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Impact of fluorosilicate compounds on lead levels in drinking water and on water distribution infrastructure

Petition: No. 245

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

Petitioner(s): Environmental Training Institute

Date Received: 2 May 2008

Status: Completed

Summary: The petitioner seeks responses from several departments on potential health concerns related to increased levels of lead in drinking water due to fluoridation. In addition, the petitioner alleges that fluorosilicates have a detrimental effect on water distribution infrastructure and asks whether the government has carried out related cost assessments.

Federal Departments Responsible for Reply: Environment Canada, Department of Finance Canada, Fisheries and Oceans Canada, Health Canada, Public Health Agency of Canada, Public Works and Government Services Canada, Treasury Board of Canada Secretariat

Petition

Petition under Section 22 of the Auditor General Act for the discontinuation of the addition of toxic substances to our drinking water (inorganic fluorides, inorganic arsenic, lead)
In violation of the Fisheries Act, section 34(1), which describe the provisions to conserve and protect fish habitat that sustain Canada’s fisheries resources, the harmful alteration, section 35(1), which prohibits the harmful alteration, disruption or destruction (HADD) of fish habitat, and sections 36-42 which control the deposition of any deleterious substance to water frequented by fish

Fluorosilicate Compounds Increase Drinking Water Lead Levels,
Hence Source Water Contamination.

[Original signed by Peter L.D. Van Caulart]

Peter L.D. Van Caulart, Dip. A.Ed., CES, CEI
VP & Director Environmental Training Institute
273 Canboro Rd. RR1 Ridgeville, ON L0S 1M0
etivc@iaw.on.ca
(905) 892-1177 Phone /Fax

Office of the Auditor General of Canada
Commissioner of the Environment and Sustainable Development
Attention: Petitions
240 Sparks Street
Ottawa, Ontario K1A 0G6

Toll free:           1-888-761-5953 (toll free)
Telephone:        613-995-3708
Fax:                 613-941-8286
Email:               petitions@oag-bvg.gc.ca


Introduction

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

Evidence from the study by Daemker and Dey 1989 indicates that some species of fish (salmon) are harmed at levels of about 0.25mg/L.10 Other studies that indicate that fluoride at levels below 1.5 ppm have lethal and other adverse effects on fish. Delayed hatching of rainbow trout have occurred at 1.5 ppm;11 brown mussels have died at 1.4 ppm;12 an alga (Porphyria tenera) was killed by a four-hour fumigation with fluoride with a critical concentration of 0.9 ppm;13 and, levels below 0.1 ppm were shown to be lethal to the water flea, Daphnia magna.14 These latter two studies suggest that salmon species also may be affected by fluoride-induced reduction of food supply.

Documents used in a 1961 court case involving Meader's Trout farm in Pocatello, Idaho,15 contain evidence that between 1949 and 1950 trout damage and loss was related to fluoride contamination due to rain washing airborne particles from leaves into hatchery water at levels as low as 0.5 ppm.

Because, in soft waters with low ionic content, a fluoride concentration as low as 0.5mg/L can adversely affect invertebrates and fishes, safe levels below this fluoride concentration are recommended in order to protect freshwater animals from fluoride pollution.16

Such demonstrated harm of aquatic species is in violation of the Fisheries Act. The addition of toxic substances (Na2SiF6 and H2SiF6 and co-contaminants arsenic, lead, mercury etc.) into our drinking water, hence source water is harmful and not sustainable.

Fluorosilicates Increase Blood Lead Levels

The actual products used in 90% of artificial water fluoridation sites are fluorosilicates that are derived from the phosphate mining industry. These products (Na2SiF6, H2SiF6) contain trace amounts of arsenic, lead and other contaminants. The direct and indirect contribution of the drinking water contaminant lead from fluorosilicates and their contribution to independent health effects are assessed below.

Direct additive: Lead is the second most common co-contaminant with the silicofluorides used in water fluoridation; “The second most common contaminant found...” (NSF Fluoride Fact Sheet on Fluoridation Chemicals)

Indirect additive: “A contaminant that is extracted into drinking water through contact with surfaces of materials or products used for drinking water treatment, storage, transmission, or distribution.” (NSF/ANSI Standard 60 2.10, P 3)

A growing body of research suggests that the practice of fluoridation may double the exposure of lead in our children from drinking water in two important ways:

  1. Direct additive: Lead is the second most common contaminant found in the silicofluoride products used in >95% of water fluoridation facilities in the US.
  2. Indirect additive: Lead is now known to leach from lead pipes, lead solder and leaded brass by mechanical and chemical interactions of fluorosilicates and/or chloramine (see below).

The University of North Carolina Environmental Quality Institute (EQI) has found that lead-bearing brass plumbing in the absence of any other source such as lead pipes is corroded by SiF treated water to such an extent that it should be considered as a serious source of ingested lead. (Contact [name withheld], Intellequity Technology Services; [information withheld])

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 blood4,5 was previously demonstrated.

   Blood lead data for twin boys born in 2000.
“After the levels were found to be higher than CDC’s [Centers for Disease Control] level of concern, DOH [department of health] inspected their home for lead paint and found only a remote exterior door as an admittedly unlikely source. However, painting the door failed to bring down the boys’ blood lead levels. But when they stopped drinking tap water and it was no longer used in cooking their meals, the boys’ blood lead levels declined rapidly.”8
 

Sodium Fluoride Silicofluorides

Silicofluorides were substituted for sodium fluoride in 1947 and endorsed in 1950 by the US Public Health Service without prior animal testing because rats teeth got as much fluoride as from sodium fluoride, and a community could save 4 cents per year per resident (McClure, 1950).1

Chlorine Chloramine

A switch from chlorine to chloramine [ammonia + chlorine] was recently recommended and adopted in some water systems for several reasons:1

  • Chloramine is cheaper than other disinfection methods
  • Easy to add ammonium to already-chlorinated water
  • Chloramine produced fewer disinfection by-products [DBPs] than chlorine

Fluorosilicates &/or Chloramine + Lead or Leaded Brass = Increased Blood Levels

Two new studies1-3 demonstrate 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. There are several chemical reasons;3

  1. fluosilicic acid, the most widely used fluoridating agent, is a good solvent for lead.
  2. chlorine, ammonia, and chloramine are all hostile to copper in that they induce copper stress cracking and/or can dissolve it.
  3. ammonia added to chlorine to produce chloramine will also react with fluosilicic acid to produce ammonium fluosilicate, an established solvent for copper alloys/brass.

