Dear brothers and sisters in Christ and fellow members in ASA
For about eight years I have been watching an issue unfold. Sometimes my
observation was very close up, and for a short time at the begining I was
actually involved. Shortly after we started this, we found that recent
scientific inquiry had produced results that started to question one of the
premises of a long-standing policy. The issue now has come to a head.
Fortunately I have recently started a different position so I can do this
without any conflict of interest.
I am asking for the help of any who have the time and interest to utilize
their scientific training. The training does not need to be "subject matter
expert". If however you have any toxicology or biomedical expertise, you
might have some specific insight. The policy application issue is a local
one at this point, but will have wide ranging effect whichever way it is
resolved.
As a first step I am asking you to request a copy of the "Draft
Environmental Assessment for Fluoridation of the Fort Detrick Drinking Water
System" from chuck.dasey@det.amedd.army.mil or by writing to:
Headquarters
US Army MRMC
Attn: MRMC-PA (Charles Dasey)
504 Scott Street
Fort Detrick, MD 21702-5012
Last Thursday they announced the mandatory 30-day comment period. Please
request an extension of the comment period when you ask for a copy. I have
already asked for an extension, and if enough folks ask for an extension
they might grant it. In the past, draft assessments were placed on the web
for comments. This time it was not. You can make your own conclusions.
Even if you think you will not have time for anything else, please take this
first step.
If you have attended under graduate school after 1962 and took any course in
public health, "water treatment engineering" (which I took), etc., you were
probably taught that "fluoride in drinking water is good and is a good
public health policy." It probably became part of our world outlook. If
you had an especially good instructor, he may have explained that ingested
fluoride causes dental fluorousis. At higher levels this is very bad, but
dental fluorousis also "hardens" teeth and makes them more impervious to
decay. So the optimum dosage of fluoride would provide enough of the
benefits of "harder" teeth with hardly any of the bad effects of dental
flourousis. The value that was selected to be "optimum", turned out to be
near 1 milligram per liter. (Remember I was an engineering student). (Also
note that if you went to University in virtually any country other than US
or Canada, in all likelihood you would have been told this: in fact you may
have been told the opposite, but that's a different story). There was also
the assumption, but never stated, that there were no other adverse effects
at this low level. Research especially in the past 12 years or so has
started to produce results that question this assumption.
If you review this document, please be aware that it has been written to
support the current policy. As such it may minimize the importance of these
recent studies. It may, in fact, dismiss them. As I mentioned, this has
been going on for 8 years. During that time some of those who were ordered
to get this done, have come and gone. One took the position for a while
that unless a study was published in a peer reviewed journal which met some
ill defined "standard", and had been validated by subsequent research, he
would not consider it valid and would ignore it, i.e. exclude it from the
assessment. Another seemed to claim for all practical purposes, that any
study that indicated any problems with the practice of fluoridation was
"junk science" and he didn't have to read it to know that. I have not
received the current draft, but some of the previous ones simply left out
important studies. There were some who tried to ensure an honest evaluation,
but before long we were left out of the loop. The current "responsible
persons" have basically inherited the situation and the current draft, and
may not fully understand what has gone on in the past. Nevertheless they are
under orders to get this "done".
While this document includes a major scientific component and also a
component of the policy and it's implementation, there is also a legal
component. This document is being prepared to meet the requirements of the
National Environmental Policy Act. The intent is to support someone
determining that a Finding of No Significant Impact is appropriate. There
are two points which you should know about this term. No means no. Not
"hardly any", not "on balance", not "no net", not "no in light of the
benefits". For example, in a different situation, if 1 acre of habitat for
an threatened species would be lost, even though 100 acres of habitat for 10
endangered species would be preserved, expanded and enhanced, the 1 lost
acre, would preclude the use of the word "no". (In this case the action
could still be done, but the full "cost" would have to be fully understood
and documented in a Environmental Impact Statement and not hidden by the
term No Significant Impact). The second is that the term "significant" is
somewhat in the eye of the beholder, specifically the person who is
designated as the one who makes this decision. This cannot be done
arbitrarily however, and has been the cause of a number of lawsuits. In the
case above, if the lost acreage were 10 acres and could no longer be used as
dairy pasture or even 100 acres were lost to that function, that would
probably not be considered "significant" in itself, regardless of the use of
the future land. In your review, your understanding of "significant" and
the term "no" may be important.
Because of the legal component, your evaluation as a concerned public
citizen, one who has scientific expertise, becomes important in this
process.
Please pay attention to the fact that in virtually every lab study, Sodium
Fluoride (generally research grade) was used as the source of fluoride.
Fort Detrick had at one time fluoridated the water using Hydrofluosilic acid
(also known as -fluosilicic acid), and I believe thatproposal is to use that
chemical again. Approximately 90% of all systems that fluoridate their
drinking water use Hydrofluosilic acid for the source of fluoride. It is
not even technical grade. At one time it was believed that it fully
dissociated to produce fluoride ions. Some early research over 20 years ago
(and which was overlooked for most of that time), shows that in fact only
about 90 to 94% of it dissociates to fluoride ion. EPA has admitted it has
not done any toxicological studies on this compound and knows of none. The
letters are posted at http://www.dartmouth.edu/~rmasters/AHABS/thurnau.htm.
Also note the English forward to the Westendorf Thesis at
http://www.dartmouth.edu/~rmasters/AHABS/. Then note the treatment of the
Masters and Copland epidemiologic studies in the Environmental Assessment
(if they are even mentioned).
As I have not seen the current draft yet, I do not know what has been
included or excluded. If any of you wish to contact me after you have
reviewed the document, for information on excluded work, etc. please contact
me at here or at fam.erbes@erols.com. At least one study that the original
support contractor on this work completed has been excluded. The contractor
had worked on this issue , for close to 7 years, in spurts, depending on
funding and "direction" of the army. It was finally agreed that he would
look into a particular question. Based on existing data from a number of
sources and consolidating it, and analyzing it, he came up with a result
that was not at all what the army wanted to know. He was fired and the
document, such as it is, was completed by "others", who seemed to have
become anonymous. I have the essence of this excluded work.
Thank you for your time, even if all the time you have available consists of
requesting a copy of the draft.
Henry Erbes, Ph.D., P.E.
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