24th January, 2003

Mrs Margot Wallstrom,

Director-General Environment, European Commission, Rue de la Loi 200, B-1049 Bruxelles. Belgium

Re : WA E 2782/02EN of 28th Nov 2002

Forced Medication of EU citizens with unproven and unlicensed substances in drinking water.

Dear Mrs Wallstrom,

We refer to your Written Answer to the question from MEP Avril Doyle, which was fowarded for our information, which asks whether "it is permissible for a health minister in any EU Member state to forcibly medicate any part of a population with random doses of a medicinally unproven and unlicensed substance, fluorosilic acid".. We refer also to the supplementary question as to whether the Commission can name a single study demonstrating any beneficial effect of fluorosilic acid in drinking water on human health.

Considering that information directly relevant to both questions was contained in our letter to you of 29th July 2002, along with other background material, your Written Answer is extremely disappointing. Not only are neither of the above questions addressed directly, but the Written Answer is factually incorrect in several respects. In addition some key assertions are unsupported by scientific or other evidence.

As an example of the poor scientific basis for this mass medication please find enclosed A Scientific Critique of the Fluoridation Forum Report 2002 [1]. The Critique provides scientific evidence for a range of adverse health effects from fluoridation and demonstrates that the Fluoridation Forum’s investigation is deeply flawed since, far from addressing the many health questions as the Irish Health Minister asserted when setting it up, the Forum simply avoided them.

It contained numerous absurdities including a ridiculous Tolerable Daily Intake of fluoride for over 8 yr olds of 10 Mg while the rest of European medical and nutritional practice seeks to minimize fluoride intake as much as possible.

1. The Drinking Water Directives.

It is utterly misleading to assert that fluoridation --- the deliberate addition of a toxic substance to public drinking water to treat humans – is addressed under EU directives 80/778/EEC of 15th July 1980 or Council Directive 98/83/EC of 3 November 1998. Firstly, nothing in either directive could be construed as inferring that drinking water should be used to medicate any part of the EU population. Secondly, the directives refer simplistically to F i.e., the fluoride ion, when the directives should be referring to fluoride compounds, either sodium fluoride or silicofluorides, which are the forms most widely added to drinking water in Ireland. Flouride is not added as an ion, it is added as a compound. These forms of fluoride compounds are registered in the UK Poisons Act 1972 as Part II Poisons and as such may are available only in ‘POISON’ labelled bottles from licensed pharmacists.

In addition, scientific research as well as basic medical science indicates that toxic volatile substances such as fluosilic acid have interactive effects with other minerals or substances which may also be present in water. For example, with lead and or with aluminium which is widely used as a flocculating agent in water systems throughout Ireland.

The latest EPA report The Quality of Drinking Water in Ireland 2001 underlines the seriousness of the aluminium problem since gross exceedances were noted in Counties Cavan, Donegal, Kerry, Leitrim and South Tipperary ; gross exceedances are defined as >1.0 mg/l or five times the MAC of 0.2mg/l which is itself a compromise based on aesthetic and practical considerations. In addition, as in 8 counties 20% of samples are above the MAC, and in another 7 over 10% exceed the legal limit, the problem is clearly widespread in Ireland.

Even the US EPA, a long-time proponent of flouridation, has now acknowledged that fluoroaluminium complexes and speciation of fluorosilic acid in raw water is not fully understood [2. EPA Letter March 15th 2002]. This confirms scientific evidence already recognized within Europe for almost 30 years which flagged the serious health implications of what is only partial dissociation of silicofluorides in drinking water (http://www.fluoridealert.org/westendorf.html) the Fluoridation Forum report still denies this fundamental scientific assumption.

It is particularly disappointing that this scientific evidence which was brought to your attention in our letter of 29th July 2002 has not been taken into account in the Written Answer.

2.Water ‘Treatment’. Fluoridation is not a ‘water treatment process’. A ‘water treatment process’ treats water. Fluoride is not added to water to enhance its quality, or ameloriate some defect. Rather, the purpose of fluoridation is to deliver a medicine or treatment to a whole population, the water is simply used as a vehicle to deliver the treatment. The original question from MEP Avril Doyle was with respect to this practice of forcibly treating a population.

