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Follow-up petition on health and environmental concerns regarding fluoride in drinking water

Petition: No. 221B

Issue(s): Environmental assessment, fisheries, human health/environmental health, toxic substances, and water

Petitioner(s): Carole Clinch

Date Received: 7 April 2008

Status: Completed

Summary: In this follow-up petition, the petitioner asks for more responses from several departments about the addition of fluoride (hydrofluorosilicic acid) to our drinking water, which she alleges is causing harm to humans, aquatic life, flora, and the environment. Among other things, the petitioner asks for toxicology reports and studies that demonstrate that the products currently used to add fluoride to drinking water are safe. The petitioner also asks about the potential impact of fluoride on western salmon stocks.

Federal Departments Responsible for Reply: Environment Canada, Fisheries and Oceans Canada, Health Canada, Public Health Agency of Canada

Petition

Petition under the Auditor General Act, section 22 requesting the discontinuation of artificial water fluoridation

H2SiF6 and NaSiF6 do not completely dissociate and reassociate under certain conditions Anthropogenic H2SiF6 and NaSiF6 are more toxic than naturally occurring calcium and sodium fluoride. According to Environment and Transport Canada these chemicals are “Hazardous Waste”, “Toxic Substances” and “Dangerous Goods” which are causing harm to humans, aquatic life, flora and the environment;

In violation of the Fishing Act, section 34(1), which describe the provisions to conserve and protect fish habitat that sustain Canada’s fisheries resources, section 35(1), which prohibits the harmful alteration, disruption or destruction (HADD) of fish habitat, and sections 36-42 which control the deposition of any deleterious substance to water frequented by fish

[Original signed by Carol Clinch]

Carole Clinch BA (Health) BPHE, 307 Normandy Ave, Waterloo, Ontario, Canada,

caclinch@gmail.com, 519-884-8184

Submitted April 7, 2008

Government warnings regarding fluoridated toothpaste and fluoridated mouthwash:
Keep out of reach of children under 6 yrs of age” & “If you swallow more than used for brushing, get medical help or contact a Poison Control Center right away” & "If more than used for brushing is accidentally swallowed, get medical help or contact a Poison Control Centre right away" & Never give fluoridated mouthwash or mouth rinses to children under six years of age, as they may swallow it” & Use non-fluoridated toothpaste or no toothpaste for young children.”

 

Office of the Auditor General of Canada
Commissioner of the Environment and Sustainable Development
Email:   petitions@oag-bvg.gc.ca



Need for Sustainable Development

Need for Sustainable Development

 

Companies should pay for their pollution and disposal of pollutants, instead of getting paid to dispose a hazardous waste, toxic substance and dangerous good into our water supplies.

Background levels of fluoride for Lake Ontario and the St. Lawrence River are up to 0.25mg/L which is double the 0.12mg/L Canadian Water Quality Guideline (CWQG). DWSP http://www.ene.gov.on.ca/envision/water/dwsp/0002/eastern/eastern.htm

Evidence suggests that sewage effluent from fluoridating communities is between 1.0ppm and 1.5ppm.1,2 A review by Camargo 2003 states: “Discharges of fluoridated municipal waters also cause significant increases (about five times the natural background level) in the fluoride concentration of recipient rivers (Sparks et al., 1983; Camargo et al., 1992a).”

Evidence from the study by Daemker and Dey 1989 indicates that Pacific salmon are harmed at levels of about 0.25mg/L.3 Evidence from Camargo 20 demonstrates that net-spinning caddisfly larvae are harmed at fluoride levels as low as 0.2mg/L.

Two food sources for salmon are also shown to be affected by fluoride at low levels. Fluoride levels below 0.1 ppm were shown to be lethal to the water flea, Daphnia magna.4 Alga (Porphyria tenera) was killed by a four-hour fumigation with fluoride with a critical concentration of 0.9 ppm.5

Such demonstrated harm of aquatic species is in violation of the Fishing Act. These violations are not sustainable.

Dissociation of Silicofluorides [H2SiF6 & Na2SiF6] – Summary

Manufacturers do not supply a free-fluoride ion direct water additive. They provide hydrofluorosilicic acid.

The incorrect assumption has been made by some that by the time the hexafluorosilicate ion (silicon ion with 6 fluoride ions attached) H2SiF6 or Na2SiF6 reaches the tap it will have been completely converted into silica and the free fluoride ion. This assumption has not been proven to be correct. In fact, growing evidence (see below) demonstrates that these silicofluoride chemicals do not completely dissociate but form many known and unknown fluoride fluorosilicate compounds when used in foods and beverages.

An “oligomer of silicic acid" or “residual species” are terms used to describe species whose exact composition is not known with certainty; “rarely is fluosilicic acid present as pure H2SiF6. . .there are well reported references to the existence of H2SiF6 ·SiF4”.10

The ability of silicofluorides to separate/dissociate into their component parts (silicon, fluoride) is dependent on several known factors: pH, presence of other substances (metal cations), water hardness, temperature. In low pH environments such as are found in acidic beverages (e.g. fruit juices, tea, coffee) which use fluoridated water, acidic foods and more importantly, in our gut where low pH levels occur, reassociation of fluoride and silicon ions is likely to occur.

Silicon is a multivalent atom -- that is, it forms compounds with more than a single atom of another element. Sodium fluoride (NaF) is a univalent atom – that is, it has one fluoride atom attached to one sodium atom. Because of the above-known facts, complete NaF dissociation cannot be used to "prove" complete dissociation of silicofluorides such as H2SiF6 and Na2SiF6 which contain 6 fluoride ions.

According to [name withheld]; “claims of safety of "water fluoridation" can no longer prevent scientific consideration of the different effects that have been observed where hydrofluosilicic acid (H2SiF6) or sodium silicoflouride (Na2SiF6) have replaced sodium fluoride (NaF) as the compounds used to fluoridate water supplies.” [Information withheld]

Testimony given under oath 2004: [Name and position withheld], Drinking Water Additives Certification Program, National Sanitation Foundation:

Q. Okay. Because if it were shown that it [hydrofluorosilicic acid] did not totally dissociate, we would need to have end points for the compound itself; isn't that correct?

[Name withheld]: That would be correct.

Without definitive research evidence to demonstrate that HFSA totally separates into its component parts (dissociates) toxicology studies must done on the actual chemicals put into our drinking water - H2SiF6 & Na2SiF6. Chronic toxicology studies are lacking on these artificial water fluoridation chemicals used in most systems in Canada. Evidence to date suggests that H2SiF6 & Na2SiF6 are significantly more toxic than calcium fluoride or sodium fluoride.

In a previous petition (#221) to Health Canada [information withheld] the following question was posed: “Testimony under oath to the US Congress by National Sanitation Foundation indicates that NSF is violating its own Standard 60 requirements for chemical additives. [see [name withheld] testimony] NSF is certifying companies which are not in full compliance with Standard 60, [section 3.2.1 requires full and accurate documentation of all impurities in these products and maximum percent or parts by weight, CAS number, chemical name, toxicology studies, selected spectra, etc.]”

Health Canada Response: This statement was later corrected by [name withheld] during the same deposition to the Superior Court of California for the District of San Diego ([Information withheld]… These requirements are generally met when there is a MAC or MCL established by the relevant agency…Because fluorosilicate compounds readily hydrolyses completely to release fluoride ions, NSF's assessment is based on the toxicology of inorganic fluoride.”

Please provide the transcript which provides evidence that [name withheld] corrected [name withheld] deposition as you state above. Here is no exclusion to the published general requirement that allows the product to "generally meet" the published requirement of submitting the data. The product review data submitted to NSF is on the product, which includes the contents, and weights of each specific contaminant. Standard 60 Section 3.2.1 does not request what it will become.

NSF may be proceeding on the basis that they may alter their requirements, but the LAWS require that the manufacturers fulfill the requirements of Standard 60. NSF's disclaimer states that it may not alleviate any responsibility of the manufacturers.

No Toxicology Studies on Hydrofluorosilicic Acid – Letters of Evidence

In a previous response to a petition (#221) requesting any toxicology studies (not a review) on hydrofluorosilicic acid, Health Canada provided a website link to the NIEHS report. Please note what this review (not study) states (p14) regarding Fluorosilicic Acid:

9.1.4 Short-term and Subchronic Exposure  No data were available.
9.1.5 Chronic Exposure  No data were available.
9.1.7 Cytotoxicity No data were available.
9.2 Reproductive and Teratological Effects No data were available.

