Notice To HRM Councillors Of Liabilities Concerning Public Health With The Addition Of Fluoride And Chlorine To The Public Water Supply
Since 1945, the use of fluoride has been considered a successful public health initiative for reducing dental cavities and improving general oral health of adults and children. However the risks have largely been ignored in media reports or shared in public health messaging.
There are many concerns regarding this manufacturing byproduct that has been added to many municipal water systems. The risk /benefit analysis has not been examined and in this age of awareness of public health there needs to be truthful and informed discussion on the broader health view of fluoride and chlorine. A recognition of the minimal benefits do not outweigh the risks to the overall population’s health. An effort to mitigate dental caries in children and adults is no longer an excuse to the many adverse effects which call into question their use as a public health measure.
Dr. Joyce Donahue EPA Scientist Office of Water, under subpoena, agrees with the position we at the CANS Board take and said new research does indeed warrant “an update to the fluoride assessment”.
If the goal is to protect health then it makes very little sense to maintain the status quo simply because the public health measure has been practised for decades. Science is the practice of questioning and by its very virtue begs the question why water fluoridation has not been constantly monitored and studied to ensure it lives up to its claim. So it is from this standpoint that some areas of serious health concern that carry liabilities for municipal government decisions with regards to fluoride, need to be addressed and discussed.
Fluoride Health Risks
Endocrine disruption
The following are statements made under oath by the CDC’s Director of the Oral Health Division Mr. Casey Hannan in a deposition
https://fluoridealert.org/content/new-deposition-videos-featuring-cdc-oral-health-director/ on November 6 2018:
Fluoride displaces Iodine in the body and causes endocrine disruption. Therefore is considered an endocrine disruptor in the broad sense in that it alters the normal function of the endocrine system.
The CDC accepts that fluoride is an endocrine disruptor and that it affects individuals differently.
Over 82 million prescriptions for Levothyroxin are filled in a year in the US where approximately 66% of municipal water is fluoridated. In Canada, where approximately 44% of municipal water is fluoridated there were nearly 20 million prescriptions of Synthroid® written in 2019. Currently sold by Mylan Pharmaceuticals, Synthroid® is the largest volume prescription drug sold in Canada.www.IQVIA.com
Neurotoxicity
Alzheimer’s Disease
Also discovered in the above mentioned deposition of the CDC’s Director of the Oral Health Division Mr. Casey Hannan, that fluoride increases the free radicals in the brain through several different biological pathways. These changes have a bearing on the possibility that fluorides act to increase the risk of developing Alzheimer’s disease. The CDC agrees to these findings in the toxicological literature.
Neurodevelopmental Disruption
Mr. Hannan stated that the CDC does not perform any research into the tolerable upper fluoride intake levels for neurotoxic effects of fluoride.
The CDC Director also stated that the agency does not have any data or is aware of any data in the published literature that define the tolerable upper fluoride intake levels for neurotoxic effects in infants, toddlers and children.
Dr. Philippe Grandjean, Chair of Environmental Medicine at the University of Southern Denmark and Adjunct Professor of Environmental Health at Harvard School of Public Health (2014):
“Prevention of chemical brain drain should be considered at least as important as protection against caries.” http://fluoridealert.org/content/bulletin_12-18-14/
“Children who lived in areas with high fluoride exposure had lower IQ scores than those who lived in low-exposure or control areas.”
https://fluoridealert.org/wp-content/uploads/choi-2012.pdf
It is difficult to reconcile that dental caries as a health concern eclipses the deleterious effects of fluoridation on children’s IQ.
Anatomical Changes in the Brain
Studies of rats exposed to sodium fluoride or aluminum fluoride have reported distortion in the cells in the outer and inner layers of the neocortex. Neuronal deformations were also found in the hippocampus and to a smaller extent in the amygdala and the cerebellum. The CDC also agrees with this summary of the findings.
ADHD
Fluoride Exposure and ADHD: A Systematic Review of Epidemiological Studies “This potentially harmful effect can be explained at two levels. First of all, the ability of fluoride to cross the less efficient blood–brain barrier in prenatal and early life. Secondly, the ability to concentrate in the brain areas responsible for memory and learning abilities, affecting the metabolism and physiology of neuronal and glial cells through oxidative stress [34,35]” https://pmc.ncbi.nlm.nih.gov/articles/PMC10143272/
National Research Council (2006):
Fluoride has the ability to “interfere with the functions of the brain and the body by direct and indirect means.”
