The US environmental Protection Agency (EPA) has denied an anti-fluoride petition to ban community water fluoridation. The document outlining its reasons for declining the petition is valuable because it considers all the arguments and evidence presented in the petition and comprehensively shows them to be misleading or even false.
This is a humiliating defeat for the petitioners – the US Fluoride Action Network (FAN), Food & Water Watch, Organic Consumers Association, American Academy of Environmental Medicine, International Academy of Oral Medicine and Toxicology and Moms Against Fluoridation. FAN, and in particular Michael Connett, had put a lot of work into their petition. The petition is a 76-page document, heavily referenced and, importantly, presenting all the best arguments that FAN could find. FAN did not keep any of their powder dry.
FAN propaganda video promoting their petition to the EPA to stop community water fluoridation
Of course, FAN and their associated international groups, Facebook pages and websites heavily promoted this petition. They had high hopes – Paul Connett himself has argued that their evidence would bring about the complete demise of community water fluoridation within a few years. The local Fluoride Free NZ issued a press release with the heading EPA Petition Could Spell End of Fluoridation claiming “FAN’s assessment provides unequivocal proof that current allowable levels of fluoride are not protective for all members of the population from damage to the brain.” Mary Byrne, their spokesperson asserted:
“Fluoridation belongs to a by-gone era and far too much is now known about adverse health effects for any further consideration on fluoridation to be seriously considered.”
Many anti-fluoridation submissions to the Parliament Health Committee considering changes to fluoridation legislation in New Zealand have relied strongly on the FAN petition – presenting it as the best thing since sliced bread.
The EPA did give the petitioners arguments serious consideration – as we should expect from such an authoritative organisation. The petition was not rejected out of hand – the EPA’s 50-page document eexaminesthem in detail.
This is what makes the EPA document so available – it considers all the FAN arguments, the scientific papers presented and the evidence claimed. It shows how many of these papers and claimed evidence are misrepresented by the petitioners. It points to the limitations of the studies FAN relies on. It shows how FAN has not even established a case for reconsideration of recommended safe levels for fluoride and explains that the methodology used by FAN, and the recent publication by FAN staff (Herzy et al., 2016 – see Debunking a “classic” fluoride-IQ paper by leading anti-fluoride propagandists), is not valid.
The documents overall assessment of the petition’s arguments is damning:
“The petition has not set forth a scientifically defensible basis to conclude that any persons have suffered neurotoxic harm as a result of exposure to fluoride in the U.S. through the purposeful addition of fluoridation chemicals to drinking water or otherwise from fluoride exposure in the U.S. Still less has the petition set forth a scientifically defensible basis to estimate an aggregate loss of IQ points in the U.S, attributable to this use of fluoridation chemicals. As noted previously, EPA has determined the petition did not establish that fluoridation chemicals present an unreasonable risk of injury to health or the environment, arising from these chemical substances’ use to fluoridate drinking water “
Some specific rejections
The petition argued about 12 points and the EPA responded to all of them. Here are a few extracts.
The central claim of the anti-fluoride petitioners is that Fluoride is neurotoxic at levels relevant to U.S. population. It cited human studies to support this but the EPA document responded by pointing out “the petition ignores a number of basic data quality issues associated with the human studies it relies upon.”
A central problem is the lack of consideration of other factors possibly involved in influencing IQ – confounders:
“The petition . . . does not properly account for the relatively poor quality of the exposure and effects data in the cited human studies (e.g., it appears to give all studies equivalent weight, regardless of their quality). When an association is suggested between an exposure and a disease outcome, the studies need to be assessed to determine whether the effect is truly because of exposure or if alternate explanations are possible. The way to do that is to adjust for potential confounders, such as diet, behavior, and socioeconomic status, in order to appropriately assess the real relationship between the exposures to a specific substance and health effects. In other words, when these confounding factors are potentially present, but not recognized or controlled for, it is not possible to attribute effects to the contaminant of concern (fluoride) as opposed to other factors or exposures. The evidence presented did not enable EPA to determine whether various confounding factors (e.g., nutritional deficiencies) were indeed placing particular subpopulations at a “heightened risk of fluoride .”