In a Congressional investigation by the United States House Committee on Science, the Environmental Protection Agency, Center for Disease Control, National Sanitation Foundation, and the Food and Drug Administration, all replied that they have no scientific studies on the actual fluorine-bearing substances used in 90% of the nation’s fluoridation programs. In subsequent communications dated 2000, 2001, 2002, the U.S. EPA National Risk Management Research Laboratory states that they have no empirical scientific data on the health and behavioral effects of hydrofluosilicic acid and sodium silicofluoride, nor on the complete dissociation of these substances, or their interaction with other elements commonly found in drinking water.

1. NSF ([name withheld]) July 7, 2000 response to questions from [name and position withheld], United States House Committee on Science: “There have not been any studies on hydrofluosilicic acid or silicofluorides submitted to NSF under claimed Confidential Business Information protection.”

2. United States Environmental Protection Agency [EPA] response [information withheld] to [name and position withheld]:“In collecting the data for the fact sheet, EPA was not able to identify chronic studies for these chemicals.”

3. EPA response November 16, 2000 from [name and position withheld] to [name and position withheld]: “To answer your first question on whether we have in our possession empirical scientific data on the effects of fluorosilicic acid or sodium silicofluoride on health and behavior, our answer is no.”

4. Letter from Sally C. Gutierrez, Director, Water Supply and Water Resources Division, Office of Research and Development, National Risk Management Research Laboratory, U.S. EPA, Cincinnati to [name withheld], March 15, 2001.

“In January, representatives from the Office of Research and Development (ORD) and the Offices of Science and Technology and Ground Water and Drinking Water met to discuss a number of water related issues including Fluoridation. Several fluoride chemistry related research needs were identified including; (1) accurate and precise values for the stability constants of mixed fluorohydroxo complexes with aluminum (III), iron (III) and other metal cations likely to be found under drinking water conditions and (2) a kinetic model for the dissociation and hydroloysis of fluosilicates and stepwise equilibrium constants for the partial hydrolysis products.As a result of these discussions, ORD is exploring options to initiate research in the identified research areas.”

5. EPA 2002 request for research regarding the measurement of fluorosilicates in drinking water: “soliciting competent researchers capable of completing research projects that fill identified gaps in scientific literature.” “The primary objective of this RFA is to investigate the reactions that take place when fluorosilicates are added to drinking water supplies…”

As of early 2008, questions regarding these “gaps in the scientific literature” remain unanswered.

Research Review

The NRC report on Fluorides in Water, published in December, 2006 p 52-3, 90-99, p 206. NRC 2006 report NRC p52-3 Fluorosilicates

“Most fluoride in drinking water is added in the form of fluosilicic acid (fluorosilicic acid, H2SiF6) or the sodium salt (sodium fluosilicate, Na2SiF6), collectively referred to as fluorosilicates (CDC 1993). Of approximately 10,000 fluoridated water systems included in the CDC’s 1992 fluoridation census, 75% of them (accounting for 90% of the people served) used fluorosilicates. This widespread use of silicofluorides has raised concerns on at least two levels.

First, some authors have reported an association between the use of silicofluorides in community water and elevated blood concentrations of lead in children ([name withheld] and Coplan 1999; [name withheld] et al. 2000); this association is attributed to increased uptake of lead (from whatever source) due to incompletely dissociated silicofluorides remaining in the drinking water ([name withheld] and Coplan 1999; [name withheld] et al. 2000) or to increased leaching of lead into drinking water in systems that use chloramines (instead of chlorine as a disinfectant) and silicofluorides (Allegood 2005; Clabby 2005; Maas et al. 2005).12'13 Macek et al. (2006) have also compared blood lead concentrations in children by method of water fluoridation; they stated that their analysis did not support an association between blood lead concentrations and silicofluorides, but also could not refute it, especially for children living in older housing.

Second, essentially no studies have compared the toxicity of silicofluorides with that of sodium fluoride, based on the assumption that the silicofluorides will have dissociated to free fluoride before consumption (see also Chapter 7).

Both Urbansky (2002) and Morris (2004) indicate that other substances in the water, especially metal cations, might form complexes with fluoride, which, depending on pH and other factors, could influence the amount of fluoride actually present as free fluoride ion. For example, P.J. Jackson et al. (2002) have calculated that at pH 7, in the presence of aluminum, 97.46% of a total fluoride concentration of 1 mg/L is present as fluoride ion, but at pH 6, only 21.35% of the total fluoride is present as fluoride ion, the rest being present in various aluminum fluoride species (primarily AlF2+ and AlF3). Calculations were not reported for pH < 6.

Further research should include analysis of the concentrations of fluoride and various fluoride species or complexes present in tap water, using a range of water samples (e.g., of different hardness and mineral content). In addition, given the expected presence of fluoride ion (from any fluoridation source) and silica (native to the water) in any fluoridated tap water, it would be useful to examine what happens when that tap water is used to make acidic beverages or products (commercially or in homes), especially fruit juice from concentrate, tea, and soft drinks. Although neither Urbansky (2002) nor Morris (2004) discusses such beverages, both indicate that at pH < 5, SiF62- would be present, so it seems reasonable to expect that some SiF62- would be present in acidic beverages but not in the tap water used to prepare the beverages. Consumption rates of these beverages are high for many people, and therefore the possibility of biological effects of SiF62-, as opposed to free fluoride ion, should be examined.”

FLUORIDE VS FLUOROSILICATE: RELATIVE TOXICITY

          TABLE 39: - Availability of Fluorine in Various Forms – Kick 19357

Fluorine Supplement Time on ration Fluorine ingested Fluorine in feces Fluorine absorbed Fluorine in urine Fluorine balance Fluorine retained
  Days Mg. Mg. Mg. Mg. Mg. Pct.
Rock phosphate (untreated) 11 217.2 128.7 88.5 31.5 +57.0 26.2
Rock phosphate (untreated) 10 213.6 131.5 82.1 20.5 +61.6 28.8
Sodium fluosilicate 23 269.9 94.3 175.6 93.6 +82.0 30.4
Sodium fluosilicate 22 259.9 94.4 175.5 90.2 +85.3 31.6
Sodium fluoride 18 211.2 116.5 94.7 25.8 +68.9 32.6
Calcium fluoride 11 229.6 225.5 4.1 4.2 -00.1 0.0

Many fluorides did not behave like calcium fluoride - the “natural fluoride”, as can be seen in the above table. Unlike calcium fluoride, sodium fluoride was retained in great amounts in the body and was very toxic. Rock phosphate and sodium fluosilicate experiments yielded the same information.7

Zipkin8 results imply that soft tissue of young male mammals suffer more exposure to fluoride from H2SiF6 and Na2SiF6 than from sodium fluoride. This is consistent with reversible equilibrium chemistry since the fluoride-bearing dissociation species in silicofluorides should undergo re-association at stomach pH around 2, regenerating membrane-permeable fluorinated silicic acid (SA) derivatives that would not be produced from sodium fluoride.

A comparison of lethal doses of fluorides in guinea pigs by Simonin et al showed:9 Hydrofluorosilicic acid 200 mg/kg, Sodium fluorosilicate 250 mg/kg, Sodium fluoride 250 mg/kg, Calcium fluoride 5,000 mg/kg. Hydrofluorosilicic acid was 20 times more toxic than “naturally occurring” calcium fluoride.

TWO papers have been published in NEUROTOXICOLOGY by [name withheld] and Coplan and one presented by them to the International Neurotoxicology Society - i.e., the leading publication in the field of toxins that harm brain chemistry and behavior. They demonstrate that silicofluorides are not biologically equivalent to “fluoride ions”, are associated with increased lead levels in drinking water and blood lead levels in young children and that silicofluorides do not completely dissociate.
Silicofluorides inhibit Acetylcholinesterase (AChE)

Coplan et al 200710 (see attached) reviews the literature regarding fluorosilicate dissociation and toxicology. They discuss the research which demonstrates that silicofluorides interfere with cholinergic function. Specifically, silicofluorides inhibit Acetylcholinesterase.

Voluntary and involuntary muscle action is stimulated by acetylcholine (ACh) which is cleaved by the enzyme acetylcholinesterase (AChE) to end the stimulation. Without AChE, muscle excitation would persist as spasm with potentially lethal effect, as caused by a nerve gas.

