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Follow-up petition on health and environmental concerns regarding fluoridation of drinking water

Petition

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

 Misrepresentation and Omissions of Material Fact
by Federal Government Agencies

H2SiF6 and NaSiF6 are “Hazardous Waste”, “Toxic Substances”, Unregulated and Uncontrolled Drugs which are causing harm to humans, aquatic life and the environment, in violation of the Fisheries 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

by
Carole Clinch
307 Normandy Avenue
Waterloo, Ontario
caclinch@gmail.com

submitted on Nov 24, 2009

[Original signed by Carole Clinch]

To:

Office of the Auditor General of Canada
Commissioner of the Environment and Sustainable Development
240 Sparks Street
Ottawa, Ontario K1A 0G6
Email: petitions@oag-bvg.gc.ca

Artificial Water Fluoridation is not Environmentally Sustainable

The addition of toxic substances, as defined by CEPA, and Hazardous Waste, as defined by Environment Canada and the Basel Convention, into our drinking water and source water is in violation of the Fisheries Act. These violations are not sustainable.

Admission of error by Health Canada has not been corrected on Auditor General Website

Health Canada admitted to this petitioner and the Auditor General of Canada petitions office that incorrect information was provided to petition #221.¹ For example, the Clark et al 2006² paper cited by Health Canada in their petition response does not support the claims made by Health Canada. This paper demonstrates the opposite to the Health Canada claim. The petitioner asked; “Does Health Canada have another Clark et al 2006 study which supports their claims?”

Health Canada replies: “The statement was erroneously assigned to Clark et al in a past response.”

This admission of error did not provide a citation, as requested by this petitioner, to support this claim. The recent Canadian Drinking Water secretariat review actually refutes this claim made by Health Canada in the petition.

This incorrect information has been posted on the Auditor General petitions website for more than a year. Health Canada has not yet given permission to post corrections to this admitted error.

Health Canada's position as reflected in petition responses is quoted and cited by many individuals and groups, including a recent paper by 2 researchers from the University of Toronto.³ It is therefore important that these Health Canada responses to petitioners be accurate.

Absence of citations to support claims is scientifically unacceptable

A scientific review should always provide scientific evidence to support any claims made, based on the basic tenets of scientific procedure. An analysis of the Canadian Drinking Water secretariat (CDW secretariat) 2009 review⁴ available for public comment from September to November 27, 2009⁵ describes claims made by the CDW without citations. For example:

• “since 1996 there has been an overall decreasing trend of dental fluorosis in Canada.”
• "Des données indiquent que dans certains cas – dans la région de Niagara, par exemple – la prévalence a augmenté de façon spectaculaire entre 1994 et 1998"" NOTE: the English translation stated that there was an DECREASE in prevalence.
• “The literature suggests that there are no health consequences associated with mild fluorosis, other than a lower number of caries experienced.”

Health Canada review done by unqualified citizens with known bias and conflicts of interest?

One of the commitments made in the Federal Accountability Act is to: “Make qualified government appointments”. One would expect qualified individuals to have expertise in areas of science and medicine that are relevant to the material facts of the issue.

The CDW secretariat appointed 6 individuals to review the research literature on artificial water fluoridation and prepare the 2009 review. None of these individuals selected for this review appear qualified to do so. The review panel consisted of 4 dentists who would seem unqualified to assess health outside the oral cavity, and 2 individuals with no demonstrated expertise in this subject (a medical doctor and a PhD who have never published an article in a peer-reviewed journal on the subject of fluoride toxicity or artificial water fluoridation chemicals and their chemical interactions in drinking water or physiological systems). One would expect that qualified individuals would be objective and without predetermined positions on the matters at issue, however, the review panel of 6 individuals are known to promote artificial water fluoridation.

