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29th Jun
2000: Dr William Hirzy
William
Hirzy
E.P.A. PROFESSIONALS OPPOSE FLUORIDATION
(NB. originally published in the Australian Fluoridation News, Nov-Dec 2000
issue).
Preliminary Hearing, U.S. Senate Subcommittee on Fisheries, Wildlife and
Water concerning Fluoridation.
Thursday, June 29, 2000, a preliminary hearing was scheduled in the US
Senate Subcommittee on Fisheries, Wildlife and Water concerning
fluoridation. Dr. J. William Hirzy, Vice-President of EPA's National
Treasury Employees Union, Chapter 280, presented his testimony at this
hearing.
STATEMENT OF DR. J. WILLIAM HIRZY, VICE-PRESIDENT, E.P.A. NATIONAL TREASURY
EMPLOYEES UNION CHAPTER 280 BEFORE THE SUBCOMMITTEE ON WILDLIFE, FISHERIES
AND DRINKING WATER UNITED STATES SENATE.
JUNE 29, 2000
Good morning Mr Chairman and Members of the Subcommittee. I appreciate the
opportunity to appear before this Subcommittee to present the views of the
union, of which I am a Vice-President, on the subject of fluoridation of
public water supplies.
Our
union is comprised of and represents the professional employees at the
headquarters location of the U.S. Environmental Protection Agency in
Washington D.C. Our members include toxicologists, biologist, chemists,
engineers, lawyers and others defined by law as "professionals". The work we
do includes evaluation of toxicity, exposure and economic information for
management's use in formulating public health and environmental protection
policy. I am not here as a representative of EPA, but rather as a
representative of EPA headquarters professional employees, through their
duly elected labour union. The union first got involved in this issue in
1985 as a matter of professional ethics. In 1997 we most recently voted to
oppose fluoridation. Our opposition has strengthened since then.
Summary of Recommendations
1)
We ask that you order an independent review of a cancer bioassay previously
mandated by Congressional committee and subsequently performed by Battelle
Memorial Institute with appropriate blinding and instructions that all
reviewer's independent determinations be reported to this Committee.
2)
We ask that you order that the two waste products of the fertiliser industry
that are now used in 90% of fluoridation programs, for which EPA states they
are not able to identify any chronic studies, be used in any future toxicity
studies, rather than a substitute chemical. Further, since federal agencies
are actively advocating that each man, woman and child drink, eat and bathe
in these chemicals, silicofluorides should be placed at the head of the list
for establishing a MCL that complies with the Safe Drinking Water Act. This
means that the MCL be protective of the most sensitive of our population,
including infants, with an appropriate margin of safety for ingestion over
an entire lifetime.
3)
We ask that you order an epidemiology study comparing children with dental
fluorosis to those not displaying overdose during growth and development
years for behavioural and other disorders.
4)
We ask that you convene a joint Congressional Committee to give the only
substance that is being mandated for ingestion throughout this country the
full hearing that it deserves.
National Review of Fluoridation
The
Subcommittee's hearing today can only begin to get at the issues surrounding
the policy of water fluoridation in the United States, a massive experiment
that has been run on the American public, without informed consent, for over
fifty years. The last Congressional hearings on this subject were held in
1977. Much knowledge has been gained in the intervening years. It is high
time for a national review of this policy by a Joint Select Committee of
Congress. New hearings should explore, at minimum, these points:
1)
excessive and uncontrolled fluoride exposures;
2)
altered findings of a cancer bioassay;
3)
the results and implications of recent brain effects research;
4)
the "protected pollutant" status of fluoride within EPA;
5)
the altered recommendations to EPA of a 1983 Surgeon General's Panel on
fluoride;
6)
the results of a fifty-year experiment on fluoridation in two New York
communities;
7)
the findings of fact in three landmark lawsuits since 1978;
8)
the findings and implications of recent research linking the predominant
fluoridation chemical with elevated blood-lead levels in children and
antisocial behaviour; and
9)
changing views among dental researchers on the efficacy of water
fluoridation.
