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UK Against Fluoridation

Monday, November 30, 2020

Sunday, November 29, 2020

Saturday, November 28, 2020

 

3 hours ago — Reintroducing fluoride into Calgary's water will cost the city a total of $30 million, with annual operating and maintenance costs of up to $4 million.

The British Fluoridation Society

 British Dental Journal 

The late, great Labour MP Dick Crossman was instrumental in the creation of The British Fluoridation Society (BFS) in 1969. As Secretary of State for Health and Social Services he could see the need for an independent organisation to communicate the benefits of water fluoridation. BFS became the scientific and academic home of this important preventive measure.

The appeal of water fluoridation to social justice campaigners is self-evident.....

“We carry out regular surveys of public opinion which consistently demonstrate that in England, the majority of people support fluoridation of the water. Our surveys are vital to the expert briefings we provide.”............

Informed public opinion does not support fluoridation as demonstrated in Southampton.

Why Greens oppose water fluoridation - Southampton Green ...

10 Sept 2016 — The Health Authorities probably spent upwards of half a million pounds on the campaign whilst Hampshire Against Fluoridation (HAF) had to ...

The whole Southampton battle against the imposition of fluoridation is archived  here from 2008 to 2016.
 http://hampshireagainstfluoridation.blogspot.com/

There are also videos of the SHA making the decision.

Yes they did win the legal  battle as we knew they would. The final Bill when it was passed stipulated the public's opinion was not important. When going through parliament all the MPs were assured it would never be forced against the wishes of the people.

In the final Bill that promise was left out so legally of course the judge had to agree with the SHA





Thursday, November 26, 2020

TheyWorkForYou - Parliament

 NHS Dentistry and Oral Health Inequalities (25 Nov 2020)

https://www.theyworkforyou.com/whall/?id=2020-11-25a.407.0&s=fluoride+fluoridation#g412.1
Jo Churchill: ...impact on somebody’s quality of life, particularly a
child’s, and dental disease is entirely preventable. In the Green
Paper published in 2019 we committed to looking at those barriers, to
*fluoridation* and to consulting on rolling out supervised
tooth-brushing schemes in more preschool and primary settings. We are
working as hard as we can to make sure we hit the consultation dates,...

fluoride fluoridation : 1 Written Answer
========================================

Written Answers - Department of Health and Social Care: Dental Services: Children (24 Nov 2020)
https://www.theyworkforyou.com/wrans/?id=2020-10-22.107597.h&s=fluoride+fluoridation#g107597.r0
Jo Churchill: ...committed to consulting on rolling out a supervised
toothbrushing scheme in more pre-school and primary school settings in
England. We also committed to exploring the barriers to increasing water
*fluoridation*. No date has yet been set for this consultation.

Tuesday, November 24, 2020

UK Parliament

 

Photo of Alex NorrisAlex Norris Shadow Minister (Health and Social Care)

To ask the Secretary of State for Health and Social Care, when the Government will announce further details of its water fluoridation plans.

Photo of Jo ChurchillJo Churchill The Parliamentary Under-Secretary for Health and Social Care

The Department of Health and Social Care has indicated that it will not be possible to answer this question within the usual time period. An answer is being prepared and will be provided as soon as it is available.

Friday, November 20, 2020

F.A.N. Newsletter

 The NTP Review: “A Chipped Vase”

Before FAN deals with the “Chip” let us again make very clear that we are happy with the “vase.” The NTP review is one of the most comprehensive reviews of fluoride’s neurotoxicity ever conducted. Its overall findings that fluoride is a “presumed neurotoxicant” and the evidence that it lowers children’s IQ at 1.5 ppm or above is sufficient in itself to end the reckless practice of water fluoridation. We could then, like any proud homeowner, simply turn the vase so the “chip” faces the wall, but we can’t. The NTP’s conclusion in the section dealing with the relevance to America (i.e. water fluoridation) is that the evidence is “less robust and less consistent” in studies at levels of exposure less than 1.5 ppm than above, is simply not true. The science does not support such a conclusion. In fact, the strongest studies, published since 2017 – and funded by the NIH – were conducted at levels less than 1.5 ppm and at the same exposure levels experienced in artificially fluoridated communities at the recommended 0.7 ppm.

