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Date: Wed, 5 Jul 2000 13:09:23 EDT
From: magnu96196@aol.com
fluoridation
of public water supplies---congressional hearing
STATEMENT OF Dr. J. WILLIAM HIRZY
NATIONAL TREASURY EMPLOYEES UNION CHAPTER 280
BEFORE THE SUBCOMMITTEE ON WILDLIFE, FISHERIES AND DRINKING WATER
UNITED STATES SENATE
JUNE 29, 2000
Good morning Mr. Chairman and Members of the Subcommittee. I appreciate
the
opportunity to appear before this Subcommittee to present the views
of the
union, of which I am a Vice-President, on the subject of fluoridation
of
public water supplies.
Our union is comprised of and represents the professional employees
at the
headquarters location of the U.S. Environmental Protection Agency in
Washington D.C. Our members include toxicologists, biologists, chemists,
engineers, lawyers and others defined by law as "professionals." The
work we
do includes evaluation of toxicity, exposure and economic information
for
management's use in formulating public health and environmental protection
policy. I am not here as a representative of EPA, but rather as a
representative of EPA headquarters professional employees, through
their duly
elected labor union. The union first got involved in this issue in
1985 as a
matter of professional ethics. In 1997 we most recently voted to oppose
fluoridation. Our opposition has strengthened since then.
Summary of Recommendations
1) We ask that you order an independent review of a cancer bioassay
previously mandated by Congressional committee and subsequently performed
by
Battelle Memorial Institute with appropriate blinding and instructions
that
all reviewer's independent determinations be reported to this Committee.
2) We ask that you order that the two waste products of the fertilizer
industry that are now used in 90% of fluoridation programs, for which
EPA
states they are not able to identify any chronic studies, be used in
any
future toxicity studies, rather than a substitute chemical. Further,
since
federal agencies are actively advocating that each man woman and child
drink,
eat and bathe in these chemicals, silicofluorides should be placed
at the
head of the list for establishing a MCL that complies with the Safe
Drinking
Water Act. This means that the MCL be protective of the most sensitive
of our
population, including infants, with an appropriate margin of safety
for
ingestion over an entire lifetime.
3) We ask that you order an epidemiology study comparing children with
dental
fluorosis to those not displaying overdose during growth and development
years for behavioral and other disorders.
4) We ask that you convene a joint Congressional Committee to give the
only
substance that is being mandated for ingestion throughout this country
the
full hearing that it deserves.
National Review of Fluoridation The Subcommittee's hearing today
can only
begin to get at the issues surrounding the policy of water fluoridation
in
the United States, a massive experiment that has been run on the American
public, without informed consent, for over fifty years. The last
Congressional hearings on this subject were held in 1977. Much knowledge
has
been gained in the intervening years. It is high time for a national
review
of this policy by a Joint Select Committee of Congress. New hearings
should
explore, at minimum, these points:
1) excessive and un-controlled fluoride exposures; 2) altered findings
of a
cancer bioassay; 3) the results and implications of recent brain effects
research; 4) the "protected pollutant" status of fluoride within EPA;
5) the
altered recommendations to EPA of a 1983 Surgeon General's Panel on
fluoride;
6) the results of a fifty-year experiment on fluoridation in two New
York
communities; 7) the findings of fact in three landmark lawsuits since
1978;
8) the findings and implications of recent research linking the predominant
fluoridation chemical with elevated blood-lead levels in children and
anti-social behavior; and 9) changing views among dental researchers
on the
efficacy of water fluoridation
Fluoride Exposures Are Excessive and Un-controlled According
to a study by
the National Institute of Dental Research, 66 percent of America's
children
in fluoridated communities show the visible sign of over-exposure and
fluoride toxicity, dental fluorosis (1). That result is from a survey
done in
the mid-1980's and the figure today is undoubtedly much higher.
Centers for Disease Control and EPA claim that dental fluorosis is only
a
"cosmetic" effect. God did not create humans with fluorosed teeth.