Fluoride Exposures Are Excessive and Uncontrolled.
Centres for Disease Control and EPA claim that dental fluorosis is only a
'cosmetic' effect. God did not create humans with fluorosed teeth. That
effect occurs when children ingest more fluoride than their bodies can
handle with the metabolic processes we were born with, and their teeth are
damaged as a result. And not only their teeth. Children's bones and other
tissues, as well as their developing teeth are accumulating too much
fluoride. We can see the effect on teeth. Few researchers, if any, are
looking for the effects of excessive fluoride exposure on bone and other
tissues in American children. What has been reported so far in this
connection is disturbing. One example is epidemiological evidence 2a,2b
showing elevated bone cancer in young men related to consumption of
fluoridated drinking water.
Without trying to ascribe a cause and effect relationship beforehand, we do
know that American children in large numbers are afflicted with
hyperactivity-attention deficit disorder, that autism seems to be on the
rise, that bone fractures in young athletes and military personnel are on
the rise, that earlier onset of puberty in young women is occurring. There
are biologically plausible mechanisms described in peer-reviewed research on
fluoride that can link some of these effects to fluoride exposures (e. g.
3,4,5,6). Considering the economic and human costs of these conditions, we
believe that Congress should order epidemiology studies that use dental
fluorosis as an index of exposure to determine if there are links between
such effects and fluoride overexposure.
In
the interim, while this epidemiology is conducted, we believe that a
national moratorium on water fluoridation should be instituted. There will
be a hue and cry from some quarters, predicting increased dental caries, but
Europe has about the same rate of dental caries as the U.S 7 and most
European countries do not fluoridate 8. I am submitting letters from
European and Asian authorities on this point. There are studies in the U.S.
of localities that have interrupted fluoridation with no discernible
increase in dental caries rates (e.g., 9). And people who want the freedom
of choice to continue to ingest fluoride can do so by other means.
•
Cancer Bioassay Findings. In 1990, the results of the National Toxicology
Program cancer bioassay on sodium fluoride were published 10, the initial
findings of which would have ended fluoridation. But a special commission
was hastily convened to review the findings, resulting in the salvation of
fluoridation through systematic downgrading of the evidence of
carcinogenicity. The final, published version of the NTP report says that
there is "equivocal evidence of carcinogenicity in male rats," changed from
"clear evidence of carcinogenicity in male rats".
The
change prompted Dr William Marcus, who was then Senior Science Adviser and
Toxicologist in the Office of Drinking Water, to blow the whistle about the
issue 22, which led to his firing by EPA. Dr Marcus sued EPA, won his case
and was reinstated with back pay, benefits and compensatory damages. I am
submitting material from Dr Marcus to the Subcommittee dealing with the
cancer and neurotoxicity risks posed by fluoridation.
We
believe the Subcommittee should call for an independent review of the tumor
slides from the bioassay, as was called for by Dr Marcus 22, with the
results to be presented in a hearing before a Select Committee of the
Congress. The scientists who conducted the original study, the original
reviewers of the study, and the "review commission" members should be
called, and an explanation given for the changed findings.
•
Brain Effects Research. Since 1994 there have been six publications that
link fluoride exposure to direct adverse effects on the brain. Two
epidemiology studies from China indicate depression of I.Q. in children
11,12. Another paper' shows a link between prenatal exposure of animals to
fluoride and subsequent birth of offspring which are hyperactive throughout
life. A 1998 paper shows brain and kidney damage in animals given the
"optimal" dosage of fluoride, viz. one part per million 13. And another 14
shows decreased levels of a key substance in the brain that may explain the
results in the other paper from that journal. Another publication, links
fluoride dosing to adverse effects on the brain's pineal gland and premature
onset of sexual maturity in animals. Earlier onset of menstruation of girls
in fluoridated Newburg, New York has also been reported 6.
