Health Canada's Embarrassing Report - National Health Federation

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FLUORIDE IN DRINKING WATER

By Health Canada
Public comments due Nov 27, 2009

Click here for report and details for submitting comments

In Sept 2009, Health Canada produced another one of those reports on fluoride that, like so many others, is more about protecting the fluoridation program than it is about protecting public health. This report is little different from other junk reports dished up by (or orchestrated by) the US government (DHHS, 1991) the Irish government (Fluoridation Forum, 2000); the UK government (MRC, 2002; South Central SHA, 2009); the Australian government (NHMRC, 1991, 1999, 2007) or the New Zealand government.

Even Alan Freeze and Jay Lehr in their recent book Fluoride Wars, which is otherwise heavily slanted towards a pro-fluoridation position, do at least concede this point when they wrote:

"There is one anti-fluoridationist charge that does have some truth to it. Anti-fluoride forces have always claimed that the many government-sponsored review panels set up over the years to assess the costs and benefits of fluoridation were stacked in favor of fluoridation. A review of the membership of the various panels conform this charge. The expert committees that put together reports by the American Association for the Advancement of Science in 1941, 1944 and 1954; the National Academy of Sciences in 1951, 1971, 1977 and 1993; the World Health Organization in 1958 and 1970; and the US Public Health Service in 1991 are rife with the names of well-known medical and dental researchers who actively campaigned on behalf of fluoridation or whose research was held in high regard in the pro-fluoridation movement.59 Membership was interlocking and incestuous." (p.156)

I expected something more honest from the Canadians. However, Health Canada appears to have been captured by the dental lobby, just like the rest of these governments, and even more blatantly so in the shape of the infamous Dr. Peter Cooney, their Chief Dental Officer. Peter Cooney holds a position with the FDI (World Dental Federation). The FDI is industry funded. Its funders include Colgate Palmolive, GlaxoSmithKline, Johnson & Johnson, Procter & Gamble, Wrigley, and Unilever - see http://www.fdiworldental.org/congress/5_0corporate.html

The FDI is really a trade association for all the world's national dental associations. In their own words, "The FDI is the unified voice of oral health professionals around the world." The FDI has strong ties with the WHO and has been pushing fluoridation since 1951. Most recently in Geneva in 2006, the FDI joined forces with the IADR and the WHO, in declaring that "access to fluoride" should be considered as a basic human right! (See Global Consultation on Oral Health through Fluoride, 17-19 November 2006 / Geneva,Switzerland, http://www.fdiworldental.org/public_health/3_2fluoride.html).

So in the push to fluoridate the world, Dr. Peter Cooney appears to be the FDI's front man in Canada, but paid to be so by the Canadian taxpayer. In the process of pushing and defending fluoridation this man has made some horrendous statements. In Dryden, Ontario on April 1, 2007 (I was at the meeting), on the safety of fluoridation, he told citizens that "I walked down your high street today and I didn't see anybody growing horns - and Dryden has been fluoridated for 40 years!" On dental fluorosis he told officials in Thunder Bay that children and adults like dental fluorosis because it gives them very white teeth - or words to that effect.

Any way, back to the Health Canada report, Fluoride in Drinking Water, prepared by the Federal-Provincial-Territorial Committee on Drinking Water for Health Canada. This 94-page report concluded that the 1.5 ppm drinking water standard is safe and should remain unchanged. The report is sloppy, superficial, selective, biased and clearly designed to protect the fluoridation program at all costs. In short, it should embarrass any Canadian who believes that Health Canada's policies are based on sound science and are bound by scientific integrity.

These are harsh words and I don't use them lightly. But it is very clear that this whole "product" was a fix from the very beginning. The first step in the process was the selection of an "expert panel" to review the literature. Let's look at the composition of that panel:

Steven M. Levy, Iowa College of Dentistry

Christopher Clark, University of British Columbia

Robert Tardiff, University of Montreal

Michael Levy, Institut National de Santé Publique du Quebec

Jayanth Kumar, New York State Department of Health

Albert Nantel, Institut National de Sante Publique du Quebec

This perhaps was the most blatantly biased panel that could have been selected for this task. Four of the panelists (Steven Levy, Chris Clark, Michael Levy and Jay Kumar) are dentists and well-known promoters of fluoridation. Three of them have received large amounts of money from government sources for their research on fluoride. While they have done some good research, and found results which clearly contradict the effectiveness of fluoridation, they are careful not to say so too loudly. When required to do so they continue to endorse fluoridation publicly. It is all part of the gravy train of keeping government money coming into their research programs. Just as this excercise appears to be. It is not clear that either of the other two panelists (Nantel and Tardiff) have written anything on fluoride before. So even if they set out to do an objective job, it is hard to believe that they could have mastered this subject in a way that could bring them close to the the quality of the review conducted by the US National Research Council (NRC, 2006). This took 12 panelists three and half years to produce. These six panelists met for one day!

