The World Health Organization, after announcing a revision of its drinking water safety guidelines, has been asked to assess the toxic risks of the addition of industrial fluorides to drinking water. Fluoride is thought to protect against dental decay by hardening the outer coating of teeth, but it seems that adverse effects such as dental and skeletal fluorosis are widespread in areas where the mineral is naturally abundant or has been artificially added to the water supply.

VOICE of Irish Concern for the Environment, an environmental campaign group, submitted comments to the WHO asking that the toxic properties of industrial fluorides often added to drinking water be studied and their risks evaluated. Robert Pocock, a spokesman, says that "in Ireland, the government has for forty years added chemical fluorides to drinking water in compliance with the WHO Drinking Water guidelines" adding that these guidelines "have always been invoked to counter consumer concerns." According to a study of the Irish government, says Pocock, this policy "has resulted in (dental) fluorosis among 15 year olds increasing from 4% in 1984 to 36% in 2002 -- a nine-fold increase of an incurable but preventable condition".

Dental fluorosis or "mottling" is an unsightly discoloration of the teeth which indicates fluoride poisoning by overdose. The condition goes hand in hand with skeletal fluorosis - brittle and demineralized bones subject to fractures and deformation.

Babies are especially vulnerable to increased fluoride levels in drinking water and it is now recommended that mothers breast-feed their newborns or prepare baby foods with specially filtered or fluoride-free bottled water to avoid intoxication, as levels of fluoride in fluoridated drinking water exceed the fluoride content in breast milk more than a hundred times.

The Alliance for Natural Health, a pan-European and international alliance of scientists, health care practitioners, natural health care companies and consumers points out that the WHO's own guidelines for fluoridation of drinking water are currently recommending 1.5 mg per liter, a level known to induce fluorosis, which has been observed at fluoride levels in drinking water as low as 0.7 mg/liter.

Any positive effects of fluoridation in preventing dental caries, which incidentally are subject to scientific debate - many of the positive fluoride studies were generated by scientists on the Manhattan Project - must therefore be carefully weighed against the clearly overlapping toxic effects of the substance at the same or even lower doses.

"What is required" says Robert Pocock in the VOICE submission, "is comprehensive, independent and transparent toxicological testing and risk assessment of hexafluorosilicic acid and disodium hexafluorosilicate, the two most used fluoride chemicals in drinking water." These chemicals are toxic industrial waste products and are used primarily for their high solubility and low cost.

Robert Verkerk, Executive Director of the Alliance for Natural Health adds the Alliance is strongly opposed to artificial fluoridation of drinking water supplies. He urges the WHO to revise its existing guidelines and to start promoting strategies other than artificial fluoridation of water supplies for the reduction of dental caries. He also calls for evaluation of the toxicological evidence of the long-term safety of water fluoridation programmes as well as formal medicinal approval of artificial fluorides.


Submissions to the World Health Organization:

Here are the actual texts of two submissions to WHO:

Alliance for Natural Health (Download Word file) submission by Dr. Robert Verkerk.

VOICE of Irish Concern for the Environment
9, Upper Mount St. Dublin 2.
Phone 01-642 5741
e-mail avoice@iol.ie


Comment by VOICE of Irish Concern for the Environment on:

Rolling Revision of the WHO guidelines for drinking-water quality

Chemical safety of drinking-water: assessing priorities for risk management.

[References are to GDWQ Draft Chemical Safety of drinking water: assessing priorities for risk management.pdf 446kb].

Does this text respond to an issue of concern?:

Yes, of growing international concern.

Fluorosis which damages the teeth and bones and for which there is no cure (only prevention) affects millions of people around the world both in developing and developed countries.

Increased bio-availability of chemically produced fluorides worldwide has led to a dramatic increase in fluorosis over the past two decades and since drinking water is typically the most significant source of fluoride according to the WHO's Water-related diseases -- Fluorosis, an in-depth risk assessment is now urgently called for.

Some of the increase in fluoride poisoning may be due in part to conflicting advice issued by the WHO in the past. For example, in 1971 the WHO warned of the importance of considering the total daily fluoride intake by the individual; again in 1994, it alerted dental and public health administrators to the total fluoride exposure in the population. Yet those very few governments that have during this period dosed drinking water with artificial fluorides have notably failed to check the resultant fluoride exposure in their populations. In Ireland for example, the government has for forty years added chemical fluorides to drinking water in compliance with the WHO Drinking Water guidelines, indeed they have always been invoked to counter consumer concerns. This policy has resulted in (dental) fluorosis among 15 year olds increasing from 4% in 1984 to 36% in 2002 -- a nine-fold increase of an incurable but preventable condition.

