The Controversy

It is important to note that the EPA gave up oversight regarding water additives, like fluoride, in 1988. There are NO federal safety standards for these substances. The standards are now dictated by industry and have never been approved as safe and effective for the full range of consumption over a lifetime.

The levels of contaminants that are present in these substances vary, batch to batch...the liabilitites rest with the fluoridating substance.

"It is difficult to get a man to understand something when his salary depends on his not understanding it." Upton Sinclair, "The Jungle"

"I am appalled at the prospect of using water as a vehicle for drugs. Fluoride is a corrosive poison that will produce serious effects on a long range basis. Any attempt to use water this way is deplorable."
- Dr. Charles Gordon Heyd, Past President of the American Medical Association.

"a most flagrant abuse of the public trust occasionally occurs when a physician or a dentist, for whatever personal reason, uses their professional standing in the community to argue against fluoridation, a clear violation of professional ethics, the principles of science and community standards of practice" - Michael Easley, Director of the National Center for Fluoridation Policy & Research.

Chemical & Engineering News
August 25, 2003 Fluoride Concerns Surface Once Again

As Waterwatch of Utah, our concern with the fluoridation issue surrounds the risks to the water operator, the impact to the water systems infrastructure and the liabilities this public policy presents.

INTRODUCTION

Water agencies must comply with the requirements mandated by the Federal Safe and Clean Drinking Water Acts. In an effort to meet all the requirements federally mandated, water agencies must assume substantial financial burdens. Unless mandated by a political decision, the fluoridating of public water supplies is not one of those requirements. Additionally, water agencies have a fiduciary responsibility to maintain the highest quality water at the lowest possible price.

Because high amounts of fluoride can be toxic and in an effort to prevent the public from being exposed to harmful levels, the EPA places a cap, or maximum contaminant level, on natural or artificial fluoride concentrations in drinking water. Water fluoridation guidelines were established by the Public Health Service more than 40 years ago. In 1993, the National Academy of Sciences (NAS) Committee reviewed EPA's maximum contaminant levels and maximum contaminant level goals (MCL’s/ MCLG’s) for fluoride and found it to be an appropriate standard until further research was completed. Now that several more studies have been done and because the Safe Drinking Water Act requires periodic reassessment of regulations, the EPA sponsored a new review by the National Research Council (NRC). The NRC is the principal operating arm of the National Academy of Sciences and the National Academy of Engineering. The fluoride review lasted 3 ½ years and was released March 22, 2006.

Since then, the Bassin Report linking osteosarcoma and fluoride consumption at 1ppm has been released. Both the NRC and the Bassin reports suggest adverse health effects associated with ingestion of fluorides found in or added to the public drinking water supplies.

As concerning the NRC report, the adverse health effects were identified by the dose response of any fluoride chemical that gives off the fluoride ion. By definition, that includes not only calcium fluorides, the most commonly identified naturally occurring fluoride and sodium fluoride but also fluoride additives in the form of fluorosilicic acid (H2SiF6) and the sodium salt (sodium fluosilicate NaSiF6) collectively referred to as fluorosilicates (CDC 1993). Little, if any, scientific literature reviewed by the NRC addressed calcium fluoride, the most commonly identified naturally occurring fluoride chemical.

To represent the NRC report as addressing only naturally occurring fluorides at levels irrelevant to water agencies is factually incorrect.

OUR EXPERIENCE

In 2000, the question, “Shall fluoride be added to the public water supply” was put to a vote. It passed by a very slim margin. The fluoridation of both counties water supplies has been not only contentious but also expensive. There have been lawsuits. The language of the question, the actual substances to be used versus what was implied and the actual versus projected costs have all been contested. How water systems complied varied drastically. Few of the engineering firms had any prior experience with either ‘fluorides’ or the HAZMET or OSHA requirements and as the fluoridating substance is so corrosive, many water systems had a number of problems with implementation. There are, however, systems that were well designed and they have had few problems. But in an effort to allay concerns, the Health Departments of both Counties hired Thomas G. Reeves, formerly the National Fluoridation Engineer with the Oral Health Division of the Center for Disease Control (CDC) now a private consultant. October 13th, 2005, he presented to water operators from both counties.

