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January 20, 2022

Dear Dr. Walensky and Dr. Hacker:

A few days ago, it was announced  that Menominee, MI received a fluoridation award from the CDC.  These types of announcements are routine across the country. (Radio Announcement)

We understand that you have a difficult job, and you have many complex issues on your plate that include Covid and PFAS, but we would like to think that we have evolved beyond handing out participation awards to cities for medicating the public drinking water supply with a substance identified as a water contaminant with substantial evidence of neurodevelopmental toxicity. We suggest that rewarding communities for consistency in fluoridation practice when there is not only evidence of neurotoxicity but also an ongoing lawsuit against the EPA in Federal Court over the neurotoxic impact on fetuses and bottle-fed infants erodes public confidence of the CDC.  

Dr. Philippe Grandjean from Harvard T.H. Chan School of Public Health published a BMD of 0.2mg/L in 2021.  The National Toxicology Program's draft review of fluoride states, "NTP concludes that fluoride is presumed to be a cognitive neurodevelopmental hazard to humans. This conclusion is based on a moderate level of evidence that shows a consistent and robust pattern of findings in human studies across several different populations demonstrating that higher fluoride exposure (e.g., >1.5 mg/L in drinking water) is associated with lower IQ and other cognitive effects in children."  If we think that 1.5mg/L is harmful then we need to have a safety factor of at least 10 which would result in a fluoride in water MCLG of 0.15 ppm.

American communities have spent millions of dollars to remove lead water pipes because of the damage it can cause to the developing brain.  Fluoride is something we are paying to add which is showing similar harm to the brains of children - just like lead. And as with lead, environmental justice communities bear an increased burden.  CDC should immediately end the practice of rewarding communities for fluoridation, as well as the practice itself.  

CDC works 24/7 to protect America from health, safety and security threats, both foreign and in the U.S.  Fluoride exposure is an emerging health and safety threat.  CDC fights disease and supports communities and citizens to do the same.  CDC’s role is tackling the biggest health problems causing death and disability for Americans.  Fluoride exposure is associated with disabilities such as lowered IQ and ADHD.  We also need to consider fluoride’s role in arthritis, thyroid disorders, and dental fluorosis seen in over half of children.  CDC needs to act on Dr. Grandjean’s science in order to prevent human suffering. 

Fluoridation can no longer be considered a healthy and safe practice.  We now know fluoride poisons  consumers and the environment as approximately 99% of the chemical added to municipal water supplies goes directly into the environment where it interferes with the ecosystem. The long term repercussions on ecological receptors from the continual addition of fluoride to municipal water are unknown.

Fluoridation policy is no longer a smart choice; neither are participation awards.  We understand you need to manage many complex issues, but we also know that fluoride is a highly important issue due to the severity of harm caused to susceptible populations from womb to tomb. It is time the CDC stops turning a blind eye to the harm caused by fluoridation policy. It is time to stop rewarding communities for ignoring modern science and consumer health with participation awards. 

We look forward to your response and action regarding fluoridation policy and fluoridation awards. Attached is an annotated bibliography that further explains the dangers of optimal fluoridation policies. 

Sincerely,

Brenda Staudenmaier, named plaintiff in FWW et al. v. EPA et al. (Case e 3:17-cv-02162-JSC)

Karen Spencer, Food & Water Watch member representative in  FWW et al. v. EPA et al. 

Attachments:  Annotated Bibliography

On Fri, Jun 10, 2022 at 8:46 AM CDCExecSec (CDC) <CDCExecSec@cdc.gov> wrote:

Dear Brenda Staudenmaier and Karen Spencer:

Thank you for your letter to Centers for Disease Control and Prevention (CDC) Director Rochelle P. Walensky, MD, MPH, and other CDC officials regarding community water fluoridation and CDC’s annual quality awards to water systems that achieve optimal fluoridation levels for all 12 months. I am responding on behalf of Dr. Walensky.

For more than 75 years, CDC has carried out a mission to protect America’s safety, health, and security at home and abroad. Across our portfolio, CDC is committed to applying the best available science to address pressing public health issues so that people and communities can make evidence-based decisions and actions. A commitment to transparency, honesty, and thorough consideration of research outcomes is central to this process.

CDC carefully and continuously monitors emerging research about benefits and risks of fluoride so that recommendations are based on the entire evidence base. CDC continues to emphasize the importance of community water fluoridation at the recommended level of 0.7 mg/L as the cornerstone of caries prevention in the United States. Although high amounts of fluoride are harmful, the amount in treated drinking water is low and is not proven to result in any unwanted health effects other than the potential for dental fluorosis, a condition that causes primarily cosmetic changes in the appearance of tooth enamel. The 2015 U.S. Public Health Service panel chose 0.7 mg/L to provide the best balance of protection from dental caries while minimizing the risk of potential harms.

 The objective of CDC’s Community Water Fluoridation Quality Awards program is to commend water operators for achieving the highest level of quality, care, and consistency as they provide an important service to their communities. Regarding your comment on the National Institute of Environmental Health Sciences’ Draft National Toxicology Program Monograph on the Systematic Review of Fluoride Exposure and Neurodevelopmental and Cognitive Health Effects, the National Academy of Sciences, Engineering, and Medicine panel stated in their recent review that “much of the evidence presented comes from studies that involve relatively high fluoride concentrations” and that “the monograph cannot be used to draw conclusions regarding low fluoride exposure concentrations, including those typically associated with drinking water fluoridation.”

CDC and U.S. Public Health Service guidance on fluoridation has always been based on the best available science, diverse perspectives, and a careful consideration of research outcomes. We are committed to continuing to monitor the available science to ensure that communities can benefit from water fluoridation while minimizing any possible risks.

 We appreciate your interest in this important public health topic.

Sincerely,

Karen Hacker, MD, MPH

Director, National Center for Chronic Disease

Prevention and Health Promotion

“Early water fluoridation studies did not carefully assess changes in renal function.” 