Given the national concern over incidence of attention deficit-hyperactivity
disorder and autism in our children, we believe that the authors of these
studies should be called before a Select Committee, along with those who
have critiqued their studies, so the American public and the Congress can
understand the implications of this work.
•
Fluoride as a Protected Pollutant. The classic example of EPA's protective
treatment of this substance, recognised the world over and in the U.S.
before the linguistic detoxification campaign of the 1940's and 1950's as a
major environmental pollutant, is the 1983 statement by EPA's then Deputy
Assistant Administrator for Water, Rebecca Hammer 15, that EPA views the use
of hydrofluosilicic acid recovered from the waste stream of phosphate
fertiliser manufacture as "... an ideal solution to a long standing problem.
By recovering byproduct fluosilicic acid (sic) from fertiliser
manufacturing, water and air pollution are minimised, and water authorities
have a low-cost source of fluoride..."
In
other words, the solution to pollution is dilution, as long as the pollutant
is dumped straight into drinking water systems and not into rivers or the
atmosphere. I am submitting a copy of her letter.
Other Federal entities are also protective of fluoride. Congressman Calvert
of the House Science Committee has sent letters of inquiry to EPA and other
Federal entities on the matter of fluoride, answers to which have not yet
been received.
We
believe that EPA and other Federal officials should be called to testify on
the manner in which fluoride has been protected. The union will be happy to
assist the Congress in identifying targets for an inquiry. For instance,
hydrofluosilic acid does not appear on the Toxic Release inventory list of
chemicals, and there is a remarkable discrepancy among the Maximum
Contaminant levels for fluoride, arsenic and lead, given the relative
toxicities of these substances.
•
Surgeon General's Panel on Fluoride. We believe that EPA staff and managers
should be called to testify, along with members of the 1983 Surgeon
General's panel and officials of the Department of Human Services, to
explain how the original recommendations of the Surgeon General's panel 16
were altered to allow EPA to set otherwise unjustifiable drinking water
standards for fluoride.
•
Kingston and Newburg, New York Results. In 1998, the results of a fifty-year
fluoridation experiment involving Kingston, New York (un-fluoridated) and
Newburg, New York (fluoridated) were published 17. In summary, there is no
overall significant difference in rates of dental decay in children in the
two cities, but children in the fluoridated city show significantly higher
rates of dental fluorosis than children in the un-fluoridated city.
We
believe that the authors of this study and representatives of the Centres
For Disease Control and EPA should be called before a Select Committee to
explain the increase in dental fluorosis among American children and the
implications of that increase for skeletal and other effects as the children
mature, including bone cancer, stress fractures and arthritis.
•
Findings of Fact by judges. In three landmark cases adjudicated since 1978
in Pennsylvania, Illinois and Texas 18, judges with no interest except
finding fact and administering justice heard prolonged testimony from
proponents and opponents of fluoridation and made dispassionate findings of
fact. I cite one such instance here.
In
November, 1978, judge John Flaherty, now Chief Justice of the Supreme Court
of Pennsylvania, issued findings in the case. Aitkenhead v. Borough of West
View, tried before him in the Allegheny Court of Common Pleas. Testimony in
the case filled 2800 transcript pages and fully elucidated the benefits and
risks of water fluoridation as understood in 1978. Judge Flaherty issued an
injunction against fluoridation in the case, but the injunction was
overturned on jurisdictional grounds. His findings of fact were not
disturbed by appellate action. Judge Flaherty, in a July, 1979 letter to the
Mayor of Auckland New Zealand wrote the following about the case: "In my
view, the evidence is quite convincing that the addition of sodium fluoride
to the public water supply at one part per million is extremely deleterous
to the human body, and a review of the evidence will disclose that there was
no convincing evidence to the contrary... "Prior to hearing this case, I
gave the matter of fluoridation little, if any, thought, but I received
quite an education, and noted that the proponents of fluoridation do nothing
more than try to impune (sic) the objectivity of those who oppose
fluoridation."
