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Volume 38, No. 2

Call to End Fluoridation

Fluoride Group's Letter to US Dept. of Health

Earlier this year, the U.S. Department of Health and Human Services (HHS) announced its recommendation to reduce the level of fluoride added to drinking water based on national survey data showing that 41% of American adolescents (ages 12-15) have dental fluorosis (a visible sign of fluoride toxicity).

In a Federal Register notice, the HHS solicited public comments on their recommendation. The Fluoride Action Network's submission to HHS is reproduced in full below.

To HHS and Honorable Secretary Sebelius,

In response to your request for comments on the recent change in your recommended level of fluoride added to community drinking water, I respectfully submit the following points supporting the stance that a reduction in fluoride levels is not sufficient, and that the United States should follow the approach of western Europe and end water fluoridation completely:

• Fluoride is not a nutrient, nor is it essential for healthy teeth. No study has ever revealed a diseased state resulting from lack of fluoride, including dental caries. (1,2) No American is, or ever was, “fluoride deficient.”

• Using the water supply to mass medicate the population is unethical. The public water supply should not be used as a drug-delivery system without regard for an individual's age, weight, health status, or knowledge of how fluoride will interact with other drugs they are taking. No informed consent is requested or given, and no medical follow-up is offered.

• The benefit and safety of ingested fluoride has never been proved by accepted medical standards. The HHS has failed to inform the public that there is not a single randomized controlled trial (the gold standard of medical research) that demonstrates the effectiveness of water fluoridation. (3) HHS has also failed to inform the public that the Food and Drug Administration has never studied, or approved, the safety of fluoride supplements and continues to classify all fluoride supplements as “unapproved new drugs.” (4, 5) Lastly, HHS has failed to inform the public that tooth decay rates have declined at the same general rate in all western, industrialized countries, irrespective of water fluoridation status. (6)

• Any benefits of fluoride are primarily topical, not systemic. The CDC has acknowledged this for over a decade (7). The Iowa Fluoride Study, funded by HHS, has reported little, if any, relationship between individual fluoride intake and caries experience. According to the study (the largest of its kind): “achieving a caries-free status may have relatively little to do with fluoride intake, while fluorosis is clearly more dependent on fluoride intake." (8)

• Americans will still be over-exposed to fluoride at 0.7 ppm. According to EPA’s recent documents “it is likely that most children, even those that live in fluoridated communities, can be over-exposed to fluoride at least occasionally. (9) At present, nearly 41% of American adolescents aged 12-15 have some form of dental fluorosis (10), an outwardly visible sign of fluoride toxicity. Reducing the fluoride levels to 0.7 ppm will not remedy this problem as national statistics clearly show that dental fluorosis remains significantly elevated at 0.7 ppm. (11) Drinking water is just one source of ingested fluoride; others include foods, beverages, dental products and supplements, pesticides and pharmaceuticals. For communities that practice artificial water fluoridation, this is the easiest source of fluoride to remove.

• Infants will not be protected. Infants fed formula made with fluoridated tap water—at the reduced level of 0.7 ppm—will still receive up to 175 times more fluoride than a breast-fed infant. In their supporting documents, EPA has not calculated the risks to the bottle-fed infant. In fact, infants from birth to six months of age were completely excluded from any consideration by EPA, despite HHS’s own admission that “The period of possible risk for fluorosis in the permanent teeth…extends from about birth through 8 years of age." (12) As the most susceptible subpopulation, the potential for long-term, irreparable damage to developing infants must be seriously considered, and should extend beyond just their teeth.

• African-American children and low-income children will not be protected. HHS’s reference (p. 2386) to the study by Sohn et al. (13) failed to mention that African-American and low-income children were found to consume significantly more total fluids and plain water, and thus receive more fluoride from drinking water, than white or higher-income children. African-Americans have been shown to have an increased risk of developing dental fluorosis, and are at higher risk for suffering from the more severe forms of this condition. (14) Despite receiving high intakes of fluoride, low-income and minority children living in fluoridated communities continue to suffer from rampant and severe dental decay (15-18)—undermining the common premise that fluoridation will prevent these problems. Additionally, low-income children have a greater risk for suffering from all forms of fluoride toxicity, as poor diet exacerbates the detrimental effects of fluoride. This is clearly, therefore, an environmental justice issue.

• HHS has failed to consider fluoride’s impact on the brain. Over 100 animal studies have observed fluoride-induced brain damage (19), 24 human studies have reported lowered IQ in children exposed to various levels of fluoride (20), and at least 6 other studies have found non-IQ neurological effects such as impaired visuo-spatial organization. (21-26) One study of 500 children in China observed reduced IQ at a water fluoride level of 1.9 ppm (27, 28) and another reported a reduction in IQ at even lower (mean=1.3 ppm) water fluoride levels. (29) HHS’s new recommendation of 0.7 ppm offers no adequate margin of safety to protect all of our children, including those with iodine deficiencies (30-32), from experiencing similar neurological damage.