- National Research Council, 2006 p. 280

"....the WHO's recommended concentrations in drinking water become nephrotoxic to CKD rats, thereby aggravating renal disease and making media vascular calcification significant.” - A. Martín-Pardillos et al. Effect of water fluoridation on the development of medial vascular calcification in uremic rats. Toxicology. 2014

September 29, 2022

Dear Dr. Walensky and Dr. Hacker, 

We are in receipt of Dr. Hacker’s letter dated June 10, 2022 which is in reply to our letter to the CDC dated January 10, 2022.  All letters are below.  

Allow us to reassure you that we not only fully understand both the CDC’s mission and policy, we also appreciate the inherent difficulties in navigating situations where adherence to policy is politicized or/and is in conflict with the overall mission, which in CDC’s case is to use the “best science” to ‘“protect America’s safety and health.” We also understand the science.  It is estimated that 4.5 million IQ points are lost per year due to fluoride neurotoxicity costing around $100 billion per year in economic damage.  This is much more costly than any possible dental benefit from swallowing fluoride.  

Your reply suggests you neither understood our position nor opened the supporting document, an annotated bibliography of approximately 100 scientific citations published after the HHS lowered the recommended concentration of fluoride in water from a range of 0.7 to 1.2 ppm to a single ‘optimal’ concentration 0.7 ppm in April 2015.  

We believe that the CDC Oral Health Division provided much of the content for your reply. That division is currently under the direction of Mr. Casey Hannan, MPH whose background is in social media marketing, communications and issue management. We respectfully suggest that Mr. Hannan might be adept at crafting talking points, but is either in over his head or being purposefully obtuse in order to protect paychecks and programs. 

Moreover, your reply did not acknowledge the BMD analysis by Dr. Philippe Grandjean that determined a 0.2 mg/L benchmark concentration level (BMCL) poses a risk to fetuses, bottle-fed babies and young children. This study was not only highlighted in the text of our letter, it was the first study in the annotated bibliography, and was explained in a November 2021 Zoom meeting with you and Mr. Hannan that included Dr. Grandjean, Dr. Christine Till and Dr. Bruce Lanphear. 

Your side-stepping dismissal of our complaint about the CDC’s continued celebration and promotion of fluoridation schemes ultimately seemed to center on the ‘cornerstone’ of an out-of-context comment from the NASEM peer review of the draft NIEHS/NTP hazard determination identifying 1.5 ppm as a presumed developmental neurotoxicant for susceptible populations beginning in the womb.  

Not only is it highly unusual, dare we say unique, that a comment from a peer-review committee be used to dismiss the multi-year effort of a government agency with a mission to protect population health by another government agency with the same mission, we suggest that the use of this comment in this way borders on disinformation as, among other things, the peer review committee also said that: 

1. “The committee did not conduct its own independent evaluation of the evidence, nor did it conduct a data audit; both were outside its scope.”

2. The NASEM committee stated their purpose was to ensure utmost clarity and transparency so that both proponents and opponents of fluoridation, even if they continue to disagree on the right course of action, can appreciate that the NTP processes by which its conclusions were derived were clear and were implemented without error. Relevant to that point, the NASEM committee found the NTP followed proper systematic review procedures but wanted more transparency concerning the OLHAT protocols and decision-making. 

That said, the NASEM was technically correct when they implied the NTP hazard determination should not be used as the final word on fluoridation policy. It is the job of the EPA to determine the safety factors which uses a hazard determination (and BMCL) as input. Ultimately, it is the EPA’s job to set a MCLG and MCL contaminant level for fluoride in water. Determining a hazard determination is the job of the NTP.

Sadly, it seems biased players which include the dental partners of the CDC Oral Health Division have put significant political pressure on both members of the NASEM committee and the NTP to not only soften the NTP language regarding their findings, but also to not issue a hazard determination. The NTP has signaled it may not present any conclusion but instead provide a “state of the science” compilation which will show that all of the high quality studies for concentrations over 1.5 ppm found a significant adverse neurotoxic effect, and 15 of 17 studies found the same neurotoxic impact in concentrations consistent with fluoridation policy concentrations. The NTP also wrote in its draft that the weight, quality and consistency of the evidence was such that further outlier studies would be unlikely to change its opinion of the developmental neurotoxic harm at 1.5 mg/L exposures.  

God only knows what the ultimate report will say, but the effort was supposed to reach a hazard determination specific to developmental neurotoxicity, just one of the risks of fluoridation policy. That hazard determination was expected to be published in 2020, 2021 and early 2022 but is still pending. 

But let’s step away from both neurotoxicity and the ‘only risk is mild dental fluorosis’ arguments for a moment and look to that annotated bibliography which provides science on adverse effects to other parts of the body including thyroids, kidneys, guts and bones. Again, although the two quotes at the beginning of this letter/email predate 2015 and should give anyone pause, the bibliography lists approximately 100 scientific science published after the publication of the 2015 report. That 2015 report was the other justification for of your dismissal. We suggest CDC medical doctors and scientists, rather than dentists and marketing staffers, should give that modern medical science serious consideration.  We are attaching an updated version of that bibliography as more science specific to fluoridation policy or relevant to fluoride exposure has been published this year. 

In particular, we like to draw your attention to the over twenty scientific studies specific to harm to kidneys and bones in the annotated bibliography, which were determined by the 2006 NRC/NASEM to be at particular risk of fluoride intoxication. May we remind you that Mr. Hannan admitted under oath in a recent deposition that the CDC accepted the 2006 NRC report as factual and accurate. As we are sure you know, fluoride is sequestered in bones and one in seven Americans will suffer from kidney disease in their lifetime, a statistic that certainly suggests an epidemic. We’ve highlighted some of those studies at the end of this letter.