That
effect occurs when children ingest more fluoride than their bodies
can handle
with the metabolic processes we were born with, and their teeth are
damaged
as a result. And not only their teeth. Children's bones and other tissues,
as
well as their developing teeth are accumulating too much fluoride.
We can see
the effect on teeth. Few researchers, if any, are looking for the effects
of
excessive fluoride exposure on bone and other tissues in American children.
What has been reported so far in this connection is disturbing. One
example
is epidemiological evidence (2a, 2b) showing elevated bone cancer in
young
men related to consumption of fluoridated drinking water.
Without trying to ascribe a cause and effect relationship beforehand,
we do
know that American children in large numbers are afflicted with
hyperactivity-attention deficit disorder, that autism seems to be on
the
rise, that bone fractures in young athletes and military personnel
are on the
rise, that earlier onset of puberty in young women is occurring. There
are
biologically plausible mechanisms described in peer-reviewed research
on
fluoride that can link some of these effects to fluoride exposures
(e.g.
3,4,5,6). Considering the economic and human costs of these conditions,
we
believe that Congress should order epidemiology studies that use dental
fluorosis as an index of exposure to determine if there are links between
such effects and fluoride over-exposure.
In the interim, while this epidemiology is conducted, we believe that
a
national moratorium on water fluoridation should be instituted. There
will be
a hue and cry from some quarters, predicting increased dental caries,
but
Europe has about the same rate of dental caries as the U.S. (7) and
most
European countries do not fluoridate (8). I am submitting letters from
European and Asian authorities on this point. There are studies in
the U.S.
of localities that have interrupted fluoridation with no discernable
increase
in dental caries rates (e.g., 9). And people who want the freedom of
choice
to continue to ingest fluoride can do so by other means.
Cancer Bioassay Findings In 1990, the results of the National
Toxicology
Program cancer bioassay on sodium fluoride were published (10), the
initial
findings of which would have ended fluoridation. But a special commission
was
hastily convened to review the findings, resulting in the salvation
of
fluoridation through systematic down-grading of the evidence of
carcinogenicity. The final, published version of the NTP report says
that
there is, "equivocal evidence of carcinogenicity in male rats," changed
from
"clear evidence of carcinogenicity in male rats."
The change prompted Dr. William Marcus, who was then Senior Science
Adviser
and Toxicologist in the Office of Drinking Water, to blow the whistle
about
the issue (22), which led to his firing by EPA. Dr. Marcus sued EPA,
won his
case and was reinstated with back pay, benefits and compensatory damages.
I
am submitting material from Dr. Marcus to the Subcommittee dealing
with the
cancer and neurotoxicity risks posed by fluoridation.
We believe the Subcommittee should call for an independent review of
the
tumor slides from the bioassay, as was called for by Dr. Marcus (22),
with
the results to be presented in a hearing before a Select Committee
of the
Congress. The scientists who conducted the original study, the original
reviewers of the study, and the "review commission" members should
be called,
and an explanation given for the changed findings.
Brain Effects Research Since 1994 there have been six publications
that link
fluoride exposure to direct adverse effects on the brain. Two epidemiology
studies from China indicate depression of I.Q. in children (11,12).
Another
paper (3) shows a link between prenatal exposure of animals to fluoride
and
subsequent birth of off-spring which are hyperactive throughout life.
A 1998
paper shows brain and kidney damage in animals given the "optimal"
dosage of
fluoride, viz. one part per million (13). And another (14) shows decreased
levels of a key substance in the brain that may explain the results
in the
other paper from that journal. Another publication (5) links fluoride
dosing
to adverse effects on the brain's pineal gland and pre-mature onset
of sexual
maturity in animals. Earlier onset of menstruation of girls in fluoridated
Newburg, New York has also been reported (6).
Given the national concern over incidence of attention deficit-hyperactivity
disorder and autism in our children, we believe that the authors of
these
studies should be called before a Select Committee, along with those
who have
critiqued their studies, so the American public and the Congress can
understand the implications of this work.
