September 5, 2000: In a twenty-two page, response to the United States House Subcommittee on Energy and the Environment, Chairman, Charles Fox, Assistant Administrator USEPA, admitted that after more than five decades of fluoridation at least tens of millions of Americans could could be adversely affected by fluoridated drinking water. Fox wrote:

• "EPA is in the process of developing medical fact sheets to provide medical practitioners (doctors, nurses, dieticians, etc.) with health data relative to drinking water contaminants that can be then used in counseling patients. This work has just begun, and will initially focus on the elderly, children and pregnant women. It will later be expanded to cover other at-risk populations. In addition, EPA has made it a requirement for public water systems to provide their clients with health effects information on contaminants in their water supply, including fluoride [Consumer Confidence Rule FR 63(160): 44512-44536]."*

Charles Fox acknowledges the Toxicological Profile for Fluorides (US Agency for Toxic Substances and Disease Registry, 1993) page 112 statement: "POPULATIONS THAT ARE UNUSUALLY SUSCEPTIBLE. Existing data indicate that subsets of the population may be unusually susceptible to the effects of fluoride and its compounds. These populations include the elderly, people with deficiencies of calcium, magnesium and vitamin C, and people with cardiovascular and kidney problems . . . Poor nutrition increases the incidence and severity of dental fluorosis and skeletal fluorosis."

The following statistics are of the 'at risk' populations compiled for the House Committee on Science inquiry by the USEPA:

• 55 years and older population--52,000,000

• Cardiovascular disease--22,000,000

• Kidney (renal) disorders--2,000,000

• Vitamin C deficiency--27% of the population

• Magnesium deficiency--37% of the population

• Calcium deficiency--44% of the population

In the response to congressman Ken Calvert, the EPA also concedes that fluorosilicic acid and fluorosilicates, the preferred chemicals used to fluoridate drinking water are captured pollution waste products from phosphate fertilizer industry.

No safety testing has ever been done with the products.**

* The addition of fluoride substances to the drinking water for the purpose of water fluoridation are regulated by EPA as contaminants.

Congressman Calvert's Question 8: "How many individuals in the nation does EPA estimate fall into the category depicted as “unusually susceptible” in the Toxicological Profile for Fluorides, Hydrogen Fluoride, and Fluorine, published by the Agency for Toxic Substances and Disease Registry? What measures does EPA recommend for these 'unusually susceptible' individuals who live in fluoridated communities or communities whose water contains fluoride at the MCL?"

Fox tried to mitigate the clear warning of the Toxicological Profile:

"Table 1 below summarizes those populations that the ATSDR Toxicological Profile (1993; Section 2.7) identifies as sensitive and includes data on the prevalence in the United States of the underlying physiological, nutritional, or age-related condition. It is important to note that the population values in Table 1 are numbers of individuals that fall in each category. There are no data to suggest that these individuals as a group are, or would be, sensitive to fluoride at the levels found in the environment. The demographic information for cardiovascular disease and renal disorders in Table 1 was collected by the Office of Water as a component of an effort to identify sensitive populations in the United States that might be sensitive to specific chemicals by virtue of their chronic disease state (O’Dey et al., 1998). Demographic data for the elderly come from a recently completed study of water intakes by the Office of Water (Jacobs et al., 2000). Prevalence values have been rounded to the nearest million and were extrapolated from the survey population to the U.S. population. Data on nutrient deficiencies are from the U.S. Department of Agriculture 1994- 1996 Continuing Survey of Food Intake by Individuals (USDA, 1998). The values given are the percent of the population consuming less than 75% of the Recommended Dietary Allowance for the nutrient in question."
However, he included the following table:

Fox diverted the congressman by commenting: "Individuals that fall in each of the categories listed in Table 1 have a number of specific risk factors that impact their health status such as body weight, diet, and life style (e.g. Smoking, alcohol consumption). Advice on beneficial life style changes for each condition is best provided by the medical community."

Despite the implications for susceptible populations acknowledged in the 1993 Toxicological Profile for Fluorides, seven years on EPA has done little to address them. Fox states:

"EPA is in the process of developing medical fact sheets to provide medical practitioners (doctors, nurses, dietitians, etc.) with health data relative to drinking water contaminants that can be then used in counseling patients. This work has just begun, and will initially focus on the elderly, children and pregnant women. It will later be expanded to cover other at-risk populations. In addition, EPA has made it a requirement for public water systems to provide their clients with health effects information on contaminants in their water supply, including fluoride [Consumer Confidence Rule FR 63(160): 44512-44536]."

Apparently unaware of any urgency, Fox added:

"Revised public notification language for fluoride has recently been proposed [FR 65(87): 25982-26049]. The new language suggests dental consultation in situations where there is a risk for dental fluorosis because the water provided by their drinking water system has exceeded the Secondary MCL for fluoride. The implementation manual for public notification is close to completion. In addition, please refer to the answer to Question 11 and EPA advice regarding fluoride exposure and infants."

Congressman Calvert's Question 9: "Do you interpret Section 101 (b)(4) of the Safe Drinking Water Act of 1996 as requiring EPA to set its MCL(G)s at a level that protects all persons, including sensitive populations, such as infants, children, people who drink 4 or more liters of water per day, people with allergies or hypersensitivity to fluoride and people with renal disease?"

Fox corrected the Congressman: "The Safe Drinking Water Act of 1996 does not have a Section 101(b)(4). Section 1412(b)(4)(a) states that “Each maximum contaminant level goal established under this subsection shall be set at the level at which no known or anticipated adverse effects on the health of persons occur and which allows an adequate margin of safety.'

"As required by the SDWA [Section 1458(a)(1)], EPA is collecting information to identify groups within the general population with increased sensitivity to contaminants such as infants, children, the elderly, persons with allergies or hypersensitivity to chemicals. Some of the data that we have collected in this process are cited in the response to Question 8 above."

Showing the EPA's apparent lack of urgency for the plight of susceptible people, Fox added: "If the MCL/MCLG for fluoride is selected for an in-depth evaluation as part of the six-year review of drinking water regulations, additional data on sensitive populations and their dose-response to fluoride will be collected and EPA will publish and seek public comment on its findings as required by the SDWA Section 1412(b)(3)(C)(i)(V)."

In regard to the use of fluosilicic acid as the source of fluoride for fluoridation, this agency regards such use as an ideal solution to a long standing problem. By recovering by-product fluosilicic acid from fertilizer manufacturing, water and air pollution are minimized, and water authorities have a low-cost source of fluoride...