Our suspicion is that this false information was slipped in to the NTP Review by a pro-fluoridation element to provide a thread on which government bodies can hang continued support for this outdated policy. Those who are unfamiliar with normal risk assessment practices might argue that 1.5 ppm is about twice as high as 0.7 ppm and it offers an adequate margin of safety for water fluoridation programs, but they would be wrong. It might be very tempting for the EPA to set a maximum contaminant level (MCL) of 1.5 ppm for fluoride, which would bring it in line with Mexico, Canada and the WHO. However, this would also be wrong – in fact all of these countries and WHO will eventually have to tighten their own standards to fit reality and the science. Simply put, fluoride research on neurotoxicity is following the same trajectory as the research on lead’s neurotoxicity from the 1970s to 1990s; namely, as far as early life is concerned there is virtually no safe level of exposure.       

At a time where the public’s trust in government agencies is reaching an all-time low, it is absolutely essential that we maintain trust in both the NTP and its parent agency NIEHS by making sure that its reports are not tainted with any political interference. That is why we are again giving chapter and verse on the science here. We are doing it in the form of three figures which all point to the simple truth that the science shows that the studies conducted at exposure levels less than 1.5 ppm are as robust – if not more so – as those studies conducted above 1.5 ppm. There is no “chip”, the “vase” is whole.

The first figure is a table summarizing the 29 studies the NTP rated as higher quality (lower Risk of Bias is NTP’s terminology). Two of the studies were essentially duplications of a third so have been excluded. Of the 27 different high quality studies, 25 found statistically significant adverse neurotoxic effects and only 2 found no significant effect. None found a significant beneficial effect.

Of the 25 finding adverse effects, 15 were at exposures below 1.5 mg/L and 11 of those found effects below 0.7 mg/L, with the 10 remaining finding effects at or above 1.5 mg/L. This represents overwhelming consistency both below and above 1.5 mg/L.

FAN has submitted the detailed explanation of how each of the 25 studies were classified by exposure to the NAS and NTP.

Table 1: Summary of the key data from the highest quality studies reviewed by NTP.

The second figure is a graph summarizing Table 1.

Figure 2: Bar graph summarizing the findings presented in Table 1 above.

The third figure summarizes results of a meta-analysis comparing the main findings for studies above 1.5 ppm versus below 1.5 ppm for all the higher quality studies for which exposure data is available at the individual level (as opposed to group-level).  This is a forest plot (named because to someone it resembles a tree) which shows the effect size found in each study by its position on the x-axis. The degree of weight given to each study is indicated by the size of its gray box.  The pooled overall estimates of effect size and significance are shown by the blue diamonds.  The units are IQ points lost for every 1 mg/L increase in the concentration of water fluoride or urine fluoride. Black dot point estimates that are to the left of the vertical black zero line indicate loss of IQ.  There are no black dots to the right of the zero line which would indicate a beneficial effect of fluoride on IQ.  The black horizontal lines extending on either side of the black dots indicate the 95% confidence interval and when they are entirely below zero the finding is considered to be statistically significant.

Figure 3.  Forest plot summarizing meta-analysis of high quality studies.

As can be seen, multiple high quality studies, conducted in varied populations, consistently found strong associations between loss of IQ or other adverse developmental neurobehavioral outcomes at fluoride exposures commonly occurring from artificial fluoridation.  At exposures below 1.5 mg/L the effect size was actually greater than in the studies above 1.5 mg/L (-4.04 versus -2.40 IQ points per 1 mg/L fluoride).  While the NTP review's authors included a statement in the narrative portion of their review stating, "the evidence that fluoride lowers IQ is less robust and less consistent at levels below 1.5ppm," this biased claim is not supported by the data NTP themselves extracted from the original studies. 

In fact, the highest quality studies, including several funded by NIH, strongly suggest that artificial fluoridation poses an unprecedented neurotoxic risk to a large proportion of the children in the US and other fluoridated countries.

Sincerely,

Paul Connett
Executive Director

Thursday, November 19, 2020

Dr. Roger Hodkinson, MA, MB, FRCPC, FCAP, CEO and medical director of Western Medical Assessments,

Leading Canadian Health Expert Outraged at Government Response to COVID

“I would remind you all that using the province's own statistics, the risk of death under 65 in this province is one in 300,000. One in 300,000. You’ve got to get a grip on this.”

