A Commentary on Phe Bedford's Report on the Oral Health Survey November

PRESENTATION TO BEDFORD BOROUGH COUNCIL’S OVERVIEW AND SCRUTINY COMMITTEE

A COMMENTARY ON PHE BEDFORD’S REPORT ON THE ORAL HEALTH SURVEY NOVEMBER 2015 WATER FLUORIDATION: SAFE AND EFFECTIVE!? 2ND February 2016

Joy Warren, BSc. (Hons) Env. Sci. Coordinator, UK Alliance Opposed to Water Fluoridation

with contributions from Douglas Cross, BSc(Hons), PGCE, CBiol, MIBiol, EurProBiol Director, United Kingdom Councils Against Fluoridation

V.4

“The Committee wishes to point out that the fluoridation program does constitute medication and medication without parallel in the history of medicine.”

(Ref: USA House Select Committee on Chemicals in Food, Jan-Mar 1952, quoted in Exner and Waldbott, p.221.)

No obvious advantage appears in favour of water fluoridation as compared with topical application of fluoride. European Scientific Committee on Health and Environmental Risks (SCHER) 2011

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“If this stuff gets out into the air, it’s a pollutant; if it gets into the river, it’s a pollutant; if it gets into the lake, it’s a pollutant; but if it goes right straight into your drinking water system, it’s not a pollutant. That’s amazing.”

Ref: Dr J. William Hirzy (May 1999), former Senior VP of Chapter 280 of the National Treasury Employees Union and Senior Chemist at the U.S. Environmental Protection Agency Headquarters .

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The Author of this report graduated in 2002 with a BSc. (Hons) in Environmental Science. This was followed by two relevant scientific courses at the University of Warwick and a Certificate in Health and Nutrition from Plaskett International. Whilst working for the University of Warwick (2000-2010) she became interested in fluoridation studies (2003) and after a year’s research into the issue, decided that the addition of fluoride to drinking water was a problematical intervention. In 2005 she became a Director of NPWA (2005-2010) but now coordinates West Midlands Against Fluoridation (2010 - ) and has recently agreed to co-ordinate the UK Alliance Opposed to Water Fluoridation (2015 - ). She is also a long-standing member of Friends of the Earth and Greenpeace and helped to defeat the proposals for a 2 nd Coventry incinerator in 2010 after 5 years of campaigning.

Contents

Executive Summary 4

1. A Critique of Public Health England’s November 2015 Report on Oral Dental Health as it Relates to Bedford’s 5-year-olds 7

2. The Moral and Medical Ethics’ Aspects of Compulsory Medicine 19

3. How Water Fluoridation Violates Toxicological Principles 23

4. Relevant Fluoride Research 29

5. Our responses to the Answers Given to our Questions Asked of PHE 38 on 10 th November 2015

6. How Water Fluoridation Wastes Money 50

7. The Causes of Dental Decay 52

8. Worsening Dental Decay in Fluoridated West Midlands 56

9. Scotland’s Successful Childsmile Oral Health Programme 61

10. The Precautionary Principle 63

Appendices

A. Sound Bites About Fluoride and the Fluoridation Programme 65

B. Bioaccumulation and Bioavailability 69

C. The Nature of Fluoride and its Toxicity 70

D. The Negative Effect of Fluoride on Our Bodies 74

E. YARA UK Guidelines for the Handling of Hexafluorosilicic Acid 79

F. CAL Laboratory Analysis of Hexafluorosilicic Acid 82

G Evidence-based medicine (EBM) 83

H T-F Index and Dean Index of Dental Fluorosis 84

I Why fluoridated water is an illegal product 85

References 89

Executive Summary and Concluding Statement

1. This report initially deals with the statistically insignificant findings of the Bedford Dental Health Impact Study for five-year-olds and which was presented to Bedford’s O&S Committee on 10 th November 2015.

2. Citing this PHE Report in Section 1, we show that the evidence for fluoride preventing children’s tooth decay is weak. The statistical methods used to attempt to justify fluoridation are transparent and whilst the bar charts seem to show that dental decay has marginally worsened since 2009 when fluoridation ceased in Bedford Borough, the Confidence Level Indicators tell a completely different story: dental decay has not worsened since fluoridation ceased in Bedford in 2009. The size of the sample was inadequate and throughout the PHE report the author is at pains to explain that the results are not statistically significant.

3. In Section 2, we move on to discussing the worrying lack of morality and medical ethics found in the practice of water fluoridation. Is it immoral to fluoridate the unborn child, the infant, baby and young child? Our analysis of the current opinions in Section 3 relating to safety factors and No-observed-adverse-effect level (NOAEL) shows that fluoridated infants and babies are being heavily overdosed.

4. If fluoride is not essential for good teeth, is it harming us? Section 4 lists and summarises recent research which cautions us to apply the Precautionary Principle (Section 10) when considering any proposal to fluoridate the public’s drinking water.

5. We felt that it would be a good idea to include a Section (Section 5) on the questions put to Dr Francis on 10 th November together with her replies and our responses since many of her answers have given us cause for concern.

6. We then move on (Section 6) to highlighting the terrific waste of public money of fluoridation programmes. We demonstrate that not only is a mere 4% of the acid drunk (with 96% being diverted elsewhere and especially into the sewers and rivers) but the amount of capital outlay and on-going revenue costs cannot be justified for the sake of making a tiny percentage of the fluoridating acid – 0.3% or less - available to disadvantaged toddlers – the target group of fluoridation.

7. In Section 7, we review the causes of dental decay and concur that although disadvantaged small children are likely to disproportionately experience dental decay (often because of the neglectful and misinformed practices of their parents and guardians), there are other reasons for tooth decay, none of which can be mitigated by systemic fluoride.

8. Section 8 explodes the myth that fluoride taken systemically reduces dental decay amongst fluoridated UK communities and we present 3 newspaper articles which report on

the current position in the West Midlands. At the time of writing, the British Fluoridation Society has published a particularly interesting piece of text which states that systemic fluoride is now understood to be the least important mechanism for preventing dental caries since it is the fluoride which is in the oral cavity which remineralises teeth and not the fluoride which is in the pulp cavity and dentine. This could be a valuable hint that those regions which are heavily fluoridated and whose dental decay is definitely not under control are being subjected to the ‘least important mechanism’ which does not prevent dental decay but which causes Dental Fluorosis or dental fluorosis – a disfigurement which originates while our fluoridated children are very small or in utero . Does this not argue strongly against fluoridating the unborn child and the infant who have no teeth?

9. An effective alternative to water fluoridation is accessible to all local authorities and Section 9 compares non-Fluoridated Scotland with fluoridated New Zealand and shows how Scotland’s Childsmile programme is producing good results. Dental decay can also be reduced by chewing gum and syrup containing xylitol. (Ref: Council on Clinical Affairs, 2011)

10. With so much controversy surrounding the practice of water fluoridation, the O&S Committee’s attention is drawn in Section 10 which discusses the Precautionary Principle.

11. We felt that no report would be complete without an explanation of why fluoridated water is an illegal medicine and an illegal product. Relevant law is explored in Appendix I.

11. We do not devote a section to summing up our conclusions but have instead chosen to make the following statement:

Concluding Statement

12. It is counter-intuitive and medically unethical to impose a developmental neurotoxin on every individual living in Bedford in the belief that fluoridation helps to remove dental health inequalities across social groups. This is clearly an erroneous belief as evidenced by the Open Letter to the Department of Health by the York Review Principle Researchers in 2002: see p. 35) and by the Cochrane Review (2015). We would like to point out that ‘belief’ is not ‘science’.

13. To date, we have seen no evidence of public support in Bedford for the re-introduction of the water fluoridation programme. Have any constituents written to Councillors urging that fluoridation restarts? Are they in the majority? This is an important question. At least two Local Authorities have turned down the fluoridation proposition in the past because of lack of public support: The London Assembly in November 2003 and Hull City Council in 1970. (Other English local authorities and Scotland have refused to fluoridate for other reasons.)

14. Moreover, recent research, and in particular the Bedford PHE Report, have failed to establish the case for systemic fluoride as a prophylaxis for the prevention of dental decay. Much dental decay is caused by factors which fluoride is ill-equipped to mitigate even if it were to be in contact with the surface of the teeth throughout the day and night. Surely it is the responsibility of those who promote fluoridation to conclusively prove that fluoride is effective. Despite their belief regarding fluoride’s effectiveness which is repeated ad nauseum , as discovered by the Cochrane Collaboration (2015) there is not one recent high quality piece of research which proves that dental decay is prevented by fluoride when taken internally.

15. Neither can we agree that fluoride is harmless in view of recent research which reinforces research which has been produced since the 1930s. We are acutely aware that fluoride was used as a highly effective treatment to dampen down over-active thyroid glands (hyperthyroidism) in the first half of the 20 th Century and this fact on its own strengthens our certainty that fluoride has a role to play in the onset of the under-active thyroid* (hypothyroidism). The cost to the NHS in treating hypothyroidism on its own is appreciable, but when we also have new research which indicates that ADHD is caused by fluoride, and that ADHD children, adolescents and adults are more prone to dental decay, the cost to the NHS escalates.

16. The deciding factor should be whether it is ethical to impose this compulsory medicine on a population when many people do not have any teeth or when, because they have matured tooth enamel there can be no further justification to impose the medicine. In any case, most adults self-medicate, i.e. they use fluoridated toothpaste, thus adding a factor to the mix which argues against Local Authorities spending money on financially wasteful fluoridation programmes.

17. Refraining from dosing our water with artificial fluoride – a developmental neurotoxin – would reduce NHS expenditure and, because we are convinced that fluoride causes ill health, its removal would make us a healthier nation. This is a goal to which we can all aspire. With alternative and available interventions available for reducing dental decay - interventions which are targeted and sustainable - there can be no excuse to resort to ‘medicating’ entire communities with a compulsory, hazardous by-product of industry which is contaminated with heavy metals.

Before launching into the rest of this report, we recommend a read of Appendix A which starts on p. 65 and Appendix I which starts on p. 85. ______

* A recent Guardian article on fluoride gave fluoride the benefit of curing hypothyroidism. The journalist was mistaken, the error was pointed out to the Editor and a correction was printed a few days later. Source: http://www.theguardian.com/society/2015/dec/25/fluoride-water-supply-benefit-unproved-tooth- decay . This includes the correction. 6

Section 1 A Critique of Public Health England’s (PHE’s) November 2015 Report on Dental Health as it Relates to Bedford’s 5-year-olds

1.1 We start this report with PHE’s November 2015 Dental Health Report because it is the most recent UK survey of 5-year-old children’s dental decay. Moreover, it concerns an unusual situation: in 2008, Bedford was fluoridated but in 2015 it was not fluoridated. We are thus provided with a before and after snap shot. The Report deals with the question: has tooth decay increased since fluoridation ceased in Bedford in 2009?

1.2 Bedford Borough and parts of Bedfordshire were first fluoridated in 1974 at the request of the Health Authorities. In those days, the public was not consulted. In 2009, Anglian Water suspended fluoridation of Bedford because their fluoridation dosing equipment at Manton Lane Water Treatment Works came to the end of its life. Again, the public was neither consulted nor informed. Nor was the Strategic Health Authority informed that Anglian Water had taken this unilateral decision. The cessation of fluoridation was discovered in 2012 by an activist who fights against water fluoridation and the news soon spread. Unaware that Bedford was no longer fluoridated, Fluoride Free Bedford in 2011 succeeded in setting up a useful dialogue with the Borough Council. This has resulted in the issue being widely publicised within the Borough.

1.3 Public Health England is anxious for fluoridation to resume in Bedford but has first to gain the approval of Bedford Borough Council which would be financially liable for revenue costs. The issue is now before Bedford’s O&S Committee. At their most recent presentation to the O&S Committee on 10th November 2015, Dr Feema Francis presented PHE’s Report on the current state of oral health in Bedford. A comparison between the current dental health of non-fluoridated 5-year-olds and fluoridated 5-year-olds in 2008 is the main topic of the report.

1.4 One would have hoped that the Report would have provided substantive proof one way or the other regarding the efficacy of systemic fluoride. Unfortunately, unless one applies a critical eye to the Report, the layman could be persuaded to believe that the dental decay has worsened even though at 13 places in the text the authors state that their results are statistically insignificant! If the efficacy of fluoridation in Bedford cannot be proven, then other interventions (which would be targeted and sustainable, unlike fluoridation) ought to be considered even though they may initially appear more time-consuming or expensive. ~~~~~~~~~~~~~~~

1.5 The title of the PHE 2015 Report is “Dental health impact of water fluoridation in children living in Bedford Borough Council in 2008, 2009 and 2015”. The Report’s authors admit to only being able to provide statistically insignificant conclusions so it is very difficult to accept the applicability of the word “impact” in the title.

Ref: https://www.gov.uk/government/publications/dental-health-impact-of-water-fluoridation-in- children-in-bedford

1.6 We are told that the report provides us with provisional results only. However, the data which were analysed by the Report’s authors cannot be provisional: it would not be ethical to analyse provisional data and to present the analysis in an official report which is intended to persuade a local authority to re-introduce a health intervention which impacts on everyone’s health and freedoms.

1.7 Neither can the methods used to analyse the data be provisional since it is difficult to envisage why the authors would have used provisional methods of analysis when as professional statisticians, they would have opted for the best methods of analysing the data from the outset.

1.8 So, if the data cannot be provisional and the analytical methods for interpreting the data cannot be provisional, in which way is the Report provisional? Until (and if) we receive a revised report, we must accept this report as being a final report and deal with it accordingly.

1.9 However, it is our considered opinion that the presentation of the provisional report on 10 th November should have been delayed until PHE was satisfied that it had produced the final report.

1.10 How can firm decisions by the O&S Committee be made based on what is claimed to be a provisional report containing statistically insignificant conclusions?

1.11 In 13 places in the text, the results are described as being statistically insignificant . In other words, the researchers cannot demonstrate that dental decay has increased since fluoridation ceased in 2009.

Ref: pp. 1.4, 5.5, 5.6, 5.14, 5.21, 5.23 bis , 5.25, 6.1 bis , 6.3.1, 6.3.2, 6.4.1

1.12 Despite the slightly greater height of the coloured bars for 2015 in most of the bar charts, the confidence level (interval) bars ( I ) superimposed on most of the blue and red bars in the bar charts are more indicative of the true state of affairs than the height of the coloured bars. The I-bars display the minimum and maximum values in each data set (the range) and thus give a more accurate picture.

1.13 Compare this with the tops of the coloured bars. The tops represent the average (mean) or the centre value of each data set. Calculating the mean is a device often used by statisticians to influence the conclusions people make about the data.

1.14 In most of the bar charts in the Report, the I- bars for each pair of data overlap . Overlapping of the I- bars for the data sets for 2008 and 2015 means that no conclusions can be drawn from the data gleaned from the examination of five-year-olds’ teeth.

Fig. 1

Where the confidence level bars overlap, no statistically significant conclusions can be assumed. Ref: p. 21 of PHE’s Bedford 2015 Oral Health Report for 5-year-olds

1.15 Had the confidence bars in the pairs of data been in wide-spread positions and not overlapping (Fig. 2), then significant conclusions could have been be drawn from the data. For example:

Fig. 2

1.16 In order for the research findings to be significant, the confidence level bars must be separated by space between their lower and upper limits. This image has been created by the author of this report and does not appear in the PHE Report.

1.17 We are left with an uneasy feeling that although dental decay has not really increased in Bedford since 2008, Public Health England is not prepared to admit this. The Report is peppered with statements that the results were not statistically significant and yet in each of the summary sections it is claimed that there are differences between whatever is being measured in fluoridated and non-fluoridated water areas. Those who are advised by PHE consultants have been primed to expect that there will be differences and the coloured bar charts seem to confirm that there are 9

differences. But, the I-bars tell another story, viz. dental decay has not increased in Bedford since 2009 when fluoridation ceased.

1.18 So, to reiterate, PHE’s Report is remarkable in that it says two quite opposite things at the same time. It agrees that fluoridation improves dental health, then disowns its own conclusions.

1.19 Both the York Review and the Cochrane Collaboration Reviews of Water Fluoridation concluded that the evidence base for the effectiveness of water fluoridation is weak. If it can’t be proven to work, it can’t have any beneficial effects. Any such effects that may appear in the analysis are an indication of faulty data or analysis or the number of children examined were too few. Any effects which are discovered, having tortured the statistics (i.e. pseudo analysis) are entirely meaningless.

1.20 If the statistics have to be tortured in order to try to prove something is true, then the fact that the torture has taken place proves the opposite. In this case, that systemic fluoride does not prevent dental caries.

1.21 Children in the upper income group seem to have had more dental decay than found in this group in 2008. But again, our eyes are drawn to the tops of the coloured bars when they should be examining the overlapping I-bars. Since this discovery is at odds with most of the received wisdom of dental decay being more prevalent in the most deprived quintiles, further research is required in order to (a) interrogate this possible increase, (b) determine the existence of confounding factors and (c) establish the reasons why these children’s carers could be failing their charges. It’s just not good enough to single out this social group for comment and not to investigate further. (Ref: p. 22, Figure 7, IMD Quintile 5.)

1.22 An interesting hypothesis has recently been published and this relates to the increase in dental decay in babies brought up in households where the parents smoke . Although we are told that families in the most deprived group are more likely to smoke than families in the most affluent group, the inhalation of secondary smoke could equally be the reason for increased dental decay in the most affluent group sampled in Bedford in 2015. We are also aware that children with ADHD experience higher levels of dental decay. ADHD strikes all families – and not only those in Quintiles 1-3. More research is definitely required. Claiming that children in the upper income group are experiencing more decay because Bedford’s drinking water is no longer fluoridated is completely unsubstantiated.

Ref: Tanaka S. et al. (2015) Secondhand smoke and incidence of dental caries in deciduous teeth among children in Japan: population based retrospective cohort study BMJ 2015; 351:h5397 doi: http://dx.doi.org/10.1136/bmj.h5397

Broadbent, J.M., K.M.S. Ayers and W.M. Thomson (2004). “Is attention-deficit hyperactivity disorder a risk factor for dental caries? A case-control study. Caries Res. 2004;38(1): 29-33

1.23 Moreover, the number of children surveyed by PHE Bedford for the November 2015 Report (863) provides too small a sample for PHE to justify the reintroduction of fluoridation into the Borough. In order to provide robust data prior to attempting to impose the fluoridation policy, a sample of more than 1000 would seem to be indicated since this is the criterion applied by the researchers running the fluoridation project, Operation Catfish, in Cumbria. (The London Assembly in 2003 also sampled 1000 Londoners during a telephone poll.) Since no-one in Bedford has ever been consulted about water fluoridation, it would be difficult to justify fluoridation based on an inadequate sample of 863 5-year-olds, particularly since the statistics which seek to justify fluoridation are admitted as being statistically insignificant.

PHE’s Perceptions of Dental Fluorosis (PHE Bedford Report, Paras 5.26-5.28)

1.24 The report also provides 3 paragraphs on Dental Fluorosis and attempts to show that this enamel defect is of scant concern. How can it be of scant concern when numerous studies reveal that although TF2 is not as disfiguring as TF3 and TF4, TF2 is widely regarded by teenagers as unacceptable (see Appendix H). Ref: Marshman et al , 2008; Edwards et al , 2005; Hawley et al 1996; Alkhatib et ali, 2004 ). See 1.28 below for a further discussion regarding TF scores.