As stated by Dr. Philip Michael, Vice-President, Europe, of the International Society of Doctors for the Environment:⁶

“Proper risk assessment of the physiological effects would require the addition of extensive expertise in fluorosis (dental & skeletal) in developmental toxicity, in neuroscience including brain and IQ effects , in endocrinology including pineal gland effects , in thyroid function, in osteopathology including bone cancer , in nephrology, and in effects on the gastrointestinal tract, immune system, reproduction, respiratory function and include allergic/hypersensitive effects.”

It is interesting to note that Health Canada did not consult with Canada's leading expert on fluoride toxicity and efficacy – Dr. Hardy Limeback, DDS, PhD, Head of Preventive Dentistry at the University of Toronto, committee member of the NRC 2006 Review and internationally respected author and researcher on fluorides. His international expertise in this area would have provided much-needed credibility to this panel, apart from the problem of being out-voted if his was the only truly scientific voice on the panel.

If fluoridation has been extensively studied, many experts should exist in Canada and should be used for this review. If many experts on fluoride do not exist, it can be assumed that artificial water fluoridation is not a well evaluated and studied health policy in Canada, and any claims to the contrary are without merit:

Freeze and Lehr in their recent book⁷ describe how international panels set up over the years to assess artificial water fluoridation are “stacked in favor of fluoridation”. Their review of the membership of various panels are “rife with the names of well-known medical and dental researchers who actively campaigned on behalf of fluoridation”. They go on to say that membership of these review panels “was interlocking and incestuous.”

Until an unbiased panel with no conflicts of interest, and demonstrated expertise in the subject of fluoride toxicity can be assembled, it is incomprehensible that any government agency can reasonably regard the findings of such a panel as valid or even relevant.

Pattern of repeating false and misleading information

The propensity of politically motivated organizations to make false and misleading statements regarding artificial water fluoridation seems to be a world-wide problem. The Chairman of the York Review states:⁸ “It is particularly worrying then that statements which mislead the public about the review's findings have been made in press releases and briefings by the British Dental Association, British Medical Association, the National Alliance for Equity in Dental Health and the British Fluoridation Society.”

The Chief Dental Officer for Health Canada is alleged by this petitioner⁹ to have provided incorrect information to government agencies, media and Canadian citizens. This misinformation can be verified by public records and has never been refuted. Four examples are provided:

• The chief dental officer for Health Canada repeatedly claims that artificial water fluoridation is safe, yet the Carcinogen Identification Committee of the California Environmental Protection Agency’s Office of Environmental Health Hazard Assessment (OEHHA)¹⁰ considered a priority ranking of 38 chemicals and has now selected fluoride as one of five chemicals for the possible listing for cancer hazard identification. The research evidence available seems to satisfy the US EPA 2005 Guidelines as “Likely to be Carcinogenic to Humans” or Category 2.^4c,11

Table 1. Chemicals Selected for Preparation of Cancer Hazard Identification Materials and Review for Possible Listing by the Carcinogen Identification Committee

• The chief dental officer for Health Canada assured Halton Regional councillors on November 13, 2008 that the inorganic fluorides used in artificial water fluoridation are “not toxic substances” yet all inorganic fluorides are “toxic substances” according to the Canadian Environmental Protection Act.
• According to the minutes of the Corporation of the Municipality of Red Lake, the chief dental officer for Health Canada stated that “fluorosis is not caused by water fluoridation” yet the research literature describes a clear, unambiguous association between fluoride intake, and fluorosis diseases that is not refuted. "Clearly the simplest way of reducing the prevalence of fluorosis in child populations is to cease to fluoridate community water supplies."¹²
• Health Canada in petition #221 states: “Fluoride used in drinking water fluoridation is therefore, not considered a drug under the Food and Drugs Act.”

Fluoride and its salts are considered to be drugs in Canada. The government of Canada does not regulate this drug when used in artificial water fluoridation, in accordance with Federal Legislation. Under the Federal Pharmacy Act drugs are listed and published by NAPRA (National Association of Pharmacy Regulatory Authorities). Drugs are regulated by Health Canada and sodium fluoride is listed as Schedule I for more than 1 mg of fluoride/day and schedule III for less than 1 mg of fluoride/day. (See www.napra.org. and search for sodium fluoride.)