Competitive Inhibition: Hydrogen fluoride forms from free fluoride ions released by NaF and the silicofluorides H2SiF6 and Na2siF6. This causes “competitive inhibition” of acetylcholinesterase. “HF [hydrogen fluoride] from the F- in NaFW [sodium fluoride] caused ‘‘competitive’’ inhibition; (ie it blocked enzyme active sites).”

NoncompetitiveInhibition: Silicofluorides also demonstrated ‘‘non-competitive’’ inhibition by distorting enzyme shape making active sites inaccessible.

Sodium fluoride—Competitive Inhibition of Acetylcholinesterase

Silicofluorides—Competitive Inhibition + Noncompetitive Inhibition of Acetylcholinesterase

Hence, for the same total fluoride in the system, silicofluorides induced competitive plus non-competitive acetylcholinesterase inhibition. These combined actions (competitive and non-competitive inhibition) created more powerful inhibitory effects than just the inhibitory effects by sodium fluoride (NaF). (Westendorf thesis, pp. 47-48)

Urbansky 200212 states the following; “Unlike the fully ionized state of fluoride (F-) in water treated with sodium fluoride (NaFW), the SiF anion, [SiF6]2- in SiFW releases F- in a complicated dissociation process which is not currently understood.” He goes on to say; “There is considerable debate over the composition and even the existence of some homo- and heteroleptic aquo-, fluoro-, and hydroxo complexes of silicon- (IV), which makes it impossible to predict what species might be found in real potable water supplies that are fluoridated or those that naturally contain fluoride and silicates as background ions.”

Machalinski et al13 reported that the four different human leukemic cell lines were more susceptible to the effects of fluorosilicates (SiF), the compounds most often used in fluoridation, than to sodium fluoride (NaF). “silicofluoride complex (SiF) has biological effects that are even more potent than those of simple fluoride released by sodium fluoride.” "The early response effect of Na2SiF6 was greater, and in several cases significantly greater, than NaF on clonogenic growth and the induction of apoptosis in all four cell lines." “In conclusion, our findings revealed that human leukemic cells can be influenced and damaged by different forms of fluorine compounds. A substantially more evident effect was caused by silicofluoride complex (SiF) compared to simple fluoride ion released by sodium fluoride.”

A study was made of the fluorine-ion content in the vegetables and grain grown on experimental plots of land fertilized for 4-6 years with fluorine-containing fertilizers: active slurry potassium tetrafluoroborate and sodium fluorosilicate.14 The animals of the experimental groups manifested a lowering of the prothrombin index by the end of the 6th month of the experimental studies. There was a statistically significant fall in the cholinesterase activity and an increase in the activity of glutaminopyruvic aminotransferase (by 35-42 units). Dizer et al 200221 demonstrate how secondary effluent inhibited AChE activity in muscle tissue and significantly increased DNA fragmentation in liver tissue of rainbow trout.

DISSOCIATION—REASSOCIATION

According to Crosby15 silicofluorides are unlikely to dissociate completely under water plant conditions, producing only free fluoride and silicic acid without side reactions (as was assumed when SiF was originally approved) because the silicofluoride moiety [SiF6]2- can react with Al(OH)3 to produce a number of derivative compounds. Moreover, silicofluoride residues may reassociate either within the stomach or in food preparation as discussed in the NRC 2006 Report cited above.

The research by McClure17 demonstrates again that complete dissociation is not probable; “In dilute aqueous solutions the hydrolysis of these two fluorine salts yielding fluoride ions is comparatively simple in the case of the sodium fluoride, which is practically completely ionized, but quite complex and somewhat obscure in the case of sodium fluosilicate." McClure's replication confirms data on percentage of fluorine retained but does not challenge Kick's finding of a difference in pathways of excretion (which is consistent with hypothesis of different biochemical side-effects from residual species of silicate found by Westendorf).

Experimental evidence is found in Westendorf 1975 and Knappwost et al 1974.19 Due to incomplete dissociation of SiF compounds into their component elements, there is a "residual complex" of silicate remaining in water that, while not definitively identified, has effects different from those when sodium fluoride is added to water. The "residual complex" from SiF has a biological effect on acetylcholinesterase inhibition, which can be dangerous because acetylcholinesterase controls the action of acetylcholine (ACh), a neurotransmitter that plays an important role in memory and other brain functions. "If one assumes that a uniform product forms as a result of hydrolysis, complex ions of the type [SiF2(OH)4]2- should be present under these conditions, which by way of the pH value and temperature approximated physiological conditions. A coordination number other than 6 is not to be expected for the Si in aqueous solution. The small concentration inhibits chain formation, as it is often observed in silicon chemistry. Of course this possibility can nonetheless not be ruled out. " (thesis, p 36).

When the safety standards for the "fluoride" were considered by a special committee convened by the [name and position withheld] in 1983, not only was there no consideration of silicofluorides but the definition of "harmful" effects was limited to death from disease.

The announcement of and Request for Public Comments on Substances Nominated to the National Toxicology Program (NTP) http://ntp.niehs.nih.gov/index.cfm?objectid=06F4DFA4-E88B-0FBA-AB0D93CEFA9DDE9D establishes the absence of contrary evidence regarding safety and efficacy of hexafluorosilicic acid and sodium hexafluoroslicate in the hands of the Center for Disease Control, EPA or other U.S. governmental agencies.

CONCLUSIONS

The decline in salmon stocks, especially Chinook and Coho, is a major economic problem for both commercial and sport fisheries. In the US, the Chinook salmon is being considered for listing under the Endangered Species Act. There has been no change in the "permissible level" of 1.5 ppm fluoride in Canada. There are many questions, but until evidence to the contrary is available, based on impartial field studies, in order to protect salmon species and caddisfly larvae, the "critical level" of fluoride in fresh water should be 0.2 mg/L. Decreases in water volume and/or flow velocity have the potential to increase fluoride concentration. Increased water temperature will enhance fluoride toxicity. It is clear that, in the case of artificially fluoridated communities, the concentration of fluoride in both surface run-off and sewer effluent exceeds 0.2 ppm.

The scientific evidence does not support the contention by Health Canada that fluorosilicates H2SiF6 and Na2SiF6 completely dissociate or never reassociate. In the absence of such evidence, toxicity studies are required for the actual products put into our drinking water. In the absence of toxicity studies demonstrating safety, the practice of water fluoridation is not permissible.