This is a crucially important and fundamentally unethical aspect of fluoridation: fluoridation is not ‘water treatment’, it is ‘people treatment’ via their drinking water. We would respectfully request that you cease misleading public representatives and MEPs in any future statements on fluoridation.

As for the suggestion that all member states have endorsed this approach, if this were the case, the majority of EU states would be fluoridating their water. They are not. And what do the ten new applicant states about to become members of the post-Nice Treaty EU think of this policy? Not much, since water fluoridation is rejected by every single one of them.

3.WHO ‘guidelines’. We are concerned that the Commission continues to rely on the WHO ‘guidelines on fluoride’ as we have already drawn attention to the many internal contradictions and inconsistencies of these guidelines.

Even the Irish government, isolated in Europe for its compulsory fluoride medication, has now decided to reject the WHO guidelines also. Fluoride poisoning in Ireland has become so serious that the Irish Health Minister has proposed a 30% reduction in the concentration of fluosilic acid to be added to water. The new target concentration is 0.7Mg/L with a range of 0.6 to 0.8Mg/L (www.fluoridationforum.ie Page 15, Recommendation 1 of Report).

Looking outside the EU, we would also like to point out that the recently re-drafted WHO Fluoride Monograph has been subjected to serious international criticism as being unscientific; indeed the whole rationale of the WHO approach to fluoride has been seriously questioned by 13 nations mostly from Asia and Africa [3].

Take for example the WHO guideline value of fluoride of 1.5Mg/L. Far from being the level of balance between positive and negative effects, the value should, according to these nations, be reduced down to 0.5 Mg/L. This, and not the widely ignored 1.5Mg/L, is the maximum tolerable range according to a one of the world’s leading fluorosis experts, Dr A.K.Susheela of the Indian Fluorosis Research & Development Foundation in Delhi, and a leading member of this international group of 13 countries.

Representative of this group would be Senegal which replaced the WHO guidelines in the early 1990’s with its own maximum fluoride level in water of 0.5 mg/L in order to protect the health of its citizens. 4.Manufacturing Quality and Purity Standards for fluosilicic acid.

The statement that fluosilic acid is manufactured to exacting quality standards and must meet strict purity standards is downright false because it completely conceals the true nature of what is in reality an industrial waste chemical . For notwithstanding countless enquiries by campaign groups and individual citizens both in the EU and elsewhere, no evidence has been offered that fluosilic acid as used is, or ever has been, subject to any quality standards. Indeed the high level of its contaminants from arsenic, chromium, lead, mercury and uranium 238, suggests the very reverse of a product made to a quality standard.

Once again, the other uses to which the fluosilic acid of the type that is added to Irish waters is put, such as etching of glass or treatment of metal surfaces, indicates an industrial product and not one suitable for human or animal ingestion.

Even its Irish importer does not provide any warranty as to quality or indeed fitness for purpose and specifically warns that it is not bio-degradable, damages teeth and bones, and is harmful to aquatic organisms (4. Health & Safety Data Sheet Attached).

If any EU citizens still had any doubts about the real reasons behind using an industrial chemical in drinking water, they need only refer to the statement by US EPA Deputy Administrator Hanmer who officially nominated drinking water ‘treatment plants’ as the ideal solution for solving the long-standing environmental problem of how to dispose silicofluorides, the pollution waste from aluminium and phosphate production. [5.http://www.fluoridealert.org/ Attached] Your letter asserts that fluorosilic acid is always added at rigorous and controlled doses in drinking water. However, this is incorrect on two counts. Firstly the concentration is not properly controlled in Ireland. We have already provided you with the EPA documented evidence of routine exceedances of the target concentration of both fluoride and aluminium throughout Ireland.