Schedule I drugs requires a doctor's prescription for his/her patient record.

Schedule III drugs (must be purchased in a pharmacy only, but is available for patient self-selection) The only time a drug can be given to a person without their consent is due to age (minor) or mental incapacitation.

Please Note: At 0.7 mg/L of fluoride in drinking water, consuming 6 glasses of water (1.5L) would appear to place drinking water into Schedule I drugs which require a prescription.

Also of concern is a commissioned project by the head of the Dental Public Health department in Toronto (Azarpazhooh A, Stewart H. Oral Health Consequences of the Cessation of Water Fluoridation in Toronto 2006 August). The Public Health Department has thus far been unwilling to release this document, paid for by taxpayers. The research does not support the hypothesis that discontinuing artificial water fluoridation will affect cavity rates.

QUESTIONS
Question #1: Will Health Canada correct the information that they provided on the auditor general petitions website which they themselves admitted is incorrect? If so, will they provide a citation for this information from peer-reviewed research – not from their own website material?

Question #2: Should it not be standard practise for the Auditor General petitions office to automatically correct erroneous information when it is detected on the Auditor General's website, so that misinformation does not continue to be disseminated to the public, the media, politicians and researchers?

Question #3: Health Canada only looked at five studies of the available 23 human studies and the 50 animal studies showing an association between fluoride and lowered intelligence. A scientifically rigorous “weight of evidence” assessment presents all of the available evidence both supporting and opposing an hypothesis. Health Canada cites no studies which did not find an association between fluoride exposure and lowered IQs and they omitted most of the available research literature that supports this association. Since Health Canada does not appear to follow the scientifically acceptable procedures for “weight of evidence” assessment, why does Health Canada believe that their assessment is a valid “weight of evidence”?

Question #4: A translation error was made in the CDW secretariat document whereby the opposite information is provided in French and English. No citation is provided for this claim, making it impossible for Canadian citizens to confirm which version is correct. Does Health Canada believe that the omission of research to support claims is acceptable in a scientific review document?

Question #5: Is the failure of the CDW secretariat to provide citations or any kind of supporting documentation for various claims, an attempt to block transparency and accountability to the Canadian taxpayer who funds these reviews?

Question #6: Is the Canadian Drinking Water secretariat willing to make available on their website the unpublished Clark 2006 document frequently cited in their review, which is paid for taxpayers, so that citizens may analyze the document for accuracy, in an open and transparent manner, consistent with the Accountability Act?

Question #7: Will Health Canada now assemble; a) an unbiased committee with no conflicts of interest; b) that is qualified to do a review of fluoridation research literature? If not, why not?

Question #8: I am concerned that there are still important errors that are being made by Health Canada representatives. I have on numerous occasions tried to correct incorrect information that is being provided to Canadian citizens and Canadian politicians. Despite my best efforts to provide factual information, I see misinformation being repeated in cities and towns across Canada by the Chief Dental Officer for Health Canada. Do Health Canada representatives have a duty to perform due diligence and act to correct all misrepresentations and omissions of material fact? If so, would Health Canada please respond to the four alleged false and misleading statements mentioned in this petition on pages 3 and 4 above?

Question #9: Is there any onus on Health Canada to be accountable for misrepresentations and omissions of material fact and to ensure that they provide information to other government agencies which is accurate?

Question #10: Is Health Canada aware that the Carcinogen Identification Committee of the California Environmental Protection Agency’s Office of Environmental Health Hazard Assessment (OEHHA) has now selected fluoride for the possible listing for cancer hazard identification. Is Health Canada aware that fluoride satisfies the US EPA 2005 Guidelines as “Likely to be Carcinogenic to Humans” or Category 2? If not, why not?

