APRIL 2004

Eu SEMINAR ON fluoridation of DRINKING WATER, Brussels, 27-28 October 2003
National Pure Water Association Submission Paper
for Consideration by Members of the Task Groups on Chemical Parameters,
Materials in Contact with Drinking Water,
and Risk Approach for Drinking Water

INTRODUCTION Although Lead in a water supply may be below the MCL, any deliberate introduction of any Lead complex in any amount into that drinking water would be a violation of the Drinking Water Directive. The MCL [Maxium Concentration Level] for contaminants in the Drinking Water Directive are not licences to contaminate up to those levels.

Fluorides are contaminants in drinking water. The current MCL of 1.5 mg/l is not a licence to contaminate up to that level. Furthermore, the suggestion that a Government or health authority may contaminate up to a level of 1 mg/l for artificial water fluoridation schemes is an extraordinary violation which is against the spirit of the Drinking Water Directive.

The artificial fluoridation agents named in the Drinking Water Directive (DWD) - hexafluorosilicic acid and disodium fluorosilicate- do not contribute to the potability or aesthetic quality of drinking water. They are not water treatment chemicals. They are added to drinking water with the express intention of creating biological change in humans. There is widespread concern among the peoples of the United Kingdom and the Republic of Ireland regarding the addition of fluoridation chemicals to the public drinking water supplies. These concerns have been routinely ignored by the respective Governments for four decades in the pursuit of a reduction in tooth decay in children. The People's Concerns include:
1.. The susceptibility of Children to toxic substances in the environment (including drinking water.). 2.. The Toxicity of Fluorides in Drinking Water.
3.. The Prevalence of Dental Fluorosis; Biomarker in Children.
4.. Failure to apply the "Precautionary Principle".
5.. Violations of The Charter of Fundamental Rights of the European Union, 2000.:
.The Susceptibility of Children to Toxic Substances in the Environment (including drinking water.). The Toxicological Profile for Fluorine, Hydrogen Fluoride and Fluorides (US Agency for Toxic Substances and Disease Registry, 2001, Draft), states

Children's Susceptibility (Section 3.7) Children are not small adults. They differ from adults in their exposures and may differ in their susceptibility to hazardous chemicals. Children's unique physiology and behavior can influence the extent of their exposure. Approximately 99% of the body's fluoride is found in calcified tissues. Chronic exposure to high levels of fluoride results in bone thickening and exostoses (skeletal >fluorosis). Because of the dynamic nature of growing bone, it is likely that children will deposit more fluoride in bone than adults consuming an equal amount of fluoride. However, it is not known if children would be more susceptible to skeletal fluorosis than adults. Children and adults may differ in their capacity to repair damage from chemical insults. Children also have a longer remaining lifetime in which to express damage from chemicals; this potential is particularly relevant to cancer.Other factors that can influence a child's vulnerability . . . circulatory flow rates are generally higher in children, which may increase a child's susceptibility to toxic effects. A child is not an adult, but most toxicological data are based on occupational exposures for adults. Most of the available information on biomarkers, interactions, and methods for reducing toxic effects is from adults and mature animals; no child-specific information was identified, with the exception of biomarker data. Because dental fluorosis is a response to fluoride exposure during the pre-eruptive maturation of teeth, only children are susceptible to this effect.

Dental Fluorosis is the biomarker of chronic fluoride toxicity. :. The Toxicity of Fluorides in Drinking Water. The Chemical Parameters position paper (4.3 Fluoride: stricter value for artificial fluoridation) refers to Dental Fluorosis as "a cosmetic effect [which] is observed in [a] sensitive sub-group of the population." It further states: "As naturally occurring fluoride is difficult to remove and the effect observed has probably no health consequences, the limit value of 1.5 mg/l (for natural fluoride) seems to be reasonable. "Neverless, the lower value (1.0 mg/l) recommended for artificially fluoridated drinking water (supplemented with fluoride to prevent caries) could also be justified as a compromise between caries prevention and dental fluorosis prevention." [Emphases added.].

