STATEMENT OF Dr. J. WILLIAM HIRZY
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,
biologists, 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 labor 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 fertilizer 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 behavioral 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 un-controlled 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 anti-social behavior; and 9)
changing views among dental researchers on the efficacy of water fluoridation
Fluoride Exposures Are Excessive and
Un-controlled According to a study by the National Institute of Dental Research,
66 percent of America's children in fluoridated communities show the visible
sign of over-exposure and fluoride toxicity, dental fluorosis (1). That result
is from a survey done in the mid-1980's and the figure today is undoubtedly much
higher.
Centers 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 over-exposure.
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 discernable 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 down-grading 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 (3) shows a link between prenatal exposure of
animals to fluoride and subsequent birth of off-spring 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
(5) links fluoride dosing to adverse effects on the brain's pineal gland and
pre-mature 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, recognized the world
over and in the U.S. before the linguistic de-toxification 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 Hanmer (15), that
EPA views the use of hydrofluosilicic acid recovered from the waste stream of
phosphate fertilizer manufacture as,
"...an ideal solution to a long standing
problem. By recovering by-product fluosilicic acid (sic) from fertilizer
manufacturing, water and air pollution are minimized, 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, hydrofluosilicic 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 Centers 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 Aukland 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 deleterious 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."
Judge Anthony Farris in Texas found: "[That]
the artificial fluoridation of public water supplies, such as contemplated by
{Houston} City ordinance No. 80-2530 may cause or contribute to the cause of
cancer, genetic damage, intolerant reactions, and chronic toxicity, including
dental mottling, in man; that the said artificial fluoridation may aggravate
malnutrition and existing illness in man; and that the value of said artificial
fluoridation is in some doubt as to reduction of tooth decay in man."
The significance of Judge 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 commitments 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 three
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 behavior. 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 pro-fluoridation
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 Aukland, 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 you 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 Human Services.1991: F1-F7.
3.Neurotoxicity of sodium fluoride in rats.
Mullenix, P.J., Denbesten, P.K., Schunior, A. and Kernan, W.J. Neurotoxicol.
Teratol. 17 169-177 (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. Natl. 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, Malm” 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, P.O. 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 aluminum- 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 Hanmer, 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, J.R. and Morin, P. Journal of Land Use and Environmental Law
14 195-248 (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 I 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, Acting Director Criteria & Standards Division
Office of Drinking Water. May 1, 1990.
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