-0.13 mg/kg/day
when iodine intake was adequate and 0.01-0.03 mg/kg/day when iodine
intake was inadequate.
77
These ranges are well within the exposure levels
experienced by the general public in Ireland. Therefore it is a scientific fact
that fluoride exposure of sensitive subgroups of the population will clearly
impact on the thyroid function of some consumers.
Subclinical hypothyroidism is considered a strong risk factor for later
development of overt hypothyroidism78
,
79
,
80
associate subclinical thyroid
dysfunction with changes in cardiac function and corresponding increased
risks of heart disease. Subclinical hyperthyroidism can cause bone
demineralization, especially in postmenopausal women, while subclinical
hypothyroidism is associated with increased cholesterol concentrations
increased incidence of depression, diminished response to standard
psychiatric treatment, cognitive dysfunction, and, in pregnant women,
decreased IQ of their offspring
81
,
82
Furthermore Klein et al.
83
reported an
inverse correlation between severity of maternal hypothyroidism (subclinical
or asymptomatic) and the IQ of the offspring.
Numerous scientists including Hinrichs (1966)
84
; Silverman (1971)
85
Biggerstaff
and Rose (1979)
86
; Noren and Alm (1983)
87
; Loevy et al. (1987)
88
; Bhat and
                                               
77 USA National Research Council, Fluoride in Drinking Water: A Scientific Review of
EPA‘s Standards, Committee on Fluoride in Drinking Water, (2006), Page 263
78 Weetman, A.P. 1997. Hypothyroidism: Screening and subclinical disease. Br.
Med. J. 314(7088): 1175-1178.
79 Helfand, M. 2004. Screening for subclinical thyroid dysfunction in
nonpregnant adults: A summary of the evidence for the U.S. Preventive
Services Task Force. Ann. Intern. Med. 140(2):128-141.
80 Biondi, B., E.A. Palmieri, G. Lombardi, and S. Fazio. 2002. Effects of subclinical thyroid
dysfunction on the heart. Ann. Intern. Med. 137(11):904-914.
81 Gold, M.S., A.L. Pottash, and I. Extein. 1981. Hypothyroidism and depression.
Evidence from complete thyroid function evaluation. JAMA 245(19):1919-
1922.
82 Brucker-Davis, F., K. Thayer, and T. Colborn. 2001. Significant effects of mild
endogenous hormonal changes in humans: Considerations for low-dose
testing. Environ. Health Perspect. 109(Suppl. 1):21-26.
83 Klein, R.Z., J.D. Sargent, P.R. Larsen, S.E. Waisbren, J.E. Haddow, and M.L. Mitchell.
2001. Relation of severity of maternal hypothyroidism to cognitive
development of offspring. J. Med. Screen. 8(1):18-20.
84 Hinrichs, E.H., Jr. 1966. Dental changes in juvenile hypothyroidism. J. Dent.
Child. 33(3): 167-173.
85
Silverman, S., Jr. 1971. Oral changes in metabolic diseases. Postgrad. Med.
49(1):106-110.
86 Biggerstaff, R.H., and J.C. Rose. 1979. The effects of induced prenatal
hypothyroidism on lamb mandibular third primary molars. Am. J. Phys.
Anthropol. 50(3):357-362.Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 29
Nelson (1989)
89
; Mg’ang’a and Chindia (1990)
90
; Pirinen (1995)
91
; Larsen and
Davies (2002)
92
; Hirayama et al. (2003)
93
; Ionescu et al. (2004)
94
. have reported
delayed eruption of teeth, enamel defects, or both, in cases of congenital or
juvenile hypothyroidism.
The effect of fluoride on the delayed eruption of teeth is a well established
fact, simply put, the teeth of babies who are bottle fed with formula made up
with fluoride erupt later than normal breast fed babies.
This was scientifically reported as far back as 1961 by Dr. Feltman in the
Journal of Dental Medicine95 who noted that the delay in the eruption of
teeth in babies may be due to hypothyroidism.
                                                                                                                                         
87 Noren, J.G., and J. Alm. 1983. Congenital hypothyroidism and changes in
the enamel of deciduous teeth. Acta Paediatr. Scand. 72(4):485-489.
88 Loevy, H.T., H. Aduss, and I.M. Rosenthal. 1987. Tooth eruption and
craniofacial development in congenital hypothyroidism: Report of case. J.
Am. Dent. Assoc. 115(3):429-431.
89 Bhat, M., and K.B. Nelson. 1989. Developmental enamel defects in primary
teeth in children with cerebral palsy, mental retardation, or hearing defects: A
review. Adv. Dent. Res. 3(2):132-142.
90 Mg’ang’a, P.M., and M.L. Chindia. 1990. Dental and skeletal changes in
juvenile hypothyroidism following treatment: Case report. Odontostomatol.
Trop. 13(1):25-27.
91 Pirinen, S. 1995. Endocrine regulation of craniofacial growth. Acta Odontol.
Scand. 53(3): 179-185.
92 Larsen, P.R., and T.F. Davies. 2002. Hypothyroidism and thyroiditis. Pp. 423-
455 in Williams Textbook of Endocrinology, 10th Ed., P.R. Larsen, H.M.
Kronenberg, S. Melmed, and K.S. Polonsky, eds. Philadelphia, PA: Saunders.
93 Hirayama, T., K. Niho, O. Fujino, and M. Murakami. 2003. The longitudinal
course of two cases with cretinism diagnosed after adolescence. J. Nippon
Med. Sch. 70(2):175-178.
94
Ionescu, O., E. Sonnet, N. Roudaut, F. PreÅLdine-Hug, and V. Kerlan. 2004.
Oral manifestations of endocrine dysfunction [in French]. Ann. Endocrinol.
(Paris) 65(5):459-465.
95
Feltman R, Kosel G. (1961). Prenatal and postnatal ingestion of fluorides - Fourteen
years of investigation - Final report. Journal of Dental Medicine 16: 190-99.
While all of this information noted above is from peer
reviewed scientific publications and is reported accurately,
the Irish Expert Body chose to ignore this science entirely as
if it actually doesn’t exist or were never published.Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 30
Contradictory Statements of Fact: Part 5
RISK TO BABIES
The Irish Expert Body on Fluorides and Health states that there is no evidence
to show a health risk to babies of any age from consumption of fluoride in
infant  formula, water or foods at the levels of fluoride observed in Ireland.
Thus, all intake levels of fluoride consumed by infants in Ireland are
considered safe.
Yet the conclusion of a Food Safety Authority of Ireland risk assessment,
published in 2002, which was accepted by Irish Expert body specifically noted
the risk of risk dental fluorosis in formula-fed infants aged 0-4 months from
consumption of formula milk constituted with fluoridated water.
In this regard it is astonishing that the Irish Expert Body on Fluoride has failed to
act to protect the most vulnerable in our society, newborn babies.
Ireland has the lowest prevalence of breast feeding in the World with
approximately 35% of mothers breastfeeding compared to 95% in Singapore
or 75% in most  mainland European countries. Less than 25% of mothers in
Ireland still breastfeed their babies beyond 3 months of age. In comparison in
Norway, for instance, the prevalence of breastfeeding at 3 months rose from
only 25–30% in 1969 to around 80% in 1985).
96
This represents one of the greatest failures of the Irish Health care system. It
also represents an abject failure of any preventative health policy to reduce
dental fluorosis, childhood obesity, diabetes and other diseases which are
now at epidemic levels in Ireland and are all linked to formula fed infant food.
For infants, not being breastfed is associated with an increased incidence of
infectious morbidity, as well as elevated risks of childhood obesity, type 1 and
type 2 diabetes, leukaemia, and sudden infant death syndrome.
97
,
98
,
99
,
100
Since no neurological or toxicological studies have been undertaken on the
effect of overexposure of infants to silicofluorides and fluoride compounds in
the early and most critical development stage of their life there is no
evidence to demonstrate effectively that fluoride exposure is not contributing
to the incidence of such disease or mortality noted above. Rather the lack of
scientific study and available evidence is presented by the Irish Expert Body
on Fluorides as demonstrating the safety of water fluoridation for infants.
                                               