Fluoride as a Protected Pollutant The classic example of EPA's
protective
treatment of this substance, recognized the world over and in the U.S.
before
the linguistic de-toxification campaign of the 1940's and 1950's as
a major
environmental pollutant, is the 1983 statement by EPA's then Deputy
Assistant
Administrator for Water, Rebecca Hanmer (15), that EPA views the use
of
hydrofluosilicic acid recovered from the waste stream of phosphate
fertilizer
manufacture as,
"...an ideal solution to a long standing problem. By recovering by-product
fluosilicic acid (sic) from fertilizer manufacturing, water and air
pollution
are minimized, and water authorities have a low-cost source of fluoride..."
In other words, the solution to pollution is dilution, as long as the
pollutant is dumped straight into drinking water systems and not into
rivers
or the atmosphere. I am submitting a copy of her letter.
Other Federal entities are also protective of fluoride. Congressman
Calvert
of the House Science Committee has sent letters of inquiry to EPA and
other
Federal entities on the matter of fluoride, answers to which have not
yet
been received.
We believe that EPA and other Federal officials should be called to
testify
on the manner in which fluoride has been protected. The union will
be happy
to assist the Congress in identifying targets for an inquiry. For instance,
hydrofluosilicic acid does not appear on the Toxic Release Inventory
list of
chemicals, and there is a remarkable discrepancy among the Maximum
Contaminant Levels for fluoride, arsenic and lead, given the relative
toxicities of these substances. Surgeon General's Panel on Fluoride
We
believe that EPA staff and managers should be called to testify, along
with
members of the 1983 Surgeon General's panel and officials of the Department
of Human Services, to explain how the original recommendations of the
Surgeon
General's panel (16) were altered to allow EPA to set otherwise unjustifiable
drinking water standards for fluoride.
Kingston and Newburg, New York Results In 1998, the results of a fifty-year
fluoridation experiment involving Kingston, New York (un-fluoridated)
and
Newburg, New York (fluoridated) were published (17). In summary, there
is no
overall significant difference in rates of dental decay in children
in the
two cities, but children in the fluoridated city show significantly
higher
rates of dental fluorosis than children in the un-fluoridated city.
We believe that the authors of this study and representatives of the
Centers
For Disease Control and EPA should be called before a Select Committee
to
explain the increase in dental fluorosis among American children and
the
implications of that increase for skeletal and other effects as the
children
mature, including bone cancer, stress fractures and arthritis.
Findings of Fact by Judges In three landmark cases adjudicated
since 1978 in
Pennsylvania, Illinois and Texas (18), judges with no interest except
finding
fact and administering justice heard prolonged testimony from proponents
and
opponents of fluoridation and made dispassionate findings of fact.
I cite one
such instance here.
In November, 1978, Judge John Flaherty, now Chief Justice of the Supreme
Court of Pennsylvania, issued findings in the case, Aitkenhead v. Borough
of
West View, tried before him in the Allegheny Court of Common Pleas.
Testimony
in the case filled 2800 transcript pages and fully elucidated the benefits
and risks of water fluoridation as understood in 1978. Judge Flaherty
issued
an injunction against fluoridation in the case, but the injunction
was
overturned on jurisdictional grounds. His findings of fact were not
disturbed
by appellate action. Judge Flaherty, in a July, 1979 letter to the
Mayor of
Aukland New Zealand wrote the following about the case:
"In my view, the evidence is quite convincing that the addition of sodium
fluoride to the public water supply at one part per million is extremely
deleterious to the human body, and, a review of the evidence will disclose
that there was no convincing evidence to the contrary...
"Prior to hearing this case, I gave the matter of fluoridation little,
if
any, thought, but I received quite an education, and noted that the
proponents of fluoridation do nothing more than try to impune (sic)
the
objectivity of those who oppose fluoridation."
In the Illinois decision, Judge Ronald Niemann concludes: "This record
is
barren of any credible and reputable scientific epidemiological studies
and
or analysis of statistical data which would support the Illinois
Legislature's determination that fluoridation of the water supplies
is both a
safe and effective means of promoting public health."
