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Health and environmental concerns regarding the fluoridation of drinking water

Petition: No. 221

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

Petitioner(s): Carole Clinch

Date Received: 19 November 2007

Status: Completed

Summary: The petitioner seeks responses from several departments on the addition to our drinking water of fluoride (hydrofluorosilicic acid), which she alleges contains arsenic, lead, and other toxic substances. She asks departments to provide toxicology studies demonstrating the safety of the chemical compound currently used to fluoridate drinking water. She also asks departments to warn those involved the in fisheriesindustry of the effects of water fluoridation on our ecosystem. The petitioner further asks what departments plan to do to protect children and other groups at risk (for example, diabetics) from fluoride in water and food.

Federal Departments Responsible for Reply: Environment Canada, Fisheries and Oceans Canada, Health Canada, Indian and Northern Affairs Canada, Natural Resources Canada 

Petition

Petition under the Auditor General Act
to Discontinue Water Fluoridation

Petition regarding the additions of fluoridation chemicals which have never been tested for safety or efficacy and are deemed toxic substances according to CEPA, Schedule 1

These additions are not effective in the prevention of cavities and are environmental and human health hazards in violation of the Fisheries Act 36(3)

Contact information:

Carole Clinch
307 Normandy Avenue
Waterloo, Ontario
519-884-8184
caclinch@gmail.com

[Original signed by Carole Clinch]

Submitted on 19 November 2007 to


Office of the Auditor General of Canada
Commissioner of the Environment and Sustainable Development
Attention: Petitions
240 Sparks Street
Ottawa, Ontario K1A 0G6
1-888-761-5953 (toll free) Ext 2923

Table of Contents

1.

Introduction

3

 

    The reasons for water fluoridation are no longer valid

3

 

    Fluoridated water causes health problems

3

 

    Fluoridated water is toxic to pets, fish and wildlife

3

 

    Public Policy is lagging behind the scientific evidence

3

2.

Background Information

3

 

    What are we putting into our water?

3

 

    The solution to pollution is dilution

4

 

    Where does the fluoride in our water go?

4

 

    What does fluoride do to our environment?

5

 

    What does fluoride do to our bodies?

5

3.

Evidence that the Reasons for Fluoridation are No Longer Valid

5

 

    How does fluoride work?

5

 

    Water fluoridation and incidence of dental cavities

6

 

              2007 Professional Statement

7

 

              2007 Pizzo Review

7

 

              Newburgh-Kingston Trial

7

 

              2007 Caledon-Brampton Study

8

4.

Evidence of Fluoride Toxicity

8

 

    Water Fluoridation Contaminants

9

5.

Evidence of Human Health Problems

11

 

    The U.S. National Research Council 2006 Report

11

 

    The National Research Council of Canada 1977 Environmental Fluoride Report

11

 

    Ontario Ministry of Health and Long Term Care 1999 Report

11

 

    U.S. Department of Heath and Human Services 1993 Report

12

 

    Bone Health

12

 

    Dental Health

12

 

    Thyroid Health

13

 

    Kidney Health

14

 

    Brain Health

14

 

    Hypersensitivity

14

 

    Cancer

15

 

    Who is most susceptible to fluoride?

15

6.

Evidence of Environmental Harm

18

 

    Fluoride in Ecosystems

18

 

    Destruction of marine and freshwater fish

18

 

    Harm to animals (pets, livestock and wild animals)

20

 

    Harm to plants and trees

20

7.

Costs of Water Fluoridation

20

8.

Presentation by Kathleen M. Thiessen on Fluoridation in California

21

9.

Ethical and Legal Concerns

24

10.

Specific Questions to Government Officials

26

11.

Recommendations to Government Officials

29

12.

Federal Departments and Agencies that Need to Respond

30

13.

Appendices

30

14.

References

30

1. Introduction

The reasons for water fluoridation are no longer valid

The original reason for fluoridating water – to prevent cavities – is no longer valid.

According to research from around the world, swallowing fluoride at concentrations found in our water has no significant effect on reducing cavities.

Fluoride applied directly to the tooth surface, at concentrations many orders of magnitude higher than in drinking water, may be effective in preventing cavities.

Concentrations of fluoride found in fluoridated water are simply insufficient to provide any significant topical benefit.

Fluoridated water causes health problems

At current concentrations, fluoridated water is causing many health problems in susceptible individuals, especially young children. The most common form of fluoride in drinking water, hydrofluorosilicic acid, is classified by the U.S. Environmental Protection Agency as a Class 1 Hazardous Waste.

Certain members of society develop teeth, bone, skin, thyroid, reproductive, gastro-intestinal, neurological and pancreatic problems, which are associated with fluorides in drinking water.

Fluoridated water is toxic to pets, fish and wildlife

The Canadian Environmental Protection Agency and the U.S. Department of Heath and Human Services both list (inorganic) fluoride as a toxin which is damaging to plant and animal health.

Fluoridated water effluent from municipal and industrial sources enters ponds, rivers, lakes and oceans, harming many species of fish and animals that drink this water. Damage to fisheries on the west coast prompted some authorities to stop fluoridating their water.

Public Policy is lagging behind the scientific evidence

The purpose of this report is to inform policymakers about the current state of knowledge. The products most commonly put into our drinking water (hydrofluorosilicic acid and sodium silicofluoride) have never been tested for safety or efficacy. Additions of these toxic substances into our drinking water should be stopped.

2. Background Information

What are we putting into our water?

The Office of the Chief Dental Officer (Health Canada) has stated that fluoride is a passive element, and is naturally found in water1. Fluoride does occur naturally, and comes form many sources. The most common form of water fluoridation however, uses hydrofluorosilicic acid, an industrial waste which is not naturally occurring, and is extremely reactive2,3

Hydrofluorosilicic acid is a by-product of emissions from the phosphate fertilizer industry4. These emissions are regulated by the U.S. Environmental Protection Agency (US EPA) and other government agencies because they contain many environmental pollutants5.

The fertilizer industry now removes contaminants from their smoke stack emissions to prevent them from being released into the atmosphere6.

However, industries are left with the problem of disposal of the removed contaminants. The next step is to separate the slurry of contaminants into different chemical classes which can be resold or disposed of in a legal manner.

The solution to pollution is dilution

For the phosphate industry, a solution containing 23% hydrofluorosilicic acid is extracted. However, this solution is often contaminated with arsenic, lead, mercury, chromium, cadmium, hydrogen fluoride and barium *(see attached Certificate of Analysis). An analysis of hydrofluorsilicic acid in Alberta found the following heavy metal concentrations:

Since the advent of water fluoridation, municipalities have been an important customer for these industries, buying fluoride-containing solutions to add to drinking water.

Dwindling supplies of fluorosilicates used in water fluoridation means that the replacement product could be shipped to us from China (see quote page 31).

"In regard to the use of fluosilicic acid as a source of fluoride for fluoridation, this Agency [US EPA] regards such use as an ideal environmental solution to a long-standing problem. By recovering by-product fluosilicic acid from fertilizer manufacturing, water and air pollution are minimized, and water utilities have a low-cost source of fluoride available to them." Rebecca Hanmer, Deputy Assistant Administrator for Water, US EPA, 30 March 1983.

Essentially, we are removing pollution from the air (where it contaminates areas surrounding smoke stacks) and putting it into our water (where it is more effectively diluted). The fact remains that we are still adding toxic chemicals to our water. Is this beneficial, legal or ethical?

"If this stuff gets out into the air, it's a pollutant; if it gets into the river, it's a pollutant; if it gets into the lake, it's a pollutant; but if it goes right straight into your drinking water system, it's not a pollutant. That's amazing!" Dr. Hirzy 2000 Senior Vice-President of EPA Headquarters Union. http://www.fluoridealert.org/phosphate/overview.htm

Where does the fluoride in our water go?

Fluoridated water is used in households, agri-culture, industry, and is released into our environment from all of these sources. Effluent from sewage treatment plants is especially important, because sewage is discharged directly into rivers, lakes and oceans.

Sewage biosolids are sometimes spread on agricultural fields. Accumulation of heavy metals found in fluoridated water becomes sediment in rivers/streams/lakes.

What does fluoride do to our environment?

Fluoride, at the concentrations found in drinking water, kills many species of fresh and saltwater fish, shellfish and insects. Wild animals, livestock and pets develop health problems similar to humans from ingesting fluoridated water7-11,117-119.

Fluoridating chemicals are very persistent – they do not break down when released into the environment. They accumulate in bodies of water and in plants and animals.

What does fluoride do to our bodies?

Swallowing hydrofluorosilicic acid and other chemicals used in water fluoridation can damage:

  • Teeth
  • Bones
  • Thyroid
  • Reproductive organs
  • Gastrointestinal system
  • Brain

These ubiquitous chemicals have also been linked to cancer, ADHD, Alzheimer's disease and Down syndrome (see NRC 2006 Report).

3. Evidence that the Reasons for Fluoridation are No Longer Valid

How does fluoride work?

Since the beginning of its use, it has been assumed that fluoride needed to be swallowed in order to work: fluoride would enter the body and then be incorporated into tooth enamel, which would make teeth stronger.

This assumption was made, because; a) fluoride had been detected in tooth enamel; b) and at the same time, there was a measured decrease in dental cavities through much of the twentieth century (see page 8). As a result, a positive association was made between dental health and the presence of fluoride in tooth enamel.

What was not understood, was that fluoride incorporation was simply a result of exposure to fluoride in the environment, through environmental contamination7-11.

Based on recent scientific research, fluoride is believed to improve dental health through topical mechanisms only (i.e. not through ingestion). In other words, fluoride is believed to work not by being incorporated into tooth enamel, but by working on the tooth's surface12-20.

"Fluoride's caries-preventive properties initially were attributed to changes in enamel during tooth development because of the association between fluoride and cosmetic changes in enamel and a belief that fluoride incorporated into enamel during tooth development would result in a more acid-resistant mineral. However, laboratory and epidemiologic research suggests that fluoride prevents dental caries predominately after eruption of the tooth into the mouth, and its actions primarily are topical for both adults and children." Centers for Disease Control; MMWR Weekly Report. 1999;48:933-940.

The currently hypothesized modes of action for topical fluoride are as follows:12

  • Destroys bacteria (by destroying enzymes) that contribute to tooth decay
  • Helps to rebuild enamel
  • Helps to prevent destruction of enamel

Although fluoride in water contacts the surface of teeth (i.e. is applied topically), the concentrations of fluoride in water are insufficient. Beneficial effects of topical fluoride occur at concentrations many orders of magnitude higher (1000 – 1500 mg/L) than concentrations found in drinking water (0.8 – 1.0 mg/L)12,16. Additionally, 80 – 90% of cavities occur in the pits and fissures of teeth, where fluoride in water is ineffective 21-25.

It is now known that increasing fluoride levels in tooth enamel does not prevent cavities. Swallowing fluoride, at recommended doses, is not effective for the prevention of tooth decay.

Water fluoridation and incidence of dental cavities

For many decades, we've seen a decline in the incidence of dental cavities in more affluent members of society (see below). However, there has been no significant change in the incidence of cavities in lower socioeconomic groups over the same time period, despite equal access to fluoridated water.

"Large reductions in caries [have] been occurring in unfluoridated areas. The magnitudes of these reductions are generally comparable with those observed in fluoridated areas over similar periods of time." Nature; 1986; vol 322; p. 125-129.

Another argument used to support the use of water fluoridation is the incidence of `baby bottle tooth decay' (BBTD), which is most prevalent among certain socioeconomic groups. It was believed that water fluoridation would reduce the incidence of BBTD, but recent research shows that rates of BBTD are highest among the urban poor, irrespective of access to fluoridated water26-29.

"The current reported decline in caries in the US and other Western industrialized countries has been observed in both fluoridated and nonfluoridated communities, with percentage reductions in each community apparently about the same." Gilbert JA. 1988 Ethics and Esthetics. Journal of the American Dental Association 117(3): 490-495.

2007 Professional Statement

In 2007, Fluoridealert.org released a Professional Statement from over 1,100 organizations and/or professionals around the world, requesting the discontinuation of water fluoridation. Those signing the Professional Statement include http://www.FluorideAction.net:

  • 2 members of the advisory panel for the York Review 2000 ([name withheld] and [name withheld])
  • 3 members of the 2006 National Research Council panel (Dr. Bob Isaacson, Dr. Hardy Limeback, Dr. Kathleen Thiessen)
  • Nobel Laureate Arvid Carlsson
  • International Academy of Oral Medicine and Toxicology
  • International Society of Doctors for the Environment (ISDE)
  • American Academy of Environmental Medicine
  • Associacion Argentina de Medicos por el Medio Ambeinte, Argentina
  • Irish Doctors' Environmental Association

2007 Pizzo Review

The most recent review of worldwide water fluoridation suggests that water fluoridation is largely ineffective.

1. The benefits of fluoride are largely topical not systemic.

    "It is now accepted that systemic fluoride plays a limited role in caries prevention."

2. Water fluoridation may be unnecessary.

    "Several studies conducted in fluoridated and nonfluoridated communities suggested that this method of delivering fluoride may be unnecessary for caries prevention, particularly in the industrialized countries where the caries level has became low."

3. Interruption of water fluoridation does not increase dental decay.

    "In the past decades, a number of authors focused their attention on caries trend of the communities that interrupted water fluoridation in comparison to communities without water fluoridation (Kuopio and Jyvaskyla, Finland; Chemnitz and Plauen, Germany; Tiel and Culemborg, Holland; La Salud, Cuba). In these communities, during the years of water fluoridation, a caries reduction had been observed, but after the cessation, caries prevalence did not rise, remained almost the same or even decreased further. These findings do indicate that the interruption of CWF [community water fluoridation] had no negative effects on caries prevalence."

4. Water fluoridation does not reduce social inequalities.

    "To date, there is limited evidence to support the view that fluoridation reduced the [social] disparities in caries."

Giuseppe Pizzo, Maria Piscopo, Ignazio Pizzo and Giovanna Giulliana. 2007 Community water fluoridation and caries prevention: a critical review. Clinical and Oral Investigations. Sep;11(3):189-193.

Newburgh-Kingston Trial

One of the four original water fluoridation trials in the world was conducted in New York. The city of Newburgh was fluoridated, while the city of Kingston was not fluoridated. A study was conducted 50 years later, with the following results:

  • More cavities in the fluoridated community vs the non-fluoridated community:

      "Among 7-14 year old lifelong residents of fluoridated Newburgh, New York, mean number of decayed, missing and filled permanent teeth exceeded that of non fluoridated Kingston, New York."

  • Higher incidence of dental fluorosis in fluoridated community;
  • Increased bone fracture in fluoridated community

Kumar JV, Swango PA. 1999 Fluoride exposure and dental fluorosis in Newburgh and Kingston, New York: policy implications. Community of Dentistry and Oral Epidemiology Jun;27(3):171-80.

2007 Caledon-Brampton Study

A comparison was made between 7-year-old children of Caledon, with unfluoridated water, and the children of Brampton, with fluoridated water. Over 1,000 children in 25 schools were surveyed for the incidence of dental cavities.

The study concluded that "The effect of fluoridation on caries in these communities was not evident"

Factors that did affect the incidence of dental cavities were:

  • dental hygiene
  • nutrition
  • use of dental sealants
  • breast feeding vs infant formulas
  • country of birth

Caledon [Not Fluoridated] - Brampton [Fluoridated] Study: D. ITO, 2007 Determinants of caries in adjacent fluoridated and non-fluoridated cities. The IADR/AADR/CADR 85th General Session and Exhibition (March 21-24, 2007).

4. Evidence of Fluoride Toxicity

Hydrofluorosilicic acid (used in water fluoridation) is an inorganic fluoride. According to the Gosselin 1983 Clinical Toxicology Textbook, inorganic fluorides are more toxic than lead, and less toxic than arsenic, as illustrated by the following bar chart. This is based on LD50 data [concentration needed to achieve lethal dose with 50% of test subjects] LD50 data from Robert E.Gosselin et al, Clinical Toxicology of Commercial Products 5th ed., 1984.

The toxicology of fluoride products indicate they are very toxic. Associated contaminants lead, arsenic, mercury etc, are also very to extremely toxic.

Note that the Maximum Allowable Contam-inant level (MAC) of fluoride has been set by Health Canada regulations to be 2 orders of magnitude higher than other comparable toxic contaminants such as arsenic and lead. Such regulation affords a tolerance for this contaminant, which appears unjustified. The government policies regarding this product suggests a lack of awareness as to this product's true toxicity.

  • MAC of lead

15

ppb

  • MAC of fluoride

1,500

ppb

  • MAC of arsenic

10

ppb

The Canadian Environmental Protection Agency (CEPA) defines a "Toxic Substance":

1. persistence [ability to be destroyed]
2. bioaccumulation [accumulation in biological systems]
3. toxicity [dangerous immediate or long-term
4. predominantly anthropogenic [use or released as a result of human activity]

"Furthermore, substances determined to be "toxic", persistent, bioaccumulative, anthro-pogenic, and which are not naturally occurring radionuclides or naturally occurring inorganic substances shall be proposed for implementation of virtual elimination under Section 65 (3) of CEPA 1999." http://www.ec.gc.ca/CEPARegistry/subs_list/ToxicList.cfm

The Canadian Environmental Protection Agency (CEPA) defines "Toxic" as:

"A substance is toxic if it is entering or may enter the environment in a quantity or concentration or under conditions that:

  1. have or may have an immediate or long-term harmful effect on the environment or its biological diversity;
  2. constitute or may constitute a danger to the environment on which life depends; or
  3. constitute or may constitute a danger in Canada to human life or health." (Section 64).

"Fluoride is a persistent bioaccumulator, and is entering into human food-and-beverage chains in increasing amounts." NRC 1977 Environmental Fluoride.

"Fluorine cannot be destroyed in the environment; it can only change its form" ATSDR Public Health Statement: Fluoride p2.

Boiling water gets rid of chlorine and concentrates fluoride. Grimaldo M, Borja-Aburto VH, Ramirez AL, Ponce M, Rosas M, Diaz-Barriga F. 1995 Endemic fluorosis in San Luis Potosi, Mexico. I. Identification of risk factors associated with human exposure to fluoride. Environmental Research 68(1):25-30.

Boiling of the drinking water (1 ppm F) in an aluminum pot increased the water Al content from 0.03 ppm to 0.20 ppm, and a concomitant increase of complexed F from non-detectable to 50% Brudevold F, Moreno E, Bakhos Y (1972). Fluoride complexes in drinking water. Archives of Oral Biology 17:1155-1163.

"While chlorine is evaporated in the process of boiling water, this does not happen with fluoride, and the concentration can become dangerously high in long periods of cooking."

McLellan H. Fluoridation. Consumer Health Group http://www.consumerhealth.org/articles/display.cfm?ID=19990817225011 http://www.consumerhealth.org/aboutus/index.html

Water Fluoridation Contaminants

It has been suggested that the addition of contaminants like arsenic is insignificant, and it is not easily measured once diluted in drinking water. But, arsenic levels and dilution factors are known - BEFORE it is diluted into drinking water.

Arsenic is classified as a Level 1 Carcinogen, meaning that it is known to cause cancer in humans. There are no known "safe" concentrations of Level 1 Carcinogens.