96 HEIBERG ENDERSEN, E. & HELSING, E. Changes in breastfeeding practices
in Norwegian maternity wards: national surveys 1973, 1982 and 1991. Acta
paediatrica, 84: 719–724 (1995).
97
Ip S, Chung M, Raman G, et al. Breastfeeding and maternal and infant health
outcomes in developed countries. Evid Rep Technol Assess (Full Rep) 2007;153:1–186.
98 Horta BL, Bahl R, Martinés JC, et al. Evidence on the long-term effects of
breastfeeding: systematic review and meta-analyses. Geneva: World Health
Organization; 2007. pp. 1–57.
99 Harder T, Bergmann R, Kallischnigg G, et al. Duration of breastfeeding and risk of
overweight: a meta-analysis. Am J Epidemiol. 2005;162:397–403
100 Alison Stuebe, MD, The Risks of Not Breastfeeding for Mothers and Infants,
Rev Obstet Gynecol. 2009 Fall; 2(4): 222–231.Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 31
In examining the limited evidence available demonstrating harm to infants
from overexposure to fluorides the Irish Expert body on Fluoride and health
have failed to acknowledge or report the published concerns of the:
 American Dental Association (ADA),
 Canadian Dental Association (CDA),
 United States Centre for Disease Control (CDC),
 United States Academy of General Dentistry (AGD),
 American Academy of Paediatrics (AAP) and the
 Canadian Paediatrics Society (CPS)
who have all advised the public and parents that fluoridated water should
not be mixed with concentrated formula or foods intended for babies. This
advice was also provided by the Scientific Committee of the Food Safety
Authority of Ireland 2001 when they recommended that infant formula should
not be re-constituted with fluoridated tap water.
The risk to babies from overexposure to fluoride has also been reported by the
European Food Safety Authority, the European Commission’s Scientific
Committee on Cosmetic Products and Non-Food Products (SCCNFP) and the
European Commission Directorate General for Health and Consumers
(SCHER), the United Kingdom’s Expert Group on Vitamins and Minerals and
the U.S Department Of Health And Human Services Public Health Service
Agency for Toxic Substances and Disease Registry.
The Irish Expert Body have clearly not accepted the concerns raised by all of
these international bodies nor have they accepted or acknowledged that
many other medical organisations such as the International Academy of Oral
Medicine and Toxicology, the International Doctors for the Environment or the
Irish Doctors Environmental Association amongst others, find that water
fluoridation delivers no discernible health benefit, causes a higher incidence
of adverse health effects and impacts negatively on the environment.
In contrast the Irish Expert Body have claimed that the balance of scientific
evidence worldwide supports water fluoridation; when in reality the vast
majority of developed countries including all mainland European countries
have either ended or never commenced the practice of water fluoridation
due to health, legal or ethical considerations.
The Irish Expert Body have further failed acknowledge that the Food and
Nutrition Board (FNB) of the  Institute of Medicine, in North America have
established dietary fluoride intakes levels for infants 0-6months at 0.01mg/L.
Similarly they have failed to acknowledge that the  Canadian Paediatrics
Society (less than 40% of public water supplies are now fluoridated in
Canada) have recommended a level of fluoride exposure of zero for babies
up to six months of age.  Both these levels are exceeded by multiples every
day by tens of thousands of babies in Ireland.  Instead of objectively
presenting these undisputed facts, the Irish Expert Body have repeatedly
stated that water fluoridation has proven to be effective and safe for all
sectors of society. This is inaccurate and a total misrepresentation of the
scientific facts.Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 32
Contradictory Statements of Fact: Part 6
Legal Interpretation on Water Fluoridation
The Irish Expert body have alleged that my interpretation of the legal issues
pertaining to water fluoridation are untrue.
The European Court of Justice, in a landmark case dealing  with the
classification and regulation of 'functional drinks' in member states of the
European Community have ruled that Fluoridated water must be treated as a
medicine, and cannot be used to prepare foods.
101
The Court found that any foodstuffs or beverages such as fluoridated water,
with the aim of treating or preventing disease in human beings or of modify
physiological functions in human beings must be regulated as a drug. The
Court found that it may not be used in the preparation of any food or
beverage, nor may such food or beverage made with fluoridated water be
exported to the European Union until it undergoes proper pharmaceutical
scrutiny and is regulated as a medicinal product in the European Union.
Legally any company making a consumable product using fluoridated water
in its preparation or as an ingredient cannot now export that product to any
other state in the EC, even if their product is permitted in their home state.
These matters were addressed in some detail in the legal review of water
fluoridation. The findings of the European court have not been challenged.
It is alarming that the Expert body appear either unaware of this European
Court ruling or alternatively they have chosen to pretend it doesn’t exist.
It is also clear that the Irish Expert Body refuse to acknowledge the Legal
findings
102 of Lord Jauncey who found that fluoridated water is defined as a
medicinal product. In 1983, the judge ruled that fluoridated water fell within
the Medicines Act 1968, “Section 130 defines ‘medicinal product' and I am
satisfied that fluoride in whatever form it is ultimately purchased by the
respondents falls within that definition.”
This legal view has been supported by the British Medical Journal
103 as well as
Medical Law International.
104
                                               
101 Warenvertirebs-Orthica vs Germany: European Court Justice Ruling (HLH
Warenvertirebs and Orthica Cases C-211/03, C-299/03, C-316/03 and C-
318/03, 9 June 2005)
102
Lord Jauncey. Opinion of Lord Jauncey in cause Mrs Catherine McColl (A.P)
against Strathclyde Regional Council. The Court of Session, Edinburgh, 1983.
103 Cheng KK, Chalmer I, Sheldon TA 2007 British Medical J October 6, 335:699-702.
104
Shaw. D. Weeping and wailing and gnashing of teeth: The Legal Fiction of
Water Fluoridation, Medical Law International 00(0) 1–17, 2011Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 33
Contradictory Statements of Fact: Part 7
Environmental Impact
The Irish Expert Body alleges that Fluoride does not accumulate in the
environment and is not harmful to biodiversity. The Irish Expert Body allege
that the view expressed by the author that there is a build up of fluoride in
the environment is unfounded and not supported by evidence and that
water fluoridation causes no risk to the wider environment.
The Irish Expert Body  was unable to provide a single Irish study to
substantiate their claim. This is because no environmental study has ever
been undertaken in Ireland to examine the environmental impact of
anthropogenic fluoride emissions from water fluoridation on the
environment. What is a scientific fact however is that over 78,400,000kgs of
fluoride have been discharged into the environment in Ireland directly
from water fluoridation.
Fluoride is a List ii substance under the Council Directive 80/68/EEC relating
to the prevention of discharges of certain toxic, persistent and
bioaccumulable substances into groundwater.  Fluoride is listed as an
undesirable substance in Annex 1 of Directive 80/778/EEC relating to the
quality of water intended for human consumption. Fluoride is a List ii
substance under Council Directive 2006/11/EC. Under this Directive it is
necessary to reduce water pollution by the substances within List ii and the
discharge of these substances into the environment.
The only reference that the Irish Expert Body use to demonstrate that
water fluoridation of water supplies does not cause an unacceptable risk
to the wider environment is the SCHER 2011 review.  The SCHER review itself
noted the study‘s own limitations by stating that ‘the environmental review
was simplistic’ and was similarly based on just one published paper.
105
This paper, contrary to the stated opinions of the Irish Expert Body, clearly
demonstrated that fluoride at concentrations of 0.2ppm may have lethal
effects of sensitive freshwater fisheries, especially in soft water rivers, similar
to many salmonid river systems found in Ireland. The natural background
level of fluoride in surface waters in Ireland is < 0.1ppm. The concentration
of fluoride emitted from waste water treatment plants in Ireland may be
800% higher than the natural background level as fluoride in not
effectively removed in the water treatment process. In addition within a
single water catchment area or river there will invariable be multiple point
source emissions from urban waste water treatment plants all discharging
into the same river at different locations along a river. The combined
cumulative effect of this on sensitive ecosystems and protected species
has also been investigated in Ireland.
                                               
105 Camargo, J, A., Fluoride toxicity to aquatic organisms: A Review.
Chemosphere 50 (2003) 251–264Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 34
The Report on the  Human Toxicity Environmental Impact and Legal
Implications examined and presented in some detail evidence from over 70
international  published peer reviewed scientific studies on the impact of
fluorides on the environment.  As a chartered water and environmental
manager I find the allegation and evidence provided by the Irish Expert Body
to be in this regard of such poor standard as to be lacking any credibility or
understanding of environmental chemistry or environmental science in
general.
This references provided in the Waugh review are not exhaustive and further
studies are available that clearly show how anthropogenic emissions of
fluoride from water fluoridation impact on surface water quality and the
environment in general.   The Irish Expert Body should be aware for example
that the WHO has stated that effluents from wastewater treatment plants that
treat fluoridated water will impact on surface water quality.
106
 