Besides these chemical factors, the lead in brass is present as nodules, so that any attack on the copper matrix of brass would make lead particles readily accessible for mobilization.3

Drinking Water is an important source of increased lead. Increased blood levels were found in homes without lead service lines or lead soldered copper piping. The only possible lead source had to be leaded-brass plumbing and/or brass faucets.

Silicofluoride use is associated with 2 neurotoxic effects:1

  1. Prevalence of children with elevated blood lead (PbB>10µg/dL) is about double that in non-fluoridated communities;
  2. Voluntary and involuntary muscle action is stimulated by acetylcholine (ACh) that is cleaved by the enzyme acetylcholinesterase (AChE) to end the stimulation. Without AChE, muscle excitation would persist as spasm with potentially lethal effect, as caused by a nerve gas. Acetylcholine modulated by acetylcholinesterase also induces saliva flow. Intense salivation is a symptom of fluoride poisoning. Silicofluorides inhibit AChE.

“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.”

One new study reports:3 “Over the first test week with chlorine flushing, lead concentrations nearly doubled [from 100ppb to nearly 200ppb]. When fluorosilicic acid was added, lead concentrations spiked from 100ppb to over 900ppb. Lead concentrations from the chlorine-based waters appeared to be decreasing over the study period. Lead concentrations seemed to be increasing with the chlorine + ammonia + fluorosilicic acid combination.”

Moss et al 19996 indicate that elevated blood lead levels may lead to increased cavities.

The quote below is from the following document:

Silicofluorides Should Not Be Added to Municipal Water Without Safety Testing Adequate to Protect Children and Other Vulnerable Populations Resolution Submitted to American Public Health Association by Myron Coplan, P.E. & Dr. Robert Carton, Ph.D. 2001.

 “Considering that data on 400,000 children in New York, Massachusetts, and in the NHANES III (National Health and Nutrition Examination Survey III) study, found that where local water is fluoridated with SiF’s the prevalence of children with venous blood lead exceeding 10mcg/dL was significantly higher than in non-fluoridated areas with risk ratios of between 2.0 and 4.0 (p<0.001) controlling for race, housing age, poverty, congestion, and parental education);40, 41and

Recognizing that blood lead is believed responsible for adverse effects inflicted in utero such as impaired immune capacity,42 brain damage and developmental problems,43, 44, 45 as well as in early childhood,46, 47, 48, 49, 50, 51 and into puberty/adolescence as impaired cognition and impulse control,52, 53 and adulthood as nephropathy and hypertension,54, 55 and into geriatric life;56

“The atomic weight of lead being about ten times that of fluorine, for each ppm of silicon bound fluorine, 10 ppm of lead would be mobilized.”1

Enzyme inhibition by SiF was also the subject of a German PhD thesis that focused on inhibiting acetylcholinesterase (AChE). AChE plays a vital role in proper functioning of cholinergic neural systems responsible for both voluntary and involuntary muscular processes. For instance, AChE quenches acetylcholine (ACh) activity after it has transmitted excitatory signals across a synaptic gap to a muscle end-plate. Without that quenching, muscle excitation would be prolonged, a spasm would occur that can be fatal...a shorthand description of how nerve gas works.17

Apart from direct adverse health problem from ingested SiF’s, it should be noted that SiF treated water is a potential source of low-level internal radiation from contaminating radionuclides as a possible cause of osteosarcoma.

COSTS OF FLUOROSILICATES TO WATER DISTRIBUTION INFRASTRUCTURE

Fluorosilicates shortens lifetime of water distribution infrastructure. Fluoride is the most corrosive of all known elements. (Merck Index) Fluorosilicates cause the following problems:

  1. leach lead from brass/copper fittings (Coplan 2007, Maas 2007, Masters 1999, 2000, NRC 2006 Report on Fluorides in Drinking Water)
  2. leach lead from lead pipes and lead solder - cast iron (CI), ductile iron (DI) piping
  3. antagonistic to the Asbestos Cement pipe matrix used in transmission watermains, hastening decay of this important infrastructure. (IAOMT p24)
  4. corrodes stainless steel, nickel, ceramic and glass.
  5. acidifies water, creating a need for neutralizing agents such as lime to increase pH and restore lost alkalinity.

Quicklime is calcium oxide (CaO) and is made by heating limestone. It's the cheapest form of lime. To use quicklime it must be slaked by adding water and allowing the insolubles to precipitate, leaving the limewater to be used for water treatment coagulation, softening or raising pH. The slaking process is labour intensive and dirty. Quicklime must be stored in sealed silo hoppers, onsite. It's a cheap ingredient that requires a high capital cost for storage and slaking equipment, plus an ongoing operational labour cost to run the system. http://www.carmeusena.com/Markets/faqs.asp?indid=4#3.

Liquid Sodium hydroxide NaOH may also be used to raise pH. It is simple to use, feed directly to pump, easier to store, but it is 5x higher price. It is used in small communities because they do not have the human resources to deal with lime sludge/limewater separation.