Question #11: On April 1, 2008 during a public presentation in Dryden, Ontario, the Chief Dental Officer of Health Canada stated; "I walked down your high street today and I didn't see anybody growing horns - and Dryden has been fluoridated for 40 years!" Is it an official policy position for Health Canada that fluorosis disease involves the “growing of horns”? If so, please provide scientific evidence.

Question #12: The Chief Dental Officer for Health Canada in a presentation to Thunder Bay city council on December 3, 2008 stated; “In, for example, British Columbia you tend to have a lot of what we call tree-huggers or environmentalist folks. They tend to feel that they are not comfortable with fluoride in the water." Is it official policy for Health Canada to describe anyone who is concerned about the environment as “tree-huggers”?

Question #13: Should Health Canada regulate the fluoride drugs added to drinking water?

Question #14: Would the Public Health Agency of Canada demand that the Azarpazhooh & Stewart 2006 meta-analysis commissioned by the Public Health Dental department of Toronto, demonstrating that the cessation of artificial water fluoridation does not lead to an increase in cavities, paid for by taxpayers, be released to the public? If not, why not?

Concluding Remarks

The Scientific Method underpinning research presupposes a willingness to continually re-examine scientific evidence and assumptions. Science is not a collection of facts but a process of weeding out misinformation and testing preliminary results with care and diligence. Scientific discourse attempts to refute what has been found, not to gather supporting evidence for the status quo. It is failure to refute a theory despite diligent, well constructed attempts, that strengthens a theory. The public relies on the scientific community to do this.

There is currently no means for holding scientists accountable for things they may say in the public forum by either self-regulation or government legislation. Therefore, any individual(s) who distort(s) or misrepresent(s) scientific evidence and known facts for reasons of ignorance, political expedience, financial gain, or self-interest imperil(s) the integrity of scientific discourse and leads to an erosion of public trust in our government institutions where policy decisions regarding public health are deemed to be made, based on scientific evidence.

These issues are important enough for the Auditor General's office to become engaged. I would recommend:

a) an audit on this subject and the Health Canada 2009 Review process on this subject by the Auditor General of Canada;

b) a Judicial or Parliamentary Review on the Health Canada Review process for artificial water fluoridation.

Government Agencies

Health Canada

Environment Canada

Public Health Agency of Canada

and any other responsible departments

Citations

1. Clinch CA. 2008 Health and environmental concerns regarding the fluoridation of drinking water. Petition 221: http://www.oag-bvg.gc.ca/internet/English/pet_221_e_30308.html

2. Clark DC, Shulman JD, Maupome G, Levy SM. 2006 Changes in Dental Fluorosis Following Cessation of Water Fluoridation. Community of Dental and Oral Epidemiology Jun;34(3):197-204. “When fluoride was removed from the water supply in 1992, the prevalence and severity of TFI scores decreased significantly-” http://www.ncbi.nlm.nih.gov/pubmed/16674751?ordinalpos=3&itool=EntrezSystem2.PEntrez.Pubmed.Pubmed_ResultsPanel.Pubmed_
DefaultReportPanel.Pubmed_RVDocSum

3. Quinonez CR, Locker D. 2009 Public Opinions on Community Water Fluoridation. Can J Pub Health 100(2):96-100.

4. Clinch CA. 2009 (a) Letter to CDW: http://fluoridealert.org/re/canada.report.letter.clinch.pdf
(b) Response to CDW: http://fluoridealert.org/re/canada.report.response.clinch.pdf
(c) Omissions by CDW: http://fluoridealert.org/re/canada.report.omissions.clinch.pdf
Connett P. 2009 http://fluoridealert.org/re/connett.canada.11-11.09.pdf

5. CDW secretariat. http://www.hc-sc.gc.ca/ewh-semt/consult/_2009/fluoride-fluorure/index-eng.php & http://www.hc-sc.gc.ca/ewh-semt/consult/_2009/fluoride-fluorure/index-fra.php

6. Dr. Phillip Michael's June 2, 2009, comments on behalf of the International Society of Doctors for the Environment to: European Union Scientific Committee on Health and Environmental Risks (SCHER): Fluoridation - Call for Information. http://fluoridealert.org/michael-2009.html

7. Freeze RA, Lehr JH. 2009 The Fluoride Wars: How a Modest Public Health Measure Became America's Longest Running Political Melodrama. Wiley ISBN: 978-0-470-44833-5, p156.