In the WHO report titled Fluoride and Fluorides the WHO reference a study by
Singer and Amstrong
107
which found 3 times the fluoride level in rivers receiving
fluoridated effluents (at 1ppm) compared to non fluoridated surface waters.
Numerous Studies have shown that elevated concentrations in fresh water
receiving fluoridated effluent may persist for some distance. Although dilution
reduces concentration over distance, the amount of fluoride in effluent is
either deposited in sediment locally or is carried to the estuary where it may
persist indefinitely.
A review of literature and documentation suggests that concentrations of
fluoride above 0.2 mg/L have lethal (LD50) effects on and inhibit migration of
"endangered" salmon species  whose stocks are now in serious decline” in
Ireland and the US NorthWest.  Warrington in a study108
for the British
Columbia Ministry of Environment also identified 0.2 mg/ L fluoride as a
“critical level” for fresh water species. While the Government of Canada
Environmental Protection Act
109
- estimated adverse effect thresholds
(lethal, growth impairment and egg production) are 0.28 mg/L fluoride for
fresh water species and 0.5 mg/L fluoride for marine species. The impact of
Fluoride on surface water was also accepted by the U.S. Agency for Toxic
Substances and Disease Registry
110 when they found that fluorides from water
                                               
106
International Programme on Chemical Safety. (1984). Environmental Health
Criteria 36: Fluorine and Fluorides. Geneva, Switzerland: World Health
Organization.
107
Singer L, Armstrong WD. 1977 Fluoride in Treated Sewage and in Rain and
Snow. Archives of Environmental Health Jan/Feb P 21-23.
108 Warrington, PD, Ambient Water Quality Criteria for Fluoride. Technical
Appendix 1990, British Columbia Ministry of Environment
109 Government of Canada 1993, Inorganic Fluorides, Canadian Environmental
Protection Act (Priority Substances List Assessment Report).
110
Toxicological Profile For Fluorides, Hydrogen Fluoride, And Fluorine, U.S.
Department Of Health And Human Services Public Health Service Agency for
Toxic Substances and Disease Registry, September 2003.Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 35
fluoridation will contribute to surface water directly and will deposit into
sediment, where they are strongly attached to sediment particles. The
Agency reported how Fluoride forms stable complexes with calcium and
magnesium in natural waters and how Fluorine cannot be destroyed in the
environment it can only change its form.
The agency noted that when deposited on land, fluorides are strongly
retained by soil, forming strong associations with soil components and found
that leaching removes only a small amount about 0.5-6% of fluorides from
soils.
The agency reported how Fluorides may be taken up from soil and
accumulate in plants and that animals that eat fluoride-containing plants
may accumulate fluoride. The U.S EPA has similarly reported how urban waste
water bio-solids accumulate fluoride in soils.
Interestingly the Irish EPA has also documented that fluoride binds strongly to
sediment and bioaccumulates in the environment.
111
Furthermore the EPA in Ireland have acknowledged that in Ireland potential
waters at risk from fluoride pollutant include receiving waters located
downstream of drinking- and wastewater treatment plants and areas where
there is significant leakage from the drinking water distribution system.
112
In the same report the EPA have furthermore reported a number of
exceedances of the standard for fluoride in surface waters associated with
the infiltration of drinking water and discharges from urban wastewater
treatment plants.
                                               
111 McCarthy, T., Duggan, S., McCarthy J., Lambe, A. Regulatory
Impact Analysis of the proposed Surface Water Classification Systems
including Environmental Quality Standards Final Report, Environmental
Protection Agency December 2007
112 Clenaghan, C,. O‘Neill N, Page, D., Dangerous Substances
Regulations
National Implementation Report, 2005 Under the Water Quality
(Dangerous Substances) Regulations, 2001 (S.I. No. 12 of 2001),
Environmental Protection Agency, 2006.
It is clear therefore that the views and personal opinions
of the Irish Expert Body on this allegation are entirely
unbelievable and grossly misrepresent the known
scientific facts on the environmental fate and impact of
fluorides on the environment.Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 36
Contradictory Statements of Fact: Part 8
FLUORIDE AND BONE CANCER/OSTEOSARCOMA
The Expert Body have stated that the Author has misreported scientific facts is
in regard to Osteosarcoma, a rare bone cancer. The Expert Body allege that
the Harvard study by Dr. Bassin presented by Waugh in his report which they
claim only suggests a link between fluoridation and this disease is a
misrepresentation of the facts, furthermore they allege that this research was
disproven by what the Expert Body claim was a later ‘definite’ study by Dr.
Douglass which showed no link to the disease.
There are in fact three part to this accusation, there is the original study
113 a
PhD Dissertation (Bassin 2001) by the Harvard School of Dental Medicine
which Found a very strong, statistically-significant relationship between
consumption of fluoridated water during the mid-childhood growth spurt
(ages 6-8) and osteosarcoma among boys less than 20 years old.
To quote the author Dr. Bassin found
"Among males, exposure to fluoride at or  above the target level was
associated with an increased risk of developing osteosarcoma. The
association was most apparent between ages 5-10 with a peak at six to
eight years of age.. [T]he results continue to demonstrate an effect after
adjusting by zipcode, county population, ever use of bottled or well water,
age, and  any use of self-administered fluoride products. For males, the
odds ratio for the high exposure group was 7.20 at 7 years of age with a 95
percent confidence interval of 1.73 to 30.01... All of our models are
remarkably robust in showing this effect during the mid-childhood growth
spurt, which, for boys, occurs at ages seven and eight years. Our results
are consistent with findings from the National Toxicology Program
animal study which found 'equivocal evidence' for an association
between fluoride and osteosarcoma .and from two ecological studies
that found an association for males less than twenty years old (Hoover
et al., 1991; Cohn 1992)."
In the 1990’s, two further population based studies found increases in the
incidence of bone and joint cancer or osteosarcoma among males under
the age of 20 living in areas with fluoridated water. Hoover et AL.
114
,
115
found
47 and 79% increases in the incidences of bone and joint cancer and
osteosarcoma, respectively among males and females living in fluoridated
                                               
113
Bassin EB. (2001). Association Between Fluoride in Drinking Water During Growth
and Development and the Incidence of Ostosarcoma for Children and Adolescents.
Doctoral Thesis, Harvard School of Dental Medicin
114 Hoover RN, Devessa SS, Cantor KP, et al. 1991a. Review of Fluoride Benefits and
Risks. Fluoridation of Drinking Water and Subsequent Cancer Incidence and Mortality.
National Cancer Institute, public health Service, Bethesda MD: Department of health
and Human Services.
115 Hoover RN, Devessa SS, Cantor KP, et al. 1991b. Review of fluoride benefits and
risks. Time trends for bone and joint cancers and osteosarcomas in the surveillance,
epidemiology and end results programe. National Cancer Institute, public health
Service, Bethesda MD: Department of health and Human Services.Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 37
areas. In contrast, 34 and 4% declines in bone and joint cancer and
osteosarcoma, respectively were found in non fluoridated areas.
In the Cohn study
116
significant increases in the osteosarcoma incidence risk
ratios were found among males under the age of 20 years living in areas with
fluoridated water. However the investigator did caution that these results
were based on a small number of cases.
The second part of this controversy involved Dr. Douglas who supervised the
research for Bassin’s 2001 Doctoral thesis (1992-1999), which concluded that
boys exposed to fluoridated water at a young age were more likely to get
the cancer.
In 2005 when the  U.S National Research Council were undertaking their
review of fluoride Professor Douglas told federal officials Harvard found no
significant correlation between fluoridated water and osteosarcoma. This
itself was astonishing when he was aware as Bassin’s thesis supervisor that her
research did in fact find a connection between fluoride in tap water and
bone cancer.
Subsequently the National Institute of Environmental Health Sciences (NIEHS),
which funded Chester Douglass's $1.3 million study and Harvard University
officials questioned why the Harvard professor appear to bury the research
and failed to inform the NRC of the findings of the research, which he himself
supervised and signed off on.
This was particularly remarkable given the final report abstract stated that:
"The study is expected to provide the nation with the best information
to date regarding a possible relationship between fluoride in the diet and
the risk of Osteosarcoma."
It was claimed that Douglass, first hid from the NRC and then misrepresented,
his graduate student's PhD thesis to the NRC, which found a "robust"
association between fluoridated water and an increased risk of
osteosarcoma in young boys, a frequently fatal disease. A subsequent
investigation exposed the Douglas actively promoted fluoridation and had
strong financial ties with fluoride industries, which could be exposed to huge
liabilities if fluoride is shown to cause cancer.
In 2006 a team of Harvard University scientists, led by Dr. Elise Bassin, published
a study
117
in a peer reviewed cancer research journal reporting  a five-fold
increased risk of developing osteosarcoma among teenage boys exposed to
fluoridated water at ages 6, 7, and 8.
                                               