1.25 “As fluorosis severity increases (TF2 or greater), the rating of images [by teenagers] and perhaps the level of acceptance declines.” (Ref: Mcgrady. 2012)

We have copied below the relevant data relating to Bedfordshire ’s survey of Dental Fluorosis (which inexplicably is not part of Bedford PHE’s report) and compared the data with the table for Bedford found in Section 5.26 (p. 24).

1.26 The first thing to note from the 2015 Report is that the term “Dental Fluorosis” is interspersed with the term “white marks”. According to the British Dental Association, PHE and the British Fluoridation Society, Dental Fluorosis (DF) is a cosmetic issue. Attempts have been made in the past by the dental fraternity to make DF sound attractive. Indeed, according to them, there is nothing to be concerned about if your teeth are chalk-white or have attractive white spots. However, their

‘belief’ was blown by Baroness Hayman in 1999 when she stated ““We accept that dental fluorosis is a manifestation of systemic toxicity…” (Hansard 2014/99: WA 158.) Thus, any degree of Dental Fluorosis is too much Dental Fluorosis. No matter the degree, the body is being poisoned.

1.27 Whilst the Bedfordshire data (from which the Bedford data was extracted) shows that 77 12- year-olds were aware that they had significant aesthetic opacities (also known as Mild-Moderate Dental Fluorosis), there is no attempt in the Bedford PHE Report to tell Bedford’s O&S Committee how many Bedford 12-year-olds were included in this figure of 77. We are not even told the number of 12-year-olds who responded with “Yes, I have white marks” although it could be calculated but ... that’s not the point. This data should be provided since it clearly exists. We have to ask why it has not been provided to Bedford’s O&S Committee? Why has important data for Bedford not been divulged?

White marks’ survey: Bedfordshire figures 2008-09. (This table combines data from two tables in the Bedfordshire report.)

Pop . of 12 - No. Yes, I No, I don’t Don’t know if No Significant White year-olds in examined have have white I have white answer aesthetic marks not Bedfordshire white marks marks opacities significant marks 5,219 765 130 494 139 (18.2) 2 77 156 (20.4% (17%) (64.6%) (0.3%) (10.1%)

Source: http://www.nwph.net/dentalhealth/reports/12%20Yr%20Old%20White%20Marks%20-%202008_09.pdf

White marks’ survey: Bedford figures 2008-09 (p. 24 of the PHE Bedford Report) This data below is contained in the data above – but data on significant aesthetic opacities is missing! Why ?

Population of No. Yes, I No, I don’t Don’t know No Significant White 12-year-olds in examined have have white if I have answer aesthetic marks not Bedford white marks white opacities significant marks marks ? 240 ? ? ? ? ? ? 19.1% 58.9 21.6%

1.28 Significant aesthetic opacities: The conventional classification for dental fluorosis which is used by most dental researchers is the TF Index which describes 9 categories of DF. It would appear that “significant aesthetic opacities” describes the same disfigurement as Mild-Moderate Dental Fluorosis which becomes more unsightly with the passing years when the ‘attractive’ white marks become ugly brown marks. But it could equally apply to TF2. Even if such white marks are not objectionable now when the child is aged 12, as time goes on, TF2 white marks become brown opacities. The brown staining cannot be removed and this implies that it is the underlying dentine which may be stained. If stains can get into the teeth then so too can decay! (See page 15 for the section on dentine bombs and Appendix H 12

for the TF index and Dean Index.). Remediation (i.e. veneers) is not available from the NHS because dental patients have to wait for their permanent to stop growing and this is after the cut-off point for NHS treatment.

1.29 Until we know the definition of “significant” we will be forced to conclude that surveyed children have been worried about fluorosed teeth which are classified as TF2 – Questionable/Very Mild.

Dental Fluorosis

Photographs of Dental Fluorosis by Dr. Hardy Limeback and Dr. Iain Pretty, et al

TF Index of Dental Fluorosis (extract)

1.30 The conclusion in the PHE Bedford Report that “concern about fluorosis is very low” is not corroborated by the Bedfordshire statistics where 765 children were asked specifically about significant aesthetic opacities and where 77 children stated that they had the enamel defect. Moreover, where approx. 10% of the sampled 765 12-year-olds in Bedfordshire had significant enamel opacities, could this have meant that a possible 500, 12-year-olds out of the total of 5219 12-year-olds in Bedfordshire (including Bedford) had significant enamel opacities? How many of the possible 500 children lived in Bedford in 2009?

1.31 “It is clear from the results of this study that participants have a preference for white, blemish- free teeth . . . . As fluorosis severity increases ( TF 2 or greater), the rating of images (and perhaps the level of acceptance) declines which is in agreement with earlier work.” (Ref: McGrady, 2012).

1.32 77 (10%) out of 765 children were concerned and ticked the significant aesthetic opacities box. This is not “very low” (10%) and the gloss put on this disfigurement by Bedford PHE is completely unsupportable.

1.33 What is the purpose of this section of the PHE 2015 Report? Why is Bedford PHE trying to minimise the negative impact that Dental Fluorosis will have on these young people when they are adults? (See p. 31 for the Cochrane Review’s Key Results relating to Dental Fluorosis.)

1.34 Throughout the USA, approximately 41% of adolescents have Dental Fluorosis with 3% having moderate and severe DF. However, the percentage experiencing dental fluorosis in fluoridated areas is higher: 70-80%. TF2 scores and higher would, by implication, also be higher. Moreover, it is in the scientific literature that black and ethnic children are more severely impacted by Dental Fluorosis than white children. (Burgstahler, 1965):

“In a survey of children in grades 7, 8 and 9 in Central High School in Grand Rapids, Michigan (1ppm Fluoride) in the 17 th year of fluoridation, Russell (1962) reported that 19.3% of the white children of continuous residence had “fluoride opacities” while more than twice this percentage (40.2%) of the Negro children were similarly affected. Among the white children 6.6% had ‘very mild’ fluorosis and 1% had mild fluorosis. Among the Negro children the figures were 9.9% and 4.2% respectively.” Ref: http://fluoridealert.org/studies/dental_fluorosis01/ Marshall 2004; Locker 1999; Luke 1997

1.35 Dental Fluorosis negatively impacts enamel and the underlying dentine. Fluoride alters the mechanical properties of enamel: fluoridated enamel is harder but paradoxically more brittle due to 14

the incorporation of fluoride into the hydroxyapatite crystal matrix when the teeth are developing under the gum. Fluorosed teeth are difficult to drill and fill so future dental treatment threatens to be more expensive for those affected. Ref : Fejerskov O, Richards A, DenBesten P. (1996). The effect of fluoride on tooth mineralization. In: Fejerskov O, Ekstrand J, Burt B, Eds. Fluoride in Dentistry, 2nd Edition. Munksgaard, Copenhagen. pp. 112-152. http://cariology.wikifoundry.com/page/Dental+Fluorosis ; http://fluoridealert.org/studies/dental_fluorosis10/

Dentine Bombs and Fluoride Bombs 1.36 Due to the change in the mechanical properties of enamel, fluoride can be the cause of microcracks forming in the enamel, through which bacteria can pass, which can in turn leads to decay beneath the enamel that often cannot be detected by a dentist’s probe. The subsequent result can be what appears to be a very minute amount of decay in the groove of a tooth which hides a ‘bombed-out tooth’ beneath it which is known in dental circles as a ‘dentine bomb’. This is explained below in extracts from Dental Journal articles.

1.37 From Dental Sense : Fluoride bombs refer to large areas of tooth decay in the absence of cavities. … if fluoridated enamel is stressed repeatedly during parafunctional states, microcracks can appear, propagate and in turn “open the door” for cariogenic bacteria to access the organic component of teeth resulting in degradation of dentine and undermining of enamel, similar to traditional models. The difference being that teeth exposed to fluoride during formative years will not cavitate as early and the same stresses that caused the microcracks continue to fuel the spread of the carious lesion. Conceivably, therefore, fluoridation may help prevent dental caries caused by “acid attack”, but equally may now mask breakdown associated with “crack attack”! Ref: http://www.dentistmidland.com.au/dental-faqs/#26

1.38 From Shore Dental : There have been some unintended consequences of the introduction of fluoride into the water. The one of relevance to this document refers to the way in which decay operates within a tooth. Fluoride causes a tremendous increase in the hardness of the enamel (a decrease in the solubility of the enamel in response to an acid attack caused by plaque). Decay does not become so evident to the dentist as it did previously. Instead of the decay forming an open cavity which was easily visualised and easily felt by a sharp metal probe, decay now tends to start inside a tooth. This is because the bacteria and saliva can get through at the very fine crack on the surface (we call this the fissure) and commence decaying at the softer portion of the tooth inside called the dentine. As a result of this, the decay can go undetected for many, many years and ends up in what dentists refer to now as a ‘fluoride bomb’. The inside of the tooth is completely decayed and the outside looks fairly normal – sometimes there is a slight discolouration evident through the enamel, but often the decay cannot even be felt with a sharp metal probe – this is scary stuff to dentists because for decades we have relied on diagnosis of decay by feeling the softening of the enamel with a metal probe. We can no longer do this. Source: https://www.shoredental.com.au/

(Figures 7 and 8 not reproduced here.) Ref: http://www.fluorideresearch.org/404/files/FJ2007_v40_n4_p214-221.pdf

1.39 Could this be the reason why some large cavities materialise very quickly where before there seemed to be none?

Evidence-based Medicine and Patients’ Values, Expectations and Beliefs 1.40 We are aware that submissions to the O&S Committee have to be evidence-based. Current evidence (PHE Bedford 2015) is admitted as being statistically insignificant data. This cannot justify the re-imposition of water fluoridation on Bedford. But this is the ‘current, ‘best’ evidence’ that we have and it’s totally inadequate.

Appended below is an excerpt from Bedford’s JSNA.

Bedford Borough JSNA, Oral Health Recommendations

 Improvements in oral health should focus on reducing oral health inequalities by reducing the decay experience of 5 year old children, providing better access to dental services for young infants and for Looked After Children.  Improve oral health of Looked After Children  Implement Smoking Cessation Level 2 service within dental practices  Bedford Borough Council to ensure all commissioned oral health promotion programmes are evidence based.

Ref : Bedford Borough JSNA, Oral Health http://www.bedford.gov.uk/health_and_social_care/bedford_borough_jsna/developing_well/oral_health.aspx

1.41 We are assuming that ‘Evidence-based’ is the same as ‘Evidence-Based Medicine’ because in our view, fluoridated water is a medicinal water. Indeed, it is hard to envisage it as being anything else.

1.42 Evidence-based medicine needs to take into account patients’ values, beliefs and wishes . (See Appendix G.) Since water fluoridation is a Public Health measure which is imposed on the masses, all the individuals who make up the ‘mass’ ought to be consulted about their values, beliefs and wishes before water fluoridation becomes re-introduced. This is built into current fluoridation law for new schemes. But it is outrageous that the entire population of Bedford is to possibly have the decision taken out of their hands once more, even though their values, beliefs and wishes ought to be sought as advised by the accepted protocol for Evidence-Based practice.

1.43 Although there would be very few Bedford residents who would be angry at not having been consulted once the decision not to fluoridate had been made, there would be much anger if Bedford Borough Council were to unilaterally decide without public consultation that fluoridation has to be reintroduced. This would be similar to the situation in the 1970s when the decision to fluoridate was taken by the Health Authority without consulting Bedford’s residents. It was unethical then and it is unethical now. How can it ever be right that those who are possibly destined to have to drink fluoridated water for the rest of their lives may be by-passed yet again?

1.44 We live in a democratic society so everyone should have the opportunity to take part in deciding on the issue, particularly since it is a controversial issue and because this Public Health measure affects all individuals – their opinions, values, beliefs, knowledge, the health of their bodies and human rights.

1.45 Summing up this Section, the case has not been proven for the reintroduction of fluoride into Bedford’s drinking water and the protocols for Evidence-Based Medicine stipulate that patients’ values, beliefs and wishes must be taken into account. Fluoride is an acknowledged agent of systemic poisoning. Children who have Dental Fluorosis will develop brown-stained teeth which are difficult and costly to remediate. DF is an enamel defect and such teeth are difficult to drill

and fill due to the alteration in the mechanical properties of the enamel and underlying dentine. Dentine bombs are hidden decay which develop because of micro-cracks in enamel which occur because of the alteration caused by fluoride in the mechanical properties of enamel.

1.46 We now move onto the issue of ethics and morality.

Section 2 The Moral and Medical Ethics’ Aspects of Compulsory Medicine

(Adapted from Blount, P.C. (1964). Compulsory Mass Medication: A Factual Guide to the Fluoridation Issue. London: The Clair Press.

2.1 “For centuries, the men and women of Britain have enjoyed, as a right, the freedom to choose the form of medication they prefer for themselves and their children. That freedom is a precious heritage even though it may be taken for granted. The present proposal for adding fluoride back into Bedford’s drinking water after a break of 6 years means that we are being asked to surrender a part of that heritage and have a little of our freedom replaced by the dictator’s method of compulsion. Granted that it will be the benevolent Big Brother compulsion of Whitehall and not that of North Korea, but it will be dictatorship none the less!

2.2 An amazing number of red herrings have been drawn in written and oral debate on the subject of fluoridation, leading to much waste of time, heated argument and even derision and personal abuse of those who are against the idea of compulsory mass medication. Some people have confused both themselves and others by starting with the assumption that there is only one matter to be considered when, in fact, there are three: (1) the moral aspect of fluoridation, (2) the material aspect of fluoridation – including the medical, scientific, practical and economic considerations and (3) the legal aspect. If chairmen of committees would insist on these three aspects being dealt with separately, and in the order given, conclusions would be reached more quickly and with less friction. 19

2.3 The essence of the moral issue can be summed up in this question : Is it right, when no question of contagion is involved, to medicate people en masse , compulsorily, and in a manner which is objectionable to some? One does not need to go to doctors, dentists, water engineers, lawyers or any other specialist for guidance about this. One need go no further than one’s own conscience and an understanding of the Golden Rule of doing unto others as one would be done by.

2.4 In considering the moral aspect of fluoridation, the question of precedent inevitably arises. Once the principle of compulsory mass medication has been accepted, the individual will find himself deprived of a long-established right and the door will have been opened for all sorts of unpredictable things in the future.

2.5 Seeking to justify their case, the proponents of fluoridation argue that the precedent has already been established by the fact that many things are added to mains supplies of drinking water. If this is true, then they must say (a) precisely what these things are and (b) why they are being added. They will be led to the inevitable conclusion that all chemicals bar one (fluoride) are added to treat the water and not the consumer and thus there is no precedent. Moreover, even though it is true that compulsory mass medication is already being carried out in the country, this, in itself, would not seem to be a valid argument for extending the practice. On the contrary, it could be a very good reason for considering ways of bringing the practice to an end.

2.6 So much for the moral aspect of fluoridation. If having, carefully considered this aspect, one reaches the conclusion that it cannot be supported on moral grounds, that would surely bring one’s deliberations to an end, for no responsible person would support a measure which he considers to be unethical, no matter how attractive it might otherwise appear to be. If on the other hand, one reaches the conclusion that the practice of using mains water supplies as a vehicle for medication is ethical, then one must turn one’s attention to the material aspect.

2.7 Since no layman could possibly decide on the material aspect without guidance, he must turn to those specialists whose integrity, personal experience and first-hand knowledge of the issues involved qualify them to speak on the subject. Since these specialists are most divided in their opinions, the layman must then decide by which group he is going to be guided – those who are in favour of fluoridation or those who, for biological reasons, are against it.

2.8 If one does not mind taking risks with one’s own life and the lives of others against their wishes, then one may be prepared to accept the guidance of those specialists who are in favour of fluoridation. On the other hand, if one’s understanding of the Golden Rule causes one to be against taking risks with other people’s lives, then one will undoubtedly be guided by those specialists who are against fluoridation.

2.9 It’s as simple as that!” ~~~~~~~~~~~~~~~~

NHS Constitution and Medical Ethics

Source: http://www.instituteofmedicalethics.org/website/

2.10 The NHS Constitution states that individuals with ‘capacity’ can refuse all medical treatment advised by their GPs/Hospital Consultants.

2.11 ”You have the right to accept or refuse treatment that is offered to you, and not to be given any physical examination or treatment unless you have given valid consent.”

Ref : https://www.gov.uk/government/publications/the-nhs-constitution-for-england/the-nhs-constitution-for- england#principles-that-guide-the-nhs , Respect, consent and confidentiality section.

2.12 The Chief Medical Officer (CMO) for England has a licence to practice as a GP. She has been told in the past that many people who have capacity object to being given a medicine compulsorily in their water supply which is impossible to avoid. The names and addresses of 2,000 objectors to compulsory mass medication have been provided to the CEO of the NHS at Richmond House since 2013 and the CMO has been advised that the CEO has these names.

2.13 To date, there has not been the courtesy of a reply from the CEO nor from the CMO for England. Why not? After all we have refused our informed consent and that should be enough to stop this unwise intervention.

2.14 Because it explains the issue better than that found in the BMA’s Code of Ethics, we’ve included an excerpt from the American Medical Association code of ethics:

“Opinion 8.08 - Informed Consent

The patient’s right of self-decision can be effectively exercised only if the patient possesses enough information to enable an informed choice. The patient should make his or her own determination about treatment. The physician's obligation is to present the medical facts accurately to the patient or to the individual responsible for the patient’s care and to make recommendations for management in accordance with good medical practice. The physician has an ethical obligation to help the patient make choices from among the therapeutic alternatives consistent with good medical practice. Informed consent is a basic policy in both ethics and law that physicians must honor, unless the patient is unconscious or otherwise incapable of consenting and harm from failure to treat is imminent. In special circumstances, it may be appropriate to postpone disclosure of information, (see Opinion E-8.122, "Withholding Information from Patients").”

Ref: http://www.ama-assn.org/ama/pub/physician-resources/medical-ethics/code-medical- ethics/opinion808.page

2.15 One important medical ethic states that a medicine should not be prescribed beyond the time when the medicine is no longer required . So why is fluoride still being sponsored and prescribed via the NHS/DH for an illness which is neither contagious, neither effective for the prevention of dental caries in adult dentition when taken systemically, and which is not needed by people who have none of their natural teeth? Moreover, adults were once supposed to benefit from systemic fluoride but that claim was dropped some years ago.

2.16 Dental caries is not infectious across whole populations and PHE has no justification for insisting that this preventative medicine is ingested by everyone in a population.

2.17 Fluoride is the only medicine given to us in our drinking water. There is no precedent in the UK of other medicines being given compulsorily in drinking water.

2.18 Most vaccinations are Public Health measures and are advised where there are infectious diseases around which could affect whole populations. But even in the case of vaccinations, we do not have to be vaccinated and parents have the right to refuse for their children to be vaccinated.