QUESTIONS

  1. Is it the position of Health Canada that the National Research Council <http://salsa.democracyinaction.org/dia/track.jsp?v=2&c=K2VaYqqv%2Biet3GbpS16EQaZhNcxmbAOQ> 507-page report of March 22, 2006, is not relevant to water fluoridation? Would you please provide any written analysis by you (or by any other government agency)?
  2. Will Health Canada please provide the transcript evidence that [name withheld] corrected [name withheld] deposition as you state above (page 3)?
  3. Has Health Canada or the Public Health Service made the public aware that we are putting hydrofluorosilicic acid or sodium silicofluoride in our drinking water – a man-made toxic substance, according to CEPA – not “fluoride”? If so, please provide evidence of where this information is available to the public.
  4. Will Health Canada, Environment Canada, Natural Resources or Fisheries and Oceans produce evidence that the research has clearly demonstrated that these fluorosilicate products completely dissociate and will never reassociate under any conditions? (e.g., acid environments in source water created by acid rain, acidic foods, beverages – tea, coffee, fruit beverages – gut, bladder)? If yes, did they evaluate dissociation of fluosilicate at different pH (3 to 8)? Please provide references.
  5. Do Health Canada, Public Health Service, Environment Canada, Natural Resources and Fisheries and Oceans agree with [name withheld] from NSF (National Sanitation Foundation) that in the absence of definitive proof that Na2SiF6 and H2SiF6 completely dissociate, toxicology tests should be performed on these products? If not, why not?
  6. Do Health Canada, Public Health Service, Natural Resources and Fisheries and Oceans and Environment Canada disagree with the evidence and conclusions of the NRC 2006 and above researchers that Na2SiF6 and H2SiF6 do not completely dissociate? If so, how so?
  7. Can Health Canada provide a published laboratory experiment that shows the dissociation of all SIX fluoride atoms from H2SiF6 or Na2SiF6? That is, merely because some of the Fluoride dissociates, it doesn't automatically follow that ALL six fluoride atoms dissociate. These compounds are "hexasilicates" (i.e., there are 6 Fluoride atoms on each molecule). For an indication that not all fluoride atoms necessarily dissociate, see evidence in Westendorf thesis, pp. 48-50.
  8. Can Health Canada provide a peer-reviewed scientific publication that DISPROVES Westendorf's finding that, when siliocofluorides are added to water, after some if not all of the six fluoride atoms have dissociated from the original silicofluoride molecule, there is an incompete dissociation of the REST of the silicate (leaving behind what Westendorf calls a "residual species") ?
  9. Can Health Canada provide a peer-reviewed scientific publication that DISPROVES Westendorf's finding that "residual complex" (which Westendorf doesn't pretend to have established definitively) has independent effects on acetylcholinesterase inhibition (an important effect on human biochemistry) that are greater than free Fluoride (thesis, pp. 47-48)?
  10. Do Health Canada, Environment Canada, Natural Resources and Fisheries and Oceans refute the evidence above that these man-made fluoride substances used in artificial water fluoridation (Na2SiF6 and H2SiF6) may be more toxic than naturally-occurring fluoride substances such as calcium fluoride and sodium? If so, how so?
  11. Health Canada stated in a previous petition response: “The standard (National Sanitation Foundation (NSF) Standard 60) requires a toxicology review to determine that the product is safe at its maximum use level and to evaluate potential contaminants in the product, such as those mentioned.” Has Health Canada been able to obtain any actual chronic toxicology studies (not a review) from the National Sanitation Foundation for hydrofluorosilicic acid (H2SiF6) which they certify for sale to municipalities across Canada? According to 2004 evidence under oath, NSF was unable to find this research, after certifying these products since 1988 – 20 years.
  12. Can Health Canada provide proof that chronic toxicology studies have been performed on H2SiF6 and Na2SiF6 after the EPA, NSF and FDA have all replied that these studies do not exist and the USA NTP program has recommended research to compensate for this lack of information? Since the NIEHS review (not study) provided by Health Canada in response to petition #221 states clearly that there are no chronic toxicology studies on hydrofluorosilicic acid, the petitioner asks Health Canada AGAIN for ANY toxicology study on H2SiF6.
  13. Can Health Canada provide irrefutable proof (scientific studies, not reviews) that H2SiF6 and Na2SiF6 are safe for human consumption, at recommended doses, for a lifetime of ingestion? Please provide scientific evidence which demonstrates clearly and unequivocally that there are no adverse health effects with the use of water fluoridated at the recommended concentration levels of 0.8-1.0mg/L.
  14. Manufacturers do not supply a free-fluoride ion direct water additive. They provide hydrofluorosilicic acid. Is Health Canada convinced that no due diligence is required on the part of provinces and municipalities which voluntarily use NSF standards, to determine whether NSF Standard 60 actually offers an assurance of safety, when the products they sell have never been tested for safety?
  15. What are the end products in food when processed with Na2SiF6 and H2SiF6? What species of fluorosilicates are then produced? Is H2SiF6 a legal food additive? Please provide references.
  16. Does H2SiF6 have a Drug Identification Number (DIN)? If so, please provide DIN number and source of this information.
  17. Is the endorsement of water fluoridation from trade organizations and some government organizations sufficient reason to implement and continue a policy?
  18. Is the Health Canada response to the previous petition regarding [name withheld] (p 3 above) an admission that the manufacturers have not submitted all product review data as required by Standard 60, and instead are assessed by NSF on another criteria?
  19. Does Health Canada agree that complete NaF dissociation cannot be used to "prove" complete dissociation of silicofluorides such as HsSiF6 and Na2SiF6 which contain 6 fluoride ions? If not, why not?
  20. Can Environment Canada, Natural Resources or Fisheries and Oceans demonstrate that fluoride did NOT play a role in the catastrophic decline in salmonid stocks in the once highly productive ecosystem along the Thompson, Columbia and Fraser Rivers?

Citations:

  1. Singer, L, Armstrong, WD, Fluoride in Treated Sewage and in Rain and Snow, 1977, Archives of Environmental Health, Jan/Feb 21-23.
  2. Foulkes RG, Anderson AC. 1994 Impact of Artificial Fluoridation on Salmon Species in the Northwest USA and British Columbia, Canada. Fluoride, 1994, 27:4 220-226.
  3. Daemker, DM, Dey, DB. Evidence for fluoride effects on salmon passage at John Day Dam, Columbia River 1982-1986, North American Journal of fisheries management, 1989, 9, 154-162.
  4. Dave G. Effects of fluoride on growth reproduction and survival in Daphnia magna, Comparative Biochemistry and Physiology, 78c (2) 425-431 1984.
  5. Ishio S, Makagawa H (1971). Cited in: Rose D. Marier J. Environmental Fluoride 1977. National Research Council of Canada, Ottawa 1977, p 30.
  6. Cameron, J.A., 1940. The effect of fluorine on the hatching time and hatching stage in Raga pipiens. Ecology, 21: 288.
  7. Kick CH, Bethke RM, Edgington BH, Wilder OHM, Record PR, Wilder W, Hill TJ, Chase SW - “Fluorine in Animal Nutrition” Bulletin 558, Ohio Agricultural Experiment Station (1935).
  8. Zipkin I, et al. Urinary fluoride levels associated with use of fluoridated water. Pub Health Rep 1956;71:767–72.
  9. Simonin P, Pierron A. 1937 Toxicite brute des derives fluores CR séances Soc Biol Fil 124: 133-134. From page 88 of Waldbott 1978. – “Calcium fluoride [CaF2] is 20 times less toxic than H2SiF6 or Na2SiF6.”
  10. [Information withheld]
  11. Maas RP, Patch SC, Christian AM, Coplan MJ 2007 Effects of fluoridation and disinfection agent combinations on lead leaching from leaded-brass parts. Neurotoxicology. Sep;28(5):1023-31.
  12. Urbansky ET. The fate of fluorosilicate drinking water additives. Chem Rev 2002;102(8):2837–54.
  13. Machalinski B, Baskiewicz-Masiuk M, Sadowska B, Machalinska A, Marchlewicz M, Wiszniewska B, Stecewicza I. 2003 The Influence of Sodium Fluoride and Sodium Hexafluorosilicate on Human Leukemic Cell Lines. Fluoride Vol. 36 No. 4 231-240.
  14.  Lykova AS, Mitrofanova AI, Skachkov MA. 1981 [Effect of rations containing fluorine ion on biochemical and hematological indices of body status] Vopr Pitan. Nov-Dec;(6):46-7. [Article in Russian]
  15. Crosby, N.T. 1969. Equilibria of fluorosilicate solutions with special reference to the fluoridation of public water supplies. Journal of Applied Chemistry 19:100-102.
  16. Feldman, I, Morkin, D, and Hodge, HC. "The State of Fluoride in Drinking Water," Journal of Dental Research, 36:2 (1957) 192-202.
  17. McClure, F.J., "Availability of Fluorine in Sodium Fluoride vs. Sodium Fluosilicate." US Public Health Service Report 65 (1950), pp. 1175-1186; reprinted in Fluoride Drinking Waters (Washington: US Public Health Service, 1962), 825: 527-532.
  18. Finney WF, Wilson E, Callender A, Morris MD, Beck LW. 2006 Reexamination of hexafluorosilicate hydrolysis by 19F NMR and pH measurement. Environmental science & technology ;40:2572-7.
  19. Westendorf J. 1974 Die kinetik der acetylocholinesterase himmung und die beeinflussung der permeabilitat von erytrozytenmemranen durch fluorid und fluorocomplex-jonen. Ph.D. thesis, University of Hamburg; Hamburg; 1975 & Knappwost A, Westendorf J. 1974 Inhibition of cholinesterases caused by fluorine complex of silicon and of iron [in German] Naturwissenschatten 61(6): 275.
  20. Camargo JA. Fluoride toxicity to aquatic organisms: a review. Chemosphere. 2003 Jan;50(3):251-64).
  21. Dizer H, Wittekindt E, Fischer B, Hansen PD. The cytotoxic and genotoxic potential of surface water and wastewater effluents as determined by bioluminescence, umu-assays and selected biomarkers. Chemosphere. 2002 Jan;46(2):225-33.