116 Cohn PD. 1992. An epidemiologic report on drinking water and fluoridation.
Environmental Health Service. New Jersey Department of Health.
117
Bassin EB, Wypij D, Davis RB, Mittleman MA. (2006). Age-specific Fluoride Exposure
in Drinking Water and Osteosarcoma (United States). Cancer Causes and Control 17:
421-8.Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 38
The study was an extension of an analysis first completed by Bassin as a
Harvard PhD thesis in 2001. Remember her thesis adviser, Dr. Chester Douglass
(a consultant to Colgate), was charged in 2005 by the Environmental Working
Group of deliberately withholding and misrepresenting these findings to the
public and scientific community.
According to Bassin the 2006 study found:
"We observed that for males diagnosed before the age of 20 years, fluoride
level in drinking water during growth was associated with an increased
risk of osteosarcoma, demonstrating a peak in the odds ratios from 6 to 8
years of age. All of our models were remarkably robust in showing this
effect, which coincides with the mid-childhood growth spurt."
In stark contrast to the comprehensive study by Dr. Bassin which was published in a
peer reviewed cancer journal (Cancer Causes and Control), the much smaller case
control study by Dr. Douglass study118 was not published in a reputable cancer
research journal but a dental journal  which has a long history of promoting water
fluoridation (Journal of Dental Research).
The Journal of Dental Research is not an appropriate or reputable journal for
publishing bone cancer research.
This paper in the Journal of Dental Research claims to show no association between
fluoride bone levels and osteosarcoma, a form of bone cancer. However, contrary to
the accolades of the Irish Expert Body on Fluoride and Health  this study had major
flaws and was incapable of refuting the previous findings of Bassin which remain
scientifically valid.
Bassin found a 500% to 600% increased risk for young boys, exposed to fluoride in their
6th to 8th years, of later developing osteosarcoma. Douglass' study does not address
exposure during this critical period because it measured the level of fluoride in bone,
which accumulates fluoride over a lifetime. These bone levels provide no information
about when the person was exposed to fluoride. Not only does Douglass' study fail to
refute Bassin's main finding, it suffers from other serious weaknesses:
1) Douglass' study was much smaller and weaker than Bassin's. It had only 20
control subjects under age 30, a fifth of Bassin's. For this key age group,
Douglass' study was so small it could provide no reliable conclusions.  Even
Douglass accepted this serious limitation in his study.
2) Douglass' choice of comparison group is suspect. Douglass compared the
bone fluoride level of patients with  osteosarcoma to "controls" with other
forms of bone cancer. If fluoride also causes these other bone cancer types,
then one would not expect to find any difference in bone fluoride between
these groups. It is biologically plausible that fluoride could cause other bone
cancers because it reaches such high concentrations in bone. One of the
only studies of fluoride and non-osteosarcoma bone cancers did find a link,
but this evidence was never mentioned by Douglass.
                                               
118
Kim FM, Hayes C, Williams PL, Whitford GM, Joshipura KJ, Hoover RN, Douglass CW.
2011. An assessment of bone fluoride and osteosarcoma. J Dent Res 90(10):1171-6.Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 39
3) The controls were severely mismatched to the cases. Controls were much
older (median 41 yrs) than the cases (18 yrs).  The risk of osteosarcoma is
highly age-dependent. Also, fluoride builds up in bone with age. Given
Douglass' small sample size, it is unlikely he could have adequately
compensated for the gross mismatch in age, especially because of these two
simultaneous age dependencies.  The groups were also mismatched on sex
ratio, and osteosarcoma risk is well known to be sex dependent. Properly
adjusting for sex and age would be virtually impossible.
By disregarding all these basic scientific facts and by disputing the previous
scientific findings of the U.S. National Toxicology Program119 which found
'equivocal evidence' for an association between fluoride and osteosarcoma;
the Irish Expert Body contend that there is in their opinion no link between
osteosarcoma and fluoridated water, and that Waugh has misrepresented
the literature in not supporting their invalid claims.
Conclusion
The scientific evidence as presented here and in answers to parliamentary
questions by the Department of Health, provided in appendices, raises very
serious questions of objectivity, transparency, ethics and governance for
those concerned, especially when peer reviewed scientific information is
deliberately misrepresented  by a scientific body funded by the taxpayer with
responsibility to protect public health.
The evidence presented here demonstrates in just a few examples how the
Irish Expert Body on Fluorides have distorted and misrepresented current
scientific knowledge to suit their benefit rather than public benefit in a
manner that is more like propaganda  than fact in order to support the
continuation of water fluoridation.
More importantly however, this raises valid concerns regarding the ability of
the Irish Expert Body on Fluoride to honestly and accurately review, in the
interest of public they are required to protect, any scientific information in a
fair and objective manner. This is perhaps best demonstrated when all
scientific evidence of the past decade clearly demonstrates that it is the
topical application of fluoride by toothpaste and improved diet, not the
ingestion of fluoride into the body via drinking fluoridated water, that is the
most effective method to reduce dental caries.
                                               