In San Diego a new stainless steel HFSA vat was destroyed within weeks of installation “After waiting four years to complete billions of dollars of improvements at five water treatment plants, the Metropolitan Water District had expected to start fluoridating in October.”…“Metropolitan [name and position withheld] said Wednesday the latest delay came after the agency's staff discovered the galvanized steel it planned to use could corrode if it came in contact with the fluorosilicic acid that will fluoridate supplies.” (Conaughton 2007)

1992 Tacoma, Washington had to shut down the fluoridation equipment due to the fact that fluoride had eaten the pipes. The municipal water had approximately 32 parts per billion (ppb) lead at the time of the breakdown. After the breakdown, the lead level dropped to 17 ppb. When the equipment was fixed, the lead level shot back up to 32 ppb. The city fathers decided to discontinue the use of fluoride, and the lead level again dropped. Over the next several years the lead level continued to drop, and today it is about 5 ppb. IAOMT p24-25.

Thurmont, Maryland had an identical experience with fluoride raising lead levels in their municipal water system. IAOMT p25.

The Centers for Disease Control now states clearly that fluorides are ineffective at the levels currently used in Canada. "Fluoride's predominant effect is posteruptive and topical." MMWR Weekly Report. Vol. 50, No. RR-14, August 17, 2001, p. 4.

“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.” MMWR Weekly Report. 1999;48:933-940.

The CDC also states that the concentration of fluoride in drinking water is too low to have a topical effect. “Studies have shown that even a drop of 0.2 mg/L below the optimum (fluoride) level can reduce dental benefits significantly. CDC Fluoridation Course 3017-G, pg. 8, Para. 3 According to the estimates by CDC, fluoride level for Ontario should be at least 1.2mg/L. According to CDC’s own calculations, the concentrations (0.5-0.8mg/L) recommended by the Ontario MOE are ineffective.

Conclusions

The direct or indirect addition of lead from fluorosilicates is shown to cause measurable health harm. Lead is a known neurotoxicant. Lead has synergistic effects with chlorine/chloramine.

This evidence suggests that the "safe level" of fluoride in the fresh water habitat of susceptible species is 0.2 ppm (mg/L). The evidence suggests that artificial water fluoridation is harmful to humans and should be discontinued.

Questions

  1. In legal circles when one product is advertised for use and then another product is used in its place, it is called “bait and switch”. Please provide evidence that Health Canada or Public Health have informed the public that we are putting H2SiF6 or Na2SiF6 into drinking water and not “fluoride”? Provide evidence of such notices.
  2. Does Environment Canada consider that removing fluoride compounds from air emissions (HF) to minimize pollution and adding them through drinking water, hence source water is a valid environmental solution to pollution? If so, explain how?
  3. How has Health Canada or Environmental Canada communicated concern about increasing lead levels in drinking water, hence source water? If so, which federal agency will conduct research to determine the relative contributions of the mixtures of free chlorine or chloramine and fluorosilicates to our lead in drinking water?
  4. What is Health Canada’s current position with respect to the American Dental Association’s explanation that fluoride works topically, not by swallowing (JADA Cover Story July 2000)? Agree or not?
  5. Has Public Works or the Treasury Board made a cost assessment of how much the use of H2SiF6 and Na2SiF6 are costing taxpayers in terms of infrastructure? Please provide estimates and the source of these estimates.
  6. Australia and US governments are being sued for health harm caused by water fluoridation. What type of risk assessment has Health Canada or any other government agency done to assess potential liability on this issue for the government of Canada?
  7. The CDC states: “Studies have shown that even a drop of 0.2 mg/L below the optimum (fluoride) level can reduce dental benefits significantly.” CDC Fluoridation Course 3017-G, pg. 8, para. 3 According to the estimates by CDC, “optimal” fluoride levels for Ontario should be 1.2mg/L or higher. According to CDC’s own calculations, the concentrations (0.5-0.8mg/L) recommended by Ont. MOE are ineffective. Why does Health Canada continue to promote this ineffective method of delivering this unregulated drug when even the Centers for Disease Control optimal dosage formula demonstrate that it is ineffective?
  8. Does Health Canada still use the Galagan-Vermillion formula and the assumptions on which it was based (e.g. Galagan and Vermillion assumed that, on average, 44% of the American children’s fluid intake was milk, which has negligible fluoride levels) to determine water fluoridation concentration guidelines? If so, please provide rationale and research evidence. If not, why? 
  9. Does Health Canada believe that 44% of Canadian children’s fluid intake is milk? If so, why? Please provide rationale and research evidence. If not, why?
  10. Does Health Canada contend that drinking water providers may compel the ingestion of, and dermal exposures to, fluoride through our addition of a direct water additive?
  11.  Which government agency is responsible for disclosing all sources of, and quantifying, potential and historically based exposures to fluoride?
  12. Is the Department of Fisheries and Oceans aware that fluoridating communities adding the toxic compounds of hydrofluorosilicic acid, arsenic and lead to our fresh water and salt water systems are pushing background levels of fluoride above the CWQG? If so, what do they plan to do about it? If not, why?
  13. Does the Department of Fisheries and Oceans believe that the discharge of municipal fluoridated effluents is a sustainable activity for fisheries? If so, why? If not, what are the Department’s plans to halt it?
  14. H2SiF6, Na2SiF6 are the primary agents used in >95% of water fluoridation schemes in the USA and assumably in Canada. These products are incorporated into the food chain through reconstituted beverages (fruit beverages, sodas) and food processing (cooking, washing). Does Health Canada have any responsibility to prevent the sale of toxic substances, as defined by CEPA (inorganic fluorides such as H2SiF6, Na2SiF6 which are anthropogenic) for consumption? Does any other federal government agency (Environment Canada?) have a responsibility to prevent the sale of toxic substances in our food chain?
  15. The Safe Drinking Water Act of Ontario, section 20, does not permit the addition of drinking water health hazards to our drinking water; dilution of drinking water health hazards is no defence. What proof Can Environment Canada or Health Canada or any other relevant government agency show that the toxic substances used in water fluoridation (H2SiF6, Na2SiF6) their complex silicate by-products and co-contaminants arsenic, lead (see Urbansky 2002, [name withheld] 2007, Smith, 1999) are not drinking water health hazards? (Urbansky concluded that hydroxo-fluoro SiF derivatives exist in drinking water. [Name withheld] et al 2007 also demonstrates that many fluorosiliciates exist in drinking water H2SiF6, H2SiF6 ·SiF4 , Na2SiF6). Please provide references.
  16. Does Health Canada, Environment Canada or any other relevant government agency disagree with the above evidence that fluorosilicates do not completely dissociate and may re-associate? If so, please provide rationale and complete references.
  17. Can Health Canada, Environment Canada or any other relevant government agency prove that complete dissociation occurs despite the above evidence? If so, please provide references.
  18. Which SINGLE peer-reviewed publication in an established scientific journal that establishes the SAFETY of either fluorosilicic acid or sodium silicofluoride (H2SiF6, Na2SiF6) for all individuals, over a lifetime of ingestion, using conventional animal studies of toxicology (and neurotoxicology) can Health Canada or any other relevant government agency provide as evidence of such?
  19. Knowing that approximately 50% of the fluoride humans and animals ingest each day accumulates in their bones, what systematic and comprehensive attempts to measure fluoride in the bones of the Canadian population or fish species to see how close some individuals or fish species are getting to levels associated with pre-clinical, phase 1, phase II or phase III skeletal fluorosis <http://salsa.democracyinaction.org/dia/track.jsp?v=2&c=d7MRwdlM6uD1oIrwfLMfOElUQHKaz7Xd> , as well as levels associated with increased susceptibility to bone fractures <http://salsa.democracyinaction.org/dia/track.jsp?v=2&c=H1PPFrMCu0Jw2jIMpmf%2BK0lUQHKaz7Xd> in animal studies <http://salsa.democracyinaction.org/dia/track.jsp?v=2&c=88KRz7vDYWGIjuURme452klUQHKaz7Xd> and clinical trials <http://salsa.democracyinaction.org/dia/track.jsp?v=2&c=2kKMD1zB%2BTHq1ASGjcrjeUlUQHKaz7Xd> ?
  20.  What published studies have satisfied you that when a child has developed dental fluorosis that fluoride has caused no other damage <http://salsa.democracyinaction.org/dia/track.jsp?v=2&c=11vtZ6CYQhmMqAt8rVhVBUlUQHKaz7Xd> to the child's developing tissues?