Studies have linked arsenic ingestion to a number of health effects. These health effects include cancer of the skin, bladder, lung, kidney, nasal passages, liver and prostate, and problems associated with cardiovascular, pulmonary, immunological, neurological and endocrine systems. EPA http://www.epa.gov/safewater/arsenic/index.html

"The concentration of arsenic in drinking water representing an "essentially negligible" risk is 0.3 ìg/L or 0.3ppb. Levels of arsenic in drinking water should be as close as possible to this level." Health Canada May 2006 Guidelines for Canadian Drinking Water Quality: Guideline Technical Document. Prepared by the Federal-Provincial-Territorial Committee on Drinking Water of the Federal-Provincial-Territorial Committee on Health and the Environment.

U.S. EPA's Maximum Contaminant Level Goal of arsenic (MCLG) = 0
California's Public Health Goal for arsenic = 4ppt ( parts per trillion)

Health Canada has no equivalent MCLG.

MCLGs are to be "set at a level which assures that the health of persons will be protected against known or anticipated adverse effects [of the substance], allowing an adequate margin of safety." Loflin JJ, Chorover NJ, Grimmer J. Amicus brief for NFFE Local 2050, NRDC and S. Carolina vs USEPA, U.S. Dist. Court of Appeals, Civ. No. 85-1839 & 1854; 1986 Sep 3.

The U.S. National Sanitation Foundation (NSF) collected 100,000 water samples between 1980 to 1998 from more than 24,000 public water systems in 25 states (all sampled states diluted fluoride additives in their water to 1 ppm). Health Canada recommended guidelines for fluoride are 0.8-1.0ppm. http://www.hc-sc.gc.ca./waterquality.

The data was compiled by the U.S. Environmental Protection Agency (EPA). The Natural Resources Defense Council (NRDC) obtained the data under the Freedom of Information Act and conducted an analysis.

American National Standards Institute/National Sanitation Foundation (ANSI/NSF) have created a Standard 60 for chemical additives which is used by most provinces and territories in Canada. NSF Standard 60 defines the amount of contaminant permissible in drinking water via their Single Product Allowable Contaminants (SPAC) whereby any one product can only contribute up to 10 percent of the Maximum Allowable Contaminant level (MAC). This is a safety factor added because other direct additives might also contribute that same contaminant in drinking water.

The following analysis demonstrates that some samples exceed the NSF SPAC:

  • Average Contaminant Concentration in Samples with Positive Results

0.49 ppb

  • Maximum Contaminant Concentration in Samples with Contaminants

1.66 ppb

  • ANSI/Standard 60 SPAC = 10% of MAC [10ppm]

1.0 ppb

  • US EPA and Health Canada MCL/MAC

10 ppb

From Table 1 in a Letter by Stan Hazan, General Manager of the Drinking Water Additives Certification Program, NSF, to the Honorable Ken Calvert, Chairman of the Subcommittee on Energy and the Environment, Committee on Science, U. S. House of Representatives, July 7, 2000.

The Maximum Allowable Contaminant level (MAC) is the point above which governments are required to remediate water contaminants. These standards do not represent a "safe" level for a lifetime of ingestion. The Maximum Contaminant Level Goals represent "safe" levels.

The NSF has inexplicably ignored their own SPAC [10% of MAC] requirement for fluoride. SPAC for fluoride is 1.2mg/L – not 0.15mg/L which is 10% of Health Canada's MAC of 1.5mg/L or 0.4mg/L which is 10% of US MCL of 4ppm].

An NRC report on Arsenic prompted the lowering of the U.S./Canadian Maximum Contaminant Levels for arsenic to 10 ppb. It calculates that 1 person in 3000 will risk lung/bladder cancer because of the addition of hydrofluorosilicic acid. Reporting these risks as non-detected or representing them as non-significant is a misrepresentation of material fact. http://www.nap.edu/openbook.php?isbn=0309076293

5. Evidence of Human Health Problems

The U.S. National Research Council 2006 Report

The most important document to date is the U.S. National Research Council's 2006 Report on Fluoride in Drinking Water. The National Research Council provides science, technology and health policy advice. The report details nearly 1,000 studies which describe individuals and groups potentially harmed from fluorides in drinking water at doses currently recommended in Canada.

The report found that people most "at risk" for adverse effects from water fluoridation chemicals are young children, diabetes patients, kidney disease patients, the elderly, hypersensitive individuals, pregnant or lactating mothers, and individuals deficient in nutrients like calcium, magnesium, iodine and selenium.

The National Research Council of Canada 1977 Environmental Fluoride Report

"Large quantities of fluoride are also discharged into streams, rivers, lakes and oceans, as a component of industrial waste-waters. It appears probable that the amounts thus discharged are several-fold larger than the amounts discharged into the atmosphere. Many systems utilized for airborne emission-control contribute extensively to the amount of fluoride discharged in wastewaters."

"Fluoride is a persistent bioaccumulator, and is entering into human food-and-beverage chains in increasing amounts."

"Long-term ingestion, with accumulation of fluoride in animals and man, induces metabolic and biochemical changes, the significance of which has not yet been fully assessed."

"Fluoride has displayed mutagenic activity in studies of vegetation, insects, and mammalian oocytes."

"In Section 5.1.1, we stated that the current total fluoride intake from foods and beverages, in areas with fluoridated (1 ppm) water, probably ranges from 3.5 to 5.5 mg/day."

"There is no doubt that inadequate nutrition increases the severity of fluoride toxicosis."

Ontario Ministry of Health and Long Term Care 1999 Report

"Current studies support the view that dental fluorosis has increased in both fluoridated and non-fluoridated communities. North American studies suggest rates of 20 to 75% in the former and 12 to 45% in the latter."

"In Canada, actual intakes are larger than recommended intakes for formula-fed infants and those living in fluoridated communities. Efforts are required to reduce intakes among the most vulnerable age group, children aged 7 months to 4 years." Report available online at http://www.health.gove.on.ca/english/public/pug/ministry_reports/fluoridation/fluoridation.html

U.S. Department of Health and Human Services 1993 Report

"Existing data indicate that subsets of the population may be unusually susceptible to the toxic effects of fluoride and its compounds. These populations include the elderly, people with deficiencies of calcium, magnesium, and/or vitamin C, and people with cardiovascular and kidney problems."

"Because fluoride is excreted through the kidney, people with renal insufficiency would have impaired renal clearance of fluoride (Juncos and Donadio 1972)."

"People on kidney dialysis are particularly susceptible to the use of fluoridated water in the dialysis machine (Anderson et al. 1980). "

"Impaired renal clearance of fluoride has also been found in people with diabetes mellitus and cardiac insufficiency (Hanhijarvi 1974). People over the age of 50 often have decreased renal fluoride clearance (Hanhijarvi 1974). This may be because of the decreased rate of accumulation of fluoride in bones or decreased renal function. This decreased clearance of fluoride may indicate that elderly people are more susceptible to fluoride toxicity."

"Recent studies indicate that fluoride may increase the rate of hip fractures in elderly men and women."

"A large study of fluoride conducted by the National Toxicology Program with both rats and mice found that a small number of male rats developed bone cancer (osteosarcoma) after drinking water with high levels of fluoride in it throughout their lives…The bone cancer seen in the rat study is rare in humans, although its frequency has recently increased among males in countries with fluoridated water…The osteosarcoma rate in males living in fluoridated areas has increased markedly in recent years…" Report available on the Agency for Toxic Substances and Disease Registry website http://www.atsdr.cdc.gov/.

Bone Health

It has been argued that skeletal fluorosis does not exist in North America. Evidence, however, is to the contrary.

Dr. William Ashe, a scientist from the Kettering Institute reported large incidences of skeletal fluorosis in workers in an aluminum plant in Massena, New York.

"The most outstanding characteristic of this group is the occurrence of 91 cases of fluorosis of the bone. X-rays showed up to 100% of bones involved – serious tooth decay, gum disease, heart problems, lung fibrosis were evident. "one sees hypertrophic changes in bone…similar to changes seen in experimental animals with bone fluorosis. The inter-osseous membranes are often ossified…" Bryson, C. The Fluoride Deception. Seven Stories Press; New Ed (March 1, 2006) p 258-259.

Dental Health

Over-exposure to fluoride causes dental fluorosis. According to the Ontario Ministry of Health and Long Term Care 1999 Report (see pages 14-15), incidence of dental fluorisis is nearly twice as prevalent in communities with fluoridated water, compared to communities that do not fluoridate their water.

"In moderate to severe forms of fluorosis, poro-sity increases and lesions extend toward the inner enamel. After the tooth erupts, its porous areas may flake off, leaving enamel defects where debris and bacteria can be trapped. The opaque areas can become stained yellow to brown, with more severe structural damage possible, primarily in the form of pitting of the tooth surface." NRC 2006, p 79.

Dental fluorosis is expensive to treat: porcelain veneers cost $600 – $800 per tooth, and have a life expectancy of 10-15 years.

Fluoridation of water "has contributed to the birth of a multi-billion dollar industry of tooth bleaching and cosmetic dentistry. More money is being spent now on the treatment of dental fluorosis than what would be spent on dental decay if water fluoridation were halted." Dr. Hardy Limeback, the Head of Preventive Dentistry at the University of Toronto Oct 22, 1999 in International Fluoride Information Network Bulletin # 3. Available from ggvideo@northnet.org

According to the Ontario Ministry of Health and Long Term Care 1999 Report, 25-70% of Canadians in fluoridated communities have dental fluorosis. Assuming that 40% of Canadians have dental fluorosis, that means that 13.2 million Canadians have dental fluorosis.

Some individuals have suggested that the dental fluorosis is a "questionable" health concern. For those who have dental fluorosis, there is nothing "questionable" about the social embarrassment caused by teeth with white or brown specks or the associated costs to repair.

Using concentrations of fluoride as low as 0.1ppm, "regardless of its amount, fluoride intake has harmful effects on both tooth and bone formation." Kakei M, Sakaeb T, Yoshikawac M, Tamurad N. 2007 Effect of fluoride ions on apatite crystal formation in rat hard tissues. Annals of Anatomy 189: 175—181.

Thyroid Health

The US National Research Council 2006 Report discusses how endocrine systems and thyroid functions are impaired at exposure levels to fluoride below the consumption levels expected from drinking "optimally fluoridated water"; "several lines of information indicate an effect of fluoride exposure on thyroid function."

According to the NRC 2006 Report on Fluorides in Drinking Water, ingesting as little as 0.7mg/day of fluoride by a 75kg individual, when iodine insufficient, may cause thyroid suppression [P 263, Table 8-2].

According to many sources, [see ATSDR 1993, NRC Canada 1977] we consume about 3mg/day, of fluoride, on average. According to the Centers for Disease Control, the average urinary iodine level today is half what it was in 1971. The agency estimates that 36% of U.S. women now have sub-optimal iodine intake. http://www.cdc.gov/nchs/products/pubs/pubd/hestats/iodine.htm

"In summary, evidence of several types indicates that fluoride affects normal endocrine function or response; the effects of the fluoride-induced changes vary in degree and kind in different individuals. Fluoride is therefore an endocrine disruptor." NRC 2006 Report on Fluorides in Drinking Water.

Kidney Health

Concern regarding the ability of damaged or undeveloped kidneys to filter toxic substances such as hydrofluorosilicic acid has been raised121-125. Also of concern is the burden of chronic, low doses of toxic substances, over a life-time, on the function of organs such as the kidney.

The US National Kidney Foundation's alleged failure to warn kidney patients that they are particularly susceptible to harm from ingested fluoride from drinking water and other sources is discussed in a precedent-setting letter to the Foundation from a legal firm http://fluoridealert.org/press/nkf.htm.

"According to the National Institute of Dental Research, also part of NIH, fluoride levels in water are set according to normal consumption of water. If an individual is consuming abnormally large quantities of water, drink bottled water." National Institute of Diabetes and Digestive and Kidney Diseases, Dept. of Health & Human Services.Harm to Thyroid, 1991.

Brain Health

A recent Lancet review referred to fluoride as an "emerging neurotoxic substance" due to evidence linking fluoride to lower IQs in children, and brain damage in animals121.

"Fluorides also increase the production of free radicals in the brain through several different biological pathways. These changes have a bearing on the possibility that fluorides act to increase the risk of developing Alzheimer's disease." NRC 2006

"Animals administered the lowest dose of AlF- [Aluminum bound to fluoride] 0.5 ppm exhibited a greater susceptibility to illness and higher mortality than animals administered higher levels [5 ppm, 50 ppm]." Varner JA, et al. (1998). Chronic administration of aluminum-fluoride and sodium-fluoride to rats in drinking water: alterations in neuronal and cerebrovascular integrity. Brain Research 784: 284-298.

"The possible association of cytogenetic effects with fluoride exposure suggests that Down's syndrome is a biologically plausible outcome of exposure." NRC 2006 p170

A 1995 study conducted by a leading neurotoxicologist, Phyllis Mullenix, Ph.D., and published in the journal Neurotoxicology and Teratology showed that baby rats — depending on when they were exposed to fluoride dosages similar to what human children receive — exhibited hyper- and hypo-activity: when the animals were exposed to fluoride before birth they exhibited behavior characterized as hyperactive; when they were dosed after birth they became hypoactive ("couch potatoes"). Mullenix PJ, Denbesten PK, Schunior A, Kernan WJ.  1995 Central Nervous System Damage from Fluorides. Neurotoxicology and Teratology. 17(2): 169-177.

Hypersensitivity

Many drugs and foods are known to cause hyper-sensitive reactions in some individuals, e.g. Penicillin and Peanuts.

According to research, 1-4% of human population is hyper-sensitive to fluoride30,31. Some animals are also known to be hypersensitive to fluoride117-119.

Toronto resident, [name withheld], born 1952 in Grand Rapids, Michigan, is hypersensitive to fluoride. [Name withheld] was born in the first city in the U.S. to add fluoride to the water (1945), and has lived in cities with fluoridated water [name withheld] entire life. [Name withheld] youngest child is also hypersensitive to fluoride and has moderate dental fluorosis.

[Name withheld] symptoms after ingesting fluoride include extreme thirst, urgent, frequent and dilute urine similar to diabetes insipidus, heart palpitations, fatigue, abdominal pain, bloating, diarrhea, lowered body temperature, head-aches, muscle weakness, and joint pain.

"In hypersensitive individuals, fluorides occasionally cause skin eruptions such as atopic dermatitis, eczema or urticaria. Gastric distress, headache and weakness have also been reported. These hypersensitivity reactions usually disappear promptly after discontinuation of the fluoride." Physician's Desk Reference, 1994, 48th Edition, p. 2335-2336.

Cancer

Evidence to date suggests an age-specific, sex-specific (young males, under the age of 20) risk associated with fluoride. A recent peer-reviewed case-controlled study from Harvard University found a  5-7 fold increase in osteosarcoma (a frequently fatal bone cancer) in young men if they live in a fluoridated community32. *(see Bassin 2006 study attached)

Using data from the Surveillance, Epidemiology and End Results (SEER)33, Hoover et al. found an unexplained increase in osteosarcoma in males less than 20 years of age in fluoridated versus non-fluoridated areas. The National Toxicology Program animal study, found a positive association for male rats, but no association for female rats or mice34. A smaller study examining osteosarcoma in New Jersey also showed an increase in incidence rates for males less than 20 years old who lived in fluoridated areas compared to those living in non-fluoridated areas35.

It is biologically plausible that fluoride affects the incidence rate of bone cancer, and that this effect would be strongest during periods of growth, particularly in males because;

  1. First, approximately 99% of fluoride in the human body is contained in the skeleton with about 50% of the daily ingested fluoride being deposited directly into calcified tissue (bone or dentition)36.
  2. Second, fluoride acts as a mitogen, increasing the proliferation of osteoblasts37,38 and its uptake in bone increases during periods of rapid skeletal growth36.
  3. Third, the amount of fluoride present in bone depends on gender and intake39 and intake, on average, is greater for males than females for all ages over 1 year40.

"I was the counsel for the plaintiffs in rigorous trials in Pennsylvania, Illinois, and Texas, resulting in judicial findings in all three cases - based on the quality of the evidence heard on both sides - that artificial fluoridation of public water supplies induces large-scale cancer and other ailments in man. Eminent experts from great universities, government institutions, and the private sector appeared in all three cases, and were all subjected to direct and cross examination by veteran trial lawyers before experienced trial judges. The professional union at the national headquarters of the United States Environmental Protection Agency later reviewed these judicial findings, and certified them as scientifically correct to a subcommittee of the United States Senate. Since those hearings, the evidence reported in leading scientific and medical journals has extensively confirmed and elaborated what the three judges found. Under these circumstances, it is morally irresponsible to continue this practice, and governments have an urgent duty to end it." John Remington Graham, BA, LLB, co-author of "La fluoration autopsie d'une erreur scientifique," 2005, St-Agapit, Quebec.

Who is most susceptible to fluoride?

The current population of Canada is estimated at 33 million. Approximately 43% of Canadians ingest hydrofluorosilicic acid through artificially-fluoridated water41 and many others ingest natural-occurring fluoride in water in excess of 0.5mg/L.

Following is a list of groups of people most susceptible to fluoridated water:

  • Young children and fetuses
  • Individuals who drink >2 litres of water per day (athletes, soldiers, laborers, lactating mothers, diabetes patients)
  • Individuals who are unable to filter water in their body (individuals with kidney damage, young children)
  • Individuals with cardiovascular disease

The elderly

1-4% of Canadians may be hypersensitive to fluoride [330,000 – 1, 320,000 Canadians]

5% of Canadians have diabetes [1,650,000 Canadians]

5% of Canadians have kidney disease [1,650,000 Canadians]

27- 44% of Canadians have diets low in calcium, magnesium, iodine (which helps to counteract fluoride toxicity) [8,910,000 – 14,520,000 Canadians]

5%- 40% of Canadians have thyroid dysfunction [1,650,000 – 13,200,000 Canadians]

Reproduced from Table 1 in a letter from J Charles Fox, Assistant Administrator, Environmental Protection Agency, to Congressman Kenneth Calvert, Chairman Subcommittee on Energy and the Environment, Committee on Science, House of Representatives, USA, September 5, 2000.

"…increasing numbers of people with carpal-tunnel syndrome, arthritic-like pains, osteoporosis may be due to the mass fluoridation of drinking water." EPA 2003 Annual Report.

"Whereas dental fluorosis is easily recognized…the skeletal involvement is not clinically obvious until the advanced stage of crippling fluorosis ... early cases may be misdiagnosed as rheumatoid-or osteo-arthritis." WHO website 1970.

Infants and Children

The American Dental Association, the US Centers for Disease Control and the Ontario Ministry of Health and Long Term Care 1999 Report express concern regarding the increased risk of dental fluorosis with children with increasing exposures to fluoride from all sources, of which fluoridated water is the primary source42. The US NRC 2006 Report on Fluoride in Drinking Water Report, and other studies43-98 raise concern about the risk of increasing exposures to the baby's developing brain and other delicate tissues like the kidney which cannot adequately filter fluoride [infants can only filter 15% fluoride42. Healthy adults are able to filter/excrete about 50% of ingested fluoride.