October 10, 2018 Press Release from Dalla Lana School of Public Health, University of Toronto:
“Higher levels of urinary fluoride associated with Attention Deficit Hyperactivity Disorder (ADHD) in children”
Neonatal Fluoride Exposure
There is a concern that some pregnant women and children may be getting exposed to more fluoride because of the many sources including treated public water, water-added foods and beverages, teas, coffee, baby formula, toothpaste, floss, and mouthwash, and the combined total intake of fluoride may exceed safe amounts. There is choice in the products that people purchase however not in the water that comes through our taps into our homes. Due diligence by HRM through Halifax Water in this matter has not been performed.
National Scientific Council on the Developing Child (2009):
It’s not just about dose. Most important is “the timing during the developmental process… The immature nervous system of an embryo or fetus is even more vulnerable to toxic exposures than is that of an infant.”
EPA Neurotoxicology Division (2009):
A team of researchers found “substantial evidence” that fluoride is a “developmental neurotoxicant“ in the same category with alcohol, arsenic, bisphenol A, lead, mercury, and nicotine.
https://cfpub.epa.gov/si/si_public_record_report.cfm?Lab=NHEERL&dirEntryID=200234
October 10, 2018, Press Release from York University:
Study: Fluoride levels in pregnant women in Canada show drinking water is primary source of exposure to fluoride
Minimal Benefit in Oral Health
Even in the areas of dental health there is minimal evidence that the addition of fluoride to the water supply gives any real benefit to the prevention of dental caries.
CATFISH Study
There is no reduction in dental caries for 12 year olds between fluoridated and non\fluoridated communities. https://pubmed.ncbi.nlm.nih.gov/36469652/
Legal Precedents
Some efforts in other jurisdictions that have removed the legal ability to add fluoride to the water supply include:
Utah Bill H.B 8l:
– defines terms;
– prohibits adding fluoride to public water systems;
– allows a pharmacist to prescribe fluoride; and
– directs the Division of Professional Licensing to establish guidelines for prescribing fluoride.
https://le.utah.gov/Session/2025/bills/introduced/HB0081S01.pdf
Food & Water Inc v United States EPA
“The issue before this Court is whether the Plaintiffs have established by a preponderance of the evidence that the fluoridation of drinking water at levels typical in the United States poses an unreasonable risk of injury to health of the public within the meaning of Amended TSCA. For the reasons set forth below, the Court so finds. Specifically, the Court finds that fluoridation of water at 0.7 milligrams per liter (“mg/L”) – the level presently considered “optimal” in the United States – poses an unreasonable risk of reduced IQ in children..the Court finds there is an unreasonable risk of such injury, a risk sufficient to require the EPA to engage with a regulatory response…One thing the EPA cannot do, however, in the face of this Court’s finding, is to ignore that risk.”
In 1983, Fluoride was ruled in Scotland as a medical treatment by Judge Lord Jauncey. His ruling found that it was beyond the power of the local authorities to add fluoride to water. He said the authorities did not have the power to treat water for general health improvement purposes.
https://www.nytimes.com/1983/06/30/world/judge-in-scotland-bars-fluoridation-of-water. html
Organizations working towards the prevention of fluoride implementation :
Moms Against Fluoridation: https://momsagainstfluoridation.org/moms-against-fluoridation
Fluoride Free Peel
Safewater Halifax: https://www.facebook.com/profile.php?id=100064799703740
Stop Forced Water Fluoridation: https://www.facebook.com/stopforcedfluoridation
Fluoride Free Alliance UK: A UK group heading a group action against the implementation of fluoridation into the public water system. www.ukfffa.org.uk
Chlorine Health Risks
Here are some areas of health concern that carry liabilities for municipal government decisions with regards to chlorine:
Chlorine Gas Toxicity
Exposure to chlorine gas is an irritant to the nasal passages, eyes, and respiratory system. Acute exposure can cause serious health issues and may be fatal.
