The City of Port Angeles is currently fluoridating our water despite mounting evidence against the practice and the wishes of a large number of citizens. The fluoridation issue is not settled. We are pursuing several different paths in an attempt to stop fluoridation.
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We have obtained more than enough signatures to put 2 different initiatives (MIA WASA) on the ballot, but the City refused to do so and the state supreme court agreed with the city in a close, 5/4 vote. This avenue is now closed. |
| (2) |
Another approach is to have fluoride recognized as a drug by State Board of Health. Unfortunately, this takes time unless they unexpectedly agree with us. We have to exhaust administrative remedies before bringing a court case to compel adherence with the state laws which clearly define a drug as a substance used to treat or prevent disease. Tooth decay is a disease.
Prevention of the disease of tooth decay is clearly and repeatedly claimed as the rationale for fluoridation of drinking water. We will ask the State Board of Health and probably the Board of Pharmacy to declare that fluorosilicic acid (FSA) is a drug when it is used to treat or prevent tooth decay. If ruled a drug, all of FSA's components must be identified, including contaminants such as lead and arsenic.
FSA as a drug would bring up issues such as licenses for dispensers and labelers, the need for informed consent, etc.
June 17, 2008 meeting of the Clallam County Board of Health Dr. Eloise Kailin and others. discussed fluoride issues with the Clallam County Board of Health, along with a member of the Washington State Board of Health. This is a summary of the fluoride discussions.
Eloise EMail to Board of Health Dr. Yu attended our County Board of Health meeting June 17, 2008 at which time she indicated that her favorable opinion of fluoridation would not be influenced by any evidence Dr. Kailin might give her. Email Eloise to Dr. Diane T. Yu, Washington State Board of Health, sent on June 28, 2008.
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Fluoridation (FSA) as Medication?
One current effort in the fight against fluoridation is to have fluorosilicic acid (FSA) recognized as medication. Unfortunately, this takes time. We will ask the State Board of Health and probably the Board of Pharmacy to declare that FSA is a drug when it is used to treat or prevent tooth decay.
If FSA is ruled a drug, it is required that all components must be identified, including all contaminants such as lead and arsenic. FSA as a drug would bring up issues such as licenses for dispensers and labelers, the need for informed consent as well as other concerns. |
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| (3) |
A third approach is to convince the Washington State Department of Health, the Clallam County Board of Health, and the Port Angeles City Council that ANSI/NSF Standard 60, Section 3.2.1 (requiring the disclosure of all toxic substances in fluorosilicic acid) is not being followed. Our efforts include the following:
| January 2008 |
A Constructive Notice
was sent to WSDOH, Clallam Board of Health, City Council, and other parties responsible for the delivery of drinking water to citizens, pointing out that Standard 60 is not being followed. |
| February 19, 2008 |
A letter from Dr. Kailin to the Port Angeles City Council described the FSA extraction process and contaminants present in fluorosilicic acid as outlined in a letter written by Gary Pittman and asked the Council to seek documentation that Standard 60 was being met. A second letter from Dr. Kailin to the County Board of Health takes the Board to task for stating that fluoridation is not a concern of the Board since the board merely supported the City in its bid to fluoridate and had nothing to do with approval of fluoridation. Once again, the violation of Standard 60 was pointed out in detail. |
| February 20, 21, and 22, 2008 |
Several emails were sent to the WSDOH asking whether the National Sanitation Foundation (NSF) has performed the analyses required by Standard 60 and, if so, requesting the analyses documentation. These emails were lost in a computer crash. |
| March 10, 2008 |
In an email response from the Department of Health, Leslie Gates stated that NSF is in compliance with Standard 60. Her conclusion is based on a July 7, 2000 letter from Stan Hazan to Representative Ken Calvert. Hazan explained that Standard 60 was developed by NSF and other organizations to insure the safety of water. NSF does not decide what is safe, it merely tests to see that EPA’s Maximum Contaminant Levels are satisfied. The blanket statement is made that the requirements of Standard 60 are being met. No data are provided on individual tests that NSF has conducted. In fact, Hazan stated that “Individual test reports, as well as formulation information, are protected by nondisclosure agreements with the certification clients.” [page 6]
Furthermore, NSF tests only for regulated metals [page10] and not for biological agents, pesticides, etc. Hazan stated that suppliers of fluorosilicic acid supply toxicological information about contaminants, but in deposition before the House Subcommittee on Energy and the Environment, Hazan testified under oath that toxicological data were not being supplied by the companies. He stated “I would say that the HFSA submissions have not come with the tox[icological] studies referenced.” [page 50, lines14 and 15]
Thus one wonders just how thorough the “once yearly” Standard 60 testing is, why no records are kept “except for positive results,” and why no individual reports are kept. How can we or anyone be assured that Standard 60 is being followed?