Recommendations

Will Fisheries and Oceans recommend the discontinuation of this practice which is no longer considered effective in the treatment of cavities, but which is influencing the migration patterns and the destruction of some marine species such as Pacific Salmon, in violation of the Fisheries Act?

Will Public Works and Government Services Canada or Finance Canada recommend that a cost estimate of damage done to water infrastructures in cities that currently fluoridate?

Because litigation is now occurring in Australia and the USA regarding water fluoridation, will Public Works and Government Services Canada or Finance Canada recommend that a cost estimate of possible litigation on this issue be made?

Will Health Canada recommend that this practice of adding hydrofluorosilicic acid or sodium silicofluoride and associated contaminants to drinking water, hence source water, stop immediately? If not, why?

Citations

  1. 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.
  2. Edwards M. 2004 Written version of testimony presented orally on March 4, 2004 to US House committee investigating facts pertaining to the reporting of high water lead in Washington, DC, on-line at http://www.dcwatch.com/wasa/040305h.htm
  3. 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.
  4. Masters RD, Coplan M. 1999 Water treatment with silcofluorides and lead toxicity. International Journal of Environmental Science 56: 435-449.
  5. Masters and Copland 2000 Association of silicofluoride treated water with elevated blood lead levels. Neurotoxicology 21(6):1091-1100.
  6. Moss, M.E. et al, 1999 Association of Dental Caries and Blood Lead Levels. JAMA. June 23/30, ;281(24): 2294-2298.
  7. Renner R. 2004 Leading to lead. Scientific American 291(1):22–4.
  8. Renner R. Mis-Lead. Environmental Science & Technology Online News: Science News May 31, 2006. http://pubs.acs.org/subscribe/journals/esthag-w/2006/may/science/rr_mislead.html.
  9. Urbansky ET. The fate of fluorosilicate drinking water additives. Chem. Rev 2002; 102(8):2837–54.
  10. 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.
  11. EIlis MM, Westfall BA, Ellis MD. Determination of Water Quality Research Report 9, Fish and Wildlife Service, Department of Interior, Washington DC 1938 pp 81-82;
  12. Hemens J: Warvick RJ, Oleff WD. Effect of extended exposure to low fluoride concentration on estuarine fish and crustacea. Progress in Water Technology 7 579-585 1975;
  13. Ishio S, Makagawa H (1971). Cited in: Rose D. Marier J. Environmental Fluoride 1977. National Research Council of Canada, Ottawa 1977, p 30;
  14. Dave G. Effects of fluoride on growth reproduction and survival in Daphnia magna, Comparative Biochemistry and Physiology, 78c (2) 425-431 1984;
  15. US Court Of Appeals, Ninth Circuit (Pocatello, Idaho) No. 17059 (1961): Food and Machinery and Chemical Corporation and J R Simplot Co. vs W S and Ray Meader. Exhibit (Table 1), August 25 1961;
  16. Camargo JA. Fluoride toxicity to aquatic organisms: a review. Chemosphere. 2003 Jan;50(3):251-64.
  17. Westendorf J. 1974 Die kinetik der acetylocholinesterase himmung und die beeinflussung der permeabilitat von erytrozytenmemranen durch fluorid und fluorocomplex-jonen. Ph.D. thesis, University of Hamburg; Hamburg; 1975 & Knappwost A, Westendorf J. 1974 Inhibition of cholinesterases caused by fluorine complex of silicon and of iron [in German] Naturwissenschatten 61(6): 275.