Wednesday, November 18, 2020

Tuesday, November 17, 2020

Monday, November 16, 2020

Saturday, November 14, 2020

2004 A Quantitative Look at Fluorosis, Fluoride Exposure, and Intake in Children Using a Health Risk Assessment Approach

 

Abstract

The prevalence of dental fluorosis in the United States has increased during the last 30 years. In this study, we used a mathematical model commonly employed by the U.S. Environmental Protection Agency to estimate average daily intake of fluoride via all applicable exposure pathways contributing to fluorosis risk for infants and children living in hypothetical fluoridated and non-fluoridated communities. We also estimated hazard quotients for each exposure pathway and hazard indices for exposure conditions representative of central tendency exposure (CTE) and reasonable maximum exposure (RME) conditions. The exposure pathways considered were uptake of fluoride via fluoridated drinking water, beverages, cow’s milk, foods, and fluoride supplements for both age groups. Additionally, consumption of infant formula for infants and inadvertent swallowing of toothpaste while brushing and incidental ingestion of soil for children were also considered. The cumulative daily fluoride intake in fluoridated areas was estimated as 0.20 and 0.11 mg/kg-day for RME and CTE scenarios, respectively, for infants. On the other hand, the RME and CTE estimates for children were 0.23 and 0.06 mg/kg-day, respectively. In areas where municipal water is not fluoridated, our RME and CTE estimates for cumulative daily average intake were, respectively, 0.11 and 0.08 mg/kg-day for infants and 0.21 and 0.06 mg/kg-day for children. Our theoretical estimates are in good agreement with measurement-based estimates reported in the literature. Although CTE estimates were within the optimum range for dental caries prevention, the RME estimates were above the upper tolerable intake limit. This suggests that some children may be at risk for fluorosis.

Friday, November 13, 2020

Can fluoride make your baby dumber?

The latest science seems to suggest that fluoride is a brain poison for babies. As fluoride is not a nutrient, but a registered pesticide, there is no need for a baby to consume fluoride. Cavities can be prevented by making sure that the child avoids acidic, sugary drinks and sleeps with its mouth closed. 

Wednesday, November 11, 2020

House of Lords

 

Photo of Lord Hunt of Kings HeathLord Hunt of Kings Heath Labour

My Lords, I declare my interest as president of the British Fluoridation Society. Just on that last point, in a number of parts of the country, no elective surgeries, except for those that might be totally prioritised, are being done at the moment. The prospect is of a few more months with a virtual lockdown of elective surgery. As far as children are concerned, will the Minister look into this matter urgently? Will the Government prioritise preventive schemes as we come out of the pandemic, such as fluoridation, supervised tooth-brushing programmes in schools and public service ads?

Photo of Lord BethellLord Bethell The Parliamentary Under-Secretary for Health and Social Care

My Lords, I completely agree with the noble Lord that prevention is the key. In our document on the matter, Advancing Our Health: Prevention in the 2020s, we have committed to the consulting on and rolling out of supervised tooth-brushing schemes in more preschool and primary school settings in England. We have also set out our support for expanding water fluoridation, and we intend to announce further details of our water fluoridation plans shortly.




Saturday, November 07, 2020

F.A.N. Newsletter

As you might recall, the Court requested on the last day of the trial that we submit a new Petition to the Environmental Protection Agency (EPA) to allow them the opportunity to respond to our original 2016 Petition in regards to the new studies that were published between 2017-2020.  The Court also requested that we include Petitioners who were pregnant or planning a pregnancy in light of the science linking early-life exposure to fluoridated water to adverse neurodevelopmental effects” in these new studies.

Yesterday’s meeting with the Judge

At the very short meeting convened by the Judge, lawyers representing both sides were in attendance. Lead attorney Michael Connett told the Court that he filed, on November 4, a Supplement to our original Petition with the EPA. The Supplement asks that EPA reconsider their denial of our 2016 Petition. The reasons are set forth in the Supplement and it’s 9 attachments (all listed below). The Supplement has done everything the Court asked us to do with a new Petition. The Supplement also responds to the issue of Standing by identifying nine members of Food & Water Watch “who are currently pregnant, women who are actively seeking to become pregnant, and/or mothers of infants…"

We believe that this is an important and highly readable document and we urge our supporters to read it in full. However, if time is short we have presented excerpts below.