Secondly, even if the amount added to water was uniform, the actual dose received cannot be controlled as it is impossible to ascertain the amount of water any individual citizen will consume from day to day, and therefore impossible to ascertain the dose an individual citizen receives. Once public water is fluoridated it is virtually impossible to avoid the ingestion of fluorides since almost every Irish-produced food and drink utilises tap water or is processed with it. This largely explains why, in the only published evidence of fluoride intake in this EU member state, six out of eight councillors in County Kildare exhibited over 3-4 milligrams of fluoride intake per day, well above the level of medical concern.

The Commission’s claim to be very conscious of the health risks associated with the excessive ingestion of fluorinated compounds would carry some weight if more proactive role were taken to protect those EU citizens in Ireland and other member states, who are unavoidably exposed to untested and unlicensed forms of fluoride in water. For instance the Commission could intervene on behalf of EU citizens by demanding that the Irish government respect the warning of systemic poisoning from fluoridation contained in the UK parliamentary Written Answer of April 1999, which defined dental fluorosis as a sign of "systemic toxicity".

As dental fluorosis is widely acknowledged to affect almost half of people in fluoridated communities, we would respectfully suggest that the Commission request the Irish government to heed the warning by immediately assessing fluoride exposure and total daily fluoride intake. Such an intervention would also be consistent with the Commissioner’s statement to Irish delegates in Dublin in January 2002, linking personal health directly to water quality.

In Conclusion In conclusion, as regards the Irish Government’s continuing support of fluoridation, its internal investigation into it has been thoroughly discredited both in Ireland and internationally. The enclosed international Scientific Critique describes as ‘blatantly false’ the Irish Government’s claim that there are no adverse health effects from water fluoridation, indeed the government-acknowledged increase in dental fluorosis is itself prima facie evidence of adverse health effect. It has also been suggested that this government report --withheld for almost a year-- was released on September 10th 2002 in order to minimize its public and media impact, in other words to impede full and open debate of these troubling issues.

The Irish Health Department has now proposed reducing the concentration of fluosilic acid in water to below the level at which, by its own admission, "there are any significant beneficial effects" in preventing tooth decay! [http://www.fluoridationforum.ie/practical_questions.htm] It has of course been driven to this absurdity by the need to be seen to be doing something (no matter how unscientific) to reduce the systemic poisoning of its people by fluoride, in particular by silicofluorides in their drinking water.

Yours sincerely,

Robert Pocock VOICE of Irish Concern for the Environment

Cc EU Commission --Mr Bernhard Merkel DG Sanco, Health Ministry Policy Analysis & Development Programme for Community Action in Public Health, 2001-2006 --Mr A.S.Tienza, Health & Consumer Protection DG, Directorate C. EU Parliament --Pat Cox, President European Parliament --Avril Doyle MEP,Leinster --Patricia McKenna MEP, Leinster --Nick Clegg MEP E.Midlands UK --Liz Lynne MEP UK Ireland --Minister Martin Cullen, Department of the Environment --Minister Michael Ahern, Department of Enterprise, Trade & Employment --Minister Micheal Martin, Department of Health & Children --John Gormley TD, Rapporteur Oireachtas All-Party Committee on Water Fluoridation --Mary Harney TD, Progressive Democrats --Liz McManus TD, Labour Party (Health) --Olivia Mitchell TD, Fine Gael ( Health) --Arthur Morgan TD, Sinn Fein (Health)

References

A Scientific Critique of the Fluoridation Forum Report, Sept 10th 2002.

US EPA Letter of March 15th 2001 (Appendix 7 of above Scientific Critique)

‘Fluorosis in Developing Countries: Remedial Measures & Approaches by AK Susheela, in Proc. Indian natn.Sci Acad.(PINSA) B68 No.5 pp389-400 (2002)

Health & Safety Data Sheet Albatros Chemicals page5 .June 6th 1996 Rev. No 0.