Judge Anthony Farris in Texas found: "[That] the artificial fluoridation
of
public water supplies, such as contemplated by {Houston} City ordinance
No.
80-2530 may cause or contribute to the cause of cancer, genetic damage,
intolerant reactions, and chronic toxicity, including dental mottling,
in
man; that the said artificial fluoridation may aggravate malnutrition
and
existing illness in man; and that the value of said artificial fluoridation
is in some doubt as to reduction of tooth decay in man."
The significance of Judge Flaherty's statement and his and the other
two
judges' findings of fact is this: proponents of fluoridation are fond
of
reciting endorsement statements by authorities, such as those by CDC
and the
American Dental Association, both of which have long-standing commitments
that are hard if not impossible to recant, on the safety and efficacy
of
fluoridation. Now come three truly independent servants of justice,
the
judges in these three cases, and they find that fluoridation of water
supplies is not justified.
Proponents of fluoridation are absolutely right about one thing: there
is no
real controversy about fluoridation when the facts are heard by an
open mind.
I am submitting a copy of the excerpted letter from Judge Flaherty and
another letter referenced in it that was sent to Judge Flaherty by
Dr. Peter
Sammartino, then Chancellor of Fairleigh Dickenson University. I am
also
submitting a reprint copy of an article in the Spring 1999 issue of
the
Florida State University Journal of Land Use and Environmental Law
by Jack
Graham and Dr. Pierre Morin, titled "Highlights in North American Litigation
During the Twentieth Century on Artificial Fluoridation of Public Water.
Mr.
Graham was chief litigator in the case before Judge Flaherty and in
the other
two cases (in Illinois and Texas).
We believe that Mr. Graham should be called before a Select Committee
along
with, if appropriate, the judges in these three cases who could relate
their
experience as trial judges in these cases.
Hydrofluosilicic Acid There are no chronic toxicity data on the
predominant
chemical, hydrofluosilicic acid and its sodium salt, used to fluoridate
American communities. Newly published studies (19) indicate a link
between
use of these chemicals and elevated level of lead in children's blood
and
anti-social behavior. Material from the authors of these studies has
been
submitted by them independently.
We believe the authors of these papers and their critics should be called
before a Select Committee to explain to you and the American people
what
these papers mean for continuation of the policy of fluoridation.
Changing Views on Efficacy and Risk In recent years, two prominent
dental
researchers who were leaders of the pro-fluoridation movement announced
reversals of their former positions because they concluded that water
fluoridation is not an effective means of reducing dental caries and
that it
poses serious risks to human health. The late Dr. John Colquhoun was
Principal Dental Officer of Aukland, New Zealand, and he published
his
reasons for changing sides in 1997 (20). In 1999, Dr. Hardy Limeback,
Head of
Preventive Dentistry, University of Toronto, announced his change of
views,
then published a statement (21) dated April 2000. I am submitting a
copy of
Dr. Limeback's publications.
We believe that Dr. Limeback, along with fluoridation proponents who
have not
changed their minds, such as Drs. Ernest Newbrun and Herschel Horowitz,
should be called before a Select Committee to testify on the reasons
for
their respective positions.
Thank you for you consideration, and I will be happy to take questions.
CITATIONS
1.Dental caries and dental fluorosis at varying water fluoride
concentrations. Heller, K.E, Eklund, S.A. and Burt, B.A. J. Pub. Health
Dent.
57 136-43 (1997).
2a. A brief report on the association of drinking water fluoridation
and the
incidence of osteosarcoma among young males. Cohn, P.D. New Jersey
Department
of Health (1992).
2b. Time trends for bone and joint cancers and osteosarcomas in the
Surveillance, Epidemiology and End Results (SEER) Program. National
Cancer
Institute. In: Review of fluoride: benefits and risks. Department of
Health
and Human Services.1991: F1-F7.