Background to the Supplement

“On November 22, 2016, the undersigned Petitioners submitted a Citizen Petition under Section 21 of the Toxic Substances Control Act (“TSCA”), requesting that the EPA prohibit the addition of fluoridation chemicals to drinking water in order to protect the public, including susceptible subpopulations, from fluoride’s neurotoxic risks.  After the EPA denied this petition, the Petitioners brought suit in the Northern District of California to challenge EPA’s denial. Following a bench trial in June of 2020, the Court stated that EPA had used an incorrect standard in assessing the evidence that the Petitioners had presented. .. The Court also noted that much of the evidence that the Petitioners relied upon at trial—including recent studies funded by the National Institutes of Health (NIH)— was not yet available at the time EPA denied the Petition. (Appendix A at 4.) In light of these facts, the Court asked Petitioners to re-submit evidence to the EPA in order to give the Agency an opportunity to give the evidence a “second look” using the “proper standard” at the administrative level, which the Court 'urged' the EPA to do."

"Pursuant to the Court’s request, the Petitioners are hereby submitting this Supplement to their Petition and requesting that EPA reconsider its denial of the Petition based on the information presented herein."

EPA HAS THE AUTHORITY TO RECONSIDER ITS DENIAL OF A SECTION 21 PETITION

"EPA has the inherent authority to reconsider its denials of Section 21 petitions, as the EPA itself has repeatedly acknowledged. The EPA has explained that: “Although TSCA does not expressly provide for requests to reconsider EPA denials of Section 21 petitions, ‘the courts have uniformly concluded that administrative agencies possess inherent authority to reconsider their decisions, subject to certain limitations, regardless of whether they possess explicit statutory authority to do so.’” … As the EPA has explained, “the power to reconsider is inherent in the power to decide.” Id. at 24 (quoting Albertson v. FCC, 182 F.2d 397, 399 (D.C. Cir. 1950)) …"

GROUNDS FOR PETITIONERS’ REQUEST FOR RECONSIDERATION

1. EPA Used an Incorrect and Impermissibly Stringent Standard of Proof

“At the close of trial in June 2020, the Court observed that EPA has subjected Petitioners’ evidence to an incorrect standard of proof. As the Court noted, “EPA appears to have applied a standard of causation ... It's not the proper standard.” (6/17 Trial Tr. 1131:5-9.)

“TSCA commands that EPA protect against “unreasonable risk,” which exists when human exposure to a toxicant is unacceptably close to the estimated hazard level. (6/10 Trial Tr. 471:11-472:9.) At trial, EPA confirmed that 'EPA does not require that human exposure levels exceed a known adverse effect level to make an unreasonable risk determination under TSCA.' (Appendix H at 4.) Thus, EPA does not require proof that human exposures under a given condition of use cause the hazard. In fact, Dr. Tala Henry agreed at trial that EPA has “never once in any of its risk evaluations to date under Section 6 used a causation standard.” (6/16 Trial Tr. 987:6-8.) Despite this, Dr. Henry admitted that EPA held Petitioners to a burden of proof where Petitioners needed to prove that human exposure to fluoride in water at 0.7 mg/L causes neurotoxicity. (6/16 Trial Tr. 985-15-987:2.) Dr. Henry thus made the extraordinary admission that EPA 'held the plaintiffs to a burden of proof that EPA has not held a single chemical under Section 6 before.' (6/16 Trial Tr. 987:16-19.)…"

2. Each of the Limitations that EPA Identified with the Fluoride/IQ Studies in the Petition Have Now Been Addressed by High Quality Studies Funded by the NIH

"In its denial of the Petition, the EPA criticized the human studies that Petitioners cited on three primary grounds: (1) the studies were cross-sectional and thus 'affected by antecedent consequent bias';1 (2) the studies failed to adjust for potential confounding factors; and (3) the studies failed to adequately establish a dose-response relationship between fluoride and neurotoxicity. (Fed Reg, Vol. 82, No. 37, p. 11882-83). …

"Following EPA’s denial of the Petition in February 2017, a series of prospective cohort studies funded by the National Institutes of Health (NIH) were published which evaluate the impact of individualized measurements of prenatal and early-infant fluoride exposure on standardized measures of neurobehavioral performance between ages 4 and 12 (Bashash 2017, Bashash 2018, Green 2019, Till 2020)."