The American Dental Association had a policy change, in November 2006, advising parents of children under 1 year to use only the following types of water when preparing infant formula; "purified, distilled, deionized, demineralized, or produced through reverse osmosis."

A letter from the Ontario Ministry of Health & Long Term Care 2000 also advises Medical Officers of Health to inform the public of the dangers of over-exposures of fluoride from all sources: "Where baby formula is used, non-fluoridated water should be used for mixing."43

"The safety of the use of fluorides ultimately rests on the assumption that the developing enamel organ is most sensitive to the toxic effects of fluoride. The results from this study suggest that the pinealocytes [cells in pineal gland] may be as susceptible to fluoride as the developing enamel organ." Luke J. (1997). The Effect of Fluoride on the Physiology of the Pineal Gland. Ph.D. Thesis. University of Surrey, Guildford. p. 176.

The US Public Health Service recommends fluoridating water from 0.7 – 1.2ppm.

Health Canada recommends fluoridating water from 0.8 – 1.0ppm.

Infants are overexposed to fluoride in most major cities. The U.S. Environmental Working Group compiled data on infant exposure across large cities in the U.S. (see http://www.ewg.org/node/21000.

Given the similar levels of fluoridation between Canada and the U.S., the data on infant overexposure in the U.S. cities is representative of overexposure in Canada:

City

Average Fluoride Levels 1998-2002

% of Babies Over Safe Exposure Level

% of Formula-Fed Babies Over Safe Exposure Level

Boston, MA

1.30ppm

36.2

61.2

Detroit, MI

1.13ppm

33.4

54.2

Minneapolis, MN

1.03ppm

28.7

47.3

Seattle, WA

1.00ppm

27.1

44.6

San Francisco, CA

1.00ppm

27.1

44.6

Philadelphia, PA

1.00ppm

27.1

44.6

New York City, NY

1.00ppm

27.1

44.6

Memphis, TN

1.00ppm

27.1

44.6

Atlanta, GA

1.00ppm

27.1

44.6

Louisville, KY

0.96ppm

26.2

44.2

Columbus, OH

0.95ppm

26

43.1

Indianapolis IN

0.92ppm

23.8

40.4

Baltimore, MD

0.91ppm

23.8

39.8

Chicago, IL

0.88ppm

23

40.2

Tampa, FL

0.85ppm

20.9

36.2

Austin, TX

0.81ppm

18.2

32.7

Washington, DC

0.80ppm

17.8

32.1

San Antonio, TX

0.80ppm

17.8

32.1

Phoenix, AZ

0.75ppm

14.5

26.7

Dallas, TX

0.68ppm

10.6

19.6

Miami, FL

0.66ppm

10.1

19.2

Los Angeles, CA

0.61ppm

8.5

15.5

Jacksonville, FL

0.61ppm

8.5

15.5

Houston, TX

0.31ppm

0.6

1.2

San Diego, CA

0.30ppm

0.6

1.0

San Jose, CA

0.13ppm

0.03

0.1

A growing body of research suggests that the practice of fluoridation may double the exposure of lead in our children. A statistically significant association between the use of silicofluorides as water fluoridation agents (in both Massachusetts and New York State) and an increased uptake of lead into children's blood44-45 was previously demonstrated.

Two new studies demonstrates that fluoride in various combinations with chlorinating chemicals (e.g. chlorine or chloramine) increases the release of lead from leaded brass fittings used in water pipes. Over the first test week with chlorine flushing, lead concentrations nearly doubled (from 100 to nearly 200ppb). When fluorosilicic acid was added, lead concentrations spiked to over 900ppb. Lead concentrations from the chlorine-based waters appeared to be decreasing over the study period, while the lead concentrations seemed to be increasing with the chloramine + fluorosilicic acid combination46.

"It is proposed here that SiFW [silicofluorides in water] induces protein mis-folding via a mechanism that would affect polypeptides in general, and explain dental fluorosis, a tooth enamel defect that is not merely "cosmetic" but a "canary in the mine" foretelling other adverse, albeit subtle, health and behavioral effects." 47.

6. Evidence of Environmental Harm

Fluoride in Ecosystems

"What happens to inorganic fluorides released into the environment? Once in water, inorganic fluorides can be taken up by aquatic plants. Fish and other aquatic animals can also take up inorganic fluoride from water and food and accumulate it in their bones or exoskeletons…Although inorganic fluorides may move around in the environment, and even change form depending on, for example, water chemistry, fluorine itself can not be degraded." Environment Canada http://www.ec.gc.ca/ceqg-rcqe/English/Html/GAAG_Fluoride.cfm

Destruction of marine and freshwater fish

"Inorganic fluorides affect basic physiological and biochemical processes of fish, plants and other aquatic organisms. By doing so, inorganic fluorides can slow growth and development, cause abnormal behaviour and lead to death. The degree to which these effects occur depends in part on the concentration and form of inorganic fluoride, period of exposure, water chemistry, and species and age of aquatic species. Some species that seem particularly sensitive include rainbow trout, fingernail clams, water fleas, and certain green algae."

"The Canadian Water Quality Guideline (CWQG) to protect freshwater life is 0.12 milligrams of inorganic fluoride per litre of water." Environment Canada

http://www.ec.gc.ca/ceqg-rcqe/English/Html/GAAG_Fluoride.cfm

Background concentrations of fluoride from fertilizers and pesticides are assumed to be between 0.1mg/L and 0.2mg/L. At 0.2 mg/L, fluoride is already at a "critical level" for some species of fish – e.g. trout, salmon and insects that fish feed upon.

"Levels of fluorides in surface water average about 0.2 parts of fluoride per million parts of water (ppm)." ATSDR Public Health Statement: Fluoride p3.

The City of Kamloops in British Columbia, when it was fluoridated to 1.0 mg/L measured secondary effluent levels discharged to the Thompson River to 1.5 mg/L. This study and others, prompted Kamloops to stop water fluoridation in 2005. Dr. Foulkes 2002 Response to WAC 197-11-960 Environmental Checklist for Tacoma-Pierce County Health Department Fluoridation.

"A review of literature and documentation suggests that concentrations of fluoride above 0.2 mg/L have lethal (LD50) effects on and inhibit migration of "endangered" salmon species whose stocks are now in serious decline in the US Northwest and British Columbia." Foulkes RG, Anderson AC. 1994 Impact of Artificial Fluoridation on Salmon Species in the Northwest USA and British Columbia, Canada. Fluoride Journal 27:4 220-226.

On the Columbia River a study was conducted to determine the effects of water fluoridation on the migration of fish. The study was set up with two `migration chutes' where the fish had a choice of which chute to enter. One chute had 0.5 mg/L of fluoride, and the other chute had no fluoride. Downstream of both chutes, water concentrations were at 0.25 mg/L (the result of both water streams mixing). Surprisingly, the research found that fish wouldn't go up the unfluoridated chute (as expected): they stopped at the water with 0.25 mg/L of fluoride. Therefore, fluoridated water is a barrier to fish migration. 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.

The mean concentration of fluoride in domestic sewage, which includes use of a fluoride product at 1.0 mg/L, is estimated to be: 2.3 mg/L in raw sewage; 1.15 mg/L in secondary effluent. Dr. Foulkes' 2002 Response to WAC 197-11-960 Environmental Checklist for Tacoma-Pierce County Health Department Fluoridation andersfoulkes@cs.com

Singer and Armstrong found secondary effluent levels in fluoridated (at 1.0 mg/L) Minneapolis-St. Paul of 1.21 mg/L and non-fluoridated Brainerd (0.13 mg/L in water) of 0.38mg/L. Singer L, Armstrong WD. 1977 Fluoride in Treated Sewage and in Rain and Snow. Archives of Environmental Health Jan/Feb P 21-23.

The mean value of domestic sewage including fluoride in the water supply at a mean concentration of 0.25 mg/L (range 0.1-0.4 mg/L) was reported as 1.55 mg/L fluoride in raw sewage and 0.63 mg/L fluoride in secondary effluent (range 0.3-1.5). Masuda TT. 1964. Persistence of Fluorides from Organic Origins in Waste Waters. Developments in Industrial Microbiology 5: 53-70.

"Studies show that elevated concentrations in fresh water receiving fluoridated effluent may persist for some distance. Bahls (19) showed that the effluent from Bozeman Montana of 0.6-2.0 mgF/L, discharged into the East Galletin River did not return to the background level of 0.33 mgF/L for 5.3 km. Singer and Armstrong (18) reported that a distance of 16 km was required to return the Mississippi River to its background level of 0.2 mg/FL after receiving the effluent of 1.21 mgF/L from Minneapolis-St Paul. Although dilution reduces concentration over distance, the amount of fluoride in effluent is either deposited in sediment locally or is carried to the estuary where it may persist for 1-2 million years (16) or may re-contaminate if dredging were to take place." Foulkes RG, Anderson AC. 1994 Impact of Artificial Fluoridation on Salmon Species in the Northwest USA and British Columbia, Canada. Fluoride Journal 27:4 220-226.

Warrington in a study for the British Columbia Ministry of Environment also identified 0.2 mg/L fluoride as a "critical level" for fresh water species. Warrington, PD, Ambient Water Quality Criteria for Fluoride. Technical Appendix 1990, British Columbia Ministry of Environment.

Government of Canada Environmental Protection Act - estimated adverse effect thresholds (lethal, growth impairment and egg production) are 0.28 mg/L fluoride for fresh water species and 0.5 mg/L fluoride for marine species. Government of Canada 1993, Inorganic Fluorides, Canadian Environmental Protection Act (Priority Substances List Assessment Report).

Harm to animals (pets, livestock and wild animals)

Hypersensitive reactions to artificially fluoridated water [0.35 to 1.3 ppm Fluoride] causes skin lesions. Dental Fluorosis and Gingivitis [inflammation of gums] in Horses. No other known source of fluoride in diets. Other reproducible symptoms include colitis, thyroid suppression.

Photos: citations 119, 11

Harm to plants and trees

Fluoride damages trees including Scots Pine. New growth on branch tips is killed off in a phenomenon called tip burn.

"The fluoride concentrates in the margins and tip so it is these areas that generally are the first to show visible injury."
http://www.ncl.ac.uk/airweb/fluoride/Fluoride1.htm

7. Costs of Water Fluoridation

According to arguments made in this petition, water fluoridation is ineffective and causes harm to humans and the environment.

In addition to these drawbacks, fluoridation is very expensive. According to the Chief Dental Officer for Health Canada, annual maintenance costs of water fluoridation are "$3 per capita per annum" [as stated in minutes]1:

City

Population

Annual Fluoridation Costs

Toronto

2.5 million x $3/person/year

$7.5 million/year

Calgary

1 million x $3/person/year

$3 million/year

Hamilton

500,000 x $3/person/year

$1.5 million/year

8. Presentation by Kathleen M. Thiessen on Fluoridation in California

Kathleen M. Thiessen, Ph.D., a committee member of the U.S. National Research Council 2006 Report on Fluorides in Drinking Water, wrote the following report on the health effects of water fluoridation. Kathleen works with the Center for Risk Analysis at SENES Oak Ridge, Inc.

The first graph illustrates the expected range of consumption of community water (public tap water) for various age groups, in quantities of milliliters per day (mL per day). The ranges include only people who actually consume tap water. Note that some people consume substantially more tap water than the usual range (indicated by the diamonds). This information is from an EPA report published in 2004.

The total consumption of community water shown here is not to be confused with total fluid consumption or total water consumption. It does not include well water, bottled water, or commercial beverages. It does include water consumed directly and water used to prepare household or restaurant foods and beverages.

The second graph shows the same information as in the first slide, but in terms of water intake per unit body weight (milliliters of community water intake per kg of body weight, or mL per kg per day). Note that infants have the highest tap water consumption per unit body weight, with some infants reaching more than 250 mL per kg per day.

In general, the people with the highest tap water intakes include babies fed formula made with tap water, people with certain medical conditions (e.g., diabetes insipidus, diabetes mellitus) or taking certain medications (e.g., lithium), people in unairconditioned residences in hot climates, people who work outside in hot climates or do heavy physical labor, and athletes.

The third graph shows estimated fluoride intakes for each age group (mg of fluoride per kg of body weight per day), assuming the range of tap water intakes shown in Slide 2 and a fluoride concentration in the tap water of 0.8 ppm (0.8 mg fluoride per liter of water). Also shown is EPA's reference dose, which is defined as "an estimate of a daily oral exposure to the human population (including sensitive subgroups) that is likely to be without an appreciable risk of deleterious effects during a lifetime." For fluoride, the reference dose is 0.06 mg per kg per day. As seen in the graph, many infants have a fluoride intake just from tap water that exceeds EPA's reference dose for fluoride. Children (ages 1-10) with high water consumption also exceed EPA's reference dose. Older children (youth) and adults with high water consumption are very close to EPA's reference dose.

Note that this graph shows estimated fluoride intakes only from tap water. These estimates do not include fluoride intakes from other sources, such as commercial beverages (which are often made with fluoridated tap water), toothpaste, tea, or food. When these other sources of fluoride intake are included, total fluoride intakes for many members of all age groups exceed EPA's reference dose.

The final graph shows the estimated fluoride intakes from tap water from Slide 3, plus estimates of the "no-effect" levels for various adverse health effects. These "no-effect" levels represent fluoride intakes at or below which most people are not expected to experience any harmful effects. Note that these estimates are based on average exposures of study populations; these estimates do not include any margin of safety, and they might not be protective for all individuals. Intakes above these levels cannot be considered safe.

Note also that most of these "no-effect" levels are lower than EPA's reference dose for fluoride. In other words, EPA's reference dose is not protective for most of these health endpoints.

Note also that most of these "no-effect" levels are exceeded by many members of the population, of all ages, just from fluoride at 0.8 ppm in community drinking water. When other fluoride sources are included, even more people are expected to exceed the "no-effect" levels. In order to be "safe" for all members of the population, fluoride intakes for all people must be kept below the lowest "no-effect" levels, when all sources of fluoride intake are included, and with an adequate margin of safety.

This list of adverse health effects does not include cancer. A carcinogenic (cancer-causing) effect of fluoride cannot be ruled out from the available data, and at the very least, a cancer-promoting effect is likely. For carcinogenic substances, the risk of cancer increases with the amount of exposure, such that even a very low exposure carries with it some cancer risk.

Ethical and Legal Concerns

Fluoride is dispensed as a drug in our drinking water, but it has never been approved as a drug in the U.S. (status of drug approval unknown in Canada).

"The Food and Drug Administration Office of Prescription Drug Compliance has confirmed, to my surprise, that there are no studies to demonstrate either the safety or effectiveness of these drugs which FDA classifies as unapproved new drugs." Letter from Dr. David Kessler, M.D., Commissioner, United States Food and Drug Administration, June 3, 1993 to Congressman Kenneth Calvert, Chairman, Subcommittee on Energy and Environment, Committee on Science, Washington, D.C.

"Fluoride, when used in the diagnosis, cure, mitigation, treatment, or prevention of disease in man or animal, is a drug that is subject to Food and Drug Administration (FDA) regulation." United States Food and Drug Administration letter Dec, 2000, to Congressman Kenneth Calvert, Chairman, Subcommittee on Energy and Environment, Committee on Science, Washington, D.C.

"In pharmacology, if the effect is local (topical), it's awkward to use it in any other way than as a local treatment. I mean this is obvious. You have the teeth there, they're available for you, why drink the stuff?" Dr. Arvid Carlsson, Nobel Laureate in Medicine, 2000.

The Precautionary Principle:
If in doubt, leave it out

"Government of Canada shall…(a) exercise its powers in a manner that protects the environment and human health, applies the precautionary principle that, where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation, and promotes and reinforces enforceable pollution prevention approaches;" Environment Canada: Toxic Substances Division.

"In the absence of comprehensive, high-quality evidence with respect to the benefits and risks of water fluoridation, the moral status of advocacy for this practice is, at best, indeter-minate, and could perhaps be considered immoral." H. Cohen and Dr. David Locker, Professor at U of T Faculty of Dentistry, Professor, Department of Community Dentistry , Faculty of Dentistry, University of Toronto, Director, Community Dental Health Services Research 2001 "The Science and Ethics of Water Fluoridation" Journal of Canadian Dental Association 67(10):578-80.

"The issue of mass medication of an unapproved drug without the expressed informed consent of each individual must also be addressed. The dose of fluoride cannot be controlled ….Individuals who are susceptible to fluoride's harmful effects cannot avoid ingesting this drug. This presents a medico-legal and ethical dilemma and sets water fluoridation apart from vaccination as a public health measure where doses and distribution can be controlled." Dr. Hardy Limeback, Associate Professor and Head, Preventive Dentistry, Faculty of Dentistry, University of Toronto "Why I am now officially opposed to adding fluoride to water." April, 2000 http://www.slweb.org/bibliography.html#reviews.

Are We Violating Our Own Rules?

Additions of drinking water health hazards are not permitted. Dilution is no defence. Ontario Safe Drinking Water Act, section 20(1,3)

Violations of ANSI/NSF Standard 60 *(see attached Stan Hazan testimony) are, by extension, violations of Certificates of Approval under the Ontario Safe Drinking Water Act and other provinces/territories in Canada. Ontario Safe Drinking Water Act, section 31(1), Section 6.1 Certificates of Approval.

Do We Want to Import Toxic Substances from China?

Water fluoridation supplies are now coming from China. Dwindling supplies of fluorosilicates used in water fluoridation means that the replacement product could be shipped to us from China. e.g. "Kip Duchon (CDC) reported in 2007 that when U.S. Agrichemicals withdrew from the market in 2005, about half of U.S. sodium silicofluoride supplies began to be imported from a producer in China." City of Boulder: Water Resources Advisory Board Agenda Item; Meeting; May 21, 2007.