Does this text compete or complement other publications in the area - if so which?

The text is not consistent with the WHO's Water-related diseases - Fluorosis which states that control of drinking-water quality is critical in preventing fluorosis. The same quoted WHO report also states that moderate-level chronic exposure to fluoride chemicals - at or near the current guideline value in addition to the multiple other sources of fluoride in food, water, air and toothpaste - cause fluorosis.

The text also fails to stress two other crucially important factors -- a person's general state of health and the body's ability to dispose of fluoride, both of which critically influence the health manifestations of an individual's fluoride exposure.

Another key contradiction with the same Fluorosis report is the threat of fluoride to newborns which it highlights as follows mothers in affected areas should breastfeed since breast milk is usually low in fluoride.

It is also at variance with a UNICEF Report Fluoride in water: an overview which details some of the most harmful effects of fluorides in drinking water, laying particular stress on the nutritional status of individuals and in particular of children; for example it is noted that a diet poor in nutrients such as calcium or magnesium increases the body's retention of fluoride.

Given that UNICEF aims to advance humanity through giving for every child Health, Education, Equality, Protection it is surprising that the GDWQ guideline value does not echo UNICEF's warnings of the increased vulnerability of children to fluoride.

It also fails to recognize the research evidence on the harmful effects of fluorides in drinking water published by the Irish Dept of Health in "Children's Oral Health in Ireland 2002" A North-South Survey coordinated by the Oral Health Services Research Centre, University College Cork. Ireland. This reveals that where drinking water contains chemical fluorides (fluorosilicic acid) the incidence of fluoride poisoning is more than twice as high as where drinking water does not contain it.

Everyday clinical evidence of Irish dentists supports the survey findings.

Moreover since there is virtually no naturally occurring fluoride in Irish drinking water, it only requires a simple policy decision to reverse this growing health threat.

It is inconsistent with the Report of the Centers for Disease Control in 1999 stating that if fluoride has any benefit to teeth, it is topical (by direct application) and not systemic (by ingestion), therefore it is not necessary to add it to drinking water.

It ignores the weight of evidence in numerous other supporting studies available on http://www.slweb.org/bibliography.html that demonstrate that long-term ingestion of fluoride has many chronic and deleterious effects on humans, especially newborns and children. The text entirely fails to acknowledge the inescapable health policy implications of this evidence.

Is the level of guidance and information provided inappropriate?

Given the doubts about the safety of fluoride in drinking water and the weight of evidence to the contrary, it is totally inappropriate to use the word guidance, particularly since public health is at risk.

The guidance as drafted is seriously defective on several other counts:

a. It fails to recognize the essential difference between naturally occurring mineral fluoride and the chemically derived forms. Each has very different bio-availablility, toxicity, persistence and bio-accumulation in humans, wildlife and soil.

b. Both historical and current scientific research on fluoride's action on the body contradicts the advice in the accompanying documents to which the GDWQ refers in particular.

c. It fails to explain the contradiction between the many governments who after extensive trials, disallow certain chemical forms of fluoride in drinking water versus the very few who do. Further it fails to either suggest possible reasons for this or draw the inescapable policy conclusions as they affect drinking water.

d. Given the industrial origin of chemically produced fluorides used to fluoridate drinking water and the industrial purposes for which the same chemical is intended, it is absurd for the GDWQ to suggest, as now drafted, that the same chemical fluorides could be considered nutrients in drinking water as alleged by the documentation referred to in b).

While sections of the text recognize the threat fluorides may pose to public health, the GDWQ as a whole is notably inconsistent. Under risk management for example in [2.1], since fluoride meets both key criteria of a priority chemical for inclusion -- long-term consumer exposure and significant hazards to health -- as shown above, why has the WHO not already carried out an assessment of the most widely used artificial fluoride, fluorosilicic acid?

Whereas the operational problems caused by fluoride are mentioned, the gravity of their health implications is not made clear; for example no mention is made of fluoride's secondary effects as when it combines with other minerals. Yet the conditions for such secondary effects occur every day in Irish public drinking water and no doubt elsewhere where artificial fluorides are present.