119 National Toxicology Program [NTP] (1990). Toxicology and Carcinogenesis Studies
of Sodium Fluoride in F344/N Rats and B6C3f1 Mice. Technical report Series No. 393.
NIH Publ. No 91-2848. National Institute of Environmental Health Sciences, Research
Triangle Park, N.C.
How the Irish Expert Body can claim that Waugh
misreported the scientific literature on this subject is
beyond reason, such accusations are entirely
unfounded.Misrepresentation of Scientific Facts and Current Scientific Knowledge on
Silicofluorides and Fluoride by the Irish Expert Body on Fluoride and Health
Page 40
It is utterly inexcusable for any public health body or official entrusted to
protect the health and welfare of the citizens of this country that they would
so clearly ignore the findings of peer reviewed studies and at the same time
deliberately misrepresent the value or weight of any scientific evidence and
do so only to support their stated opinion and their express beliefs in largely
unproven,  unsubstantiated and inaccurate facts.  Furthermore it is evident
that the Irish Expert Body on Fluoride have deliberately misrepresented
scientific facts to protect their interest in supporting fluoridation of drinking
water, at whatever cost, including potentially grave implications for public
health.
In summing up the Expert Body has sought to undermine in a disturbingly
inadequate & disproportionate response the quality of research undertaken
and information presented by the Author of the report titled Human Toxicity,
Environmental Impacts and Legal Implications of Water fluoridation.
When one looks at the huge amount of scientific information now available
which highlights the associated risk of silicofluorides and fluoride to illhealth it is
no wonder that the Ministries for Health in every other European Country have
followed the precautionary approach to preventative healthcare and
avoided implementing or ended water fluoridation.  In the UK, the only other
EU country that supports water fluoridation less than10% of the population
drink fluoridated water and their legal courts have found the practice to be in
violation of EU law. In Europe the European Courts of Justice have ruled that
fluoridated water  may not be used in the preparation of any food or
beverage, nor may such food or beverage made with fluoridated water be
exported to the European Union until it undergoes proper pharmaceutical
scrutiny and is regulated as a medicinal product in the European Union.
It is evident that the Irish Expert Body has failed to produce any significant
evidence of scientific misrepresentation or untruths by the Author of this
report. They have failed to communicate in any reasonable manner with the
author and only acted to discredit him in the press and in recent
communications to local authorities and public representatives by
questioning his ability as a scientist and researcher.
In their review the Expert Body has demonstrated their own ability to misread
scientific research, which has been clearly demonstrated with illustrated
examples in this rebuttal.  It is obvious from the detailed evidence based on
current scientific knowledge presented in the report by Waugh  more
accurately represents the reality of the complex chemistry involved in  the
addition of hexafluorosilicate acid to drinking water and the potential health
risks associated with this practice for the public in Ireland, in comparison to
those presented by the Expert Body.  There is a clear danger that the
groupthink mentality that appears to exist within the Expert body presents a
very real risk for the health and welfare of the citizens of Ireland. History has
demonstrated that such organisations can become narrow minded and
close their minds entirely too alternative viewpoints or information and
thereby show themselves to be reluctant to change.  The fact that this
organisation remains alone within European Nation States in continuing to
support such an unnecessary policy is perhaps reflective of this overall
intolerance to change. Appendix 2 Parliamentary Questions
Page 41
Deputy Maureen O Sullivan T.D.
DÁIL QUESTION 1282 addressed to the Minister of State at the Department of
Health (Ms. Shortall)  by Deputy Maureen O'Sullivan  for WRITTEN ANSWER on
18/04/2012.
Question:
To ask the Minister for Health if he will cease the fluoridation of drinking water
until the Department of Health can provide evidence to demonstrate that
the silica fluoride compounds used for water fluoridation have been tested for
human safety and environmental toxicity in accordance with international
and EU law; and if he will make a statement on the matter.
REPLY.
The Health (Fluoridation of Water Supplies) Act, 1960 provides  for the
fluoridation of public piped water supplies. This is achieved through the
addition of hydrofluorosilicic acid (HFSA) to the water.  The complete and
rapid reaction between HFSA and water produces hydrogen ions (which are
removed through a process called buffering),  silica (sand) and fluoride ions.
Consumers do not come into contact with HFSA as water from the tap
contains fluoride, not HFSA or fluorosilicates.  The balance of scientific
evidence worldwide confirms that water fluoridation, at the  optimal level,
does not cause any ill effects and continues to be safe and effective in
protecting the oral health of all age groups. There are no plans to discontinue
the policy of fluoridation of public water supplies, which continues to make
an effective contribution to oral health in Ireland.
Deputy Catherine Murphy T.D
DÁIL QUESTIONS 194 and 195 addressed to the Minister of State at the
Department of Health (Ms. Shortall) by Deputy Catherine Murphy TD. for
WRITTEN ANSWER on 23/05/2012.
Question
To ask the Minister for Health if he will confirm if the fluoridation chemicals
administered in drinking water has been tested to determine if they meet the
requirements of EU legislation for the protection of public health and the
environment; and if he will make a statement on the matter.
Reply
The Health (Fluoridation of Water Supplies) Act, 1960 provides for the
fluoridation of public piped water supplies. This is achieved through the
addition of hydrofluorosilicic acid (HFSA) to the water. The complete and
rapid reaction between HFSA and water produces hydrogen ions (which are
removed through a process called buffering), silica (sand) and fluoride ions.
Consumers do not come into contact with HFSA as water from the tap
contains fluoride, not HFSA or fluorosilicates.Appendix 2 Misrepresentation of York Review
Page 42
Professor Trevor A. Sheldon
Head of Department
DEPARTMENT OF HEALTH STUDIES
Innovation Centre
York Science Park
University Road
York YO10 5DG
Tel: (01904) 435142
Fax: (01904) 435225
3/1/2001
In my capacity of chair of the Advisory Group for the systematic review on the effects of
water fluoridation recently conducted by the NHS Centre for Reviews and Dissemination
the University of York and as its founding director, I am concerned that the results of the
review have been widely misrepresented. The review was exceptional in this field in that it
was conducted by an independent group to the highest international scientific standards and a
summary has been published in the British Medical Journal. It is particularly worrying then
that statements which mislead the public about the review's findings have been made in
press releases and briefings by the British Dental Association, the British Medical
Association, the National Alliance for Equity in Dental Health and the British
Fluoridation Society. I should like to correct some of these errors.
1. Whilst there is evidence that water fluoridation is effective at reducing caries, the
quality of the studies was generally moderate and the size of the estimated benefit,
only of the order of 15%, is far from "massive".
2. The review found water fluoridation to be significantly associated with high
levels of dental fluorosis which was not characterised as "just a cosmetic issue".
3. The review did not show water fluoridation to be safe. The quality of the research
was too poor to establish with confidence whether or not there are potentially
important adverse effects in addition to the high levels of fluorosis. The report
recommended that more research was needed.
4. There was little evidence to show that water fluoridation has reduced social
inequalities in dental health.
5. The review could come to no conclusion as to the cost-effectiveness of water
fluoridation or whether there are different effects between natural or artificial
fluoridation.
6. Probably because of the rigour with which this review was conducted, these findings
are more cautious and less conclusive than in most previous reviews.
7. The review team was surprised that in spite of the large number of studies carried out
over several decades there is a dearth of reliable evidence with which to inform
policy. Until high quality studies are undertaken providing more definite evidence,
there will continue to be legitimate scientific controversy over the likely effects and
costs of water fluoridation.
(Signed) T.A. Sheldon,
Professor Trevor Sheldon, MSc, MSc, DSc, FMedSci. Appendix 3 Dr Richard Sauerheber Ph.D.
Page 43
Dr. Richard Sauerheber
(B.A. Biology, Ph.D. Chemistry, University of California, San Diego, CA)
Palomar College, 1140 W. Mission Rd., San Marcos, CA 92069
Email: richsauerheb@hotmail.com  Phone: 760-744-2547
June 6, 2012
Response in Support of
Human Toxicity, Environmental Impact, and Legal Implications of Water
Fluoridation
Declan Waugh, Enviro Management Services, 2012
First, it must be made clear that ingested fluoride ion does not decrease dental caries
systemically. This has been amply demonstrated in the dental literature and the scientific
literature
Hellwig and Lennon,  Caries Research 38: 258, 2004;  http://fluoride-class-action.com/wpcontent/uploads/caries-research-systemic-versus-topical-fluoride.pdf; Zero, 1992; Rolla and
Ekstrand, 1996; Featherstone,1999; Limeback,1999; Clarkson and McLoughlin, 2000 as
reviewed in the 2006 National Research Council Report,
http://www.nap.edu/openbook.php?record_id=11571&page=16
and in conclusions published by the U.S. Centers for Disease Control that systemic fluoride
does not benefit teeth (Morbidity and Mortality Weekly Report, August, 2001).  Moreover,
not only does ingested fluoride not decrease caries, ingested fluoride cannot decrease caries,
even topically, because fluoride that filters into saliva from the bloodstream (which averages
0.21 ppm in residents of 1 ppm fluoride water cities) is only approximately 0.02 ppm (NRC,
2006, p. 71), unable to influence teeth surfaces as can fluoride  in pastes (1,500 ppm) and
highly concentrated gels. This demonstrates that the process referred to was ‘water
fluoridation’ to treat dental caries by taking fluoride ion internally through ingestion in
humans squanders public funds.
Although many presume  otherwise, the EPA does not regulate or promote the infusion of
fluoride compounds into public water supplies (NRC, 2006, p.18; personal letter from U.S.
EPA, Office of Drinking Water, 2012). Instead, fluoride is correctly regarded by EPA as a
contaminant in water that must be kept below levels estimated interim to help minimize the
known pathologic effects of long-term ingestion of fluoride. Further, the U.S. Food and Drug
Administration correctly ruled in 1963 that fluoride is not a mineral nutrient and when added
into water is an uncontrolled use of an unapproved drug. Synthetic industrial fluoride
compounds lacking calcium are all listed toxics in poisons registries with an LD50 in
mammals of 125 mg/kg single oral dose (Merck Index, Rahway, N.J., 1976), while natural
calcium fluoride is not a listed toxic, where calcium minimizes assimilation of fluoride from
the GI tract and is the antidote to fluoride poisoning.
  Ingested fluoride is now known to incorporate into the bloodstream by virtue of first forming
the membrane lipid soluble agent hydrofluoric acid HF in the acidic stomach. HF is freely
permeable across cells membranes, while the fluoride charged ion is not. After assimilation,
at the alkaline pH of blood and interstitial fluid, HF largely re-dissociates to the free fluoride
ion. The trace levels of HF that remain in blood can be calculated with the Henderson
Hasselbach equation for an aqueous solution buffered at physiologic pH 7.4, an average blood
fluoride level of 0.21 ppm, and the dissociation constant for the weak acid HF of 6 x 10
-4
, and
is approximately 0.2 ppb HF.  Although 1,000 times less concentrated than the free fluoride
ion in blood, HF, being 1 million times more lipid soluble than fluoride ion, is the form by
which fluoride enters intracellular fluid (Buzalaf, MA; Whitford, GM, Fluoride metabolism,
Monographs in oral science 2011;22:20-36). Appendix 3 International Comments on Report.
Page 44
Fluoride indeed is known from biochemical measurements to incorporate into brain and other