US EPA Agency Letter March 1983, Deputy Administrator Rebecca Hanmer

7 Upper Camden Street, Dublin 2. Phone: 01 475 0467 Fax: 01 476 2042 E-mail: avoice@iol.ie 24th January, 2003

Mrs Margot Wallstrom, Director-General Environment, European Commission, Rue de la Loi 200, B-1049 Bruxelles. Belgium

Re : WA E 2782/02EN of 28th Nov 2002

Forced Medication of EU citizens with unproven and unlicensed substances in drinking water.

Dear Mrs Wallstrom,

We refer to your Written Answer to the question from MEP Avril Doyle, which was fowarded for our information, which asks whether "it is permissible for a health minister in any EU Member state to forcibly medicate any part of a population with random doses of a medicinally unproven and unlicensed substance, fluorosilic acid".. We refer also to the supplementary question as to whether the Commission can name a single study demonstrating any beneficial effect of fluorosilic acid in drinking water on human health.

Considering that information directly relevant to both questions was contained in our letter to you of 29th July 2002, along with other background material, your Written Answer is extremely disappointing. Not only are neither of the above questions addressed directly, but the Written Answer is factually incorrect in several respects. In addition some key assertions are unsupported by scientific or other evidence.

As an example of the poor scientific basis for this mass medication please find enclosed A Scientific Critique of the Fluoridation Forum Report 2002 [1]. The Critique provides scientific evidence for a range of adverse health effects from fluoridation and demonstrates that the Fluoridation Forum’s investigation is deeply flawed since, far from addressing the many health questions as the Irish Health Minister asserted when setting it up, the Forum simply avoided them.

It contained numerous absurdities including a ridiculous Tolerable Daily Intake of fluoride for over 8 yr olds of 10 Mg while the rest of European medical and nutritional practice seeks to minimize fluoride intake as much as possible.

1. The Drinking Water Directives.

It is utterly misleading to assert that fluoridation --- the deliberate addition of a toxic substance to public drinking water to treat humans – is addressed under EU directives 80/778/EEC of 15th July 1980 or Council Directive 98/83/EC of 3 November 1998. Firstly, nothing in either directive could be construed as inferring that drinking water should be used to medicate any part of the EU population. Secondly, the directives refer simplistically to F i.e., the fluoride ion, when the directives should be referring to fluoride compounds, either sodium fluoride or silicofluorides, which are the forms most widely added to drinking water in Ireland. Flouride is not added as an ion, it is added as a compound. These forms of fluoride compounds are registered in the UK Poisons Act 1972 as Part II Poisons and as such may are available only in ‘POISON’ labelled bottles from licensed pharmacists.

In addition, scientific research as well as basic medical science indicates that toxic volatile substances such as fluosilic acid have interactive effects with other minerals or substances which may also be present in water. For example, with lead and or with aluminium which is widely used as a flocculating agent in water systems throughout Ireland.

The latest EPA report The Quality of Drinking Water in Ireland 2001 underlines the seriousness of the aluminium problem since gross exceedances were noted in Counties Cavan, Donegal, Kerry, Leitrim and South Tipperary ; gross exceedances are defined as >1.0 mg/l or five times the MAC of 0.2mg/l which is itself a compromise based on aesthetic and practical considerations. In addition, as in 8 counties 20% of samples are above the MAC, and in another 7 over 10% exceed the legal limit, the problem is clearly widespread in Ireland.

Even the US EPA, a long-time proponent of flouridation, has now acknowledged that fluoroaluminium complexes and speciation of fluorosilic acid in raw water is not fully understood [2. EPA Letter March 15th 2002]. This confirms scientific evidence already recognized within Europe for almost 30 years which flagged the serious health implications of what is only partial dissociation of silicofluorides in drinking water (http://www.fluoridealert.org/westendorf.html) the Fluoridation Forum report still denies this fundamental scientific assumption.

It is particularly disappointing that this scientific evidence which was brought to your attention in our letter of 29th July 2002 has not been taken into account in the Written Answer.

2.Water ‘Treatment’. Fluoridation is not a ‘water treatment process’. A ‘water treatment process’ treats water. Fluoride is not added to water to enhance its quality, or ameloriate some defect. Rather, the purpose of fluoridation is to deliver a medicine or treatment to a whole population, the water is simply used as a vehicle to deliver the treatment. The original question from MEP Avril Doyle was with respect to this practice of forcibly treating a population.