In
the Illinois decision, Judge Ronald Niemann concludes: "This record is
barren of any credible and reputable scientific epidemiological studies and
or analysis of statistical data which would support the Illinois
Legislature's determination that fluoridation of the water supplies is both
a safe and effective means of promoting public health."
Judged Anthony Farris in Texas found: "[That] the artificial fluoridation of
public water supplies, such as contemplated by (Houston) City ordinanced No.
80-2530 may cause or contribute to the cause of cancer, genetic damage,
intolerant reactions, and chronic toxicity, including dental mottling in
man; and that the value of said artificial fluoridation is in some doubts as
to reduction of tooth decay in man."
The
significance of Judged Flaherty's statement and his and the other two
judges' findings of fact is this: proponents of fluoridation are fond of
reciting endorsement statements by authorities, such as those by CDC and the
American Dental Association, both of which have long-standing commitment
that are hard if not impossible to recant, on the safety and efficacy of
fluoridation. Now come three truly independent servants of justice, the
judges in these three cases, and they find that fluoridation of water
supplies is not justified.
Proponents of fluoridation are absolutely right about one thing: there is no
real controversy about fluoridation when the facts are heard by an open
mind.
I
am submitting a copy of the excerpted letter from judge Flaherty and another
letter referenced in it that was sent to Judge Flaherty by Dr Peter
Sammartino, then Chancellor of Fairleigh Dickenson University. I am also
submitting a reprint copy of an article in the Spring 1999 issue of the
Florida State University Journal of Land Use and Environmental Law by Jack
Graham and Dr Pierre Morin, titled "Highlights in North American Litigation
During the Twentieth Century on Artificial Fluoridation of Public Water." Mr
Graham was chief litigator in the case before Judge Flaherty and in the
other two cases (in Illinois and Texas).
We
believe that Mr Graham should be called before a Select Committee along
with, if appropriate, the judges in these cases who could relate their
experience as trial judges in these cases.
•
Hydrofluosilicic Acid: There are no chronic toxicity data on the predominant
chemical, hydrofluosilicic acid and its sodium salt, used to fluoridate
American communities. Newly published studies 19 indicate a link between use
of these chemicals and elevated level of lead in children's blood and
anti-social behaviour. Material from the authors of these studies has been
submitted by them independently.
We
believe the authors of these papers and their critics should be called
before a Select Committee to explain to you and the American people what
these papers mean for continuation of the policy of fluoridation.
•
Changing Views on Efficacy and Risk: In recent years, two prominent dental
researchers who were leaders of the profluoridation movement announced
reversals of their former positions because they concluded that water
fluoridation is not an effective means of reducing dental caries and that it
poses serious risks to human health. The late Dr John Colquhoun was
Principal Dental Officer of Auckland, New Zealand, and he published his
reasons for changing sides in 1997 20. In 1999, Dr Hardy Limeback, Head of
Preventive Dentistry, University of Toronto, announced his change of views,
then published a statement 21 dated April 2000. I am submitting a copy of Dr
Limeback's publications.
We
believe that Dr Limeback, along with fluoridation proponents who have not
changed their minds, such as Drs Ernest Newbrun and Herschel Horowitz,
should be called before a Select Committee to testify on the reasons for
their respective positions.
Thank you for your consideration, and I will be happy to take questions.
CITATIONS
1.
Dental caries and dental fluorosis at varying water fluoride concentrations.
Heller, K.E., Eklund, S.A. and Burt, B.A. J. Pub. Health Dent. 57 136-43
(1997).
2a.
A brief report on the association of drinking water fluoridation and the
incidence of osteosarcoma among young males. Cohn, P .D. New
Jersey Department of Health (1992).
2b.Time trends for bone and joint cancers and osteosarcomas in the
Surveillance, Epidemiology and End Results (SEER) Program. National Cancer
Institute. In: Review of fluoride: benefits and risks. Department of Health
and Humarrservices. 1991: Fl-F7.
3.
Neurotoxicity of sodium fluoride in rats. Mullenix, PJ., Denbesten, R K.
