City of SeattleJanuary 2012
REQUEST FOR NOTICE
“Mother’s milk is best for infants. This water contains more fluoride than mother’s milk. Use non-fluoridated water for infant drinking and making formula.”
Bill Osmunson DDS, MPHAesthetic, Comprehensive and
Neuromuscular Dental Practitioner, Educator, Author, Lecturer and Nutritionistwww.smilesofbellevue.com 425.455.2424
1418-112th Ave Ste 200 Bellevue, WA 98004
www.washingtonsafewater.comwww. IAOMT.org
www.fluoridealert.org
The Food, Drug, and Cosmetics Act (FDCA) and RCW 69.41.010(9) define a drug as an article:
“… intended for use in the diagnosis, cure, mitigation, treatment, or prevention of disease in man or other animal.” 21 U.S.C. 321 (g)(1)(B).
Dental caries is a disease, and fluoride is added to water with the intent to prevent caries.
The WA Board of Pharmacy has confirmed fluoride is a legend drug.The FDA CDER has confirmed the ingestion of fluoride is an unapproved drug and
unapproved drugs are illegal drugs.
FLUORIDE IS A DRUG UNDER FEDERAL AND STATE LAWS
NOT UNDER DOH DEA LICENSE
”Our Environmental Health Division provided me with the following:
The Washington State Department of Health (DOH) does not dispense fluoride. Rather, the DOH regulates water systems that choose to add fluoride to water. Therefore, DOH does not operate under any DEA license for the dispensing of fluoride.” Victor Colman, JD Sr. Policy Advisor
UNDER WHO’S DEA LICENSE DOES SEATTLE CITY FLUORIDATE PUBLIC WATER?
The WA legislature has authorized water districts to fluoridate, but authorization does not exempt FDA CDER approval, customary and general laws Federal and State laws for approval, manufacturing and dispensing.
A pea size of toothpaste has0.25 mg of fluoride,the same as one glassof Seattle water.
In 2002, the US Poison Control Centers reported 24,087 exposures involving toothpaste with fluoride. emedicine
“Flexible language”, FDA
CDC and ADA warn NOT to mix fluoridated water with infant formula. Centers for Disease Control and the American Dental Association
NO prescription fluoride before age 6 monthsNO more than one cup of water (0.25mg) 6 mo. To 3 yr. Pediatrics May 1998 Vol. 95, Number 5 RE9511
Fluoridated water has 170 times more fluoride than mother’s milk. NRC p33
Risks to fetus and babies include dental fluorosis, thyroid damage with ¼ cup, decrease in IQ, mental retardation, and more.
Burgstahler (4)2006 Fluoride www.fluorideresearch.org
http://www.fluoridealert.org/health/teeth/caries/who-dmft.html
Fluoridated vs. Unfluoridated Countries.Tooth Decay Trends for 12 Year Olds: Data from World Health Organization. (Graph by Chris Neurath).
Fluoridation makes no difference in the incidence or prevalence of dental caries.
Chen et al, BMJ 5 October 2007
Colquhoun J. Perspectives in Biology and Medicine 41, 1, Autumn 1997http://www.fluoride-journal.com/98-31-2/312103-f.htm
Huge caries crushing “UNKNOWN”Before Fluoridation
2000
CONFOUNDING FACTORS PROBLEMS WITH RESEARCH
HUGE Decay crushing “UNKNOWN”
• A. Not one Double Blinded Prospective Randomized Controlled Trial
• B. Socioeconomic status usually not controlled
• C. Inadequate Sample Size • D. Difficulty in diagnosing decay• E. Delay in tooth eruption • F. Diet: Vitamin D, calcium, strontium,
total and frequency of sugar. • G. Total exposure of Fluoride, (Water,
Toothpaste, Foods, Medicines) • H. Oral hygiene • I. Not evaluating Life time benefit • J. Estimating or assuming subject
actually drinks the fluoridated water.• K. Dental treatment expenses • L. Breast feeding and infant formula• M. Bias, fraud or gross errors. • N. Genetics
GOOD TEETH AND FLUORIDATION
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50 STATESRanked, % Whole Population Fluoridated
% .
% WholePopulationFluoridated
% High incomechildrenreportinggood/excellentteeth
% Low incomechildrenreportinggood/excellentteeth
Linear (% Highincomechildrenreportinggood/excellentteeth)Linear (% Lowincomechildrenreportinggood/excellentteeth)
Comparing 50 states , fluoridation does not improve dental health.
