NAS Report: Comment 1 - Figures

Comments on the 2006 NAS/NRC report
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NAS Report: Comment 1 - Figures

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Posted: 29 Mar 2006 06:10 am
Post subject: NAS Report: Comment 1 - Figures

On Wednesday, March 22, 2006 the NAS/NRC released its long-awaited report "Fluoride in Drinking Water: A Scientific Review of EPA's Standards".

While it is being heralded by anti-fluoridationists and winning accolades from groups such as the EWG, numerous members from our group have already emailed our office, having found quite a few severe shortcomings of the report.

Over the next few weeks and months we will have a close look at the NAS report and these shortcomings - of which they are quite a few.

Today we start with the following letter, addressing just a few of the erroneous statements and figures found in the NAS report, sent today by Darlene Sherrell to Susan Martel at the NAS.

Date: Mon, 27 Mar 2006 05:18:39 -0800 (PST)
From: Darlene Sherrell <island_gram2003@...>
Subject: Subject: Fluoride in Drinking Water: A Scientific Review of EPA's ...
To: Susan Martel <smartel@.....>

Susan Martel,

On page 139 of "Fluoride in Drinking Water: A Scientific Review of
EPA's Standards (2006)" you will find the following erroneous
"In clinical stage II, symptoms characterized by sporadic pain,
stiffness of joints, and osteosclerosis of the pelvis and spine are
observed. Clinical stage III is associated with chronic joint pain,
arthritic symptoms, calcification of ligaments, and osteosclerosis of
cancellous bones."
According to the 1991 U.S. Public Health Service "Review of Fluoride
Benefits and Risks," page 46, the symptoms above are associated with
"Clinical Phase I" and "Clinical Phase II" - not II and III.
Table 23 Preclinical and clinical stages of human skeletal fluorosis
and correlation of bone ash fluoride concentration
"Normal Bone ... 500 - 1,000 (mg F/kg)"
"Preclinical Phase ... 3,500 - 5,500 (mg F/kg)
asymptomatic; slight radiographically-detectable increases in bone
"Clinical Phase I ... 6,000 - 7,000 (mg F/kg)
sporadic pain; stiffness of joints; osteosclerosis of pelvis &
vertebral column"
"Clinical Phase II ... 7,500 - 9,000 (mg F/kg)
chronic joint pain; arthritic symptoms; slight calcification of
ligaments; increased osteosclerosis/cancellous bones; with/without
osteoporosis of long bones"
"Clinical Phase III
Crippling Fluorosis ... >8,400 (mg F/kg)
limitation of joint movement; calcification of ligaments/neck, vert.
column; crippling deformities/spine & major joints; muscle wasting;
neurological defects/compression of spinal cord"
"(Adapted from: Smith and Hodge, 1979; Franke et al. 1975; Schlegal,
According to "FLUORIDES - Biological Effects of Atmospheric Pollutants"
p. 211 (NAS 1971), Table 9-18 "Radiographic Findings in Cryolite
Workers" the 1st phase appeared after 2.5 years of emplyoment, the 2nd
phase appeared after 4.5 years, and the 3rd phase appeared after 11
years. The reference cited is Roholm (1937), who stated "In man the
disease is probably caused by 0.20-0.35 mg. fluorine daily per kg. body
If we use a wide range in body weight (100 to 229 pounds), the
following would represent Roholm's data:
0.20 mg/kg X 45.36 kg X 4018.0 days (11 yr) = 36,451 mg
0.35 mg/kg X 103.87 kg X 4018.0 days (11 yr) = 146,072 mg
............ 10 mg/day X 3652.5 days (10 yr) = 36,525 mg
............ 20 mg/day X 7305.0 days (20 yr) = 146,100 mg
Note that at 5 to 10 mg/day the time frame would be 20 to 40 years, and
at 2.5 to 5 mg/day, the time frame would be 40 to 80 years.
This is consistent with NRC 1977, NRC 1993, and Hodge 1979.
According to Hodge, "Crippling fluorosis as an occupational disease
follows exposures estimated at 10 to over 25 mg of fluoride daily
during periods of 10-20 years." -Hodge, HC. The Safety of Fluoride
Tablets or Drops, in Continuing Evaluation of the Uses of Fluoride,
Westview Press (1979).
In addition, with regard to the reference on page 139 to defluoridation
in Bartlett, Texas:
An internal report by the Division of Dental Public Health of the
Public Health Service, written in 1950, gives the following details
about the defluoridation project in Bartlett, Texas:
"Complementary projects are in operation at Britton, South Dakota, and
Bartlett, Texas. The Britton project began operation in December 1948.
Bartlett has been active since December 1949 and is designed to provide
data for comparison with that being obtained at Britton.