We expect medical doctors and scientists at the CDC will study the items included in this letter and the separate attachment, but allow us to present a sample of excerpts from those studies for your convenience in the event you personally cannot find the time to read the science: 

“Taken together, these findings indicate that there can be some alterations in liver enzyme activities at early stages of fluoride intoxication followed by renal damage.” (Perera T. et al. 2018)

“The available guidelines for drinking water are solely based on healthy populations with normal renal function. But, it is evident that once the kidney function is impaired, patients enter a vicious cycle as fluoride gradually accumulates in the body, further damaging the kidney tissue.” (Nanayakkara, et al. 2020)

“In this cohort of postmenopausal women, the risk of fractures was increased in association with two separate indicators of fluoride exposure. Our findings are consistent with RCTs and suggest that high consumption of drinking water with a fluoride concentration of  ∼1 mg/L may increase both BMD (bone mineral density) and skeletal fragility in older women.” (Helte et al. 2021)

Allow us to make two more important points before closing:

1. An item which seems to elude the dentists and social marketing staff in the CDC Oral Health Division but which should resonate with medical doctors: concentration should not be conflated with dose. When diabetics or those reduced renal function drink excessive amounts of water, they exceed a typical dose that is considered safe by as much as a factor of six. If that person happens to be pregnant, the fetus will be swimming 24/7 in an amniotic fluid with a fluoride concentration that could exceed 5 ppm. The much higher concentration of fluoride in amniotic fluid from normal consumption of  1 ppm water by pregnant women was known by the PHS in the 1950s (Gardner DE, et al. 1952) 

2. As to the purpose of the awards CDC hands out to communities whose water workers maintain the 0.7 ppm target, celebrating doing the wrong thing well is not a good thing. Many water workers are beside themself with guilt over what they are doing, at least the ones with integrity. A recently retired water worker in Manchester-by-the-Sea, MA wrote in 2019 that it made him “heartsick” to poison his friends and family (attached). One of us, Brenda Staudenmaier, is a water worker actively opposing to fluoridation. The other, Karen Spencer, is an analyst and allergic person who consumed fluoridated water for decades and suffered a range of conditions consistent with the scientific findings. 

Simply put, citing mission statements and dated endorsements of policy is neither a refutation of modern science nor defense of tropes such as ‘balance the risks and benefits’ - not when the CDC encourages the use of municipal water systems to dose entire populations from womb to tomb with a poison that damages brains, bodies and bones. 

• See “Brenda and Karen's Fluoride Neurotoxicity Letter Response for CDC Hacker & Walensky” published on YouTube for a more detailed response to your letter:
                          https://www.youtube.com/watch?v=PzviupO1cDQ   

We look forward to a meaningful reply from the CDC, ideally a withdrawal of its support for fluoridation programs based on emerging science and evidence of harm to susceptible sub-populations. 

Sincerely, 

Brenda Staudenmaier, named plaintiff in FWW et al. v. EPA et al. (Case e 3:17-cv- 02162-JSC) 

Karen Spencer, Food & Water Watch member representative in FWW et al. v. EPA et al.

attached: Gardner DE, et al. The fluoride concentration of placental tissue as related to fluoride content in drinking water. Science. February 1952; MBTS water worker letter; water worker opinions; an oral response on YouTube; annotated bibliography (separate cover).

SAMPLE SCIENCE 

(see separate annotated bibliography attachment for more)

KIDNEY EXCERPTS FROM ANNOTATED BIBLIOGRAPHY

KIDNEY KILLER: Using U.S. NHANES data, finds water fluoridation results in significantly higher plasma fluoride levels in those with lower renal function, suggesting a vicious feedback loop for those with CKD. 

https://www.sciencedirect.com/science/article/abs/pii/S0013935122009306  

• John Danziger, Laura E.Dodge, HowardHu. Role of renal function in the association of drinking water fluoride and plasma fluoride among adolescents in the United States: NHANES, 2013–2016. Environmental Research. 7 June 2022.

KIDNEYS: This study of 1,070 adults found every 1 mg/L increment in the urinary fluoride concentrations was associated with significant increases of 22.8% in the risk of kidney function injury after adjusting for potential confounding factors. Authors conclude that long-term fluoride exposure is associated with compromised kidney function in adults, and that urinary NAG is a sensitive and robust marker of kidney dysfunction caused by fluoride exposure. 

https://pubmed.ncbi.nlm.nih.gov/34478979/ 

• Wu L, Fan C, Zhang Z, Zhang X, et al. Association between fluoride exposure and kidney function in adults: A cross-sectional study based on endemic fluorosis area in China. Ecotoxicol Environ Saf. 2021 Aug 31;225:112735.

AMERICAN KIDNEYS: Using U.S. NHANES data from two recent cycles, finds ‘optimal’ amounts of fluoridated water results in high incidence of uric acid in adolescents suggesting higher risk of kidney disease and other illnesses. Identifies dose-response trend in plasma fluoride of teens. 

https://www.sciencedirect.com/science/article/pii/S0147651320315074

• Yudan Wei, Jianmin Zhu, Sara Ann Wetzstein. Plasma and water fluoride levels and hyperuricemia among adolescents: A cross-sectional study of a nationally representative sample of the United States for 2013–2016. Ecotoxicology and Environmental Safety. Volume 208. 15 January 2021.

WHO IGNORES KIDNEYS: WHO guidelines of safety below 1.5 ppm fluoride concentration is wrong. “The available guidelines for drinking water are solely based on healthy populations with normal renal function. But, it is evident that once the kidney function is impaired, patients enter a vicious cycle as fluoride gradually accumulates in the body, further damaging the kidney tissue.”

https://www.sciencedirect.com/science/article/abs/pii/S0045653520313795

• Shanika Nanayakkara, et al. The Influence of fluoride on chronic kidney disease of uncertain aetiology (CKDu) in Sri Lanka. Chemosphere. Volume 257, October 2020, 127186

KIDNEY CASCADE:  “Taken together, these findings indicate that there can be some alterations in liver enzyme activities at early stages of fluoride intoxication followed by renal damage.” https://pubmed.ncbi.nlm.nih.gov/29769014/  

• Perera T. et al. Effect of fluoride on major organs with the different time of exposure in rats. Environmental Health and Preventive Medicine (2018) 23:17

WORSE THAN ARSENIC: ”In conclusion, F exposure was related to the urinary excretion of early kidney injury biomarkers, supporting the hypothesis of the nephrotoxic role of F exposure.” https://www.sciencedirect.com/science/article/pii/S0041008X18302382  

• Monica I. Jiménez-Córdova, Mariana Cardenas-Gonzaleza,  Guadalupe Aguilar-Madrid, Luz C. Sanchez-Peña, Ángel Barrera-Hernández, Iván A. Domínguez-Guerrero, Carmen González-Horta, Olivier C. Barbier, Luz M. Del Razo. Evaluation of kidney injury biomarkers in an adult Mexican population environmentally exposed to fluoride and low arsenic levels. Toxicology and Applied Pharmacology. May 2018.