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Minister's Response: Environment Canada

26 August 2008

Mr. Peter L.D. Van Caulart
Vice President and Director
Environmental Training Institute
273 Canboro Road
R.R. 1
Ridgeville, Ontario
L0S 1M0

Dear Mr. Van Caulart:

I am responding to your Environmental Petition No. 245, to the Interim Commissioner of the Environment and Sustainable Development, concerning the addition of toxic substances to drinking water. Your petition was received in the Department on May 16.

Please find enclosed Environment Canada’s response to question 2, which falls under the mandate of the Department. I understand that the ministers of other departments will be responding separately to petition questions that fall under the mandate of their departments.

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

Sincerely,

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

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

Enclosure

c.c.: The Honourable Rob Nicholson, P.C., M.P.
The Honourable Loyola Hearn, P.C., M.P.
The Honourable Vic Toews, P.C., M.P.
The Honourable Tony Clement, P.C., M.P.
The Honourable James M. Flaherty, P.C., M.P.
The Honourable Michael Fortier, P.C.
Mr. Ronald C. Thompson, Interim Commissioner of the Environment and Sustainable Development


Environment Canada Response to Environmental Petition No. 245,
requesting discontinuation of artificial water fluoridation

Question 2: Does Environment Canada consider that removing fluoride compounds from air emissions (HF) to minimize pollution and adding them through drinking water, hence source water is a valid environmental solution to pollution? If so, explain how?

Response: The Priority Substances List (PSL) assessment on inorganic fluorides, which was published in 1993 by Environment Canada and Health Canada (www.ec.gc.ca/substances/ese/eng/psap/PSL1_fluorides.cfm), concluded that these chemicals posed a risk to both aquatic and terrestrial organisms by way of water and air exposure, respectively. Sources and estimated quantities of releases to both media were listed in the assessment report and are further summarized below:

At the time of the PSL assessment, inorganic fluorides were used in Canada and emitted into the Canadian environment both from anthropogenic (estimated releases of approximately 23,500 tonnes/year) and natural sources (amounts released are not known). The main anthropogenic sources of inorganic fluorides in Canada included phosphate fertilizer production, chemical production, and aluminum smelting. Gaseous inorganic fluorides (e.g., hydrogen fluoride and sulphur hexafluoride) were primarily released into the atmosphere, whereas particulate compounds (e.g., sodium fluoride and calcium fluoride) were released into the aquatic and terrestrial environments.

The assessment indicated that about 23 percent of total inorganic fluorides releases were emitted to air and 58 percent were discharged to water. Fluoridated drinking water was not identified as a priority source in the PSL assessment; therefore, risk management activities focused on the other sources that were identified and quantified in the PSL document.

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Minister's Response: Department of Finance Canada

29 August 2008

Mr. Peter L.D. Van Caulart, Dip. A.Ed., CES, CEI
VP& Director Environmental, Training Institute
273 Canboro Road, RR1
Ridgeville, ON L0S 1M0

Dear Mr. Van Caulart:

Further to my acknowledgement letter of May 31, 2008, I am pleased to provide you with a response to the petition (Petition No. 245—Impact of fluorosilicate compounds on drinking water lead levels and on water distribution infrastructure) that you submitted through the Commissioner of the Environment and Sustainable Development. This petition was also sent to my colleagues, the Ministers of Fisheries and Oceans, Natural Resources, Health, Public Works and Government Services, the Environment and the President of the Treasury Board. My response outlines the Government of Canada’s position on your second and third recommendations in the petition.

In this petition, you asked if Public Works and Government Services (PWGSC) or Finance Canada would recommend that a cost estimate be undertaken of damage done to water infrastructures in cities that currently fluoridate their water. You also asked if PWGSC or Finance Canada would recommend that a cost estimate of possible litigation over disputes regarding water fluoridation be undertaken in light of litigation that is now occurring in Australia and the United States on the same issue.

Maintenance of water infrastructure and provision of water services to cities and municipalities in Canada is generally a municipal and provincial activity and is defined as such within the Constitution Act. While some government departments do operate water distribution networks for their own purposes and are responsible for their maintenance, it is not within the mandate of the federal government to investigate potential costs of damage to municipal water infrastructure due to fluoridation, and/or to estimate the cost of any litigation that may arise as a result of any damage that fluoridation will cause. I would encourage you to address your questions to the relevant provincial and municipal institutions.

Thank you for providing me this opportunity to respond to your concerns.

Sincerely,

[Original signed by James M. Flaherty, Minister of Finance]

James M. Flaherty
cc.  Scott Vaughan
Commissioner of the Environment and Sustainable Development

The Honourable Christian Paradis, P.C., M.P.
The Minister of Public Works and Government Services

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

The Honourable Loyola Hearn, P.C., M.P.
Minster of Fisheries and Oceans

The Honourable Vic Toews, P.C., M.P.
President of the Treasury Board

The Honourable Tony Clement, P.C., M.P.
Minister of Health and Minister for the Federal
Economic Development Initiative for Northern Ontario

Mr. Mike Milito
Director, Internal Audit and Evaluation, Finance Canada

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Minister's Response: Fisheries and Oceans Canada

5 September 2008

Mr. Peter L.D. Van Caulart, Dip. A. Ed., CES, CEI
VP & Director Environmental Training Institute
273 Canboro Road. RR1
Ridgeville, Ontario
L0S 1M0

Dear Mr. Van Caulart,

Thank you for sharing your concerns in your May 2, 2008, Environmental Petition No. 245, submitted under the provisions of the Auditor General Act to the Commissioner of the Environment and Sustainable Development. The questions in your petition were addressed to many departments, including Fisheries and Oceans Canada (DFO).

I would like to take this opportunity to set out the mandate of DFO related to the conservation and protection of fish and fish habitat. The federal government has constitutional authority for seacoast and inland fisheries. The Minister of Fisheries and Oceans is responsible to Parliament for the Fisheries Act. The Fisheries Act contains provisions to conserve and protect fish habitat (defined in subsection 34(1) of the 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 existing and potential fisheries resources.

