Sunday, July 29, 2012

Waugh Rebuttal to Irish Expert Body on Fluorides and Health

The Department of Health in Ireland established the Irish Expert Body on Fluorides and Health which is funded by the taxpayer who provide €400,000 in public money annually for secretarial services for the organisation. The objective of the organisation is to advise the Department and Minister for Health and Children on all matters relating to water fluoridation to include risk management, adverse health effects and protection of public health. The administration and secretarial services for the Expert Body are provided by the Dental Health Foundation, whose members largely represent the Expert Body itself.

The review by the Expert Body of the report titled Human Toxicity, Environmental Impact and Legal Implication of Water fluoridation was undertaken by Dr. Joe Mullen, a public health dentist and representative of the Health Boards on the Expert Body. Dr. Mullen was previously a member of the Forum for Fluoridation who published a report on water fluoridation in 2002.  It should be noted that this report was severely criticised by a group of international scientists  for producing what they claimed was a blatantly false report in which they stated that the aim of the authors of the report was not to study the scientific evidence, but to find ways to get around it.

In comparison to the comprehensive review by Waugh examining human toxicity to silicofluoride and fluoride compounds, the report of which Dr Mullen’s was a senior contributor devoted only two pages to an independent analysis of specific health studies.

Dr. Mullen himself has publicly claimed that the effectiveness of water fluoridation is beyond dispute and that it is his duty and responsibility to support water fluoridation.  In the July 17th 2001 issue of the Irish Medical News Dr. Andrew Rynne, who testified before Dr. Mullen, expressed his concerns about the bias of the members of this Forum. Given their record to date it is to be expected that with such a long history of promoting fluoridation by members of the Expert Body, that such an organisation will not in any way undertake a fair and impartial assessment of a report which questions the very core of their beliefs.  This should be of some concern to the Government of Ireland, public representatives and taxpayers who fund this organisation and in particular to consumers in Ireland who are left with no choice but to drink fluoridated water or eat fluoridated food. Clearly the objective of such a body should be first and foremost to be independent and from this position of independence provide unbiased, impartial and truly independent advice. The evidence presented here will conclusively demonstrate in just a few examples how the Irish Expert Body on Fluorides and Health have distorted and misrepresented current scientific knowledge including Waugh’s report, to suit their beliefs in a manner that is more like propaganda than fact, in order to support the continuation of water fluoridation in Ireland at whatever cost.


It is perhaps worth noting at the beginning some of the alarming health statistics relevant for Ireland. Fluoride is now known to be a risk factor in developing many of the most serious health problems prevalent in the population of Ireland today. This includes neurological and cardiovascular disease, type ii diabetes, osteoporosis, hypercalcemia, hypothyroidism, dental fluorosis, skeletal muscular disorders and chronic pain. The incidence of these diseases in Ireland is far above the global average and continues to rise.

It has been medically documented that at a minimum 1% of the population may be hypersensitive to exposure to fluoride. Documented reactions under clinical observation include some of the following symptoms: gastrointestinal upsets, skin rashes, mouth sores, migraine like headaches, arthritic-like pains, dryness of the throat, excessive water consumption, frequent need to urinate, chronic fatigue, depression, nervousness and respiratory difficulties. This latter observation means that in Ireland, around 46.000 people at a minimum may evidence some sensitivity or ill-health in one way or another to drinking fluoridated water or consuming tainted foodstuffs contaminated with fluoridated water in the processing or cooking of foodstuffs. The ill-health may be representative in any of the conditions listed above.

The symptoms may include for example depression, which was one of the clinically observed reactions to exposure to fluoride. It should be noted that it is now estimated that in the region of 400,000 people in Ireland currently suffer from depression. These figures do not reflect however the enormous prevalence of general ill-health as documented for Ireland. According to the World Health Organisation the global average for neurological disease is 6.3 percent of the population, yet according to the Department of Health’s own statistics the prevalence of neurological disease in Ireland is now at 17.3 per cent of the population. That represents a truly astonishing 770,000 people who have been diagnosed with some form of neurological illness in Ireland.

Astonishingly  the health consequences of ingesting fluoride have never been examined in Ireland, this is truly remarkable given that Ireland is perhaps the most fluoridated country in the world. This fact itself is astounding, especially when you look at the health statistics for Ireland compared to any other country in the world. Apart from neurological illness Ireland also has twice the level of osteoporosis found in other countries including northern Ireland and the UK. Ireland also has one of the highest levels in the world of epilepsy, as well as certain type of cancers associated with the digestive tract, including cancer of the liver, kidney, stomach, bowel and intestinal cancer. On top of this the number of adults under 65 years of age with cardiovascular disease has increased dramatically (due in part to calcification of arteries to which Fluoride is now known to be a major contributor and risk factor). In addition Ireland has one of the highest levels of cardiovascular disease overall in the world. Add to this the fact that some 400,000 people in Ireland are now estimated to be diabetic and noting in particular that the WHO have identified such sensitive subgroups as having a lower margin of safety to fluoride than normal individuals.