2 *Attachments:

Westendorf Thesis                                 Coplan 2007

GOVERNMENT AGENCIES
Health Canada                                     Environment Canada
Fisheries and Oceans                            Natural Resources

*[attachments not posted]

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Minister's Response: Environment Canada

14 August 2008

Ms. Carole Clinch
307 Normandy Avenue
Waterloo, Ontario
N2K 1X6

Dear Ms. Clinch:

I am pleased to provide Environment Canada’s response to your Environmental Petition No. 221-B, to the Interim Commissioner of the Environment and Sustainable Development, regarding the addition of fluorination chemicals to drinking water as it relates to their dissociation and toxicity. Your petition was received in the Department on April 7, 2008.

The enclosed response addresses the issues that fall under Environment Canada’s mandate. I understand that the Minister of Health, the Honourable Tony Clement, will be responding separately to questions that fall under the mandate of his department.

I appreciate this opportunity to respond to your petition and trust that you will find this information helpful.

Sincerely,

[Original signed by John Baird, Minister of the Environment]

John Baird, P.C., M.P.

Enclosure

c.c.: The Honourable Tony Clement, P.C., M.P.
The Honourable Loyola Hearn, P.C., M.P.
The Honourable Gary Lunn, P.C., M.P.
Mr. Ronald C. Thompson, Interim Commissioner of the Environment and Sustainable Development


Environment Canada’s Response to
Environmental Petition No. 221-B, requesting
discontinuation of artificial water fluoridation

Question 4:Will Health Canada, Environment Canada, Natural Resources or Fisheries and Oceans produce evidence that the research has clearly demonstrated that these fluorosilicate products completely dissociate and will never reassociate under any conditions? (e.g., acid environments in source water created by acid, acidic foods, beverages—tea, coffee, fruit beverages - gut, bladder)? If yes, did they evaluate dissociation of fluosilicate at different pH (3 to 8)? Please provide references.

Response: Any information that Environment Canada has on the dissociation of these fluorosilicate compounds would be what is already found in published scientific literature.

Question 5: Do Health Canada, Public Health Service, Environment Canada, Natural Resources and Fisheries and Oceans agree with [name withheld] from NSF (National Sanitation Foundation) that in the absence of definitive proof that Na2SiF6 and H2SiF6 completely dissociate, toxicology tests should be performed on these products? If not, why not?

Question 6: Do Health Canada, Public Health Service, Natural Resources and Fisheries and Oceans and Environment Canada disagree with the evidence and conclusions of the NRC 2006 and above researchers that NA2SiF6 and H2SiF6 do not completely dissociate? If so, how so?

Question 10: Do Health Canada, Environment Canada, Natural Resources and Fisheries and Oceans refute the evidence above that these man-made fluoride substances used in artificial water fluoridation (Na2SiF6 and H2SiF6) may be more toxic than naturally-occurring fluoride substances such as calcium fluoride and sodium? If so, how so?

Response to Questions 5, 6 and 10: Environment Canada has no position on any statements that may have been made by [name withheld] or [name withheld] organization. Our risk assessment for aquatic organisms, based primarily on sodium fluoride (NaF), is deemed to be protective for all inorganic fluorides. There is too little data on the aquatic toxicity of the above-mentioned salts to reach a conclusion on their toxicity relative to other forms of fluoride (salts). It is always preferable to base risk assessments on data for the substance of concern; however, if it were true that the above-mentioned salts did not completely dissociate, it is likely that they would be less toxic than NaF, since undissociated salts are generally less toxic to aquatic life than the corresponding free ion.

Question 20: Can Environment Canada, Natural Resources or Fisheries and Oceans demonstrate that fluoride did NOT play a role in the catastrophic decline in salmonid stocks in the once highly productive ecosystem along the Thompson, Columbia and Fraser Rivers?

Response: Although it is true that west coast salmon stocks are currently experiencing low returns, it is highly unlikely that fluoride concentrations are in any way responsible. A combination of factors such as over-fishing, habitat destruction, warmer than normal conditions, and fluctuation in marine and freshwater survival are likely the main factors.

Environment Canada monitoring data for fluoride on the Columbia River, upstream and downstream of Trail, British Columbia, does not indicate an increase in fluoride concentration in recent years. In fact, the station downstream of Trail (Waneta—see the attached graph) indicates a decrease in fluoride from the early 1980s to approximately mid-1995; since then, the level has been fairly stable. This decrease was likely due to upgrading at the Teck Cominco smelter at Trail, which occurred during that period. All samples taken since the late 1980s are less than the B.C. water quality criterion for the protection of aquatic life (0.2 milligrams/Litre [mg/L]).

Data for Fraser River stations and the Thompson River is available from 1985 to 1999. All values were less than the B.C. water quality criterion for the protection of aquatic life, with the exception of one value in 1998, at the Fraser River Red Pass site (Environment Canada’s upstream reference site, just downstream of Mt. Robson Provincial Park), where a single reading just exceeds the hardness-adjusted criterion of 0.3 mg/L. There is no apparent trend in the fluoride levels in the Fraser River, except for a possible downward trend at the downstream Hope site (circa 1999).

The monitoring data is being compared to the B.C. water quality criteria rather than the Canadian Council of Ministers of the Environment Canadian water quality guidelines for the protection of aquatic life (0.12 mg/L), as the former are more applicable to the specific environmental conditions of B.C. It is important to note that, given the conservative nature of water quality guidelines in Canada, the small exceedance of a guideline is not an indicator of harm, but rather a trigger for closer examination of the situation, including understanding natural background concentrations.

The B.C. water quality criterion for the protection of aquatic life state that the total fluoride concentration of freshwaters should not exceed 0.2 mg/L when hardness is less than 50 mg/L, or 0.3 mg/L when hardness is greater than or equal to 50 mg/L. The criterion is designed for soft, coastal waters where salmon species reproduce, and apply everywhere in B.C. where natural, uncontaminated background levels of fluoride do not exceed the criterion. It should be noted that the value of 0.2 mg/L fluoride is greater than the mean value for all lakes and rivers in B.C. The criterion document further explains that if normal uncontaminated background fluoride levels exceed 0.2 mg/L then organisms living there will have adapted to these high fluoride levels (Neuhold and Sigler, 1960). Water with normally low fluoride levels should not be increased beyond 0.2 mg/L, because such levels could stress unadapted organisms.

Apart from naturally high background levels of 0.2 to 0.3 mg/L in the Okanagan Valley, only one coastal and three interior water samples showed fluoride levels over 0.2 mg/L, excluding contaminated areas around Trail and Kimberley. In interior areas where natural hardness levels and natural fluoride levels are elevated, a higher criterion level for fluoride is not judged to be harmful. Thus a level of 0.3 mg/L in areas where natural hardness levels exceed 50 mg/L is not likely to stress organisms already adapted to fluoride levels in this range.

The water chemistry of the Skeena River system is similar to the Fraser, Columbia and Thompson rivers, and the fluoride concentrations are similar. The salmon population in the Skeena River system indicates consistently large returns. This indicates that fluctuations in salmon population in these rivers are more likely affected by factors other than fluoride concentrations.

With respect to salmon population in these river systems, the interior Fraser coho (predominantly the North and South Thompson River populations, but including the other Fraser River populations) experienced a decline in returns starting in 1994 that extended to 2000 and then re-occurred in the fall of 2006. Juvenile tagging programs indicate that the loss of coho is occurring during the early marine periods and is not related to fishing mortality (no directed coho fishing since the mid-1990s). The Fraser sockeye population exhibits cyclical abundance and returns are sensitive to marine survival conditions. Chinook populations in the Fraser and Thompson rivers have generally increased in abundance from the early 1970s, but, similar to coho salmon, have also shown recent declines due to poor marine survival. Populations of salmon in the Columbia River are impacted by hydroelectric dams, but the chinook salmon abundance has increased in recent years.

All of the salmonid populations are being affected by poor marine and freshwater survival, due to warmer than normal water temperatures in the southern parts of their range. Survival dramatically increases with latitude and cooler marine temperatures. Based on a comparison of the available monitoring data, there is no indication that the fluoride levels in the three river systems were the causative agents for the decline of the salmonid population.