3.Neurotoxicity of sodium fluoride in rats. Mullenix, P.J., Denbesten,
P.K.,
Schunior, A. and Kernan, W.J. Neurotoxicol. Teratol. 17 169-177 (1995)
4a. Fluoride and bone - quantity versus quality [editorial] N. Engl.
J. Med.
322 845-6 (1990)
4b. Summary of workshop on drinking water fluoride influence on hip
fracture
and bone health. Gordon, S.L. and Corbin, S.B. Natl. Inst. Health.
April 10,
1991.
5. Effect of fluoride on the physiology of the pineal gland. Luke, J.A.
Caries Research 28 204 (1994). 6. Newburgh-Kingston caries-fluorine
study
XIII. Pediatric findings after ten years. Schlesinger, E.R., Overton,
D.E.,
Chase, H.C., and Cantwell, K.T. JADA 52 296-306 (1956).
7. WHO oral health country/area profile programme. Department of
Non-Communicable Diseases Surveillance/Oral Health. WHO Collaborating
Centre,
Malm†University, Sweden. URL: www.whocollab.odont.lu.se/countriesalphab.html
8. Letters from government authorities in response to inquiries on
fluoridation status by E. Albright. Eugene Albright: contact through
J. W.
Hirzy, P.O. Box 76082, Washington, D.C. 20013.
9. The effects of a break in water fluoridation on the development of
dental
caries and fluorosis. Burt B.A., Keels ., Heller KE. J. Dent. Res.
2000
Feb;79(2):761-9.
10. Toxicology and carcinogenesis studies of sodium fluoride in F344/N
rats
and B6C3F1 mice. NTP Report No. 393 (1991).
11. Effect of high fluoride water supply on children's intelligence.
Zhao,
L.B., Liang, G.H., Zhang, D.N., and Wu, X.R. Fluoride 29 190-192 (1996)
12. Effect of fluoride exposure on intelligence in children. Li, X.S.,
Zhi,
J.L., and Gao, R.O. Fluoride 28 (1995). 13. Chronic administration
of
aluminum- fluoride or sodium-fluoride to rats in drinking water: alterations
in neuronal and cerebrovascular integrity. Varner, J.A., Jensen, K.F.,
Horvath, W. And Isaacson, R.L. Brain Research 784 284-298 (1998).
14. Influence of chronic fluorosis on membrane lipids in rat brain.
Z.Z.
Guan, Y.N. Wang, K.Q. Xiao, D.Y. Dai, Y.H. Chen, J.L. Liu, P. Sindelar
and G.
Dallner, Neurotoxicology and Teratology 20 537-542 (1998).
15. Letter from Rebecca Hanmer, Deputy Assistant Administrator for Water,
to
Leslie Russell re: EPA view on use of by-product fluosilicic (sic)
acid as
low cost source of fluoride to water authorities. March 30, 1983.
16.Transcript of proceedings - Surgeon General's (Koop) ad hoc committee
on
non-dental effects of fluoride. April 18-19, 1983. National Institutes
of
Health. Bethesda, MD.
17. Recommendations for fluoride use in children. Kumar, J.V. and Green,
E.L.
New York State Dent. J. (1998) 40-47.
18. Highlights in North American litigation during the twentieth century
on
artificial fluoridation of public water supplies. Graham, J.R. and
Morin, P.
Journal of Land Use and Environmental Law 14 195-248 (Spring 1999)
Florida
State University College of Law.
19. Water treatment with silicofluorides and lead toxicity. Masters,
R.D. and
Coplan, M.J. Intern. J. Environ. Studies 56 435-49 (1999).
20. Why I changed my mind about water fluoridation. Colquhoun, J.
Perspectives in Biol. And Medicine 41 1-16 (1997).
21. Letter. Limeback, H. April 2000. Faculty of Dentistry, University
of
Toronto.
22.. Memorandum: Subject: Fluoride Conference to Review the NTP Draft
Fluoride Report; From: Wm. L. Marcus, Senior Science Advisor ODW; To:
Alan B.
Hais, Acting Director Criteria & Standards Division Office of Drinking
Water.
May 1, 1990.