About the fluoridating substance he stated, “It’s a byproduct of the phosphate fertilizer industry, okay? So when the phosphate fertilizer industry doesn’t need to produce phosphate fertilizer, guess what? You don’t get any acid produced.”

Regarding the fluoride MCL’s and the MCLG’s he said, “It was developed in the late 30’s,40’s and 50’s…and it was based on water consumption.” “This chart, 1.0 [ppm] which is the average amount, is based on two liters of water being consumed by an adult male, 155 pounds. Most males are way over that now, but that’s what it’s based on.” Further, he said, “In Canada, they’ve changed their numbers. Canada should basically be 1.2 and they were for many years. I think they’ve changed theirs to .9. Places like Hong Kong and Singapore have changed theirs to .5.” Later in the presentation Mr. Reeves said, “If you cook water that has 1ppm fluoride, if you cook it over a long period of time…the fluoride level is going to actually increase. …you have water that is at a very high temperature for long periods of time, you can increase the fluoride content up to about 8ppm.”

The 2006 NRC Report states," After reviewing the collective evidence on adverse health effects associated with fluoride, our committee concluded unanimously that EPA should lower the maximum contaminant level goal for fluoride." The MCLG is currently set at 4ppm.

As Stated in the NRC report “On a per-body-weight basis, infants and young children have approximately three to four times greater exposure than do adults.”

In 2005, the USDA published the National Fluoride Database of Selected Beverages and Foods.

So although no water systems fluoridate at 4ppm, the level identified in the NRC report as causing adverse health effects, the question remains, if the fluoridated water is boiled, what are the fluoride levels, then? If the MCL and MCLG levels are based on a 155 lb man drinking two litres of water, how much fluoridated water can be safely ingested by a child, if total exposure from all sources is considered?

As a result of the NRC review, the EPA is now charged with the responsibility of doing a risk assessment that will determine the level of natural or artificial fluorides that will be allowed in the drinking water. That assessment will most likely, take years. And according to Mr. Reeves, “…once you put fluoride in the water, it is very, very difficult to remove, very expensive to remove…”

Our primary concern with public water fluoridation is the impact to the water operator.

• Any silicofluoride offgasses hydrogen fluoride (HF)

• According to the ACGIH (American Conference of Governmental Industrial Hygienists) “The Threshold Limit Value (TLV) for Hydrogen Fluoride was changed as of 2005. The current TLV-TWA is 0.5 ppm, with a TLV-Ceiling of 2 ppm and a Skin notation.” At present, the OSHA PEL for hydrogen fluoride is still set at 2.5 m/m(3). At that level, it has been reported the occupational exposure level can be as high as 25 mg per day, a level several times higher than the 4ppm the NRC committee unanimously agreed caused adverse health effects.

• The most commonly used fluoridation substance is fluosilicic acid (H2SiF6). The acid presents a hazard to the worker not only by the offgassed HF but also by the direct exposure to the acid.

• The dry fluorides, sodium salt (sodium fluosilicate NaSiF6) and sodium fluoride (NaF) present a different set of concerns. The dust when combined with moisture, such as sweat or moisture in the air of the water plant, combines to form an acid solution. There is the additional problem of air particulates. The dust is explosive.

• In light of newly revised ACGIH levels, HAZMET and OSHA standards should be very carefully reviewed to ensure best practice as well as optimal employee safety.

• Tom Reeves (on dry fluorides) “ You really should keep your clothes in the locker when in the environment, in the water plant, but you don’t want to have-get some dust on your clothes, you know, on your overalls or coveralls and go home and your kid comes and gives you a big hug and you’ve got dust on your face. So always change your clothes. Don’t use the same clothes that you use at work going home, especially if you’re around loading or unloading chemical or, you know, filling the saturator and things like that.”

• Tom Reeves “You’re going to have nosebleeds, and the nosebleeds will come unexpectedly. It won’t occur while you are doing this work. You’ll do the work and you’ll clean up and take a shower. Go home and sit there watching TV and all of a sudden, your nose will start bleeding. And of course, it damages your lungs and you can have respiratory problems. “

• Tom Reeves “The point is, it gets dangerous and you should have a mask.”