Yet Gates concluded “We do not believe that NSF is in violation of its standards for judging the safety applicability of FSA that is used as a drinking water additive. . .The ANSI/NSF protocols for drinking water additives used by approved third party entities such as NSF International satisfy our concerns that ancillary materials are not contributed at harmful levels when the additive is properly applied.” |
| May 7, 2008 |
Kailin email to WSDOH (Mary Selecky) again requested evidence that Standard 60 requirements are being met and presenting arguments that it has not been followed. |
| June 17, 2008 |
PPF presentation by Dr. Kailin to joint meeting of the Clallam and State Boards of Health. It was pointed out that repeated requests for documentation that Standard 60 have not been supplied. Once again this information was requested. |
| June 30, 2008 |
A Public Disclosure Request concerning Standard 60 resulted in a Letter to Dr. Kailin from Diana Thieme of the DOH which included copies of the analysis done at the Seattle Tolt Water Treatment Facility in 2006. Also included was an earlier letter from Denise Clifford of DOH to James Deal, a Lynnwood attorney who opposes fluoridation. In both cases, the Tolt Analysis was used as evidence that Standard 60 was met. |
| August 13, 2008 |
Email from Lynn Kirby, Water Quality Engineer for Seattle, to Dr. Kailin. Kirby provided data from a December 2006 Tolt Treatment Facility analysis. This analysis, besides being outdated, is deficient in that it included no analysis of organic contaminants added to or formed by the fluoride extraction process. Among others, these include dioxins, pesticides, oil defoamers, polymers, naphthalene, and Synspar.
According to the NSF Fact Sheet from the NSF web site Standard 60 “requires full disclosure of each chemical ingredient (emphasis added) in a product. It also requires a toxicology review. A toxicology evaluation of test results is required to determine if any contaminant concentrations have the potential to cause adverse human health effects.” |
| October 21, 2008 |
Dr. Kailin presented another handout to the Clallam County Board of Health. Once again the DOH was informed that so far all we have gotten are statements that Standard 60 is being followed but there has been no documentation to support such a claim. |
| October 28, 2008 |
A Public Disclosure Request included a Letter from WSDOH (Gregg Gruenfelder. Gruenfelder stated that “we have confirmed the city [Port Angeles] uses fluorosilicic acid provided from J. R. Simplot Company in Rock Springs, Wyoming. The product is NSF Standard 60 certified . . .”
He admitted that “Washington Administrative Code 246-290-220(3) requires that: ‘Any treatment chemicals . . . added to water intended for potable use must comply with ANSI/NSF Standard 60,’” but he provided no documentation other than a reference to the Hazan letter to Calvert and the statement that compliance was satisfied. The Hazan argument was discounted on March 10, 2008 (see directly above). |
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| (4) |
The fourth approach, acted on in January 2008, involved sending Constructive Notices to all parties responsible for the delivery of drinking water to citizens.
The notice identified unlawful activity (such as noncompliance with NSF/ANSI 60 Gen. Rqmt. Sect. 3.2.1, failures to warn, and misrepresentations such as omissions of material facts concerning the use of hydrofluosilicic acid and its contaminants. This has implications that can result in liability for the entities and responsible parties notified.
Citizens have the right to know what substances are being put into the drinking water and the potential effects on their health.
Constructive Notice document (and cover letter) directed to parties with authority over delivery of public drinking water to which hydrofluosilicic acid (also referred to as FSA, fluorosilicic, and fluosilicic acid) and its contaminants are added, and is to serve as legal notice to all such parties. Written by Eloise Kailin, M. D., Secretary, PPF on January 2, 2008
The following documents were included as attachments to the Constructive Notice. They provide valuable information relative to the effects of water fluoridation and the difficulties encountered in getting accurate information about the substances that contaminate fluorosilicic acid:
- Poughkeepsie’s letter to Solvay. This letter, dated May 9, 2007, from Poughkeepsie’s Joint Water Board to Solvay Fluorides requests information concerning their water fluoridation product. The Water Board was particularly concerned about safety and whether Solvay’s product met Standard 60 requirements.
- Solvay’s reply. The next attachment, Solvay’s reply, dated July 19, 2007, shows that Solvay did not address any of the Water Board’s questions but instead referred them to the Centers for Disease Control, which would not have the specific information requested.
- Hazan deposition. On March 10, 2004 of Stan Hazan, Ph.D., executive director for the Center for Public Health Education for NSF International (National Sanitation Foundation) testified that hydrofluorosilicic acid is included in Standard 60 and so it is required that HFSA be tested for contaminants.
- Adverse health effects of fluoride. Three graphs show water intake, fluoride intake, and estimated fluoride intake that would prevent adverse health effects for people in different age groups. The data show that the rate of consumption of fluoridated water produces various health problems for many individuals and is especially a problem for infants.
- Peninsula Pointers. Brief articles put out by Protect the Peninsula’s Future and published in the Peninsula Daily News detail some of the health problems associated with fluoridation.
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| (5) |
A fifth approach is to disseminate updated information about fluoridation problems to the City Council, the Clallam County Health Board, and other entities via regular presentations at Council meetings, letters to the editor, and emails.
Wash Dept Health Letter This letter questions Washington State Drinking water fluoridation policy in light of the National Research Council Report to EPA in March 2006. It also questions pollutant loading of fluoride additive materials and NSF/ANSI Standard 60 as required by WAC 246-290-220. The letter requests that WDOH disclose their efforts to address these two issues, and obtain evidence that requirements of the protocol for NSF/ANSI Standard 60 are or are not being met. What are all the components of the fluoridation chemical mixtures we are putting in our drinking water? E. Kailin to Mary Selecky, Washington Dept. of Health, May 7, 2008.
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| (6) |
A sixth approach is to bring public attention to the latest information on what other areas are doing to stop fluoridation of drinking water. We are not alone in our opposition to this practice. |
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