8. Sheldon T, chair of the York Review 2000. Chewing over the facts about fluoride and our dental health. http://www.yorkshirepost.co.uk/letters-to-the-editor/Chewing-over-the-facts-about.1651774.jp

9. Clinch CA 2009 False and Misleading Statements. Available at: http://www.newmediaexplorer.org/chris/2009/10/26/people_for_safe_drinking_water.htm

10. Announcement of Chemicals Selected by OEHHA for Consideration for Listing by the Carcinogen Identification Committee and Request for Relevant Information on the Carcinogenic Hazards of These Chemicals under Proposition 65. http://www.oehha.ca.gov/prop65/CRNR_notices/state_listing/data_callin/sqe101509.html

11. The 2005 United States Environmental Protection Agency guidelines for carcinogenicity are available at: http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=116283Discussion of available evidence supporting these guidelines is available in document 4 (c) above.

12. Affidavit submission by Michele Giddings, Manager of the Water Quality and Science Division in the Water Quality and Health Bureau, Millership vs British Columbia and Canada (Attorney General) Oct 10, 2001, BC Supreme Court 82, Exhibit 15, pg.151, citing the Locker Report. An update of the 1996 Federal-Provincial subcommittee report. Prepared for Public Health branch, Ontario Ministry of Health, First Nation and Intuit Health Branch, Health Canada by Community Health Services Research Unit. Faculty of Dentistry, University of Toronto, November 15, 1999.

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Joint Response: Health Canada, Public Health Agency Canada

25 March 2010

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

Dear Ms. Clinch:

This is in response to your environmental petition no. 221-E of November 24, 2009, addressed to the Commissioner of the Environment and Sustainable Development (CESD).

In your petition, you raised concerns about the addition of fluoridation chemicals to drinking water.

I am pleased to provide you with the enclosed joint Health Canada and Public Health Agency of Canada response to your petition.

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

Sincerely,

[Original signed by Leona Aglukkaq, Minister of Health]

Leona Aglukkaq

Enclosure

c.c.  Mr. Scott Vaughan, CESD

Response to
Environmental Petition 221-E filed by Ms. Carole Clinch
under section 22 of the Auditor General Act
Received December 10, 2009

Petition requesting the discontinuation of artificial water fluoridation

April 9, 2010

Minister of Health

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.

In January 2007, Health Canada convened a panel of experts to provide advice and recommendations based on the current state of relevant science with respect to fluoride in drinking 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 Expert Panel report was posted online and can be found at
www.hc-sc.gc.ca/ewh-semt/pubs/water-eau/2008-fluoride-fluorure/index-eng.php.

The report produced by the Expert Panel was used to help inform the development of an updated guideline for fluoride in drinking water. In September 2009, Health Canada published its draft Guideline Technical Document on fluoride in drinking water, for a two-month public consultation period which ended on November 27, 2009.

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 protect the health of Canadians.

Q. 1  Will Health Canada correct the information that they provided on the Auditor General petitions website which they themselves admitted is incorrect? If so, will they provide a citation for this information from peer-reviewed research – not from their own website material?

Health Canada is submitting an addendum to Petition 221-C to correct the citation used in the response. The addendum will be posted on the Auditor General petitions website with the response to Petition 221-C. The correction is as follows:

In response to Question 4 of Environmental Petition No. 221-C, Health Canada stated:

“The actual prevalence of moderate dental fluorosis in Canada is very low, and all evidence suggests that there has been an overall decreasing trend of moderate dental fluorosis in Canada since 1996. This is based on a review of Canadian data conducted by Clark et al. 2006.”