10. Specific Questions to Government Officials

  1. The US EPA classifies hydrofluorosilicic acid as a Class 1 hazardous waste. Is hydrofluorosilicic acid a Class 1 hazardous waste or equivalent in Canada?
  2. Can Health Canada or any other government department point to any toxicology study or studies demonstrating safety of the fluorosilicate products used to fluoridate drinking water for more than 60 years? If so, would that department please provide a reference to or copy of such documented research?
  3. Does Health Canada or any other federal government department believe that there is any legitimate government interest fulfilled by adding arsenic, lead, mercury, cadmium, barium, chromium and other contaminants which are bundled with hydrofluorosilicic acid, to our drinking water and hence our environment, in the process of water fluoridation? If so, how so?
  4. Are Health Canada, Environment Canada and other government departments aware that inorganic arsenic, lead, mercury and inorganic fluorides (e.g., hydrofluorosilicic acid) are on the CEPA 2006 toxic substances list and that hydrofluorosilicic acid is not naturally present in the environment?
  5. How many cases of osteosarcoma/bone cancer – the often fatal cancer associated with fluoride exposure – are reported in one year in Canada? Has Health Canada advised the Canadian Cancer Society of the increased risks for bone cancer associated with water fluoridation? If not, why not?
  6. Does Health Canada have current information regarding the incidence of dental fluorosis in Canada? If so, please provide data or source of data. If not, will Health Canada request this information from the Canadian Dental Association?
  7. What is the average cost to repair dental fluorosis for an individual? Will Health Canada see to it that those who are harmed by water fluoridation are appropriately reimbursed?
  8. Is any federal government department aware that these chemical additions are allegedly violating NSF Standard 60 and the Safe Drinking Water Act [SDWA] of Ontario and similar acts of other jurisdictions? What other provincial and territorial acts are being violated by fluoridation chemicals? Does Health Canada, environment Canada or any other federal government department have a mechanism for investigating such alleged violations?
  9. In the absence of safety studies, does any Canadian government department feel comfortable in claiming that hydrofluorosilicic acid is safe? In the absence of safety studies on the products used in water fluoridation, how do you justify your actions to promote the use of a hazardous waste product that has never been tested for safety?
  10. According to the Ontario Ministry of Health & Long Term Care 1999 report, 20 to 75% of individuals in fluoridated communities have dental fluorosis. 12 to 45% of individuals in non-fluoridated communities have dental fluorosis. The Chief Dental Officer for Canada is quoted as saying: "Fluorosis is not caused by Water Fluoridation" 1 Would the CDO please explain how and why his opinion differs so much from the Ontario Ministry of Health, NRC 2006 Report, EWG 2006 and NAS Report, [page 21 above]. reports? Will the government of Canada conduct a peer-review study to determine who is correct?
  11. According to NRC reports, ATSDR reports and other sources those who drink more than average quantities of water (e.g. kidney disease patients, diabetic patients, lactating mothers) are at risk for fluoride toxicity. The Dental Officer of Health for Halton, Ontario states: "Even if you drink a whole lot of water it's impossible to overdose if water is fluoridated at the optimal level" Oakville Beaver, April 13, 2007. Would the government of Canada conduct a peer-review study to determine who is correct?
  12. Is Health Canada genuinely capable of providing an estimated range of total daily water ingestion of fluoride by infants and children, by age, in all artificially fluoridated communities in Canada who use your recommended guideline of 0.8mg/L – 1.0mg/L? If Yes, please submit the data specific to this request and the source for the estimates. If No, please so state.
  13. Is Health Canada genuinely capable of providing an estimate for the full range of daily water ingestion of fluoride, by consumers of fluoridated water who use your recommended guideline of 0.8mg/L – 1.0mg/L, including specific ranges for labourers, athletes, the excessively thirsty such as those individuals with diabetes, and those encouraged by health professionals to use water for health or detoxifying purposes? If Yes, please submit the data specific to this request and the source for the estimates. If No, please so state.
  14. Can any Canadian or provincial government department or agency force an individual to be medicated with a substance that has not been specifically approved for the purpose it is intended, and especially approved in the manner it is administered? Does the approval of one substance, or manner of delivery, translate to an approval for another similar substance or different mode of delivery?
  15. Is fluoride considered to be a drug that is subject to Health Canada or any other regulation(s)?
  16. Have fluorosilicates ever been approved as a drug in Canada?
  17. Do fluorosilicates have a Drug Identification Number [DIN]?
  18. As fluoride is not removed by simple carbon filtration, what is the estimated cost for installation and yearly maintenance for a drinking water system that adequately filters fluoride [e.g. reverse osmosis, distillation]? Please identify your source.
  19. Who should pay the cost for installation and maintenance of any fluoride removal system for a consumer identified in government scientific literature as unusually susceptible to fluoride's adverse health effects, i.e., the consumer, an entity promoting or endorsing fluoridation, the local dental society, the Canadian Dental Association, an insurance company, the water system operator, the department of health, etc?
  20. Does Health Canada provide documentation of known sources of fluoride exposure in foods and beverages? If not, why not?
  21. Do government departments such as Fisheries and Wildlife, Natural Resources, Environment Canada have any duty to inform those involved in fisheries and wildlife of the inherent risks of water fluoridation to our ecosystem?
  22. There is ample evidence that fluoride interferes with the body's ability to utilize essential nutrients such as calcium, magnesium, iodine, etc. via various metabolic pathways, [see NRC Canada 1977, US NRC 2006]. Is fluoride an essential nutrient? If so, please provide evidence. If not, does Health Canada or any other federal government agency have adequate grounds to justify that purported benefits of fluoridation of drinking water should outweigh and compromise the good nutrition of our citizens?
  23. Does Health Canada believe that statements of endorsement for the public policy of fluoridation also are endorsements for use of the products actually used for water fluoridation?
  24. Derivation of the Maximum Allowable Contaminant levels [MACs] is based largely on the level of carcinogenicity assigned to a toxic substance; 1) carcinogenic; 2) probably carcinogenic; 3) possibly carcinogenic; 4) probably not carcinogenic. What classification was given to fluoride? Why?
  25. Is Health Canada aware of the following quote by a report by the Ontario Ministry of Health & Long Term Care 1999: "Efforts are required to reduce (fluoride) intake among the most vulnerable age groups, children aged 7 months to 4 years..."? Does Health Canada have evidence that their initiative to reduce the recommended guideline from 1.0-1.2 mg/L to 0.8-1.0 mg/L in 1999 has significantly reduced fluoride exposures in vulnerable populations and significantly reduced associated health risks, such as bone cancer [especially in young men between the ages of 6-20], dental fluorosis ["mottled teeth"], thyroid suppression, etc? Please provide references.
  26. Does Health Canada acknowledge that timing of the fluoride exposure, and vulnerability of the child to fluoride exposure are important in fluoride toxicity?
  27. In regard to the statement made by Health Canada; "There are no studies indicating an association between fluoridated water in reconstituted infant formula and moderate or severe dental fluorosis", is anyone at Health Canada aware of the 56 studies48-108 demonstrating an association between the use of fluoridated water use in reconstituted infant formula and the risk of dental fluorosis of varying severity? If not, why not?
  28. Is Health Canada aware that the American Dental Association, The Academy of Dentistry, the Center for Disease Control have all issued advisories on their websites in letters, recommending that parents should not give children under the age of 1 year fluoridated water mixed with infant formula? Not all parents have computers or visit these particular websites. The concerns of fluoridated water and fluoridated toothpaste mentioned in the September 20, 2000 letter from the Ontario Ministry of Health has not been conveyed to the general public. Is it the intent of Health Canada to inform parents in Canada of these concerns? If not, why not?
  29. With the publication of the NRC 2006 Report, and evidence contained therein that endocrine systems and thyroid functions are impaired at exposure levels to fluoride below the consumption levels expected from drinking "optimally fluoridated water", what does Health Canada or any other federal department, plan to do to inform the consumer of such risks to their health?
  30. Is Health Canada aware that the US NRC 2006 Review states that 0.7mg/day with a 75kg individual, of ingested fluoride, when iodine insufficient, may cause thyroid suppression? If so, why is Health Canada permitting the additions of an inorganic fluoride such as hydrofluorosilicic acid in our drinking water, which account for most of our total fluoride consumption109? What does Health Canada intend to do to protect the population from iodine deficiency and fluoride over-exposure, which in combination, apparently leads to increasing numbers of people with thyroid insufficiency?
  31. Is Health Canada aware that doctors in Europe from 1930-1970 used fluoride to suppress thyroid function? 110-116
  32. Is Health Canada aware that ethnicity also seems to be important in regards to toxicity of fluoride exposure? E.g. Moderate to severe dental fluorosis is found in many black and aboriginal children whose cumulative dose from fluoridated water and foods processed in fluoridated water is identical to poor white children with milder cases of fluorosis.
  33. The protection of minorities is enshrined in the Canadian Charter of Rights and Freedoms, section 15, Equality Rights. Do Health Canada and relevant government agencies have an obligation to protect these minorities with regard to fluoridation of drinking water and the dispersal?
  34. In regard to the statement made by Health Canada: "Possible higher exposure in the first year would be mitigated by lower exposures in the subsequent two years of life." According to the NRC 2006 Report, p21, dental fluorosis cannot be reversed by lowering the intake of fluoride after the exposure; "The condition is permanent after it develops in children during tooth formation, a period ranging from birth until about the age of 8.". Would Health Canada please explain how and why they differ from the evidence of the NRC 2006 report? Please provide peer-reviewed scientific evidence of this claim.
  35. In regard to the statement made by Health Canada: "Fluoride must still meet standards of purity and quality before it is used in drinking water treatment," This product is bundled with many toxic substances such as arsenic, lead, cadmium, mercury, etc. Does this product meet Health Canada's standard for purity and quality? If so, how so? If not, why does Health Canada make this claim?
  36. In regard to the statement made by Health Canada on their website: "Public water fluoridation has been ranked one of the top ten public health measures of the twentieth century by the World Health Organization"; Will Health Canada provide the WHO documentation to support the above statement? If not, why does Health Canada use this quote on their website?
  37. Will the Government of Canada commit to establishing long-term health based objectives for drinking water contaminants, similar to the Maximum Contaminant Level Goals (MCLGs) established by the U.S. Environmental Protection Agency? If not, why not?

11. Recommendations to Government Officials

  1. Will Health Canada immediately prohibit any dental association, medical association or public health organization from promoting water fluoridation until a parliamentary committee has had a chance to review the accumulated peer-reviewed evidence which documents the public health concerns, environmental concerns, ethical concerns and legal concerns associated with water fluoridation? If not, why not?
  2. Will the Department of Justice and the Public Accounts Office please investigate these potential legal violations and their implications to taxpayers, of NSF Standard 60, the Safe Drinking Water Act, the Fisheries Act and other relevant government legislation? If not, why not?
  3. Will Health Canada organize immediately a public education campaign to offset the misconceptions the public has about the safety and efficacy of fluoride, when ingested, at recommended doses in drinking water?
  • Will Health Canada inform the public, dental and public health officials of the correct mode of action of fluoride; purported benefits are topical [applied directly to the surfaces of the teeth], not systemic [swallowed]? If not, why not?
  • Has Health Canada advised parents of young children [especially under the age of one] explicitly not to use fluoridated drinking water? If not, why not?
  • Has Health Canada advised those who are unable to adequately filter fluoride of their higher risks associated with water fluoridation [e.g., young children, elderly, kidney patients, diabetic patients, Walkerton, Ontario residents with impaired kidney function]? If not, why not?
  • Has Health Canada advised those who drink larger than normal quantities of water [e.g. athletes, lactating mothers, soldiers, diabetic patients] of the higher risks associated with water fluoridation? If not, why not?
  • Has Health Canada advised those with poor nutrition [e.g., calcium, magnesium, iodine, selenium] of their higher risks associated with water fluoridation [see ATSDR, NRC Canada 2007, NRC 2007]? If not, why not?
  • Have those working with Fisheries and Oceans, Natural Resources, Environmental Agency advised those involved with fisheries of the inherent risks of water fluoridation to many species of fish and the insects upon which they feed? If not, why not?
  • Will the Government of Canada commit to starting national bio-monitoring studies to regularly identify and track the exposure of Canadians to fluoride by testing blood, urine, saliva, etc.? If not, why not?
  • Would Health Canada enhance their website to include pictures of dental fluorosis so that the population and dentists can better identify this health concern?
  • Will Health Canada instruct the manufacturers of fluoridated toothpaste and mouthwash to put warning labels similar to the FDA warnings in the USA?
  1. 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 Stan Hazan 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.]
    • How can Environment Canada, Natural Resources, Transport Canada, Fisheries and Oceans, Public Health Agency, Indian and Northern Affairs, Public Health Agency, Environmental Assessment Agency or other relevant government agencies ensure that the public and the environment will be adequately protected from an accidental spill of this product [hydrofluorosilicic acid] if Standard 60 information is not available for the NSF-certified products?
    • How can emergency response workers be protected from potential accidents if the content of these products is not fully disclosed?

    12. Federal Departments and Agencies that Need to Respond

    • Canadian Environmental Assessment Agency
    • Environment Canada
    • Fisheries and Oceans Canada
    • Health Canada
    • Indian and Northern Affairs
    • Natural Resources Canada
    • Parks Canada
    • Public Health Agency of Canada
    • Public Safety Canada
    • Transport Canada
    • Department of Justice
    • Public Accounts
    • All other related ministries

