NFFE Statement on Dietary Reference Intakes

Local 2050

by Richard Foulkes, M.D.

September 23, 1997

The document "Dietary Reference Intakes, Prepublication Copy" (DRI) is seriously flawed and deficient as an instrument to justify a public policy to establish fluoride as an "essential nutrient". The DRI document is rife with inadequacy, error and deceptive information, only some of which can be touched upon here.

For example, the only adverse effects of fluoride exposure discussed in DRI are enamel and skeletal fluorosis. These effects are only cursorily and deceptively touched upon, and no connection is made between them, as though they were independent effects and fluoride affinity for and damage to enamel is not a biochemical window on what is happening in bone.

While DRI lays out the parameters for conducting risk assessments in Chapter 3, it ignores application of those parameters particularly egregiously with respect to fluoride in purporting to establish a "tolerable upper intake level". One component of risk assessment is hazard identification, whose components include addressing evidence of adverse effects in humans. DRI attempts to deceive the public into believing the only identified adverse effects of fluoride exposure of significance are those mentioned above. The DRI document omits any mention of studies in humans showing increased risk of hip fractures and bone cancer and decreased I.Q. in children in areas with artificially fluoridated water or other sources of dietary fluoride that result in fluoride intakes that are below the "tolerable appear intake". Neither does the DRI document properly address use of animal data in the hazard and risk assessments on fluoride. There are recent (1990-1995) animal data supporting concern for both cancer and central nervous system effects.

Even if one grants as accurate the statement at page 8-15 in the prepublication copy of DRI, "Most research has indicated that an intake of at least 10 mg/day for 10 or more years is needed to produce clinical signs of the milder forms of the condition" (skeletal fluorosis), consider the simple mathematics of this "tolerable upper intake" level. That level is set at 10/mg/day for individuals aged 9 years and up. At age 39, the individual who has received the "tolerable upper intake" since age 9 will have accumulated 3 times the amount of fluoride needed, according to the DRI, to put him or her at high risk or skeletal fluorosis -- not to mention bone fracture, cancer and decreased mental capacity

When a chemical manufacturer wants to make a new chemical to use, for example, as an additive in motor oil, all existing toxicological data must be presented to the Environmental Protection Agency for review of potential risks before manufacture and use can begin. In the DRI we see risk assessment principles, as applied to a major public policy issue, flouted -- even the existence of a massive body of information on adverse effects of fluoride is ignored, let alone discussed. And this for a chemical the National Academy recommends we purposely add to our diets, not our motor oil.

Furthermore, the claimed benefits from the "adequate intake" level have been shown to be based on biased or otherwise flawed studies. Not a single one of those studies was a randomized control trial.

In summary, our union members' review of the literature over the last 11 years has led us to conclude that a causal link exists between fluoride exposure and cancer, increased risk of hip fracture, and damage to the central nervous system. For the National Academy of Sciences to attempt to anoint this substance an "essential nutrient" is a travesty and a matter of shame for the U. S. science community.

National Federation of Federal Employees Local 2050 represents and is comprised of scientists, lawyers, engineers and other professionals at Headquarters, U S Environmental Protection Agency Washington D.C.

Central Nervous System References:

1. Li, X S , Zhi, J L , Gao, R. O. Effect of fluoride exposure on intelligence in children. Fluoride 28:4, 189-192 (1995).

2. Zhao, L.B., Liang, G., Zhang, D., Lu-Liang, X. Wu. Effect of a high fluoride water supply on children's intelligence. Fluoride 29:4, 190-192 (1996).

3. Mullenix, P.J., Denbesten, P.K., Schunior, A., Kernan, W.J. Neurotoxicity of sodium fluoride in rats. Neurotoxicology and Teratology 17:2, 169-177 (1995).

CONTACT: Dr. J. William Hirzy, Senior Vice President 202-260-4683