The citation for this statement should be corrected to read:

“The actual prevalence of moderate dental fluorosis in Canada is very low, and all evidence suggests that there has been an overall decreasing trend of moderate dental fluorosis in Canada since 1996. This is based on Health Canada (2008) Findings and Recommendations of the Fluoride Expert Panel Meeting - Water, Air and Climate Change Bureau, Safe Environments Programme, Healthy Environments and Consumer Safety Branch, Health Canada, Ottawa.  Further background information on this statement, including the original research taken into consideration, can be found in Clark, 2006. This document is available to the public upon request. To obtain a copy, please contact: water_eau@hc-sc.gc.ca.”

Q. 2  Should it not be standard practice for the Auditor General petitions office to automatically correct erroneous information when it is detected on the Auditor General’s website, so that information does not continue to be disseminated to the public, the media, politicians and researchers?

It is not appropriate for Health Canada to respond on behalf of The Office of the Auditor General. We recommend that you address this question directly to the Office of the Auditor General.

Q. 3  Health Canada only looked at five studies of the available 23 human studies and the 50 animal studies showing an association between fluoride and lowered intelligence. A scientifically rigorous “weight of evidence” assessment presents all of the available evidence both supporting and opposing a hypothesis. Health Canada cites no studies which did not find an association between fluoride exposure and lowered IQs and they omitted most of the available research that supports this association. Since Health Canada does not appear to follow the scientifically acceptable procedures for “weight of evidence” assessment, why does Health Canada believe that their assessment is a valid “weight of evidence”?

The process for developing a Guideline for Canadian Drinking Water Quality requires the examination of numerous studies, through a comprehensive research of the scientific literature. Studies that are not found to meet scientifically-accepted quality criteria are not included in our final assessment. The majority of available studies regarding an association between fluoride and lowered intelligence have not been found to meet the required quality criteria, which means that they cannot be considered as part of our risk assessment.

Q. 4  A translation error was made in the CDW secretariat document whereby the opposite information provided in French and English. No citation is provided for this claim, making it impossible for Canadian citizens to confirm which version is correct. Does Health Canada believe that the omission of research to support claims is acceptable in a scientific review document?

Health Canada is aware of the translation error and has corrected it on the website.
The English document is the correct version, as technical documents are originally written in English. The text is referenced to: Clark, 2006. Health Canada is committed to communicating accurate information and corrects any identified errors.

Q. 5  Is the failure of the CDW secretariat to provide citations or any kind of supporting documentation for various claims, attempts to block transparency and accountability to the Canadian taxpayer who funds these reviews?

All Guideline Technical Documents that are posted by Health Canada, on behalf of the Federal-Provincial-Territorial Committee on Drinking Water, provide appropriate references.

Q. 6  Is the Canadian Drinking Water secretariat willing to make available on their website the unpublished Clark 2006 document frequently cited in their review, which is paid for taxpayers, so that citizens may analyse the document for accuracy, in an open and transparent manner, consistent with the Accountability Act?

Clark, 2006 is a literature review on the risks and benefits of fluoride, conducted by a consultant for Health Canada. It is available to the public upon request, to obtain a copy please contact: water_eau@hc-sc.gc.ca.

Q. 7  Will Health Canada now assemble a) an unbiased committee with no conflicts of interest; b) that is qualified to do a review of fluoridation research literature? If not, why not?

Health Canada will not be forming a new committee as the Department considers these issues to have been addressed.

Q. 8  I am concerned that there are still important errors that are being made by Health Canada representatives. I have on numerous occasions tried to correct incorrect information that is being provided to Canadian citizens and Canadian politicians. Despite my best efforts to provide factual information, I see misinformation being repeated in cities and towns across Canada by the Chief Dental Officer of Health Canada. 

Do Health Canada representatives have a duty to perform due diligence and act to correct all misrepresentations and omissions of material fact? If so, would Health Canada please respond to the four alleged false and misleading statements mentioned in this petition on pages 3 and 4 above?