cells in man and animals and to alter intracellular structural components. In brain cells this
was a chief concern to the NRC committee because brain functional alterations can be subtle
and can go undetectable for long periods and are difficult to assess by experimental
measurement. In fact, human controlled clinical drug testing trials, required by the Food Drug
and Cosmetic Act for any chemical proposed to be used as an ingestible to be taken internally
the US., do not evaluate brain impairment in data submitted to the FDA for drug approval. It
is necessary thus to state clearly that there are no ‘robust’ studies on any ingestible fluoride
compound in humans to this date.
We now have data unknown at the time water ‘fluoridation’ began. Fluoride incorporation
into bone is permanent and irreversible, accumulating during lifetime consumption typically
to levels that weaken bone, rendering bone more subject to fracture, where bone
concentrations of 4,000 mg/kg lifetime in a 1 ppm treated city are more subject to fracture
than at lower fluoride intake levels. Most disturbing, published only months ago at the
Veterans Administration Health Care Center, Los Angeles, CA, PET scan direct observations
proved that systemic fluoride incorporates into atherosclerotic plaque in coronary arteries of
cardiovascular disease patients, the  leading lethal disease entity in the U.S. (Yuxin, et.al.,
Nuclear Medicine Communications, January, 2012).
Yes, the NRC Report did not have the objective of evaluating water fluoridation per se and
did not have the original intent of examining data published on safety and effectiveness, or
lack thereof, for water fluoridation levels at the widely used concentration of 1 ppm compared
to lower levels. However, it is false to claim the analysis and data reviewed only apply to
persons exposed to concentrations far higher than used in water fluoridation. Much data
published since 1993 were reviewed relevant to fluoridation, at 1 ppm, as controls to compare
effects found at 2–4 ppm and higher. It is also incorrect to claim that the NRC report only
applied to natural fluoride in drinking water. Both natural and artificial fluoride in water were
thoroughly investigated (NRC, 2006, pp. 14-15). The committee intention was to mainly
evaluate whether the EPA primary and secondary Maximum Contaminant Level interim
assignments from 1984 were achieving their stated purpose in the U.S.  NRC concluded
UNANIMOUSLY, yes unanimously, that the MCL and SMCL must be lowered because
current allowed levels are not protective of human health. This is because of the widely and
conclusively documented adverse pathology in those exposed to 2 and 4 ppm fluoride in
water, compared to lower levels (NRC, 2006, p. 6). Vast data in the scientific literature, some
reviewed in the NRC Report, prove that fluoride consumed long-term in humans at 1 ppm
causes pathology.  
In full agreement with the NRC committee consensus, the U.S. Health and Human Services
recommended January, 2012 that water fluoride levels not exceed 0.7 ppm  fluoride as a
temporary measure until official regulations can be established. The motivation for this
change is the glaring fact that as of 2004, 41% of U.S. children aged 12-15 have permanent
abnormal tooth fluorosis, with its enamel hypoplasia that is difficult and expensive to restore.
It is false to claim that calcium present in water with fluoride has no effect on fluoride
toxicology. In fact, calcium fluoride is not a toxic compound and has a safe high LD50 of 3-
5,000 mg/kg (Merck Index, 1976), while all fluoride compounds lacking calcium are listed
toxics. As far as interest to human dental caries, the largest study we have is international and
very long-term in scope that demonstrated well that highest caries incidence occurs in
populations with calcium deficiency and high fluoride intake, while lowest caries incidence
occurs in regions with sufficient dietary calcium and low fluoride intake (SPS Teotia and M
Teotia,  Dental Caries: A Disorder of High Fluoride and Low Dietary Calcium Interactions
(30 Years of Personal Research), Fluoride 1994; 27(2): 59-66). It is widely known that
dietary calcium severely restricts fluoride assimilation form the GI tract into the bloodstream
(NRC, 2006). Dental journals routinely publish that high calcium diets cause 4 fold lower
plasma fluoride levels from drinking fluoride water, compared to diets low in calcium. For
this reason, calcium is the antidote to synthetic industrial fluoride poisoning. Calcium fluoride Appendix 3 International Comments on Report.
Page 45
is less soluble in water than the industrial synthetic fluoride compounds sodium fluoride and
fluorosilicic acid and can produce only about 8-10 ppm fluoride maximum, too low to induce
acute poisoning as can synthetic fluorides used as insecticides and rodenticides.
Levels of fluoride required to precipitate calcium ion from water depend on the prevailing
calcium concentration. Low levels of fluoride precipitate calcium at high concentrations,
where the solubility product constant for calcium fluoride is 5 x 10
-11
.   5 ppm fluoride in
blood is always lethal where the calcium concentration is about 80 ppm. Actual precipitates
of calcium fluoride however are not found in cases of human acute lethal fluoride poisoning
from water fluoridation overfeeds (Gessner, New England Journal of Medicine, 330, 1994).
Calcium uptake into heart tissue is blocked at this fluoride concentration that prevents heart
function because of calcium ion sequestration. The decreased mobility of the calcium ion is
an activity effect and does not require physical precipitation of the cation to be severely
pathologic. In the same way, fluoride tends to remain in aqueous solutions containing calcium
more than in solutions absent calcium, an effect that does not require precipitation of calcium.
This is consistent with the citation that calcium in water causes dissociation of fluorosilicic
acid far more quickly, in a minute, compared to the time required in the absence of calcium.
And yes, fluoride water would not cause calcium deficiency when dietary calcium is plentiful.
The idea that dental fluorosis with its associated enamel hypoplasia is an acceptable
alternative to tooth decay is a false choice.  First, fresh clean drinking water does not contain
either fluoride, sodium, or silicic acid. Fluoridation of water supplies with fluorosilicic acid
caustic soda mixtures typically produces about 1 ppm fluoride, 1 ppm silicic acid and 2-4
ppm sodium, again none of which belong in pristine fresh drinking water. Fresh normal
drinking water contains no sugar and does not cause teeth caries. Second, as above, ingested
fluoride systemically or topically does not interfere with caries, which are caused by sugary
foods that are not brushed which are substrates for bacterial acid production. Fluorosis is thus
unnecessary to induce, to fight and repair caries.    
It is appropriate now to grade the effectiveness and usefulness of the EPA regulations
imposed in 1984 on the fluoride contaminant in drinking water.  The MCL was set at 4 ppm
to help minimize development of severe toxic effects in those exposed lifetime. The idea was
to minimize severe bone fluorosis, a bizarre painful condition that causes a person to be
unable to walk. The NRC reported that severe debilitating skeletal fluorosis cases in the U.S.
are extremely rare and this particular adverse pathologic effect caused by fluoride was
basically achieved. However, we now know that 4 ppm fluoride in water lifetime leads to
10,000-12,000 mg/kg fluoride levels in bone, severely weakening bone making bone more
subject to fracture compared to consumption of water at lower fluoride levels. Because the
U.S. now has 1/3 million cases of hip fractures in the U.S. elderly, it is appropriate that the
NRC Committee request the MCL be lowered.
The failing grade for the MCL is also given due to the fact that severe dental fluorosis occurs
in significant abundance in children exposed to 4 ppm fluoride in water.  The severe form of
dental fluorosis is a permanent toxic poisoning effect on the damaged teeth. The MCL, at the
time of the NRC review, appeared to prevent the incidence in excess of the intended 15%
amount, but this now may be a too low estimate of this condition in the U.S. Also, moderate
fluorosis afflicts an enormous number of U.S. children currently, and it is necessary to
understand that the NRC reviewed studies proving that this condition is not merely cosmetic,
but harmful. Moderate fluorosis on front teeth is detrimental to one’s appearance and can
affect one’s overall sense of well-being and likelihood of employability and is now known to
be associated with systemic pathology. 50% of all ingested fluoride is retained permanently in
bone lifetime, independent of water concentration consumed, and there is no concentration
low enough at which tooth fluorosis from systemic fluoride can exist without concurrent
massive accumulation of fluoride in bone. The vastly increased incidence of ‘moderate’
fluorosis with enamel hypoplasia (estimated in 2006 at 15% even at 2 ppm and far higher at 4
ppm) is itself an effect that should be restricted according to the original intent of the EPA
MCL under auspices of the Safe Drinking Water Act.  Appendix 3 International Comments on Report.
Page 46
Detailed well-controlled human clinical trials proved an elevated risk of nonvertebral
fractures after only 4 years of exposure to drinking water with the MCL fluoride level of  4
ppm. Also there was consensus that fluoride can weaken bone and increase fracture risk in
animals and man. The effect of fluoride on bone density observed in animal studies is fully
consistent with the human evidence (p. 7). Thus the MCLG, which technically was intended
to prevent any significant toxic effect in the exposed population, was never adequately low.
The current MCL does not protect U.S. citizens from the substantial occurrence of fluorideinduced bone weakening and fracture or from permanent abnormal tooth fluorosis with its
enamel hypoplasia, where the function of normal (non-fluoridated enamel hydroxyapetite) is
to protect underlying dentin and pulp from cavitation and infection.
The SMCL was set by EPA decades ago at 2 ppm for the purpose of minimizing, not just
sever toxicity, but any significant adverse effect on human health. In regards to the fluoride
contaminant, a provisional effect chosen for this purpose was severe dental enamel fluorosis,
to be maintained under 15% of the exposed population. Although this might have been
achieved if fluoride exposures were limited to water intake alone, or might have been
successful for healthy persons, this SMCL has failed. Fluoride in the U.S. from sources other
than water account for 30% of total  fluoride found in blood and add to the burden from
fluoride in water, which is the major but not the only source.  Also, many persons consume
far more water than the National average, those who work outdoors in heavy labor such as
field work, and athletes, and those with diabetes who consume twice as much water as
normal. As a result, existing fluoride water levels have led to the endemic of enamel fluorosis
of all forms that we now have in U.S. children. And as above, moderate fluorosis is a
significant adverse effect and is in fact defined as the first visible sign of systemic fluoride
poisoning, is a more appropriate SMCL endpoint.
Taken together the NRC could have been more adamant in requesting water fluoridation be
halted. Abnormal permanent tooth fluorosis, objectionable, unsightly and costly to restore,
increases in incidence in every city from fluoridation, without exception. But the NRC made
it clear their stated purpose was not to evaluate fluoridation at levels less than 2 ppm because
the actual purpose was to determine whether 2 ppm was an adequate level for the fluoride
contaminant to prevent significant adverse pathology, so no request on water fluoridation was
made. The NRC however is fully justified in concluding that the EPA standards must be
lowered because the health of American citizens is now compromised  by taking fluoride
internally through ingestion, mostly from  public water supplies, natural or by intentional
infusion of industrial synthetic fluoride compounds. Since water fluoridation leads to 57-90%
of the total fluoride concentration in the bloodstream, depending on the health of the
consumer and on water hardness and other factors, many on the NRC committee have chosen
to oppose fluoridation of public water supplies (personal communication, NRC committee
member).
The claim that aluminum fluoride interaction studies have published contradictory findings is
false. The presence of low level fluoride ion in water that also contains low levels of
aluminum ion causes enhanced assimilation of aluminum. There is no doubt about this effect
of fluoride on the uptake of aluminum which causes consistent, widely observed
accumulation of aluminum in brain tissue with dramatic alterations in the structure of cellular
