27 Question For The Food Safety Authority In Ireland

How much fluoride does the average Irish person consume? Depending on who you go to for information – the Irish government and its agencies on the one hand, or Irish campaigning scientist Declan Waugh and a plethora of international scientific studies on the other – you’ll get a drastically different answer to an essentially straightforward question.

Irish authorities give a very low figure, and insist there’s nothing to worry about. The others provide a high figure, and warn we have a serious fluoride overexposure problem. So who’s right? We wanted to know...
In the middle of June, Hot Press set about getting an explanation from the Food Safety Authority of Ireland (FSAI) as to why the figures for fluoride content in Irish food and beverages, as reflected in their Total Diet Study (2011), are so low alongside international comparators.
In the case of black tea, the kind consumed by the vast majority of Irish people, the figures published by the FSAI are approximately a tenth of the level found in a series of international studies. The obvious conclusion is that it can only be a dreadful mistake. But we wanted to find out more.
Since our investigations began, one absurdity has been heaped on another, to the extent that you’d wonder: what madness is afoot on this issue in the Irish public service?
Initially, in response to our query, the FSAI told me to ask the Department of Health, since this issue is, in part at least, about the extent to which water fluoridation contaminates our food. Bollocks. Tired of being shunted from one government agency to another, I insisted that – as the authors of the Total Diet Study 2011, in which the fluoride content of a variety of Irish food had ostensibly been measured – it was clearly the responsibility of the FSAI to answer questions in relation to how much fluoride is really in our food and drink, and whether our exposure to dietary sources of fluoride is at ‘safe’ levels.
Unwilling to be fobbed off, I insisted that I wanted to speak to the FSAI scientist who had actually conducted the fluoride tests on Irish food and drink. The FSAI admitted (rather defensively it seemed) that they had in fact contracted a UK government laboratory to test the Irish samples. Even more bizarrely, it emerged (following further probing) that the samples analysed for their fluoride content in the Total Diet Study of 2011, and currently being used by the Dept of Health to say everything is hunky-dory as far as fluoride exposure is concerned, had been gathered in 2002 – and thus were already 9 years out of date when the study was published.
While I have become well aware of the casual disregard with which the Department of Health and its agencies seem to treat the welfare of Irish citizens, I was still utterly shocked. Why would the Food Safety Authority of Ireland publish information as if it was new, in 2011, when it was all of nine years out of date?
I asked to speak to whoever in the FSAI had liaised with the relevant UK lab – the Food and Environment Research Agency (FERA) – as I had questions to ask about how the tests were conducted. Bizarrely, the FSAI told me, over the phone, that I should ring Cork Dental Hospital with my questions. What relevance has the Cork Dental Hospital, I asked, when I’m trying to understand the discrepancies between Irish and international data for fluoride in food and beverages?
I informed the FSAI that I intended to contact the FERA lab in the UK directly with my questions, and I asked for co-operation from the FSAI in putting me in contact with whoever processed the tests at FERA.
An e-mail, refusing cooperation, came back from the FSAI. “FERA,” it stated, “would not have provided the results to the FSAI if it had been concerned in any way that its methods were not sound. The FSAI has no reason to believe that the results were incorrect at the time of measurement. It is not warranted to request FERA to co-operate in the manner you have described during our telephone conversation earlier. The important thing for consumer protection is to measure current exposure to fluoride which has no doubt changed since 2002/3. As we have previously pointed out, the FSAI is in the process of doing a second up to date total diet study in which we will measure the fluoride content of food today using today’s food consumption patterns.”
This was an obvious brush-off. Refusing to accept it, Hot Press contacted FERA directly and asked specifically to speak to the scientist who had done the testing. A mail came back saying that the scientist responsible no longer works at FERA, and asking would I like to continue with my questions under their DWO (‘Deal With Officially’) procedure, which would take fifteen days? I said yes.
The ‘DWO’ came back on July 11. It said that because the testing was done in 2003, and they are only legally obliged to keep results for 6 years, they no longer have a record of the testing they conducted for the FSAI!
In a potentially sinister twist, on the same date, scientist Declan Waugh received a letter from the FSAI which stated the following: “In your mail and report you state that the FSAI data is erroneous, which suggests that there were problems with the original analysis. However we asked the laboratory to conduct a review and they have confirmed to us in writing that they are confident in the quality of the data supplied to the FSAI at the time.”
So: at the request of the FSAI, FERA can apparently conduct a review of data – and give reassurances as to the quality – while separately telling me that they no longer have this very data. It is the sort of Kafkaesque quagmire that stinks to high heaven of institutional tomfoolery of one kind or another. Meanwhile, the crazily skewed nature of the Irish data remains entirely unexplained.
So what is going on here? And have we been hoodwinked all along?
In the world of professional cycling, we read on a weekly basis about how drug tests, carried out in the 1990s, are being reviewed, using more modern techniques. If the blood samples collected during those tests were retained, it is very hard indeed to understand why no records were kept by FERA of the data for such an important study, being conducted for, and paid for by, the Irish government!
Hot Press decided separately to have samples of specific foodstuffs, alcoholic drinks, tea and water tested by the Public Analyst’s Laboratory, which in Dublin operates under the auspices of the HSE. When we called, we were told that the lab could not carry out tests on food or alcoholic drinks. There was no problem, however, with tea or water. Brilliant! That, at least, was something...
We delivered samples of tea and water urgently, as requested, on the morning of Friday, July 12. They were accepted and we were told to expect results by 5pm, on Monday, July 15. We waited for the outcome with baited breath.
We are still waiting. Despite having specifically told us that they could carry out the tests on tea, come Monday, the lab had backtracked: apparently they were now incapable of carrying out what has to be a relatively simple scientific test on tea or coffee.
This was just the final indignity in a chain of events that reflects very badly on various arms of the Irish health service.
Which is why we have decided to put the following set of 27 Questions – for symmetry the same number that we put to the Minister for Fluoridation, Alex White, a few months back – to the FSAI, in the form of a public letter.
We await their response with interest.