This is extremely alarming given that the World Health Organisation (WHO) itself has warned that patients with kidney dysfunction may be particularly susceptible to fluoride toxicity in the body.
According to the World Health organisation  “It is known that persons suffering from certain forms of renal impairment have a lower margin of safety for the effects of fluoride than the average person.”.
Yet incomprehensively, the safety margins for high risk subgroups of the population is the same in Ireland as that for normal healthy individuals.

In addition to diabetics, it is now known that a further 300,000 people in Ireland over the age of 50 have osteoporosis. The recently published Irish Longitudinal Study of Ageing, by Trinity College Dublin, found that musculoskeletal pain involving bones, muscles, ligaments, tendons, and nerves was the most widely reported condition amongst the wider Irish population with a prevalence of 40%.  Remarkably, it is estimated that there are approximately 585,000 people in Ireland who suffer from chronic pain representing 36% of all households in Ireland. Musculoskeletal pain is one of the most easily recognisable symptoms of overexposure to fluoride brought on from excessive quantities of fluoride deposited in the skeleton and soft tissues.

This is particularly disturbing for future generations as it is now known that 1 in 3 children have dental fluorosis exhibiting a visible sign of chronic overexposure to fluoride in their bodies at an early stage in life. It is now known as reported by the European Food Safety Authority that 90% of fluoride in babies and infants is absorbed into bone. Even more worrying is the fact that all bottle fed infants in Ireland fed infant formula with fluoridated water exceed the maximum recommended daily tolerable intake for fluoride with long-term medical consequences for their health.

All of this has grave implications for public health, society and the economy as the younger generation ages in future decades.

What is particularly disturbing is that the appraisal by the Expert Body actually did was to totally ignore all of this information which clearly as a matter of urgency should be examined urgently by such an organisation and the HSE in general. In regard to international studies noted in the report by Waugh the Expert Body ignored completely the most recent study by Valdez-Jimenez, et al.  published in the Journal Neurologia, which reported that "the prolonged ingestion of fluoride may cause significant damage to health and particularly to the nervous system”. This study observed that chronic exposure to, and ingestion of, the synthetic fluoride chemicals added to water supplies can cause serious brain and neurological damage.
The fact that the Expert Body also chose to ignore the significant finding by Mehali et al. and Liu et al. which found that fluoride inhibits AdoHydrae and homocysteine metabolism, when it is now known that elevated homocysteine levels are linked to cardiovascular disease, atherosclerotic disease, congenital heart defects, Down Syndrome, neurodegenerative disorders including depression, schizophrenia, bi-polar disorder, epilepsy and behavioural disorders, as well as many other medical conditions, is equally disturbing.
This also applies to the most recent research by Li Y et al. published in the journal Nuclear Medicine Communications, which found that fluoride may be associated with an increased cardiovascular risk as it causes hardening of your arteries. The significance of this finding cannot be overstated given that it is the leading lethal disease in Ireland. A disease that has seen a fourfold increase in primary care for cardiovascular conditions in recent years.

What is perhaps most interesting overall however, is that the Expert Body have also declined to comment on the evidence presented in the Waugh report examining the known geographic disease hotspots in Ireland and the correlation of disease incidence for certain cancers, cardiovascular disease, hypothyroidism and neurological illness, with geographic areas where the fluoridated drinking water is very soft.
It is truly astonishing that the Expert Body failed to even mention these established facts in their review. The Irish Expert Body has not commented on any of these statistics, perhaps because many come from the HSE itself. So what exactly was noted in their report and what was the objective and aim of the ‘appraisal ‘by the Expert Body?

From the evidence presented in their appraisal of the Waugh report it is obvious that the review clearly had one task, which was to discredit the research and the author rather than objectively research any of the information provided. In their review the Expert Body have demonstrated their own ability to misread scientific research, which will be conclusively demonstrated with illustrated examples in this rebuttal. Overall the Expert Body have sought to undermine in a disturbingly inadequate & disproportionate response the quality of research undertaken and information presented by the Author of the report titled Human Toxicity, Environmental Impacts and Legal Implications of Water fluoridation, a report which represents the most comprehensive study and research on water fluoridation ever undertaken in the history of the State. A study that was undertaken voluntarily by the Author.