"These NIH-funded studies address each of EPA’s three criticisms of the studies in the Petition…"

3. The National Toxicology Program Has Concluded that Fluoride Is a Presumed Human Neurotoxicant that Lowers IQ in Children

"Petitioners’ contention that fluoride is a neurotoxicant has gained powerful new support from the National Toxicology Program’s (NTP) recently revised systematic review and meta-analysis…"

A. NTP Agrees that Fluoride Is a Likely Neurodevelopmental Hazard to Humans

"On September 16, 2020, the NTP released its Draft Monograph on the Systematic Review of Fluoride Exposure and Neurodevelopmental and Cognitive Health Effects. The Monograph is a revised version of a draft issued in October 2019, and incorporates the recommendations made by a committee of the National Academy of Sciences (NAS). After making the changes recommended by the NAS, the NTP reconfirmed its conclusion that 'fluoride is presumed to be a cognitive neurodevelopmental hazard to humans.' (p. 2) …"

B. The Relationship Between Fluoride and Neurotoxic Effects Is Unlikely to Be Explained by Confounding or Other Issues of Methodology and Bias

"The NTP reached its hazard conclusion for fluoride after carefully considering issues of study quality and bias, including potential confounding, publication bias, translation bias, and the validity of exposure and outcome assessments. Each of these methodological issues were raised at trial by EPA to question the confidence in the numerous studies reporting neurotoxicity from fluoride exposure. Importantly, the NTP’s report makes clear that none of the issues identified by EPA at trial warrant a downgrade in the confidence that fluoride is a human neurotoxicant. In other words, the issues identified by EPA at trial do not explain the overwhelmingly consistent association between fluoride and neurotoxic harm…"

C. The NTP Identified a Large Number of Low Risk-of-Bias Studies Linking Fluoride to Neurotoxicity

"… In total, the NTP identified 31 human studies on fluoride and neurodevelopment that it found to have a relatively low potential for bias (p. 25) and the vast majority of these studies found significant associations between fluoride and adverse effects. This highlights that the association between fluoride and neurotoxicity is not the artifact of poor study design or bias, as EPA argued at trial."

D. The NTP Has Judged the New Zealand Studies that EPA Has Relied Upon to Be at High Risk of Bias

E. The Animal Data Supports the Conclusion that Fluoride Produces Neurodevelopmental Effects

F. The NTP’s Recently Retired Director Has Called for Measures to Protect Pregnant Women and Bottle-Fed Babies from the Neurotoxic Effects of Fluoride

"The relevance of the NTP’s findings to water fluoridation has recently been highlighted by none other than the recently retired director of the NTP, Dr. Linda Birnbaum. On October 7, 2020, shortly after the NTP released its revised Monograph, Dr. Birnbaum issued a public statement calling for measures to protect pregnant women and bottle-fed babies from the neurotoxic effects of fluoride. Dr. Birnbaum noted that the NTP’s conclusion is 'consequential,' given that “about 75 percent of Americans on community water systems have fluoride in their water.'…"

G. Limitations and Weaknesses of NTP’s Report

"The NTP Monograph provides an exceptionally comprehensive review of the scientific literature on fluoride neurotoxicity, and provides ample support for its conclusion that fluoride is a neurotoxicant that reduces IQ. There are, however, some limitations and weaknesses with the NTP’s analysis that Petitioners wish to bring to the EPA’s attention…"

H. Even with Its Limitations, the NTP Monograph Demonstrates that Water Fluoridation Poses an Unreasonable Risk of Neurodevelopmental Harm

"Even with its limitations, the NTP Monograph demonstrates that neurotoxicity is an unreasonable risk of water fluoridation…"

4. Pooled BMD Analysis of the NIH-Funded Birth Cohort Data Confirms that Pregnant Women in Fluoridated Areas Are Exceeding the Dose Associated with IQ Loss

"A team of scientists, including the authors of the NIH-funded studies, have recently completed a pooled benchmark dose (BMD) analysis of the maternal urinary fluoride data from the ELEMENT and MIREC datasets (Grandjean, et al. 2020, in review)… Given that BMD analysis is EPA’s preferred method for determining toxicity values and risk estimates, the new pooled analysis provides compelling grounds for EPA to reconsider its denial of the Petition. The analysis, which became publicly available on November 4, 2020, is attached as Appendix G…"

5. Millions of Americans Are at Risk of Harm as a Result of EPA’s Failure to Regulate Fluoridation, Including Petitioners