• HHS has failed to consider fluoride as an endocrine disruptor. The 2006 NRC report (33) states that fluoride is an endocrine disruptor, and even at low levels can be detrimental to the thyroid gland. Pre- and post-natal babies, people with kidney disease, and above-average water drinkers (including diabetics and lactating women) are especially susceptible to the endocrine disrupting effects of fluoride in drinking water.

• HHS has failed to consider or investigate current rates of skeletal fluorosis in the U.S. According to EPA's supporting document (34), there is a general lack of information on the prevalence of stage II skeletal fluorosis in the U.S. Yet, many of the symptoms of stage II skeletal fluorosis (e.g. sporadic pain, stiffness of the joints) are identical to arthritis (35-40), which affects at least 46 million Americans. People with renal insufficiency are known to be at an elevated risk for developing skeletal fluorosis (33), as crippling stage III skeletal fluorosis with renal deficiency has been documented in the U.S. at water fluoride levels as low as 1.7 ppm. (41) Since skeletal fluorosis in kidney patients has been detected in small case studies, it is likely that systematic studies would detect skeletal fluorosis at even lower fluoride levels.

• HHS has failed to consider fluoride as a potential carcinogen. Bassin et al. (42) reported a significantly elevated risk of osteosarcoma in boys living in fluoridated communities, and thus fluoride may be a carcinogen. Chester Douglass, who has serious conflicts-of-interest concerning fluoride research, has stated that a subsequent study will refute these findings (43), but no publication has appeared in the five years since he made this claim. As EPA has still not completed carcinogenicity testing for fluoride, HHS should not support the addition of a potential carcinogen to our drinking water.

• HHS has failed to confirm the safety of silicofluorides. Despite being used in more than 90% of artificial water fluoridation schemes, no chronic toxicity testing of silicofluorides has ever been completed: “No short-term or subchronic exposure, chronic exposure, cytotoxicity, reproductive toxicity, teratology, carcinogenicity, or initiation/promotion studies were available” for the toxicological summary for silicofluorides, as prepared for the National Institute of Environmental Health Sciences. (44) However, recent epidemiological research has found an association between the use of silicofluoride-treated community water and increased blood lead concentrations in children (45) – a link that is consistent with recent laboratory findings. (46) HHS has failed to inform the American public that the fluoridating agent used in drinking water is a hazardous waste product from the phosphate fertilizer industry, and can be laced with arsenic and radionuclides, (47, 48) which are known carcinogens. HHS should not support the addition of a non-tested substance to our drinking water.

Most of the arguments listed above are covered in far more detail in the recently published book "The Case Against Fluoride" by Connett, Beck and Micklem (Chelsea Green, 2010). We urge director Sebelius to appoint a group of experts from HHS, who have not been involved in promoting fluoridation, to provide a fully documented scientific response to the arguments and evidence presented in this book. Were director Sebelius to do this we strongly believe that neither she nor these experts will want to see the practice of water fluoridation continue. The practice is unnecessary, unethical and hitherto the benefits have been wildly exaggerated and the risks minimized. A scientific response to this book from a HHS team would allow the public to judge the cases both for and against fluoridation on their scientific and ethical merits.


1. National Research Council. 1993. Health Effects of Ingested Fluoride. Washington, D.C.: National Academy Press. Page 30.

2. Letter from the Presidents of the National Academy of Sciences and the Institute of Medicine to Albert W. Burgstahler, Ph.D. and others. January 12, 1999. Online at

3. McDonagh M, Whiting PF, Wilson PM, Sutton AJ, Chestnutt I, Cooper J, Misso K, Bradley M, Treasure E, Kleijnen J. 2000. A systematic review of public water fluoridation. NHS Center for Reviews and Dissemination. University of York. Online at

4. Kelly JV. 1993. Letter from John V. Kelly, Assemblyman 36th District, New Jersey State Legislature, to Dr. David Kessler, M.D., Commissioner, United States Food and Drug Administration, Rockville, Maryland. June 3. Online at

5. Plaisier MK. 2000. Letter from Melinda K. Plaisier, Associate Commissioner for Legislation, Department of Health and Human Services, Public Health Service, Rockville, MD, to Honorable Ken Calvert, Chairman, Subcommittee on Energy and Environment Committee on Science, House of Representatives, Washington DC. December 21. Online at

6. Tooth Decay Trends in Fluoridated vs. Unfluoridated Countries. Fluoride Action Network. Online at

7. Centers for Disease Control and Prevention. 2001. Recommendations for using fluoride to prevent and control dental caries in the United States. MMWR 50(RR14):1-42. August 17. Online at

8. Warren JJ, Levy SM, Broffitt B, Cavanaugh JE, Kanellis MJ, Weber-Gasparoni K. 2009. Considerations on optimal fluoride intake using dental fluorosis and dental caries outcomes—a longitudinal study. J Pub Health Dent 69(2):111-5.