THE 27 QUESTIONS
The World Health Organisation has stated that prior to commencement of fluoridation of any public water supply, in order to avoid overexposure to fluoride, authorities must accurately determine the total existing fluoride exposure of the population – including the exposure of all sensitive subgroups, such as infants and the elderly; people with diseases such as dieabetes or thyroid dysfunction; and heavy consumers of water, such as labourers and sports enthusiasts.
1. In the light of the above, can you please explain why, before the publication of the so-called Total Diet Study in 2011, the FSAI had not ever conducted tests to determine the total existing fluoride exposure of the Irish population, and in particular the exposure of sensitive subgroups?
2. (a) Were the FSAI aware of the requirement, set out in Section 6.1 of the 1960 Health (Fluoridation of Water Supplies) Act introducing mandatory fluoridation of the water supply in Ireland, that the effects of fluoridation should, under Irish law, be subject to ongoing monitoring?
(b) If so, why was monitoring not carried out at all by the FSAI until 2011?
(c) If not, then why not?
3. (a) There are large discrepancies between the fluoride levels that (i) the FSAI say are in Irish food and beverages (in particular tea and beer) and (ii) the fluoride levels in food and beverages found in the international studies, as highlighted by Irish scientist Declan Waugh in his fluoridation reports, of which the FSAI has received copies and which are available online at enviro.ie. Were the FSAI aware of these discrepancies, after the information in the Total Diet Study 2011 was collated, but before the report was published?
(b) If not, why did the FSAI not check the results against international studies?
(c) If so, why were the figures not subjected to a fresh level of scrutiny and re-evaluation?
4. According to the international studies referenced in Declan Waugh’s reports, and to experiments carried out by Waugh, the FSAI has significantly underestimated the levels of fluoride being ingested by the public, in particular by vulnerable members of the public. There is a difference of over 1,000 per cent in the FSAI’s data for fluoride in some products, compared to the much higher figures given for the same products in other studies. Can the FSAI please explain these huge discrepancies?
5. Given the scale of the discrepancies between its figures and those in international studies, including a new UK study into the amount of fluoride in tea by Laura Chan et al (see panel), does the FSAI accept that there is reason to suspect that the information in the FSAI-produced Total Diet Study is, not to mince words, completely wrong?
6. (a) Has anyone in the FSAI specifically examined international studies into the effects of fluoride?
(b) If yes, can you please explain the nature of the research carried out and by whom it was done?
(c) If no, can you please explain why this research was not undertaken?
7. (a) Does the FSAI accept the evidence that serious adverse health effects are linked to fluoride toxicity, as has been confirmed in a large and expanding body of international scientific studies?
(b) If not, can the FSAI explain why it rejects this information, which is widely available in the public domain?
8. P. Mansfield’s 2010 research report, Fluoride Consumption: the Effect of Water Fluoridation, published in Fluoride 43 (4), Oct-Dec 2010, found that 21.3% of adults tested in UK in areas where water fluoride levels were less than 0.3ppm exceeded the safe intake level specified by the Committee on the Medical Aspects of Food Policy for the UK. For geographic areas where the fluoride level in tap water was between 0.3 and 0.8ppm, 52.6% of those tested exceeding the safe intake level, while in artificially-fluoridated areas, the figure was 65.3%.
In the same article, the author reported that a recent Irish study using the same testing method in three fully-fluoridated neighbourhoods of County Donegal found that 73% of subjects exceeded the safe intake level. This was the highest exposure across either Ireland or the UK, clearly reflecting the fact that the Irish Republic has a mandatory water fluoridation policy, while only 10% of the British population is exposed to artificial water fluoridation. What does the FSAI have to say to Irish citizens who are extremely concerned by this confirmation of fluoride overexposure in Ireland?
9. Does the FSAI have accurate current data for fluoride levels in Irish foods and beverages? If so, when will that data be put into the public domain?
10. In a previous communication with Hot Press, the FSAI stated: “tap water containing fluoride at the recommended levels by the Department of Health (0.8mg/l) does not pose a food safety issue.”
(a) Does the FSAI have accurate, up to date scientific evidence to back up this safety assurance?
(b) Upon what grounds does the FSAI make the safety assurance above, given the current controversy over out-of-date – and apparently inaccurate – FSAI data on fluoride levels in Irish food and beverages?