This is a crucially important and fundamentally unethical aspect of fluoridation: fluoridation is not ‘water treatment’, it is ‘people treatment’ via their drinking water. We would respectfully request that you cease misleading public representatives and MEPs in any future statements on fluoridation.

As for the suggestion that all member states have endorsed this approach, if this were the case, the majority of EU states would be fluoridating their water. They are not. And what do the ten new applicant states about to become members of the post-Nice Treaty EU think of this policy? Not much, since water fluoridation is rejected by every single one of them.

3.WHO ‘guidelines’. We are concerned that the Commission continues to rely on the WHO ‘guidelines on fluoride’ as we have already drawn attention to the many internal contradictions and inconsistencies of these guidelines.

Even the Irish government, isolated in Europe for its compulsory fluoride medication, has now decided to reject the WHO guidelines also. Fluoride poisoning in Ireland has become so serious that the Irish Health Minister has proposed a 30% reduction in the concentration of fluosilic acid to be added to water. The new target concentration is 0.7Mg/L with a range of 0.6 to 0.8Mg/L (www.fluoridationforum.ie Page 15, Recommendation 1 of Report).

Looking outside the EU, we would also like to point out that the recently re-drafted WHO Fluoride Monograph has been subjected to serious international criticism as being unscientific; indeed the whole rationale of the WHO approach to fluoride has been seriously questioned by 13 nations mostly from Asia and Africa [3].

Take for example the WHO guideline value of fluoride of 1.5Mg/L. Far from being the level of balance between positive and negative effects, the value should, according to these nations, be reduced down to 0.5 Mg/L. This, and not the widely ignored 1.5Mg/L, is the maximum tolerable range according to a one of the world’s leading fluorosis experts, Dr A.K.Susheela of the Indian Fluorosis Research & Development Foundation in Delhi, and a leading member of this international group of 13 countries.

Representative of this group would be Senegal which replaced the WHO guidelines in the early 1990’s with its own maximum fluoride level in water of 0.5 mg/L in order to protect the health of its citizens. 4.Manufacturing Quality and Purity Standards for fluosilicic acid.

The statement that fluosilic acid is manufactured to exacting quality standards and must meet strict purity standards is downright false because it completely conceals the true nature of what is in reality an industrial waste chemical . For notwithstanding countless enquiries by campaign groups and individual citizens both in the EU and elsewhere, no evidence has been offered that fluosilic acid as used is, or ever has been, subject to any quality standards. Indeed the high level of its contaminants from arsenic, chromium, lead, mercury and uranium 238, suggests the very reverse of a product made to a quality standard.

Once again, the other uses to which the fluosilic acid of the type that is added to Irish waters is put, such as etching of glass or treatment of metal surfaces, indicates an industrial product and not one suitable for human or animal ingestion.

Even its Irish importer does not provide any warranty as to quality or indeed fitness for purpose and specifically warns that it is not bio-degradable, damages teeth and bones, and is harmful to aquatic organisms (4. Health & Safety Data Sheet Attached).

If any EU citizens still had any doubts about the real reasons behind using an industrial chemical in drinking water, they need only refer to the statement by US EPA Deputy Administrator Hanmer who officially nominated drinking water ‘treatment plants’ as the ideal solution for solving the long-standing environmental problem of how to dispose silicofluorides, the pollution waste from aluminium and phosphate production. [5.http://www.fluoridealert.org/ Attached] Your letter asserts that fluorosilic acid is always added at rigorous and controlled doses in drinking water. However, this is incorrect on two counts. Firstly the concentration is not properly controlled in Ireland. We have already provided you with the EPA documented evidence of routine exceedances of the target concentration of both fluoride and aluminium throughout Ireland.

