Here’s what I could do for you for the time being today. Thanks for your work.  

                                   Feb. 21, 2010

Comments for the Port Angeles case on water fluoridation, 82225-5, Supreme Court, Washington State

Submitted from:

Dr. Richard D. Sauerheber, Ph.D. Chemistry, University of CA, San Diego, La Jolla, CA 92037

Currently Palomar College, San Marcos, CA 92069

  First, on page 37 of the Pollick article, a sweeping bold claim is made that is false, that “there is no credible evidence that the [fluoride] chemicals are unsafe.”  This bias held by the author is easily refuted below with just one simple example.  Second, the court briefing points contained additional falsehoods, particularly regarding the claim that LD₅₀’s have no applicability to water fluoridation and that fluoride chemicals ingested and assimilated into the blood are not being used as drugs.

   On page 94 of the National Research Council Report on Fluoride in Drinking Water, 2006, note that in only 24 months consuming water with fluoride (Cumulative data from natural and artificially fluoridated water at these levels!!) at 1-4 ppm that fluoride incorporates irreversibly into bone at thousands of times that in the water. This is consistent with the fact that only 50% of assimilated fluoride is ever excreted. The NRC found that once fluoride incorporates into bone it is permanent. Bone fluoride cannot be removed or lowered even after transfer for 25 years to fresh water consumption. The fact that the accumulation is a linear dose response that is not saturable, even to levels above 12,000 ppm in bone (p. 95) and is not reversible demonstrates without doubt that this effect is pathologic, not physiologic. All mineral nutrients required to support physiologic processes always exhibit effects in dose response studies that are fully saturable and are reversible and cuvilinear.

   At 1 ppm water fluoride, on average where blood levels are 0.21 ppm (p. 70) bone levels are several thousand ppm typically, with scatter in the data determined mainly by water hardness and calcium ion content.  After lifetime consumption by reasonable extrapolation from lifetime consumption data for 3-4 ppm water (10,000- 12,000 ppm in bone which often causes hospitalization for severe bone pain) 1 ppm water leads to about 4-5,000 ppm in bone.  The NRC concluded that levels above 3,000 ppm definitely weakens bone to a significant, readily detectable degree.  Yes, the error of measurement is larger than the smaller effect noted at 1 ppm for 2 years (2,000 ppm in bone), but any claim bone at this level is magically not weakened at all is erroneous. Indeed, this is why toxicology data at high accumulation levels are needed to help determine any significance of data at much lower incorporation levels (that of course continue to accumulate toward significant levels with continued consumption).  We have an epidemic of hip fractures in the elderly that are fatal during convelescence while waiting for bone to heal. Fluorotic bone is weakened and metabolically abnormal and I personally blame artificial fluorides as a chief cause of this rise in slow healing of fractures experienced in recent decades.

   The idea that the NRC report does not apply to ‘water fluoridation’ is an incredible sweeping claim, that in fact completely contradicts the claim also made, that fluosilicic acid after dilution is argued by fluoride promoters to mimic natural water fluoride. Which is it? This self-contradiction is simply bizarre, where fluosilicic acid after dilution duplicates natural fluoride (from calcium fluoride, not an acute toxic compound with an LD₅₀ of 3,500 ppm), and yet since some of the data in the NRC Report are from natural fluoride water, the entire data set (which includes also unnatural fluoridated water AS WELL) “does not apply”, because it is natural and fluoridation is suddenly now “not natural”. This is self-serving at best and is a blind hope that promoting the pro viewpoint is somehow just, which is merely promoting a vested interest, in my humble opinion.

    The idea that LD₅₀’s do not apply to ‘water fluoridation’ was disproved in 1994 in Hooper Bay, Alaska where 302 people in the half of the village where an overfeed occurred were sent to the clinic with severe chest pain and acute stomach pain. One victim did not survive a heart attack. In my review of the work it was firmly established that the fluoride blood level in the lethal victim had reached that which precipitates calcium from the blood to block the heart beat (see attached document submitted for publication).  Gessner in his review (“Acute Fluoride Poisoning form a Public Water System”, New England Journal of Medicine, vol. 330, 1994) was unable to decide whether the artificial fluoride killed and poisoned by decreasing blood calcium or rather another mechanism.  Of course everyone desires that such overfeeds will never happen again but sadly this is not the case (www.fluoridealert.org for an accumulating list of overfeeds in the U.S.). If overfeeds did not exist, then we could switch to using MCL’s rather than LD₅₀’s to describe only chronic toxicity. In such an ideal world where no one made dosing errors for this hazardous waste, then I might have agreed, that we then have the luxury to switch to using MCL’s as our concern for only chronic low level toxicity at that point, but I deal with the actual world, not the dream ideal one.