    13. Appendices

    • Certificate of Analysis: LCI Ltd
    • NSF-Stan Hazan Congressional Testimony

    14. References

    1. The Corporation of the Municipality of Red Lake, Minutes of a Regular Council Meeting Held on 13 January 2004, In the Council Chembers, at 6:00pm. Accessed November 10, 2007: http://64.233.167.104/search?q=cache:CMvOsxYJI0AJ:www.red-lake.com/pdf/minutes/2004/040113.pdf+peter+cooney+fluorosis&hl=en&ct=clnk&cd=10&gl=ca
    2. Centers for Disease Control Website Accessed November 8, 2007: http://www.cdc.gov/fluoridation/engineering/faqs.htm
    3. LCI, Ltd, Material Safety Data Sheet: Fluorosilicic Acid: "highly toxic and extremely corrosive" http://www.lciltd.com/msds%5Cmsdshfs.htm see also AWWA bulletin.
    4. CDC website IBID. see also AWWA-B703-00 Standard for Fluorosilicic Acid
    5. CDC website IBID. For discussion visit: http://www.fluoridealert.org/APHA-silicofluorides.htm
    6. "In the manufacture of super-phosphate fertilizer, phosphate rock is acidulated with sulfuric acid, and the fluoride content of the rock evolves as volatile silicofluorides. In the past, much of this volatile material was vented to the atmosphere, contributing heavily to pollution of the air and land surrounding the manufacturing site. As awareness of the pollution problem increased, scrubbers were added to strip particulate and gaseous components from the waste gas..." (Bellack 1970) in: Connett M. 2003 The Phosphate Fertilizer Industry: An Environmental Overview. Fluoride Action Network http://www.fluoridealert.org/phosphate/overview.htm
    7. Kierdorf U, Kierdorf H. 2000 The fluoride content of antlers as an indicator of fluoride exposure in red deer (Cervus elaphus): A historical biomonitoring study. Archives of Environmental Contamination and Toxicology 38(1):121-7. "Bone fluoride concentrations were analyzed in 141 red deer antlers grown between the 17th/early 18th century and 1997, that originated from four study areas (Arnsberg, Bad Berleburg, Dammerwald, Schmidtheim) in the federal state of North Rhine-Westphalia, Germany… With the onset and expansion of large-scale industrial activities, bone fluoride concentrations in the antler samples markedly increased over these baseline values."
    8. Kierdorf H, Kierdorf U, Sedlacek F. 1999 Monitoring regional fluoride pollution in the Saxonian Ore mountains (Germany) using the biomarker dental fluorosis in roe deer (Capreolus capreolus L.) Science of the Total Environment 232(3):159-68. "A close spatial relationship between the main fluoride emission sources in North-Bohemia and the regions with the highest prevalence and severity of dental fluorosis in roe deer was discernible."
    9. Kierdorf U, Kierdorf H, Erdelen M, Korsch JP. 1989 Mandibular fluoride concentration and its relation to age in roe deer (Capreolus capreolus L.). Comparative Biochemistry and Physiology Part A 94(4):783-5. "Bone fluoride level was positively correlated with age"
    10. Mikaelian I, Qualls CW Jr, De Guise S, Whaley MW, Martineau D. 1999 Bone fluoride concentrations in beluga whales from Canada. Journal of Wildlife Disease. Apr;35(2):356-60.
    11. Krook LP, Justus C. 2006 Fluoride poisoning of horses from artificially fluoridated drinking water. Fluoride 39(1)3–10.
    12. Featherstone JDB. 2000 Cover Story: The Science and Practice of Caries Prevention. J American Dental Association. 131: 890. "Importantly, this means that fluoride incorporated during tooth mineral development at normal levels of 20 to 100 ppm (even in areas that have fluoridated drinking water or with the use of fluoride supplements) does not measurably alter the acid solubility of the mineral. Even when the outer enamel has higher fluoride levels, such as 1,000 ppm, it does not measurably withstand acid-induced dissolution any better than enamel with lower levels of fluoride... The fluoride incorporated developmentally – that is, systemically into the normal tooth mineral – is insufficient to have a measurable effect on acid solubility."
    13. Centers for Disease Control; MMWR Weekly Report. Vol 50, No. RR-14, August 17, 2001, p. 4. "The prevalence of dental caries in a population is not inversely related to the concentration of fluoride in enamel (37), and a higher concentration of enamel fluoride is not necessarily more efficacious in preventing dental caries."
    14. Shellis RP, et al. "Studies on the cariostatic mechanisms of fluoride". International Dental Journal 44; 263-273,1994. "…the predominant view for some time was that fluoride reduced the solubility of dental mineral and that, for caries prevention, it was essential to make fluoride available during tooth formation, for incorporation into the mineral. Preventive measures based on this view included fluoridation of public water supplies to the 1 mg/L level or, alternatively, supplying fluoride in tablet form to children. This approach has, however, ceased to be prevalent."
    15. Ten Cate JM, et al. Mechanistic Aspects of the Interactions Between Fluoride and Dental Enamel. Critical Reviews in Oral Biology and Medicine. 2(2):283-296, 1991.
    16. Margolis HC, et al. 1990 Physicochemical Perspectives on the Cariostatic Mechanisms of Systemic and Topical Fluorides. Journal of Dental Research (Special Issue) 69: 606-612.
    17. Fejerskov O. et al. "Rational use of fluorides in caries prevention". Acta Odontol. Scand. 1981, 39:241-249. "Until recently most caries preventive programs using fluoride have aimed at incorporating fluoride into the dental enamel. The relative role of enamel fluoride in caries prevention is now being increasingly questioned, and based on rat experiments and reevaluation of human clinical data, it appears to be of minor importance.""As a direct consequence any method which places particular emphasis on incorporation of bound fluoride into dental enamel during formation may be of limited value. Therefore, there is limited scientific data to support the assertion that systemic fluoride treatment should be initiated from shortly after birth."
    18. The 1997 Canadian Consensus Conference Results "The primary mechanism of action of fluoride to prevent dental decay is topical."
    19. Osgaard B. "Effects of Fluoride on Caries Development and Progression in vivo." J Dent Research Vol 69 (Special Issue) 813-819, February 1990.
    20. Carlos JP. 1983 (Director, National Caries Program, National Institute of Dental Research) "Comments on Fluoride". The Journal of Pedodontics, Winter 1983.
    21. Gray AS. (1987). Fluoridation: time for a new base line? Journal of the Canadian Dental Association 53: 763-5. "The type of caries now seen in British Columbia's children of 13 years of age, is mostly the pit and fissure type. Knudsen in 1940, suggested that 70 percent of the caries in children was in pits and fissures. Recent reports indicate that today, 83 percent of all caries in North American children is of this type. Pit and fissure cavities aren't considered to be preventable by fluorides, they are prevented by sealants.
    22. Scholle R. (1984). Editorial: Preserving the perfect tooth. Journal of the American Dental Association 108:448. "It is estimated that 84% of the caries experience in the 5 to 17 year-old population involves tooth surfaces with pits and fissures. Although fluorides cannot be expectedappreciably to reduce our incidence of caries on these surfaces, sealants can."
    23. Raloff J. (1984). Dental study upsets the accepted wisdom. Science News 125(1): January 7. "The program focused on four caries-prevention techniques: sealants, a plastic-like coating applied to the chewing surfaces of back teeth and to pits and fissures on the sides of teeth (these surfaces are most prone to decay and ones which fluorides cannot protect adequately)".
    24. Facts from the National Institute of Dental Research. Marshall Independent Marshall, Minnesota. May 28, 1992. "Nearly 90 percent of cavities in school children occur in the surfaces of teeth with vulnerable pits and grooves, where fluoride is least effective."
    25. White B. (1993). Toward improving the oral health of Americans: an overview of oral health status, resources and care delivery . Public Health Reports 108(6): 657-672.
    26. Shiboski CH et al. The Association of Early Childhood Caries and Race/Ethnicity Among California Preschool Children. J Pub Health Dent; Vol 63, No 1, Winter 2003. "Among 2,520 children, the largest proportion with a history of falling asleep sipping milk/sweet substance was among Latinos/Hispanics (72% among Head Start and 65% among non-HS) and HS Asians (56%). Our analysis did not appear to be affected by whether or not children lived in an area with fluoridated water."
    27. Kelly M et al. The Prevalence of Baby Bottle Tooth Decay Among Two Native American Populations. J Pub Health Dent; 47:94-97, 1987. "The prevalence of BBTD in the 18 communities of Head Start children ranged from 17 to 85 percent with a mean of 53%. The surveyed communities had a mixture of fluoridated and non fluoridated drinking water sources. Regardless of water fluoridation, the prevalence of BBTD remained high at all of the sites surveyed."
    28. Barnes GP et al. Ethnicity, Location, Age, and Fluoridation Factors in Baby Bottle Tooth Decay and Caries Prevalence of Head Start Children. Public Health Reports; 107: 167-73, 1992. "By either of the two criterion i.e., two of the four maxillary incisors or three of the four maxillary incisors, the rate for 5-year-olds was significantly higher than for 3-year-olds. Children attending centers showed no significant differences based on fluoride status for the total sample or other variables."
    29. Von Burg MM et al. Baby Bottle Tooth Decay: A Concern for All Mothers. Pediatric Nursing; 21:515-519, 1995. "Data from Head Start surveys show the prevalence of baby bottle tooth decay is about three times the national average among poor urban children, even in communities with a fluoridated water supply."
    30. Feltman R, Kosel G. (1961). Prenatal and postnatal ingestion of fluorides - Fourteen years of investigation - Final report. Journal of Dental Medicine 16: 190-99.
    31. Grimbergen GW. (1974). A Double Blind Test for Determination of Intolerance to Fluoridated Water (Preliminary Report). Fluoride 7:146-152.
    32. Bassin EB, Wypij D, Davis RB, Mittleman MA 2006 Age-specific fluoride exposure in drinking water and osteosarcoma. Cancer Causes Control. 17:421–428
    33. Hoover RN, Devesa S, Cantor K, Fraumeni JF Jr (1991) Time trends for bone and joint cancers and osteosarcomas in the Surveillance, Epidemiology and End Results (SEER) Program. In: Review of fluoride benefits and risks. U.S. Department of Health and Human Services, Washington, DC (Appendix F).
    34. National Toxicology Program [NTP] (1990). Toxicology and Carcinogenesis Studies of Sodium Fluoride in F344/N Rats and B6C3f1 Mice. Technical report Series No. 393. NIH Publ. No 91-2848. National Institute of Environmental Health Sciences, Research Triangle Park, N.C. p. 74.
    35. Cohn PD. (1992). A Brief Report On The Association Of Drinking Water Fluoridation And The Incidence of Osteosarcoma Among Young Males. New Jersey Department of Health Environ. Health Service: 1- 17.
    36. Whitford GM (1996) The metabolism and toxicity of fluoride, 2nd edn. Basil, Karger, pp 1–5, 89–90, 94.
    37. Gruber HE, Baylink DJ (1991) The effects of fluoride on bone. Clin Orthop 267:264–277.
    38. Kleerekoper M (1996) Fluoride and the skeleton. In: Bilezikian JP, Raisz LG, Rodan GA (eds) Principles of bone biology. Academic, San Diego, pp 1053–1062.
    39. WHO (1984) Fluorine and fluorides. World Health Organization,Geneva (Environmental Health Criteria 36).
    40. Ershow AG, Cantor KP (1989) Total water and tapwater intake in the united states: population-based estimates of quantities and sources. Life Sciences Research Office, Federation of American Societies for Experimental Biology, Bethesda, pp 21–24.
    41. Provincial and Territorial Estimates for Community Water Fluoridation Coverage http://www.hc-sc.gc.ca/ahc-asc/branch-dirgen/fnihb-dgspni/ocdo-bdc/project_e.html#6
    42. Whitford GM. 1994 Intake and metabolism of fluoride. Advances in Dental Research. Jun;8(1):5-14, Review. P10. "Overall, an average of 86.8% of the dose was retained by the infants, which is about 50% higher than would be expected for adults. There is a clear need for more information about the renal handling and general metabolism of fluoride in young children..."
    43. Letter from the Minister of Health to all Medical Officers of Health in Ontario, dated September 20, 2000 http://www.pdhu.on.ca/pdf/minlett.pdf.
    44. Masters RD, Coplan M. 1999 Water treatment with silcofluorides and lead toxicity. International Journal of Environmental Science 56: 435-449.
    45. Masters RD, Coplan MJ, Hone BT, Dykes JF. 2000 Association of silicofluoride treated water with elevated blood lead. Neurotoxicology 21(6): 1091-1100.
    46. 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.
    47. Coplan MJ, Patch SC, Masters RD, Bachman MS. 2007 Confirmation of and explanations for elevated blood lead and other disorders in children exposed to water disinfection and fluoridation chemicals. Neurotoxicology. Sep;28(5):1032-42.
    48. Diesendorf M, Diesendorf A. (1997). Suppression by medical journals of a warning about overdosing formula-fed infants with fluoride. Accountability in Research 5:225-237. "the uptake of fluoride into bone is greatest in infants and young children. Thus, infants who drink mainly powdered formula reconstituted with fluoridated water are likely to be a high-risk group for developing both skeletal fluorosis and hip fractures in old age."
    49. 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.
    50. Coplan MJ, Patch SC, Masters RD, Bachman MS. 2007 Confirmation of and explanations for elevated blood lead and other disorders in children exposed to water disinfection and fluoridation chemicals. Neurotoxicology. Sep;28(5):1032-42.
    51. Masters RD, Coplan M. 1999 Water treatment with silcofluorides and lead toxicity. International Journal of Environmental Science 56: 435-449.
    52. Masters RD, Coplan MJ, Hone BT, Dykes JF. 2000 Association of silicofluoride treated water with elevated blood lead. Neurotoxicology 21(6): 1091-1100.
    53. Barnes GP, et al. (1992). Ethnicity, location, age, and fluoridation factors in baby bottle tooth decay and caries prevalence of Head Start children. Public Health Reports 107: 167-73.
    54. Bentley EM, et al. (1999). Fluoride ingestion from toothpaste by young children. British Dental Journal 186(9):460-2.
    55. Brothwell D, Limeback H. 2003 Breastfeeding is protective against dental fluorosis in a nonfluoridated rural area of Ontario, Canada. J Hum Lact. Nov;19(4):386-90.
    56. Brothwell DJ, Limeback H. 1999 Fluorosis risk in grade 2 students residing in a rural area with widely varying natural fluoride. Community Dent Oral Epidemiol. 1999 Apr;27(2):130-6.
    57. Buzalaf MA, Granjeiro JM, Damante CA, de Ornelas F. 2001 Fluoride content of infant formulas prepared with deionized, bottled mineral and fluoridated drinking water. ASDC J Dent Child. 2001 Jan-Feb;68(1):37-41, 10.
    58. Diesendorf M, Diesendorf A. (1997). Suppression by medical journals of a warning about overdosing formula-fed infants with fluoride. Accountability in Research 5:225-237.
    59. Ekstrand J. (1989). Fluoride intake in early infancy. Journal of Nutrition 119(Suppl 12):1856-60.
    60. Erdal S, Buchanan SN. (2005). A quantitative look at fluorosis, fluoride exposure, and intake in children using a health risk assessment approach. Environmental Health Perspectives 113:111-7.
    61. Fomon SJ, Ekstrand J, Ziegler EE. (2000). Fluoride intake and prevalence of dental fluorosis: trends in fluoride intake with special attention to infants. Journal of Public Health Dentistry 60(3):131-9.
    62. Fomon SJ, Ekstrand J. (1999). Fluoride intake by infants. Journal of Public Health Dentistry 59(4):229-34.
    63. Franco AM, et al. (2005). Total fluoride intake in children aged 22-35 months in four Colombian cities. Community Dentistry and Oral Epidemiology 33:1-8.
    64. Franzman MR, et al. (2006). Fluoride dentifrice ingestion and fluorosis of the permanent incisors. Journal of the American Dental Association 137:645-52.
    65. Heilman JR, et al. (1997). Fluoride concentrations of infant foods. Journal of the American Dental Association 128: 857-863.
    66. Heller KE, et al. (2000). Water consumption and nursing characteristics of infants by race and ethnicity. Journal of Public Health Dentistry 60(3):140-6.
    67. Kelly M, Bruerd B. (1987). The Prevalence of Baby Bottle Tooth Decay Among Two Native American Populations. Journal of Public Health Dentistry 47:94-97.
    68. Kumar JV, Swango PA. (2000). Low birth weight and dental fluorosis: is there an association? Journal of Public Health Dentistry 60(3):167-71.
    69. Kunzel W, et al. (2000). Decline in caries prevalence after the cessation of water fluoridation in former East Germany. Community Dentistry and Oral Epidemiology 28: 382-389.
    70. Levy SM, et al. (2003). Patterns of fluoride intake from 36 to 72 months of age. Journal of Public Health Dentistry 63: 211-20.
    71. Levy SM, et al. (1995). Sources of fluoride intake in children. Journal of Public Health Dentistry 55(1):39-52.
    72. Lewis DW, Limeback H. (1996). Comparison of recommended and actual mean intakes of fluoride by Canadians. Journal of the Canadian Dental Association 62: 708-715.
    73. Locker, D. (1999). Benefits and Risks of Water Fluoridation. An Update of the 1996 Federal-Provincial Sub-committee Report. Prepared for Ontario Ministry of Health and Long Term Care.
    74. Marshall TA, et al. (2004). Associations between Intakes of Fluoride from Beverages during Infancy and Dental Fluorosis of Primary Teeth. Journal of the American College of Nutrition 23(2):108-16.
    75. Martinez-Mier EA, et al. (2003). Fluoride intake from foods, beverages and dentifrice by children in Mexico. Community Dentistry and Oral Epidemiology 31: 221-30.
    76. Mascarenhas AK. (2000). Risk factors for dental fluorosis: a review of the recent literature. Pediatric Dentistry 22(4):269-77.
    77. Mascarenhas AK, Burt BA. (1998). Fluorosis risk from early exposure to fluoride toothpaste. Community Dentistry and Oral Epidemiology 26(4):241-8.
    78. Pendrys DG, Katz RV. (1998). Risk factors for enamel fluorosis in optimally fluoridated children born after the US manufacturers' decision to reduce the fluoride concentration of infant formula. American Journal of Epidemiology 148: 967-74.
    79. Shiboski CH, et al. (2003). The association of early childhood caries and race/ethnicity among California preschool children. Journal of Public Health Dentistry 63(1):38-46. Von Burg MM, et al. (1995). Baby bottle tooth decay: a concern for all mothers. Pediatric Nursing 21:515-519.
    80. Whitford GM. 1994 Intake and Metabolism of Fluoride Advances in dental Research 8(1): 5-14.
    81. Barnes GP, et al. (1992). Ethnicity, location, age, and fluoridation factors in baby bottle tooth decay and caries prevalence of Head Start children. Public Health Reports 107: 167-73.
    82. Bentley EM, et al. (1999). Fluoride ingestion from toothpaste by young children. British Dental Journal 186(9):460-2.
    83. Brothwell D, Limeback H. 2003 Breastfeeding is protective against dental fluorosis in a nonfluoridated rural area of Ontario, Canada. J Hum Lact. Nov;19(4):386-90.
    84. Brothwell DJ, Limeback H. 1999 Fluorosis risk in grade 2 students residing in a rural area with widely varying natural fluoride. Community Dent Oral Epidemiol. 1999 Apr;27(2):130-6.
    85. Buzalaf MA, Granjeiro JM, Damante CA, de Ornelas F. 2001 Fluoride content of infant formulas prepared with deionized, bottled mineral and fluoridated drinking water. ASDC J Dent Child. 2001 Jan-Feb;68(1):37-41, 10.
    86. Diesendorf M, Diesendorf A. (1997). Suppression by medical journals of a warning about overdosing formula-fed infants with fluoride. Accountability in Research 5:225-237.
    87. Ekstrand J. (1989). Fluoride intake in early infancy. Journal of Nutrition 119(Suppl 12):1856-60.
    88. Erdal S, Buchanan SN. (2005). A quantitative look at fluorosis, fluoride exposure, and intake in children using a health risk assessment approach. Environmental Health Perspectives 113:111-7.
    89. Fomon SJ, Ekstrand J, Ziegler EE. (2000). Fluoride intake and prevalence of dental fluorosis: trends in fluoride intake with special attention to infants. Journal of Public Health Dentistry 60(3):131-9.
    90. Fomon SJ, Ekstrand J. (1999). Fluoride intake by infants. Journal of Public Health Dentistry 59(4):229-34.
    91. Franco AM, et al. (2005). Total fluoride intake in children aged 22-35 months in four Colombian cities. Community Dentistry and Oral Epidemiology 33:1-8.
    92. Franzman MR, et al. (2006). Fluoride dentifrice ingestion and fluorosis of the permanent incisors. Journal of the American Dental Association 137:645-52.
    93. Heilman JR, et al. (1997). Fluoride concentrations of infant foods. Journal of the American Dental Association 128: 857-863.
    94. Heller KE, et al. (2000). Water consumption and nursing characteristics of infants by race and ethnicity. Journal of Public Health Dentistry 60(3):140-6.
    95. Kelly M, Bruerd B. (1987). The Prevalence of Baby Bottle Tooth Decay Among Two Native American Populations. Journal of Public Health Dentistry 47:94-97.
    96. Kumar JV, Swango PA. (2000). Low birth weight and dental fluorosis: is there an association? Journal of Public Health Dentistry 60(3):167-71.
    97. Kunzel W, et al. (2000). Decline in caries prevalence after the cessation of water fluoridation in former East Germany. Community Dentistry and Oral Epidemiology 28: 382-389.
    98. Levy SM, et al. (2003). Patterns of fluoride intake from 36 to 72 months of age. Journal of Public Health Dentistry 63: 211-20.
    99. Levy SM, et al. (1995). Sources of fluoride intake in children. Journal of Public Health Dentistry 55(1):39-52.
    100. Lewis DW, Limeback H. (1996). Comparison of recommended and actual mean intakes of fluoride by Canadians. Journal of the Canadian Dental Association 62: 708-715.
    101. Locker, D. (1999). Benefits and Risks of Water Fluoridation. An Update of the 1996 Federal-Provincial Sub-committee Report. Prepared for Ontario Ministry of Health and Long Term Care.
    102. Marshall TA, et al. (2004). Associations between Intakes of Fluoride from Beverages during Infancy and Dental Fluorosis of Primary Teeth. Journal of the American College of Nutrition 23(2):108-16.
    103. Martinez-Mier EA, et al. (2003). Fluoride intake from foods, beverages and dentifrice by children in Mexico. Community Dentistry and Oral Epidemiology 31: 221-30.
    104. Mascarenhas AK. (2000). Risk factors for dental fluorosis: a review of the recent literature. Pediatric Dentistry 22(4):269-77.
    105. Mascarenhas AK, Burt BA. (1998). Fluorosis risk from early exposure to fluoride toothpaste. Community Dentistry and Oral Epidemiology 26(4):241-8.
    106. Pendrys DG, Katz RV. (1998). Risk factors for enamel fluorosis in optimally fluoridated children born after the US manufacturers' decision to reduce the fluoride concentration of infant formula. American Journal of Epidemiology 148: 967-74.
    107. Shiboski CH, et al. (2003). The association of early childhood caries and race/ethnicity among California preschool children. Journal of Public Health Dentistry 63(1):38-46. Von Burg MM, et al. (1995). Baby bottle tooth decay: a concern for all mothers. Pediatric Nursing 21:515-519.
    108. Whitford GM. 1994 Intake and Metabolism of Fluoride Advances in dental Research 8(1): 5-14.
    109. "For typical individuals, the single most important contributor to fluoride exposures (approaching 50% or more) is fluoridated water and other beverages and foods prepared or manufactured with fluoridated water" NRC 2006 Chapter 2, p 87.
    110. Galletti P, Joyet G. (1958). Effect of Fluorine on Thyroidal Iodine Metabolism in Hyperthyroidism. Journal of Clinical Endocrinology 18:1102-1110.
    111. Goldemberg L. (1930). Compt Rend Soc Biol (Paris) 104:1031.
    112. Goldemberg L. (1926). [Action physiologique des fluorures] Compt Rend Soc Physiol (Paris. 95:1169.
    113. May W. (1935). [Antagonismus zwischen Jod und Fluor im Organismus] Klin Wochenschr 14:790-792.
    114. May W. (1937). [Behandlung the Hyperthyreosen einschliesslich des schweren genuinen Morbus Basedow mit Fluor] Klin Wochenschr 16:562-564.
    115. Schuld A. (1999). Fluoride-Iodine Antagonism: Some History. Parents of Fluoride Poisoned Children.
    116. Schuld - 2005- Is Dental Fluorosis Caused by Thyroid Hormone Disturbances? Fluoride 35(2): 91-94.
    117. Saito N, Kuratate H. On the capacity of sodium fluoride to sensitize guinea pigs and rabbits. Nihon Hoigaku Zasshi 1951;5(3):148-52. [In Japanese]
    118. Lewis A, Wilson CW. Fluoride hypersensitivity in mains tap water demonstrated by skin potential changes in guinea-pigs. Med Hypotheses 1985;16:397-402.
    119. Justus C, Krook LP. 2006 Allergy in Horses from Artificially Fluoridated Water. Fluoride 39(2)89–94. "The horses exhibited classical signs of chronic fluorosis, viz., colic, dental fluorosis, decreased serum thyroxin, osteomegaly as hyperostosis and endostosis, hoof deformities, and fluoride retention in bone tissue. Here we add allergy as another expression of fluorosis in horses. Allergy or hypersensitivity to fluoride is well documented in humans,2 and it has been reported in laboratory studies on rabbits and guinea pigs3 and confirmed in guinea pigs.4" "Artificially fluoridated water (AFW) was introduced into the community in the 1980s and was the only source of water for the horses. It was also essentially the only source of fluoride, since the horses were not fed a fluoride-containing calcium-phosphorus mineral mix, nor was their roughage contaminated by fluoride-containing fertilizer. Altogether, over the years eleven horses were exposed to the AFW. Allergy to the water was noted in two of the horses in the form of skin lesions, documented with photographs, which form the basis of this report.
    120. Grandjean P, Landrigan P. (2006). Developmental neurotoxicity of industrial chemicals. The Lancet, Dec 16;368(9553):2167-78.
    121. Bansal R, Tiwari SC. (2006). Back pain in chronic renal failure. Nephrology Dialysis Transplantation 21:2331-2332. "Individuals with kidney disease have decreased ability to excrete fluoride in urine and are at risk of developing fluorosis even at normal recommended limit of 0.7 to 1.2 mg/l."
    122. Ayoob S, Gupta AK. (2006). Fluoride in Drinking Water: A Review on the Status and Stress Effects. Critical Reviews in Environmental Science and Technology 36:433–487. "Persons with renal failure can have a four fold increase in skeletal fluoride content, are at more risk of spontaneous bone fractures, and akin to skeletal fluorosis even at 1.0 ppm fluoride in drinking water."
    123. National Research Council. (2006). Fluoride in Drinking Water: A Scientific Review of EPA's Standards. National Academies Press, Washington D.C. p140 . "In patients with reduced renal function, the potential for fluoride accumulation in the skeleton is increased. It has been known for many years that people with renal insufficiency have elevated plasma fluoride concentrations compared with normal healthy persons and are at a higher risk of developing skeletal fluorosis."
    124. Torra M, et al. (1998). Serum and urine fluoride concentration: relationships to age, sex and renal function in a non-fluoridated population. Science of the Total Environment 220: 81-5. "It is important to control the intake of this element [fluoride] and the prolonged use of fluoridated dental products in the subjects with chronic renal insufficiency, to avoid a risk of fluorosis."
    125. Usuda K, Kono K, Yoshida Y (1997). The effect of hemodialysis upon serum levels of fluoride. Nephron 75:175-8.  "HD (hemodialysis) patients need to practice dietary control for the restriction of oral F intake."