Schunior, A. and Keman, W.I. Neurotoxicol. Teratol.17169-177 (1995)
4a. Fluoride and
bone - quantity versus quality [editorial] N. Engl. J. Med. 322 845-6
(1990).
4b.Summary of workshop on drinking water fluoride influence on hip fracture
and bone health. Gordon, S.L. and Corbin, S.B. Nall. Inst. Health. April 10,
1991.
5.
Effect of fluoride on the physiology of the pineal gland. Luke, J.A. Caries
Research 28 204 (1994).
6
Newburgh-Kingston caries-fluorine study XIII. Pediatric findings after ten
years. Schlesinger, E.R., Overton, D.E., Chase, H.C., and Cantwell, K.T.
JADA 52 296-306 (1956).
7.
WHO oral health country/area profile programme. Department of
Non-Communicable Diseases Surveillance/Oral Health. WHO Collaborating
Centre, Malmo University, Sweden URL: www.whocollab.odont.lu.se/countriesalphab.html
8.
Letters from government authorities in response to inquiries on fluoridation
status by E. Albright. Eugene Albright: contact through J.W. Hirzy, PO. Box
76082, Washington, D.C. 20013.
9.
The effects of a break in water fluoridation on the development of dental
caries and fluorosis. Burt B.A., Keels, Heller KE. J. Dent. Res. 2000
Feb.79(2):761-9.
10.Toxicology and carcinogenesis studies of sodium fluoride in F344/N rats
and B6C3F1 mice. NTP Report No. 393 (1991).
11.
Effect of high fluoride water supply on children's intelligence. Zhao, L.B.,
Liang, G.H., Zhang, D.N. and Wu, X.R. Fluoride 29 190-192 (1996).
12. Effect
of fluoride exposure on intelligence in children. Li, X.S., Zhi, J.L. and
Gao, R.O. Fluoride 28 (1995).
13.Chronic administration of
aluminium-fluoride or sodium-fluoride to rats in drinking water: alterations
in neuronal and cerebrovascular integrity. Varner, J.A., Jensen, K.F.,
Horvath, W and Isaacson, R.L. Brain Research 784 284-298 (1998).
14.
Influence of chronic fluorosis on membrane lipids in rat brain. Z.Z. Guan,
Y.N. Wang, K.Q. Xiao, D.Y. Dai, Y.H. Chen, J.L. Liu, P Sindelar and G.
Dallner, Neurotoxicology and Teratology 20 537-542 (1998).
15.Letter from Rebecca Hammer, Deputy Assistant Administrator for Water, to
Leslie Russell re: EPA view on use of by-product fluosilicic (sic) acid as
low cost source of fluoride to water authorities. March 30, 1983.
16.Transcript of proceedings - Surgeon General's (Koop) ad hoc committee on
non-dental effects of fluoride. April 18-19, 1983. National Institutes of
Health, Bethesda, MD.
17.
Recommendations for fluoride use in children. Kumar, J.V and Green, E.L. New
York State Dent. J. (1998) 40-47.
18.
Highlights in North American litigation during the twentieth century on
artificial fluoridation of public water supplies. Graham, I.R. and Morin, P
Journal of Land Use and Environmental Law 14195-248 (Spring 1999) Florida
State University College of Law.
19.
Water treatment with silicofluorides and lead toxicity. Masters, R.D. and
Coplan, M.J. Intern. J. Environ. Studies 56 435-49 (1999).
20.
Why 1 changed my mind about water fluoridation. Colquhoun, J. Perspectives
in Biol. And Medicine 41 1-16 (1997).
21.Letter. Limeback, H. April 2000. Faculty of Dentistry, University of
Toronto.
22.
Memorandum: Subject: Fluoride Conference to Review the NTP Draft Fluoride
Report; From: Wm. L. Marcus, Senior Science Advisor ODW; To: Alan B. Hais.
Adine Director Criteria & Standards Division Office of Drinking Water, May
1, 1990. |