Secondly, even if the amount added to water was uniform, the actual dose received cannot be controlled as it is impossible to ascertain the amount of water any individual citizen will consume from day to day, and therefore impossible to ascertain the dose an individual citizen receives. Once public water is fluoridated it is virtually impossible to avoid the ingestion of fluorides since almost every Irish-produced food and drink utilises tap water or is processed with it. This largely explains why, in the only published evidence of fluoride intake in this EU member state, six out of eight councillors in County Kildare exhibited over 3-4 milligrams of fluoride intake per day, well above the level of medical concern.

The Commission’s claim to be very conscious of the health risks associated with the excessive ingestion of fluorinated compounds would carry some weight if more proactive role were taken to protect those EU citizens in Ireland and other member states, who are unavoidably exposed to untested and unlicensed forms of fluoride in water. For instance the Commission could intervene on behalf of EU citizens by demanding that the Irish government respect the warning of systemic poisoning from fluoridation contained in the UK parliamentary Written Answer of April 1999, which defined dental fluorosis as a sign of "systemic toxicity".

As dental fluorosis is widely acknowledged to affect almost half of people in fluoridated communities, we would respectfully suggest that the Commission request the Irish government to heed the warning by immediately assessing fluoride exposure and total daily fluoride intake. Such an intervention would also be consistent with the Commissioner’s statement to Irish delegates in Dublin in January 2002, linking personal health directly to water quality.

In Conclusion In conclusion, as regards the Irish Government’s continuing support of fluoridation, its internal investigation into it has been thoroughly discredited both in Ireland and internationally. The enclosed international Scientific Critique describes as ‘blatantly false’ the Irish Government’s claim that there are no adverse health effects from water fluoridation, indeed the government-acknowledged increase in dental fluorosis is itself prima facie evidence of adverse health effect. It has also been suggested that this government report --withheld for almost a year-- was released on September 10th 2002 in order to minimize its public and media impact, in other words to impede full and open debate of these troubling issues.

The Irish Health Department has now proposed reducing the concentration of fluosilic acid in water to below the level at which, by its own admission, "there are any significant beneficial effects" in preventing tooth decay! [http://www.fluoridationforum.ie/practical_questions.htm] It has of course been driven to this absurdity by the need to be seen to be doing something (no matter how unscientific) to reduce the systemic poisoning of its people by fluoride, in particular by silicofluorides in their drinking water.

Yours sincerely,

Robert Pocock VOICE of Irish Concern for the Environment

7 Upper Camden Street, Dublin 2. Phone: 01 475 0467 Fax: 01 476 2042 E-mail: avoice@iol.ie

Cc EU Commission --Mr Bernhard Merkel DG Sanco, Health Ministry Policy Analysis & Development Programme for Community Action in Public Health, 2001-2006 --Mr A.S.Tienza, Health & Consumer Protection DG, Directorate C. EU Parliament --Pat Cox, President European Parliament --Avril Doyle MEP,Leinster --Patricia McKenna MEP, Leinster --Nick Clegg MEP E.Midlands UK --Liz Lynne MEP UK Ireland --Minister Martin Cullen, Department of the Environment --Minister Michael Ahern, Department of Enterprise, Trade & Employment --Minister Micheal Martin, Department of Health & Children --John Gormley TD, Rapporteur Oireachtas All-Party Committee on Water Fluoridation --Mary Harney TD, Progressive Democrats --Liz McManus TD, Labour Party (Health) --Olivia Mitchell TD, Fine Gael ( Health) --Arthur Morgan TD, Sinn Fein (Health)

References

A Scientific Critique of the Fluoridation Forum Report, Sept 10th 2002.

US EPA Letter of March 15th 2001 (Appendix 7 of above Scientific Critique)

‘Fluorosis in Developing Countries: Remedial Measures & Approaches by AK Susheela, in Proc. Indian natn.Sci Acad.(PINSA) B68 No.5 pp389-400 (2002)

Health & Safety Data Sheet Albatros Chemicals page5 .June 6th 1996 Rev. No 0.

US EPA Agency Letter March 1983, Deputy Administrator Rebecca Hanmer