KIDNEY & LIVER: Researchers at Mt. Sinai Medical School find American teens 

in optimally fluoridated American towns have markers for altered kidney & liver 

parameters that puts them at higher risk for kidney & liver disease as adults. 

Notes the primary source of fluoride is water. 

https://www.sciencedirect.com/science/article/pii/S0160412019309274 

• Malin AJ, Lesseur C, Busgang SA, Curtin P, Wright RO, Sanders AP. Fluoride
  exposure and kidney and liver function among adolescents in the United
  States: NHANES, 2013–2016. Environment International. August 8, 2019.

KIDNEYS: Fluoride is a common exposure that is selectively toxic to the kidneys. 

https://www.sciencedirect.com/science/article/pii/S0270929518301827 

• Lash LH. Environmental and Genetic Factors Influencing Kidney Toxicity.
  Seminars in Nephrology. Volume 39, Issue 2, March 2019, Pages 132-140. 

BONE EXCERPTS FROM ANNOTATED BIBLIOGRAPHY

GENOTOXIC: According to public health authorities, fluoride has a narrow range between the concentration which is beneficial and that which has adverse effects. The primary exposure to the fluoride-ion is through drinking water supplemented with fluorosilicic acid (FA). FA in ‘safe’ doses causes DNA damage in human osteoblast cells, reduces the telomere length and induces oxidative stress. Although combinations of fluoride with other toxins could have a synergistic effect, this study found that FA alone affects the genomic integrity of human bone cells.   

https://pubmed.ncbi.nlm.nih.gov/35483789/ 

• Garcia ALH, Matzenbacher CA, Soares S, Rohr P, da Silva J. Fluorosilicic acid and cotinine, separately and in combination, induce genotoxicity and telomeric reduction in human osteoblast cell line MG63. Mutat Res Genet Toxicol Environ Mutagen. 2022 Apr-May;876-877:503474.

BRITTLE BONES: “In this cohort of postmenopausal women, the risk of fractures was increased in association with two separate indicators of fluoride exposure. Our findings are consistent with RCTs and suggest that high consumption of drinking water with a fluoride concentration of  ∼1 mg/L may increase both BMD (bone mineral density) and skeletal fragility in older women.” https://pubmed.ncbi.nlm.nih.gov/33822648/ 

• Helte E, Donat Vargas C, Kippler M, Wolk A, Michaëlsson K, Åkesson A. Fluoride in Drinking Water, Diet, and Urine in Relation to Bone Mineral Density and Fracture Incidence in Postmenopausal Women. Environ Health Perspect. 2021 Apr;129(4):47005. 

OSTEOARTHRITIS: Identifies fluoride as an environmental chemical that has adverse effects on articular cartilage and osteoarthritis (OA) risk.  “In full sample analysis, a 1 mg/L increase in UF (urinary fluoride) level was associated with a 27% higher risk of OA.” 

https://link.springer.com/article/10.1007/s12011-021-02937-2 

• Sowanou, A., Meng, X., Zhong, N. et al. Association Between Osteoarthritis and Water Fluoride Among Tongyu Residents, China, 2019: a Case–Control of Population-Based Study. Biol Trace Elem Res (2021).

DECEPTION: This historical analysis documents how the ADA suppressed the established science that vitamin D was necessary for healthy teeth and bones in order to promote falsely fluoride which was and is more profitable for their membership. “Public health may well depend on looking at professional societies no different than the way we look at the pharmaceutical industry—conflicted organizations with a power to shape conventional wisdom based on fragile evidence.” https://www.mdpi.com/2072-6643/13/12/4361/htm# 

• Hujoel PE. How a Nutritional Deficiency Became Treated with Fluoride. Nutrients. 2021. 

BONE HEALTH: Low to moderate fluoride exposure weakens and damages bones in women. 

https://www.sciencedirect.com/science/article/abs/pii/S0147651320308708

• Minghui Gao et al, Association between low-to-moderate fluoride exposure and bone mineral density in Chinese adults: Non-negligible role of RUNX2 promoter methylation. Ecotoxicology and Environmental Safety. Volume 203, 15 October 2020.

BONES: Found an age-specific association between fluoride exposure and altered CALCA methylation in adult women, affecting bone health. https://pubmed.ncbi.nlm.nih.gov/32283421/ 

• Sun R, Zhou G, Liu L, Ren L, Xi Y, Zhu J, Huang H, Li Z, Li Y, Cheng X, Ba Y. Fluoride exposure and CALCA methylation is associated with the bone mineral density of Chinese women. Chemosphere. 2020 Aug;253:126616. 

PEDIATRIC BONE DISEASE: Identifies fluoride concentrations in water above 1.2 ppm as “dangerously high” that can cause pediatric bone disease. Urine measurements of fluoride in those afflicted are below the fluoride concentrations in women living in optimally fluoridated communities per 2017 Canadian study by Green et al. 

https://pubmed.ncbi.nlm.nih.gov/32692054/ 

• Nipith Charoenngam, Muhammet B Cevik, Michael F Holick. Diagnosis and management of pediatric metabolic bone diseases associated with skeletal fragility. Curr Opin Pediatr. 2020 Aug;32(4):560-573. 