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

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

I am pleased to provide the following responses to the specific questions addressed to my Department and that fall within its mandate:

Question 12: Is the Department of Fisheries and Oceans aware that fluoridating communities adding the toxic compounds of hydrofluorosilicic acid, arsenic and lead to our fresh water and salt water systems are pushing background levels of fluoride above the CWQG? If so, what do they plan to do about it? If not, why?

Response: DFO does not monitor for fluoride levels in the aquatic environment. By memorandum of understanding between the Minister of DFO and the Minister of the Environment, the Minister of the Environment administers the pollution prevention provisions of the Fisheries Act in relation to the disposal or the deposit of a toxic substance in waters frequented by fish. To date, monitoring data from Environment Canada suggest fluoride levels are highly unlikely to be affecting fish and fish habitat.

Question 13: Does the Department of Fisheries and Oceans believe that the discharge of municipal fluoridated effluents is a sustainable activity for fisheries? If so, why? If not, what are the Department’s plans to halt it?

Response: Current monitoring data suggest fluoride levels are highly unlikely to be affecting fisheries.

Question 19: Knowing that approximately 50% of the fluoride humans and animals ingest each day accumulates in their bones, what systematic and comprehensive attempts to measure fluoride in the bones of the Canadian population or fish species to see how close some individuals or fish species are getting to levels associated with pre-clinical, phase I, phase II or phase III skeletal fluorosis, as well as levels associated with increased susceptibility to bone fractures in animal studies and clinical trials?

Response: DFO is unaware of any monitoring data that suggest current fluoridation levels in the aquatic environment are affecting fish populations. DFO is not familiar with any jurisdiction in Canada or elsewhere that has measured fluoride in the bones of fish species or established levels at which skeletal fluorosis may pose a risk to populations.

Recommendation 1: Will Fisheries and Oceans recommend the discontinuation of this practice which is no longer considered effective in the treatment of cavities, but which is influencing the migration patterns and the destruction of some marine species such as Pacific Salmon, in violation of the Fisheries Act?

Response: Current monitoring data do not suggest fluoride is influencing the migration patterns or affecting some marine species such as Pacific Salmon. Therefore, DFO will not be recommending the discontinuation of this practice.

In summary, the role of DFO is characterized as providing support to other departments and agencies whose jurisdiction and legislation more directly address the efficacy and potential impacts of water fluoridation. The Department will continue to provide information and support to the responsible departments and agencies with the objective of protecting fish and fish habitat in accordance with the habitat provisions of the Fisheries Act.

Sincerely,

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

Loyola Hearn, P.C., M.P.

c.c.: The Honourable John Baird, P.C., M.P.
The Honourable James Michael Flaherty, P.C., M.P.
The Honourable Tony Clement, P.C., M.P
The Honourable Robert Douglas Nicholson, P.C., M.P.
The Honourable Michael Fortier, P.C., M.P,
The Honourable Vic Toews, P.C., M.P.
Mr. Scott Vaughan, Commissioner of the Environment and Sustainable Development

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Joint Response: Health Canada, Public Health Agency of Canada

25 August 2008

Mr. Peter L.D. Van Caulart
273 Canboro Road
R.R. 1
Ridgeville, Ontario
L0S 1M0

Dear Mr. Van Caulart:

This is in response to your environmental petition no. 245 of April 18, 2008, addressed to Mr. Ronald C. Thompson, the former Interim Commissioner of the Environment and Sustainable Development (CESD).

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

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

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

Yours sincerely,

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

Tony Clement

Enclosure

c.c. Mr. Scott Vaughan, CESD              
The Honourable Loyola Hearn, P.C., M.P.
The Honourable John Baird, P.C., M.P.
The Honourable James M. Flaherty, P.C., M.P.
The Honourable Michael Fortier, P.C., Senator
The Honourable Robert Nicholson, P.C., Q.C., M.P.
The Honourable Vic Toews, P.C., M.P.


Response to
Environmental Petition 245 filed by Mr. Peter L.D. Van Caulart
under Section 22 of the Auditor General Act
Received May 16, 2008

Petition for the discontinuation of the addition of toxic substances to our drinking water (inorganic fluorides, inorganic arsenic, lead)

September 13, 2008

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

Background:

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

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

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

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

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

  1. In legal circles when one product is advertised for use and then another product is used in its place, it is called “bait and switch”. Please provide evidence that Health Canada or Public Health have informed the public that we are putting H2SiF6 or Na2SiF6 into drinking water and not “fluoride”? Provide evidence of such notices.

The fluorosilicate compounds you mention readily hydrolyse in water to release fluoride ions, which means that drinking water is not a source of exposure to these compounds. Fluorosilicate compounds are added as a source of the mineral nutrient fluoride.

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

  1. How has Health Canada or Environmental Canada communicated concern about increasing lead levels in drinking water, hence source water? If so, which federal agency will conduct research to determine the relative contributions of the mixtures of free chlorine or chloramine and fluorosilicates to our lead in drinking water?

Levels of lead in drinking water are due to leaching from materials within the distribution system and residential plumbing system. Lead is not generally found naturally in the environment in Canada. Provincial/territorial governments are generally responsible for the safety of drinking water. Health Canada and the Federal-Provincial-Territorial Committee on Drinking Water have developed a guidance document on controlling corrosion in drinking water distribution systems. Public consultation of the document has been conducted. The document, once finalized and approved through Federal-Provincial-Territorial processes, will be posted on Health Canada’s website at www.healthcanada.gc.ca/waterquality.

  1. What is Health Canada’s current position with respect to the American Dental Association’s explanation that fluoride works topically, not by swallowing (JADA Cover Story July 2000)? Agree or not?

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.