When one looks at the huge amount of scientific information presented in the review examining over 1200 peer reviewed studies many highlighting the associated risk of silicofluorides and fluoride to illhealth and environmental harm, it is no wonder that the Ministries for Health in every other European Country have followed the precautionary approach to preventative healthcare and avoided implementing or ended water fluoridation altogether. 

As noted in the report Human Toxicity, Environmental impact and Legal Implications of Water Fluoridation, It is clearly time for Irish citizens to have the same standard of care and legal protection as other European citizens. To this end, the Government must urgently adopt a precautionary approach to risk prevention and in doing so harmonise its public health and water management policies with those of all other EU Member States by ending its policy of water fluoridation immediately.


There are a number of examples where the Irish Expert Body  appear to have deliberately ignored published peer reviewed scientific findings or intentionally misrepresented scientific facts in general to support their stated position and biased beliefs in artificial fluoridation of drinking water. In doing so, as a publicly funded organisation they have induced the Government of Ireland to continue with a policy that is based on a representation of science that is clearly untrue. Whilst there are a number of specific examples that may be drawn upon to illustrate this behaviour, perhaps the most important examples are examined herein, which clearly demonstrates the mindset that exists within the Irish Expert Body on Fluoride and Health and which clearly demonstrates a lack of credibility that reflects poorly on the nature and quality of governance within the organisation.

Probably the most significant finding is that the Irish Expert Body have consistently and repeatedly stated that hydrofluorosilicic acid (HFSA) poses no risk to consumers based solely on their unqualified opinion that the chemical dissociates completely in drinking water into harmless fluoride ions and that consumers never come in contact with silicofluorides or any other potentially toxic metal silicofluoride complexes. For this sole reason, the Irish Expert Body have determined, in their wisdom, that there is no need for the Government of Ireland to undertake toxicological testing on the synthetic chemicals used for artificial fluoridation.  Such testing that would ensure the health and wellbeing of Irish citizens as well as protect its natural heritage and biodiversity.

The Information presented herein will show how the Irish Expert Body have deliberately misrepresented scientific facts to support their personal pro-fluoridation beliefs and in doing so have misplaced the trust placed in them to protect the health and welfare of Irish citizens.  Rather than ensuring that decisions are based on valid and scientifically sound facts I will demonstrate how they are instead based on a clear  misrepresentation of scientific facts.

Following publication of the report titled Human Toxicity, Environmental impact and Legal Implications of Water Fluoridation and subsequent to numerous written questions to the Minster for Health by elected public representatives, seeking clarification on various matters raised in the aforementioned report,  it has now come to light that the Irish Expert Body on Fluorides and Health have repeatedly and deliberately misinformed the Minister for Health & Children and the Irish public on critical matters relating to public safety. In doing so they have created a false and misleading impression of the safety of chemical compounds used for artificial fluoridation of drinking water in Ireland.

This is nothing short of deliberate media and government misinformation by a body that has been entrusted to protect public interest and raises serious questions regarding the motivation, professional judgement and abilities of the body to undertake its work in the interests of consumers and public health in a transparent and objective manner.

In response to parliamentary questions raised by Deputies Maureen O Sullivan T.D. and Catherine Murphy T.D as well as other Oireachtas members seeking evidence to demonstrate that the silicofluoride compounds used for water fluoridation have been tested for human safety and environmental toxicity, the Expert Body has falsely stated that when hydrofluorosilicic acid (HFSA) is added to water a complete reaction occurs producing only hydrogen ions, silica (sand) and fluoride ions to which consumers would only be exposed.

Furthermore the Expert Body falsely stated that since consumers do not come into contact with HFSA as water from the tap contains fluoride, not HFSA or fluorosilicates, there is no need for the State to demonstrate the safety of the chemical for human consumption. The Expert Body believe, incorrectly and in violation of a European Court ruling, that it is unnecessary for the State to undertake toxicological testing, as would be required legally for any such chemical compound variants in structure consumed by the public for the purpose of medical intervention.

The evidence to support such a position by the Expert Body was established in correspondence by The Irish Expert Body to Dr Kevin Kelleher, Asst National Director- ISD-Health Protection, Health Service Executive regarding their appraisal of the main themes of the report titled Human Toxicity, Environmental impact and Legal Implications of Water Fluoridation in which Dr Joe Mullen, Chair of the New and Emerging Issues Sub Committee of the Irish Expert Body on Fluorides alleged how the scientific evidence contained in the report, is in the opinion of the Irish Expert Body both unreliable and unscientific.