BONES & GENES: This 30 day animal study at 8 mg/L fluoride documents DNA & RNA damage that inhibits gene expression which can be passed on through generations affecting bone development and contributing to weak bones, blood & bone cancers and skeletal fluorosis. 

https://www.sciencedirect.com/science/article/pii/S0147651318311734?via%3Dihub 

• Atule P. Daiwile, Prashant Tarale, Saravanadevi Sivanesan, et al. Role of fluoride induced epigenetic alterations in the development of skeletal fluorosis. Ecotoxicology and Environmental Safety. Volume 169, March 2019, Pages 410-417.

OVERDOSED BABIES: Over one third of babies (37%) in fluoridated American communities consume amounts of fluoride in excess of the upper limits of fluoride considered safe per government regulations. Even 4% of babies in non-fluoridated communities are overdosed on fluoride due to consumption of products made with fluoridated water. At the very least, this puts these children at high risk for developing dental fluorosis. Dental fluorosis is associated with increased incidence of learning disabilities, broken bones and kidney disease. 

http://jocpd.org/doi/10.17796/1053-4625-43.1.7 

• Claudia X Harriehausen, Fehmida Z Dosani, Brett T Chiquet, Michelle S Barratt, and Ryan L Quock. Fluoride Intake of Infants from Formula. Journal of Clinical Pediatric Dentistry. 2018.

GENES & BONES: “This study provides evidence that chronic oxidative and inflammatory stress may be associated with the fluoride-induced impediment in osteoblast differentiation and bone development.” http://link.springer.com/article/10.1007/s12011-016-0756-6  

• Gandhi, D., Naoghare, P.K., Bafana, A. et al. Fluoride-Induced Oxidative and Inflammatory Stress in Osteosarcoma Cells: Does It Affect Bone Development Pathway? Biol Trace Elem Res (2017) 175: 103.

CDCExecSec (CDC) Mon, Nov 7, 12:38 PM

Dear Brenda Staudenmaier:

The Centers for Disease Control and Prevention (CDC) is in receipt of your most recent correspondence to CDC leaders regarding community water fluoridation. Your email was referred to my office for a response.

CDC has responded to your previous inquiries on this topic, and we have no further information to share with you. Please send any future correspondence by return email to CDCExecSec@cdc.gov. CDC staff have been advised to refer any correspondence to this office as well.

We appreciate your interest in this important public health issue.

Sincerely,

Angela Oliver, JD

Executive Secretary

Office of the Executive Secretariat

Office of the Chief of Staff, CDC

January 1, 2023

Dear Ms. Oliver,

We are in receipt of your communication dated November 7, 2022 regarding our letters to Dr. Walensky and Dr. Hacker dated January 20, 2022 and September 29, 2022.

Since the June 7, 2022 non-responsive CDC reply to our first letter failed to address the medical, scientific or ethical issues we raised, your letter stating that the entire CDC has been informed to forward any communications from us to your office rather than respond isn’t that surprising. We assume you have read our letters and watched the associated YouTube; however, we wonder how much you understand about what is going on.

Allow us to provide you, Ms. Oliver, with more information:

We know from the October 26th court hearing for the TSCA lawsuit that the final version of the NTP report was about to be published in May but got held up at the 11th hour. We also know from that hearing that the report is circulating among departments in HHS, and perhaps with some of the pro-fluoridation private partners of the CDC Oral Health Division.

It occurs to us that it is highly likely that Drs. Rochelle Walensky, Karen Hacker and Peter Briss as well as Mr. Casey Hannan would have seen the NTP report. These CDC personnel accompanied by CDC Senior Attorney, Joanna Stetner, were in attendance at the Zoom call on November 1, 2021 with researchers Drs. Philippe Grandjean, Christine Till and Bruce Lanphear.

•   This begs the question: why are people at senior levels of CDC, who are undoubtedly in the know, shunting us off to an attorney whose job is to ‘clearly articulate CDC’s policy’ in communications with the public?

Medical doctors Dr. Walensky and Dr. Hacker might make a weak argument that they are too busy with their administrative duties to pay attention to the fluoride science, although we made it nigh on impossible for them not to in our letters as did those who arranged the Zoom call with expert published research scientists. However, Peter Briss, MD, MPH who we understand reports directly to Dr. Hacker and was on that call in his role as the CDC Medical Director has no excuse for not doing his homework. Moreover, per attached subset of CDC NHANES studies published after 2015, he and the entire staff of NCCDPHP and the Office of Science have considerable alarming information of population level harm at their fingertips which, at the very least, presents CDC with an ethical crisis regarding its promotion of fluoridation.

We know Dr. Briss, an epidemiologist, has been honored for his diligence in protecting population health in the past. So why the stonewalling tactics in the non-responsive CDC reply?

•   Why have Dr. Briss and other qualified CDC medical scientists remained silent regarding the evidence of harm? Why has CDC leadership lawyered up rather than address the voluminous science published after the 2015 HHS whitewash of CDC policy?

Could it be because Dr. Briss signed off on the 2015 policy endorsement that lowered the range of ‘optimal’ fluoride concentrations to a single limit of 0.7 ppm? Dr. Linda Birnbaum, a former NIEHS and NTP director, also signed off on that report. She has since changed her stance. As a matter of fact, Dr. Birnbaum who was a supervisor for a large part of the yet-to-be published NTP report coauthored a 2020 article with two of the researchers from the 2021 Zoom call. That trio wrote:

“New evidence questions existing policies about the safety of fluoride for babies' developing brains. Given that safe alternatives are available and that there is no benefit of fluoride to babies' teeth before they erupt or appear, it is time to protect those who are most vulnerable.” - Bruce Lanphear MD, PhD; Christine Till PhD; & Linda S. Birnbaum PhD in “It is time to protect kids’ developing brains from fluoride.” Environmental Health News (October 7, 2020)

It is Ms. Spencer’s observation as a former analyst in Corporate America that people in senior positions are very adept at positioning members of their teams in ways that sacrifice the integrity and compromise the careers of the less politically savvy subordinates. Regardless of whether or not senior CDC officials are attempting to protect themselves in this manner, the CDC is:

1. Failing to use the best available science to protect population health

2. Profiting from a policy that promotes chronic disease
3. Using disinformation tactics to gaslight and stonewall the public.

