A SCIENTIFIC CRITIQUE OF THE FLUORIDATION FORUM REPORT, IRELAND 2002.

Section 1.

Executive Summary

The undersigned scientists have been asked to review the Fluoridation Forum report published on September 10, 2002.

In our view, the report fails to provide a proper scientific review of the many health concerns raised about the practice of water fluoridation in Ireland, and elsewhere. Out of a total of 295 pages, only 17 pages (pp. 108-124) are devoted to health issues other than dental fluorosis. Of these, a heavy reliance is placed on reviewing "other reviews" some of which are dated. Incredibly, for a study which took two years, only 2 pages (pp. 122-3) are devoted to an independent analysis of specific health studies.

The report:

1) Fails to address important studies presented by two of us (Limeback and Connett) in testimony (e.g. the accumulationof fluoride in the pineal gland, Luke, 2001).

2) Fails to address many other important studies in the recent literature, including the studies of Masters and Coplan (1999, 2000), who have showed that the fluoridating reagent (hexafluorosilicic acid) used in Ireland has never been tested in animal testing and has been associated with increased levels of lead in children's blood as well as to an increase in violent behavior. The Forum's claim that this untested industrial grade fluoridating agent replaced sodium fluoride for technical reasons is invalid.

3) Fails to take a comprehensive look at the single health issue that it did examine (hip fractures). The Forum ignored the important of work of Li et al  (2001) and Alarcon-Herrera et al (2001), and failed to acknowledge the significance of important clinical studies.

4) Demonstrates a weakness in their understanding of the basics of toxicology. For example, in their derivation of Tolerable Daily Intakes (TDI), the Forum made three mistakes. The authors failed to use the most sensitive endpoint of fluoride's toxicity (Varner et al, 1998). They failed to use an uncertainty factor for determining a TDI for children under 8  years of age, and they reported a TDI for children over 8 years of age which is twice the acutely toxic -- possibly lethal -- dose!

5) Fails to establish a significant clincial difference in dental decay between children living in fluoridated and non-fluoridated communities in Ireland and throughout largely non-fluoridated Europe. The Forum also failed to acknowledge the several modern studies which have found that dental decay has not increased when fluoridation has been halted in communities in Finland, Cuba, former East Germany and Canada (Maupome et al, 2001; Kunzel and Fischer, 1997, 2000; Kunzel et al, 2000 and Seppa et al, 2000).

6) Fails to deal convincingly with the issue of dental fluorosis, making several unsupportable assertions.

7) Fails to discuss the fact that certain individuals in a population are going to be more sensitive and more vulnerable to fluoride's toxic effects than others. By ignoring the plight of these individuals, the Forum authors are able to duck the implications of a policy which seeks to help some members of society, while hurting others. A similar argument applies to  those individuals who suffer from mild, moderate and severe dental fluorosis.

8) Fails to provide the necessary precautionary advice to nursing mothers not to use infant formula made up with fluoridated tap water. Their failure in this respect is inconsistent with the Scientific Subcommittee of the FSAI (appendix 18) which recommends breastfeeding exclusively for the first four to six months of the baby's life. Even with the modified "optimal" level for water fluoridation lowered to 0.7 ppm, a bottle-fed baby would be getting 70 times more fluoride than a baby which is breast-fed. Not only is the Forum authors' assertion that there is no evidence of increased risk of dental  fluorosis in babies drinking fluoridated water incorrect, but also there are far more serious risks to the baby which they are ignoring.

In our view, by failing to assess properly all the evidence available in the international scientific literature, the Forum wasted a valuable opportunity  to fully engage the scientific case opposing fluoridation as proposed by the Irish Minister of Health when he invited submissions to the Forum. Moreover, the Forum failed to carefully weigh all the evidence. As scientists familiar with the literature on this matter we can only conclude that the aim of the authors of this report was not to study the evidence, but to find ways to get around it. The report's primary conclusion that there are no adverse health effects is not defendable, and in our view, is blatantly false.

Sadly, the omissions and failings in this report, and particularly, the authors' specious justification for using an industrial grade waste product (hexafluorosilicic acid) for the fluoridating agent, if considered on a purely scientific level, are so inexplicable that we are forced to look for other explanations for its weaknesses. The most logical conclusion is that the majority of the panel members (who worked in some capacity for the Irish government, or received their research funding from the same) were persuaded to produce a report in support of this long-standing government policy rather than freely and objectively analyzing the information which was made directly available to them in testimony as well as that available in the open scientific literature.