Also of concern is the cost and impact to the water system and infrastructure.

• Due to poor engineering, many water systems experience infrastructure corrosion. As any silicofluoride offgasses hydrogen fluoride (HF), we encourage water systems require a separate fluoride room, to better protect the rest of the infrastructure from corrosion due to the offgassed HF. A separate fluoride room also provides a better opportunity to monitor and contain exposures, spills and leaks. If done correctly, separate fluoride rooms at each site is expensive. Infrastructure must be very carefully engineered so as to protect the system, the employee and the end-user.

• Tom Reeves “ Remember one thing, fluoride level in your drinking water doesn’t dissipate like chlorine. You have a chlorine demand, chlorine in water over a period of time and over the length of the pipe will dissipate. That is not true with fluoride in your drinking water.”

• Tom Reeves “..It’s never- fluorine as an element - is never found in nature because it is so reactive.”

• NRC Report “…chloramines are produced with an excess of ammonia, which appears to react with silicofluorides to produce an ammonium-fluorosilicate intermediate which facilitates lead dissolution from plumbing components.”

• As the offgassed HF is so corrosive, infrastructure deteriorates. Replacing infrastructure is expensive. Water systems have fiscal priorities which may not include replacing infrastructure every 7-10 years.

There are environmental concerns.

• If there is a spill while offloading the substance, what happens to the neutralized slurry? Is it dumped down the drain? As fluorides do not dissipate as do chlorines and as conventional methods will not remove fluorides from the water, is the sewer system infrastructure capable of removing the fluorides or reducing them to acceptable levels? Is the slurry hauled away to a public landfill? Are empty sodium fluoride bags being taken to a landfill where they are burned and HF, offgassed?

• In addition to other contaminating substances, there is arsenic in most fluoridating substances, in levels upwards of 23ppm. If the arsenic MCLG is 0, how can any arsenic be intentionally added to the water supply? As each batch of fluoridating substance many contain varying amounts of additional contaminants, a complete certificate of analysis should be required with each delivery.

• The EPA classifies fluorides as an inorganic contaminant. As fluorides do not dissipate as do chlorines, to what levels are the Total Dissolved Solid’s (TDS) raised? Can the water classification be downgraded due to the presence of accumulating inorganic fluoride contaminants? What happens to the waters value? Is water quality degraded, reducing its worth?

Liabilities

“From a constitutional standpoint, dental caries is neither communicable nor contagious; therefore, there is no substantial threat to the general public health and safety. Those citizens most susceptible to this non-communicable disease can seek treatment individually by less invasive and more discreetly targeted means.." Legal Issues of Fluoridation Dental Didactics 1999

• NRC Fluoride in Drinking Water: A Scientific Review of EPA's Standards
“Fluoride may be found in drinking water as a natural contaminant or as an additive…”

• Should a vote mandate a Water Provider use a fluoridation chemical that contains arsenic, a known carcinogen, at a concentration that presents a significant cancer risk, which entity will indemnify the water Company against all resulting claims and legal actions?

• As OSHA is responsible for enforcement of the (HF) PEL, what are the requirements imposed on the employer/water district to monitor the HF level to ensure the PEL is not exceeded?

• If no exposure records have been maintained to date, what are the liabilities to water districts? What is the cost of recording then maintaining those records?

• As Stated in the NRC report “On a per-body-weight basis, infants and young children have approximately three to four times greater exposure than do adults.” Therefore, the recently released NRC Report as well as the Bassin report which links osteosarcoma to fluoride at 1ppm raises a question of liabilities.

Finally, should there be a mandate or should the public be allowed to vote on requiring an inorganic contaminant be added to every end-users public water supply, a necessary commodity?

Should the public be allowed to vote on requiring a water system to arbitrarily assume a fiscal responsibility that is not required by either the Safe or Clean Drinking Water Acts?

All things considered, is this even a question that should be placed on a ballot?

Remember, all these concerns must be addressed so that a small percent of the population might drink less than one percent of the total volume of artificially fluoridated water for benefits that are hotly debated and will be legally contested.

One thing is certain.

The 'fluoride' issue involves far more than teeth.

How much fluoride are we already injesting?

How are water systems impacted?