Given such grave allegations it is necessary to examine in detail the evidence provided by the Expert Body.

Prior to doing so it is however important to put the quality if the review into context, the review was undertaken by one individual. To counter balance Dr. Mullen’s opinion, Appendix 4 provides additional third party comments from International Academics in science, medicine and chemistry in support of the report.

Contradictory Statements of Fact: Part 1


The Expert Body claim that Waugh has misreported scientific literature by misquoting the York review and referencing the NRC study which they claim is not relevant to Ireland.
The Expert Body repeatedly claim that the York Review found water fluoridation to be safe and effective for all ages. This is an entirely false and untrue statement and a gross misrepresentation of scientific facts. Professor Sheldon the Chair of the NHS York Review published a public letter  in 2001 stating that the results of the review have been widely misrepresented by certain bodies in support of water fluoridation. Prof Sheldon stated categorically that:

“the review found water fluoridation to be significantly associated with high levels of dental fluorosis which was not characterised as "just a cosmetic issue" and “ the review did not show water fluoridation to be safe”.

It is clearly evident therefore that the Irish Expert Body have inaccurately interpreted and continue to deliberately misrepresent scientific facts to suit their own goals in support of water fluoridation.

In regard to the Expert Body allegation that the author misrepresented the NRC Report. The NRC report did not have the objective of evaluating water fluoridation per se and did not have the original intent of examining data published on safety and effectiveness, or lack thereof, for water fluoridation levels at the widely used concentration of 1 ppm compared to lower levels.

However, it is false to claim the analysis and data reviewed only apply to persons exposed to concentrations far higher than used in water fluoridation.
Much of the data in the NRC report published since 1993 were reviewed relevant to fluoridation, at 1 ppm, as controls to compare effects found at 2–4 ppm and higher.

It is also incorrect to claim that the NRC report only applied to natural fluoride in drinking water. Both natural and artificial fluoride in water were thoroughly investigated (NRC, 2006, pp. 14-15).

The committee intention was to mainly evaluate whether the EPA primary and secondary Maximum Contaminant Level interim assignments from 1984 were achieving their stated purpose in the U.S.  NRC concluded UNANIMOUSLY, that the MCL and SMCL must be lowered because current allowed levels are not protective of human health.

This is because of the widely and conclusively documented adverse pathology in those exposed to 2 and 4 ppm fluoride in water, compared to lower levels (NRC, 2006, p. 6). Vast data in the scientific literature, some reviewed in the NRC Report, prove that fluoride consumed long-term in humans at 1 ppm causes pathology.

In full agreement with the NRC committee consensus, the U.S. Health and Human Services recommended in January, 2012 that water fluoride levels not exceed 0.7 ppm fluoride as a temporary measure until official regulations can be established.  The limit for Ireland is 0.8ppm.

The motivation for this change is the glaring fact that as of 2004, 41% of U.S. children aged 12-15 (similar to Ireland) have permanent abnormal tooth fluorosis. Further information is kindly provided in Appendix 3 by Dr. Richard Sauerheber (B.A. Biology, Ph.D. Chemistry, University of California, San Diego, CA) in his personal response to the Irish Expert Body’s review of the Waugh Report.

Therefore it is clear once again that the Irish Expert Body have falsely accused the author of deliberately misrepresented scientific facts in this regard.

Contradictory Statements of Fact: Part 2
Misrepresentation of WHO

The Irish Expert Body on Fluorides and Health have stated in their appraisal of my report that the Author had made several misrepresentation of the views of the World Health Organisation.

It is important to note that there were in total over 1200 peer reviewed studies noted in the report. Despite the extensive reference by the author to WHO information in the Expert Body’s appraisal of my report they were only able to provide two examples to support such a claim, both of these examples are addressed in detail here and demonstrate clearly that the Author did not misrepresent the WHO as was alleged by the Expert Body.

The Expert Body make reference to the report by the World health Organisation (WHO) titled Calcium and Magnesium in Drinking Water; Public Health Significance dated 2009 which was noted extensively in the report.

The goal of this report as stated by the WHO in the preface was to:

 “elucidate the role of drinking-water as a contributor to total daily intake of calcium and magnesium and to determine whether there is a plausible case that drinking-water could be an important health factor, especially for cardiovascular disease mortality, at least for people whose dietary intake is deficient in either of those nutrients.”