9. U.S. Environmental Protection Agency. December 2010. Fluoride: Exposure and Relative Source Contribution Analysis. EPA 820-R-10-015. Page 109. Online at

10. Beltrán-Aguilar ED, Barker L, Dye BA. 2010. Prevalence and severity of dental fluorosis in the United States, 1999-2004. NCHS data brief, no 53. Hyattsville, MD: National Center for Health Statistics. Online at

11. Heller KE, Eklund SA, Burt BA. 1997 Dental caries and dental fluorosis at varying water fluoride concentrations. J Public Health Dent. 57(3):136-43. Figure 4.

12. U.S. Department of Health and Human Services. January 2011. Proposed HHS recommendation for fluoride concentration in drinking water for prevention of dental caries. Federal Register 76(9):2383-8. Online at

13. Sohn W, Heller KE, Burt BA. 2001. Fluid consumption related to climate among children in the United States. J Pub Health Dent 61(2):99-106.

14. Beltrán-Aguilar E, Barker L, Dye BA. 2010. Prevalence and Severity of Dental Fluorosis in the United States, 1999-2004. NCHS Data Brief. Available online at:

15. Burt BA, Kolker JL, Sandretto AM, Yuan Y, Sohn W, Ismail AI. 2006. Dietary patterns related to caries in a low-income adult population. Caries Research 40(6):473-80.

16. Shiboski CH, Gansky SA, Ramos-Gomez F, Ngo L, Isman R, Pollick HF. 2003. The association of early childhood caries and race/ethnicity among California preschool children. J Pub Health Dent 63(1):38-46.

17. VVon Burg MM, Sanders BJ, Weddell JA. 1995. Baby bottle tooth decay: a concern for all mothers. Pediatric Nursing 21(6):515-9.

18. Barnes GP, Parker WA, Lyon TC Jr, Drum MA, Coleman GC. 1992. Ethnicity, location, age, and fluoridation factors in baby bottle tooth decay and caries prevalence of head start children. Public Health Reports 107(2):167-73. Online at

19. Connett P, Beck J, Micklem H S. 2010. The Case Against Fluoride. How Hazardous Waste Ended Up in Our Drinking Water and the Bad Science and Powerful Politics That Keep It There. Vermont: Chelsea Green Publishing. Appendix 1, online at

20. Fluoride and IQ: The Studies. Fluoride Action Network. Updated January 2010. Online at

21. Rocha-Amador D, Navarro M, Trejo-Acevedo A, Carrizales L, Pérez-Maldonado I, Díaz-Barriga F, Calderón J. 2009. Use of the Rey-Osterrieth Complex Figure Test for neurotoxicity evaluation of mixtures in children. Neurotoxicology 30(6):1149-54.

22. Li J, Yao L, Shao QL, Wu CY. 2004. Effects of high fluoride level on neonatal neurobehavioural development. Chinese Journal of Endemiology 23:464-465 (republished in Fluoride 41:165-70). Online at

23. Calderon J, Machado B, Navarro M, Carrizales L, Ortiz MD, Diaz-Barriga F. 2000. Influence of fluoride exposure on reaction time and visuospatial organization in children. Epidemiology 11(4):S153. Online at

24. Yu Y, Yang W, Dong Z, Wan C, Zhang J, Liu J, Xiao K, Huang Y, Lu B. 1996. Neurotransmitter and receptor changes in the brains of fetuses from areas of endemic fluorosis. Chinese J Endemiology 15: 257-259 (republished in Fluoride 41(2):134-8). Online at

25. Du L. 1992. The effect of fluorine on the developing human brain. Chinese Journal of Pathology 21(4):218-20 (republished in Fluoride 41:327-30). Online at

26. Han H, Cheng Z, Liu W. 1989. Effects of fluorine on the human fetus. Chinese Journal of Control of Endemic Diseases 4:136-138 (republished in Fluoride 41:321-6). Online at

27. Xiang Q, Liang Y, Chen L, Wang C, Chen B, Chen X, Zhou M. 2003. Effect of fluoride in drinking water on children’s intelligence. Fluoride 36(2):84-94. Online at

28. Xiang Q, Liang Y, Zhou M, Zang H. 2003. Blood lead of children in Wamiao-Xinhuai intelligence study. Fluoride 36(3):198-9. Online at

29. Ding Y, Gao Y, Sun H, Han H, Wang W, Ji X, Liu X, Sun D. 2010. The relationships between low levels of urine fluoride on children’s intelligence, dental fluorosis in endemic fluorosis areas in Hulunbuir, Inner Mongolia, China. J Hazard Materials doi: 10.1016/j.jhazmat.2010.12.097.