A fifth panel member (Albert Nantel) is a colleague of Michael Levy and comes from the same pro-fluoridation institute. Two of the panelists (Michael levy, and Robert Tardiff) had already written, or were in the process of writing, a pro-fluoridation review for the same Institut National de Sante Publique du Quebec, and a third (Albert Nantel) was acknowledged for his help in writing that report. This report was entitled Water Fluoridation: An Analysis of the Health Benefits and Risks, and was published in June 2007. This report can be accessed at http://www.inspq.qc.ca/pdf/publications/705-WaterFluoration.pdf

Perhaps the most shocking omission from this "expert" panel - whose selection could have offered a morsel of balance to the process - was Dr. Hardy Limeback. Both Limeback and Kumar served on the NRC (2006) panel that produced the 507-page landmark review Fluoride in Drinking Water: A Scientific Review of EPA's Standards. Incredibly, Health Canada selected Kumar from New York, over Limeback from Toronto. There is one obvious reason for that preference. Kumar is avidly pro-fluoridation and Limeback is now, after intensely reviewing the literature, opposed to fluoridation. There is no question which one is the more qualified. Limeback has both a DDS and a PhD in biochemistry and was the former President of the Canadian Association for Dental Research. Limeback also teaches in the department of Preventive Dentistry at the University of Toronto and has his own dental practice. Kumar is a state bureaucrat whose main task is to promote fluoridation (oops I mean "oral health").

Not unexpectedly this panel delivered its support for fluoridation in a skinny five-page report which was published on the Health Canada website in April, 2008 - available at http://fluoridealert.org/canada.expert.panel.2008.pdf). Can there be any doubt that this was no more than a cynical self-fulfilling prophecy orchestrated by the pro-fluoridation lobby within Health Canada? Citizens are trying to find out more about the process in which these six panelists were selected to do this job. My hunch is that they were handpicked by Cooney to do precisely the job that they did.

This panel met in Ottawa in January, 2007, and their report was published on Health Canada's website at the time there was an intense debate going on about whether Hamilton, Ontario, would stop fluoridating its water. Here are some excerpts from their 5-page report:

"The Expert Panel was asked to provide expert advice and to make recommendations to Health Canada and the Federal-Provincial-Territorial Committee on Drinking Water (CDW) regarding fluoride in drinking water. Advice was sought from the Expert Panel on five specific issues of concern:

Total Daily Intake of Fluoride;

Dental Fluorosis;

Other Health Effects;

Risk Assessment; and

Drinking Water Fluoridation: Risks and Benefits

"The Expert Panel reached a consensus on all key issues identified, and its main conclusions and recommendations to Health Canada and the Federal-Provincial-Territorial Committee on Drinking Water on each issue are provided below…

"Fluoride - Other potential health effects

"Conclusions/Concerns:

"Skeletal fluorosis: The primary functional adverse effect associated with excess fluoride intake (after dental fluorosis) is still skeletal fluorosis (milder forms), likely to occur at about 10 mg/day after 10 or more years of exposure. Definitions of the different stages of skeletal fluorosis should be developed.

"Cancer: Weight of evidence does not support a link between exposure to fluoride and increased risks of cancer. It is important to avoid any generalization and overinterpretation of the results of the Bassin et al. paper and to await the publication of the full study before drawing conclusions and particularly before influencing any related policy. In addition, there is supplemental negative evidence from the 2005 NTP study, even with higher levels of fluoride than the original 1992 (sic, it was 1990) NTP study.

"Intelligence Quotient: - Weight of evidence does not support a link between fluoride and intelligence quotient deficit. There are significant concerns regarding the available studies, including quality, credibility, and methodological weaknesses such as the lack of control for confounding factors, the small number of subjects, and the dose of exposure.

"Bone fracture: Studies that do not control for confounding factors, such as intake of calcium, fluoride, or vitamin D supplements, intake of other medication, or consideration of traumatic fractures, should be interpreted cautiously.

"Immunotoxicity, reproductive and developmental toxicity, genotoxicity and neurotoxicity: Weight of evidence does not support a link between exposure to fluoride in drinking water at 1.5 mg/L and any adverse health effects regarding immunotoxicity, reproductive/developmental toxicity, genotoxicity and/or neurotoxicity.