      *[attachments not posted]

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Minister's Response: Environment Canada

27 March 2008

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

Dear Ms. Clinch:

I am pleased to respond to your Environmental Petition No. 221, which you sent to the Interim Commissioner of the Environment and Sustainable Development, regarding the addition of fluoridation chemicals to drinking water. The petition was received in Environment Canada on November 19, 2007.

Due to the nature of the issues raised in your petition, Environment Canada has collaborated with the other departments involved to prepare a joint response. My colleague, the Honourable Tony Clement, Minister of Health, will respond to your petition on behalf of the petitioned Ministers.

Thank you for your interest in this important issue.

Sincerely,

[Original signed by John Baird, Minister of Environment]

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

c.c.:

The Honourable Tony Clement, P.C., M.P.
The Honourable Chuck Strahl, 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

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Minister's Response: Fisheries and Oceans Canada

17 March 2008

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

Dear Ms. Clinch,

Thank you for sharing your concerns in your November 19, 2007 Environmental Petition No. 221, submitted under the provisions of the Auditor General Act to the Commissioner of the Environment and Sustainable Development. This correspondence has been forwarded to Fisheries and Oceans Canada (DFO) for response to the concerns related to the mandate of this Department.

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 Fisheries 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 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 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 implements the pollution prevention provisions (sections 36-42) which control the deposition of any deleterious substances to water frequent by fish or affect the use by man of fish that frequent that water. Subsection 36 of the Fisheries Act is the key pollution prevention provision.

The specific questions addressed to the Minister of Fisheries and Oceans Canada in your letter of November 19, 2007 were as follows:

Question 21: Do government departments such as Fisheries and Wildlife, Natural Resources, Environment Canada have any duty to inform those involved in fisheries and wildlife of the inherent risks of water fluoridation to our ecosystem?

    Response: There is no statutorily imposed duty on the Minister of Fisheries and Oceans to inform those involved in fisheries and wildlife of the potential risks related to water quality.

    Fisheries and Oceans Canada does, however, work collaboratively with other federal departments, such as Health Canada and Environment Canada, and provincial agencies, to ensure that the public is informed of any issues related to the health of fish used for human consumption.

    Provincial fisheries agencies also issue sport fish consumption advice for various recreation species of fish based on health protection guidelines developed by Health Canada.

Question 47: Have those working with Fisheries and Oceans, Natural Resources, Environmental Agency advised those involved with fisheries of the inherent risks of water fluoridation to many species of fish and the insects upon which they feed? If not, why not?

    Response: There is no statutorily imposed duty on the Minister of Fisheries and Oceans to inform those involved in fisheries of the potential risks related to fluoridation chemicals.

    By memorandum of understanding between the Minister of Fisheries and Oceans and the Minister of the Environment, the Minister of the Environment implements the pollution prevention provisions of the Fisheries Act. Environment Canada will provide a complete response to this question in the Joint Government of Canada Response to Environmental Petition No. 221.

Question 52: How can Environment Canada, Natural Resources, Transport Canada, Fisheries and Oceans, Public Health Agency, Indian and Northern Affairs, Public Health Agency, Environmental Assessment Agency or other relevant government agencies ensure that the public and the environment will be adequately protected from an accidental spill of this product [hydrofluorosilicic acid] if Standard 60 information is not available for the NSF-certified products?

    Response: By memorandum of understanding between the Minister of Fisheries and Oceans and the Minister of the Environment, the Minister of the Environment implements the pollution prevention provisions of the Fisheries Act. Environment Canada and other departments will provide a complete response to this question in the Joint Government of Canada Response to Environmental Petition No. 221.

I appreciate the 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.

c.c.:

The Honourable Tony Clement, P.C., M.P.
The Honourable John Baird, P.C., M.P.
The Honourable Gary Lunn, P.C., M.P.
The Honourable Chuck Strahl, P.C., M.P.
Mr. Ronald C. Thompson, FCA

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Minister's Response: Indian and Northern Affairs Canada

22 January 2008

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

caclinch@gmail.com

Dear Ms. Clinch:

This is in response to the November 19, 2007 environmental petition sent to the Commissioner of the Environment and Sustainable Development, pursuant to subsection 22(3) of the Auditor General Act. The petition relates to your concerns with the additions of fluoridation chemicals to drinking water.

To my knowledge, the addition of fluoridation chemicals to drinking water is not a current practice in First Nation communities. The departmental Protocol for Safe Drinking Water in First Nations Communities, which is applicable to community water systems that serve public facilities of five or more households, does not require the addition of fluoride to drinking water. Fluoridation should therefore not be an issue in First Nation communities. You can access the Protocol at the following address: http://www.ainc-inac.gc.ca/h2o/.

Thank you for your interest in these matters.

Sincerely,

[Original signed by Chuck Strahl, Minister of Indian Affairs and Northern Development and Federal Interlocutor for Métis and Non-Status Indians]

Chuck Strahl

c.c.:

The Honourable Tony Clement, PC, MP
The Honourable John Baird, PC, MP
The Honourable Loyola Hearn, PC, MP
The Honourable Gary Lunn, PC, MP
Mr. Ronald C. Thompson, FCA

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Minister's Response: Natural Resources Canada

12 March 2008

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

Dear Ms. Clinch:

Thank you for your Petition no. 221 to the Commissioner of the Environment and Sustainable Development, regarding the Petition under the Auditor General Act to discontinue water fluoridation. My department received the petition on November 20, 2007.

Natural Resources Canada's (NRCan) technical experts have reviewed the petition with respect to my mandate as the Minister of Natural Resources Canada and have concluded that none specifically pertain to the NRCan mandate.

In response to Question 21, where NRCan is specifically named;

Question 21. Do government departments such as Fisheries and Wildlife, Natural Resources, Environment Canada have any duty to inform those involved in fisheries and wildlife of the inherent risks of water fluoridation to our ecosystem?

Response: NRCan is not involved in evaluating ecosystem risks to introduced chemicals and as such, I must rely on my colleagues from other departments to address the question.

I understand that my colleagues ,The Honourable Tony Clement, Minister of Health, The Honourable John Baird, Minister of the Environment, The Honourable Chuck Strahl, Minister of Indian Affairs and Northern Development, and The Honourable Loyola Hearn, Minister of Fisheries and Oceans, will be responding separately to questions that fall under their mandates.

Thank you for bringing your important questions to my attention.

Yours sincerely,

[Original signed by Gary Lunn, Minister of Natural Resources Canada]

The Honourable Gary Lunn, P.C., M.P.

c.c.:

Mr. Ronald C. Thompson, FCA
Interim Commissioner of the Environment and Sustainable Development

The Honourable Tony Clement, P.C., M.P.
Minister of Health

The Honourable John Baird, P.C., M.P.
Minister of the Environment

The Honourable Chuck Strahl, P.C., M.P.
Minister of Indian Affairs and Northern Development

The Honourable Loyola Hearns, P.C., M.P.
Minister of Fisheries and Oceans

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Joint Response: Environment Canada, Fisheries and Oceans Canada, Health Canada, Indian and Northern Affairs Canada, Natural Resources Canada, Transport Canada (For consultation only)

18 March 2008

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

Dear Ms. Clinch:

This is in response to your environmental petition no. 221 of November 19, 2007, addressed to Mr. Ronald Thompson, the Interim Commissioner of the Environment and Sustainable Development (CESD).

In your petition, you raised concerns regarding the addition of fluoridation chemicals to drinking water as it relates to its safety, toxicity and efficacy.

Due to the nature of the issues being raised in the petition, I am pleased to provide you with a joint Government of Canada response prepared in collaboration with my colleagues, the Minister of the Environment and the Minister of Indian and Northern Affairs. This response also includes a contribution from the Minister of Transport who provided information regarding the transportation of dangerous goods. I understand that the Minister of Fisheries and Oceans and the Minister of 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 you will find the 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

c.c. Mr. Ronald C. Thompson, Interim CESD
The Honourable John Baird, P.C., M.P.
The Honourable Chuck Strahl, P.C., M.P.
The Honourable Lawrence Cannon, P.C., M.P.


Joint Government of Canada Response to
Environmental Petition No. 221 filed by Ms. Carole Clinch
under Section 22 of the Auditor General Act
Received November 19, 2007

Petition to Discontinue Water Fluoridation

March 18, 2008

Minister of Health and the Minister for the Federal Economic
Development Initiative for Northern Ontario,
Minister of the Environment,
Minister of Indian Affairs and Northern Development
and Federal Interlocutor for Métis and Non-Status Indians, and
Transport Canada

Petition to Discontinue Water Fluoridation

The Response of the Federal Departments 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.

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.

1. The US EPA classifies hydrofluorosilicic acid as a Class 1 hazardous waste. Is hydrofluorosilicic acid a Class 1 hazardous waste or equivalent in Canada?

Health Canada Response:

The U.S. Resource Conservation and Recovery Act (RCRA) establishes a federal program to manage hazardous wastes from cradle to grave in the United States, to ensure that hazardous waste is handled in a manner that protects human health and the environment. It classifies waste in categories through a listing process. Hydrofluorosilicic acid is included in lists of commercial chemical products in a concentrated (unused) form. The RCRA focuses on ensuring the safe disposal of these waste products.

In Canada, the responsibility for managing hazardous waste rests primarily with the provinces and territories, who control the waste producers, the recycling, processing and elimination facilities, and the transportation of waste within their territory. The federal government regulates international and interprovincial movements. The main definitions for hazardous wastes in Canada are under CEPA regulations for exports and imports of hazardous wastes and hazardous recyclable materials. Fluoridation additives certified for use in drinking water are not classified as hazardous waste in Canada.

Environment Canada Response:

It is difficult to make a direct comparison between the hazardous waste classification system applied by the US Environmental Protection Agency (EPA) and Canada's, due to the differences in legal statutory authorities. Although the Canadian system for hazardous waste and hazardous recyclable material classification for international movements has recently been harmonized as far as legally possible with the lists of hazardous waste set out in the US Code of Federal Regulations, Title 40 (40CFR), discrepancies continue to exist.

In Canada, the management of hazardous waste and hazardous recyclable material is a shared responsibility between the federal government and the provinces/territories. The federal statute controls the movements of hazardous wastes and hazardous recyclable materials crossing an international border, or for movements within Canada crossing between provinces or territories. The provinces and territories have jurisdiction over the transportation of hazardous wasteand hazardous recyclable material within their respective boundaries, and the licensing and permitting of authorized facilities undertaking disposal or recycling operations, as well as licensing authorizing carriers.

Environment Canada implements and administers the Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations (EIHWHRMR) and the Interprovincial Movement of Hazardous Waste Regulations (IMHWR). The EIHWHRMR apply to movements of hazardous waste and hazardous recyclable material crossing an international border when destined for a disposal or recovery operation respectively, whereas the IMHWR apply to interprovincial movements within Canada of hazardous waste and hazardous recyclable material. The EIHWHRMR are also the means by which Canada implements its international obligations under a number of international agreements which are legally binding on the member countries. One of these international agreements is the United Nations, Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal. Canada is a Party to the Convention, however the US is not which also gives rise to a variation in the controls placed the international transboundary movements of hazardous waste and hazardous recyclable material between the two countries.

Hydrofluorosilicic acid1 (also known as fluorosilicic acid2) is identified as a dangerous good under the Transportation of Dangerous Goods Regulations and has been classified as a Class 8 corrosive substance. The Canadian federal transportation regulations are available for consultation at http://www.tc.gc.ca/tdg/clear/tofc.htm. It should be noted that this classification of the hydrofluorosilicic acid also agrees with the US Transportation rule set out in the US Code of Federal Regulations, Title 49 (49CFR).

1  Hydrofluorosilicic acid is also known as dihydrogen hexaflorosilicate, hexafluorosilicic acid, fluorosilicic acid, hydrogen hexafluorosilicate or silicofluoric acid. 

2  Fluorosilicic acid is listed as UN1778 under the Transportation of Dangerous Goods Regulations (TDGR).

The EIHWHRMR references the hazard class criteria set out in the Transportation of Dangerous Goods Regulations as a means of classifying the hazard characteristics of waste and recyclable material. Therefore, fluorosilicic acid would meet the regulatory definition for a "hazardous waste" or "hazardous recyclable material" when it is intended for a disposal or recycling operation as set out in Schedules 1 or 2 of the EIHWHRMR respectively. The actual text of the EIHWHRMR is available to the public at the following website:
http://www.ec.gc.ca/ceparegistry/documents/regs/g2-13911_r1.pdf

In the case of mixtures of waste or recyclable material, the Canadian EIHWHRMR also controls hazardous constituents under a specified leachate test with regulated limits set in the parts per million level. Fluoride is one of the hazardous constituents listed and the waste or recyclable material would be considered hazardous when the concentration of the fluoride in the leachant exceeds the regulated limit of 150.00 mg/L. The leachate test referenced in the Canadian EIHWHRMR is the US Toxicity Characteristic Leaching Procedure, SW846, Test Method 1311. In the case of fluoride, the regulated limit for leachate toxicity is based on Health Canada's drinking water quality guidelines.

2. Can Health Canada or any other government department point to any toxicology study or studies demonstrating safety of the fluorosilicate products used to fluoridate drinking water for more than 60 years? If so, would that department please provide a reference to or copy of such documented research?

Health Canada Response:

When added to water, fluorosilicate compounds readily hydrolyse completely to release fluoride ions, which means that drinking water is not a source of exposure to these compounds. As a result, the research conducted to date has focussed 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

3. Does Health Canada or any other federal government department believe that there is any legitimate government interest fulfilled by adding arsenic, lead, mercury, cadmium, barium, chromium and other contaminants which are bundled with hydrofluorosilicic acid, to our drinking water and hence our environment, in the process of water fluoridation? If so, how so?

Health Canada Response:

Health Canada strongly recommends that all products added to drinking water during its treatment and distribution be certified as meeting the appropriate NSF standard(s). This is true for all additives used for fluoridation, and means that any impurity in the additive is below levels that could pose a risk to human health. Water properly treated with these certified additives would present no health risk to the consumer from either the fluoride or any impurity.

NSF Standards are voluntary standards, which can be referenced in legislation or regulation to make them enforceable. Products are certified as meeting a specific standard. An additive that does not meet the requirements of standard 60 cannot be certified.

The standard 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. NSF International carried out tests of fluoridation additives using 10 times the maximum use level of the additive in water. The concentration of contaminants was compared to the single product acceptable concentration (SPAC), which is 10% of the Canadian guideline or the U.S. EPA Maximum Contaminant Level (based on a harmonized list of values). Limiting individual products to a contribution of 10% of the MCL for a given contaminant provides an extra margin of safety so that it is unlikely that the summation of the contributions from all potential sources will exceed the MCL at the tap. All contaminant levels, even when tested at 10 times the maximum use level, were well below the SPAC. Details on the results can be found on the NSF International website, at http://www.nsf.org/business/water_distribution/pdf/NSF_Fact_Sheet.pdf

4. Are Health Canada, Environment Canada and other government departments aware that inorganic arsenic, lead, mercury and inorganic fluorides (e.g., hydrofluorosilicic acid) are on the CEPA 2006 toxic substances list and that hydrofluorosilicic acid is not naturally present in the environment?

Health Canada Response:

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 focussed 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.

Inorganic arsenic compounds, lead and mercury have been found to be entering the environment at levels that can pose risks to both human health and the environment. An assessment report is available for arsenic, which identifies the principal anthropogenic sources of releases into the environment as base-metal and gold-production facilities. In determining whether a substance should be declared "toxic" under CEPA 1999, the likelihood and magnitude of releases into the environment and the harm it may cause to human health or ecosystems at levels occurring in the Canadian environment are taken into account.

Environment Canada Response:

The above substances indeed appear on the CEPA 1999's List of Toxic Substances. Inorganic fluorides were added as a result of a Priority Substance List (PSL) Assessment on Inorganic Fluorides conducted under the Canadian Environmental Protection Act (CEPA) [http://www.hc-sc.gc.ca/ewh-semt/pubs/contaminants/psl1-lsp1/fluorides_inorg_fluorures/index_e.html]. This assessment concluded that these substances were entering the environment in quantities or under conditions that may be harmful to the environment. This conclusion was based on scenarios involving environmental concentrations of fluoride near anthropogenic sources such as phosphate fertilizer production, chemical production, and aluminum smelting. Note that the PSL assessment did not evaluate hydrofluorosilicic acid specifically.

5. How many cases of osteosarcoma/bone cancer—the often fatal cancer associated with fluoride exposure—are reported in one year in Canada? Has Health Canada advised the Canadian Cancer Society of the increased risks for bone cancer associated with water fluoridation? If not, why not?

Public Health Agency of Canada Response:

Canadian cancer data indicates there were 299 cases of bone cancer diagnosed in Canada in 2004, the last year for which data are available. Roughly one-third of bone cancers are osteosarcomas, suggesting that there are roughly 100 cases of osteosarcoma each year in Canada, an age-adjusted rate of about 0.3 cases per 100,000 population. The rates of bone cancer have been stable since 1969 when the national cancer reporting system began.

As the rates of bone cancer have remained stable, there is no science to support an increase in risk for bone cancer associated with water fluoridation. Consequently, there has been no need to contact the Canadian Cancer Society on this issue.

6. Does Health Canada have current information regarding the incidence of dental fluorosis in Canada? If so, please provide data or source of data. If not, will Health Canada request this information from the Canadian Dental Association?