30. Ge Y, Niu R, Zhang J, Wang J. 2011. Proteomic analysis of brain proteins of rats exposed to high fluoride and low iodine. Archives of Toxicology 85(1):27-33.

31. Guan ZZ, Zhuang ZJ, Yang PS, Pan S. 1988. Synergistic action of iodine deficiency and fluorine intoxication on rat thyroid. Chin Med J 101(9):679-84.

32. Lin FF, Aihaiti, Zhao HX, Jin L, Jiang JY, Maimaiti, and Aiken. 1991. The relationship of a low-iodine and high-fluoride environment to subclinical cretinism in Xinjiang. Iodine Deficiency Disorder Newsletter 7(3). Online at

33. National Research Council. 2006. Fluoride in Drinking Water: A Scientific Review of EPA’s Standards. Washington, D.C.: National Academies Press. 507 pp. Online at

34. U.S. Environmental Protection Agency. December 2010. Fluoride: Dose-Response Analysis for Non-cancer Effects. EPA 820-R-10-019. Online at

35. Gupta R, Kumar AN, Bandhu S, Gupta S. 2007. Skeletal fluorosis mimicking seronegative arthritis. Scandanavian Journal of Rheumatology 36(2):154-5.

36. Savas S, Cetin M, Akdogan M, Heybell N. 2001. Endemic fluorosis in Turkish patients: relationship with knee osteoarthritis. Rheumatology International 21:30-5.

37. Hileman B. 1988. Fluoridation of water. Questions about health risks and benefits remain after more than 40 years. Chemical and Engineering News, 26-42. August 1.

38. Czerwinski E, Nowak J, Dabrowska D, Skolarczyk A, Kita B, Ksiezyk M. 1988. Bone and joint pathology in fluoride-exposed workers. Archives of Environmental Health 43:340-3.

39. Teotia SPS, Teotia M, Teotia NPS. 1976. Symposium on the Non-Skeletal Phase of Chronic Fluorosis: The Joints. Fluoride 9:19-24

40. Singh A, Jolly SS. 1970. Chronic toxic effects on the skeletal system. In: Fluorides and Human Health. World Health Organization. pp. 238-49..

41. Johnson WJ, Taves DR, Jowsey J. 1979. Fluoridation and bone disease. Pp. 275-293 in: Continuing Evaluation of the Use of Fluorides. E Johansen, DR Taves, and TO Olsen, eds. AAAS Selected Symposium. Boulder, CO: Westview Press.

42. Bassin EB, Wypij D, Davis RB, Mittleman MA. 2006. Age-specific fluoride exposure in drinking water and osteosarcoma (United States). Cancer Causes and Control 17(4):421-8.

43. Douglass CW, Joshipura K. 2006. Caution needed in fluoride and osteosarcoma study. Cancer Causes and Control 17(4):481-2.

44. Haneke KE and Carson BL. 2001. Sodium Hexafluorosilicate [CASRN 16893-85-9] and Fluorosilicic Acid [CASRN 16961-83-4]: Review of Toxicological Literature. Prepared for Scott Masten, Ph.D., National Institute of Environmental Health Sciences, Research Triangle Park, North Carolina. Contract No. N01-ES-65402. Online at

45. Coplan MN, 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.

46. Maas RP, Patch SC, Christian AM, Coplan MJ. 2007. Effects of fluoridation and disinfection agent combinations on lead leaching from leaded-brass parts. Neurotoxicology Sep;28(5):1023-31.

47. Hanmer R. 1983. Letter to Leslie A. Russell, D.M.D, from Rebecca Hanmer, Deputy Assistant Administrator for Water, US EPA. Mar 30, 1983. Copy of original letter at

48. Hazan S. 2000. Letter from Stan Hazan, General Manager, Drinking Water Additives Certification Program, NSF International; to Mr. Juan (Pepe) Menedez, State of Florida, Department of Public Health, Tallahassee FL. April 24. Online at

For informational purposes only - not intended as medical advice, diagnosis or treatment, nor an endorsement by the American Nutrition Association®. Use permitted for non-profit and non-commercial uses or by healthcare professionals in their practice, with attribution to Other use only with written ANA℠ permission. Views expressed are those of the author and not necessarily those of the ANA℠. Works by a listed author subject to copyrights as marked. © 2010 ANA℠