"The objective of these studies is to develop and demonstrate
practical, efficient, and economical methods of preventing endemic
fluorosis in affected areas by reducing the fluoride content of
drinking water supplies to 1.5 : 1,000,000.

"A contact filter method using activated alumina is employed at
Bartlett, Texas.

"Personnel requirements, 1.3 man years. Funds available for fiscal year
1950, $13,470."
Source: The Division of Dental Public Health, its authorization,
functions, objectives, organization, resources, projects, prepared by
the Division of Dental Public Health, Federal Security Agency, Public
Health Service, 1950; in the Ruth Roy Harris papers, National Library
of Medicine
Furthermore, Table 2-13 "Contributions to Total Fluoride Chronic
Exposure at 1 mg/L in Drinking Water" (page 53) contains the following
4.0% from pesticides and air .. 2.17 x 0.040 = 0.0868
36.3% from food ............... 2.17 x 0.363 = 0.78771
4.6% from toothpaste .......... 2.17 x 0.046 = 0.09982
55.1% from drinking water ..... 2.17 x 0.551 = 1.19567
Total .................................... 2.17 mg/day
I do not believe these figures represent current conditions.
According to Canada's National Research Council: "Fluoride is a
persistent bioaccumulator, and is entering into human food-and-
beverage chains in increasing amounts. Careful consideration of all
available data indicates that the amount of fluoride ingested daily in
foods and beverages by adult humans living in fluoridated communities
currently ranges between 3.5 and 5.5 mg"
-Environmental Fluoride (1977) National Research Council of Canada
(NRCC No.16081) Associate Committee On Scientific Criteria For
Environmental Quality
According to Drinking Water and Health, (NRC 1977): "Two recent
articles from Spencer's group (Kramer et al., 1974; Dace et al., 1974)
appear to support a higher estimate for dietary fluoride intake. The
first is based on hospital-prepared food from 16 U.S. cities. The
fluoride intake from food in the fluoridated communities was found to
range from 1.6 to 3.4 mg/day (av. 2.6) while that from nonfluoridated
cities was 0.8-1.0 mg (av. 0.9)."
This is a portion of Kramer's data:
LOCATION ....... F- in Water ..... F- in Food
Corvalis, OR .... 0.60 mg/L ..... 3.44 mg/day
Milwaukee, WI ... 0.85 mg/L ..... 3.41 mg/day
Cleveland, OH ... 1.27 mg/L ..... 3.05 mg/day
Tuscaloosa, AL .. 0.76 mg/L ..... 2.94 mg/day
Madison, WI ..... 1.11 mg/L ..... 2.88 mg/day
-Kramer, Osis, Wiatrowski and Spencer, Dietary Fluoride In Different
Areas in the United States, American Journal of Clinical Nutrition -
27:590- 594, 1974. (Note: these figures do not include non-meal foods
or beverages)
According to Dietary reference intakes for calcium, phosphorus,
magnesium, vitamin D, and fluoride, (IOM 1997): "... average dietary
fluoride intakes by adults living in fluoridated communitues have
ranged from 1.4 to 3.4 mg/day, or from 0.02 to 0.05 mg/kg/day for a 70
kg person." These figures represent a dramatic increase in total daily
fluoride intake from sources other than drinking water.
In 1971 NRC reported: "The daily intake of fluoride consists of
approximately 0.2 mg from foods, some amount contributed from drinking
water (which depends on the concentration of fluoride in the water
supply), and fluoride from industrial sources, dentifrices, and
possibly drugs. For the average U.S. adult not working in a fluoride
industry and using a water supply containing 1 mg/liter, the
approximate daily intake is 1.2-1.5 mg of fluoride.
-Biologic Effects of Atmospheric Pollutants FLUORIDES, Committee on
Biologic Effects of Atmospheric Pollutants, Division of Medical
Sciences, National Academy of Sciences, 1971.
According to Recommended Dietary Allowances, (NRC 1989), the adequate
fluoride intake for adults is just 1.5 mg/day (0.02 mg/kg/day) - the
same quantity reported by McClure in 1943 and 1949 for adults living in
"optimally" fluoridated areas (1 mg/L).
The National Research Council of Canada reported that British teenagers
have an estimated mean daily intake of fluoride from toothpaste of .32
mg with an extreme high of 5.0 mg.
-National Research Council of Canada, NRC Associate Committee on
Scientific Criteria for Environmental Quality, "Environmental Fluoride,
1977," page 79
Darlene Sherrell
Woburn Post Office
St. George's
West Indies
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