Statements from within the body of the petition (“four alleged false and misleading statements mentioned in this petition on pages 3 and 4 above”):

• The chief dental officer for Health Canada repeatedly claims that artificial water fluoridation is safe, yet the Carcinogen Identification Committee of the California Environmental Protection Agency's Office of Environmental Health Hazard Assessment (OEHHA)10 considered a priority ranking of 38 chemicals and has now selected fluoride as one of five chemicals for the possible listing for cancer hazard identification.  The research evidence available seems to satisfy the US EPA 2005 Guidelines as “Likely to be Carcinogenic to Humans” or Category 2^{10, 11}

The fluoridation of drinking water supplies is a well-accepted and safe 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.

Health Canada is aware of international decisions and considerations on fluoride. However, as stated in response to an earlier petition, Health Canada’s decisions are based on internal scientific reviews of available relevant information, not on the stated position of individuals or agencies.

• The chief dental officer for Health Canada assured Halton Regional councillors on November 13, 2008 that the inorganic fluorides used in artificial water fluoridation are “not toxic substances” yet all inorganic fluorides are “toxic substances” according to the Canadian Environmental Protection Act

At the November 13, 2008 meeting in Halton, Dr. Cooney stated that hydrofluorosillic acid hydrolyzes readily in water to release fluoride ions and that it is not on the “CEPA-toxic” list. This fact is supported in a previous response provided to question four in Petition 221 as well. This response stated the following:

“Health Canada works with Environment Canada to assess substances under the Canadian Environmental Protection Act, 1999 (CEPA), which includes prioritizing substances for assessment.  Under the Act, a substance is considered “CEPA-toxic” if it enters or may enter the environment in amounts that may pose a risk to human health, to the environment (such as fish or wildlife) and/or to the environment upon which life depends (such as water, soil, and air). Substances determined to be “CEPA-toxic” may be added to the List of Toxic Substances (Schedule 1 of CEPA 1999). The process focuses on whether the substance is entering the environment at levels of concern.

Inorganic fluorides are “toxic” to the environment as defined under CEPA and this assessment focused principally on four inorganic fluorides: hydrogen fluoride (HF), calcium fluoride (CaF2), sodium fluoride (NaF), and sulphur hexafluoride (SF6).  These compounds were considered the most relevant of the inorganic fluorides on the basis of quantities released to the Canadian environment, environmental concentrations, and toxicological effects on biota. Hydrofluorosilicic acid was not assessed for this classification.”

• According to the minutes of the Corporation of the Municipality of Red Lake, the chief dental officer for Health Canada stated that “fluorosis is not caused by water fluoridation” yet the research literature describes a clear, unambiguous association between fluoride intake, and fluorosis diseases that is not refuted. “Clearly the simplest way of reducing the prevalence of fluorosis in child populations is to cease to fluoridate community water supplies.”

The first part of the above statement refers to a quote by the Chief Dental Officer: “fluorosis is not caused by water fluoridation.” This quote was taken out of context and was previously addressed in a response provided in petition 221. The context of the statement is that water fluoridated at an optimal level would not lead to dental fluorosis of a cosmetic concern (moderate or severe according to Dean’s Index). In Canada, it is the use of fluoridated toothpaste or fluoride supplements at the critical age which is of greater concern. The development of fluorosis is time and dose dependent, which means that sufficient fluoride during a specific age period is required to cause fluorosis of cosmetic concern (moderate according to Dean’s Index). This is why Health Canada has the position that fluoride supplements should not be used and that children under age 3 should not use fluoridated toothpaste unless deemed appropriate by a health professional.

The comment you cite should be referenced as “Locker, D. (1999) Benefits and Risks of Water Fluoridation, An Update of the 1996 Federal-Provincial Sub‑committee Report, p. 42.” It should be noted that the comment represents the position of the author, not that of Health Canada, and that it is taken out of context. The paragraph continues to state: “Whether or not this is an acceptable option depends on the balance of benefits and risks with respect to dental caries and fluorosis.”