components in brain:
Varner, 1998 http://www.actionpa.org/fluoride/aluminum.html ; Miu, 2003;
Bhatnager, 2002; Shivarajashankara, 2002 as reviewed in NRC, 2006, p. 218).
Because aluminum in the stomach at acidic pH competes with hydrogen ion for binding with
fluoride, and because the association constant for aluminum fluoride is far greater than that
for HF (also discussed in NRC,2006, p. 211), aluminum fluoride complexes  form, which,
being uncharged, are assimilated well. Free aluminum ion, not complexed with fluoride, is
not assimilated significantly after ingestion. (In fact for this reason many cities infuse
aluminum as an inexpensive method to clarify water supplies).  Fluoridation of water that Appendix 3 International Comments on Report.
Page 47
contains aluminum is a contraindication because of assimilation of aluminum that fluoride
causes.
  At the same time fluoride enhances aluminum uptake, aluminum itself also inhibits
assimilation of fluoride. Aluminum lowers the free fluoride concentration in the gut, due to
complexation, which interferes greatly with formation of HF. Normally at stomach pH, 50%
of ingested fluoride ion is converted to HF (Sauerheber, submitted to Journal of Toxicology
and Pharmacology, 2012), in  agreement with data at a pH below and above this pH (NRC,
2006, p. 268), and HF is then freely assimilated. HF, not charged fluoride,  freely permeates
cell membranes (Buzalaf, 2011) and is the form by which fluoride gains entry into the blood.
Charged fluoride ion is eliminated out the GI tract well. In the presence of aluminum found
infused into public water supplies, little fluoride is converted to HF and the fluoride that is
assimilated is mostly that complexed with aluminum. Most all fluoride would be assimilated,
as HF, if aluminum is absent. So it is correct to state that fluoride enhances aluminum uptake
(from zero) and that aluminum decreases fluoride assimilation (less than 100%), all at the
same time. The presence of aluminum helps keep fluoride as the charge ion rather than HF,
the assimilated form, while fluoride complexes significant aluminum, raising its assimilation
from otherwise essentially zero. The effects are relative, and both are observed. There is no
‘contradictory’ data set.
The claims that the fluoride-induced salmon collapse in the Columbia River have never been
confirmed is ludicrous. It is unethical to dump toxic industrial synthetic fluorides into fresh
waters in the U.S. to re-test whether the salmon will again collapse in the  Columbia. The
University of Oregon performed more than sufficient experiments that confirmed the
phenomenon, that prompted the Oregon State legislature to revoke mandatory fluoridation of
public water supplies in the State of Oregon (see Youtube video by Brent Foster).  Indeed,
fluoride at 1 ppm in the ocean is not toxic to salmon due to the presence of thousands of ppm
magnesium and calcium in the water.  On the contrary, fluoride at only 0.3 ppm in fresh soft
water lacking appreciable calcium narcotizes salmon brain.
All epidemiologic studies in which correlations are made in an attempt to promote the notion
that fluoride when ingested can affect caries are weak for many reasons. First, calcium levels
in the water that affect fluoride assimilation are not measured. Second, random variables
among humans in a population are vast that cannot be controlled except in clinical studies
with volunteers. The original suggestion by T. Dean and Gerald Heard ascribed to fluoride
what calcium can do, that is calcium helps build strong teeth made of normal hydroxyapetite,
fluoride only alters enamel to an abnormal structure. The original weak epidemiologic
correlations have been extensively analyzed with more thorough data published by
Zeigelbecker (reviewed in Connett,  The Case Against Fluoride, 2010), demonstrating the
wide scatter in the original Southwest cities and the complete absence of reduced caries as a
function of wide variation in fluoride concentration in water supplies.  Moreover, the original
fluoride treatments in the test cities Newburgh, N.Y. and Grand Rapids, MI are known to
have caused delayed teeth eruption in children.  There is no difference in caries incidence
when the age of the teeth is used in the analysis, rather than the age of the child. Sadly,
exuberant promoters of fluoridation labeled absence of teeth (due to delayed eruption) as
absence of cavities.  Controlled clinical trials data have not been done with volunteer human
subjects who agree to control diet and other confounding variables, that cannot be done in
observational or epidemiologic studies that have little place in the discussion of whether a city
or country should mandate fluoridation of public water supplies or not. Indeed, we agree with
the FDA that mass fluoridation of all water supplies where dosage cannot be regulated is
unacceptable when we now know that citizens, when educated about what causes caries
(sugary sodas, etc), are fully able to care for their own teeth to effectively minimize tooth
decay. The Waugh report includes data indicating that non-fluoridated European countries
compare favorably in caries incidence reduction to any fluoridated country in the world.
Richard Sauerheber, Ph.D.Appendix 3 International Comments on Report.
Page 48
Note: That tooth fluorosis is abnormal enamel and not a benefit is abundantly clear. Normal
teeth enamel is a crystalline glass-like hard substance but only forms when systemic fluoride
in the blood is very low. Fluoride in blood can produce abnormal enamel, as discussed
recently by dentists who have banned industrial fluoride form their practices long ago. Below
is an interesting discussion.
http://www.identalhub.com/article_enamel-hypoplasia-370.aspx
Hypocalcaemia is a specific  cause of  tooth enamel  hypoplasia. Recently evidence has
suggested that the etiology of enamel hypoplasia is highly specific. Enamel hypoplasia is seen
in children having disorders of calcium homeostasis. Low calcium level in serum is one of the
major causes of enamel hypoplasia.
Enamel Hypoplasia and Caries.  Enamel  hypoplasia is clinically significant not only
because it is disfiguring and the restorative treatment costly, but because it may affect caries
susceptibility. There was a strong correlation between hypoplasia in the teeth of British
schoolchildren and caries susceptibility. Out of a collection of 1,500 extracted teeth, 74% of
very hypoplastic teeth were carious, whereas 80% of the nonhypoplastic teeth were caries–
free. Caries has also been associated with hypoplasia in many parts of the Third World. There
is no information about the chemical composition of hypoplasia enamel so the exact reason
for its greater proneness to caries is uncertain, but it is possible that its irregularity and pits
may favor the development of more plaque compared with smooth well-formed enamel.
Enamel hypoplasia is due to many causes. It can be due to high fluoride level or due to some
medicines or if the child becomes ill when the teeth which are affected by enamel hypoplasia
are being formed. The treatment depends on degree of hypoplasia. Intially the composite
restorations are done and if it is more (i.e. whole of enamel is hypoplastic) then veneers or
crowns are indicated in later age when the teeth are fully formed.Appendix 3 International Comments on Report.
Page 49
Independent Reviews of Report
Dr. Richard Sauerheber
(B.A. Biology, Ph.D. Chemistry, University of California, San Diego, CA)
Palomar College, 1140 W. Mission Rd., San Marcos, CA 92069
Email: richsauerheb@hotmail.com  Phone: 760-744-2547
June 6, 2012
Human Toxicity, Environmental Impact, and Legal Implications of Water Fluoridation
Declan Waugh, Enviro Management Services, 2012
What I find important is that the U.S. National Research Council (NRC) review of about
1,000 fluoride studies, the Case Against Fluoride by Dr. Paul Connett review of 1,154 studies
and the Waugh review of 1,216 studies each have their own particular strengths.  For
example, the Connett text best delineates why ingested fluoride does not decrease dental
caries, with its good description of the detailed Ziegelbecker statistical analyses.
The Waugh review to me reveals the important concept that has been known to some for so
long but is denied by others, a point made in dramatic fashion, that genetic or other variations
in a particular population play an important part in determining the toxic effects caused by
chronic fluoride ingestion. The correlation of fluoridation in soft water sections of Ireland
with one of the worlds-leading incidence in epilepsy is particularly disturbing. To fluoridation
advocates, this merely justifies in their own mind that fluoride intake is 'not harmful' because
all fluoridated people in the world in their view should be leading the world in epilepsy cases
if fluoride actually induces or worsens the condition. What these advocates fail to grasp is that
genetic differences can pre-arrange for a particular organ system to be more susceptible to
fluoride in one person or a population group, while in another group a different organ system
may be affected with first clinical symptoms.
Fluoride, being ubiquitous throughout an organism after ingestion, and continuously altering
the normal structure of water by forming abnormal hydrogen bonding throughout an aqueous
solution, can be toxic to every physiologic process known depending on concentration,
duration and the genetic, anatomic and physiologic makeup of the particular individual.
African and Hispanic people are more susceptible to Alzheimer's incidence and it may be that
Irish and other peoples could be more susceptible to fluoride-induced epilepsy. The very
frightening problem this all represents is made far worse by the fact that this biologic
variability provides a cover-up for fluoride advocates who argue that unless fluoride does a
particular toxic effect in all subjects of a population, then in their mind it is nothing but a false
correlation.
The studies in Fluoride on the Justus horses and on alligators and the various species Spittle
identified with differing fluoride susceptibility come to mind. And I don't know how to
counter this widely held attitude, that unless all animals in a species are affected the same
way then what you are looking at is being caused by 'something else' besides fluoride. These
studies were well controlled and rigorously done, as also for example were the original
Waldbott studies revealing fluoride allergy in 1% of people. Advocates don't care about this
because they perceive it's either mistaken or accidentally caused, not by fluoride, or else the
% would be higher.  We somehow have to get across the truth about individual susceptibility
and biologic variability even within a particular species, but I don't know how, other than
what the Waugh review already does, simply presenting the true data and making judgments
about it.
Richard Sauerheber, Ph.D.Appendix 3 International Comments on Report.
Page 50
     24th May 2012
Dear Mr. Waugh
I welcome your identification of hydrofluorosilicic acid (and the silicofluorides)  as highly
dangerous compounds now widely added in public water supplies in the U.S. and the
Republic of Ireland even though they have never been adequately studied for their toxic
effects.
In the U.S. senior EPA personnel have found no evidence Silicofluoride (SiF) was ever tested
for adverse health effects.
120
,
121
(Fox 1999, Thurnau 2000). This was confirmed by the formal
decision on this part by the US National Toxicology Program in 2002, nominating SiF’s for
toxicological studies on animals because information on this topic was not sufficiently
established.
No data is yet available on the results of the toxicological study and as of 2007 no testing had
as yet begun despite the formal decision to proceed in 2002.
The NRC report, “Fluoride in Drinking Water...A Scientific Review of EPA’s Standards”
(NRC 2006) emphasizes the importance of such testing with questions about incompletely
dissociated [SiF6]2- end-products in human diets. It recommends study of silicofluoride
treated water (SiFW) of different hardness, mineral content, and silica native to the water,
taking into account the reversible equilibrium aspects of [SiF6]2- dissociation.
The most important finding we have on SiF when added to water; is that the biological effects
of ingesting water treated with these compounds are that lead from ANY environmental
source (industrial pollution, lead paint in old housing, lead in water, lead leached from brass
water fixtures) is ENHANCED by the residues from SiF’s.
Some of the neurotoxic and related effects associated with chronic ingestion of SiFW that
have heretofore escaped attention are discussed in the attached report I have included for your
attentions.
Roger Masters PhD
Research Professor of Government & Nelson A. Rockefeller Professor
Department of Government
Dartmouth College
                                               