"… Each year, there are approximately 2.5 million pregnancies in fluoridated areas; in utero exposures are thus widespread. (Appendix B at p. 78 ¶ 406.) Many of those exposed in utero will also be exposed during the sensitive neonatal period, with upwards of 1.9 million infants living in fluoridated areas being fed formula at least part of the time, including 400,000 infants who are exclusively formula-fed for their first six months. (Id.) Petitioner Organizations have members who fall within these zones of danger…"

6. EPA Erred in Considering the Purported Dental Benefits of Fluoridation in its Denial of the Petition

"In its denial of the Petition, EPA cited the purported dental benefits of fluoridation as a basis for its denial. This was improper because the Amended TSCA statute forbids risk evaluations from considering 'costs and other nonrisk factors.' 15 U.S.C. § 2620(b)(4)(B(ii). …"

7. EPA Erred in Claiming that Petitioners Failed to Adequately Identify the Chemicals at Issue

"… During the litigation on this matter, the Court considered and rejected each of these arguments, and held that the Petitioners had adequately identified the chemicals at issue, and that there was no merit to EPA’s contention that it 'would become obligated to address all conditions of use of the category.'" 

Thursday, November 05, 2020

Fluoride exposure and intelligence in school-age children: evidence from different windows of exposure susceptibility

 

Conclusions

Prenatal and childhood excessive fluoride exposures may impair the intelligence development of school children. Furthermore, children with prenatal fluoride exposure had lower IQ scores than children who were not prenatally exposed; therefore the reduction of IQ scores at higher levels of fluoride exposure in childhood does not become that evident.

F.A.N. Newsletter

 This Thursday, November 5th, at 10:30AM (Pacific US) / 1:30PM (Eastern US) Judge Edward Chen will hold a status hearing on our TSCA case in federal court.   

At the end of the trial in July, the judge urged the EPA to independently re-assess the hazard posed by fluoridation chemicals.  At the last status hearing in August, the EPA claimed that they "didn't have the resources to do a risk assessment," and were going to let the court record stand without taking any further action.  The judge continued to insist the EPA reconsider their position, and also said he wanted to review the updated National Toxicology Program's review of fluoride's neurotoxicity, which was released this October.

On Thursday, the judge will see if the EPA has made any progress in re-evaluating fluoride's safety, or if FAN intends to submit an updated TSCA petition that the EPA will have no choice but to assess over a 90-day period.     

The proceeding will be open for public viewing on Zoom.   Below is the sign in information provided by the judge to watch or listen to his meetings.

Link to join TSCA trial zoom hearing:
https://cand-uscourts.zoomgov.com/j/1619911861?pwd=TjVma1lnMlJlNHR3ZE9QMkFjNkFndz09

Meeting ID: 161 991 1861
Password: 912881

Tuesday, November 03, 2020

Pervasive, Unsafe Exposures to Mercury and Fluoride, Developmental Toxicants that Are Biologically Plausible Causal Agents in the Jaw Epidemic

Kahn and colleagues (2020) highlight the underrecognized, modern epidemic of jaw shrinkage, including crowded teeth and constricted airways, but overlook a powerful explanatory variable: our pervasive exposures to developmental toxicants. In a landmark 2014 review on environmental causes for the epidemics of neurodevelopmental disorders, which affect 10%–15% of all US births, 11 common chemicals were recognized as neurodevelopmental toxicants (Grandjean and Landrigan 2014). Of these, we address mercury and fluoride. Both are systemic toxicants; they target certain molecular components having key roles in fundamental cellular processes—­including mineral assimilation, enzyme function, energy production, and gene expression. Both are particularly harmful during fetal and childhood development. Both have been used... 

Thursday, October 29, 2020

F.A.N. Newsletter

Summary

The Fluoride Action Network (FAN) is pleased that the updated NTP Review has re-confirmed that fluoride is “presumed to be a cognitive neurodevelopmental hazard to humans.” We would also underline that

the NTP rating of “presumed” is the highest confidence rating possible
without doing a controlled human experiment, which would be unethical. 
Human experiments are not allowed for testing toxicity of a chemical

However, FAN is concerned with NTP’s highly flawed “risk assessment” which claims that

the evidence that fluoride lowers IQ in children is less robust and less consistent
at levels below 1.5 ppm.

This claim is not supported by the science that their review used. The highest quality studies, including several funded by the National Institute for Environmental Health Sciences, have shown that IQ (or cognitive development) is lowered at exposure levels experienced in communities that have fluoridation programs which add 0.7 ppm fluoride to the water (Bashash 1 2017; Green 2 2019 and Till 3 2020).