Health Canada Response:

Dental fluorosis can be classified in a number of ways. One of the most universally accepted classifications, and the one used in this document, was developed by H.T. Dean in 1942. The individual’s fluorosis score is based on the severest form of fluorosis recorded for two or more teeth. Dean’s Index is described in the table below:

Classification

Criteria—Description of enamel

Normal

Smooth, glossy, pale creamy-white translucent surface

Questionable

A few white specks or white spots

Very mild

Small opaque, paper-white areas covering less than 25% of the tooth surface

Mild

Opaque white areas covering less than 50% of the tooth surface

Moderate

All tooth surfaces affected; marked wear on biting surfaces; brown stains may be present

Severe

All tooth surfaces affected; discrete or confluent pitting; brown stain present

Questionable, very mild and mild fluorosis have no effect on tooth function and may make the tooth enamel more resistant to decay. The end-point for cosmetic concern for fluoride is considered to be moderate dental fluorosis. The actual prevalence of moderate dental fluorosis in Canada is low, and all evidence suggests that since 1996 there has been an overall decreasing trend of moderate dental fluorosis in Canada. In the United States, where the optimal level of fluoride in drinking water is between 0.7 and 1.2 mg/L, approximately 10% of dental fluorosis is attributable to water fluoridation and is in the very mild or mild fluorosis categories, neither of which would be of cosmetic concern.

7. What is the average cost to repair dental fluorosis for an individual? Will Health Canada see to it that those who are harmed by water fluoridation are appropriately reimbursed?

Health Canada Response:

There is no cost associated with questionable, very mild or mild fluorosis as these affect neither tooth function nor cosmetic aspects. As mentioned earlier, the end-point for cosmetic concern is considered to be moderate dental fluorosis. Moderate dental fluorosis would not lead to any functional or disease issues that would require dental treatment. In some but not necessarily all cases of moderate dental fluorosis an individual may decide that cosmetic treatment is necessary. 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. Due to the low occurrence of fluorosis of cosmetic concern, there is no average cost available to report.

8. Is any federal government department aware that these chemical additions are allegedly violating NSF Standard 60 and the Safe Drinking Water Act [SDWA] of Ontario and similar acts of other jurisdictions? What other provincial and territorial acts are being violated by fluoridation chemicals? Does Health Canada, environment Canada or any other federal government department have a mechanism for investigating such alleged violations?

Health Canada Response:

NSF Standards are voluntary standards, which can be referenced in legislation or regulation to make them enforceable. Products are certified as meeting a specific standard. An additive that does not meet the requirements of standard 60 cannot be certified.

Health Canada recommends that products be certified to the appropriate standards. Certification bodies, as accredited by the Standards Council of Canada, can certify drinking water materials as meeting the standards. Certification bodies control the use of the certification mark and conduct regular audits, as well as unscheduled inspections, to ensure products continue to meet requirements. The Government of Canada does not regulate these standards. However, many provinces and territories have adopted such legislation and should be contacted directly for information regarding their regulatory programs.

9. In the absence of safety studies, does any Canadian government department feel comfortable in claiming that hydrofluorosilicic acid is safe? In the absence of safety studies on the products used in water fluoridation, how do you justify your actions to promote the use of a hazardous waste product that has never been tested for safety?

Health Canada Response:

As indicated in response to question 2, fluoridated drinking water is not a source of exposure to hydrofluorosilicic acid. When added to water, fluorosilicate compounds readily hydrolyse completely to release fluoride ions, which means that drinking water is not a source of exposure to these compounds.

10. According to the Ontario Ministry of Health & Long Term Care 1999 report, 20 to 75% of individuals in fluoridated communities have dental fluorosis. 12 to 45% of individuals in 35 non-fluoridated communities have dental fluorosis. The Chief Dental Officer for Canada is quoted as saying: “Fluorosis is not caused by Water Fluoridation”. Would the CDO please explain how and why his opinion differs so much from the Ontario Ministry of Health, NRC 2006 Report, EWG 2006 and NAS Report? Will the government of Canada conduct a peer-review study to determine who is correct?

Health Canada Response:

The context of the statement attributed to Dr. Cooney 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 assessed on an individual basis.

11. According to NRC reports, ATSDR reports and other sources those who drink more than average quantities of water (e.g. kidney disease patients, diabetic patients, lactating mothers) are at risk for fluoride toxicity. The Dental Officer of Health for Halton, Ontario states: "Even if you drink a whole lot of water it's impossible to overdose if water is fluoridated at the optimal level" Oakville Beaver, April 13, 2007. Would the government of Canada conduct a peer-review study to determine who is correct?

Health Canada Response:

Health Canada recognizes the importance of protecting all Canadians from possible adverse health effect related to drinking water, including sub-groups at highest risk. Some sub-groups in the population could potentially be more susceptible to fluoride, for example people with kidney problems, osteoporosis, or poor nutrition. Similarly, some sub-populations may be exposed to a greater amount of fluoride on a daily basis, such as those working outdoors, living in hot climates, or living in proximity to fluoride-emitting facilities. This is more of a concern in the U.S., where the MCL for fluoride is established at 4 mg/L (compared to a MAC of 1.5 mg/L in Canada) and where individuals are normally expected to consume more water in response to higher temperatures.

However, as mentioned by the ATSDR 2003 report, this possible increased susceptibility to fluoride is not supported by science. Health Canada uses a population-based approach in the risk assessment process and establishes drinking water guidelines based on the sub-population likely to be most affected. The sub-population most affected by exposure to fluoride is young children aged 22-26 months old, which is also the sub-population used for establishing a drinking water guideline which is protective of all Canadians. Based on these considerations, there is no need to conduct a peer-reviewed study.

12. Is Health Canada genuinely capable of providing an estimated range of total daily water ingestion of fluoride by infants and children, by age, in all artificially fluoridated communities in Canada who use your recommended guideline of 0.8 mg/L – 1.0 mg/L? If Yes, please submit the data specific to this request and the source for the estimates. If No, please so state.

Health Canada Response:

An estimated total daily intake of inorganic fluoride by the Canadian population was published in 1993 for different age groups, comparing communities with and without fluoridated drinking water. The exposure data are presented as ranges of possible daily intake values of fluoride from all sources of exposure, to cover all communities. You can find the estimated exposure assessment for fluoride in the document at the following link:
http://www.hc-sc.gc.ca/ewh-semt/pubs/contaminants/psl1-lsp1/fluorides_inorg_fluorures/index_e.html

13. Is Health Canada genuinely capable of providing an estimate for the full range of daily water ingestion of fluoride, by consumers of fluoridated water who use your recommended guideline of 0.8 mg/L – 1.0 mg/L, including specific ranges for labourers, athletes, the excessively thirsty such as those individuals with diabetes, and those encouraged by health professionals to use water for health or detoxifying purposes? If Yes, please submit the data specific to this request and the source for the estimates. If No, please so state.

Health Canada Response:

Daily water ingestion rates would be specific to individuals within these groups. As mentioned previously, there is no science to suggest additional health concerns in these groups. Health Canada uses a population-based approach in the risk assessment process and establishes drinking water guidelines based on the sub-population likely to be most affected. The sub-population most affected by exposure to fluoride is young children aged 22-26 months old, which is also the sub-population used for establishing a drinking water guideline which is protective of all Canadians.

14. Can any Canadian or provincial government department or agency force an individual to be medicated with a substance that has not been specifically approved for the purpose it is intended, and especially approved in the manner it is administered? Does the approval of one substance, or manner of delivery, translate to an approval for another similar substance or different mode of delivery?

Health Canada Response:

The purpose of fluoridating municipal drinking water is to provide a commonly available source of fluoride. Hydrofluorosilicic acid (HFA) or any other form of fluoride used in drinking water fluoridation is a source of the mineral nutrient fluoride. Fluoride, when added at the recommended level, has been determined to provide the daily intake that is considered adequate for optimal nutrition by various health agencies.

Health Canada does not regulate fluoridation additives added to drinking water supplies because provincial and territorial governments are responsible for the safety and quality of public drinking water supplies in municipalities.

Under the Food and Drug Act, approval of a drug and its manner of delivery does not automatically translate to an approval for another similar substance or different mode of delivery. However, since fluoride used in drinking water fluoridation is not considered a drug, the approval requirements are not considered applicable.

15. Is fluoride considered to be a drug that is subject to Health Canada or any other regulation(s)?

Health Canada Response:

When fluoride is offered for sale in a final dosage form, used in large concentration and with a drug delivery system (e.g., dental rinse, toothpaste) and is labeled for therapeutic use (or makes therapeutic claims), the products are considered drugs under the Food and Drugs Act and are regulated under the Natural Health Product Regulations. Since the Natural Health Product Regulations came into force on Jaunuary 1, 2004 with a transition period till December 31, 2009, some of the products may still be regulated under the Food and Drug Regulations.

Where minerals are added or where food is fortified with a mineral (e.g., iron in cereals), the food does not become a drug. Fluoride used in drinking water fluoridation is; therefore, not a considered a drug under the Food and Drugs Act.

16. Have fluorosilicates ever been approved as a drug in Canada?

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. Information for the two homeopathics products and for the anti-fungal product can be obtained from the following links:

http://www.hc-sc.gc.ca/dhp-mps/prodpharma/databasdon/index_e.html

http://cpe0013211b4c6d-cm0014e88ee7a4.cpe.net.cable.rogers.com/dpdonline/displayInfo.do? drugCode=6L6aHfFUgEY%3D

To date, no Natural Health Products (NHP) containing fluorosilicates have been licensed for sale in Canada. Should Health Canada one day licence for sale a fluorosilicate-containing NHP, this product would bear an NPN or DIN-HM on the label.

17. Do fluorosilicates have a Drug Identification Number [DIN]?

Health Canada Response:

Yes, in the case of those fluorosilicate-containing drugs and/or NHPs that have been licensed for sale by Health Canada. Fluorosilicate-containing drugs that have received market authorization will have a DIN on the label whereas licensed fluorosilicate-containing natural health products would have an NPN or DIN-HM on the label.

18. As fluoride is not removed by simple carbon filtration, what is the estimated cost for installation and yearly maintenance for a drinking water system that adequately filters fluoride [e.g. reverse osmosis, distillation]? Please identify your source.

Health Canada Response:

Drinking water treatment systems vary in cost and complexity depending on the exact needs of the homeowner and the quality of the source water. Systems certified to reduce fluoride would also reduce the concentration of other inorganic substances and minerals, which would affect the maintenance cost for the system. Costing information would also depend on: the capacity and expected lifespan of the device and its components; any additional certified claim; type of installation; plumbing configuration for the installation; local water and electricity costs and the inclusion of service agreements.

Certified point-of-use reverse osmosis unit prices start at $200 for a portable or under-sink unit, with replacement pre-filters ranging in price from approximately $100 – $200 each. Certified point-of-use distillation units start at about $300.

19. Who should pay the cost for installation and maintenance of any fluoride removal system for a consumer identified in government scientific literature as unusually susceptible to fluoride's adverse health effects, i.e., the consumer, an entity promoting or endorsing fluoridation, the local dental society, the Canadian Dental Association, an insurance company, the water system operator, the department of health, etc?

Health Canada Response:

The use of residential-scale treatment devices on municipally treated water is generally not necessary but primarily based on individual choice. As such, any consumer wishing to remove fluoride from their drinking water would be responsible for bearing the costs of installation and maintenance of a device for this purpose.

For Canadians who rely on private wells as their source of drinking water, the quality of the water, including the installation and maintenance of any treatment system, is the responsibility of the individual.

20. Does Health Canada provide documentation of known sources of fluoride exposure in foods and beverages? If not, why not?

Health Canada Response:

From a dietary perspective, the Food Directorate has recently included fluoride as part of the chemicals to monitor within the Canadian Total Diet Study. Data on concentration of fluoride in selected foods is being generated and will be used in support of intake calculation from food of fluoride from food sources.

21. Do government departments such as Fisheries and Wildlife, Natural Resources, Environment Canada have any duty to inform those involved in fisheries and wildlife of the inherent risks of water fluoridation to our ecosystem?

Environment Canada Response:

There is no such duty incumbent on the Minister of the Environment.

It is to be noted that the ecological component of the Priority Substance List (PSL) Assessment on Inorganic Fluorides was based on three scenarios (air, water, vegetation) where environmental concentrations near anthropogenic sources were found to be comparable to levels capable of causing effects in organisms. The scenario for the aquatic environment involved concentration ranges of fluoride ion found in water bodies near anthropogenic sources such as phosphate fertilizer production, chemical production, and aluminum smelting. The extent of inorganic fluoride releases into aquatic environments from the fluoridation of municipal drinking water and the effects on aquatic life were not specifically evaluated.

22. There is ample evidence that fluoride interferes with the body’s ability to utilize essential nutrients such as calcium, magnesium, iodine, etc. via various metabolic pathways, [see NRC Canada 1977, US NRC 2006]. Is fluoride an essential nutrient? If so, please provide evidence. If not, does Health Canada or any other federal government agency have adequate grounds to justify that purported benefits of fluoridation of drinking water should outweigh and compromise the good nutrition of our citizens?

Health Canada Response:

Evidence shows that fluoride competes with some ions (e.g., calcium) in the metabolism of teeth and bone formation. This is the same process that provides beneficial effects to prevent tooth decay. Health Canada does not consider fluoride as an essential nutrient. However, fluoride is considered to have a beneficial effect in humans to reduce dental caries. The Institute of Medicine (IOM) in United States established an adequate intake (AI) for fluoride based on maximal dental caries reduction without unwanted side effects. By definition, an AI is an average nutrient intake that appears to be sufficient to sustain a defined nutritional state in a specified population.

23. Does Health Canada believe that statements of endorsement for the public policy of fluoridation also are endorsements for use of the products actually used for water fluoridation?

Health Canada Response:

Health Canada and its Chief Dental Officer have endorsed drinking water fluoridation as a public health measure to protect and maintain dental health, and reduce tooth decay. Health Canada does not endorse specific products or chemicals, but recommends that any product used in the treatment or distribution of drinking water be certified to the appropriate standard by an accredited certification body. See responses to questions 3 and 8 for additional information regarding the certification process.

24. Derivation of the Maximum Allowable Contaminant levels [MACs] is based largely on the level of carcinogenicity assigned to a toxic substance; 1) carcinogenic; 2) probably carcinogenic; 3) possibly carcinogenic; 4) probably not carcinogenic. What classification was given to fluoride? Why?

Health Canada Response:

The approach used in the establishment of a Maximum Acceptable Concentration is dependent upon the carcinogenicity classification of the substance under evaluation. A cancer approach would be used for any chemical contaminant which is classified as a human carcinogen or as a probable human carcinogen, based on the results of both epidemiological and toxicological studies.

In the case of fluoride, there are major limitations in human studies conducted to date, which prevents the interpretation of carcinogenicity of fluoride. Data from animal studies are also inadequate to allow an evaluation of carcinogenicity. There is an important body of scientific studies, which fails to show a causal link between exposure to fluoride in drinking water and cancer.

The criteria used for classification of carcinogenicity can be found at: http://www.hc-sc.gc.ca/ewh-semt/pubs/contaminants/existsub/approach/index_e.html
Based on these criteria, and using the available scientific information, fluoride is classified in Group VI—Unclassifiable with respect to carcinogenicity in humans. This corresponds to the International Agency for Research on Cancer (IARC) classification which classifies fluorides (inorganic, used in drinking-water) in Group 3: Not classifiable as to its carcinogenicity to humans.

25. Is Health Canada aware of the following quote by a report by the Ontario Ministry of Health & Long Term Care 1999: "Efforts are required to reduce (fluoride) intake among the most vulnerable age groups, children aged 7 months to 4 years..."? Does Health Canada have evidence that their initiative to reduce the recommended guideline from 1.0-1.2 mg/L to 0.8-1.0 mg/L in 1999 has significantly reduced fluoride exposures in vulnerable populations and significantly reduced associated health risks, such as bone cancer [especially in young men between the ages of 6-20], dental fluorosis [“mottled teeth”], thyroid suppression, etc? Please provide references.

Health Canada Response:

Health Canada is aware of this report, which was prepared by a consultant for the Ontario Ministry of Health and represents the opinion of the author. Health Canada had established an optimal range of 1.0 – 1.2 mg/L in 1978, which was reduced to 0.8 – 1.0 mg/L in 1996. According to the Findings and Recommendations of the 2007 Expert Panel Meeting, the actual prevalence of moderate dental fluorosis in Canada is low, and all evidence suggests that since 1996, there has been an overall decreasing trend of dental fluorosis in Canada. Furthermore, the weight of scientific credible evidence does not support a link between exposure to fluoride in drinking water and cancer or thyroid suppression.

26. Does Health Canada acknowledge that timing of the fluoride exposure, and vulnerability of the child to fluoride exposure are important in fluoride toxicity?

Health Canada Response:

The timing, level and length of exposure to fluoride are important factors to take into account when assessing the health effects of fluoride. As mentioned previously, Health Canada uses a population-based approach in risk assessment and therefore establishes drinking water guidelines based on the sub-population likely to be most affected. The sub-population most affected by exposure to fluoride is young children aged 22-26 months old, which is also the sub-population used for establishing a drinking water guideline which is protective of all Canadians.

27. In regard to the statement made by Health Canada; “There are no studies indicating an association between fluoridated water in reconstituted infant formula and moderate or severe dental fluorosis”, is anyone at Health Canada aware of the 56 studies demonstrating an association between the use of fluoridated water use in reconstituted infant formula and the risk of dental fluorosis of varying severity? If not, why not?

Health Canada Response:

Only a few of the 33 individual studies cited above found an association between greater use of infant formula reconstituted with fluoridated water and a greater prevalence of dental fluorosis (please note that 28 of the provided studies were duplicates). However, none of these studies examined a link between exposure to infant formula reconstituted with fluoridated water and moderate and severe forms of dental fluorosis. Consequently, the references provided do not alter Health Canada’s statement cited above.

28. Is Health Canada aware that the American Dental Association, The Academy of Dentistry, the Center for Disease Control have all issued advisories on their websites in letters, recommending that parents should not give children under the age of 1 year fluoridated water mixed with infant formula? Not all parents have computers or visit these particular websites. The concerns of fluoridated water and fluoridated toothpaste mentioned in the September 20, 2000 letter from the Ontario Ministry of Health has not been conveyed to the general public. Is it the intent of Health Canada to inform parents in Canada of these concerns? If not, why not?

Health Canada Response:

Health Canada is aware of the current advisories made in the U.S. regarding infant formulas reconstituted with fluoridated drinking water and recognizes the importance of protecting infants from possible adverse effects from fluoride. Health Canada is also aware that these advisories reflect potential exposure levels in the U.S. that are much higher than Canadian levels.

Health Canada communicates with the public and public health professionals through web publications and by working directly with the provinces and territories in this area. However, there is no evidence to support a link between the exposure to infant formula reconstituted with drinking water at the Maximum Acceptable Concentration (MAC) for fluoride in Canada and moderate and severe forms of dental fluorosis in the population. The incidence of dental fluorosis is best correlated with the total cumulative fluoride exposure to the developing dentition. According to the Findings and Recommendations of the Expert Panel Meeting recently held in Canada (to be published on Health Canada’s website), an increased risk of dental fluorosis would be associated with extended periods (e.g., multiple years) of exposure to excessive amounts of fluoride, and a higher exposure in the first year of life may not be as much of a concern if it is followed by low exposure.