The World Health Organisation is well aware of the dangers of over-exposure to fluorides. In the Conclusion to its 1994 Monograph, "Fluorides and Oral Health", the WHO stated: "Dental and public health administrators should be aware of the total fluoride exposure in the population before introducing any additional fluoride programme for caries prevention." Notwithstanding this warning, no Government health department of ANY country which artificially fluoridates its drinking water conducts - or has conducted - tests to determine the total fluoride exposure in the populations receiving artificially fluoridated drinking water. Therefore, the WHO advice is routinely ignored and, according to the UK Government's recent systematic scientific review of world studies

(1), Dental Fluorosis is seen in 48% of people living in fluoridated areas, with 12.5% of the people exhibiting Dental Fluorosis "of concern". Dental fluorosis occurs exclusively in children, during enamel formation of the teeth. It is a permanent condition for which there is no cure. Governments regard Dental Fluorosis as "a classic public health trade-off" for fewer cavities. In a paper published in the International Journal of Dental Research, 1989/90 Special Edition, Vol. 69, Professor D.M. O'Mullane of Cork Dental School, Ireland, stated that 50% of children living in fluoridated areas have dental fluorosis. In another paper published in the same Journal, Dr. Gary M. Whitford expressed the need to regulate the intake of fluoride.. "There is a growing body of evidence which indicates that the prevalence of dental fluorosis is increasing in both the fluoridated and non-fluoridated regions of the U.S . . . This trend is undesirable for several reasons: 1.. It increases the risk of aesthetically objectionable enamel defects (dental fluorosis); 2.. 3.. in severe cases it increases the risks of harmful effects to >dental function; . . .

2.)1 Dental Fluorosis is Visible Evidence of Fluoride Intoxicatio "With few exceptions the biochemistry of fluorine [fluoride] emphasizes its toxic features. The production of endemic dental fluorosis (mottled enamel) in human beings by drinking water is an outstanding example of the toxic effect of the excessive intake of the element." McClure, FJ, Ingestion of fluoride and dental caries, American Journal Diseases of Children 66: >362-369. 1943. "Mottled enamel is an endemic hypoplasia of permanent teeth produced by toxic quantities of fluoride in drinking water. . . . There is a direct quantitative relation between the fluoride content of drinking water and clinical manifestations of dental fluorosis." - McClure, FJ. Dental fluorosis is characterized by mottling and erosion of the enamel. Only children are susceptible since their teeth are still developing. Taber's Cyclopedic Medical Dictionary, 19th Edition, 2001 defines Fluorosis as: Chronic fluorine poisoning, sometimes marked by mottling of tooth enamel. It may result from excessive exposure to fluorides from dietary, waterborne, and supplemental sources. The Concise Oxford Dictionary, (Eighth edition, 1993) defines Fluorosis as poisoning by fluorine or its compounds. Therefore, drinking water fluoridation, however well-intentioned, is the indiscriminate poisoning of children, evidence for which, dental fluorosis, is the biomarker.

Proponents of fluoridation and Government advisers routinely dismiss dental fluorosis as unimportant - "merely a cosmetic issue". Professor Trevor Sheldon, MSc, DSc, FmedSci, of the NHS Centre for Reviews and Dissemination at the University of York, has written of his concern that the results of the York Review(1) were (and are) being widely misrepresented by the British Dental Association, the British Medical Association, the British Fluoridation Society and the National Alliance for Equity in Dental Health. One of the points of contention was whether dental fluorosis could be categorised as "just a cosmetic effect". On 3 January 2001, Prof. Sheldon wrote: The review found water fluoridation to be significantly associated with high levels of dental fluorosis which was not characterised as "just a cosmetic issue" . . . The review did not show water fluoridation to be safe. The quality of the research was too poor to establish with confidence whether or not there are potentially important adverse effects in addition to the high levels of fluorosis. The report recommended that more research was needed . . . There was little evidence to show that water fluoridation has reduced social inequalities in dental health.

3.) The Prevalence of Dental Fluorosis The following Table shows early examples of the prevalence of dental fluorosis occurring in naturally fluoridated areas before the widespread use of supplementation, toothpastes, fluorinated medications, anaesthetics, fluorinated pesticides, herbicides and air pollution, etc. Fluorine in drinking water: Its effect on dental caries, Journal of the American Dental Association 36: 28-36 1948. In 1993, The Health Effects of Ingested Fluoride (USPHS/NAS review of >studies) found dental fluorosis to range from 22% to 84% in fluoridated and non-fluoridated areas. This indicates that populations are seriously over-exposed to toxic levels of fluorides from a variety of sources. In 2000, the Newcastle NHS Trust found that the prevalence of dental fluorosis among 8 - 9-year-old children in fluoridated Newcastle was 54%. They also found that in "fluoride-deficient" Northumberland, 23% of 8 - 9-year-old children have dental fluorosis. They concluded that the prevalence of "aesthetically important" dental fluorosis in the fluoridated area was 3% - six times higher than was found in the non-fluoridated area, >where 0.5% of the children were affected. This indicates that the incidence of dental fluorosis more than doubled in the fluoridated area with a 6-fold increase in "aesthetically important" dental fluorosis.