Background

The National Toxicology Program (NTP) performed a Systematic Review of Fluoride Exposure and Neurodevelopmental and Cognitive Health Effects (the “Review). This Review was initiated in response to a nomination from FAN. The NTP began the Review in 2016 and produced its first draft in 2019. The first draft Review was sent to the National Academies of Sciences, Engineering and Medicine (NASEM) for peer review. The NASEM Committee (see members below) that performed the peer-review recommended that NTP make several changes. The NTP incorporated the changes requested and released a second draft Review in September 2020 which was sent to NASEM for a second peer-review.

The NASEM Committee held a zoom meeting on October 19 that was open to the public and gave FAN’s Science Director, Chris Neurath, the opportunity to communicate our agreement with their overall finding but challenge their flawed risk assessment.

Making the best studies disappear

At this meeting FAN was shocked when Kyla Taylor, of the NTP, showed a slide of a table of results from a NTP meta-analysis of IQ studies that indicated that the Bashash 2017 study did not find a lowering of IQ!  See figure A5-6 on page 268 of the Review:

This figure above shows a Forrest plot for the range of IQ loss for a meta-analysis of all the high-quality studies. The bottom axis shows the IQ points lost. The NTP authors show the IQ values in the Bashash, 2017 study range from a loss of 0.18 to an increase of 0.42 IQ points with a mean IQ above the No effect level (0). Such a selected data set is miss-leading and a miss-representation of the full Bashash study. Even so the overall SMD for all the studies combined is -0.50 which is equivalent to a loss of 7-8 IQ points. So while this meta-analysis does not affect the overall – and vitally important - conclusion that fluoride is a presumed developmental neurotoxicant, this manipulation of the Bashash study helped the NTP to incorrectly question the robustness of the studies performed at less than 1.5 ppm and their relevance to the US fluoridation program.

How could this have happened?

For those who have followed the studies on fluoride’s neurotoxicity, Bashash 2017 had been the big breakthrough study showing a strong relationship between pregnant women’s exposure to fluoride and 1) a lowered cognitive function (CGI) in their offspring at 4 years of age and 2) a lowered IQ measured between 6 and 12 years of age. It was the breakthrough moment when they confirmed that the critical period of vulnerability to fluoride’s neurotoxicity was during fetal development.  So how could the NTP now suggest that the Bashash study does not show a lowering of IQ? 

Neurath has delved into how the NTP reached this “extraordinary” conclusion about the Bashash 2017 findings in particular and the studies at lower fluoride exposures generally?  The good news from a science perspective is that the NTP is wrong.  However, FAN is deeply concerned about why such disturbing manipulations occurred. It leaves us questioning whether the CDC or other pro-fluoridation forces have corrupted the NTP’s analysis.

While this downplaying of the Bashash 2017 study did not alter the overall conclusion that fluoride is a presumed developmental neurotoxin, it is a key factor in the NTP’s tacked-on claim that at exposure levels relevant to the US and artificial fluoridation, the evidence is “inconsistent” and “unclear."

This claim arises in a section the NTP added that they call "Generalizability to the US”. It is essentially a risk assessment.  This section was never within the planned scope nor was it in the protocol, so it violates a fundamental principle of systematic review. The NAS peer review panel itself said in 2019 it was not appropriate.  But worse than doing an unplanned risk assessment, the NTP used improper methods that underestimate the confidence that fluoride causes developmental neurotoxicity at levels relevant to the US and to artificial fluoridation – which is what the strongest studies have found.

FAN’s submission to the NTP/NAS

Chris Neurath, on behalf of FAN, submitted formal written comments to NASEM and NTP, as well as the short oral comments during the public meeting:

  1. Transcript of Chris' 5-minute oral presentation at the Oct 19 meeting (see above).
     
  2. Outline summary of findings.
     
  3. Full written submission to the NTP and NAS.

Chris identified and explained how the NTP downgraded evidence in the 2020 review. The following are the downgrades (fully discussed in Chris’ submission – see 3. above)

NTP downgraded the following evidence in their 2020 Review. The NTP:

• Excluded the largest effect in the strongest study: Bashash 2017.
• Excluded strongest low-dose studies from dose-response meta-analysis.
• Unnecessary division of studies lowers power in dose-response meta-analyses.
• Simplistic exposure assessment underestimates hazard at doses relevant to US.
• NTP’s simplistic dose-response meta-analysis methods underestimated effects at low doses because they used the mean exposure while most studies had individual-level exposures that ranged well below the mean.
• Improperly downgraded the animal evidence to “inadequate” despite the NTP 2016 review of the animal evidence concluding it was “low to moderate”.
• The NTP monograph deviated from the OHAT guidelines in its section “Generalizability to the U.S. Population”.
• Meta-analyses have inadequate documentation.