MEET THE FSAI SCIENTIFIC COMMITTEE
In a letter from the FSAI to Declan Waugh, dated 11th July last and signed by Dr Rhodri Evans, the FSAI state:
Your concerns over our data, given its age, are best addressed by the new TDS [Total Diet Study], which we are currently undertaking. We can assure you that we will review the data contained in the publications you have cited and compare this with the results of analyses that will be available from the new TDS. These data, considered in the light of the data you have identified, will be used along with recently available food consumption data availabe from the National Adult Nutrition Survey conducted by the Irish Universities Nutrition Alliance, to undertake an updated assesment of exposure of the Irish population to fluoride from food.
The exposure assessment will be carried out under the auspices of the FSAI Scientific Committee, which will consider the findings in relation to published upper tolerable limits for fluoride. The Scientific Committee is a statutory body under the FSAI Act charged with providing independent scientists appointed by the Minister for Health.
11. (a) In the light of the above, can the FSAI explain what was the point in publishing the Total Diet Study in 2011 – which, among other things, provided information on fluoride levels in foodstuffs and beverages – using samples that were up to nine years out-of-date?
(b) Was the information in other areas of this report similarly out of date, or was fluoride seen as a special case, where being up to date didn’t matter?
(c) What was the time-lag in relation to collection and publication of information on other substances tested-for in the Total Diet Study?
(d) If fluoride was an exception, can the FSAI please explain why?
12. Does the FSAI consider that presenting information that is up to nine years out of date as if it is new, and without any attached ‘health warning’ or other notification to the public, is an adequate way for a State body to conduct its business?
13. Can the FSAI please tell us when they plan to re-test fluoride levels in Irish food and beverages, so that the public can get a full and accurate picture of our fluoride exposure?
14. Will the FSAI now, immediately, compare its current fluoride data with international findings?
15. Does the FSAI acknowledge that the need to provide accurate information on fluoride exposure in Ireland is urgent, given the growing controversy over water fluoridation and fluoride contamination in Irish-produced food and beverages?
16. Is the FSAI aware that inaccurate fluoride information is a serious public health and safety issue, since it means that the authorities are unaware of possible fluoride overexposure problems in this country?
17. In the letter to Declan Waugh quoted from above, the FSAI state that the new fluoride exposure assessment will be carried out “under the auspices of the FSAI Scientific Committee”, comprising scientists appointed by the Minister for Health. How can the independence and objectivity of these scientists be guarranteed, when they are appointed by a government with an already stated commitment to maintaining an entrenched pro-fluoridation policy?