Consequently, our question to you, Ms. Oliver, is:

 •   Can you draw upon your personal values and professional integrity to make a positive difference in the world by advancing the scientific material in our letters with CDC medical scientists who will honestly address that material and who have the courage to prioritize protecting people ahead of protecting policy?

For purposes of transparency, we are publishing this correspondence history. We suggest that this action also documents that CDC is in effect a learned intermediary regarding the scientific evidence of potential and actual harm caused to susceptible sub-populations by fluoride exposure consistent with fluoridation practices. This status confers CDC with a duty to warn consumers. See: https://www.fluoridelawsuit.com/actions

Sincerely,

Brenda Staudenmaier, named plaintiff in FWW et al. v. EPA et al. (Case e 3:17-cv-02162-JSC)

Karen Spencer, Food & Water Watch member representative in FWW et al. v. EPA et al.

att: Recent NHANES studies

cc: Rochelle Walensky, Karen Hacker, Peter Briss, Rebecca Bunnell and NASEM leadership

NHANES Reports Relevant to Fluoridation Harm

1.     INFLAMMATION: “Our finding that neutrophils and monocytes are associated with higher plasma fluoride in U.S. children and adolescents is consistent with animal data showing fluoride related effects of increased inflammation.” https://ehjournal.biomedcentral.com/articles/10.1186/s12940-022-00911-6

•       Den Besten P, Wells CR, Abduweli Uyghurturk D. Fluoride exposure and blood cell markers of inflammation in children and adolescents in the United States: NHANES, 2013-2016. Environ Health. 2022 Oct 27;21(1):102.

2.     KIDNEYS: “Water fluoridation results in higher plasma fluoride levels in those with lower renal function. How routine water fluoridation may affect the many millions of Americans with Chronic Kidney Disease, who are particularly susceptible to heavy metal and mineral accumulation, needs to be further investigated.”

https://pubmed.ncbi.nlm.nih.gov/35688217/

•       Danziger J, Dodge LE, Hu H. Role of renal function in the association of drinking water fluoride and plasma fluoride among adolescents in the United States: NHANES, 2013-2016. Environ Res. 2022 Oct;213:113603.

3.     LIVERS & KIDNEYS: “Fluoride exposure may contribute to complex changes in kidney and liver related parameters among U.S. adolescents. As the study is cross-sectional, reverse causality cannot be ruled out; therefore, altered kidney and/or liver function may impact bodily fluoride absorption and metabolic processes.” https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6754771/

•       Malin AJ, Lesseur C, Busgang SA, Curtin P, Wright RO, Sanders AP. Fluoride exposure and kidney and liver function among adolescents in the United States: NHANES, 2013-2016. Environ Int. 2019 Nov;132:105012.

4.     BLOOD PRESSURE: “This study suggested that fluoride exposure may affect childhood blood pressure.” https://pubmed.ncbi.nlm.nih.gov/35168424/

•       Guo M, Afrim FK, Li Z, Li N, Fu X, Ding L, Feng Z, Yang S, Huang H, Yu F, Zhou G, Ba Y. Association between fluoride exposure and blood pressure in children and adolescents aged 6 to19 years in the United States: NHANES, 2013-2016. Int J Environ Health Res. 2022 Feb 15:1-11.

5.     LOW BIRTH WEIGHT & ENVIRONMENTAL JUSTICE: “Our findings suggest a significant association between excess water fluoride exposure (>0.7 ppm) and LBW weight in Hispanic women, independent of established LBW risk factors.” https://pubmed.ncbi.nlm.nih.gov/35897326/

•       Arun AK, Rustveld L, Sunny A. Association between Water Fluoride Levels and Low Birth Weight: National Health and Nutrition Examination Survey (NHANES) 2013-2016. Int J Environ Res Public Health. 2022 Jul 23;19(15):8956.

6. DENTAL FLUOROSIS; “The prevalence of dental fluorosis was 70% in the U.S. children and adolescents in survey of NHANES 2015–2016.” https://pubmed.ncbi.nlm.nih.gov/34166938/

•       Dong H, Yang X, Zhang S, Wang X, Guo C, Zhang X, Ma J, Niu P, Chen T. Associations of low level of fluoride exposure with dental fluorosis among U.S. children and adolescents, NHANES 2015-2016. Ecotoxicol Environ Saf. 2021 Sep 15;221:112439.

7.     REPRODUCTIVE HEALTH: “Median (IQR) water and plasma fluoride levels were 0.48 (0.53) mg/L and 0.34 (0.30) µmol/L respectively. An IQR increase in water fluoride was associated with a 3.3 month earlier first menstrual period (B= -0.28, 95%CI: -0.54, -0.02, p = 0.05). Additionally, we observed a significant interaction between plasma fluoride and race/ ethnicity in association with age of menarche (p = 0.01). For non-Hispanic black females, each IQR increase in plasma fluoride was associated with a 5-month earlier age of menarche (B=-0.42, 95%CI: -0.61, -0.23, p < 0.001).” https://ehp.niehs.nih.gov/doi/abs/10.1289/isee.2020.virtual.O-OS-619

•       Fluoride exposure and reproductive health among adolescent females in the United States: NHANES 2013-2016. A. J. Malin, S. A. Busgang, J. C. Garcia, P. Curtin, and A.P. Sanders. ISEE National Meeting Presentation. Environmental Health Perspectives. 23-26 August 2021.

8. DENTAL FLUOROSIS: “In 2001-2002, the weighted percentage prevalence of the denoted dental fluorosis categories were: 49.8% normal (i.e., unaffected), 20.5% questionable, and 29.7% very mild and above. In 2011-2012, the weighted percentage prevalence categories were: 31.2% normal, 7.5% questionable, and 61.3% very mild and above. When comparing years 2001-2002 with the years 2011-2012, the prevalence of very mild and above fluorosis increased by 31.6% (P <.0001) for the 2011-2012 group.” “There was a difference of 31.6% in dental fluorosis prevalence between 2012-2011 when compared to data from 2002-2001 in adolescents aged 16 and 17 years. The continued increase in fluorosis rates in the U.S. indicates that additional measures need to be implemented to reduce its prevalence.” https://pubmed.ncbi.nlm.nih.gov/29500282/

•       Wiener RC, Shen C, Findley P, Tan X, Sambamoorthi U. Dental Fluorosis over Time: A comparison of National Health and Nutrition Examination Survey data from 2001-2002 and 2011-2012. J Dent Hyg. 2018 Feb;92(1):23-29.