2.19 What strange quirk of logic mandated the medication of whole populations with fluoride and its accompanying 28 contaminants? (Appendix F) We cannot refuse to receive a medicine via our water supply. We are even taken to court if we refuse to pay our water charges if we object to being dosed with an unethical prophylactic which we don’t need. It is the author’s considered opinion that it is a criminal act to force medicines on whole populations without their consent. The Nuremberg Code was formulated to prevent excessive and criminal measures being taken by governments. PHE seems to have forgotten about the existence of that particular code. 22

Section 3 How Water Fluoridation Violates Toxicological Principles

3.1 Fluorine gas is acknowledged throughout the World as being a poisonous gas. Its ion, fluoride, is toxic. In the last few years we hear the term “developmental neurotoxin” being increasingly applied to fluoride. (Section 4 lists some of the relevant research.) Thus, as a toxin, fluoride falls to be considered under toxicological principles.

3.2 The most important toxicological principle relating to the addition or presence of a toxin in food (including water) and air runs as follows:

3.3 “...if we find harm in a human study (e.g. Dental Fluorosis) and wish to determine the level that would protect everyone in a large population from that harm, we take the dose which has been found to cause no harm (the no observable adverse effect level or NOAEL ) and divide that dose by 10 to give a safe dose (the safety factor) for the most sensitive individual in the population. (Alternatively, if there is no NOAEL, we have to use the LOAEL (the lowest observable adverse effect level) and divide that by 100.)

3.4 The units for the NOAEL are often expressed as mg per kg body weight per day. (mg/kgbw/day)

3.5 The Safety Factor (Safe Dose) is 1/10 th of the NOAEL.

3.6 Neither have anything to do with the concentration of fluoride in the water supply. We are concerned here with the amount consumed per day and that is why the units are different.

3.7 As an example, if the NOAEL is considered to be 0.1mg of a toxin per kilo body weight per day and where a person weighs 60 kg, then the NOAEL would be 0.1 x 60 per day = 6mg per day. However, in order to protect the most sensitive people in a population, the maximum allowable would be 6mg divided by the safety factor of 10 = 0.6mg per day.

3.8 Let’s now concentrate on fluoride intake by the most vulnerable members of our society – fluoridated bottle-fed infants. We have taken advice from the Department of Health and have been assured that the current NOAEL etc. is contained in COT Statement 2003/03 of September 2003. ( http://cot.food.gov.uk/sites/default/files/cot/fluoride.pdf ).

3.9 The relevant NOAEL was established in 2003 by the COT (Committee on Toxicity, Department of Health) with the intention that children do not go on to develop Stage 4 Moderate Dental Fluorosis in their Permanent Teeth. It is concerned only with the risk of developing Moderate DF in permanent teeth and Stages 1-3 DF are considered to be ‘cosmetic’ effects. Also any other health effects are not the concern of the current NOAEL. In any case, other adverse health effects which are caused by fluoride are not admitted to by the Department of Health.

3.10 A strange quirk in COT’s assignment of the NOEAL is that infants cannot be involved in the genesis of Dental Fluorosis because COT believes that the Permanent Teeth enamel organ doesn’t start developing until age 6 months. The consequence of this argument is that COT accepts that formula-fed infants under the age of 6 months can safely receive more than the NOAEL because they are not setting the body up for Moderate Dental Fluorosis:

“46. We note that the most sensitive effect of fluoride in humans appears to be dental fluorosis which occurs in children under the age of 8 years. A total fluoride intake of 0.05 mg kg bw/day represents a NOAEL for moderate (aesthetically significant) dental fluorosis.

48. We note that fluoride intakes of formula-fed infants may exceed the NOAEL for dental fluorosis, but consider that infants are at lesser risk because the critical time for development of aesthetically significant dental fluorosis is during formation of the permanent teeth.”

Ref. http://cot.food.gov.uk/sites/default/files/cot/fluoride.pdf , pp. 2-3, 11

3.11 COT’s opinion is therefore that an intake of 0.05 mg/kg bw/day is assumed to be a no observed adverse effect level ( NOAEL ) for M oderate Dental Fluorosis . However, the situation in the USA is slightly different: “... the American Dental Association now recommends that parents use non- fluoridated water for infant baby formula, while the Institute of Medicine recommends that babies only consume a minuscule 10 micrograms (10ppb) of fluoride daily, a near-impossible feat when babies are fed infant formula reconstituted with fluoridated water— even where levels are within the “optimal” range of 0.7–1 ppm.” (Ref: Barnett-Rose, p. 214)

3.12 From a dental text book, it appears that permanent teeth buds start to develop under the gums of the unborn child in the 4th month of gestation, not in the 6th month of life.

“For human teeth to have a healthy oral environment, all parts of the tooth must develop during appropriate stages of fetal development. Primary (baby) teeth start to form between the sixth and eighth week of prenatal development, and permanent teeth begin to form in the twentieth week .”

Ref. Ten Cate's Oral Histology, Nanci, Elsevier, 2013, pages 70-94

3.13 Moreover, permanent teeth develop further during the 1 st 6 months of life :

“The mesiobuccal cusp of the 1 st permanent molar begins its formation at about the time of birth .”

“ The early infancy period is characterised by the beginning of growth and calcification of the permanent 1 st molars and all the anterior teeth with the exception of the upper lateral incisors.”

“The 1st permanent molar is the first of the permanent teeth to develop . It begins to form and calcify at birth.”

“The permanent anterior teeth begin their formation at from 4-6 months of age in regular order from central

incisor to cuspid [canine ]. Upper lateral incisors begin formation at the end of the infancy period.”

Ref: Schour, I. (April 1941). “The Development of the Human Dentition.” The Journal of the American Dental Association, p. 1153-1160. www.ada.org/~/media/ADA/Publications/files/JADA_Centennial_April.Schour_1941.ashx

3.14 So the infant who has no teeth but who has developing Permanent Teeth calcifying buds under the gum is not protected by the NOAEL whilst the older baby from 6 months of age is protected.

3.15 Here is Section 43 of the COT opinion:

“Based on the results of an Australian survey of fluoride concentrations in infant formula, intake in formula-fed infants could exceed the threshold for aesthetically significant dental fluorosis. However, although dental fluorosis may occur in the primary teeth, this may not lead to dental fluorosis of the permanent teeth if fluoride intakes have decreased by the time of the development and maturation of the dental enamel of the permanent teeth. Therefore infants may be at lesser risk than children aged 3 to 4 years.”

3.16 No reference is provided for this opinion . So based on a ‘may’, the tiny infant is to be exposed to more fluoride than theoretically allowed for the 6-month-old baby! And note that dental fluorosis of the milk teeth is regarded as being acceptable even though permanent teeth being calcified under the gum in the new-born child would be within fluoride’s field of influence.

“The 1 st Permanent Molar is the first of the permanent teeth to develop. It begins to form and calcify at birth.” (Schour, op. cit.)

3.17 We are most concerned about the negative effect that fluoride has on the infant’s intelligence . (See Section 4 for relevant research on children’s reduced intelligence.)

COT has failed to apply a safety factor to its NOAEL.

3.18 Fluoride is a toxin so the safety factor should have been applied . However, in its rush to ensure that the 6-month-old baby gets its daily dose of fluoride to strengthen its teeth, the Safety Factor has been chucked out of the window! This is contrary to toxicological principles . At the very least the safety factor should be one-tenth of the NOAEL which in this case would be 0.005 mgF/kgbw/day.

3.19 Most full-term babies need between 150ml and 200ml of formula per kilogram of their body weight every day. We also need to consider that the infant’s bath water will contain fluoride at 1ppm. Hydrogen fluoride is absorbed through the skin and immediately enters the bloodstream meaning that it’s not prevented from becoming bioavailable which is what happens to 50% of fluoride in the stomach.

3.20 The following table demonstrates that all formula-fed infants are being overdosed with fluoride if they live in a fluoridated area and if their formula has boiled tap water added to it:

NOAEL = 0.05 mg F/kgbw/day Safety Factor = 0.005 mg F/kgbw/day

1. Infant’s weight 2. Volume in litres of formula fluoridated with 3. Daily dose of NOEAL Safety in kilograms 1ppm Fluoride fluoride 0.05 Factor 0.005 2.7kg (at birth) – (NOAEL = lower end of the 2.7 x 0.05 scale 0.372 0.372 mg = 0.135 0.0135 3.2 0.441 0.441 mg 0.16 0.016

3.6 (average birth 0.495 0.495 mg 0.18 0.018 weight in the UK) 4.1 at 1 mth 0.564 0.564 mg 0.200 0.020

4.5 at 2 mths 0.619 0.619 mg 0.225 0.023

5.0 at 2 mths 0.688 0.688 mg 0.250 0.025

5.4 at 3 mths 0.743 0.743 mg 0.270 0.027

5.9 at 4 mths 0.812 0.812 mg 0.295 0.030

6.4 at 5 mths 0.867 0.867 mg 0.320 0.032

6.8 at 5 mths 0.936 0.936 mg 0.340 0.034

7.3 at 6 mths 0.991 0.991 mg 0.365 0.037

7.7 at 7 mths 1.060 (formula and fluoridated water/drinks) 1.060 mg 0.385 0.039

8.2 at 8 mths 1.115 (formula and fluoridated water/drinks) 1.115 mg 0.410 0.041

8.6 at 9 mth s 1.183 (formula, fluoridated drinks and/or 1.183 mg 0.430 0.043 fluoridated commercial purée or boiled vegetables.) 9.1 at 9 mths 1.239 (formula and fluoridated drinks and/or 1.239 mg 0.455 0.046 fluoridated commercial purée or boiled vegetables.)

3.21 Taking the 5 month-old baby as an example, the baby’s weight is 6.4 kg and it drinks 0.867 kg baby formula per day which contains 0.867mg fluoride.

1. Infant’s weight 2. Volume in litres of formula 3. Daily do se of NOEAL 0.05 Safety Factor in kilograms fluoridated with 1ppm Fluoride fluoride 0.005

6.4 at 5 mths 0.867 0.867 mg 6.4 x 0.05 = 0.032 0.320

3.22 The NOAEL is 0.320 mg F/day and the Safety Factor brings this down to 0.032 mg Fluoride/day.

3.23 The baby is overdosing by a factor of 2.7 if the NOAEL is applied and is being overdosed by a huge factor of 27 if the Safety Factor is applied. The 5-month-old child should receive no more than 0.032 mg fluoride per day.

3.24 Babies fed on human breast milk do not overdose on fluoride although there will still be the factor of skin absorption from fluoridated bath water, and later from swallowed fluoridated toothpaste from 6 months of age and possibly from commercial purées which are made from fluoridated de-boned meat where the animals were reared in a fluoridated area.

3.25 Thus, all fluoridated babies are heavily overdosing on fluoride, especially if we accept that the Safety Factor should be applied to protect the most sensitive infants and babies in our society.

3.26 We conclude that the NOAEL is not protective of infants. Moreover, the Safety Factor has not been considered at all. Since fluoride is a developmental neurotoxin this failure of the COT not to apply the Safety Factor of 10 is criminal negligence.

3.27 HM Government refuses to reduce the level of fluoride down to 0.7ppm stating that “Public Health England advise that there is no current evidence from monitoring data to support a variation of the target level for fluoride in drinking water.” (Ref: Hansard HL4593, 15 th December 2015.) However, even if the concentration was to be lowered, babies would still be overdosed.

Fluoridated Toothpaste

3.28 From the age of 6 months, when the first tooth erupts, babies will be subjected to the added burden of fluoridated toothpaste although their consumption of fluoridated baby formula will start to reduce. Parents should add no more than a smear of toothpaste to the brush. It is so easy for babies to ingest toothpaste since they are not capable of refraining from swallowing. “The absorption of fluoride from ingested toothpaste, whether added as sodium fluoride or monofluorophosphate (MFP), is close to 100 percent.” (Ekstrand and Ehrnebo, 1980). Is the NOAEL protective of 6-month-old babies who inadvertently swallow their fluoridated toothpaste?

3.29 The following is a reminder of the pronouncements of the pro-fluoridation American Dental Association before it changed its position:

“A word of warning is thus offered to any plan to build caries resistance into teeth by addition of fluorides to public water supplies as a public health procedure ... The range between toxic and non- toxic levels of fluoride consumption is very small. Any procedure for increasing fluorine consumption to the so-called upper limit of non-toxicity would be hazardous. This would be especially true in the case of addition of fluorine to public food and water supplies where uncontrollable individual fluctuations in intake would be encountered.”

Ref: Smith M.C. and H.V. Smith (1944). Amer. J. Public Health, 30 : 1050 (1940); cf. Supporting editorials, J. Amer. Dent. Assoc., 27 : 1115 (1940); 31 ; 1360 (1944)

3.30 To summarise this section, if it is true that permanent teeth enamel begins to develop at birth, then the NOAEL which is designed to protect a 6-month-old baby’s developing enamel is not protective of the infant’s future permanent dentition. Is it not counter-intuitive for infants to be exposed to more fluoride per kilo/body weight than the older baby? Moreover, there is no safety factor applied which would protect the most sensitive members of society. Since fluoride is a developmental neurotoxin, the Department of Health must totally revise its policy of adding 1mg fluoride to each litre of drinking water so that formula-fed babies where fluoridated water is used to make up the formula are protected from Dental Fluorosis and from reduced intelligence (see Section 4).

3.31 Section 4 lists recent relevant research into fluoride toxicity.

Section 4 Relevant Fluoride Research: 2004

1. Peckham , S., D. Lowery and S. Spencer ( 2015 ). “Are fluoride levels in drinking water associated with hypothyroidism prevalence in England? A large observational study of GP practice data and fluoride levels in drinking water.” J. Epedemiol Community Health 2015; 0: 1-6

Summary: There was 30% more hypothyroidism in women aged 40+ living in fluoridated areas of England than in women of the same age living in non-fluoridated areas of England. There was almost double the amount of hypothyroidism in women aged 40+in the fluoridated West Midlands compared with women of the same age living in non-fluoridated Manchester.

This was an observational study. Although it didn’t examine individual women, each woman had had a diagnosis from her GP/Hospital Consultant.

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2. Choi A L, Sun G, Zhang Y, Grandjean P ( 2012 ). Developmental Fluoride Neurotoxicity: A Systematic Review and Meta-Analysis. Environ Health Perspect :-. http://dx.doi.org/10.1289/ehp.1104912

Summary : We performed a systematic review and meta-analysis of published studies to investigate the effects of increased fluoride exposure and delayed neurobehavioral development.

“The children in high fluoride areas had significantly lower IQ than those who lived in low fluoride areas,” write Choi et al.

After reviewing fluoride toxicological data, the National Research Council (NRC) reported in 2006, “It’s apparent that fluorides have the ability to interfere with the functions of the brain.”

Choi’s team at Harvard School of Public Health writes, “Fluoride readily crosses the placenta. Fluoride exposure to the developing brain, which is much more susceptible to injury caused by toxicants than is the mature brain, may possibly lead to damage of a permanent nature.”

Fluoride accumulates in the body. Even low doses are harmful to babies, to thyroid, kidney patients and heavy water-drinkers. There are even doubts about fluoridation’s effectiveness . New York City legislation is pending to stop fluoridation. Many communities have already stopped.

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3. Grandjean, P. and P.J. Landrigan ( 2014 ). “Neurobehavioural effects of developmental toxicity.” The Lancet Neurology , Vol. 13, Issue 3 , Pages 330 - 338, March 2014

Summary : Neurodevelopmental disabilities, including autism, attention-deficit hyperactivity disorder, dyslexia, and other cognitive impairments, affect millions of children worldwide, and some diagnoses seem to be increasing in frequency. Industrial chemicals that injure the developing brain are among the known causes for this rise in prevalence. In 2006, we did a systematic review and identified five industrial chemicals as developmental neurotoxicants: lead, methylmercury, polychlorinated biphenyls, arsenic, and toluene. Since 2006, epidemiological studies have

documented six additional developmental neurotoxicants—manganese, fluoride, chlorpyrifos, dichlorodiphenyltrichloroethane, tetrachloroethylene, and the polybrominated diphenyl ethers. We postulate that even more neurotoxicants remain undiscovered. To control the pandemic of developmental neurotoxicity, we propose a global prevention strategy. Untested chemicals should not be presumed to be safe to brain development, and chemicals in existing use and all new chemicals must therefore be tested for developmental neurotoxicity. To coordinate these efforts and to accelerate translation of science into prevention, we propose the urgent formation of a new international clearinghouse.

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4. Malin, A.J. and C. Till (2015 ) Exposure to fluoridated water and attention deficit hyperactivity disorder prevalence among children and adolescents in the United States: an ecological association.” Environmental Health , doi:10.1186/s12940-015-0003-1. Article URL http://dx.doi.org/10.1186/s12940-015-0003-1

Summary: ... this study has empirically demonstrated an association between more widespread exposure to fluoridated water and increased ADHD prevalence in U.S. children and adolescents, even after controlling for SES. The findings suggest that fluoridated water may be an environmental risk factor for ADHD. Population studies designed to examine possible mechanisms, patterns and levels of exposure, covariates and moderators of this relationship are warranted.

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5. Broadbent, J.M., K.M.S> Ayers and W.M. Thomson ( 2004 ). “Is attention-deficit hyperactivity disorder a risk factor for dental caries? A case-control study. Caries Res. 2004;38(1): 29-33

Another piece of research relating to ADHD that was published in 2004 is thought-provoking in the extreme. The 2004 research was a case-controlled study of children in Otago, South Island, New Zealand and explored the theory noticed in dental practices which suggested that children with ADHD tended to have a higher DMFT score than children without the condition.

“After controlling for fluoride history, medical problems, diet and self-reported oral hygiene, children with ADHD had nearly 12 times the odds of having a high DMFT score than children who did not have ADHD.” “No other factors were significant predictors. Dental practitioners and parents should consider ADHD to be a condition that may affect children’s dental caries experience.”

This suggestion is offered for consideration and further research is required: if fluoride causes ADHD and if children with ADHD have a greater risk for dental caries, then the extra financial burden incurred in looking after ADHD children and in treating their dental decay could tip the financial scales and argue against the introduction of fluoridated water in an area. Even if it is not possible to conduct a survey at this time into the percentage of ADHD children having teeth extracted under GA, the Precautionary Principle should be invoked (see Section 10 ).

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6. Sawan RM 1, Leite GA, Saraiva MC, Barbosa F Jr, Tanus-Santos JE, Gerlach RF (2010 ). “ Fluoride increases lead concentrations in whole blood and in calcified tissues from lead-exposed rats.” Toxicology . 2010 Apr 30;271(1-2):21-6. doi: 10.1016/j.tox.2010.02.002.

Summary : Higher blood lead (BPb) levels have been reported in children living in communities that receive fluoride-treated water. Here, we examined whether fluoride co-administered with lead increases BPb and lead concentrations in calcified tissues in Wistar rats exposed to this metal from the beginning of gestation. We exposed female rats and their offspring to control water (Control Group), 100mg/L of fluoride (F Group), 30mg/L of lead (Pb Group), or 100mg/L of fluoride and 30mg/L of lead (F+Pb Group) from 1 week prior to mating until offspring was 81 days old. Blood and calcified tissues (enamel, dentine, and bone) were harvested at day 81 for lead and fluoride analyses. Higher BPb concentrations were found in the F+Pb Group compared with the Pb Group (76.7+/- 11.0microg/dL vs. 22.6+/-8.5microg/dL, respectively; p<0.001). Two- to threefold higher lead concentrations were found in the calcified tissues in the F+Pb Group compared with the Pb Group (all p<0.001). Fluoride concentrations were similar in the F and in the F+Pb Groups. These findings show that fluoride consistently increases BPb and calcified tissues Pb concentrations in animals exposed to low levels of lead and suggest that a biological effect not yet recognized may underlie the epidemiological association between increased BPb lead levels in children living in water-fluoridated communities.