5.   Has Public Works or the Treasury Board made a cost assessment of how much the use of H2SiF6 and Na2SiF6 are costing taxpayers in terms of infrastructure? Please provide estimates and the source of these estimates.

From Health Canada’s perspective, there are no data available to support the suggestion that fluoridation additives have a negative impact on infrastructure.

  1. Australia and US governments are being sued for health harm caused by water fluoridation. What type of risk assessment has Health Canada or any other government agency done to assess potential liability on this issue for the government of Canada?

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. Health Canada’s guideline for fluoride in drinking water is protective of the health of all Canadians.

  1. The CDC states: “Studies have shown that even a drop of 0.2 mg/L below the optimum (fluoride) level can reduce dental benefits significantly.” According to the estimates by CDC, “optimal” fluoride levels for Ontario should be 1.2mg/L or higher. According to CDC’s own calculations, the concentrations (0.5-0.8mg/L) recommended by Ont. MOE are ineffective. Why does Health Canada continue to promote this ineffective method of delivering this unregulated drug when even the Centers for Disease Control optimal dosage formula demonstrate that it is ineffective?

It is not appropriate to use calculations from an external agency to assess the adequacy of a fluoridation program, considering their data and conclusions are based on a different exposure pattern. Health Canada has based its conclusions on exposure data specific for the Canadian situation and developed the Guidelines for Canadian Drinking Water Quality accordingly. Health Canada endorses the fluoridation of drinking water to prevent tooth decay, but does not make the decision on whether or not to fluoridate drinking water. 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.

  1. Does Health Canada still use the Galagan-Vermillion formula and the assumptions on which it was based (e.g. Galagan and Vermillion assumed that, on average, 44% of the American children’s fluid intake was milk, which has negligible fluoride levels) to determine water fluoridation concentration guidelines? If so, please provide rationale and research evidence. If not, why?
  1. Does Health Canada believe that 44% of Canadian children’s fluid intake is milk? If so, why? Please provide rationale and research evidence. If not, why?

Answer to Questions 8 & 9:

Health Canada has conducted its own assessment of exposure to fluoride, based on foods and water available in Canada. Health Canada does not use the Galagan-Vermillion formula. Further information can be found on Health Canada’s website at www.healthcanada.gc.ca/waterquality

  1. Does Health Canada contend that drinking water providers may compel the ingestion of, and dermal exposures to, fluoride through our addition of a direct water additive?

Fluoridation is the process by which a drinking water provider will adjust the level of fluoride that is naturally present in most Canadian source waters to the optimal level to protect dental health. 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.

  1. Which government agency is responsible for disclosing all sources of, and quantifying, potential and historically based exposures to fluoride?

There is no federal agency responsible for such data.

  1. H2SiF6, Na2SiF6 are the primary agents used in >95% of water fluoridation schemes in the USA and assumably in Canada. These products are incorporated into the food chain through reconstituted beverages (fruit beverages, sodas) and food processing (cooking, washing). Does Health Canada have any responsibility to prevent the sale of toxic substances, as defined by CEPA (inorganic fluorides such as H2SiF6, Na2SiF6 which are anthropogenic) for consumption? Does any other federal government agency (Environment Canada?) have a responsibility to prevent the sale of toxic substances in our food chain?

Fluoridated drinking water is not a source of exposure to hydrofluorosilicic acid, nor was hydrofluorosilicic acid included in the CEPA assessment of inorganic fluorides. Fluoridation additives certified for use in drinking water are not classified as CEPA toxic. 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.

  1. The Safe Drinking Water Act of Ontario, section 20, does not permit the addition of drinking water health hazards to our drinking water; dilution of drinking water health hazards is no defence. What proof Can Environment Canada or Health Canada or any other relevant government agency show that the toxic substances used in water fluoridation (H2SiF6, Na2SiF6) their complex silicate by-products and co-contaminants arsenic, lead (see Urbansky 2002, Coplan 2007, Smith, 1999) are not drinking water health hazards? (Urbansky concluded that hydroxo-fluoro SiF derivatives exist in drinking water. Coplan et al 2007 also demonstrates that many fluorosiliciates exist in drinking water H2SiF6, H2SiF6 •SiF4 , Na2SiF6). Please provide references.

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. For questions regarding the interpretation of the Safe Drinking Water Act of Ontario, please communicate directly with the Ontario Ministry of the Environment.

  1. Does Health Canada, Environment Canada or any other relevant government agency disagree with the above evidence that fluorosilicates do not completely dissociate and may re-associate? If so, please provide rationale and complete references.
  1. Can Health Canada, Environment Canada or any other relevant government agency prove that complete dissociation occurs despite the above evidence? If so, please provide references.
  1. Which SINGLE peer-reviewed publication in an established scientific journal that establishes the SAFETY of either fluorosilicic acid or sodium silicofluoride (H2SiF6, Na2SiF6) for all individuals, over a lifetime of ingestion, using conventional animal studies of toxicology (and neurotoxicology) can Health Canada or any other relevant government agency provide as evidence of such?

Answers to Questions 16, 17 & 18:

Fluorosilicate compounds readily hydrolyse in water to release fluoride ions, which means that drinking water is not a source of exposure to these compounds. This is based on currently available research and science.

The research community has focussed to date on levels that would result from exposures in occupational settings. A review of the toxicological literature on Sodium Hexafluorosilicate and on Fluorosilicic Acid conducted for the National Institute of Environmental Health Sciences is available at the following URL:
http://ntp.niehs.nih.gov/ntp/htdocs/Chem_Background/ExSumPDF/Fluorosilicates.pdf
Health Canada does not conduct research on the chemistry of fluoride species.

  1. What published studies have satisfied you that when a child has developed dental fluorosis that fluoride has caused no other damage <http://salsa.democracyinaction.org/dia/track.jsp?v=2&c=11vtZ6CYQhmMqAt8rVhVBUlUQHKaz7Xd> to the child's developing tissues?