WHO IS TESTING FLUORIDE IN IRISH FOOD AND BEVERAGES?
In the same letter from the FSAI to scientist Declan Waugh dated 11th July last (see above), the FSAI also wrote:
In your email and report you state that the FSAI data [on fluoride levels in food and beverages] is erroneous, which suggests that there were problems with the original analysis. However we asked the laboratory to conduct a review and they have confirmed to us in writing that they are confident in the quality of the data supplied to FSAI at the time.
17. The laboratory referred in this letter is the Food and Environment Research Agency (FERA) in York, UK, who were contracted by the FSAI to analyse Irish food and drink samples. Will the FSAI please supply Hot Press with a copy of (a) their request that FERA conduct a review, and (b) the written correspondence from FERA mentioned in the letter to Declan Waugh, confirming FERA’s confidence in the data quality?
18. (a) Will the FSAI also please supply Hot Press with copies of the lab reports which relate to FSAI’s 2011 Total Diet Study?
(b) Hot Press has been informed by FERA that the data referred to has been destroyed. Can the FSAI please explain how, therefore, they (i) conducted a review and (ii) how they could state that they were confident in the quality of the data supplied to the FSAI at the time?

STRANGE BREW – TEA, WHAT’S
INSIDE OF YOU
A new British scientific study has warned that consumption of tea, made using non-fluoridated water, alone, can exceed daily upper limits set for fluoride, leading to what they describe as worrying levels of fluoride overexposure and high risks of adverse health effects (see panel). The average fluoride level for all economy tea bags tested in the British study was 6mg/L. This is over 10 times the level of fluoride in tea given by the FSAI, which has said that the level of fluoride in tea in Ireland is between 0.4 and 0.7mg/L.
19. (a) Was the FSAI aware that it gave data for fluoride in tea that was, more than somewhat bizarrely, less than the level of fluoride in Irish tap water?
(b) If so, how was – or is – this very strange anomaly explained?
(c) If the FSAI used de-ionised, non-fluoridated water to make the tea infusions that were tested, is this an accurate measure of fluoride exposure for Irish people through tea, considering that the vast majority of people use fluoridated tap water in their kettles?
20. Can you also please explain why the FSAI’s data on fluoride levels in tea are so dramatically lower than the levels measured in all of the international studies outlined by Declan Waugh?
The British study states that 1 litre of tea is equivalent to four cups, which is the average quantity of tea consumed per day by British individuals. Thus many British people are consuming 6mg of fluoride per day from tea alone. According to the Food and Agriculture Organisation of the UN, the Irish drink even more tea than the British, ranking as the highest tea-drinkers in the Western/developed world.
US scientists have warned that over 4mg per day of fluoride can lead to serious adverse health effects, including skeletal fluorosis (painful calcification of the bones). According to the European Food Safety Authority (EFSA) the maximum tolerable upper limit for fluoride intake from all food sources, including water, for adults, is 7mg of fluoride per day. The WHO has set a considerably lower recommended daily intake for fluoride of 3mg for adults.
The fluoride levels in tea, in research conducted by Declan Waugh, and in many other international published studies, corresponds with the high levels of fluoride found in the recent UK report.
For example, a study by Cao et al, “Safety evaluation on fluoride content in black tea”, (Food Chemistry 88 (2004) 233–236) concludes: “These results suggest that, for heavy black tea drinkers, the fluoride intake in areas with drinking water fluoridation, and also other probable sources of fluoride, may approach or reach the level of risk from chronic fluoride intoxication.”
Referring to the studies listed above, Declan Waugh has stated to Hot Press: “The results of all these studies show that the total dietary intake just from consuming black tea for a large percentage of the adult Irish population could exceed the upper safe limit for fluoride. Yet the Minister for Health and the FSAI claim that the dietary fluoride intake level from all foods and beverages for consumers in Ireland is less than 10% of the upper limit. As I outlined to the Minister in November last year, my view is that this is not only incorrect, but scientifically impossible.”
20. Bearing the above in mind, what is the FSAI’s response to the new British research on fluoride overexposure through tea?
21. Considering that the Irish are amongst the highest black-tea drinkers in the world, and that most Irish citizens make tea with fluoridated tap water, what is the FSAI’s considered response to the warning from scientists regarding risk of chronic fluoride intoxication in heavy tea-drinkers?
22. In the light of all the evidence for very high levels of fluoride in tea, and considering how much tea the Irish consume, would the FSAI please explain how it is scientifically possible to make the claim that the fluoride intake level from all dietary sources for Irish adults is (i) only 1.65mg on average per day, and (ii) less than 10 per cent of the upper limit? [Figures from letter from Minister for Health, Dr James Reilly, to Mr Jimmy Deenihan, Minsiter for Arts, Heritage and Gaeltacht Affairs, dated 9th November 2012. The Health Minister in this letter attributes his fluoride figures to the FSAI’s 2011 Total Diet Study.]
23. (a) Does the FSAI intend to warn the Irish public about the fluoride overexposure health risks (outlined in international scientific studies) associated with drinking excessive amounts of tea, especially when it is made with fluoridated tap water?
(b) If not, why not (please note that the failure to do so suggests that the FSAI does not believe that there is any ‘upper limit’, and that the consumption of any level of fluoride is perfectly safe and acceptable)?
24. (a) Was any consideration whatsoever given to the issue of allergies, when the statement was issued by the FSAI claiming that consumption of tap water at the level of fluoride recommended by the Department of Health poses no safety issue?
(b) If possible allergies to fluoride were not considered, why was a blanket statement of ‘safety’ delivered by the FSAI?
(c) Has the FSAI ever conducted any examination of the possibility of individuals being allergic to fluoride?
(d) The Republic has an abnormally high incidence of asthma (almost three times the European level and 60% higher than in non-fluoridated Northern Ireland), and this has been increasing in recent years. We also have an exceptionally high incidence of Rheumathoid Arthritis. All of the fluoridated countries in the world have much higher incidences of both of these diseases than non-fluoridated countries. What evidence can the FSAI offer that neither of these elevated disease rates relate in any way to exposure (or to over-exposure) to fluoride as a result of mandatory fluoridation?