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7. Mullenix, P.B. (2014). A new perspective on metals and other contaminants in fluoridation chemicals. International Journal of Occupational and Environmental Health . Volume 20, Issue 2 (April–June 2014), pp. 157-166

Summary : Fluoride additives contain metal contaminants that must be diluted to meet drinking water regulations. However, each raw additive batch supplied to water facilities does not come labeled with concentrations per contaminant. This omission distorts exposure profiles and the risks associated with accidents and routine use.

Metal concentrations were analyzed in three hydrofluorosilicic acid (HFS) and four sodium fluoride (NaF) samples using inductively coupled plasma-atomic emission spectrometry. Arsenic levels were confirmed using graphite furnace atomic absorption analysis

Results show that metal content varies with batch, and all HFS samples contained arsenic (4·9–56·0 ppm) or arsenic in addition to lead (10·3 ppm). Two NaF samples contained barium (13·3–18·0 ppm) instead. All HFS (212–415 ppm) and NaF (3312–3630 ppm) additives contained a surprising amount of aluminum.

Such contaminant content creates a regulatory blind spot that jeopardizes any safe use of fluoride additives.

(See Appendix F for an analysis of Hexafluorosilicic acid (aka Hydrofluorosilicic acid)

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8. Fluoride Action Network ’s website section lists research on reduced human and animal intelligence caused by fluoride exposure. (www.fluoridealert.org/brain ). To activate the links, click on them while pressing Ctrl .

Over 100 animal studies showing that prolonged exposure to varying levels of fluoride can damage the brain , particularly when coupled with an iodine deficiency, or aluminum excess;

49 human studies linking moderately high fluoride exposures with reduced intelligence ;

34 animal studies reporting that mice or rats ingesting fluoride have an impaired capacity to learn and/or remember ;

12 studies (7 human, 5 animal) linking fluoride with neurobehavioral deficits (e.g., impaired visual-spatial organization);

3 human studies linking fluoride exposure with impaired fetal brain development.

Based on this accumulating body of research, several prestigious reviews — including a report authored by the U.S. National Research Council , a meta-analysis published by a team of Harvard scientists , and a review published in The Lancet — have raised red flags about the potential for low levels of fluoride to harm brain development in some members of the population.

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9. Cochrane Collaboration (2015). Water fluoridation for the prevention of dental caries. http://onlinelibrary.wiley.com/doi/10.1002/14651858.CD010856.pub2/full

Background Tooth decay is a significant problem worldwide affecting the majority of adults and children. Although levels of tooth decay have been decreasing in some communities (levels vary both between and within countries), generally children from poorer backgrounds (measured by income, education and employment) have greater levels of tooth decay.

Untreated tooth decay causes progressive destruction of teeth which is often accompanied by severe pain. This may lead to teeth having to be removed under local or general anaesthetic.

Fluoride is a mineral that prevents tooth decay. It occurs naturally in the soil, water and atmosphere at varying levels worldwide. Water can be artificially fluoridated (also known as community water fluoridation) through the controlled addition of a fluoride compound to a public water supply. Fluoridation is set at the 'optimum level', considered to be around 1 part per million (ppm).

Fluoride is also available in most toothpastes and can be provided as an extra preventive measure through products like mouth rinses, varnishes and gels.

An unwanted effect of fluoride use is the marking of permanent teeth (dental fluorosis) that is caused when young children, whose permanent teeth are developing, swallow excessive fluoride. This can range from mild white patches on the teeth to severe mottling with brown staining.

Review question This review was conducted to assess the effects of water fluoridation (artificial or natural) for the prevention of tooth decay. It also evaluates the effects of fluoride in water on the white or brown marks on the tooth enamel that can be caused by too much fluoride (dental fluorosis).

Study characteristics Researchers from the Cochrane Oral Health Group reviewed the evidence - up to 19 February 2015 - for the effect of water fluoridation. They identified 155 studies in which children receiving fluoridated water (either natural or artificial) were compared with those receiving water with very low or no fluoride. Twenty studies examined tooth decay, most of which (71%) were conducted prior to 1975. A further 135 studies examined dental fluorosis.

Key results Data suggest that the introduction of water fluoridation resulted in a 35% reduction in decayed, missing or filled baby teeth and a 26% reduction in decayed, missing or filled permanent teeth. It also increased the percentage of children with no decay by 15%. Although these results indicate that water fluoridation is effective at reducing levels of tooth decay in children's baby and permanent teeth, the applicability of the results to current lifestyles is unclear because the majority of the studies were conducted before fluoride toothpastes and the other preventative measures were widely used in many communities around the world.

 There was insufficient information available to find out whether the introduction of a water fluoridation programme changed existing differences in tooth decay across socio-economic groups.

 There was insufficient information available to understand the effect of stopping water fluoridation programmes on tooth decay.

 No studies met the review’s inclusion criteria that investigated the effectiveness of water fluoridation for preventing tooth decay in adults, rather than children.

 The researchers calculated that, in areas with a fluoride level of 0.7 ppm in the water, approximately 12% of the people evaluated had fluorosis that could cause concern about their appearance. [Note that it was 10% in Bedfordshire in 2008]

Quality of the evidence The review authors assessed each study included in the review for risk of bias (by examining the quality of the methods used and how thoroughly the results were reported) to determine the extent to which the results reported are likely to be reliable. This showed that over 97% of the 155 studies were at a high risk of bias , which reduces the overall quality of the results. There was also substantial variation between studies in terms of their results.

Our confidence in the size of effect shown for the prevention of tooth decay is limited due to the high risk of bias in the included studies and the fact that most of the studies were conducted before the use of fluoride toothpaste became widespread.

Our confidence in the evidence relating to dental fluorosis is also limited due to the high risk of bias and variation in the studies' results.

~~~~~~~~~~~~~~~

10. SCHER’s (European Scientific Committee for Health and Environmental Risks ) 2010 Report.

In the table, we read that fluoride exposure to the developing fetus occurs as a result of the maternal fluoride crossing the placenta. Since fluoride is a developmental neurotoxin, this would appear to be the way in which fluoride adversely affects the fetal brain. Fluoride is also found in amniotic fluid. Expectant mothers are not warned to avoid fluoride yet they are warned off drinking alcohol. This is short-sightedness by the NHS.

Note that the exposure to fluoride from drinking human breast milk is 200 – 250 times less than the exposure to drinking baby formula made up with fluoridated water.

The Scientific Committee in its 2011 Final Report (p. 4) states : “Systemic exposure to fluoride through drinking water is associated with an increased risk of dental and bone fluorosis in a dose-response manner without a detectable threshold. Limited evidence from epidemiological studies points towards other adverse health effects following systemic fluoride exposure, e.g. carcinogenicity , developmental neurotoxicity and reproductive toxicity; however the application of the general rules of the weight-of-evidence approach indicates that these observations cannot be unequivocally substantiated.” (My emphasis added.) Ref: SCHER (2011, p.4)

The identification of even “ limited evidence ” that fluoride may exert carcinogenic or developmental neurotoxicity effects should be ringing the alarm bells most vigorously in Bedford Council This warning is reinforced by Grandjean et al ’s identification of fluoride as an endocrine disruptor.

The emergence of understanding of nonmonatonic effects of such substances indicates that concern over these potential risks noted by SCHER must be raised to a much higher level. (“Nonmonatonic” effects refers to the non-linearity of dose-effect responses to toxic substances at extremely low concentrations. This occurs at concentrations that may be three, four or even more orders of magnitude below that at which overt, acute toxicity of the same substance appears to have declined to an insignificant level.)

~~~~~~~~~~~ 11. Three final pieces of evidence are more than 10 years old. However, they are included in the firm belief that the O&S Committee will not have been referred to them. Their existence is of great importance since they set the record straight. a. The table below is US data which was used to justify fluoridation. It’s from Trendley Dean’s et al paper on “Domestic Water and Dental Caries including Certain Epidemiological Aspects of Oral L. Acidophilus.” Pub Health Report 54, 862-88, 24 th May 1939 and is in Exner and Walbott (p.115):

Towns in Illinois Fluoride in ppm Carious Permanent Calcium in the water Teeth per 100 children in ppm Galesberg 1.9 194 62.2 Monmouth 1.6 208 65 Macomb 0.2 368 47.1 Quincy 0.2 628 28.2

Columns 2 and 3 show that dental caries increases as the concentration of fluoride decreases. But there is another factor in this report – that of decreasing calcium correlated with increasing caries. Calcium is good for teeth and bones. Which element reduces tooth decay? Fluoride or calcium? Why was this observation never picked up?

~~~~~~~~~~~~~ b. The 2015 research by Peckham et al of Kent University is included above at 4.1. The following information is of great relevance to the issue of hypothyroidism.

Hyperthyroidism, the euthyroid state and hypothyroidism lie on a continuum:

Hyperthyroidism The Euthyroid State Hypothyroidism

Over-active Normal Underactive

From evidence of medical practice of the 1930s – 1960s, an effective way of returning the over- active thyroid gland to normality was to give patients hot baths in which a carefully measured amount of a fluoride compound had been placed. Almost without exception, the treatment cured these patients. The fluoride was absorbed through the skin and dampened down the over-active thyroid. Some patients were not so lucky since if the treatment continued past the point when the Euthyroid state had been reached, they became ill with hypothyroidism. Worse still, the functionality of some of the patients’ thyroid glands was destroyed.

The initial difficulty was to accurately measure the volume of water added to a bath since baths vary in shape and size. Then great care had to be taken to add just the right concentration of the fluoride compound to the bath water. It would also be important to time the bath’s duration. The practice ceased when more convenient and more standardised drugs were developed. (Ref: Gorlitzer von Mundy, 1932)

We can now relate this medical practice to the discovery that women aged more than 40 in the fluoridated areas of England have 30% more hypothyroidism than their peers in non-fluoridated areas. The West Midlands shows an increase in hypothyroidism of almost double of that diagnosed in Manchester. These days, it is not just bath water which contains fluoride. Fluoride is everywhere and in the most unexpected places. For example, Pepsi Max is made from a concentrate using Rugby town water which contains 1ppm fluoride. A “traditional cider” sold by Sainsburys contains 0.5ppm fluoride because West Country apples are delivered to the food manufacturer as a concentrate. Naturally fluoridated water is added before it is canned. Fluoride is in the cement used to attach implants, veneers and crowns. (Ref: http://www.ncbi.nlm.nih.gov/pubmed/16515011 ).

White fillings (glass ionomer) contain fluoride. Teeth whitening preparations, toothpaste, mouthwash, fluoride varnishes, dental milk, fluoridated salt, fluoridated toothpaste and dental floss all have a liberal sprinkling of fluoride. Food manufactured in fluoridated areas or imported fruit from the USA all contain fluoride because fluoridated tap water and fluoridated pesticides are used to prepare and cultivate foods. Many pharmaceutical drugs contain fluoride, e.g. Prozac and Larium (Mefloquine). Fluoride is a major ingredient of Sarin gas.

Women deficient in iodide and who live in a fluoridated area and who are exposed to all or some of the sources listed above, are more likely to experience hypothyroidism than those women who are not exposed to fluoridated tap water, particularly if they enjoy long hot baths. So, it’s no wonder that the incidence of hypothyroidism is greater in fluoridated areas where the main avenue for exposure to fluoride is via their kitchen and bathroom taps. For a chronology of fluoride and the thyroid gland, we refer you to: http://poisonfluoride.com/pfpc/html/thyroid_history.html

~~~~~~~~~~~~~~ c. The Research Team Principals of the York Review (2000) wrote an open letter to the Department of Health in December 2002. The letter is appended here. Please note, in particular, Item 2.

4 YORK SCIENTISTS' OPEN LETTER

11th December 2002

Dear Minister,

We are scientists involved in the systematic review of evidence on the effects of water fluoridation, carried out by the NHS Centre for Reviews and Dissemination at the University of York. As far as we are aware, no other review of this topic is of comparable scientific standard, and we are concerned about some continuing misinterpretations of the evidence which could have implications for public policy. It is not for us to say whether the standard of evidence should be judged sufficient for a public health measure affecting whole populations, but we think it is important that decision makers are aware of what the review really found:

1. Effectiveness of fluoridation in reducing caries

We could discover no reliable, good-quality evidence in the fluoridation literature world-wide. What we found suggested that fluoridation was likely to have a beneficial effect, but in fact the range could be anywhere from a substantial benefit to a slight disbenefit to children's teeth.

2. Effectiveness of fluoridation in reducing inequalities in dental health across social groups

This evidence is weak, contradictory and unreliable.

3. Safety of fluoridation

Apart from an increase in dental fluorosis (mottled teeth) we found no clear pattern among the possible negative effects we examined, and we felt that not enough was known because the quality of the evidence is poor.

We append relevant extracts from the report of the review from which the conclusions under 1. and 2. can be substantiated. 3. covers too broad an area to summarise easily.

Since the report was published in September 2000 there has been no other scientifically defensible review that would alter the findings of the York review. As emphasised in the report, only high-quality studies can fill in the gaps in knowledge about these and other aspects of fluoridation. Recourse to other evidence of a similar or lower level than that included in the York review, no matter how copious, cannot do this.

We think these matters are important enough to bring directly to your attention, as well as to the notice of others who have a stake in public health policy.

Yours sincerely,

(SIGNED) Professor Jos Kleijnen Director, NHS Centre for Reviews and Dissemination

(SIGNED) Sir Iain Chalmers UK Cochrane Centre

(SIGNED) Professor Trevor Sheldon Head of Department Department of Health Sciences, University of York

(SIGNED) Professor George Davey-Smith Department of Social Medicine University of Bristol

[Ref: http://www.appgaf.org.uk/archive/archive_letter_york/ ] [APPGAF is the All Party Parliamentary Group Against Fluoridation]

Section 5 Our Response to the Answers Given to Our Questions Asked of Public Health England on 10 th November 2105.

Q1. Do the presenters consider themselves to be more expert than the internationally recognised and respected specialists who work at the York Centre for Dissemination or for the Cochrane Collaboration?

A. Feema Francis explained that she did not consider herself an expert like researchers involved in the two named research units and reminded Members of her role in providing support to local Public Health teams and NHS England locally on dental public health matters rather than purely on academic research or in teams involved in writing up systematic reviews.

Our Response : Has Dr Francis conducted a review on the reviews or has she just accepted their findings without question. Has she read the criticisms of some of the Reviews? If so, has she taken on board the criticisms of the reviews? If not, why not? Is she aware that researchers who conduct reviews are prone to bias?

~~~~~~~~ Q2. Do the presenters agree with those specialists that the evidence in support of fluoridation is so weak as to be worthless? If they don’t agree, why not, or is that merely their opinion?

A. Feema Francis reported that systematic reviews analysed research nationally and internationally using strict criteria for the inclusion of research with study designs which would help to answer the questions posed by the systematic review such as the effectiveness on reducing dental decay. The studies would be of high quality as they would need to meet the inclusion criteria. She confirmed that, nowhere in such reviews or studies had there been any mention that evidence in support of water fluoridation was so weak as to be worthless. In fact the systematic reviews support the fact that water fluoridation does have a dental health benefit.

Our Response: It is not unknown for the writers of some Reviews to be biased in their interpretation of results. Or, they may have deliberately omitted consideration of some research which fulfilled the strict criteria for inclusion but which had concluded that fluoridation did not improve dental health. Finally, sponsors of research often set parameters on the scope of the Review so that the researchers are not enabled to investigate “the elephant in the room”. This is indeed what happened with the York Review

whose brief was confined to human in vivo studies and to a very small range of illnesses. Animal and other toxicological studies were also excluded.

~~~~~~~~~~~~~ Q3. Why are the York Review and the Cochrane Review not referred to in the November 2015 document?

A - Members were informed that the Cochrane Review was included in the November 2015 document as it was published since December 2014. The summary report includes web links. The York Review was not included in the November 2015 document as the report only covered the research published since December 2014. The York Review was covered in a presentation in December 2014.

Our Response : There is no mention of the Cochrane Collaboration Report in “Dental health impact of water fluoridation in children living in Bedford Borough Council in 2008, 2009 and 2015”.

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Q4. Why is Public Health England not surveying the fluoridated population of England to ensure that they are not consuming more than 6mg of fluoride per day particularly since we know that ingested fluoride increases thirst and that this increases fluoride intake? The last Total Diet and Nutrition Survey for the United Kingdom showed that in fluoridated water areas, 70% of the population receive more fluoride in total than the Government considers good for them.

A. Feema Francis agreed to provide a written reply. [She denied that fluoride causes excessive thirst.]

Our Response: Where is PHE’s reply? However, the World Health Organisation recommends that: “ In setting national standards for fluoride or in evaluating the possible health consequences of exposure to fluoride, it is essential to consider the intake of water by the population of interest and the intake of fluoride from other sources (e.g., from food, air and dental preparations). Where the intakes from other sources are likely to approach, or be greater than, 6 mg/day, it would be appropriate to consider setting standards at a lower concentration than the guideline value. ” (Ref: WHO Guidelines for Drinking Water Quality, 2 nd Addendum to 3 rd Edition, Vol. 1 Recommendations, p. 48. )

The WHO seems to be stating that we should not be consuming in the region of 6mg Fluoride per day from sources other than water. So, if we were getting approx. 5.5mg from food and other sources (i.e. “approaching 6mg/day), then our intake of fluoride should be monitored in case it is appropriate to set standards at a lower concentration than the guideline value. 5.5mg + 2mg from water is 7.5mg and we consider that this is the absolute maximum. It’s probably too much for small adults. The DH has not commissioned recent research to monitor our intake to see how much we’re ingesting and absorbing. Surely Bedford Borough Council should insist on this monitoring exercise being undertaken in a fluoridated town before risking the health of its constituents?

Our response to the increased thirst issue

Regarding fluoride increasing thirst (and we’re not talking her of patients with diabetes mellitus having increased thirst):

“Other measurements in the table were from actual blood samples drawn from Hooper Bay, Alaska victims where fluoridated municipal water for which machinery malfunctioned poisoned 296 residents [in 1992]. Not mentioned is the increased thirst associated with heavily fluoridated water, a biologic response to this insult that was up to that time unknown.” (Ref: Sauerheber , 1999 : http://www.nofluoride.com/toxicity_of_fluoridated_water.cfm )

“Moolenburgh described abdominal discomfort occurring on a double-blind basis with exposure to fluoride. He found in his Dutch general practice patients with illnesses similar to those described by Waldbott. He considered that far from having exaggerated the side effects, Waldbott had, on the contrary, been inclined to under-statement. Although Moolenburgh expected to find an allergic basis for the adverse effects associated with fluoride, he considered that the symptoms represented poisoning with inhibition of the immune system by a toxic substance in sensitive persons. Where an exacerbation of illnesses with an allergic component such as eczema and asthma occurred, his view was that immune system inhibition by fluoride had resulted in a loss of the ability to cope with the allergy. Double blind testing with 60 patients showed that certain individuals were intolerant to fluoride and that exposure to this could reproduce gastrointestinal symptoms, stomatitis, joint pains, excessive thirst , headaches and visual disturbances.”