Cancer risk
The use of chlorine for water treatment to reduce the risk of infectious disease may account for a substantial portion of the cancer risk associated with drinking water. https://ehp.niehs.nih.gov/doi/epdf/10.1289/ehp.95103s8225
Drinking chlorinated water with trichloromethane (THM) by-products causes an increased risk of bladder, colon, and rectal cancer. An article published in the 1995 Environmental Health Perspectives gives study details of how chlorination and by-products may account for up to 8,000 cases of bladder cancer and 5,000 cases of rectal cancer annually. https://ehp.niehs.nih.gov/doi/10.1289/ehp.95103s8225
Congenital Disabilities
A study of close to 400,000 women in Taiwan who were exposed to THMs during pregnancy had a higher likelihood of giving birth to a baby with congenital disabilities. Being exposed to THMs in drinking water while pregnant, they were born with three abnormalities: lack of brain development, ventricular septal heart defect, and cleft lip.https://wcts.sinica.edu.tw/wctsI/abstract/D5P2.pdf
This submission is by no means an exhaustive list of the studies concerning Fluoride and Chlorine. If an organization, such as CANS, can find this data, it would stand to reason that the Nova Scotia Department of Health and Wellness, the Chief Medical Officer of Health, Public Health Nova Scotia and all the considered experts in the area of health would not only have access to this same data, but would also be required to perform ongoing analysis of their recommendations to the fluoridation and chlorination of drinking water. It seems this duty to the public has not been employed. Due diligence was not applied when making such recommendations and properly informing the public, who trust this risk/benefit analysis work is being done, did not take place.
Municipal Liabilities
● Client being prescribed a medical treatment for a an illness they don’t have
● Client’s clinical history is not factored into the medical treatment and therefore drug interactions are not considered.
● Client has no right to refuse treatment.
● Client is not given informed consent.
● Client experiences uncontrolled dosing with higher probability of overdosing.
● Client unaware of being treated medically for a hypothetical potential disease.
● Client is unaware what drug is being administered.
The type of fluoride used in the fluoridation process is not readily available on the Halifax Water website for public scrutiny and therefore cannot constitute full informed consent of the HRM ratepayer who consume and purchase the treated water.https://www.halifaxwater.ca/publications-reports
HRM Ratepayers
At the head of the HRM organizational chart are the Citizens of HRM and thus their wishes, concerns and informed consent are by default, the priority measure when implementing programs and services to the citizens.
Based on the position held by the HRM Citizens as the authority over the administration of their city there should be no difficulty with the HRM Council supporting the changes to water treatment in light of the evidence of harm posed by these additives.
Regardless of how the practice of adding these substances to our public water system came about, there is ample evidence that there are many harms attributed to this intervention. The decrease in IQ from daily fluoride use has been known for decades as exemplified by this meta study. Fluoride Exposure: Neurodevelopment and Cognition.
Healthy Alternatives to the Purification of Water
An alternate but well established solution to water purification can be found in Chlorine Dioxide (ClO2) which has been safely used worldwide for decades. The World Health Organization (WHO) recognizes chlorine dioxide as a safe and effective disinfectant for drinking water, including for taste and odor control, and includes it in its Guidelines for Drinking-water Quality. https://www.who.int/teams/environment-climate-change-and-health/water-sanitation-and -health/chemical-hazards-in-drinking-water/chlorine-dioxide-chlorate-and-chlorite
Informed Consent
At the end of the day the only question that should be asked is: Has informed consent taken place when fluoride or chlorine is added to the public water system? The Department of Health and Wellness in its Nova Scotia Immunization Manual https://www.nshealth.ca/sites/default/files/2023-08/Immunization-Manual.pdf outlines what forms proper full informed consent to medical treatments in Chapter 4 page 34. The consent must:
• state exactly what is going to be done
• be informative
• be freely given (voluntary) and not have been obtained through misrepresentation or fraud
The answer is unequivocally, no and the promotion by HRM that fluoride and chlorination of the water supply is a health measure could be considered fraudulent.
Ethical Implications
Based on the long held fundamental statements in legislation, international declarations and the supreme law in Canada, the right to choose is foundational to a democratic society. The implementation of fluoridation and chlorination in the treatment of the water supply based solely on public health recommendations is a violation of this cornerstone belief and the discontinuance of this scientifically unsupported practice needs to occur. If harm can result from the intervention then it cannot be identified as a health measure.
This letter serves as Notice to the Halifax Regional Municipality Councillors and its Corporate Administrators concerning fluoridation and chlorination of the municipal water supply and the liabilities involved in its implementation. Any action on the part of the Halifax Regional Municipality going forward is done with the knowledge of the information presented within and acceptance of the liabilities that come with the continuation of the current water treatment practices.
Responses