An Open Letter To The Junior Minister for Health

Hot Press has put various questions and concerns in relation to the policy of mandatory fluoridation of the water supply in Ireland to the Department of Health over the past several weeks. In particular, a series of questions was sent to the Department on the morning of March 4, with a request for a reply by close of business on March 7. No reply was received, nor was the communication even acknowledged by the department.

Against that background, Hot Press believes that it is appropriate to present all of the relevant questions via this Open Letter to the Minister in charge of fluoridation policy, Alex White. We are hereby requesting answers to the questions, which are set out below and which cover the areas dealt with in the questions already submitted, and some additional queries besides.
We are asking these questions in the belief that (a) there is a very serious issue of public health at stake; (b) there is a growing body of evidence that the policy of fluoridation of the water supply is unsafe; (c) the Department of Health has not given sufficient weight to this evidence; (d) in general, the authorities here are negligent in their failure to carry out the research necessary to test the systemic effects of the policy of fluoridation in Ireland as envisaged by S.6 of the 1960 Fluoridation Act; and (e) that the public has a right to know the answers to the questions which we are posing.
There is no valid reason why the Department of Health would refuse to answer our queries. Let us hope that they do so sooner rather than later.

LONG-TERM CONSUMPTION OF FLUORIDATED TAP WATER: IS IT SAFE?
1. What evidence does the Minister or the Department of Health have to prove that fluoride is safe for long-term daily consumption by humans? Note: since the Irish Expert Body on Fluorides and Health is without expertise in toxicology, we do not regard safety assurances from this source as an answer to this question.
2. Has the Dept carried out any research to ascertain the effects, other than in relation to tooth decay, of the fluoridation of the water supply in Ireland? If not, why not? And on what basis has the claim been made that the policy is having no adverse health impacts on Irish people’s health?
3. Does the Dept of Health know what the average level of fluoride is in the urine, blood, bone and hair of people in this State?
4. Have any attempts been made to collect such values on a systematic or scientific basis? If not, why not?
5. Prestigious scientific associations, as well as thousands of individual scientists internationally, assert that fluoridated tap water poses unacceptable risks to human health. It is for this reason, as well as on ethical grounds, that other EU member states do not fluoridate their water supplies. There are many quality peer-reviewed scientific studies associating serious health risks with fluoridated tap water. Why does the Irish Department of Health believe that it is safe to ignore the growing body of international scientific opinion which holds that fluoridated water presents an unacceptable danger to human health?
6. Considering that Irish people are consuming fluoride from other sources as well as from tap water, how can the Dept of Health guarantee that individual citizens in Ireland – including vulnerable sub-groups such as women with babies in utero, newborn infants, people with particular illnesses, and children with disabilities (for example, who are unable to spit out toothpaste) – are not ingesting a higher than recommended level of fluoride?
7. Is the Dept aware of the studies showing that prevalence of dental fluorosis (white marks, discolouration and, in some cases, weakening of the teeth) – representing chronic overexposure of the population to fluoride – is now endemic in Ireland? (‘Dental Fluorosis in Primary Teeth of 5-year-olds in Ireland’, O Mullane et al, paper presentation at American Association for Dental Research conference, San Antonio, USA, 2003; ‘Fluoride Metabolism and Fluorosis’, Browne et al, Journal of Dentistry, Volume 33 Issue 3, March 2005; Verkerk, ‘The paradox of overlapping micronutrient risks and benefits obligates risk/benefit analysis’, Journal of Toxicology, Feb 2010)
8. Does the Dept accept that the high dental fluorosis rates prevalent indicate that Irish children are currently getting too much fluoride?
9. Why do the Minister and the Dept of Health believe that it is safe to ignore the findings of international peer-reviewed studies that have found fluoride to be a neurotoxin, and that modest exposure lowers IQ in children in geographic areas with endemic fluorosis? (‘Developmental Fluoride Neurotoxicity: A Systematic Review and Meta-Analysis’ by Choi, Sun, Zhang and Grandjean, published online Environmental Health Perspectives on July 20, 2012)

EVIDENCE FOR DENTAL BENEFITS OF FLUOROIDATING TAP WATER
10. Considering that most dental researchers now concede, as did the European Commission Scientific Assessment on Fluoride in 2010, that the major benefit of fluoride in relation to dental health is TOPICAL not SYSTEMIC, is the Dept still justified in exposing the Irish population to fluoride systemically through drinking water?
11. What is the logic in exposing every tissue in the body – including the bones, the brain and the endocrine system – to a toxic substance, or a potentially toxic substance, when its benefit can be achieved topically via fluoridated toothpaste?
12. Has the Dept conducted or can it cite any randomised clinical trial that has conclusively demonstrated the effectiveness of water fluoridation in reducing tooth decay?
13. What primary published peer-reviewed studies (as opposed to reviews) have convinced the Dept that swallowing fluoride actually reduces tooth decay by a significant amount?