 

Page 4

Columbia River at Birchbank

Fluoride (mg/L)

mg/L

BC Aquatic Life Guideline

0.2 mg/L (Hardness < 50 mg/L)

0.3 mg/L (Hardness > 50 mg/L)

Specific Conductivity

Fluoride

uS/cm

Jan-83


Page 5

Columbia River at Waneta

Fluoride (mg/L)

mg/L

BC Aquatic Life Guideline – 0.3 mg/L

99% of Hardness values > 50 mg/L

(0.2 mg/L if H < 50 mg/L, 0.3 mg/L if H > 50 mg/L)

Specific Conductivity

Fluoride

uS/cm

Jan-83


Page 6

Fraser River at Red Pass

Fluoride (mg/L)

mg/L

BC Aquatic Life Guideline – 0.3 mg/L

99% of Hardness values > 50 mg/L

(0.2 mg/L if H < 50 mg/L, 0.3 mg/L if H > 50 mg/L)

Specific Conductivity

Fluoride

uS/cm

Jan-83


Page 7

Fraser River at Marguerite

Fluoride (mg/L)

mg/L

BC Aquatic Life Guideline

0.2 mg/L (Hardness < 50 mg/L)

0.3 mg/L (Hardness > 50 mg/L)

Specific Conductivity

Fluoride

uS/cm

Jan-83


Page 8

Fraser River at Hope

Fluoride (mg/L)

mg/L

BC Aquatic Life Guideline

0.2 mg/L (Hardness < 50 mg/L)

0.3 mg/L (Hardness > 50 mg/L)

Specific Conductivity

Fluoride

uS/cm

Jan-83


Page 9

Thompson River at Spences Bridge

Fluoride (mg/L)

mg/L

Specific Conductivity

Fluoride

BC Aquatic Life Guideline
(0.2 mg/L if H < 50 mg/L, 0.3 mg/L if H > 50 mg/L)

uS/cm

Jan-83

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Minister's Response: Fisheries and Oceans Canada

July 30, 2008

Ms. Carole Clinch
307 Normandy Avenue
Waterloo, Ontario
N2K 1X6

Dear Ms. Clinch:

Thank you for sharing your concerns in your Environmental Petition No. 221-B, submitted to me on April 22, 2008, under the provisions of the Auditor General Act by the Commissioner of the Environment and Sustainable Development. The questions in your petition were addressed to many departments, including Fisheries and Oceans Canada (DFO). I would like to explain the mandate of the Department and answer the questions that are addressed to my Department (see attachment).

Mandate of Fisheries and Oceans Canada

Before answering your questions, we would like to take this opportunity to provide you with the mandate of DFO related to the conservation and protection of fish and fish habitat. The federal government has constitutional authority for seacoast and inland fisheries. The Minister of Fisheries and Oceans is responsible to parliament for the Fisheries Act. The Fisheries Act contains provisions to conserve and protect fish habitat (defined in subsection 34(1) of the Act as “spawning grounds and nursery, rearing, food supply and migration areas on which fish depend directly or indirectly in order to carry out their life processes”) that sustain Canada’s existing and potential fisheries resources.

There are two types of habitat-related provisions in the Fisheries Act: habitat protection and pollution prevention. A key habitat protection provision is subsection 35(1). This section prohibits the harmful alteration, disruption or destruction (HADD) of fish habitat caused by works and undertakings without an authorization from the Minister or by regulation. Other habitat protection provisions include those dealing with obstructions impeding the free passage of fish, the minimum flow of water for fish and the destruction of fish by means other than fishing. Environment Canada administers the pollution prevention provisions (sections 36 - 42) which control the deposition of any deleterious substances to water frequented by fish. Subsection 36 of the Fisheries Act is the key pollution prevention provision.

You will find enclosed detailed responses to questions that were addressed to my Department, and that fall within its mandate.

I appreciate this opportunity to respond to your petition, and I trust that you will find this information helpful.

Sincerely,

[Original signed by Loyola Hearn, Minister of Fisheries and Oceans]

Loyola Hearn, P.C. M.P.

Attachment

c.c.: The Honourable John Baird, P.C., M.P.
The Honourable Gary Lunn, P.C., M.P.,
The Honourable Tony Clement, P.C., M.P.,
Mr. Scott Vaughan, Commissioner of the Environment and Sustainable Development

 


 

Environmental Petition 221-B
Discontinuation of Water Fluoridation

RESPONSE FROM THE MINISTER OF FISHERIES AND OCEANS

Questions addressed to Fisheries and Oceans Canada

Question 4: Will Health Canada, Environment Canada, Natural Resources or Fisheries and Oceans produce evidence that the research has clearly demonstrated that these fluorosilicate products completely dissociate and will never reassociate under any conditions? (e.g., acid environments in source water created by acid, acidic foods, beverages - tea, coffee, fruit beverages - gut, bladder)? If yes, did they evaluate dissociation of fluosilicate at different pH (3 to 8)? Please provide references.

Response: My colleague the Honourable John Baird, Minister of the Environment will be responding to this question.

Question 5: Do Health Canada, Public Health Service, Environment Canada, Natural Resources and Fisheries and Oceans agree with [name withheld] from NSF (National Sanitation Foundation) that in the absence of definitive proof that Na2SiF6 and H2SiF6 completely dissociate, toxicology tests should be performed on these products? If not, why not?

Response: While DFO will take into consideration the position of other experts, DFO’s conclusions are based on internal scientific reviews of available relevant information.

Question 6: Do Health Canada, Public Health Service, Natural Resources and Fisheries and Oceans and Environment Canada disagree with the evidence and conclusions of the NRC 2006 and above researchers that NA2SiF6 and H2SiF6 do not completely dissociate? If so, how so?

Response: DFO has no position on the evidence and conclusions of the 2006 United States National Research Council (NRC) report and above researchers. While DFO takes the findings of other experts into consideration, DFO’s position is based on conclusions of internal scientific reviews of available relevant information, not on the stated position of other individuals and agencies.

Question 10: Do Health Canada, Environment Canada, Natural Resources and Fisheries and Oceans refute the evidence above that these man-made fluoride substances used in artificial water fluoridation (Na2SiF6 and H2SiF6) may be more toxic than naturally-occurring fluoride substances such as calcium fluoride and sodium? If so, how so?

Response: DFO has not done toxicity research nor peer review of the literature to refute or confirm the evidence provided above that man-made fluoride substances may be more toxic than naturally-occurring fluoride substances. When providing science advice DFO takes into consideration the position of other experts and available relevant information.

Question 20: Can Environment Canada, Natural Resources or Fisheries and Oceans demonstrate that fluoride did NOT play a role in the catastrophic decline in salmonid stocks in the once highly productive ecosystem along the Thompson, Columbia and Fraser Rivers?

Response: While it is true that west coast salmon stocks are experiencing low returns currently, it is highly unlikely that fluoride concentrations are in any way responsible. A combination of factors such as over-fishing, habitat destruction, warmer than normal conditions, fluctuations in marine and freshwater survival are likely the main drivers.
Environment Canada monitoring data for fluoride on the Columbia River, upstream and downstream of Trail, does not indicate an increase in fluoride concentration during recent years. In fact the station downstream of Trail (Waneta; see the attached graph), indicates a decrease in Fluoride from the early 1980s to about mid-1995; since then the level has been fairly stable. All samples since the late 1980s are less than the British Columbia water quality criterion for the protection of aquatic life (0.2 mg/L).
Data for Fraser River stations and Thompson River are available from 1985 to 1999. All values were less than the B.C. water quality criterion for the protection of aquatic life, with the exception of one value in 1998 at the Fraser River at Red Pass site (our upstream reference site, just downstream of Mt. Robson Provincial Park), where a single reading just exceeds the hardness-adjusted criterion of 0.3 mg/L. There is no apparent trend in the fluoride levels in the Fraser, except for a possible downward trend at downstream Hope site (Circa 1999).
The monitoring data is being compared to the B.C. water quality criteria rather than the CCME Canadian water quality guidelines for the protection of aquatic life (0.12 mg/L), as the former are more applicable to the specific environmental conditions of B.C.
The water chemistry of the Skeena River system is similar to the Fraser, Columbia and Thompson. The fluoride concentrations are similar. The salmon population in the Skeena River system indicates consistently large returns. This indicates that fluctuations in salmon population in these rivers are more likely affected by factors other than fluoride concentrations.
With respect to salmon population in these river systems, the interior Fraser coho (predominately the North and South Thompson River, but includes the other Fraser River populations) experienced a decline in returns starting in 1994 and extending to 2000, then re-occurred in the fall of 2006. Juvenile tagging programs indicate that the loss of coho is occurring during the early marine periods and is not related to fishing mortality (no directed coho fishing since mid-1990s). Fraser sockeye population exhibit cyclical abundance and returns are sensitive to marine survival conditions. Chinook populations in the Fraser and Thompson Rivers have generally increased in abundance from the early 1970’s, but similar to coho salmon, have also shown recent declines due to poor marine survival.
Populations of salmon in the Columbia River are impacted by hydroelectric dams, but the chinook salmon abundance has increased in recent years.
All of the salmonid populations are being affected by poor marine and freshwater survival due to warmer than normal water temperatures in the southern parts of their range. Survival dramatically increases with latitude and cooler marine temperatures.
Based on the comparison of the available monitoring data there is no indication that the fluoride levels in the three river systems were the causative agents for the decline of the salmonid population.