"Recommendations:

"Weight of evidence does not support modifying the current Health Canada position/opinion on the carcinogenicity of fluoride. Policy decisions should not be based on the Bassin et al. (2006) paper.

"The current Maximum Acceptable Concentration (MAC) of 1.5 mg/L of fluoride in drinking water is unlikely to cause adverse health effects, including cancer, bone fracture, immunotoxicity, reproductive/developmental toxicity, genotoxicity, and/or neurotoxicity." http://www.hc-sc.gc.ca/ewh-semt/pubs/water-eau/2008-fluoride-fluorure/index-eng.php

Since this report summary appeared on the Health Canada web site, Health Canada has published a full report on fluoridation, in September 2009, which is the subject of this bulletin.

This final report relies heavily on the findings of this "expert panel."

Because this bulletin is already rather long, let me focus on just one health issue here: the lowering of IQ in children.

In the written report submitted by one of the expert panelists Dr. Robert Tardiff, a toxicologist, only two short paragraphs are spent reviewing IQ studies. He cites only two studies: Li et al., 1995 and Xiang et al., 2003. He refers to the NRC (2006) report but manages to miss the fact that the NRC reviewed five studies (and six if you include the Lin et al. 1991 study on the thyroid). Even with this very limited review of IQ studies, Tardiff did cite Xiang's bottom line: "In endemic fluorosis areas, drinking water fluoride levels greater than 1.0 mg/L may adversely affect the development of children's intelligence." You might think that was a pretty devastating finding if your charge was to review the safety of a standard set at 1.5 ppm. How were Tardiff and the other five panel members going to wriggle out of this?

We have seen how they did this above, they claimed that:

"Intelligence Quotient: - Weight of evidence does not support a link between fluoride and intelligence quotient deficit. There are significant concerns regarding the available studies, including quality, credibility, and methodological weaknesses such as the lack of control for confounding factors, the small number of subjects, and the dose of exposure."

What "weight of evidence" are we talking about here? Tardiff only looked at two studies. No studies were cited which did not find an association between fluoride exposure and lowered IQs. So what studies are these two studies being weighed against? Answer: they were being weighed against continuing support for the fluoridation program!

Now, we know there have been 23 studies that have found this association (one from Iran, one from Mexico, one from India and 20 from China). We also know that there has been one small study in New Zealand which did not find this association. 23 to 1 is not looking too good for a weight of analysis in favor of continuing the fluoridation program. In addition, there have been three studies which have found an association between fetal brain damage in aborted fetuses in endemic fluorosis areas in China and over 50 animal studies which have found that fluoride damages the brain and alters behavior, starting with the classic paper from Mullenix et al. (1995) over which she was fired!

All the citations to the brain studies can be found at http://fluoridealert.org/brain/ and http://fluoridealert.org/iq.studies.html

Were Tardiff and the other 5 panel members unaware of the other human studies? Hard to believe because several had been published before January 2007. Maybe they weren't looking to hard.

If Hardy Limeback had been on this panel he would certainly have drawn attention to the other IQ studies. Probably one of the reasons he was not on the panel. He knows the literature too well!

What about the Health Canada team, were they unaware of the other IQ studies? Hardly. The Fluoride Action Network and the International Society for Fluoride Research organized a back-to-back conference right under their noses in Toronto, in August of 2008 - nearly a year before the Health Canada (2009) report was published. OK so Health Canada didn't bother to send someone to the conference. That won't do. FAN, with the help of local citizens, organized a media conference in Toronto where Dr. Vyvyan Howard and I spoke specifically about these 23 IQ studies. This media conference got major TV, radio and press coverage in Canada. FAN made links to all 23 IQ studies available on its home page. In other words these studies were not difficult to find, even for a bumbling state bureaucrat. In addition, the journal Fluoride printed 19 Chinese studies on the brain (which FAN had had translated), including some of the IQ studies, a couple of the animal studies and the three studies on fluoride's impact on fetal brain.

By September 2009, Health Canada had a great deal of published literature on which they could do a really decent "weight of evidence" analysis. This included three meta-analysis, and one presented by Dr. Limeback as a poster at the International Association for Dental Research (IADR) conference in - guess where? - Toronto!

What kind of updated "weight of analysis" did Health canada publish in September 2009?