Source: http://www.drkaslow.com/html/fluoride.html

“Petraborg described a wide spectrum of symptoms in 27 persons exposed to fluoridated water. He considered that since none of the persons were aware that their drinking water was fluoridated or were familiar with the manifestations of fluoride toxicity, he felt that the accounts of their illnesses were equivalent in validity to those associated with double-blind procedures. He noted that several patients were not convinced that something in their drinking water was causing their illness and resumed drinking fluoridated water. Relapses of their illnesses followed. The symptoms included extreme chronic fatigue, excessive thirst , 40

general hives, headaches and gastrointestinal symptoms.” Source: http://www.drkaslow.com/html/fluoride.html

Waldbott states that “in other cases a well-recognized condition of polydipsia (excessive thirst) is present which is made “more pronounced upon drinking water”.

Ref: Waldbott , G.L. (1962). “Fluoride in Clinical Medicine,” Suppl. 1 to Vol. 20, Internat, Arch. Allergy Appl. Immulol., quoted in Burghstahler , A.W., “Dental and Medical Aspects of Fluoridated Drinking Water”, Transactions of the Kansas Academy of Science, Vol. 68, Nos 2 & 3, 1965.

~~~~~~~~~~ Q5. Has Public Health England realised that a substantial amount of fluoride is absorbed via the skin when we take hot fluoridated baths? Does Professor Newton acknowledge that this would increase the body burden of fluoride appreciably and probably increase it above the 6mg per day considered by the World Health Organisation to be the maximum?

A. Feema Francis reported that she is not aware that fluoride can be absorbed through the skin as stated in the question. If there was the potential that fluoride at significant levels or at levels which could cause harm then this would be reviewed in systematic reviews. Given the fact that it is unlikely that fluoride is absorbed through the skin and that systematic reviews or research has not been done in this area it is unlikely that absorption of fluoride from hot baths poses a significant health risk, for more or further research to be done in this area.

Our Response: Reviews can only review existing literature and existing literature may only be concerned with ingested fluoride or with in vitro studies which look at cells and organs as is often the case. It is clear that we use preparations on our skins which are intended to be absorbed, for example, Deep Heat and Raljex which penetrates the skin in order to believe muscle pain. So we know that the skin is able to absorb substances. We are more concerned here with the absorption of a fluoride compound which, when in water, could be in a dissociated state although many chemists regard hexafluorosilicic acid as not being completely hydrolysed.

Skin absorption is a very difficult effect to test using ethical methods of conducting research. However, we have strong evidence from the early part of the 20 th Century of Austrian patients with hyperthyroidism being cured using fluoride which was added to hot water for the patients to bathe in. The treatment was almost 100% successful. The only way in which hyperthyroidism could have been cured in these cases was by absorption through the skin. In the earliest test cases, the treatment was continued for too long and the patients experienced hypothyroidism and/or a damaged thyroid gland. When pharmaceutical drugs 41

were developed in the 1960s, hot fluoride baths were no longer used to cure hyperthyroidism.

“In 1932, Gorlitzer von Mundy, being aware that fluorides also get absorbed through the skin, began fluoride treatments of hyperthyroid patients in Austria by prescribing 20 minute baths containing 30ccm (0.03l) HF [Hydrofluoric acid] per 200 liters of water. He reported on his successful treatment spanning over 30 years and involving over 600 patients at a 1962 symposium on fluoride toxicity in Bern, also attended by other world-leading experts including George Waldbott."

Ref: B. Gorlitzer von Mundy V - "Ein neuer Weg zur Behandlung der Thyreotoxikose mit Fluorwasserstoffsäure" Med Klin 21:&17-719 (1932).

Citing a more extreme example, Material Safety Data Sheets include a section regarding the effect of spillages on skin of 20% - 30% solutions of Hexafluorosilicic acid. For example:

Ref: http://ffo-olf.org/MSDS_HFS_Solvay.html and ....

Ref: http://msds.redox.com/1976.pdf

Exposure and absorption can result in hypocalcemia since excessive fluoride in the body renders calcium non-functioning in bones, tissues and heart muscles. Without treatment with a calcium gluconate compound, death from heart failure occurs. The gel is not intended to treat burns but to prevent any absorbed fluoride doing any more damage to the underlying tissues. The problem with this treatment is that fluoride is rapidly absorbed and the application of the fluoride gluconate gel may be too late after 15 minutes.

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Q6. Does Public Health England acknowledge that fluoride is a developmental neurotoxin? (as per the Lancet Neurology March 2014, The Harvard School of Public Health 2012 and the Environmental Protection Agency USA Toxcast database).

A. Feema Francis explained that research as noted in systematic review does not indicate water fluoridation is a developmental neurotoxin. The Irish review published more recently reviewed the evidence for neurological effects of water fluoridation and did not find good evidence to support the view that water fluoridation could have neurological effects.

FFB Response: Reviews are only as good as the brief which they have been given by the sponsor who pays for the research to be conducted. If the brief did not ask for a Review of neurological effects, then the Review Team would not examine research literature regarding neurological effects. The Irish Review has been cited and this Review did actually look at research into neurological effects, including the effect on intelligence. We are aware that only research which is well designed met the criteria for the Irish Review. However, here is what the Fluoride Action Network has to say on the topic:

BRAIN

Fluoride’s ability to damage the brain is one of the most active areas of fluoride research today. Over 300 studies have found that fluoride is a neurotoxin (a chemical that can damage the brain). This research includes: Over 100 animal studies showing that prolonged exposure to varying levels of fluoride can damage the brain , particularly when coupled with an iodine deficiency, or aluminum excess; 49 human studies linking moderately high fluoride exposures with reduced intelligence ; 34 animal studies reporting that mice or rats ingesting fluoride have an impaired capacity to learn and/or remember ; 12 studies (7 human, 5 animal) linking fluoride with neurobehavioral deficits (e.g., impaired visual-spatial organization); 3 human studies linking fluoride exposure with impaired fetal brain development.

Source: http://fluoridealert.org/issues/health/brain/

So the “red flag” has been raised and while it is raised, we should observe the Precautionary Principle. ~~~~~~~~~~

Question 7. If fluoridation does indeed work as well as they claim, how come these results actually show that there is no difference between dental health in fluoridated and unfluoridated water areas? I’m referring to the 2015 Dental Health Survey for Bedford

recently published. The phrase in the survey document shows that there is no proof of statistical significance in relation to the 2015 Survey findings.

A. Feema Francis explained that, at no time up to 2008 did children receive 1ppm which meant that children during that time did not receive the optimal level. She explained that if level had been at 1ppm consistently there would be better dental health.

A cross-sectional survey did not allow direct conclusions to be drawn about the effects of water fluoridation. However it could be assumed that the trend of worsening dental health as shown by the slight increase of decayed, missing and filled teeth could be as a result of suspending water fluoridation as evidenced from around the world and systematic reviews would strongly point to the conclusion that water fluoridation improves dental health.

Statistical significance demonstrated whether a result had occurred by chance alone.

Basing a decision on statistical significance was not appropriate as consideration must be given to cost, practicalities of one intervention over another, the benefit an intervention had for the whole population consistently rather than a targeted prevention approach only and of course the evidence base from the majority of studies on water fluoridation etc. It was better to have an intervention that supported the whole population and as well targeted intervention for those in most need. As the survey was a cross- sectional survey and there were unknown factors which had not been measured or identified it was therefore not possible to state that there was no statistical significance when testing for water fluoridation alone. Other factors which would need to have been measured or identified as having a potential impact on the result and therefore studied, were for example, the concentration of fluoride in toothpaste used, frequency of toothpaste brushing, frequency of sweets/sugary drink consumption, frequency of consumption of drinking water as opposed to sugary drinks during the time when water fluoridation was present or immigration into Bedford Borough. Also the individuals within population would need to be surveyed throughout their lives as water fluoridation benefits all ages. There was no funding or time to do this. Therefore a cross-sectional survey was undertaken as this was conducted nationally throughout England. It was done to a specific protocol and examiners were trained to ensure everyone measured dental decay experience in the same way. As the protocol was strict, it was not possible to ask additional questions such as toothpaste concentrations or examination what was not in the protocol.

She also urged caution over the interpretation of significance testing as only a small number of children were surveyed rather than surveying a census sample or a sample of at least 50% of the population of five year olds may have altered the results as more children in the non- fluoridated and fluoridated areas could be surveyed.

Our Response: ‘Optimal fluoride’ is 0.7ppm in the USA, 0.8ppm in Ireland, 0.5ppm in Hong Kong and 0.7ppm in New Zealand. The Department of Health has refused to reduce the UK’s ‘optimal fluoride’. The 2015 Bedford report compared dental health in 2008 and earlier at a water fluoride concentration of 0.7 and higher in 2008 and in earlier years (para. 4.11) against a concentration of 0.25ppm in 2015. The ‘optimal fluoride’ of 1ppm was specified in the 1930s and 1940s in the USA when there was very little natural fluoride in a child’s environment apart from in the water and in vegetables irrigated with naturally fluoridated water. It was never suspected that fluoride would become far more commonplace in our environment. The ‘optimal’ concentration is no longer relevant.

Now that fluoride is everywhere in our environment, we have to acknowledge that even though Bedford children did not drink water at 1ppm in 2008 and earlier, they were most certainly exposed to fluoride from other sources such as fluoridated toothpaste, in the main. Rock and Sabieha (1997) reported that “highly significant associations were found between estimated fluoride ingestion from toothpaste and fluorosis”. Some canned and bottled drinks also contain fluoride if they are manufactured in fluoridated areas such as Rugby (1ppm). Children love lengthy hot baths and in 2008 and earlier, they would have absorbed fluoride through their skin. (We know that it can be absorbed through the lining of the mouth, so why should it not be absorbed through skin when the pores are open?) Therefore it is highly probably that they were being exposed to more than 0.7ppm during the early part of their lives. Where is the proof that there would have been better dental health in Bedford at 1ppm fluoride?

Is there a trend of worsening dental health in 5-year-olds? The size of the sample (863) is inadequate for PHE to make this conclusion.

Dr Francis stated that “Basing a decision on statistical significance was not appropriate”. Factors such as cost , practicalities of one intervention over another, the benefit an intervention had for the whole population consistently rather than a targeted prevention approach only and of course the evidence base ”.

Now there is much to find fault with in this statement. 45

Firstly, water fluoridation programmes waste public money because only 4% of drinking water is drunk and of that 4%, only a tiny percentage (let’s say, 0.3% of the total amount of water provided) is possibly drunk and absorbed by disadvantaged children. So 96% of the fluoridated water goes down the drain and with it, 96% of the fluoridating acid. Moreover, it is counterintuitive to spend money of administering the fluoridation programme when only 0.3% of the population is the target group. This money also ‘goes down the drain’. Practicalities : fluoridation is a lazy intervention which unnecessarily targets whole populations, and whilst it is more time-consuming for PHE to correctly target disadvantaged children, it would be the right thing to do. So perhaps PHE Bedford needs to consider recommending the Scottish Childsmile programme to the Councillors? If Scotland can do it then it should be easier for a more compact area such as Bedford to initiate such a programme. Similarly, Wales has “Designed to Smile” which is showing good results. Regarding the “ benefit for the whole population ”, we would really like to see proof to substantiate this statement. The most recent statement which we’ve seen concerns adult dentition and how the evidence-base for improved adult dentition using systemic fluoride does not prove that systemic fluoride prevents dental decay.

“No studies met the review’s inclusion criteria that investigated the effectiveness of water fluoridation for preventing tooth decay in adults, rather than children. Ref. Cochrane, 2015, see pp. 31-3).

As far as the ‘ evidence base’ is concerned, even the British Fluoridation Society now states that systemic fluoridation is the “least important mechanism” and that organisation does not make such statements unless they’re carefully researched. (Ref: http://www.bfsweb.org/facts/dental_benefits/howfworks.htm .) The pro-fluoridation Centers for Disease Control (CDC) in the USA are more likely to admit, when confronted with their own statements, that topical fluoride is the way in which fluoride acts to prevents dental decay. “...fluoride prevents dental caries predominately after eruption of the tooth into the mouth, and its actions primarily are topical for both adults and children.” (Ref: CDC quoted in http://fluoridealert.org/studies/caries04/ )

Turning now to the plea that there was not enough time or money to survey a larger group of children and to ask questions about lifestyle factors, this is a very poor excuse. Councillors may not have yet registered the fact that fluoridation is compulsory medicine which violates our right to refuse medical treatment under the NHS Constitution. Or they may not know that 1mg fluoride per litre of water contains millions of fluoride atoms (the fluoride atom being very tiny indeed) and that each atom is capable of disrupting one enzyme ‘pathway’, thus causing a negative bio-accumulative effect on our bodies which tips us over into ill-health sooner or later. If it is seriously proposed to put fluoride back into 46

Bedford’s water, then constituents would need to see proof that, at the very least, fluoride benefits people of all ages and social groups. Merely stating this, does not make it so!

And finally, in order to put Q8 to bed, “examiners were trained to ensure everyone measured dental decay experience in the same way”. Can Dr Francis state that the examiners in 2008 were using the same protocols as the examiners in 2015? Or perhaps, the examiners in 2008 were fresh out of training and applied different skills to those examiners employed in 2015, or vice versa?

~~~~~~~~~

Q8. Do they wish to either endorse the claims in the document that there are differences that favour fluoridation or the statements in the document that there are no significant differences? Is part of the document wrong or all of it?

A. Feema Francis explained that the report showed a trend from 2008 to 2015 of worsening dental health which may have been because of the suspension of water fluoridation- there was a strong suggestion of this given the large evidence base globally for water fluoridation. If the water fluoridation continued to be suspended, there was the risk dental health may become much worse (as suggested by the evidence base from systematic reviews) and if statistical test was applied then it might show statistical significance of worsening which would favour the support for water fluoridation. As discussed previously statistical significance needed to be interpreted correctly, errors could occur if only looking at statistical significance on a cross-sectional survey with a small sample of children living in fluoridated and non-fluoridated areas. As noted before water fluoridation never reached a mean of 1ppm for a whole year in the five years leading up to the survey in 2008 or during the survey period itself.

Our response: At this stage we feel justified in displaying a graph which shows that dental decay throughout Europe has been falling whether or not populations are fluoridated.

In 2003, Basel (Switzerland) ceased water fluoridation after 41 years. “ It is clear throughout the report that the GSK [Health Committee] had developed serious doubts about the effectiveness of water fluoridation. Adding to these doubts were recent findings showing that tooth decay had risen in Basel’s children since 1996, coupled with an absence of any evidence showing Basel to have a lower rate of tooth decay than other Swiss cities (most of which have low – although increasing *– rates of tooth decay).” “After “‘weighing carefully the pros and cons… the GSK took its decision to recommend [the] abolition of water fluoridation by a 11:2 margin”, stated GSK board member Dr. Tobias Studer.” Source: Quoted in http://fluoridealert.org/articles/basel/ * At the time Zurich had many immigrant children who had higher levels of dental decay.

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Q9. Is the concentration of fluoride an issue?

A. A consistent water fluoridation level at 1ppm was the optimal concentration for a health benefit and lower concentration would lead to lower dental health outcomes.

Our Response : The USA has now opted for a concentration of 0.7ppm. It is no longer wise to add 1ppm because there is more fluoride in our lives than there was in the 1940s when the ‘optimum’ concentration of 1ppm was proposed as being protective of teeth but not too high that it would cause more than 10% Dental Fluorosis. This was a concentration plucked out of thin air at the time. As time has gone by, 1ppm has become more and more 48

unrealistic with the commonplace use of fluoridated toothpaste and the presence of fluoride in manufactured food, etc. There is now an alarming increase of dental fluorosis in affected populations and this is the reason why the USA has finally acted. We should not be exposed to 1ppm fluoride now that we have fluoride available to us from other sources.

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Q10. What types of fluoride are used for water fluoridation?

A. Feema Francis agreed to provide a written reply – see Appendix to these minutes.

Our Response : This beggars belief! Anyone who endorses water fluoridation should know that the fluoridating acid is called hexafluorosilicic acid (aka hydrofluorosilicic acid) with a chemical formula H 2SiF 6 .

As a postscript to demonstrate how idiosyncratic fluoridation law is, successive UK Water

Acts have also specified the use of disodium hexafluorosilicate as an alternative to H2SiF 6 . However, this particular compound is listed in the UK’s Poisons List Order 1982, List 2 as sodium silicofluoride. Slightly different name but the same chemical formula, Na 2SiF 6

Note also that hydrofluoric acid is also in List 2. This toxin is a component of hexafluorosilicic acid. Ref: http://www.legislation.gov.uk/uksi/1982/217/article/2/made

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Question 11: If fluoridation does indeed work as well as they claim, how come these results show that there is no difference between dental health in fluoridated and unfluoridated water areas? (See paras 1.4, 5.5, 5.14, 5.21, 5.23, 5.26, 6.1 bis , 6.3.1, 6.3.2, 6.4.1

A. Dr Francis answered this question but the reply is not in the record.

Our Response: The issue is discussed in Section 5.

Section 6 How Water Fluoridation Wastes Money

27.5% of fluoridated water used by households is not drunk by the family.

Only 4% of fluoridated water sold by fluoridating water companies is drunk.

(The above figures were acquired by making a Freedom of Information request)

6.1 We have no way of calculating the possible annual revenue costs of a fluoridation programme for Bedford. So, a ‘round ball-park figure’ has been chosen to illustrate the potential amount of financial wastage. If Bedford was to be invoiced by PHE for £100,000 pa for fluoridation revenue costs, £96,000 pa worth of fluoridating acid and its supporting services would “go down the drain”. This would be an unjustifiable waste of money since it could never be a financially viable proposition to waste that amount of money on a non- targeted programme for the sake of a tiny percentage of disadvantaged tiny tots. Targeted dental hygiene programmes, such as Childsmile or the Welsh programme Designed to Smile , would be far less expensive and more effective.

6.2 The responsibility for initial capital expenditure (fluoridation equipment) would need to be negotiated with PHE.

Section 7 The Causes of Dental Decay

7.1 The following causes of tooth decay argue against the efficacy of fluoride in preventing dental caries. Even with fluoride in the water supply, dental decay continues to be cause for concern in fluoridated areas. (See Section 8). Fluoride is not a silver bullet.

Lead causes tooth decay

7.2 In research published in the International Journal of Environmental Studies (September 1999), Masters and Coplan studied lead screening data from 280,000 Massachusetts children. They found that average blood lead levels are significantly higher in children living in communities whose water is treated with silicofluorides [such as hexafluorosilicic acid]. Data from the Third National Health and Nutrition Evaluation Survey (NHANES III) and a survey of over 120,000 children in New York towns (population 15,000 to 75,000) corroborate this effect.

7.3 Masters and Coplan reported that some minorities are especially at risk in high SiF exposure areas, where Black and Mexican American children have significantly higher blood lead levels than they do in non-fluoridated communities.