9. FLUORIDE & DEMOGRAPHICS: “About 30% of the children were at the risk of dental fluorosis.” https://pubmed.ncbi.nlm.nih.gov/28110134/

•       Jain RB. Concentrations of fluoride in water and plasma for US children and adolescents: Data from NHANES 2013-2014. Environ Toxicol Pharmacol. 2017 Mar;50:20-31.

10.  SLEEP PATTERNS: “Fluoride exposure may contribute to changes in sleep cycle regulation and sleep behaviors among older adolescents in the US. Additional prospective studies are warranted to examine the effects of fluoride on sleep patterns and determine critical windows of vulnerability for potential effects.” https://pubmed.ncbi.nlm.nih.gov/31818308/

•       Malin AJ, Bose S, Busgang SA, Gennings C, Thorpy M, Wright RO, Wright RJ, Arora M. Fluoride exposure and sleep patterns among older adolescents in the United States: a cross-sectional study of NHANES 2015-2016. Environ Health. 2019 Dec 9;18(1):106.

Dr. Mandy K. Cohen, MD, MPH
Director, Centers for Disease Control

Via email

September 14, 2023

Dear Dr. Cohen et al.,

Congratulations on your appointment! We understand that a requirement of your new position is cutting $1.5 billion dollars from the CDC budget.

Please allow us to offer you an opportunity for fulfilling that fiscal requirement by bringing your attention to our correspondence with your predecessor and Dr. Karen Hacker concerning:

1. Modern science documents that fluoridation policy even at ‘optimal concentrations’ is harmful to susceptible subpopulations who include pregnant women and their fetuses; bottle-fed infants and young children; the elderly and those in fragile health, such as diabetics and those with compromised kidney or thyroid function.

2. The considerable CDC financial incentives for fluoridation which do not result in health benefits, but rather serve to entrench a public harm  

3. NHANES documentation that fluoridation has multiple ill effects on American teens (See subset of NHANES citations in 1/1/23 letter)

4. Lack of any good quality evidence of substantial dental benefit.

CORRESPONDENCE (Jan. 20, 2022 - current): https://www.fluoridelawsuit.com/actions

ANNOTATED BIBLIOGRAPHY (since 2015): https://www.fluoridelawsuit.com/science

Allow us to suggest that given the numbered points above supported by the linked peer-reviewed published science, and the evidence of recent months which includes the National Toxicology Program (NTP) systematic review and meta-analysis relevant to developmental neurotoxicity and FOIA documentation of HHS/CDC political interference in the NTP scientific process apparently at the behest of the Oral Health Division and its private partners, as well as evidence of scientific fraud by a highly biased major advisor to the ATSDR, you could make a well-justified start on fulfilling your budgetary responsibilities by eliminating CDC promotion of and support for fluoridation policy.

POLITICS & NTP:

• Article on FOIA revelations of suppression: https://capitalandmain.com/health-officials-delayed-report-linking-fluoride-to-brain-harm

• Dr. Christine Till, PhD on NTP science: https://www.youtube.com/watch?v=NOc4XYto8eo

SCIENTIFIC FRAUD:

• Article: https://childrenshealthdefense.org/defender/researchers-hid-data-fluoride-lower-iq/

• Documents: https://fluoridealert.org/wp-content/uploads/Connett_Letter-to-NTP_May-24-2023-1.pdf

Given that the lawsuit against the EPA re its failure to fulfill its Congressional mandate per the Toxic Substances Control Act (TSCA) should be wrapping up in February (see our signatures), we suggest it also would be an good strategic move for the CDC to largely dismantle the Oral Health Division as it seems fluoridation is its primary focus and its penchant for spending money on marketing products largely imported from China and Mexico which are contaminated with arsenic and other metals is becoming less tolerable to informed citizenry who realize that approximately 99% of those imported chemicals go directly to wastewater where those pollutants “harvested” from foreign industry contaminate the American environment.

As to the broader arguments against fluoridation policy, we suggest the YouTube presentation to the Fitchburg, MA City Council and petition sent to the Massachusetts Water Resources Authority (MWRA), both from March 2023, should resonate with your current position:

• Liability, Legality & Ledgers: https://www.youtube.com/watch?v=C7_K0ZA0-Tc

• MWRA packet: https://fluoridealert.org/wp-content/uploads/MWRAletter_2023.03.pdf

To sum up, allow us to advise that CDC leadership consider two important checks on bias and decision making before making any comment on fluoridation going forward:

I.  Black Swan: Fluoridation can not be assumed safe- not any longer. Persistence in ‘safe and effective’ claims is demonstrably dishonest.

II.  Sunk-Cost Fallacy: Persistence in endorsing fluoridation policy is throwing good money after bad, an emotionally driven and fiscally irresponsible position. 

Thank you for your attention to this important issue. We are cc’ing a few significant stakeholders on your leadership team so as to familiarize them with this material, as well. We eagerly await your considered response.

Sincerely,

Brenda Staudenmaier, named plaintiff in FWW et al. v. EPA et al. (Case e 3:17-cv-02162-JSC)

Karen Spencer, Food & Water Watch member representative in  FWW et al. v. EPA et al.

cc: Debra Hourly (Chief Medical Officer), Nirav Shah (Principal Deputy Director), Aaron Bernstein (Director, NCEH/ATSDR), Howard Zucker (Deputy Director, Global Health), Jennifer Layden (Director, Public Health Data), Karen Hacker (Director, Chronic Disease Prevention), CDC Office of the Executive Secretariat, assorted NASEM & other stakeholders

Dr. Mandy K. Cohen, MD, MPH 

Director, Centers for Disease Control

Via email 

January 1, 2024

Dear Dr. Cohen et al., 

We trust this letter finds you well. We appreciate the gravity of your responsibilities and the demands on your time, but given recent developments, we feel compelled to write again in order to reiterate the concerns communicated in our letter dated September 23, 2023, regarding the promotion of fluoridation by the Centers for Disease Control and Prevention (CDC). Regrettably, we have yet to receive a response from your agency, and we seek your attention to this crucial matter. 