A COMMONSENSE ALTERNATIVE STRATEGY
14. Does the Minister agree that tooth decay is concentrated largely in families of low income? Why then is everyone else being subjected to the mandatory consumption of fluoride when there is no evidence that they need any dental treatment?
15. Would the Dept consider that it would make more sense to target children from low-income families with education for better dental hygiene and better diet, rather than forcing the entire population to drink a toxic, or potentially toxic, substance?
16. Why does the Department believe that force-feeding fluoride to the entire population represents a better option than initiating a campaign to get children to consume less sugar and take personal responsibility for care of
their teeth?

THE FLUORIDATING CHEMICALS
17. Is the Dept aware that, according to the European Commission, the toxicological characteristics of the chemicals used to fluoridate public water systems are inappropriately known? (EU Scientific Committee on Health and Environmental Risks SCHER; Committee on Fluoride in Drinking Water, NRC, National Academy of Sciences; ‘Fate of Fluororsillicate Drinking Water Additives’, Edward Todd Urbansky, US EPA, 2002)
18. Based on numerous MSDS (material safety data sheets) it has been shown that one of the contaminants of these fluoridating chemicals is arsenic. Is the Dept aware that the US EPA considers that there is no safe level of exposure to arsenic because it is a known human carcinogen? (Forum on Fluoridation Review 2002; ‘Arsenic in Drinking Water’, WHO 2011; ‘Basic Information about Arsenic in Drinking Water’, US EPA)
19. What evidence has the Minister or the Dept that the use of these arsenic-contaminated industrial grade chemicals in the water will NOT increase the cancer rates in this country?
20. Does the Dept consider it justifiable to risk increasing cancer rates in order to possibly reduce tooth decay by a very small amount via ingestion, when topical treatment with fluoridated toothpaste is just as effective?

OVEREXPOSURE IN CHILDREN AND INFANTS
21. Is the Minister aware that according to two scientific reports (Irish Study, published in Caries Research, Sept-Oct 2004 and the EU Report from the Scientific Committee on Health and Environmental Risks, 2011), Irish children frequently exceed the upper limit set for fluoride consumption? Why does the Dept of Health consider this overexposure risk to children and infants to be acceptable?

FLUORIDATION POLICY AND THE PRECAUTIONARY PRINCIPLE
22. In light of the many serious concerns over health risks raised by thousands of scientists and other experts, and a growing body of scientific evidence associating fluoride toxicity with harmful health effects, on what basis does the Dept of Health believe that the Irish State’s fluoridation policy conforms to the Precautionary Principle? (As an EU member state, Ireland is obliged to follow this principle.)

CLASSIFICATION OF FLUORIDE
23. Does the Dept classify sodium fluoride as a medicine? If not, how is it classified?
24. Does the Dept classify hydrofluorosilicic acid as a medicine? If not, how is it classified?

IS OUR FLUORIDATION POLICY LEGAL WITHIN THE EU?
As Minister, Alex White, told the Seanad on 30th January 2013 that hydrofluorosilicic acid added to Irish drinking water is supplied by Derivados del Fluor in Spain. It is our understanding that this product has not been clinically trialled and does not have a marketing authorisation in the EU. Since Irish fluoridation is based on the minister’s medical claim in the Seanad of ‘making teeth more resistant to decay in people of all ages’, why has the Dept of Health not obtained legal authorisation for this use of hydrofluorosilicic acid in the EU, as is required to comply with the Clinical Trials Directive (2001/20/EC) and Medicinal Products Directive 2001/83/EC?
25. Based on what appears to us to be an ongoing infringement of EU law, has the Dept. of Health sought a derogation from the European Commission? And if not, why not?

A NEW, INDEPENDENT REVIEW OF THE WATER FLUORIDATION POLICY
Irish fluoridation policy is based on the report produced in 2002 by the government-appointed Forum on Fluoridation.
This report was criticised by an international team of eleven scientists, all experts on the effects of fluoridation. These scientists stated: “In our view, by failing to assess properly all the evidence available in the international scientific literature, the (Irish) Forum wasted a valuable opportunity to fully engage the scientific case opposing fluoridation… We can only conclude that the aim of the authors of this report (the Forum’s) was not to study the evidence but to find ways to get around it. The report’s primary conclusion that there are no adverse health effects is not defensible and in our view is blatantly false.”
The scientists also concluded:
* The Fluoridation Forum report failed to address a number of recently published important studies of fluoridation. 
* It failed to establish a significant clinical difference in dental decay between children living in fluoridated and non-fluoridated communities in Ireland and throughout largely non-fluoridated Europe. 
* It failed to ‘deal convincingly with the issue of dental fluorosis’, ‘making several unsupportable assertions’. 
* It failed to discuss the fact that certain individuals in a population are going to be ‘more sensitive and more vulnerable to fluoride’s toxic effects than others’. 
* It failed to provide the necessary precautionary advice to mothers not to use infant formula made up with fluoridated tap water. Taking the above into account:
26. Why does the Department of Health insist on following the advice of an ‘Expert Body’ whose foundation document recommending ongoing fluoridation has been so roundly condemned by prestigious international scientific experts?
27. And finally, considering the criticism above, what is the reason for the Minister’s and the Department’s apparent resistance to establishing a fully independent inquiry into Ireland’s policy of mandatory fluoridation of the water supply, taking on board all the new scientific evidence for the harmful effects of fluoride that have emerged since 2002, when the recommendation for ongoing fluoridation in Ireland was made?