7.4 Silicofluorides are used by over 90% of U.S. fluoridated towns and cities. Ironically, children with higher blood lead levels also have more tooth decay (Journal of the American Medical Association , June 23/30, 1999).

7.5 In certain towns and cities in the UK, there is a percentage of black and ethnic families. Such families are more prone to being damaged by silicofluorides, especially if they live in houses where the water pipes are made of lead. Also, certain poor areas of a town or city are close to contaminated land where children play.

Low calcium in soft tap water once weaned and poor calcium-deficient diets

7.6 Birmingham has soft water (total dissolved solids t.d.s 77) because the Elan Valley water which is piped to the city is soft with low levels of calcium carbonate.

7.7 In the Republic of Ireland, much of the tap water is very soft (t.d.s 35). Disadvantaged families consume foods which are traditionally low in calcium. Calcium is an essential component of growing teeth and bones although Vitamin D and phosphorus are also essential. Vitamin D can be replenished by exposure to the sun in the summer months and/or by eating butter, milk and eggs. Low fat spreads may be fortified with vitamins A and D although this is not required by law. Up until recently we have all been warned off eating butter, and many people will have eaten low-fat spreads as a substitute which may not contain Vitamin D. Now that the intake of saturated fats and eggs is no longer advised against, the health of the nation should improve. However, those families which remain uninformed, could be developing teeth which are weak and prone to dental decay.

Baby-bottle decay (Early Childhood Caries)

7.8 It has been admitted by the dental fraternity that this type of decay could never be prevented by fluoride. Such decay is aggressive. Those unaware of why early childhood caries is so aggressive need to picture a toddler put to sleep with a bottle of sugary liquid on which it sucks for hours at a time.

Early Childhood Caries

7.9 The remineralisation of enamel in milk teeth cannot occur fast enough to prevent this type of decay. Extractions of decayed teeth in this category ought to be excluded from dental decay statistics when used for the purposes of promoting water fluoridation.

Kissing the young child on the mouth

7.10 Being kissed on the mouth by parents or siblings once the first teeth have erupted can infect the young child with bacteria such as Streptococcus mutans . If dental hygiene in the family is not well observed, then the young child is more likely to experience dental decay. Note that xylitol chewing gum reduces the growth of decay-causing bacteria in a parent’s mouth, thus preventing the transmission of the bacteria from parent to baby. (Ref: Council on Clinical Affairs, 2011, p. 175, col. 2).

Too much sugar/acid/phosphate

7.11 If young children don’t drink water, they will preferentially seek out pop (Coke, lemonade, Fanta, etc.) Such drinks are acidic and full of sugar or if Coke is the preferred drink, full of phosphoric acid which is more acidic than vinegar. In all cases, an acidic environment is generated in the oral cavity which encourages the erosion of enamel. If bacteria, such as Streptococcus mutans, are present in the oral cavity, decay will soon follow.

7.12 Regarding sugar, Dr Alison Tedstone, chief nutritionist for Public Health England, the Government agency responsible for tackling obesity, said: ‘Children are having too much sugar, three times the maximum recommended amount. This can lead to painful tooth decay, weight gain and obesity, which can also affect children’s well-being as they are more likely to be bullied, have low self-esteem and miss school. Children aged five shouldn’t have more than 19 grams of sugar per day - that’s five cubes, but it’s very easy to have more.’ (Ref: http://www.dailymail.co.uk/health/article-3383197/Children-eat-3-5-stone-sugar- year-three-times-recommended-amount.html#ixzz3wIEvLadq

7.13 The question has to be asked at this stage: do disadvantaged children preferentially opt for tap water when thirsty, or do they open the fridge door? If the latter, this further reduces the number of children in the target group for water fluoridation and increases the waste of money.

Insufficient saliva

7.14 Although it’s adults who are more prone to “dry mouth”, if young children are unable to produce enough saliva, they are more prone to rampant tooth decay.

Poor enamel deposition (Amelogenesis imperfecta)

7.15 A small number of children are genetically unable to deposit a thick layer of enamel on their teeth. These teeth are prone to more rapid decay.

Dentine Bombs

7.16 This is explained on pp. 14-15. In brief, the dentine is decayed by bacteria entering through micro-cracks in fluoridated enamel and is not detected until the enamel overlying the decayed dentine caves in, when it is too late to save the tooth. If not suitable for the placement of a crown or root canal filling, it has to be extracted. Could it be that the practice of water fluoridation is unintentionally creating more work for dentists?

The Connection between ADHD and Dental Decay

7.17 If fluoride causes ADHD (see p. 20), then it is counter-intuitive to fluoridate the young child which has ADHD. Research shows that fluoride is a developmental neurotoxin. The New Zealand research (2004 – see p. 21 ) points to children with ADHD experiencing alarming levels of dental decay.

7.18 It could be that fluoridated children with ADHD are not able to lay down robust tooth enamel due to the disruptive effect that fluoride has on their enzymes.

7.19 Further research is required.

7.20 In summary, many types of dental decay should not be included in oral health surveys which attempt to show that systemic fluoride prevents tooth decay. To do so incorrectly skews the results in favour of fluoridation.

Section 8 Worsening Dental Decay in Fluoridated West Midlands

8.1 All three newspaper reports appended below in full attest to the fact that the imposition of fluoride in the public water supply is not working to reduce dental decay. The apologists for water fluoridation state that dental decay is on the increase because of increasing number of immigrants and indeed that has been demonstrated in Zurich. However, if that is the case in the UK, then we need to see the proof. None has been forthcoming! Yet another ‘belief’ that is steering or propelling policy!

Coventry Observer, November 2008 (no longer accessible via the Internet)

Coventry has been fluoridated since 1979.

Birmingham Mail, September 2011

Scheme piloted in Birmingham to boost children's dental health 10:54, 15 SEP 2011 UPDATED 12:18, 14 OCT 2012

A TRIAL to boost children’s teeth is being pioneered in the region after it was shamed for youngsters’ rotting gnashers.

Dental issues

A TRIAL to boost children’s teeth is being pioneered in the region after it was shamed for youngsters’ rotting gnashers.

Nine dental practices in the West Midlands have been selected to look at ways of getting more children and other patients to see an NHS dentist by changing the way they are paid.

It comes after it emerged in June that a third of five-year-olds in Birmingham have rotting teeth with a mouth full of decay or fillings.

That was coupled with nearly 50,000 fewer city residents seeing an NHS dentist compared to five years ago when controversial changes to the dental contract were introduced.

Dentists are now paid for the amount of treatment they do but this trial by the Department of Health will see dentists paid for the number of patients they care for and the health results.

It will also include dentists promoting preventative dental treatments like fluoride varnish to prevent fillings.

Health Secretary Andrew Lansley said: “It is great to see that dentists in the West Midlands have signed up to be part of this important work. Birmingham has been fluoridated since 1964

“It will allow them to focus on promoting good oral health and preventing dental decay, rather than simply being paid to perform a series of procedures.

“It is vital that patients, and especially children receive high quality dental care, and the changes being trialled will mean dentists are paid according to the outcomes their patients see.”

Dentists selected to pilot the new system include Amblecote Dental Practice,in Dudley; Henry Road Dental Practice, in Yardley; Hillbrook Dental Health Centre, in Balsall Heath; South Road Dental Surgery, Stourbridge; West Park Dental, Smethwick and University Dental Centre, in Edgbaston.

There were 26,000 fewer children nationwide able to see a dentist up to June 2011, compared to the year up to March 2006 when the new NHS contract came in, according to the NHS Information Centre.

Patients struggling to register with an NHS dentist should call the dental helpline on 0121 465 1037.

Source : http://www.birminghammail.net/news/top-stories/2011/09/15/scheme-piloted-in-birmingham- to-boost-children-s-dental-health-97319-29423545/#ixzz1cvp8u7Hr

Birmingham has been fluoridated since 1964.

Coventry Telegraph, 17 th July 2014

'Shocking' increase in tooth decay in children in West Midlands 14:01, 17 JUL 2014 BY COVENTRY TELEGRAPH 300 per cent rise in youngsters in the region admitted to hospital for multiple teeth extractions

Tooth decay in children is rising rapidly in the West Midlands

There has been a 300 per cent rise in children in the West Midlands being admitted to hospital for multiple teeth extractions in what a senior dentist described as a “massive parenting failure”.

Some youngsters are undergoing hospital operations to remove all 20 baby teeth, according to Dr Nigel Carter, the chief executive of the Rugby-based British Dental Heath Foundation , who practises in the region.

Dr Carter said it “beggared belief” that a parent would not notice their child had a “mouthful of teeth rotten down to the gums”.

Figures revealed by the Health and Social Care Information Centre showed that in the West Midlands in 2010-11 there were 456 children under the age of 10 admitted to hospital with tooth decay. In 2013-14 a “shocking” 1,444 were admitted.

Experts blame the trend on a culture of parents rewarding children with sweets while failing to clean their teeth properly as infants.

Dr Carter said: “The rise is absolutely incredible and is indicative of a massive failure in parenting.

“Partly it’s down to background and people from lower socio-economic groups have higher levels of tooth decay.

“It has to be about parenting and looking after children.

“In many cases the first time the child has ever seen a dentist is when they’re taken there in great pain.

“Basically if it gets as far as needing to go to hospital for general anaesthetic then you’re talking about multiple extractions. Birmingham has been fluoridated since 1964

“It’s not unusual for a child to have 12 to 14 teeth taken out and in some cases we’ve heard of all 20 baby teeth being removed.”

In 2010-11 120 under-fours were admitted to hospital for surgery in the West Midlands. This had rocketed 353 last year.

One theory for the rise in childhood tooth decay in the last three years is rising immigration of people from Eastern Europe, who are moving over with their families and receiving treatment on the NHS.

Three years ago the total number of people under the age of 19 needing to go to hospital for surgery was 996. Last year it was 2,074.

In 2010-11 there were 6,000 hospital admissions for tooth decay in the West Midlands of all ages. In 2013-14 that had risen to 7,883.

The move away from three square meals a day can also be blamed for the growing problem, said Dr Carter.

Dr Carter said: “Children are now having seven to 10 ‘grazing’ meals, many of which are full of sugar.

“Studies have shown that if you put a spread of food in front of children they would chose to eat a balanced diets.

“But we have the problem where sweets are given as a reward and so they are identified as such by the children.”

Source : http://www.coventrytelegraph.net/news/coventry-news/shocking-increase-tooth-decay- children-7446405 Birmingham has been fluoridated since 1964

8.2 The West Midlands has been fluoridated since 1964 when Birmingham was first fluoridated. Other cities and towns soon followed suit. Today, even Stratford-on-Avon in Warwickshire is fluoridated.

Section 9 Scotland’s Successful Childsmile Oral Health Programme

Evidence from New Zealand (2015)

9.1 The Scottish Government refused to initiate water fluoridation programmes in 2004 and has now rolled out Childsmile throughout Scotland. Childsmile is reported as being highly successful. This success has been used by activists in New Zealand to urge the discontinuation of fluoridation on the grounds that fluoride is not reducing dental decay at the same rate that Childsmile has recently reduced decay in Scotland.

COMPARISON of Age 5 Children:

In 20 years, Scotland’s rate of dental fillings* New Zealand’s rate of dental fillings for age 5 For age 5 children has been cut by more than children unfortunately has INCREASED in this time, half (2.93 to 1.27). from 1.71 to 1.88 average fillings per child

Since CHILDSMILE began, the rate of age 5 Scottish NZ has improve d only by 3% in this time. children FREE of decay has gone from Now at 57%, we are far behind Scotland. 45% to 68%, national average. This is an improvement of 23%.

High decile areas of Scotland now have 83% of Nowhere in NZ comes even close to this. Our top Children FREE of decay. rated areas are non-fluoridated Wairarapa & Waitemata (76% & 72%).

COMPARISON of Year 8 children:

Since CHILDSMILE began, Scotland’s rate of fillings* for Year 8 Kiwis have nearly twi ce as many fillings Year 8 children has also been cut by more than half. as Year 8 Scots. A fantastic low rate of only 0.60 fillings per (1.14 fillings per NZ child.) child now. Previously it was 1.29. In 20 years, the rate of Scottish Year 8 children FREE of NZ has improved only by 5% in this time. It is now decay has almost doubled . 54% which lags far behind Scotland. An improvement from 38% to 73%

* Refers to fillings, decayed and missing teeth

Childsmile , Scotland compared with New Zealand which has water fluoridation.

(Note how New Zealand’s dental decay rate for Year 8 children has not improved since 1993.)

Source: https://www.youtube.com/watch?v=EZ4FHnW4e_0

The use of Xylitol for preventing dental decay

9.2 This is an interesting development which has been researched in Finland and elsewhere. A short paper entitled “Guideline on Xylitol Use in Caries Prevention” is recommended to Bedford’s O&S Committee. The paper lists 46 documents, the authors of whom have researched the use of xylitol. “Clinicians may consider recommending xylitol use to moderate or high caries-risk patients”. “A randomized trial of xylitol syrup (8 grams/day) reduced early childhood caries by 50-60% in children 15 – 25 months of age.” (Ref: Council on Clinical Affairs, Academy of Pediatric Dentistry, 2011).

Section 10 The Precautionary Principle

10.1 The Precautionary Principle enables rapid response in the face of a possible danger to human, animal or plant health, or to protect the environment. In particular, where scientific data do not permit a complete evaluation of the risk, recourse to this principle may, for example, be used to stop distribution or order withdrawal from the market of products likely to be hazardous.

Source: Communication from the Commission on the Precautionary Principle (COM (2000) 1 final of 2 February 2000)

SUMMARY

10.2 The Precautionary Principle is detailed in Article 191 of the Treaty on the Functioning of the European Union (EU). It aims at ensuring a higher level of environmental protection through preventative decision-taking in the case of risk. However, in practice, the scope of this principle is far wider and also covers consumer policy, European legislation concerning food and human , animal and plant health .

10.3 This Communication establishes common guidelines on the application of the precautionary principle.

10.4 The definition of the principle shall also have a positive impact at international level, so as to ensure an appropriate level of environmental and health protection in international negotiations. It has been recognised by various international agreements, notably in the Sanitary and Phytosanitary Agreement (SPS) concluded in the framework of the World Trade Organisation (WTO).

Recourse to the precautionary principle 10.5 According to the European Commission the precautionary principle may be invoked when a phenomenon, product or process may have a dangerous effect, identified by a scientific and objective evaluation, if this evaluation does not allow the risk to be determined with sufficient certainty.

10.6 Recourse to the principle belongs in the general framework of risk analysis (which, besides risk evaluation, includes risk management and risk communication), and more particularly in the context of risk management which corresponds to the decision-making phase.

10.7 The Commission stresses that the precautionary principle may only be invoked in the event of a potential risk and that it can never justify arbitrary decisions.

10.8 The precautionary principle may only be invoked when the three preliminary conditions are met:  identification of potentially adverse effects

 evaluation of the scientific data available

 the extent of scientific uncertainty

Precautionary measures

10.9 The authorities responsible for risk management may decide to act or not to act, depending on the level of risk. If the risk is high, several categories of measures can be adopted. This may involve proportionate legal acts, financing of research programmes, public information measures, etc.

Common guidelines 10.10 The precautionary principle shall be informed by three specific principles :

 the fullest possible scientific evaluation, the determination, as far as possible, of the degree of scientific uncertainty

 a risk evaluation and an evaluation of the potential consequences of inaction

 the participation of all interested parties in the study of precautionary measures, once the results of the scientific evaluation and/or the risk evaluation are available

10.11 In addition, the general principles of risk management remain applicable when the precautionary principle is invoked. These are the following five principles:

 proportionality between the measures taken and the chosen level of protection

 non-discrimination in application of the measures

 consistency of the measures with similar measures already taken in similar situations or using similar approaches

 examination of the benefits and costs of action or lack of action

 review of the measures in the light of scientific developments

The burden of proof

10.12 In most cases, European consumers and the associations which represent them must demonstrate the dange r associated with a procedure or a product placed on the market, except for medicines, pesticides and food additives .

10.13 However, in the case of an action being taken under the precautionary principle, the producer , manufacturer or importer may be required to prove the absence of danger . This possibility shall be examined on a case-by-case basis . It cannot be extended generally to all products and procedures placed on the market.

Appendix A Sound Bites About Fluoride and the Fluoridation Programme

A1 Using metric units, 1 litre of water weighs 1 kilogram. This is a universal standard.

A2 On the other hand, 1 litre of milk weighs more than 1 kilo because milk is denser than water.

Ref: https://www.quora.com/Why-is-it-that-1-litre-of-water-weighs-1-kg-while-this-doesnt-apply-for-other- liquids

A3 In metric units, 1 milligram (mg) is one thousandth of a gram. 1 gram is one thousandth of a kilogram. Therefore, 1 mg is 1000 x 1000 = 1 millionth of a kilo.

A4 When we talk about 1ppm fluoride in water, we are describing one-millionth of a litre.

A5 With reference to water , since 1 mg is one-millionth of a litre, 1mg is the same thing as 1ppm .

A6 1mg fluoride is not the same thing as 1 atom of fluoride. In fact, there are millions of atoms of fluoride in 1mg. Fluoride is a very tiny atom indeed. 50% of all fluoride ingested and absorbed bioaccumulates in teeth, bones and organs. In fact, where there is calcium in situ, fluoride will eventually be found. In fluoridated communities, we drink and absorb fluoride 24/7, 52 weeks of the year, every year of our lives. Although 1%-2% of the population are sensitive to fluoride, most of us are initially unharmed but sooner or later, our bodies reach a tipping point when the amount of bioaccumulated fluoride starts to cause poor health.

A7 Babies and people with poor kidney function bioaccumulate 70% - 90% fluoride. Since this fluoride deposits in our bones, patients with chronic kidney disease could begin to experience the symptoms of undiagnosed Stage 1 or even Stage 11 skeletal fluorosis. (Most UK medical professionals are unaware of the existence of skeletal fluorosis unless they have practised in parts of the World where skeletal fluorosis is endemic.)

A8 ‘Concentration’ is the word used to describe how much fluoride is in each litre of water. This is not the same as ‘ dose’ . A dose is the amount of fluoridated water drunk each day. The average dose is 2 litres water/day. However many people drink more. Therefore, the dose is uncontrolled .

A9 The ‘ optimum’ concentration of fluoride added to treated water in the UK is 1mg/litre of water or 1ppm. In the last few years, the USA and the Republic of Ireland have reduced the ‘optimum’ down to 0.7 – 0.8 ppm in order to reduce the widespread occurrence of Dental Fluorosis in permanent teeth . Hong Kong adds 0.5 ppm to drinking water for the same

reason and because it is a hot country. The UK has failed to follow suit. The reason for this failure is said to be “lack of evidence from monitoring data to support a variation of the target level for fluoride in drinking water.” (Hansard HL4593, 15 th December 2015). This is a risible reply by the Government spokesperson since the evidence for Dental Fluorosis caused by fluoride is easily accessible from other fluoridated countries which have temperate climates.

Ref: http://www.parliament.uk/business/publications/written-questions-answers-statements/written- questions-answers/?page=1&max=20&questiontype=AllQuestions&house=lords&member=3446

A10 The ‘optimum’ concentration was arbitrarily decided back in the 1940s in the USA. It was thought, with no credible research being done, that above this level children would get Moderate Dental Fluorosis (DF) whilst below this level there would be no protection for teeth from dental decay. We now know better!