4.) Failure to apply the Precautionary Principle. Drinking water fluoridation is indiscriminate treatment of populations which has visible adverse effects at levels as low as 0.1 mg/l. The Precautionary Principle is routinely ignored and the poisoning of children is widespread in England and Ireland. It should be noted that:
a.). fluorides (fluorosilicates) are added to drinking water with the intention of creating biological change in humans - especially young children.
b.). neither fluorides nor fluorosilicates are water treatment chemicals.
c..) neither fluorides nor fluorosilicates contribute to the purity or wholesomeness of drinking water. d.). fluorides delivered via the public drinking water supply are uncontrollable because they are regulated only by the degree of thirst of the individual, the amount of water used in the preparation of food at home and in food manufacturing processes and exposures via bathing and showering (dermal absorption is recognised by toxicologists as an important exposure route).
e..) f..) Little is known about the long-term health consequences of chronic childhood intoxication from exposures to fluorides in drinking waters and from the wide variety of other sources available today. The only toxicological effect acknowledged by the World Health Organisation, the Governments of the United Kingdom and the Republic of Ireland is dental fluorosis, which now affects approximately half of the children living in fluoridated areas and up to 23% of those living in non-fluoridated areas.
g..) Presently, we can safely assert that, from the Newcastle NHS Trust study and the York Report and other peer-reviewed studies from around the world, that raising the level of fluoride in water to 1 part per million - 1.0 mg/l - currently doubles the incidence of fluoride poisoning and is a foreseeable event.

It is, therefore, a very harmful act by Governments and water companies on Children.
a..) The harmful effects of dental fluorosis extend beyond tooth disfigurement and possible loss of dental function. A body of scientific evidence shows that dental fluorosis can affect the psychological well being of both children and adults.
h..) i..) Dental fluorosis is visible as soon as the secondary teeth erupt. While developing social and early life skills, children are at their most vulnerable to the psychological impact of discrimination. (See enclosure, "The Public Perception of Dental Fluorosis; the crucial issue?".).

. Artificial water fluoridation is the imposition of
1.. a "public health measure" which authorities know will affect at least ten percent of children, who will exhibit symptoms of poisoning;
2.. a "public health measure" which authorities know produces a foreseeable condition which causes psychological pain and suffering to a significant subset of the population, particularly children;
3.. a "public health measure" which creates a significant subset of the population that is vulnerable to social discrimination.

Violations of the Charter of Fundamental Rights of the European Union, 2000. Article 3, Right to the integrity of the person, states:
1.. Everyone has the right to respect for his or her physical and mental integrity.
2.. In the fields of medicine and biology, the following must be respected in particular: the free and informed consent of the person concerned, according to the procedures laid down by law . . .

Artificial water fluoridation is a denial of
1.. the individual's right to respect for his or her physical and mental integrity;
2.. the right of individuals to refuse treatment which they neither want nor need;
3.. the right of a significant subset of children not to be poisoned.

The Drinking Water Directive must not permit Fluorides to be deliberately introduced into public drinking water supplies for any reason.
1. McDonagh MS, Whiting PF, Wilson PM, Sutton AJ, Chestnutt I, Cooper J, Misso K, Bradley M, Treasure E, Kleijnen J. A systematic review of water fluoridation, Report 18, NHS Centre for Reviews and Dissemination, University of York, 2000.
NATIONAL PURE WATER ASSOCIATION'S Admin Office: Rose Court, 180 Milton Road, Hoyland, Barnsley, S. Yorkshire, S74 9BW Phone: 01226 360909
Email: Registered in England & Wales, No: 3366087 Registered office: Croft End, Lowick Bridge, Cumbria LA12 8EE
A not for profit Company This document may be freely copied