Downgrading the Bashash study

On the specific case of the “downgrading” of the Bashash study discussed above, Neurath gives several examples, here are two:

  1. The NTP discriminated against the findings in the Bashash study by ignoring neurocognitive development findings for 4-year-olds in favor of the IQ studies for 6-12-year-olds. They used the latter finding to conclude a threshold for lowering of IQ at 0.8 ppm in maternal urinary levels. Whereas, the excluded analysis for cognitive index (GCI) in 4-year-olds found a linear dose-response relationship with no threshold down to the lowest measured level of 0.2 ppm. This bizarre exclusion was based on the NTP’s characterization of GCI (General Cognitive Index) scores as an “other outcome” rather than a measure of neurocognitive development. These GCI measures are used for young children where IQ measures are less appropriate. GCI is generally considered as a valid measure of neurocognitive development and the NTP was wrong to exclude this key analysis.
     
  2. Also for the Bashash study, the NTP focused on a secondary analysis which used childhood urine fluoride levels dichotomized into just two levels (below 0.8 ppm versus 0.8 ppm and above) as the measure of fluoride exposure, instead of the primary analyses, which used maternal urine fluoride levels. The former only found a small non-significant effect, the latter a large and significant effect (11 IQ points lost per 1 ppm maternal urine fluoride).

Bashash 2017 was a landmark study in part because

• it was the first to focus directly on fetal fluoride exposure
• it was a longitudinal cohort study (of the subtype prospective cohort)
• it had individual-level exposure data
• it controlled for a wide range of other factors
• it was very rigorously conducted 

Many of the previous ecological studies in China had been restricted to children who were mostly life-long residents of a single location with a constant water F concentration.  For those studies, their prenatal exposure would have been similar to their exposure measured when they were older children.  So, the prenatal period was captured in those studies and probably explains why the IQ loss was so great in many of them, with an average of -7 IQ points

Paul Connett’s submission

A separate submission by FAN executive director, Paul Connett, PhD, emphasizes that NTP’s conclusion of harm to the developing brain at levels at or above 1.5 ppm offers no adequate margin of safety to protect all children in the USA. It is standard practice in Risk Assessment to divide a dose that finds harm in a human study by 10 to determine a safe dose sufficient to protect the whole population. This is especially needed In the case of fluoride, not only to allow for the anticipated range of genetic susceptibility in a large population of children but also to allow for wide range of doses they are likely to experience. If we ignore the difference between dose and concentration, 1.5 ppm divided by 10 would indicate that in order to protect the whole population the level of fluoride allowed in water should not be higher than 0.15 ppm. 

A simple way of demonstrating why a safety factor is necessary is to look at the EPA’s exposure assessment handbook where it shows that the 5% of Americans who drink the most water drink twice as much as the average.  Therefore, the NTP’s conclusion that water concentrations of 1.5 ppm are presumed to cause neurotoxic harm to those who consume AVERAGE amounts of water, would also apply to anyone drinking twice as much water with a concentration of around 0.7 ppm.  Their internal dose would be roughly the same as those drinking water with 1.5 ppm.

From even such a simple but valid Risk Assessment, it is clear that adding fluoride to water at 0.7 ppm (the current recommended level) is likely to be harming some children. Paul Connett’s commentary on Margin of Safety can be viewed on video.

FAN was pleased to see that Dr. Linda Birnbaum, former head of both the NIEHS and the NTP, submitted her Oct 19 Op-ed to the NASEM panel for their consideration. In this Op-ed she advised that there was enough solid evidence in the available neurocognitive studies for regulatory bodies to recommend to pregnant women that they avoid fluoridated water and parents not use fluoridated tap water to make up baby formula.

We have provided links to all the documents pertaining to the NTP’s systematic review and our criticisms. See the Overview of the NTP study that contains the documents, news articles, and videos.