• Health Canada in petition #221 states “Fluoride used in drinking water fluoridation is therefore, not considered a drug under the Food and Drugs Act fluoride and its salts are considered to be drugs in Canada"

As previously stated in past petitions, fluoridating drinking water is to provide a dietary source of fluoride, a mineral nutrient. Fluoride added to water in the concentrations available in Canada is considered nutritive as opposed to therapeutic. Fluoride used in drinking water fluoridation is not considered a drug by Health Canada as per the Food and Drugs Act and is not regulated by the Department as a drug. 

Q. 9  Is there any onus on Health Canada to be accountable for misrepresentations and omissions of material fact to ensure that they provide information to other government agencies which is accurate?

Health Canada is committed to communicating accurate information and corrects any identified errors.

Q. 10  Is Health Canada aware that the Carcinogen Identification Committee of the California Environmental Protection Agency’s Office of the Environmental Health Hazard Assessment (OEHHA) has now selected fluoride for the possible listing for cancer hazard identification? Is Health Canada aware that fluoride satisfies the US EPA 2005 Guidelines as “Likely to be Carcinogenic to Humans” or Category 2? If not, why not?

Health Canada is aware that the OEHHA has added fluoride to their list to reassess its carcinogenicity, and that this assessment has not been initiated yet. Health Canada is aware that the U.S. EPA has not classified fluoride with respect to carcinogenicity.

Q. 11  On April 1, 2008 during a public presentation in Dryden, Ontario, the Chief Dental Officer of Health Canada stated: “I walked down your high street today and I didn’t see anybody growing horns – and Dryden has been fluoridated for 40 years!” Is it an official policy position for Health Canada that fluorosis disease involves the “growing of horns”? If so, please provide scientific evidence.

The Chief Dental Officer was referencing and refuting one of the unscientific claims against fluoridated water.

Q. 12  The Chief Dental Officer for Health Canada in a presentation to Thunder Bay city council on December 3, 2008 stated: “In, for example, British Columbia you tend to have a lot of what we call tree-huggers or environmental folks. They tend to feel that they are not comfortable with fluoride in the water.” Is it official policy for Health Canada to describe anyone who is concerned about the environment as “tree-huggers”?

No, it is not the official policy of Health Canada to describe anyone who is concerned about the environment as “tree huggers.” As mentioned in previous correspondence and in petition 221D, the above-quoted statement was taken out of context. The Chief Dental Officer was saying that some areas of the country seem to have heightened concerns as compared to other areas of the country. British Columbia currently has about 4% of its population drinking fluoridated water, whereas provinces like Ontario, Manitoba and Alberta have over 70%.

Q. 13  Should Health Canada regulate the fluoride drugs added to drinking water?

Fluoridating drinking water is to provide a dietary source of fluoride, a mineral nutrient. Fluoride added to water in the concentrations available in Canada is considered nutritive as opposed to therapeutic. Fluoride used in drinking water fluoridation is not considered a drug by Health Canada as per the Food and Drugs Act and is not regulated by the Department as a drug. 

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 of 1.5 mg/litre 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. Nutritionally, fluoride has been shown to help produce strong teeth that are more resistant to decay. This is similar to the nutritional role of other nutrients. Nutrients, when consumed at adequate levels, help build and maintain a healthy body that is resistant to disease. As a nutrient in the diet, fluoride is expected to help prevent tooth decay if consumed at adequate levels. 

Fluoride as a nutrient 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.

Q. 14  Would the Public Agency of Canada demand that the Azarpazhooh and Stewart 2006 meta-analysis commissioned by the Public Health Dental department of Toronto, demonstrating that the cessation of artificial water fluoridation does not lead to an increase in cavities, paid for by taxpayers, be released to the public? If not, why not?

The Public Health Agency of Canada has no contract-based power to compel the City of Toronto to provide it or any other party with a copy of the study in question nor does any federal law give it the power to compel the City of Toronto to provide it with a copy of the study.