The issue of confounders is central to the petitioners claim that recent epidemiological studies corroborate neurotoxic risk in Western populations. The petition cites two studies from Western populations to attempt to corroborate the assertion that exposure to fluoridated water presents unreasonable risks for neurotoxicity. I have discussed these in previous posts – Peckham et al (2015) which claim to show that hypothyroidism is related to fluoridation and Malin & Till (2015) which demonstrated a relationship of ADHD prevalence to extent of fluoridation.
The EPA response says of the Peckham et al (2015) paper that:
“Adjustment for some confounders was considered, including sex and age, but other potential confounders (such as iodine intake) were not assessed. Fluoride from other sources and other factors associated with hypothyroidism were not assessed in this study.”
Iodine deficiency is a well-known factor in hypothyroidism.
The EPA response was relatively kind in its comment on the Malin & Till study:
“Although it is possible that there may be biological plausibility for the hypothesis that water fluoridation may be associated with ADHD, this single epidemiological study is not sufficient to “corroborate” neurotoxic health effects, as stated in the petition. More study would be needed to develop a body of information adequate.”
I showed in my article ADHD linked to elevation not fluoridation that once factors like elevation, poverty, and house ownership were included there was no statically significant relationship between ADHD prevalence and the extent of fluoridation in Malin & Till’s data. That is a clear example how conclusions based on correlations can be completely wrong when confounders are not properly considered.
The petitioners fell back onto their claim that neurotoxic risks of fluoride are supported by animal and cell studies – a common anti-fluoride tactic. However, the EPA document responded by pointing out that the petitioners had misrepresented such studies. It pointed out that these studies had been recently reviewed by the US National Toxicity Program (NTP) and the petitioner’s misrepresentation of the studies:
“do not change EPA’s agreement with the conclusions of the NTP report that their “[r]esults show low-to-moderate level-of-evidence in developmental and adult exposure studies for a pattern of findings suggestive of an effect on learning and memory.”
The petitioners claim susceptible subpopulations at heightened risk from CWF is a common claim of anti-fluoride propagandists. The EPA found this argument unconvincing:
“The data and information provided in the petition do not support the claims that “nutritional status, age, genetics and disease are known to influence an individual’s susceptibility to chronic fluoride toxicity.”“
The petition argued there were no established benefits of CWF to public health. The EPA responded by outlining some of the evidence for CWF benefiting oral health and responded to the petitioners claims with:
EPA does not believe that the petition has presented a well-founded basis to doubt the health benefits of fluoridating drinking water.
Despite not showing that community water fluoridation is linked to IQ losses the petitioners asked that because fluoridation covers a large population any harm would affect a large number of people so drinkign water fluoridation should be stopped on those grounds alone. Incidentally, Hirzy et al (2016) promised a future paper where they estimate economic losses to the USA because of fluoridation. I guess they will just ignore the Swedish work that actually shows drinking water fluoride levels are positively related to increased income and chances of employment (see Large Swedish study finds no effect of fluoride on IQ).
The EPA response to this argument:
As noted previously, EPA has determined the petition did not establish that fluoridation chemicals present an unreasonable risk of injury to health or the environment, arising from these chemical substances’ use to fluoridate drinking water. The fact that a purported risk relates to a large population is not a basis to relax otherwise applicable scientific standards in evaluating the evidence of that purported risk.
I like that bit about “relaxing scientific standards.” Doesn’t it just describe the whole approach of the anti-fluoride propagandists to the science?
According to the rejection letter the Petitioners, the Fluoride Action Network and their ideological mates can appeal the declining of their petition:
“by commencing a civil action in a U.S. district court to compel initiation of the requested rulemaking proceeding within 60 days of the date of this denial letter.”
The letter was dated February 17 – so they have until mid-April to get this underway. Michael Connett – who did the heavy lifting in the preparation of this 76-page petition – is an attorney so may be more capable with such legal action than he appears to be with the scientific arguments.
At the moment the anti-fluoride groups, including those in New Zealand, are silent. It’s as if they did not receive their rejection letter almost 10 days ago. Perhaps they are busy debating their possibilities – and the public stance on this rejection they will eventually have to take.