Firstly there is the risk of lead which the fluoride compound leaches from the still widely used lead pipes and/or lead-solder; second is the risk of fluoride complexing with the aluminium that is added as a flocculant chemical at the water treatment plants. The failure to fully recognize the reality of this fluoride-linked hazard effectively undermines all of the section [8.2.2. Coagulants].

Chapter 3.1 [Identifying priority chemicals in drinking water supply] recognizes that four priority chemicals - arsenic, fluoride, selenium and nitrate - produce adverse health effects. However no policy or administrative intervention, as recommended in [1.4], has been forthcoming from those few governments involved. The only policy response by the Irish government is to continue the deliberate addition of industrial fluorides albeit at a lower level.

Another reference to fluoride [in 4. Practical comments on selected parameters], accurately describes it as a chemical contaminant that must be considered adding because high fluoride levels in drinking-water are a major source of adverse health effects in some parts of the world.

While the general principles and strategies for identifying and managing risk for priority chemicals are sound, they are undermined by serious errors of fact and interpretation in accompanying fluoride documentation and in particular by Fluoride in Drinking-water. Background document for development of WHO Guidelines for Drinking-water Quality.

For these reasons the information as drafted is incapable of guiding policymakers on fluoride in drinking water intended for human consumption.

Are there major omissions that should be corrected?

In view of the above omissions on the parameter "Fluoride" a total revision is required if policymakers are not to be misled.

The key omission is the reality of the risk posed by fluorosilicic acid and similar industrial fluoride chemicals. And however much the accompanying documentation attempts to mask it, there is a fundamental error in the GDWQ suggestion that fluoride in drinking water is merely a naturally occurring mineral. The fact is that the fluorides added to drinking water are industrial-grade chemicals, often contaminated with other hazardous substances with toxicity and bio-availability many times greater than the naturally occurring form.

What is required therefore is comprehensive, independent and transparent toxicological testing and risk assessment of hexafluorosilicic acid and disodium hexafluorosilicate , the two most used fluoride chemicals in drinking water (used primarily for their high solubility and low cost).

Is there superfluous information that could be omitted?

Since much of the background information was co-authored by oral health advisers to the Irish government it is surprising that it ignores the current Irish evidence of the harmful effects of chemical fluorides among the Irish population. Due to this crucial omission much of the attached documentation, for instance that which alleges a nutrient role for fluoride in drinking water, is misleading and should be omitted from the GDWQ chemicals risk assessment.

Are there errors of fact or interpretation that should be corrected - if so what?

The whole thrust of the risk assessment as drafted is based on an inaccurate and false scientific profile of fluoride in drinking water therefore errors of interpretation will likely follow.

It is one thing to use drinking water, as the fluoridation promoters do, to deliver a fluoride dose to a whole community - it is another thing entirely to use the authority of WHO expert groups to allege that this intervention has a nutritional role when its function is primarily therapeutic.

Most at risk from such interventions are newborns who receive from one hundred to two hundred times more fluoride if fed water containing the WHO guideline value of 1 mgF/L, than they would if fed breast milk. Mothers in affected areas (i.e. where fluorosis is prevalent like Ireland) should be encouraged to breastfeed states the above quoted WHO report on Fluorosis. Since less than half of Irish newborns receive breast-milk which nature designed fluoride-free, the Irish government has much to do for newborns.

Additional comments.

Given the greatly increased levels of fluoride exposure in the population in 2004 versus 1994 and 1984 along with the growing evidence of the wide range of harmful effects of fluoride in the body, the GDWQ must highlight the fluorosis issue without further delay.

Industrial grade chemical fluorides must be assigned top priority for risk assessment which should be carried out not on the basis of misleading or uninformed comments such as those in the attached documentation but objectively, weighing all available evidence.

Faced with the growing manifestation of an incurable condition (fluorosis) among children at risk from industrial fluorides in drinking water, there is an irrefutable argument for risk assessment on fluorides to commence immediately and separately from the GDWQ rolling revision process.

The weight of scientific, epidemiological and clinical evidence is such that the WHO is now morally obliged to act on chemical fluorides, as it would do and be expected to do in the case of any other widespread chemical threat.

This is an opportunity for the WHO to draw a line under past contradictory, unscientific, unsafe and widely ignored advice on fluoride in drinking water and to replace it with guidelines that can command international respect as a meaningful safeguard of community and child health.

Dublin, Ireland 30th November 2004