In summary, the involvement of Fisheries and Oceans Canada to date is characterized as providing support to other departments and agencies whose jurisdiction and legislation more directly addresses the activities of water fluoridation. Be assured that the Department will continue to provide information and support with the objective of protecting fish and fish habitat in accordance with the habitat provisions of the Fisheries Act.




 

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Joint Response: Health Canada, Public Health Agency of Canada

18 August 2008

Ms. Carole Clinch
307 Normandy Avenue
Waterloo, Ontario
N2K 1X6

Dear Ms. Clinch:

This is in response to your environmental petition no. 221-B of April 7, 2008, addressed to Mr. Ronald C. Thompson, the former Interim Commissioner of the Environment and Sustainable Development (CESD).

In your petition you raised concerns about the addition of fluoridation chemicals to drinking water as it relates to its safety and toxicity. You also had additional questions about some of the answers Health Canada provided you in your environmental petition no. 221.

I am pleased to provide you with the enclosed joint Health Canada and Public Health Agency of Canada response to your petition. I understand that the Ministers of the Environment, Fisheries and Oceans, and Natural Resources will be responding separately to questions which come under the purview of their respective departments.

I appreciate your interest in this important matter, and I hope that you will find this information useful.

Yours sincerely,

[Original signed by Tony Clement, Minister of Health and the Minister for the Federal Economic Development Initiative for Northern Ontario]

Tony Clement

Enclosure

c.c. Mr. Scott Vaughan, CESD
The Honourable John Baird, P.C., M.P.
The Honourable Gary Lunn, P.C., M.P.
The Honourable Loyola Hearn, P.C., M.P.


Response to
Environmental Petition No. 221B filed by Ms. Carole Clinch
under Section 22 of the Auditor General Act
Received April 22, 2008

Petition requesting the discontinuation of artificial water fluoridation

August 20, 2008

Minister of Health and the Minister for the Federal Economic
Development Initiative for Northern Ontario

Petition to Discontinue Water Fluoridation

The Response of Health Canada to the Petition

Background:

Health Canada works with the provinces and territories to develop the Guidelines for Canadian Drinking Water Quality. The Guidelines are then used by each province and territory as a basis to establish their own requirements for drinking water quality. Fluoride is one of the many substances for which a guideline has been established. The Maximum Acceptable Concentration (MAC) for fluoride has been established taking into consideration all sources of exposure to fluoride, including foods and dental products. In Canada, the fluoridation of drinking water supplies is a decision that is made by each municipality, in collaboration with the appropriate provincial or territorial authority. This decision may also include consultation with residents, often through a referendum.

Fluoride occurs naturally in many source waters in Canada. It can also be added to drinking water as a public health measure to protect dental health and prevent or reduce tooth decay. The fluoridation of drinking water supplies is a well-accepted measure to protect public health and is strongly supported by scientific evidence. Fluoride is used internationally to protect dental health. It has been added to public drinking water supplies around the world for more than half a century, as a public health/dental health measure. The use of fluoride in the prevention of dental caries continues to be endorsed by over 90 national and international professional health organizations including Health Canada, the Canadian Dental Association, the Canadian Medical Association, the World Health Organization and the Food and Drug Administration of the United States.

As part of its ongoing review of the health effects of exposure to fluoride in drinking water, Health Canada convened a panel of experts in January 2007 to provide advice and recommendations based on the current state of relevant science with respect to the fluoridation of water. Advice was sought from the Expert Panel on five specific issues of concern including Total Daily Intake of Fluoride; Dental Fluorosis; Other Health Effects; Risk Assessment; and Drinking Water Fluoridation: Risks and Benefits. Discussions were based on topic-specific literature reviews developed and presented by some of the invited experts.

The report produced by the Expert Panel will be used to help inform the development of an updated fluoride guideline for Canadian drinking water, by ensuring our analysis is based on the latest sciencific evidence. The Expert Panel report was posted online and can be found at http://www.hc-sc.gc.ca/ewh-semt/pubs/water-eau/2008-fluoride-fluorure/index-eng.php.

Health Canada will continue to monitor the science and review new scientific reports and articles which explore possible links between fluoride and various health effects to ensure the health of Canadians is protected.

Q1.       Is it the position of Health Canada that the National Research Council 507 page report of March 22, 2006, is not relevant to water fluoridation? Would you please provide any written analysis by you (or by any other government agency)?

Health Canada response:

Health Canada works in collaboration with the provinces and territories to develop the Guidelines for Canadian Drinking Water Quality. These guidelines are based on original relevant scientific studies that are published in internationally recognized peer-reviewed journals, and the guidelines are reviewed and revised periodically to take into account new and emerging scientific knowledge. Reviews such as the one done by NRC are useful to the extent that they help ensure all relevant science has been considered.

Q2.       Will Health Canada please provide the transcript evidence that [name withheld] corrected [name withheld] deposition as you state above (page 3)?

Health Canada response:

Please contact the Superior Court of the State of California for the County of San Diego to obtain the desired document from the original source.

Q3.       Has Health Canada or the Public Health Service made the public aware that we are putting hydrofluorosilicic acid or sodium silicofluoride in our drinking water- a man-made toxic substance, according to CEPA-not “fluoride”? If so, please provide evidence of where this information is available to the public.

Health Canada response:

As stated in a response to an earlier petition, fluorosilicate compounds readily hydrolyse in water to release fluoride ions, which means that drinking water is not a source of exposure to these compounds. Fluorosilicate compounds are added as a source of the mineral nutrient fluoride.

Health Canada endorses the fluoridation of drinking water to prevent tooth decay, but does not participate in the decision to fluoridate a water supply. Provincial and territorial governments, in collaboration with their municipalities, decide whether or not to fluoridate their drinking water and the amount of fluoride to be added. This decision may include consultation with residents, often through a referendum. Health Canada cannot comment on what information is available to residents of a specific province or territory related to their drinking water.

Public Health Agency of Canada response:

This issue is within the mandate of Health Canada. The Public Health Agency of Canada has not addressed the issues raised in this question.

Q4.       Will Health Canada, Environment Canada, Natural Resources or Fisheries and Oceans produce evidence that the research has clearly demonstrated that these fluorosilicate products completely dissociate and will never reassociate under any conditions? (e.g., acid environments in source water created by acid, acidic foods, beverages-tea, coffee, fruit beverages-gut, bladder)? If yes, did they evaluate dissociation of fluosilicate at different pH (3 to 8)? Please provide references.

Health Canada response:

As stated in the response to question 3, fluorosilicate compounds readily hydrolyse in water to release fluoride ions, which means that drinking water is not a source of exposure to these compounds. This is based on currently available research and science. Health Canada does not conduct research on the chemistry of fluoride species.

The research community has focussed to date on levels that would result from exposures in occupational settings. A review of the toxicological literature on Sodium Hexafluorosilicate and on Fluorosilicic Acid conducted for the National Institute of Environmental Health Sciences is available at the following URL:
http://ntp.niehs.nih.gov/ntp/htdocs/Chem_Background/ExSumPDF/Fluorosilicates.pdf

Q5.       Do Health Canada, Public Health Service, Environment Canada, Natural Resources and Fisheries and Oceans agree with [name withheld] from NSF (National Sanitation Foundation) that in the absence of definitive proof that Na2SiF6 and H2SiF6 completely dissociate, toxicology tests should be performed on these products? If not, why not?