A11 Natural fluoride occurs in small isolated areas in the UK. Approx. 330,000 people drink this water. Natural fluoride is calcium fluoride (CaF 2) but when in drinking water, the calcium and fluoride are disassociated. It’s only when the two elements are no longer in water (e.g. in the stomach as “the water drains away” that the two elements bond and are no longer bioavailable.

A12 5,797,000 people living in England purchase drinking water to which an artificially- produced fluoride compound has been added. That’s approx. 10% of the population of the UK. Ref: British Fluoridation Society’s publication One in a Million, 3 rd ed., March 2012

A13 The fluoride atom in its electrically negative state (F -) is the same atom found in both natural and artificially-produced compounds. The other substances present in our stomachs and in the fluoridating acid alter the way in which the body copes with fluoride.

A14 Due to lack of research, there is lack of knowledge about the additive effects of combinations of the substances added to our drinking water when the fluoridating acid is added. However, it is known that fluoride increases the bioavailability of aluminium.

A15 The fluoridating acid has many names. In UK Law, it’s known as hexafluorosilicic acid. It should more accurately be called hydrofluorosilicic acid. The chemical formula for both is the same: H2SiF 6. However, this would make it more obvious that Hydrofluoric acid (a Part II poison listed in the UK Poison’s List Order, 1982) and hydrofluorosilicic acid are very similar! In the fluoridating acid, there is the potential for the elements to combine to make 1.5% hydrofluoric acid. A laboratory analysis of the fluoridating acid added to drinking water in the Republic of Ireland detected 28 contaminants (See Appendix F). (Fluoride, silica and hydrogen are in the chemical formula so there was no need to analyse the acid for these elements.)

Source: CAL Ltd analysis, Dublin, 14 th August 2000. See Appendix F 66

A16 The fluoridating acid added to English and Irish drinking water is a hazardous waste by- product which arises from the manufacture of phosphate fertiliser. The fluoridating acid used in Ireland originates in Spain whilst the English fluoridating acid originates in Finland. Source: Wikipedia: https://en.wikipedia.org/wiki/Fertilizer#Phosphate_fertilizers

A17 The fluoridating acid is hazardous because the acid forms corrosive Hydrofluoric Acid (HF) which, when it evaporates, forms highly corrosive and toxic Hydrogen Fluoride gas (also HF). HF was implicated in the Meuse Valley (Belgium) and Donora (Pennsylvania) disasters.

A18 The fluoridating acid used for water fluoridation is approximately a 20% solution. This means that: 20% is fluoride 76 – 76.5% is contaminated factory water which is used to ‘scrub’ the poisonous gases out of the phosphate factory chimney 1.5% - 2% is hydrofluoric acid – or rather atoms of hydrogen and fluoride capable of forming hydrofluoric acid and hydrogen fluoride gas 2% is contaminants and silica – approx. 29 in no., depending on the contents of the factory floor water and on the origin of the ore used to manufacture phosphate fertiliser.

A19 In order to add 1mg fluoride to each litre of treated water, it is necessary to add more than 5mg (precisely 5.36mg) of the fluoridating acid to each litre of water. This little known fact is not admitted by the British Fluoridation Society in its publication One in a Million. Source: YARA UK Guidelines - See Appendix E.

A20 Although added to drinking water in minute quantities, many of the contaminants are bio-accumulative. Many have a synergistic effect in that their negative effects on our bodies are magnified when present in combination. More research is needed on this aspect. BSEN 12175 admits that many of the contaminants in the acid are not controlled by the BS because they weren’t in the original raw material – phosphate rock. But does this mean that such uncontrolled contaminants are present in the acid at concentrations higher than legally allowed in foodstuffs?

A21 Hexafluorosilicic acid is not of British Pharmaceutical grade and could never be of BP grade whilst there is uncertainty about the concentration of these other contaminants. A22 Local Authorities which are considering proposals to fluoridate their areas would do well to consider how it could be lawful to add an acid to drinking water which is not of pharmaceutical grade and which contains heavy metals of unknown concentrations. A23 Moreover, as already pointed out elsewhere in this Report, it is not permissible to add hexafluorosilicic acid to food. Ref : EU Reg. 1170/2009, Annex III.

A24 Finally, if fluoridated water is to be regarded as being a medicine (and it fulfils the legal criteria for being classified as a medicine – a prophylactic – then as a medicine it does not fall to be considered under the Drinking Water Directive . Medicinal waters are specifically excluded from consideration as drinking water. Therefore, this removes any legal protection which people should expect had fluoridated water been drinking water and not medicinal water. (Ref: European Union Drinking Water Directive, Article 3)

Appendix B Bioaccumulation and Bioavailability B1 It is scientifically accepted that 50% of swallowed fluoride is excreted via the kidneys leaving 50% to bio-accumulate in the body. Why does the body reject 50% of the fluoride? The only explanation can be that calcium and magnesium bond with some of the fluoride and thus ‘escort’ the toxin out of the body. When there is calcium and magnesium present in the diet and stomach, the bioaccumulation of fluoride is less. The remaining 50% of fluoride passes through the stomach lining or the lining of the ileum where it becomes strongly attracted to positive atoms such as in situ calcium and magnesium which are already ‘attached’ to bones and organs.

B2 “Absorption of fluoride is rapid and extensive, with about 50% of the absorbed fluoride becoming associated with calcified tissues within 24 h and the remainder being excreted in the urine.” (Ref: http://ndt.oxfordjournals.org/content/22/10/2763.full )

B3 Babies and patients with Chronic Kidney Disease (CKD) will clear between 10% - 30% fluoride, leaving between 70% - 90% to bioaccumulate. Bioaccumulation takes places in bones and organs. In fact, wherever calcium is naturally deposited in the body, fluoride will also be found. Calcium fluoride is found in the pineal gland. (Luke, 1997, p. 168).

B4 Fluoride has been described as an avid bone-seeker .

“Physiologically, the fluoride ion is an avid bone seeker and a potent enzyme inhibitor ." (Burghstahler, 1977).

B5 In certain towns and cities such as Birmingham, residents could be described as being deficient in calcium because their drinking water is low in calcium carbonate. Moreover, since fluoride prevents the bioavailability of calcium and magnesium, the deficiency is made even worse. Thus fluoride has the effect of weakening the teeth because calcium is deficient.

B6 Ca + and F – make a particularly strong bond in the body in the absence of water. This means that bonded fluoride cannot enter tooth material but at the same time calcium cannot be effective at helping the body in its numerous essential processes.

Appendix C The Nature of Fluoride and its Toxicity

C1 Fluoride is fluorine gas but since fluorine cannot exist on its own in nature, it has to bond with another element. This means that the name of fluorine changes to fluoride to denote its dependence on bonding with another element.

C2 Whenever we encounter fluoride, it’s shown as F -. This means that fluoride is fluorine with an extra electron meaning that the fluoride anion has an extra electro-negative ( -) charge. (Electrons are negatively charged so the more electrons, the higher the negative charge. The chosen partner for bonding with fluoride would be an element with a positive (+) charge. Thus aluminium fluoride, calcium fluoride, magnesium fluoride, hydrogen fluoride and + - + - + - + - + - potassium fluoride: Al F , Ca F2 , Mg F , H F and K F

C3 Fluoride is the most negatively charged of all the elements in the periodic table. This means that it packs a punch! As you move from left to right in the Periodic Table of the Elements (see next page), the negative reactivity of the elements increases. (The noble gases - far right - are outside this sequence.)

C4 Electro-negative elements attract positive elements. The more electro-negative elements attract the more positive elements. Thus Calcium + is strongly attracted to Fluoride -. The same is true of the attraction between magnesium and fluoride: Mg +F-.

C5 The ability of fluoride to bond with elements which are in situ in the body is the key to its toxicity. It is capable of distorting proteins which are held together with hydrogen:

Ref: Murphy, D. (2008). The Devil’s Poison: How Fluoride is Killing You. p.73

Periodic Table of the Elements

Inert Gases

Fluorine

Periodic Table of the Elements

Magnesium (MG) Calcium (Ca) Potassium (K)

C6 Fluoride is capable of crossing through cell membranes and entering our cells. Therefore it is not too difficult to see that poisoning can occur to our genetic material since DNA is held together with hydrogen bonds and fluoride also forms strong bonds with hydrogen. As the above extract states, fluoride “can also be implicated in altering genetic expression as the helical shape of DNA and RNA can be affected.”

C7 Fluoride disrupts the functionality of the thyroid gland. Put simplistically, it substitutes for iodide and prevents the production of thyroid hormone.

C8 British Standard (EN) 12175 , lists a few of the contaminants in the fluoridating acid. Extracts from the BSEN are as follows:

“Hexafluorosilicic acid is only stable in an aqueous solution. On evaporation it decomposes to hydrogen fluoride (HF) and silicon tetrafluoride (SiF 4). It produces hydrogen on contact with metals, e.g. steel, nickel and aluminium. It is a strong acid [pH < 1] and reacts violently with alkalis. If forms hydrogen fluoride (HF) on contact with concentrated acids. It attacks glass. Hydrogen fluoride is present in the acid at a maximum of 1.5%. Chemicals present: antimony, arsenic, cadmium, chromium, lead, mercury, nickel, selenium. Other chemicals are not relevant because the raw materials used in the manufacturing process are free of them.”

C9 [This final sentence seems to imply that certain contaminants are in the acid but are not admitted to as being contaminants. If not in the raw material (phosphate rock), they can only come from polluted factory water used to scrub the gases out of the phosphate factory chimney. It is strange that the BSEN is not concerned with protecting our health from the negative effects of these ‘other contaminants’ in the factory water.]

C10 Even though BSEN 12175 is not concerned about these ‘other contaminants’, we are protected to a certain extent by EU Regulations which have been adopted by the UK Government. Thus EU Reg 1925/2006 and EU Reg 1170/2009 (which have been transposed into UK Reg. 1631) do not allow the addition of hexafluorosilicic acid to food. Water is food. So by adding the fluoridating acid to our drinking water, water companies are in breach of the law.

C11 The following bar chart illustrates the relative toxicity when compared with lead and arsenic:

C12 It is unfortunate that the fetus is not protected from fluoride, particularly since the fetal blood brain barrier is not well developed during pregnancy. The table below is taken

from a report by the European Scientific Committee on Environmental Risks – a Committee which is often cited by those who promote water fluoridation.

C13 Whilst it is true that fluoride at 1ppm does not kill us outright, the poisoning effect is very gradual over many years. The fetus is exposed to fluoride in the womb with the result that, if it survives gestation, its intelligence is impaired.

Avenues of exposure to fluoride

Source: http://ec.europa.eu/health/scientific_committees/environmental_risks/docs/scher_o_122.pdf

(Note that the information about the formation of permanent teeth is at odds with earlier researchers. (See Section 3). The scientists also imply that mother’s milk contains quite a lot of fluoride when this is very far from the truth.)

C14 Looking a ‘bulk’ fluoride, there are numerous Material Safety Data Sheets on H2SiF 6 on the Internet which make chilling reading, e.g. http://www.cleartech.ca/msds/sillyacid.pdf . Most of us will not encounter tanker spillages in our lifetime. However, it is important to appreciate the worst acute damage that the 20% acid can do to our bodies if it touches our skins. Fluoride is rapidly absorbed into the skin and ‘burns’ through bones (that is, it rapidly bonds with all the available calcium in bones which are destroyed in the process) before non-bonded fluoride atoms start to withdraw calcium from the tissues. The hopeful antidote to burning is calcium gluconate gel which must be applied to the skin after it has been sluiced with water for 15 minutes.

C15 In summary, the fluoride atoms which become bioavailable interfere with the structure/shape of proteins and destroy their functionality. We need to remember that in 1mg of fluoride, there are millions of atoms.

Appendix D The Negative Effect of Fluoride on Our Bodies

The following article provides a wealth of information about fluoride. It is written by a fluoride researcher.

Fluoride: Damning New Evidence

Excerpted from “What Doctors Don’t Tell You”, March 1999

Researcher, Doris Jones, has unearthed startling new evidence demonstrating that fluoride interferes with enzymes, damaging many organs of the body.

D1 The fluoride issue, a perennial hot potato, is heating up once again. In Britain, the government has recently announced its intention to fluoridate the water of deprived inner city areas, supposedly to improve the dental health of children living there. Later, water fluoridation may be introduced nationwide. A White Paper outlining the government's plans is scheduled for the spring, 1999 (when-specific date).

D2 The government and the dental profession have convinced the public that fluoridated water offers nothing but benefits-that there is overwhelming evidence that it prevents tooth decay and contributes to the strength of bones. There is tacit admission in the pro-fluoride camp that fluoride can also cause harm, but only at very high levels: 2 ppm in water may cause mottled teeth and 8 ppm may lead to bone disorders and degenerative changes in the vital organs.

D3 A few lone voices have countered the prevailing view, with published evidence that fluoride can have devastating effects, causing mottled teeth and osteoporosis at very low levels. While much has been written about the effects of too much fluoride on teeth and bones, little is known about the effects of fluoride on the rest of the body. But new evidence has emerged demonstrating that it has devastating effects on just about every organ in the body, and may even be partly responsible for behavioural problems like hyperactivity and many puzzling illnesses like ME.

D4 The late fluoride critic George L Waldbott discovered that, besides teeth and bones, fluoride can damage soft tissue. According to his research, the small fluorine ion with a high- charge density can combine with other ions and penetrate every cell in the body. It interferes with the metabolism of calcium and phosphorus and the function of the parathyroid glands. It has a strong affinity to calcium, but will also readily combine with magnesium and manganese ions and so can interfere with many enzyme systems that require these minerals. The interruption of these enzyme systems, in turn, may disturb carbohydrate metabolism, bone formation and nerve-muscle physiology. Indeed, every vital function in the body depends on enzymes; because fluoride easily reaches every organ, many diverse toxic symptoms can result.

D5 "Most diseases are results of disturbances of the enzyme systems," says Professor Abderhalden. "Damage due to fluoride could be shown on 24 enzymes." Enzyme systems react to fluoride in different ways; some are activated, others are inhibited. Lipase (essential for the digestion of fat) and phosphatases are very sensitive to fluoride. In patients with skeletal fluorosis, succinate dehydrogenase activity is inhibited. In chronic fluoride poisoning, this diminished enzyme activity accounts for muscular weakness and even muscle wasting. Human salivary acid phosphatase is diminished by half when exposed to 3.8 ppm of fluoride, while blood enzyme cholinesterase is inhibited by 61 per cent on exposure to 0.95 ppm 74

fluoride-a level within recommended levels So what does this do in the body? (Author, Handbook of Experimental Pharmacology, Springer Verlag, 1970: 48-97).

D6 Alkaline phosphatase, an enzyme involved in bone growth and liver function, may also be poorly affected by low-level fluoride intake. According to scientists from the Department of Chemistry of the University of California at San Diego, fluoride switches off an enzyme by attacking its weakest links-the delicately balanced network of hydrogen bonds surrounding the enzyme's active sites (J Biol Chem, 1984; 259: 12984-88).

D7 Their particular studies concerned the enzyme cytochrome C oxidase, an oxygen- carrying respiratory enzyme; deficiencies of this vital enzyme have been linked to cancer, severe diseases and even cot death.

D8 It's also been shown by research at Kings College in London that fluoride forms very strong hydrogen bonds with amides, which are formed when amino acids join together to form a protein (J Am Chem Soc, 1981; 103: 24-8). This can also cause chromosomal damage. If the protein is greatly distorted, the body's immune system no longer recognises it, treats it as a foreign protein and will try to destroy it, which in turn triggers allergic skin or gastrointestinal reactions (J Yiamouyannis, Fluoride: The Aging Factor ,. Delaware, Ohio: Health Action Press, 1993: 94-9).

D9 Stomach and bowel disorders are the main features of fluoride intolerance. Even small amounts of fluoride can form hydrofluoric acid in the stomach to produce gastric pains, nausea and vomiting. Young children are particularly at risk. Fluoride tablets can even cause gastric haemorrhages; in one instance, a 9-year-old boy sustained such damage that he required the removal of large parts of his stomach (Fluoride, 1977; 10: 149-51).

D10 The most readily identifiable feature of soft-tissue fluorosis is extraordinary general fatigue, which is frequently linked to thyroid deficiency. The thyroid gland requires iodine to produce the hormone thyroxine, which controls the rate of metabolism in the body. But when fluorine is present, it displaces iodine, which will cause a thyroid gland to stop working properly (K Roholm: Fluor and Fluorverbindungen, in: Handbuch Experimenteller Pharmakologie, Ergaenzungswerk, Vol.7, Springer, 1938: 20).

D11 The parathyroid gland, which regulates the distribution of calcium and phosphorus in the body, is extremely sensitive to excessive amounts of fluoride. Over fifty years ago, Indian clinicians found a close relationship between skeletal fluorosis and hyperparathyroidism (J Hyg 1942; 42: 500-4).

D12 Fluoride has even been shown to affect the pituitary gland, which controls growth rate by regulating the production of thyroid hormones (Seances Soc Biol Fil, 1930; 103: 981-2). In animals, less than normal amounts of thyroid hormones are produced when animals are given water containing a fluoride content equivalent to that of artificial water fluoridation (Bull Schweiz Akad Med Wiss, 1954; 10: 211-20). Using scanning electron-microscope photographs, Professor AK Susheela of the Fluoride and Fluorosis Research Foundation of India and Senior Consultant to the Indian government, who has published over 100 scientific papers on the hazards of fluoride, proved that when exposed to fluoride, red blood cells are killed prematurely, lowering haemoglobin and causing anaemia.

D13 She also showed that calcium levels diminish as fluoride levels in the body rise; the gastrointestinal tract mucosa is damaged, causing irritable bowel syndrome; and blood fluoride levels rise continuously with prolonged use of fluoridated toothpaste.

D14 When people are bombarded with fluoride, in the form of fluoridated water, toothpaste and mouth rinses, muscles and elements of connective tissue, particularly collagen fibre and bone tissue, undergo degenerative changes.

D15 At the 1998 US Conference of the International Society for Fluoride Research in Bellingham, Washington, Dr Jennifer Luke from the University of Surrey, UK, presented evidence on the effects of low and high doses of fluoride on the pineal gland in gerbils. In both gerbils and humans this gland helps control the aging process and the production of melatonin, which regulates the sleep/wake cycle. Gerbils exposed to a high level of fluoride experienced a significant decrease in the production of melatonin, and earlier genital maturation. While animal studies may not always be applicable to humans, Dr Luke theorised that mass fluoridation may be behind the general decline in the age of puberty in the West (Fluoride, 1998; 31: 4: 175).

D16 In areas where water is fluoridated, evidence shows that dangerously high fluoride concentrations accumulate in many soft tissues and organs of the population, including the heart, kidney and bladder; the highest level ever recorded-8400 ppm-was found in the aortas of people living in Grand Rapids, Michigan, where fluoride was first introduced in America.