  The notion that artificial fluosilicic acid is injected to treat cavities and thus is “not a drug” has no pharmacological basis. First, please examine for example ‘the Bible of Pharmacology’, Goodman and Gilman’s “Pharmacologic Basis of Therapeutics” which contains a fluoridation section because indeed injecting any artificial material, no matter if found in a natural environment in some waters or not, for the purpose of elevating fluoride levels in human blood to affect any tissue is the definition of a drug. Second, the FDA has never approved of artificial fluoride ingestion and indeed also for the same reasons require warning labels on toothpastes to not swallow, or to use at all in any person under six. Third, FDA spokesmen routinely refer to water fluoridation as an “uncontrolled use of a drug” where dosage cannot be regulated because individuals require vastly different water consumption amounts depending on a plethora of normal physiologic differences and various abnormal health conditions, such as diabetes mellitus where consumption rates are often twice normal (NRC, 2006). Finally, please understand that there is no mechanism by which one can direct swallowed fluoride, that enters the bloodsream, to only attach to teeth rather than to incorporate into systemic tissues. All swallowed fluoride seeks calcium wherever it is enriched because fluoride is a calcium chelator. Calcium is the antidote to fluoride poisoning and minimizes assimilation when fluoride is injected into hard water. Indeed, artifcial fluorides when intentionally ingested are drugs and require listings of exact dosage instructions and known side effects of overconsumption, accidental or otherwise. If natural calicum fluoride had been used to ‘fluoridate’ drug Hooper Bay water supplies, then no one would have been killed or severely poisoned (LD50 = 3,500 ppm for natural calcium fluoride) because calcium fluoride already has its desired ingredient along with it and because only artificial fluorides without calcium are soluble to massive amounts in soft, calcium deficient water. The other well documented case of poisoning intermediate between ‘acute’ and ‘chronic’ are the Pagosa Springs horses raised by out of state ranchers on city fluoridated soft water. the horses were slowly slaughtered over a 9 year period before toxicologists arrived to determine it was the massive fluorosis that killed them. This could not have happened in hard water, or if calcium fluoride were used as a drug instead of fluosilicic acid in the soft water the city has (Krook and Justus, “Horses Poisoned from a Fluoridated Water Supply”, Fluoride, Jan, 2006. The distinction between acute LD50 and chronic MCL is irrelevant since the animals were killed, which do we call it when it happened to require 9 years to achieve but the effecte was terminal? Much more important is the fact that fluoride at 1 ppm in the ocean, with thousands of ppm calcium, is harmless to salmon, that are extremely sensitive and are narcotized in fresh calcium-free water by only 0.3 ppm artificial fluoride.  

  Please consult www.lulu.com for the free pdf download entitled “Toxicity of Water Fluoridated Artificially” for the petition to the FDA to ban this practice for our country. 

  This is only a partial list of problems with the testimony submitted in this Port Angeles, WA fluoridation case. I also have examined the detailed studies of Phyllis Mullenix and found they are exceptional and are unbiased, performed with computer controlled movie cameras that determined animals at blood levels of fluoride comparable to humans in 1 ppm fluoridated cities exhibit alterations in mental behavior with confusion under stress in hundreds of studies that correlate with incorporation of fluoride into the brain medulla oblongata. There is zero doubt that assimilated fluoride crosses the blood brain barrier. The issue is how long can one incorporate it with only minor unrecognized effects (i.e. in extracellular brian components) before eventually exhibiting adverse effects that are demonstrably significant in humans. The numerous foreign journal artricles (about 18 in number) recently translated into English that demonstrate decreased IQ in children raised on only 2-3 ppm water are now available at www.fluoridealert.org.

Sincerely,
Richard Sauerheber, Ph.D. Chemistry

Attachment naturefluoridearticle.doc: “Chemical Analysis of Poisoning from Fluoridated Public Water”—contains data indicating the pH dependence of formation of hydrofluoric acid HF from artificial fluoride and data indicating the activity vs. the concentration of the fluoride ion in water as a function of calcium concentration as well as a detailed chemical analysis of the mechanism by which blood fluoride from an overfeed disaster killed and poisoned in Alaska. This article has thus far received comments by the editors of Nature who felt it of insufficient priority to publish at this time. I plan to shorten the manauscript and submit it to a general toxicology journal.