29. With the publication of the NRC 2006 Report, and evidence contained therein that endocrine systems and thyroid functions are impaired at exposure levels to fluoride below the consumption levels expected from drinking “optimally fluoridated water”, what does Health Canada or any other federal department, plan to do to inform the consumer of such risks to their health?

Health Canada Response:

Scientific reviews conducted by a number of international agencies are in agreement that the science is inadequate to support a link between the exposure of fluoride in drinking water and an adverse effect on thyroid function. The regulation of thyroid function is dependent upon a wide range of factors, which means that results from epidemiological studies need to be considered cautiously in order to assess the link between any environmental chemical and adaptative response or even potential adverse health effects on the thyroid function. Current science does not indicate a causal relationship at or below the currently established Maximum Acceptable Concentration for fluoride in drinking water of 1.5 mg/L.

30. Is Health Canada aware that the US NRC 2006 Review states that 0.7 mg/day with a 75 kg individual, of ingested fluoride, when iodine insufficient, may cause thyroid suppression? If so, why is Health Canada permitting the additions of an inorganic fluoride such as hydrofluorosilicic acid in our drinking water, which account for most of our total fluoride consumption? What does Health Canada intend to do to protect the population from iodine deficiency and fluoride over-exposure, which in combination, apparently leads to increasing numbers of people with thyroid insufficiency?

Health Canada Response:

Scientific reviews conducted by a number of international agencies are in agreement that the science is inadequate to support a link between the exposure of fluoride in drinking water and an adverse effect on thyroid function. As stated in the U.S. NRC 2006 review, it is difficult to predict the effects fluoride may have on thyroid function, at which concentrations, and under what circumstances. Health Canada’s population-based approach to establish drinking water guidelines based on the sub-population likely to be most affected (young children aged 22-26 months old) remains most protective of all Canadians.

31. Is Health Canada aware that doctors in Europe from 1930-1970 used fluoride to suppress thyroid function?

Health Canada Response:

Historical medical strategies are only relevant today if they have been supported by credible peer-reviewed studies. Health Canada has reviewed the available information regarding the potential effects of fluoride on thyroid function and found that current science does not show a causal relationship between exposure to fluoride and thyroid function.

32. Is Health Canada aware that ethnicity also seems to be important in regards to toxicity of fluoride exposure? E.g. Moderate to severe dental fluorosis is found in many black and aboriginal children whose cumulative dose from fluoridated water and foods processed in fluoridated water is identical to poor white children with milder cases of fluorosis.

Health Canada Response:

At optimal levels, water fluoridation is not correlated to moderate or severe fluorosis (according to Dean’s Index) for any segment of the population. Severe fluorosis rarely occurs in Canada, but may be found in certain immigrant populations that have been exposed to very high levels of fluoride before they arrived in Canada. However, there are no scientific peer-reviewed studies available to determine whether ethnicity could play a role in the effects of fluoride.

33. The protection of minorities is enshrined in the Canadian Charter of Rights and Freedoms, section 15, Equality Rights. Do Health Canada and relevant government agencies have an obligation to protect these minorities with regard to fluoridation of drinking water and the dispersal?

Health Canada Response:

As mentioned earlier, there are no scientific peer-reviewed studies available to determine whether ethnicity could play a role in the effects of fluoride. Health Canada’s population-based approach to establish drinking water guidelines based on the sub-population likely to be most affected (young children aged 22-26 months old) remains most protective of all Canadians.

34. In regard to the statement made by Health Canada: “Possible higher exposure in the first year would be mitigated by lower exposures in the subsequent two years of life.” According to the NRC 2006 Report, p21, dental fluorosis cannot be reversed by lowering the intake of fluoride after the exposure; "The condition is permanent after it develops in children during tooth formation, a period ranging from birth until about the age of 8.". Would Health Canada please explain how and why they differ from the evidence of the NRC 2006 report? Please provide peer-reviewed scientific evidence of this claim.

Health Canada Response:

Health Canada agrees that dental fluorosis is a permanent condition that develops in children during tooth formation, which does not contradict our statement. The incidence of dental fluorosis is best correlated with the total cumulative fluoride exposure to the developing dentition, particularly with a fluoride intake that is elevated for all of the first 3 years of life. Fluoride intake (in mg/kg-body weight) declines substantially after 6 months of age and remains steady thereafter. The risk of dental fluorosis in permanent teeth is therefore smaller, because permanent teeth start forming after this higher exposure level. In addition, extended periods (e.g., multiple years) of exposure to fluoride would be associated with an increased risk of dental fluorosis, and a higher exposure in the first year of life is less of a concern if it is followed by low exposure.

35. In regard to the statement made by Health Canada: “Fluoride must still meet standards of purity and quality before it is used in drinking water treatment,” This product is bundled with many toxic substances such as arsenic, lead, cadmium, mercury, etc. Does this product meet Health Canada’s standard for purity and quality? If so, how so? If not, why does Health Canada make this claim?

Health Canada Response:

As stated in our response to question 3, Health Canada strongly recommends that all products added to drinking water during its treatment and distribution be certified as meeting the appropriate standard(s). This is true for all additives used for fluoridation, and means that any impurity in the additive is below levels that could pose a risk to human health. Water properly treated with these certified additives would present no health risk to the consumer from either the fluoride or any impurity. Most the provinces and territories require that additives such as fluoride meet NSF Standard 60. The standard 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 you have mentioned.

NSF International carried out tests of fluoridation additives using 10 times the maximum use level. The concentration of contaminants was compared to the single product acceptable concentration (SPAC), which is 10% of the Canadian guideline or the U.S. EPA Maximum Contaminant Level (based on a harmonized list of values). Limiting individual products to a contribution of 10% of the MCL for a given contaminant provides an extra margin of safety so that it is unlikely that the summation of the contributions from all potential sources will exceed the MCL at the tap. All contaminant levels, even when tested at 10 times the maximum use level, were well below the SPAC. Details on the results can be found on the NSF International website, at http://www.nsf.org/business/water_distribution/pdf/NSF_Fact_Sheet.pdf

36. In regard to the statement made by Health Canada on their website: “Public water fluoridation has been ranked one of the top ten public health measures of the twentieth century by the World Health Organization”; Will Health Canada provide the WHO documentation to support the above statement? If not, why does Health Canada use this quote on their website?

Health Canada Response:

This statement is not found on Health Canada’s website. Nevertheless, the WHO and many other public health organizations support fluoridation as a public health measure to protect dental health.

37. Will the Government of Canada commit to establishing long-term health based objectives for drinking water contaminants, similar to the Maximum Contaminant Level Goals (MCLGs) established by the U.S. Environmental Protection Agency? If not, why not?

Health Canada Response:

The guideline development process already addresses this issue. Guideline Technical Documents include the calculation of the “health-based value”, which is based solely on health considerations. The Maximum Acceptable Concentration is normally established at this value, unless the Federal-Provincial-Territorial Committee on Drinking Water has identified a need to risk manage the guideline to take into account limitations, usually analytical methods or treatment technology. This health-based value is similar to the U.S. EPA Maximum Contaminant Level Goals (MCLG).

38. Will Health Canada immediately prohibit any dental association, medical association or public health organization from promoting water fluoridation until a parliamentary committee has had a chance to review the accumulated peer-reviewed evidence which documents the public health concerns, environmental concerns, ethical concerns and legal concerns associated with water fluoridation? If not, why not?

Health Canada Response:

Current science would not support such action. The effects of fluoride to prevent and reduce tooth decay are well documented around the world. The decision on whether or not to fluoridate a drinking water supply is made by the province and the municipality affected. Health Canada does not participate in this decision.

39. Will the Department of Justice and the Public Accounts Office please investigate these potential legal violations and their implications to taxpayers, of NSF Standard 60, the Safe Drinking Water Act, the Fisheries Act and other relevant government legislation? If not, why not?

Health Canada Response:

On basis of the information provided, there does not appear to be grounds on which to conduct the requested investigation. To Health Canada's knowledge, there has been no violation of federal statutes in regard to the fluoridation of drinking water. The Government of Canada is not responsible for the enforcement and compliance of provincial legislation.

40. Information on drinking water fluoridation

Health Canada Response:

Drinking water fluoridation is still considered to be a safe and effective public health method to reduce the prevalence of dental caries in the population, as supported by many International Organizations (e.g., World Health Organization, Australian Government, U.S. Centers for Disease Control and Prevention, American Dental Association, Canadian Dental Association, British Dental Association, Institute of Medicine, etc.). As Health Canada uses a population-based approach in the risk assessment process, drinking water guidelines are based upon the sub-population of greatest risk and are therefore protective of all Canadians.

41. Will Health Canada organize immediately a public education campaign to offset the misconceptions the public has about the safety and efficacy of fluoride, when ingested, at recommended doses in drinking water?

Health Canada Response:

In Canada, the provinces and territories have primary responsibility regarding the provision of drinking water. Health Canada’s role is mostly in the area of scientific leadership and coordination and as such already provides information regarding fluorides and human health to the public through its website.

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 are generally responsible for the safety of drinking water. In collaboration with their municipalities, they decide whether or not to fluoridate and the amount of fluoride to be added. Hence Health Canada will not organize a public education campaign on water fluoridation.

42. Will Health Canada inform the public, dental and public health officials of the correct mode of action of fluoride; purported benefits are topical [applied directly to the surfaces of the teeth], not systemic [swallowed]? If not, why not?

Health Canada Response:

There are beneficial effects of fluoride from both topical and systemic exposures. The maximum reduction in dental decay is achieved when fluoride is available preeruptively (systemically) for incorporation during all stages of tooth formation and posteruptively (topically) at the tooth surface. Water fluoridation provides both types of exposure. Health Canada is informing the public and public health professionals through web publications and by working directly with the provinces and territories in this area.

43. Has Health Canada advised parents of young children [especially under the age of one] explicitly not to use fluoridated drinking water? If not, why not?

Health Canada Response:

The incidence of dental fluorosis is best correlated with the total cumulative fluoride exposure to the developing dentition. According to the Findings and Recommendations of the Expert Panel Meeting recently held in Canada (to be published on Health Canada’s website), an increased risk of dental fluorosis would be associated with extended periods (e.g., multiple years) of exposure to excessive amounts of fluoride, and a higher exposure in the first year of life may not be as much of a concern if it is followed by low exposure.

Water that is optimally fluoridated does not pose a problem with respect to moderate fluorosis for any age group and does not create a need to advise parents of a health concern. Rather, it is the use of fluoride supplements and the ingestion of fluoridated toothpaste during the critical ages that is of concern. As a result, Health Canada is recommending the following steps to minimize exposure in small children:

  • Never give fluoridated mouthwash or mouth rinses to children under six years of age, as they may swallow it
  • Talk to your dentist before using fluoridated mouthwash.
  • Health Canada does not recommend the use of fluoride supplements (drops or tablets). This guideline is consistent with recommendations made by Health Canada's First Nations and Inuit Health Branch (FNIHB) and the Canadian Association of Public Health Dentistry (CAPHD).
  • Make sure that your children use no more than a pea-sized amount of toothpaste on their toothbrush, and teach them not to swallow toothpaste. Children under six years of age should be supervised while brushing, and children under the age of three should have their teeth brushed by an adult without using any toothpaste.

44. Has Health Canada advised those who are unable to adequately filter fluoride of their higher risks associated with water fluoridation [e.g., young children, elderly, kidney patients, diabetic patients, Walkerton, Ontario residents with impaired kidney function]? If not, why not?

Health Canada Response:

Health Canada uses a population-based approach in the risk assessment process; drinking water guidelines are developed to be protective of the sub-population at greatest risk and are therefore protective of all Canadians. There are very limited data to support or refute an increased susceptibility to fluoride in any sub-population other than small children. There are no data to suggest that exposure to fluoride at typical levels found in drinking water (e.g., at the maximum acceptable concentration of 1.5 mg/L) would result in adverse effects in these potentially susceptible sub-populations.

The issue of filtering water for individuals requiring dialysis applies to many minerals and not specifically to fluoride. Dialysis teams who support such individuals are already aware of the need for mineral removal from water used for dialysis.

45. Has Health Canada advised those who drink larger than normal quantities of water [e.g. athletes, lactating mothers, soldiers, diabetic patients] of the higher risks associated with water fluoridation? If not, why not?

Health Canada Response:

As mentioned previously, Health Canada uses a population-based approach in risk assessment and therefore establishes drinking water guidelines based on the sub-population likely to be most affected. The sub-population most affected by exposure to fluoride is young children aged 22-26 months old, which is also the sub-population used for establishing a drinking water guideline which is protective of all Canadians. There are no data to suggest that exposure to fluoride at typical levels found in drinking water (e.g., at the maximum acceptable concentration of 1.5 mg/L) would result in adverse effects for those consuming larger quantities of drinking water.

46. Has Health Canada advised those with poor nutrition [e.g., calcium, magnesium, iodine, selenium] of their higher risks associated with water fluoridation [see ATSDR, NRC Canada 2007, NRC 2007]? If not, why not?

Health Canada Response:

As mentioned previously, Health Canada uses a population-based approach in risk assessment and therefore establishes drinking water guidelines based on the sub-population likely to be most affected. The sub-population most affected by exposure to fluoride is young children aged 22-26 months old, which is also the sub-population used for establishing a drinking water guideline which is protective of all Canadians. Any potential health risk from fluoridation in Canada would be much lower than the risks associated with poor nutrition.

47. Have those working with Fisheries and Oceans, Natural Resources, Environmental Agency advised those involved with fisheries of the inherent risks of water fluoridation to many species of fish and the insects upon which they feed? If not, why not?

Environment Canada Response

By memorandum of understanding between the Minister of Fisheries and Oceans and the Minister of the Environment, the Minister of the Environment implements the pollution prevention provisions of the Fisheries Act (sections 36, 38, 40). The Minister of the Environment does not have a statutory duty to inform the fisheries industry or the public of the use of fluoridation chemicals (or other substances) under these sections of the Fisheries Act. There are also no provisions that require the Minister of the Environment to inform fish farms and fisheries regarding known harmful substances in water under the Canadian Environmental Protection Act, 1999, and other wildlife legislation that deals with fish, such as the Canada Wildlife Act and the Species at Risk Act.

48. Will the Government of Canada commit to starting national bio-monitoring studies to regularly identify and track the exposure of Canadians to fluoride by testing blood, urine, saliva, etc.? If not, why not?

Health Canada Response:

The Government of Canada's Chemical Management Plan has committed to conducting national biomonitoring studies to monitor Canadians' exposures to environmental chemicals. Statistics Canada, in partnership with Health Canada and the Public Health Agency of Canada, is conducting the Canadian Health Measures Survey (CHMS) between March 2007 and Winter 2009. Through personal interviews and the collection of physical and chemical measurements from 5,000 Canadians aged 6 to 79 years, the CHMS will provide nationally representative data on indicators of environmental exposure (i.e. biomonitoring), chronic diseases, infectious diseases, fitness and nutritional status, as well as risk factors and protective characteristics related to these areas. Blood and urine specimens will be collected in a mobile clinic and analysed for a number of different classes of substances including; metals, phthalates, polychlorinated biphenyls (PCBs), brominated flame retardants, perfluorinated compounds, organochlorine pesticides and pyrythroid pesticides, organophosphate insecticide and phenoxy herbicide metabolites.

Fluoride measurements are not included in the current CHMS as it was not identified as a priority measurement in the consultations undertaken as part of the development of the survey.

49. Would Health Canada enhance their website to include pictures of dental fluorosis so that the population and dentists can better identify this health concern?

Health Canada Response:

Dentists and other health professionals have access to scientific and medical documents to identify issues such as moderate to several dental fluorosis. As with any medical condition, moderate to severe dental fluorosis should be identified by trained professionals and not by the general public.

50. Will Health Canada instruct the manufacturers of fluoridated toothpaste and mouthwash to put warning labels similar to the FDA warnings in the USA?

Health Canada Response:

When fluoride is used in large concentration and with a drug delivery system (e.g. dental rinse, toothpaste), the products are considered drugs under the Food and Drugs Act and are regulated under the Natural Health Product Regulations. Since the Natural Health Product Regulations came into force on January 1, 2004 with a transition period till December 31, 2009, some of the products may still be regulated under the Food and Drug Regulations. Under these regulations, a warning is required on the labels of fluoridated toothpastes and mouthwashes sold in Canada. The warning is established in Health Canada's "Fluoride-Containing Anti-Caries Products Monograph", which states that the labels of fluoride containing mouthwashes and toothpastes must carry the following cautionary statement: "If more than used for brushing is accidentally swallowed, get medical help or contact a Poison Control Centre right away".

51. 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 Stan Hazan 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 Stan Hazan during the same deposition to the Superior Court of California for the District of San Diego (March 9, 2004). NSF assesses the toxicity of chemicals using available toxicity information and the protocol under Annex A which outlines the toxicology data requirements. These requirements are generally met when there is a MAC or MCL established by the relevant agency. The requirement under section 3.2.1 of Standard 60 is to provide published and unpublished toxicology studies when available. The toxicity assessment is done on the chemical form that it is found in drinking water. Because fluorosilicate compounds readily hydrolyses completely to release fluoride ions, NSF’s assessment is based on the toxicology of inorganic fluoride.

52. How can Environment Canada, Natural Resources, Transport Canada, Fisheries and Oceans, Public Health Agency, Indian and Northern Affairs, Public Health Agency, Environmental Assessment Agency or other relevant government agencies ensure that the public and the environment will be adequately protected from an accidental spill of this product [hydrofluorosilicic acid] if Standard 60 information is not available for the NSF-certified products?

And

53. How can emergency response workers be protected from potential accidents if the content of these products is not fully disclosed?

Health Canada Response:

NSF Standards are designed to ensure the safety of products within acceptable concentrations in drinking water. They do not address concerns related to accidental spills or occupational exposures. Other mechanisms exist for such situations, including the Hazardous Products Act, Part 2, which requires a Materials Safety Data Sheet to be made available by the manufacturer, and requirements under the Transportation of Dangerous Goods Act and regulations.

Public Health Agency of Canada Response:

The issues are the responsibility of provincial and territorial governments.

Environment Canada Response:

Currently, Environment Canada does not regulate hydrofluorosilicic acid under the Environmental Emergency Regulations nor does it have any plans to do so in the near future. These regulations under CEPA 1999 require emergency plans to be prepared and implemented for listed substances at or above specified threshold quantities.

Transport Canada Response:

In Canada, transportation of dangerous goods is strictly regulated under the Transportation of Dangerous Goods Act, 1992. The Act promotes public safety during the transportation of dangerous goods. Transport Canada's TDG program is based on the premise that dangerous goods must be properly classified and transported in a proper means of containment. Proper containment, along with proper safety markings and shipping documents, amongst other requirements, are crucial elements in the safe transportation of dangerous goods. A person in Canada who is handling, offering for transport, transporting or importing a dangerous good must follow the TDG Act and its regulations. Transport Canada conducts inspections to verify compliance with the Act and its regulations. Should a person fail to comply, then enforcement action can be taken. As the TDG Act is criminal law, the enforcement action could lead to an offence punishable on summary conviction and liable to a fine not exceeding fifty thousand dollars for a first offence, and not exceeding one hundred thousand dollars for each subsequent offence. Or the enforcement action could lead to an indictable offence and liable to imprisonment for a term not exceeding two years.