D17 The heart and blood vessels are affected by fluoride. Cardiac irregularities and low blood pressure have been noted in experimental poisoning using large doses (Publ Health Report, 1956;71:459-67). In 1950, five years after experimental introduction of fluoride into drinking water in Grand Rapids, Michigan, the number of deaths from heart disease nearly doubled (The Grand Rapid Herald, July 28, 1955). Death rates due to cancer, intracranial lesions, diabetes and arteriosclerosis were all markedly increased compared to death rates per 100,000 in the entire state.

D18 In electrographic studies, Japanese researcher Taka Mori showed a direct link between damage to the heart and dental fluorosis in children who drank water with a fluoride content of 0.5-6.2 ppm. Fluoride also affects arteries, causing bruise-like skin lesions called "Chizzola maculae'", showing inflammatory areas around capillary blood vessels. Because fluoride attracts calcium, it contributes to their hardening. Fluoride affects the brain and entire central nervous system. Neurological problems like headaches, vertigo, spasticity in extremities, visual disturbances and impaired mental acuity can all result. Tissue damage to anterior horn cells has been found (Fluoride,1975;8:61-85). Official annual statistics revealed that death rates among malnourished children in the Chilean town of Curico, fluoridated since 1953, were to 104 per cent higher than in comparable, non-fluoridated towns, and the general mortality was higher by 113 per cent, compared with the average for the country (Ziegelbecker R et al, Journal? 1995:47-48).

Fluoride, hyperactivity and violence D19 Several studies have shown that exposure to fluoride can cause behavioural changes (Int Clin Psychopharmacol, 1994;9:79-82; Neurotoxicol and Teratol, 1995;17:169-77; Fluoride, 1996;29:187-88) At a 1998 Conference on Fluoride, Professor Roger Masters reported a link between the blood lead levels of 280,000 children in Massachusetts and the use of silicofluorides for water fluoridation. Here and in Georgia, behaviours associated with lead toxicity, such as violent crime, are more frequent in communities using silicofluorides than in areas not using them. At the same conference Dr Phyllis Mullenix reported results of a study using two steroids to treat childhood leukaemia, one of which had a fluorine atom in its structure. In the study, this steroid caused behaviour patterns typical of hyperactivity. A follow-up study of children using this drug for two years showed a significant drop in average IQ scores, compared with children using the non-fluoride drug (Fluoride, Nov.1998;31;4:175).

D20 In one family in Glasgow, every member is severely affected by fluoride-the mother experienced an anaphylactic shock to Prozac, which contains fluorine, and all four children exhibited erratic/violent behaviour and suffered from immune system damage on exposure to fluoride (in their drinking water?

Fluoride and ME D21 Although few researchers have looked at the role of fluoride in the development of ME, there are conspicuous similarities between key features of ME/CFS and those seen in the very early stages of chronic fluoride intoxication (Fluoride,1998; 31:13-20)

D22 Dr John McLaren Howard of Biolab in London offers a few important clues why. He discovered that ME patients experience reduced movement of white blood cells when exposed to quite low levels of fluoride (InterAction 14, Autumn, 1994:53-54). This effect on white blood cells might render patients less able to fight infections efficiently, or lead to an exacerbation of their health problems.

D23 Fluoride also interferes with phagocytosis ,as well as causing the release of superoxide free radicals in resting white blood cells. This means that fluoride slows down and weakens the very cells which serve as the body's defence system; bacteria, viruses, chemicals and the body's own damaged or cancerous cells are then allowed to wreak havoc. Minor infections take longer to throw off and cause more serious illness (John Yiamouiannis, The Aging Factor, Health Action Press, 1993:p32). This is precisely what appears to be happening in many cases of ME.

D24 We do not know how many children or teenagers had topical high concentration fluoride dental treatment before succumbing to infections which led to ME/CFS. My son had fluoride treatment to prevent tooth decay in the autumn of 1979, after which his health dramatically deteriorated, commencing with gastric problems, various minor infections, then glandular fever, followed by atypical measles, more infections and eventually resulting in ME in 1980. In the end the fluoride treatment didn't work in preventing tooth decay-he's needed 15 fillings over the past nine years.

D25 The American pathologist Majid Ali explains that chronic fatigue results due to "accelerated oxidative molecular injury". Only a well functioning enzyme system can protect us from such injury and maintain normal energy levels. In chronic fatigue there is a high frequency of membrane deformities, due to increased oxidative stress on the cell membranes, which is why sufferers lack energy. Interestingly, Ali also highlights gastrointestinal disturbances, such as IBS, as playing a significant part in chronic fatigue (The Canary and Chronic Fatigue, Life Span Press, 1994).

D26 Many ME patients have an underactive thyroid (InterAction 27, Sept.1998:27). Chronic fatigue and exhaustion due to hypothyroidism is a cardinal feature in the Chronic Fluoride Toxicity Syndrome.

D27 Experienced researchers who have studied ME for decades maintain that as with polio, it is damage to anterior horn cells caused by a gut virus, which explains why polio victims are paralysed or suffer from impaired motor function (The Clin and Scientific Basis of ME/CFS). But fluoride has also been shown to damage anterior horn cells . Gastrointestinal disturbances, often referred to as IBS, are also known to play a significant part in ME, as they are in the Chronic Fluoride Toxicity Syndrome.

D28 Severe sleep disturbances, or reversal of sleep rhythm, are a common feature in ME/CFS (Clin). Deposits of large quantities of fluoride in the pineal gland of animals have caused similar problems (Ref. J Luke, Bellingham Conference, 1998). 77

D29 At this point, no one knows to what extent these syndromes overlap, or fluoride or fluorine facilitates the development of ME by various biological agents. The indications are that fluoride may act as as a "facilitating co-factor" and exacerbate existing problems in such patients. Or it could be, as Dr H C Moolenburgh suggests, that ME is one of the end stages of a general chemical poisoning, with fluoride one of the worse offenders (personal communication, 7.1.1999). Although many unanswered questions remain, one thing can be said with certainty. Fluoride not only is not beneficial, but may turn out to be one of the major factors in the serious health problems besetting modern man.

Doris Jones

Source: http://www.nofluoride.com/what_doctors_donot_tell.cfm

Damning new evidence

Appendix E. YARA UK Guidelines for the Handling of Hexafluorosilicic Acid

Appendix F CAL Laboratory Analysis of Hexafluorosilicic Acid

Source: http://www.wmaf.org.uk/userfiles/CAL%20Lab%20Anal%20and%20explanation.pdf

Appendix G Evidence-based medicine (EBM)

The concept of EBM is about making sure that when decisions are made they are made on the basis of the most up-to-date, solid, reliable, scientific evidence. In the case of medicine or health care, these are the decisions about the care of individual patients.

“Evidence-based practice is the conscientious explicit and judicious use of current best evidence in helping individual patients make decisions about their care in the light of their personal values and beliefs.”

What sort of evidence are we looking for? “Current best evidence”. Not perfect evidence – simply, the best there is. But not old or out-of-date evidence ; we need to find modern, up-to- date current evidence.

How is this to be done? In a conscientious, explicit and judicious way. Again, the words are important.

Conscientious – being careful, and thorough, in what you do Explicit – being “up-front”, open, clear and transparent Judicious – using good judgement and common sense

If you are going to practice in this way, you have to be able to find evidence from scientific studies that are relevant to your patients. You then have to understand those studies and be able to appraise them (not all studies will be relevant to your patient and even if they are, they may not be good studies). And finally you have to apply those results when making decisions about your patient. This means being able to integrate the evidence with your patients’ personal needs, their values, beliefs and wishes.

Source: http://www.students4bestevidence.net/start-here/what-is-evidence-based-medicine/

Appendix H T-F Index and Dean Index of Dental Fluorosis

The Thylstrup -Fejerskov ( TF) Index Score Criteria 0 Normal translucency of enamel remains after prolonged air-drying.

1 Narrow white lines corresponding to the perikymata. [Dean = Questionable/Very Mild]

2 Smooth surfaces: More pronounced lines of opacity that follow the perikymata. Occasionally confluence of adjacent lines. Occlusal surfaces: Scattered areas of opacity <2 mm in diameter and pronounced opacity of cuspal ridges. [Dean = Questionable/Very Mild] 3 Smooth surfaces: Merging and irregular cloudy areas of opacity. Accentuated drawing of perikymata often visible between opacities. Occlusal surfaces: Confluent areas of marked opacity. Worn areas appear almost normal but usually circumscribed by a rim of opaque enamel. [Dean = Very Mild/Mild] 4 Smooth surfaces: The entire surface exhibits marked opacity or appears chalky white. Parts of surface exposed to attrition appear less affected. Occlusal surfaces: Entire surface exhibits marked opacity. Attrition is often pronounced shortly after eruption. [Dean = Mild/Moderate] 5 Smooth surfaces and occlusal surfaces: Entire surface displays marked opacity wtih focal loss of outermost enamel (pits) <2 mm in diameter. [Dean = Severe]

6 Smooth surfaces: Pits are regularly arranged in horizontal bands <2 mm in vertical extension. Oc clusal surfaces: Confluent areas <3 mm in diameter exhibit loss of enamel. Marked attrition. [Dean = Severe]

7 Smooth surfaces: Loss of outermost enamel in irregular areas involving <1/2 of entire surface. Occlusal surfaces: Changes in the morphology caused by merging pits and marked attrition. [Dean = Severe]

8 Smooth and occlusal surfaces: Loss of outermost enamel involving >1/2 of surface. [Dean = Severe]

9 Smooth and occlusal surfaces: Loss of main part of enamel with change in anatomic appearance of surface. Cervical rim of almost unafffected enamel is often noted. [Dean = Severe]

Source: Thylstrup and Fejerskov, 1978. As Reproduced in “Health Effects of Ingested Fluoride” National Academy of Sciences, 1993. pp. 171.

Correlating TF Index Score with Dean Index Diagnosis (Mabelya 1994)

TF Score Dean Index Diagnosis

Questionable Very Mild Mild Moderate Severe

0 90.2% 7.1%

1 6.1% 50.1% 8.8%

2 3.7% 35.7% 41.0% 4%

3 7.1% 42.2% 50.0% 6.1%

4 7.0% 46.6% 93.9%

5-9 100%

No. of Teeth Examined 895 3696 2293 1226 6730

Average TF Value 1.4 2.5 3.4 3.9 *

SOURCE: Mabelya L, et al. (1994). Comparison of two indices of dental fluorosis in low, moderate, and high fluorosis Tanzanian populations. Community Dentistry & Oral Epidemiology 22:415-20.

Appendix I Why fluoridated water is an illegal product

I.1 In relation to water fluoridation, Directives and Conventions, etc., which originate in Europe or at the United Nations are disregarded by the UK’s Department for Health For example, The UNESCO Universal Declaration on Bioethics and Human Rights, October 2005, Art. 6, is ignored even though the UK is a founding member of that organisation . And it also seems that the UK Government is oblivious to the Rome Statute of the International Criminal Court , 17 July 1998, Article 7k.

Fluoridated water is a prophylactic medicine

I.2 The UK Government denies that fluoridated water is a medicine. Yet fluoride is added to our water supply as a prophylactic substance. This is indisputable since the practice has been in existence since 1945 ever since American researchers ‘pronounced’ that fluoride prevented tooth decay. Having denied that fluoridated water is a medicine , the UK Government and its agencies are now in a corner, i.e. they are now very reluctant to state that fluoride cures a human disease. In fact the MHRA has instructed fluoridating water companies to avoid this claim in any of their published literature. At the same time, they are unable to classify fluoridated water and consequently can’t provide a reason for adding fluoride to drinking water. In the absence of an alternative reason for adding fluoride to drinking water and without an alternative classification, there can be no justification whatsoever for fluoridating 5.7 million people.

I.3 In 1983 Judge Lord Jauncey ruled that fluoridated water (the product) is a medicine within the definition of such in the UK’s Medicines Act 1968 , S.130. The promotion of the product as having the property of preventing dental decay makes its regulation as a medicine mandatory, irrespective of whether it actually has that property (European Court of Justice, Ter Voort decision (C219,91)). I.4 As a medicinal water or as a medicine, only medicinal law applies. The quality standards that apply to drinking water - a food - cannot be enforced on fluoridated public water supplies. (Article 1, Water Quality Directive 80/778/EEC).

I.5 Uncertainty over whether or not fluoridated water should be regulated under the water or medicinal legislation can be traced back at least as far as the 1980 Water Quality Directive (80/778/EEC) . Article 1 stated that ‘This Directive shall not apply to … waters which are medicinal products within the meaning of Council Directive 65/65/EEC …. relating to medicinal products.’

But Article 4 then qualified this by stating that the Directive ‘shall not apply to: . . medicinal waters recognized as such by the competent national authorities.’ (My emphasis added)

I.6 This loophole allowed a national authority to refuse to recognize fluoridated water as a medicinal product. It could then be regulated by default as potable water. However, in Directive 98/83/EC , which replaced 80/778/EEC , this exemption is absent. In effect, from 1998, national authorities could no longer claim that fluoridated water was not a medicinal product simply by refusing to recognize it as such.

I.7 The critical issue is therefore whether or not fluoridated water is a medicinal product. Much of the promotional material issued by proponents of fluoridation contains claims, both explicit and implicit, that its regulation falls under one or more of the Directives dealing with foods, food supplements, medicinal foods, and cosmetics. Some even argue that it is one of the ill-defined ‘borderline products’ that may be a combination of two, or even all three of these three types of product. So if there is doubt that 98/83/EC does apply to fluoridated water, precisely what is its appropriate designation? The answer lies in a poorly understood section of 98/83/EC dealing with products that may be exempt from control under the Directive.

I.8 Article 3 permits member states to exempt drinking water from the water quality directive under specific conditions. The Directive does not apply to any waters that are either natural mineral waters or those that are classed as a medicinal product under 65/65/EEC and its successors. But it goes further than this. Article 3.2 (a) states that

“Member States may exempt from the provisions of this Directive:

(a) water intended exclusively for those purposes for which the competent authorities are satisfied that the quality of the water has no influence, either directly or indirectly, on the health of the consumers concerned.”

I.9 The general assumption appears to be that this exemption may be invoked if 'supplementation' of 'natural fluoride' has no adverse effect on health, and this may account for proponents' claims that the only adverse effect is dental fluorosis, an “insignificant” and “cosmetic effect”. This is fallacious: no substances may be added to drinking water if they have any direct or indirect effect, even if that effect is beneficial. If proponents claim that fluoridation improves the dental health of the population, then this immediately excludes the product from exemption under 98/83/EC , and requires that it be controlled under the foods regulations. But it does more than this. In claiming medicinal properties for fluoridated water, it is mandatory that it be classified as a medicinal product.

I.10 Fluoridated water has no marketing authorisation (medicinal product licence) under medicinal law. It is therefore prohibited to promote or advertise it (Article 3, Medicines (Advertising) Regulations 1994) or to supply it to the public. (Article 87, 2004/27/EC)

I.11 Even though fluoridated water is also an illegal food (see I.13 et seq.) , the main thrust of our argument revolves around the fact that fluoridated water is a medicine and that it is forced on us without our consent. Moreover, fluoridated water has not been clinically tested and is not licensed.

I.12 Dr David Shaw has concluded that the status quo rests on the legal fiction that fluoridated water does not constitute a medicine.” (Ref: Shaw, 2012)

Fluoridated water is also an illegal food

I.13 Not only is fluoridated water a medicine, claims that it is potable food-water also fail as per EU Reg. 1925/2006 and EU Reg. 1170/2009 + UK Reg. 1631/2007 .

I.14 In 2007, EU Reg. 1925/2006 was translated into UK Reg. 1631/2007 – thus legitimising the EU Regulations in the UK. Article 17 of EU Reg. 1925/2006 stipulates the final date after which Annex III of EU Reg. 1170/2009 came fully into force. This date was 19 th January 2014.

I.15 EU Reg. 1170/2009, Annex III, does NOT list hydrofluorosilicic acid (aka hexafluorosilicic acid) and disodium fluorosilicate (aka sodium silicofluoride) as being permitted source compounds for fluoride as an additive to food . Consequently, it is illegal to use water to which hydrofluorosilicic acid has been added for food production. UK food manufacturers are adding a weak solution of hydrofluorosilicic acid to food when it is being made and this is illegal under UK Law (UK Reg. 1631/2007)

I.17 It is legally permitted to use sodium fluoride as the source of fluoride for adding to school milk and to use potassium fluoride as a source of fluoride for adding to salt. Whilst fluoridated salt is available in Europe (but not in the UK) and fluoridated school milk is available in the north of England, the ingesting of both foodstuffs are voluntary and not compulsory and if a school wishes to provide fluoridated milk, the consent of a parent/ guardian has to be sought and granted.

I.18 Notwithstanding the EU law which precludes hydrofluorosilicic acid from being added to foods and notwithstanding the UK law which has translated the EU law, the UK’s Department of Health has issued guidance on EU Regs. 1925/2006 and 1170/2009 and has stated that water is only food when it emerges from the ‘point of compliance’ i.e. when it comes out of the tap.

I.19 However, EU Reg 1925/2006 can only relate to food while it is being made, i.e. pre-food, and it is our contention that raw water during treatment is pre-food. Any other interpretation would be nonsensical. For example, manufacturers do not add baking powder to a packet of cake mix after the cake mix has left the factory. The EU Regulations apply to the raw cake mixture when the ingredients are mixed together. So the same must apply to the pre-food product, drinking water, before it is released from the water treatment works.

I.20 Dr David Shaw dealt with this aspect in his paper (pp. 20-21) and concluded that the decisions reached by the MHRA and the Food Standards’ Agency (FSA) conflict.

I.21 Finally, note that it is also a criminal offence to make any medical claim for a food. (Part 1.2 of Schedule 6 of the UK’s Food Labelling Regulations 1996 ).

Source: http://www.legislation.gov.uk/uksi/1996/1499/schedule/6/made

I.22 If this product is a food, then its promotion as having a preventive property against dental decay, and its manufacture and supply for that purpose, is an offence. The existence of the above Schedule 6 neatly gets around the UK Department of Health’s objection to accepting the validity of EU Reg 1925/2006 in relation to tap water.

I.23 The DH’s opinion is that water is only a food when it emerges from the ‘point of compliance’ – the kitchen tap, means that that Department is admitting that water is food. However, every time water fluoridation is proposed, it’s because it’s supposed to prevent a human disease. Therefore, the inference that is clearly understood by the ordinary man in the street is that there is definitely a claim that food (fluoridated water) is a medicine. This claim is illegal according to the UK’s Food Labelling Regulations 1996 .

I.24 In summary, fluoridated water is a medicine. It is also an illegal medicine because it has not been clinically tested and is not licensed as a medicine. Applying legislation from another limb of the law, fluoridated water is an illegal food and foodstuffs manufactured using fluoridated water are illegal.

I.25 As a postscript, in the event that it is eventually confirmed in a Court of Law that fluoridated water is indeed, and always has been, subject to medicinal law, then the historical implications of evidence that the MHRA, Local Authority Councils and PHE have been warned of this constraint but have deliberately and persistently ignored these warnings, may prove extremely costly indeed. Chronic illnesses and, in particular, Dental Fluorosis, are for life, and action may be brought at any time within three years of a legal ruling that exposure was a causative effect. By implication, Councils may be found to have been acting as accessories in enforcing an improper action against the claimants.

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