120 Fox JC 1999 Letter from EPA Assistant Administrator, May 10, 1999 to Representative
Ken Calvert acknowledging EPA was not aware of any tests for toxicity of SiF treated water
121 Thurnau RC Letter from Chief of Treatment Technology Evaluation Branch of the Water
Supply and Water Resources Division of the EPA National Risk Management Laboratory to
RD Masters admitting EPA and National Environmental Effects Research Laboratory were
unable to find information on effects of silicofluorides on health and behavior. Nov 2000Appendix 3 International Comments on Report.
Page 51
28
th
April 2012
Mr. Declan Waugh's unbiased report has done what government has not.  His report identifies
the narrow fallacy about decay prevention versus widespread impacts to national ecosystems,
economics and health care costs.  In simple terms and clear language he proves it.  Drinking
water fluoridation has been re-framed in terms of the triple bottom line and due diligence.  To
any politician or sitting councillor facing spending decisions about real threats to the public’s
health, this work is the defacto primer about ceasing water fluoridation.  Well done, Mr.
Declan Waugh for the courage to follow the science and acting for humanity!    
Prof. Peter L.D. Van Caulart, Dip.AEd.,CES,CEI
Executive Director, Environmental Training Institute
Ridgeville, (Niagara) Ontario, Canada
etivc.org
(905) 892-1177
April 28, 2012
I understand that you are engaged in an evaluation of fluoridation of public water supplies as a
matter of policy. Let me urge you to consider thoroughly the scientific evidence that has been
published in the past two decades. In particular the meticulously researched and
comprehensive report of Mr. Declan Waugh deserves your careful attention.
I am a physician and biophysicist who has studied fluoridation for the last twelve years or so. I
have found much of the early scientific literature on effectiveness of fluoridation in prevention
of dental caries to be so faulty as to be misleading. And the appropriate toxicological studies
are simply lacking, while evidence of particular adverse effects of fluoride and
hexafluorosilicic acid continues to surface.
The report of Mr. Waugh, “Human Toxicity, Environmental Impact and Legal Implications of
Water Fluoridation”, is a supreme effort that succeeds in presenting a massive amount of
evidence of adverse effects of fluoride at exposures comparable to those encountered by
persons using fluoridated water. No responsible evaluation of fluoridation can fail to give it
careful attention.
Aside from the scientific and legal issues—aside from the conclusions that ingestion of
fluoride is not substantially effective and that exposure to fluoridated water carries
unacceptable risks—it must be said that fluoridation is unethical. It violates the requirements
of informed consent, monitoring of effects and option for the individual to stop their exposure.
In addition, given the existence of accessible and safe alternatives for preventing cavities, it
does not pass the test of the precautionary principle.
Respectfully,
James S. Beck, M.D., Ph.D.
Professor Emeritus of Medical Biophysics
University of CalgaryAppendix 3 International Comments on Report.
Page 52
29
th
April 2012
Fluoridation is illegal, unethical, unscientific and toxic
As coauthors of Fluoridation: Autopsy of a Scientific Error, Edition Berger, 2010, and experts
on the fluoridation issue, we have been impressed by the scientific quality of the report of Mr
Declan Waugh: Human Health Toxicity and the Environmental Impact of Water Fluoridation.
Dr Pierre Jean Morin, Ph.D. was one of the coauthors of the report prepared by the
Environmental Consultative Committee of the Quebec Environment Ministry that have put a
drastic end in 1979 to the Mandatory Fluoridation Act in Quebec: Fluoride, Fluoridation and
the Quality of the Environment, English version 1980.  We have obtained proofs that
fluoridation is using untested, unapproved, uncontrolled and unsanitary industrial chemicals
to treat populations against a disease, this is illegal and unethical.
Gilles Parent, ND.A. and
Pierre Jean Morin, Ph.D. in experimental medicine, former Research Director, Laval
Hospital,
Coauthors of Fluoridation: Autopsy of a Scientific Error
Gilles Parent, ND.A.
30, rue des Prés Verts, C.P. 598
Danville, QC, Canada
514-747-2259 or 819-839-1530
Gilles.parent-nd@bellnet.ca
Dr Pierre Jean Morin, Ph.D.
336, Rang Castor
Leclercville, QC, Canada
819-292-3045
Dr Morin is a renown scientist, you could find is curriculum in Who’s in the World

http://www.enviro.ie/Rebuttal_June_2012.pdf

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