NFFE Statement on Dietary Reference Intakes
NATIONAL FEDERATION OF FEDERAL EMPLOYEES
SERVING FEDERAL EMPLOYEES ... AND THE NATION ... SINCE 1917
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
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