Exposure to fluoride has been linked to dental fluorosis and, at extremely high exposure levels, skeletal fluorosis. Based on a thorough review of the available relevant scientific literature, the weight of evidence does not support any other adverse effects.

Health Canada conducts internal scientific reviews of original relevant scientific studies that are published in internationally recognized peer-reviewed journals. Health Canada continues to monitor the science and review new scientific reports and articles to ensure the department’s decisions are supported by the weight of credible evidence from relevant peer reviewed scientific studies.

R4. Will Health Canada recommend that this practice of adding hydrofluorosilicic acid or sodium silicofluoride and associated contaminants to drinking water, hence source water, stop immediately? If not, why?

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.

Drinking water fluoridation is 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.

Health Canada endorses the fluoridation of drinking water to prevent tooth decay, but does not make the decision on whether or not to fluoridate drinking water. 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.

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Minister's Response: Public Works and Government Services Canada

12 September 2008

Mr. Peter L. D. Van Caulart
273 Canboro Road
Rural Road 1
Ridgevile, Ontario L0S 1M0

Dear Mr. Van Caulart:

I am pleased to respond to your petition concerning issues related to the discontinuation of adding fluoridation products to our drinking water. This petition was received by the Commissioner of the Environment and Sustainable Development on May 2, 2008, and was forwarded to my department on May 16, 2008.

In addition to my department, the Commissioner’s Office has asked the Ministers of the Environment, Fisheries and Oceans, Finance, and Health, as well as the President of the Treasury Board, to respond.

Question 5 of your petition asks Public Works and Government Services to provide cost estimates of how much the use of water fluoridation additives, H2SiF6 and Na2SiF6, is costing taxpayers in terms of infrastructure. It also asks for the sources of these estimates. I would like to take this opportunity to clarify my department’s involvement with respect to water distribution infrastructures it owns and/or manages.

The majority of government-owned and lease-purchase buildings under my administration as Minister of Public Works and Government Services Canada are supplied by water distribution infrastructures owned and operated by the respective municipalities where these assets are located. It is important to note that while Public Works and Government Services Canada owns and/or manages sixteen water distribution infrastructures, it has limited involvement in the production and distribution of potable water. These infrastructures are:

  • five campus-type distribution networks which supply potable water to multiple buildings situated at the same location. The responsibility for supplying potable water to these networks rests with the respective municipalities; and,
  • eleven systems, which supply federal buildings in remote areas with potable well water. My officials have confirmed that fluoridation products are not added to the potable well water supplying these federal buildings.

Maintenance of water infrastructure and provision of water services to cities and municipalities in Canada are generally municipal and provincial activities and are defined as such within the Constitution Act. My department has not received any indication that fluoridated water received from the municipalities is adversely affecting infrastructures under its responsibility. As such, Public Works and Government Services Canada has not conducted any cost assessments or estimates related to fluoridation of drinking water and its possible effects on infrastructure it owns and/or manages.

I understand that my colleagues have agreed to provide separate responses to questions that address their respective mandates. With regards to the recommendations jointly directed at Public Works and Government Services Canada and Finance Canada, I have been advised that my colleague, the Honourable James Michael Flaherty, Minister of Finance, will respond to both recommendations on behalf of the Government of Canada.

Thank you again for writing and for providing me the opportunity to respond to you on this matter.

Yours sincerely,

[Original signed by Christian Paradis, Minister of Public Works and Government Services]

The Honourable Christian Paradis, P.C., M.P. (Mégantic-L’Érable)

c.c.    Mr. Scott Vaughan
Commissioner of the Environment and
Sustainable Development

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

The Honourable Loyola Hearn, P.C., M.P.
Minster of Fisheries and Oceans

The Honourable Vic Toews, P.C., M.P.
President of the Treasury Board

The Honourable James Michael Flaherty, P.C., M.P.
Minister of Finance

The Honourable Tony Clement, P.C., M.P.
Minister of Health and Minister for the Federal
Economic Development Initiative for Northern
Ontario

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Minister's Response: Treasury Board of Canada Secretariat

8 August 2008

Mr. Peter L.D. Van Caulart
Vice President and Director
Environmental Training Institute
273 Canboro Road, R.R. 1
Ridgeville, Ontario
L0S 1M0

Dear Mr. Van Caulart:

I am pleased to respond to your petition regarding the addition of fluoridation additives to our drinking water, received by the Commissioner of the Environment and Sustainable Development on May 2, 2008.

In addition to the Treasury Board Secretariat (TBS), the Commissioner has asked the Ministers of Environment, Fisheries and Oceans, Finance, and Health, as well as Public Works and Government Services Canada to respond. I understand that my colleagues will be providing separate responses to your questions that fall within their respective mandates.

Question 5 asks TBS to provide cost estimates of how much the use of the water fluoridation additives, H2SiF6 and Na2SiF6, are costing taxpayers in terms of infrastructure. I would like to take this opportunity to clarify the role of TBS.

As a central agency of the federal government, TBS promotes improved management performance, examines the proposed spending plans of other departments, and acts as the principal employer for the core public administration. The role of TBS is to ensure that the Government is well managed, accountable, and resources are allocated to achieve results.

While TBS has an interest in value-for-money assessments of federal investments, the kind of specific cost analysis study mentioned in the petition is beyond the scope of the Secretariat’s activities.
Yours sincerely,

[Original signed by Vic Toews, President of the Treasury Board]

Vic Toews, P.C., Q.C., M.P.

c.c.: The Honourable Robert Douglas Nicholson, P.C., M.P.
The Honourable Loyola Hearn, P.C., M.P.
The Honourable John Baird, P.C., M.P.
The Honourable Tony Clement, P.C., M.P.
The Honourable James M. Flaherty, P.C., M.P.
The Honourable Christian Paradis, P.C., M.P.
Mr. Scott Vaughan, Commissioner of the Environment and Sustainable Development