Our previous correspondence outlined our belief that discontinuing all promotion of fluoridation aligns with the CDC's mission and supports its 2024 cost-cutting objectives. Additionally, we have some pertinent comments relevant to the November 30, 2023 report, “Advancing Chronic Disease Practice Through the CDC Data Modernization Initiative,” authored by Dr. Karen Hacker, Dr. Peter Bris and others.

That article notes that one of the CDC initiatives is: 

• Leveraging Cloud Technologies: The Water Fluoridation Reporting System modernization project is seeking to modernize the online tool that helps states manage the quality of their water fluoridation programs and describes the percentage of the US population on community water systems that receives optimally fluoridated drinking water. The WFRS modernization will use cloud technology to enhance the system with additional functionality. The new system will provide more flexibility for data entry at the state and local levels, on-demand reporting and visualization, and easier data analysis. (Division of Oral Health)

We question whether this technological advancement aligns with the growing body of evidence against water fluoridation, particularly as outlined in the "Document Fraud" attachment accompanying this letter because:

1. Per the “Document Fraud” attachment, CDC has known since at least 2000 based on its own documents that fluoridation is an ineffective strategy. 

2. We have brought CDC’s attention to the science against fluoridation published just since 2015 on multiple occasions in the past couple of years with full scientific citations with hyperlinks and thumbnail annotations of the harms to bodies, brains and bones caused consumers by exposure to low dose fluoride exposures considered ‘optimal” by CDC. Moreover, we are not the first to do so. 

3. CDC has known since the publication of the 2006 National Research Council (NRC) report to the EPA, that there is no safety data for susceptible sub-populations and significant scientific evidence of probable harm. In 2018, Mr. Casey Hannan of the CDC admitted under oath in a deposition for the trial in federal court expected to wrap up in February 2024 that the CDC accepts the 2006 NRC conclusions. Mr. Hannan also admitted that the CDC has no safety data specific to pre- and post-natal exposure. We understand Mr. Hannan decided to retire before commencement of that trial.
   
   

4. CDC has been aware since the 1990s of both the developmental neurotoxicity of fluoride per the work of Dr. Phyllis Mullenix at Forsyth Dental and the oncogenic capacity of fluoride per the much publicized persecution of EPA senior scientist Dr. Wm. Marcus. If you personally are not aware of the political intrigues of that decade, we recommend you read “The Fluoride Deception” by investigative reporter Christopher Bryson (2004).     

5. Public Health Service (PHS) researchers advised the PHS in 1956 and 1961 that a portion of the allergic population would experience significant and acute ill effects from fluoridation programs with no pragmatic recourse to avoid the irritant. Other researchers in that decade advised that the placentas of women living in ‘optimally’ fluoridated communities were saturated with fluoride at twice the concentration of the water they drank. They opined that although they didn’t know the fetal impact, the mothers would probably be fine.  (Feltman 1956; Feltman & Kosel 1961; Gardner et al. 1952)

The adverse impact of even low dose exposure to fluoride on bodies, brains and bones include several of the conditions bemoaned by Drs. Hacker, Briss et al. in the CDC report. Diabetics and kidney patients get at least triple the dose of fluoride assumed ‘typical’ because they consume at least three times more water than a healthy adult. This constitutes a double threat for them as fluoride interferes with glucose metabolism and is nephrotoxic. 

Allow us to bring your attention to other chronic health conditions of epidemic proportions that that are fluoride related not mentioned in the CDC November report: 1) Arthritis and degenerative disc disease afflicting millions are clinically indistinguishable from stages of skeletal fluorosis, 2) Inflammatory gastrointestinal conditions which are consistent with stages of fluoride intoxication/poisoning are also rampant, 3) Thyroid disease is also caused or worsened by fluoride exposure and is epidemic in the U.S, which is predictable as fluoride is an endocrine disruptor affecting thyroid hormones. 

Ms. Spencer, an allergic person, suggests that auto-immune diseases are also caused and worsened by fluoridation policy. This is consistent with the findings of the controlled dose PHS study by Reuben Feltman and George Kosel on pregnant women (1956, 1961) and her reading of immunology and subsequent fluoride science, as well as her personal experience. Moreover, based on the birth of her son whose heart rate dropped down to 12 beats a minute in the hours after his birth, she suggests that allergic newborns born to allergic mothers sometimes die because of fluoridation policy. Her son’s heart rate variability began an hour or so after his healthy birth at full-term. Although medical staff at both her local hospital and the MGH neonatal ICU prepared her to lose her son that night, he survived. However, she never forgot what the NICU doctors told her: “We don’t know why, but sometimes babies just die like this.” 

• See: Krzeczkowski JE, et al. Prenatal fluoride exposure, offspring visual acuity and autonomic nervous system function in 6-month-old infants. Environment International. 2023 Nov 27.

This letter is being cc'd Mr. Casey Hannan’s temporary replacement, Dr. Gina Thornton-Evans, and is being logged at: https://www.fluoridelawsuit.com/actions 

Given the CDC mission and the mounting evidence against its safety and efficacy, we must insist that the CDC reevaluate its stance on fluoridation policy and promotion. Aligning CDC policies with the latest scientific findings is not only prudent but also vital for the well-being of the American population.

Sincerely,

Brenda Staudenmaier, named plaintiff in FWW et al. v. EPA et al. (Case e 3:17-cv-02162-JSC)

Karen Spencer, Food & Water Watch member representative in FWW et al. v. EPA et al. 

att: PDF “Document Fraud CDC” 

      PDF "Series_52.56.61.03" Feltman 1956; Feltman & Kosel 1961; Gardner et al. 1952