Anti-fluoridationists in Boulder got their proposal for repeal of water fluoridation on this year’s general-election ballot by petition. The petition labelled this as a proposal for “drinking water standards.” However, its principal — if not only — effect is on just one additive: fluoride. The apparent hope is to convince Boulder voters to do unwittingly what they would be unlikely to do if asked directly … eliminate a safe and effective public health program that is objected to only by a very few having a fringe political and social agenda.
The true effects of this short proposal can be seen by an analysis of its separate provisions.
The Environmental Protection Agency (EPA), and not the Food & Drug Administration (FDA), has jurisdiction over and responsibility for the quality of drinking water. EPA has set a maximum level of fluoride in water at 4 parts per million (ppm). There is a naturally occuring level of fluoride in water coming into Boulder’s treatment plant — usually around 0.3 ppm. Boulder has long been fluoridating to raise the fluoride level to about 0.9 ppm, considered optimal for dental health.
The FDA, meanwhile, recommends daily intakes of nutrients, and fluoride is included amongst other minerals, such as iron and zinc, that are considered essential for good health at all ages. However, the FDA does not “approve” (regulate) nutrients or supplements. Congress has specifically denied such authority to the FDA.
EPA’s job is not to determine what is safe in toto, but whether a particular level of contamination is unsafe for a particular source (like water). In any event, the established maximum levels (4 ppm) are sufficiently above the levels employed in water fluoridation (0.9 ppm) that there is no cause for concern about fluoride “ingestion”. Since fluoride does not accumulate in the human body (which is why we need continuous exposure to get health effects), there is no concern for an “entire lifetime of ingestion”.
As for contamination of other “toxic” substances, MCLGs are not “the scientific points of safety” set by the EPA as claimed here. The actual safety points are called Maximum Contaminant Levels (MCLs). The “goals” are just that — goals. For instance, with lead and arsenic, the goals are zero — desirable perhaps, but scientifically recognized as unobtainable in the real world. As a result, MCLs are used in safety regulations, not MCLGs.
The fluoridation additive used in Boulder — and in most cities in the US — is hydrofluorosilicic acid (HFS), which is an industrial-grade chemical containing barely detectable levels of the contaminants mentioned, especially after being added to water. When added to water, HFS completely breaks down into simple substances: hydrogen ions, fluoride ions, and silicon dioxide (sand) which is filtered out. Drinking water is tested thoroughly for contaminants, and no increase in contaminants like lead and arsenic has been noticed due to the addition of HFS. By the way, the Boulder Water Department has an excellent safety record for its water treatment.
Moreover, it should be remembered that both MCLs and MCLGs are applied to the water coming out of the tap (or leaving the treatment plant) and not to the individual additives to the water during treatment. Naturally occuring sources of contamination usually swamp any contribution by water-treatment additives. Thus, it is nonsense to worry about unavoidable contaminants going into the treatment process, when the process itself assures that the water coming out is safe and healthful by all regulatory standards.
There is no medication going on in Boulder’s water treatment plant. Specifically, fluoridation is not “medication.” Medication is something that treats an illness. No amount of fluoride is going to make a big cavity heal up.
Fluoride is actually a nutrient: something that helps the body maintain optimal good health. Fluoride strengthens teeth so they can fight off decay. Fluoride appears to also play a part in good bone formation in the inner ear and also helps us avoid hearing loss.
For those few unfortunates who cannot tolerate fluoridated water, there are filtering and other financially reasonable options. People with uncommon infirmities, with options available for dealing with their individual concerns, may not want to stand in the way of the general public reaping the significant benefits of fluoridated water.
Consider also that fluorine is the 17th most abundant element on Earth and occurs naturally in all water. Fluoridation is just the adjustment of the amount to give people optimal benefit at very little risk.
THEREFORE, be it ordained by the people that:
Section 1. A person or public or private water system may not add any substance to the public water supply which is intended for medication or to cure, mitigate, treat or prevent any disease (or maintain dental health) above the general purposes of making the water safe for drinking unless:
As mentioned above, the FDA does not regulate free-flowing water or water-treatment additives. (That is the job of the EPA.) Nor, by order of Congress, can it regulate naturally occuring nutrients or nutrient supplements.
Even if the FDA could regulate any of those things, it has no scientific means of establishing a margin of safety at “all dosage ranges” for any substance. That is an impossible standard for any manufacturer of any water additive to meet.
Thus, introduction (or re-introduction) of any fluoridation additive into Boulder’s water, even including a “pharmaceutical-grade” product, is a legal and scientific impossibility. In short, the intentional effect of this provision is a complete and permanent ban on fluoridation.
A Maximum Contaminant Level Goals for lead and arsenic are zero. Given all reasonable manufacturing processes, a goal of having a 100% pure product is impossible to reach. Thus, any additive which is actuality completely safe, but still not 100% pure, would be banned.
If a product added to the water for the general purpose of making the water safe for drinking had to meet this requirement, all water-treatment would become impossible. But it only applies to additives made for health reasons. Thus, only the intended purpose makes a product “toxic”!
So as with the FDA requirements, the introduction (or re-introduction) of any fluoridation additive into Boulder’s water, even including a “pharmaceutical-grade” product, is a scientific impossibility. In short, the intentional effect of this provision is a complete and permanent ban on fluoridation.
This message is from the Vote No on 2B Committee,
supported by the many very concerned health professionals serving the people of Boulder.