Dear Editor
I am a Registered dietitian in Guelph, Ontario and I currently work with adults with gastrointestinal diseases and functional disorders. I have recently become interested and concerned with the long-standing practice of water fluoridation. My first reason for concern is the possible risk of chronic fluoride toxicity and its impact on an individual's health. This concern is shared by the US National Research Council, The US Agency for Toxic Substances and Disease Registry and Health Canada.
In the U.S. National Research Council's 2006 publication, Fluoride in Drinking Water A Scientific Review of EPA's Standardsi, it is stated that the major dietary source of fluoride for most people in the United States was identified as "fluoridated municipal (community) drinking water, including water consumed directly, food and beverages prepared at home or in restaurants from municipal drinking water, and commercial beverages and processed foods originating from fluoridated municipalities".
The National Research Council also identified a number of population subgroups "whose water intake is likely to be substantially above the national average for the corresponding sex and age group. These subgroups include people with high activity levels (e.g. athletes, workers with physically demanding duties, military personnel); people living in very hot or dry climates, especially outdoor workers; pregnant or lactating women; and people with health conditions that affect water intake. Such health conditions include diabetes mellitus, especially if untreated or poorly controlled; disorders of water and sodium metabolism, such as diabetes insipidus; renal problems resulting in reduced clearance of fluoride; and short-term conditions requiring rapid rehydration, such as gastrointestinal upsets or food poisoning".
A figure on page 85 of this report clearly indicates that a bottle-fed infant where fluoridated tap water is used to make up formula, will exceed the US EPA's safe reference dose for fluoride (0.05 mg/kg/day).
The US Agency for Toxic Substances and Disease Registry (ATSDR), in their publication Toxicological Profile for Fluorides, Hydrogen Fluoride, and Fluorine"ii state that "human breast milk contains very little fluoride (about 0.01 mg/L) and provides <0.01 mg fluoride/day". An infant exclusively fed formula reconstituted with fluoridated municipal water containing between 0.5 and 0.8 mg/L will be exposed to far greater levels of fluoride. The ATSDR also states that "absorption may be different in neonates because of the immaturity of their gastrointestinal tract and their larger skin surface area in proportion to body weight" and that "infants have an immature blood-brain barrier". In light of these facts it is important to recognize that fluoride is both a known toxin and neurotoxin.
In Health Canada's publication, Guidelines for Canadian Drinking Water Quality: Guideline Technical Document – Fluorideiii, Table B3 shows that babies fed milk-based formula made with fluoridated water will receive a fluoride intake that is significantly higher than the adequate intake (AI) set by the Institute of Medicine (IOM).iv
In the U.S. the American Dental Association and the Centers for Disease Control both advise using unfluoridated water to mix formula if mothers wish to avoid dental fluorosis but not Health Canada.
The second reason for concern is that many communities in Ontario, including Torontov, Ottawavi, Hamiltonvii and Londonviii, use the fluoridation chemical hydrofluorosilicic acid (HFSA) to fluoridate their municipal drinking water.
Hydrofluorosilicic acid is one of many dangerous goods documented in Transport Canada's 2016 Emergency Response Guidebook.ix Hydrofluorosilicic acid (ID No. 1778) is included in their list of substances considered toxic and/or corrosive (non-combustible) and they recommend that First Responders during the initial phase of a hydrofluorosilicic acid incident follow specific guidelines (see guide #154).
This raises several questions :
1) Why is it that Transportation Canada recognizes hydrofluorosilicic acid as a hazardous substance and yet Health Canada does not seem to be concerned with diluting it in municipal drinking water?
2) Why is hydrofluorosilicic acid, permitted to be sold as a fluoridation chemical to many Canadian municipalities to add to municipal drinking water?
3) Since Ontario's Safe Drinking Water Act (2002)x states "dilution is no excuse for adding a contaminant to drinking water" is it legal to add hydrofluorosilicic acid to municipal water?
4) Is this chemical safe for human consumption?
An individual in Edmonton filed a FOIA request asking for Health Canada to provide any toxicological studies on the water fluoridation chemical hydrofluorosilicic acid. The response letter from Health Canada's Access to Information and Privacy Division, file # A-2014-00168/na, dated May 26, 2014 stated the following:
This is in response to your request under the Access to Information Act (the Act) for: Clarified Request Text:
Reports, studies, toxicology and clinical tests relating to hydrofluorosilicic acid in Canadian tap water.
After a thorough search for the requested information, no records were located which respond to your request."
Not testing for toxins does not mean the product is safe. Nor does it excuse officials charged with protecting community health from distributing an unapproved drug that is at risk of being contaminated with toxins as a prophylactic measure through the municipal water supplies.
In 2014, toxicologist, Dr. Phyllis J. Mullenix did test fluoridation products, HFSA and NaF. Her study results showed that although metal content varied with batch, every batch included a surprising amount of aluminum. In addition, all HFSA samples in the study contained arsenic, cadmium, barium and lead were other tramp contaminants.xi
Fluoride, aluminum, cadmium, barium, arsenic and lead are all recognized toxic substances according to the US Agency for Toxic Substances and Disease Registry (ATSDR).
The ATSDR has set minimum risk levels (MRL) for these substances. The following statements are taken from the MRL report:
 Chronic oral exposure of 0.05 mg/kg/day sodium fluoride can cause muscular symptoms.
 Chronic oral exposure of 1.0 mg/kg/day aluminum can cause neurological symptoms.
 Chronic oral exposure of 0.0003 mg/kg/day arsenic can cause dermatological symptoms.
ATSDR has also published toxicological profiles for fluoride, aluminum, arsenic and lead.
Please feel free to contact me regarding any questions or concerns you have regarding the content of this letter. I can be contacted via email at jmarett@rogers.com or by telephone at (519) 836-5484.
Sincerely yours,
Jennifer Marett, R.D.
i http://www.nap.edu/catalog/11571/fluoride-in-drinking-water-a-scientific-review-of-epas-standards
ii http://www.atsdr.cdc.gov/ToxProfiles/tp11.pdf
iii http://hc-sc.gc.ca/ewh-semt/consult/_2009/fluoride-fluorure/b-table-b-tableau-eng.php#tab3
ivhttp://www.ncbi.nlm.nih.gov/books/NBK109832/#ch8.s13
v http://www1.toronto.ca/City%20Of%20Toronto/Toronto%20Water/Files/pdf/D/Drinking%20Water%20Annual%20Report%202015%20FINAL.pdf
vi http://documents.ottawa.ca/sites/documents.ottawa.ca/files/documents/2015Annual_Report-Lemieux_en.pdf
http://documents.ottawa.ca/sites/documents.ottawa.ca/files/documents/2015Annual_Report-Britannia_en.pdf
vii https://d3fpllf1m7bbt3.cloudfront.net/sites/default/files/media/browser/2014-12-01/2015_woodward_annual_moe.pdf
viii http://www.watersupply.london.ca/Annual_Reports/2015/2015_ELGIN_Annual_Report_FINAL.pdf
ix https://www.tc.gc.ca/media/documents/tdg-eng/EnglishERGPDF.pdf
x https://www.ontario.ca/laws/statute/02s32
xi http://www.gloucester-ma.gov/DocumentCenter/View/3044