DANGERS TO CHILDREN
It has been scientifically established that young children, and in particular infants fed with formula milk made with fluoridated tap water, are at very high risk of daily fluoride overexposure (see article in the last issue of Hot Press). At current fluoride levels in Irish drinking water, all bottle-fed babies will exceed the maximum upper recommended fluoride level for adults when fluoridated tap water is used to constitute the formula. This is of major concern in Ireland especially, given that breastfeeding rates are very low here, with 97% of infants drinking formula milk by the age of six months.
Because of the risk of the overexposure of bottle-fed infants to fluoride, various organisations, including the American Dental Association and the US Centre for Disease Control, as well as many eminent paediatricians, have warned that fluoridated tap water should not be used to make formula milk.
24. As the body responsible for food safety in Ireland, and by extension for the safety of Irish citizens in this crucial area, can the FSAI please explain why it has not made Irish parents aware of these hugely important health warnings?
25. Can the FSAI please clarify its position on the safety of the use of fluoridated tap water in bottle-feeds for infants?
26. (a) If the FSAI is not issuing any warning or making any other public information announcement in relation to the existing studies on this issue, and specifically on the recommendations of the US Centre for Disease Control, will the FSAI take responsibility for its failure to do so now, in the event that the relevant figures are confirmed by subsequent studies?
(b) Does the FSAI accept that, on the basis of the precautionary principle, a warning of this kind would represent the minimum level of prudence required of a public authority of its kind?
(c) If not, why not?

AND FINALLY….
27. (a) As the authority charged with ensuring the safety of all food and beverages consumed by the citizens of Ireland, does the FSAI accept that until we have reliable scientific evidence for the dietary fluoride exposure of the Irish population, including in particular infants and other sensitive sub-groups, water fluoridation should be stopped in line with the precautionary principle?
(b) Again, if not, why not?

* The 1971-2003 WHO International Standards for
Drinking Water