They review only 5 of the 23 IQ studies. They state on page 36,

"The impact of fluoride exposure on children's intelligence quotient (IQ) was measured in several studies in China (Li et al, 1995; Zhao et al., 1996; Lu et al., 2000; Xiang et al., 2003 and Wang et al., 2007) [note they have missed out the studies from Mexico, Iran and india and the other 15 studies from China, as well as the three fetal brain studies and the three meta-analyses, PC] As discussed later in this section, these studies are controversial and therefore need to be interpreted cautiously."

Why are these studies controversial do you think? Is it because if they are given any validity they could wreck the fluoridation program? Is it interesting to contrast how cautiously we must view these IQ findings with the way this government agency throws caution to the wind and continues to sanction Canadian babies' brains being dosed with fluoride at levels (in Canada) up to 200 times higher than the level in mothers' milk, with every bottle of baby formula (made up with fluoridated water) they drink!

Wouldn't you think that these experts at Health Canada who know so much about the methodological flaws in these epidemiological studies, would have designed a really superb and flawless IQ study and carried it out in Canada? Have they done that? NEVER. How cautious is that? The absence of study does not mean absence of harm. As long as Canada and the other fluoridating countries do not bother to do any IQ studies these 23 studies have to be taken seriously. At the very least they are waving a large red flag.

Health Canada continues:

"These studies were recently reviewed by the Expert Panel on fluoride convened by Health Canada in 2007. Despite the consistency in the results from these studies, the committee agreed that the weight of evidence does not support a link between fluoride and IQ deficit... These studies performed in China were also reviewed by other organizations and/or committees, which also mentioned that the significance of these studies is uncertain (ICPS, 2002; ATSDR, 2003; NRC, 2006)."

NOTE:

The ICPS (actually WHO) 2002 review only considered two studies: Li et al., 1995 and Zhao et al., 1996. http://www.inchem.org/documents/ehc/ehc/ehc227.htm
The ATSDR 2003 review only considered three IQ studies (Li et al., 1995; Zhao et al, 1996; Lu et al., 2000), one behavioral study (Morgan et al., 1998) and an abstract from a paper from Mexico which indicated a decrease in visuospatial organization (Calderon, et al., 2000). http://www.atsdr.cdc.gov/toxpro../files/tp11.pdf
The NRC, 2006 review only considered five or six studies: Li et al, 1995; Zhao et al., 1996; Lu et al., 2000; Xiang et al., 2003 a and b and Lin et al., 1991 (considered under lowered thyroid function). http://www.nap.edu/catalog.php?record_id=11571

If this was an honest exercise, especially when using the phrase "weight of analysis", one would have expected that Health Canada would have gone forward from the date of the "expert panel" not backwards to previous reviews, with even fewer studies available to them. If they had gone forward and done just a moderate amount of research they should have found the other 18 studies which they somehow managed to "overlook."

This is just one health issue outrageously covered by this Health Canada review. There are others. It is an embarrassing scandal.

Public Comments on Fluoride in Drinking Water are due by November 27, 2009.

If you live in Canada:

1) Carole Clinch, Research Coordinator for People for Safe Drinking Water in Ontario, suggests that people submit commentary to Health Canada and the Ontario Ministry of the Environment using any or all of the following material:

Letter: Health Canada's review, Fluoride in Drinking Water, is Inaccurate and Unacceptable
Response to Health Canada 2009 Review
Omissions

And EMAIL to:

CDW Secretariat water_eau@hc-sc.gc.ca [CDW = Federal-Provincial-Territorial Committee on Drinking Water, authors of report]
Satish Deshpande Satish.deshpande@ontario.ca [Ontario Ministry of Environment, Department of Drinking Water Standards]
Minister, MOE minister.moe@ontario.ca [Ontario Ministry of Environment]
Environmental Commissioner of Ontario commissioner@eco.on.ca

If any group wishes to sign the letter, please contact Carole Clinch at caclinch@gmail.com

2) Please write to your MP and ask him to raise questions about this report in parliament. Specifically, ask him to find out who selected this biased panel? Let him or her know how embarrassing this process and this report is for Canada's reputation for honesty and fairness. You might choose to attach this bulletin so you don't have to spell out all the arguments again. Copy the Prime Minister. Also the leaders of the other major parties.

Please send us a copy of what you send, so that we can share some of the most powerful letters with all our readers. Be angry but also be polite. I urge you not to stray to other reasons for opposing fluoridation. Focus here on the dreadful bias of this report and the hold that the undue influence that dental lobby control has over Health Canada on this matter.

Paul Connett

* The full 5-page Expert panel report

• The full 94-page Health Canada report