And

Q6.       Do Health Canada, Public Health Service, Natural Resources and Fisheries and Oceans and Environment Canada disagree with the evidence and conclusions of the NRC 2006 and above researchers that NA2SiF6 and H2SiF6 do not completely dissociate? If so, how so?

Health Canada response to Q5 and Q6:

Health Canada has no position on [name withheld] comments or the NRC review. Our conclusions are based on internal scientific reviews of original relevant scientific studies that are published in internationally recognized peer-reviewed journals. Health Canada recommends the use of certified products to ensure the protection of public health. The department works with certification and accreditation bodies to help meet this goal, but has no mandate or authority regarding the certification process.

Public Health Agency of Canada response:

This issue is within the mandate of Health Canada. The Public Health Agency of Canada has not addressed the issues raised in this question.

Q7.       Can Health Canada provide a published laboratory experiment that shows the dissociation of all SIX fluoride atoms from H2SiF6 or Na2SiF6? That is merely because some of the Fluoride dissociates, it doesn’t automatically follow that ALL six fluoride atoms dissociate, These compounds are ‘’hexasilicates’’ (i.e., there are 6 Fluoride atoms on each molecule). For an indication that not all fluoride atoms necessarily dissociate, see evidence in Westendorf thesis, pp. 48-50.

And

Q8.       Can Health Canada provide a peer-reviewed scientific publication that DISPROVES Westendorf’s finding that, when siliocofluorides are added to water, after some if not all of the six fluoride atoms have dissociated from the original silicofluoride molecule, there is an incomplete dissociation of the REST of the silicate (leaving behind what Westendorf calls a ‘’residual species’’)?

And

Q9.       Can Health Canada provide a peer-reviewed scientific publication that DISPROVES Westendorf’s finding that ‘’residual complex’’ (which Westendorf doesn’t pretend to have established definitively) has independent effects on acetylcholinesterase inhibition (an important effect on human biochemistry) that are greater than free Fluoride (thesis, pp.47-48)?

And

Q10.     Do Health Canada, Environment Canada, Natural Resources and Fisheries and Oceans refute the evidence above that these man-made fluoride substances used in artificial water fluoridation (Na2SiF6 and H2SiF6) may be more toxic than naturally-occuring fluoride substances such as calcium fluoride and sodium? If so, how so?

And

Q13.     Can Health Canada provide irrefutable proof (scientific studies, not reviews) that H2SiF6 and Na2SiF6 are safe for human consumption, at recommended doses, for a lifetime of ingestion? Please provide scientific evidence which demonstrates clearly and unequivocally that there are no adverse health effects with the use of water fluoridated at the recommended concentration levels of 0.8-1.0mg/L.

And

Q19.     Does Health Canada agree that complete NaF dissociation cannot be used to ‘’prove’’ complete dissociation of silicofluorides such as H2SiF6 and Na2SiF6 which contain 6 fluoride ions? If not, why not?

Health Canada response to Q7, Q8, Q9, Q10, Q13, Q19:

Health Canada’s position is based on currently available research and science. Health Canada does not conduct research on the chemistry of fluoride species. As mentioned above, the Guidelines for Canadian Drinking Water Quality developed by Health Canada, in consultation with the provincial and territorial governments, are based on original relevant scientific studies that are published in internationally recognized peer-reviewed journals.

Q11.     Health Canada stated in a previous petition response: ‘’The standard (National Sanitation Foundation (NSF) Standard 60) requires a toxicology review to determine that the product is safe at its maximum use level and to evaluate potential contaminants in the product, such as those mentioned.’’ Has Health Canada been able to obtain any actual chronic toxicology studies (not a review) from the National Sanitation Foundation for hydrofluorosilicic acid (H2SiF6) which they certify for sale to municipalities across Canada? According to 2004 evidence under oath, NSF was unable to find this research, after certifying these products since 1988—20 years.

And

Q12.     Can Health Canada provide proof that chronic toxicology studies have been performed on H2SiF6 and Na2SiF6 after the EPA, NSF and FDA have all replied that these studies do not exist and the USA NTP program has recommended research to compensate for this lack of information? Since the NIEHS review (not study) provided by Health Canada in response to petition #221 states clearly that there are no chronic toxicology studies on hydrofluorosilicic acid, the petitioner asks Health Canada AGAIN for ANY toxicology study on H2SiF6.

And

Q14.     Manufacturers do not supply a free-fluoride ion direct water additive. They provide hydrofluorosilicic acid. Is Health Canada convinced that no due diligence is required on the part of provinces and municipalities which voluntarily use NSF standards, to determine whether NSF Standard 60 actually offers an assurance of safety, when the products they sell have never been tested for safety.

And

Q18.     Is the Health Canada response to the previous petition regarding [name withheld] (p3 above) an admission that the manufacturers have not submitted all product review data as required by Standard 60, and instead are assessed by NSF on another criteria?

Health Canada response to Q11, Q12, Q14 and Q18:

Health Canada has not conducted toxicology studies on fluorosilicates. As stated in the response to question 3, fluorosilicate compounds readily hydrolyse in water to release fluoride ions, which means that drinking water is not a source of exposure to these compounds. Health Canada recommends the use of certified products to ensure the protection of public health. The department works with certification and accreditation bodies to help meet this goal, but has no mandate or authority regarding the certification process. Health Canada also works collaboratively with provincial and territorial governments, who are responsible for the safety of drinking water.

Q15.     What are the end products in food when processed with Na2SiF6 and H2SiF6? What species of fluorosilicates are then produced? Is H2SiF6 a legal food additive? Please provide references.

Health Canada response:

Health Canada is not aware of any published literature specific to the transformation products of silicofluorides in food, nor of any reassociations that may take place during food preparation or in food matrices. Any such reactions are likely to depend on a variety of chemical (such as pH) and physical (such as temperature) factors related to the specific food matrix and any food processing that occurs.

Fluorosilicates (including H2SiF6 and Na2SiF6) are not permitted food additives, and as such cannot be directly added to foods, with the exception of bottled water and pre-packaged ice, where their addition is considered as a mineral nutrient rather than as a food additive. Food additives for which provisions exist in the Food and Drug Regulations can be found in the Tables of Division 16 on Health Canada’s website at the following address: http://www.hc-sc.gc.ca/fn-an/legislation/acts-lois/fdr-rad/index-eng.php

Q16.     Does H2SiF6 have a Drug Identification Number (DIN)? If so, please provide DIN number and source of this information.

Health Canada response:

There are a number of drugs that contain various forms of fluoride that have received market authorization. Three of these drugs with valid Drug Identification Numbers (DIN) contain fluorosilicates. Of these three, two are homeopathics and one is an over-the-counter anti-fungal product. You can access Health Canada’s website to identify whether there are any drugs with a DIN containing hydrofluorosilicic acid. Information can be obtained from the following links:

http://www.hc-sc.gc.ca/dhp-mps/prodpharma/databasdon/index_e.html
http://205.193.93.51/dpdonline/changeLanguage.do?formname=/startup.do

Q17.     Is the endorsement of water fluoridation from trade organizations and some government organizations sufficient reason to implement and continue a policy?

Health Canada response:

Health Canada’s decisions are based on internal scientific reviews of available relevant information, not on the stated position of individuals or agencies. The fact that others have reached the same conclusions is stated as a fact, and demonstrates similar independent conclusions from the various agencies.

As part of its ongoing review of the health effects of exposure to fluoride in drinking water, Health Canada convened a panel of experts in January 2007 to provide advice and recommendations based on the current state of relevant science with respect to the fluoridation of water. The report produced by the Expert Panel will be used to help inform the development of an updated fluoride guideline for Canadian drinking water, by ensuring our analysis is based on the latest scientific evidence. The Expert Panel report was posted online and can be found at http://www.hc-sc.gc.ca/ewh-semt/pubs/water-eau/2008-fluoride-fluorure/index-eng.php.

Health Canada will continue to monitor the science and review new scientific reports and articles which explore possible links between fluoride and various health effects to ensure the health of Canadians is protected and to support our decision-making.

Q20.     Can Environment Canada, Natural Resources or Fisheries and Oceans demonstrate that fluoride did NOT play a role in the catastrophic decline in salmonid stocks in the once highly productive ecosystem along the Thompson, Columbia and Fraser Rivers?

Health Canada response:

No response is required from Health Canada