http://mchb.hrsa.gov/oralhealth/portrait/1cct.htm National Survey of Children's Health. very little common cause variation U.S. Department of Health and Human Services, Health Resources and Services Administration, Maternal and Child Health Bureau. The National Survey of Children's Health 2003. Rockville, Maryland: U.S. Department of Health and Human Services, 2005
http://www.cdc.gov/oralhealth/waterfluoridation/fact_sheets/states_stats2002.htm http://pubs.usgs.gov/circ/2004/circ1268/htdocs/table05.html
• Higher income = better teeth
For the rich
Or the poor
GOOD TEETH AND FLUORIDATION
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1 7 13 19 25 31 37 43 49
50 STATES
%
% WholePopulationFluoridated
% High incomechildrenreportinggood/excellentteeth
% Low incomechildrenreportinggood/excellentteeth
Linear (% Highincomechildrenreportinggood/excellentteeth)Linear (% Lowincomechildrenreportinggood/excellentteeth)
**http://www.doh.wa.gov/cfh/Oral_Health/Documents/SmileSurvey2005FullReport.pdf*http://www.oregon.gov/DHS/ph/oralhealth/docs/databook.pdf#search='Oregon%20Decay%20experience‘http://quickfacts.census.gov/qfd/states/41000.html
http://www.cdc.gov/fluoridation/fact_sheets/states_stats2002.htm
http://www.fluoridationcenter.org/papers/2002/cdcmmwr022102.htm
Oregon has better dental health with less costOregon Washington
Population fluoridated 19% 59%Decay % 6-8 yr. olds 57%* 59%**Any permanent teeth extracted 60%**** 63% “Very Good/Excellent Teeth” 58%*** 51% Low Income Children
Dental expenses $176/child/yr. $180/child/yr.*****
Median income $42,593 $48,185Preventive dental visit 45% 60%(within 12 mo Low income)
Delay in tooth eruption --- 5% compared to Oregon Bachelor’s Degree 25.1% 27.7%English spoken 88% 88%Race similar +1% Hispanic +1% Black
***National Survey of Children's Health. http://mchb.hrsa.gov/oralhealth/portrait/1cct.htm ***** Portland vs Vancouver Maupome 2007 J PHDU.S. Department of Health and Human Services, http://www.cdc.gov/oralhealth/waterfluoridation/fact_sheets/states_stats2002.htmBRFSS 2002 http://www.dhs.state.or.us/dhs/ph/chs/brfs/02/orahea/dentvisi.shtml ****http://apps.nccd.cdc.gov/brfss/display.asp?state=WA&cat=OH&yr=2004&qkey=6610&grp=0&SUBMIT4=Go Sample size OR 3509 and WA 12,926 2004 data
Washington Counties% of Washington fluoridated
46% in 199659% in 2007
City of Seattle has not considered the evidence and
continues to promote fluoridation.
dfs+DFS Caries Prevalence and % of people Fluoridated
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Washington State Counties
%Fluoridated
CariesPrevalence
Linear(CariesPrevalence)
Leroux, et al Univ. WAJ Dent Res 1996
– CDC and ADA warn infants should NOT consume fluoridated water www.cdc.gov www.ada.org
– CDC: Ingestion of fluoride is not likely to reduce tooth decay CDC (1999).
Achievements in Public Health, 1900-1999: Fluoridation of Drinking Water to Prevent Dental Caries. MMWR, 48(41); 933-940, October 22
– EPA Scientists find fluoridation borders on a “criminal act” on the part of governments NTEU 1999 Hirzy
– NIH evidence for fluoridation is “incomplete” 2001 Consensus Development Conference
Conclusion
– FDA toothpaste warning, if more than 0.25 mg is swallowed call the poison control center. (The same amount as found in ONE glass of fluoridated water)
– Most European Dental Associations and Canadian Dental Ass.say “NO” to Fluoride Supplements Zimmer 2003 and CDA has exceptions with expensive testing .
Fluoridation does NOT reduce dental expenses
Portland – Not fluoridated $176/yr. dental expenses (children)
Vancouver - Fluoridated $180/yr. dental expenses (children)
1995 Data, Published 2007 Maupome JPHD
Claims of cost benefit are based on estimates of assumptions, not measured data.
6 year dental expenses
http://www.smilesbysoileau.com
DentalFluorosis
$12,000 Treatment
Lifetime $50,000 to$100,000 damage.
•Tooth damage•Rheumatoid and osteoarthritic like pain•Bone cancer •Bone fractures•Thyroid reduction• Diabetes• Obesity•Kidney damage•Reproductive problems•Lower IQ and increased mental retardation•Allergies (overactive immune system)•Gastrointestinal disorders.
Dental Fluorosis White Spots
For references See NRC 2006 report, http://www.nationalacademies.org/morenews/20060322.html www.fluoridalert.org and contact [email protected]
National Research Council unanimous agreement: EPA’s MCL for fluoride is too high due to risks of:
Comparing 0.04 ppm serum fluoride With 0.08 ppm serum fluoride
Half a standard deviation IQ drop
Xiang 2003 & 2005 Fluoride
2005 FLUORIDATION AND 2006 MENTAL RETARDATION
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50 STATES RANKED ON % WHOLE POPULATION FLUORIDATED
Per
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000
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Mental Retardation
Linear (MentalRetardation )
8 IQ Point Loss
Ranking 50 USA States on percentage of population fluoridated, confirms half a standard deviation drop with triple the number of mentally.
http://apps.nccd.cdc.gov/giscvh/map.aspx http://apps.nccd.cdc.gov/nohss/FluoridationV.asphttp://pubs.usgs.gov/circ/2004/circ1268/htdocs/table05.html http://www.cdc.gov/mmwR/preview/mmwrhtml/00040023.htm
"In summary, we hold that fluoridation is an unreasonable risk. That is, the toxicity of fluoride is so great and the purported benefits associated with it are so small - if there are any at all – that requiring every man, woman and child in America to ingest it borders on criminal behavior on the part of governments." -Dr. J. William Hirzy, Senior Vice-President, Headquarters Union, -US Environmental Protection Agency, March 26, 2001
“The process by which EPA arrived at the RMCL for fluoride is scientifically irrational and displays an unprofessional review of relevant scientific data.” Amicus to the US Court of Appeals, DC Circuit, Natural Resources Defense Council, Inc., v EPA Civ. No. 85-1839 http://www.fluoridealert.org/health/epa/nrdc/union-brief1986.pdf
Hujoel et al.’s review in JADA (2009) by Levy 2010