The WHO continues in the preface of the report would that the goal was to:

 “provide background information on the scientific, nutritional and technological issues that were discussed by the meeting of experts and the symposium participants and that contributed to the report of the meeting of experts. Among the numerous issues addressed were the concentrations and distributions of minerals in drinking-water worldwide, nutritional requirements, biochemical and biomedical aspects of minerals in the body, technologies such as water softening and desalination that significantly alter the mineral composition of drinking-water, the desirability and feasibility of remineralization for stabilization and potential benefits, and the availability of information on water composition so that the public can make informed judgements with respect to their options for bottled water, softened water and naturally soft water.”

The Introduction to the Expert Consensus of the report  begins with the following statement:

“Both calcium and magnesium are essential to human health. Inadequate intake of either nutrient can impair health”.

The WHO goes on to say that:

“Individuals vary considerably in their needs for and consumption of these
Elements. Available evidence suggests that, because of food habits, many people in most countries fail to obtain from their diets the recommended intakes of one or both of these nutrients.”

The WHO continues  with:

 “while the concentrations of calcium and magnesium in drinking-water vary markedly from one supply to another” and note in particular how  “water treatment processes can affect mineral concentrations and, hence, the total intake of calcium and magnesium for some individuals”

In section 1.2 of the report the WHO reports the following:

“Over 99% of total body calcium is found in bones and teeth, where it functions as a key structural element. The remaining body calcium functions in metabolism, serving as a signal for vital physiological processes, including
vascular contraction, blood clotting, muscle contraction and nerve transmission. Inadequate intakes of calcium have been associated with increased risks of osteoporosis, nephrolithiasis (kidney stones), colorectal cancer, hypertension and stroke, coronary artery disease, insulin resistance and obesity.”

In  Section 1.3 of the report the WHO report the following regarding Magnesium.

“Magnesium is a cofactor for some 350 cellular enzymes, many of which are involved in energy metabolism. It is also involved in protein and nucleic acid synthesis and is needed for normal vascular tone and insulin sensitivity. Low magnesium levels are associated with endothelial dysfunction, increased vascular reactions, elevated circulating levels of Creactive protein and decreased insulin sensitivity. Low magnesium status has been implicated in hypertension, coronary heart disease, type 2 diabetes mellitus and metabolic syndrome.”

And Section 8.1 the WHO report that

“Calcium and magnesium play important roles in bone structure, muscle contraction, nerve impulse transmission, blood clotting and cell signalling.” And “It is clear that very large numbers of people consume levels of magnesium and calcium that are insufficient to support even the most conservative estimates of their physiological needs.”

The WHO continues in Section 3.8 of the report by reporting:

“In some geographical areas, the magnesium and calcium contents of drinking waters (including tap and bottled waters) are extremely low and may provide little supplementation towards a person’s daily requirement. Physiologically, waterborne minerals are in ionic form, which tend to be easily absorbed by the human gastrointestinal tract; thus, water can be an important source of mineral intake.”

The importance of these facts were examined in some detail in Waugh’s Report  (for the first time in Ireland) given that large geographic areas of the country and their respective populations who consume low calcium and magnesium waters such as found in Counties Cork, Kerry, Mayo and Donegal, where the calcium levels may be as low as <20mg/L in comparison to other geographic areas in the country such as in the Leinster, where the calcium level may be in excess of 300mg/l in drinking water. Representing a very significant difference in water chemistry that would influence fluoride bioavailability and toxicity.

The bioavailability of calcium and magnesium were addressed by the WHO in their report when they stated that:

 "The bioavailability of calcium from water is likely to be influenced by the same factors that affect calcium bioavailability from food, which has been reviewed. The presence of anions in certain waters can influence the bioavailability of calcium from either water or other sources in the diet."

Current scientific knowledge clearly accepts that Fluoride can and does influence the bioavailability of calcium in drinking water. The WHO report however did not however examine any of these matters in any detail. It is clear that nowhere in my report have any of these scientific facts been in any way misrepresented as alleged by the Expert Body on Fluoride and Health.

Nevertheless the Irish Expert Body allege that my reporting is unreliable and unscientific because Dr Mullen’s of the Expert Body claims I misrepresent the WHO in not stating the following section from their report:

"Treatment and stabilization practices should ensure that the overall process does not significantly reduce total intake of nutrients such as calcium, magnesium, fluoride and others below recommended values. Based on local circumstances, water suppliers and public health authorities may wish to further modify final drinking-water composition in light of overall mineral nutrition"

This statement was not included in my report as it is clearly incorrect and not scientifically accurate.

Calcium and Magnesium are essential nutrients however it must be noted that fluoride is not a nutrient. This has been clearly stated as a scientific fact by the European Food Safety Authority  or other bodies.

The issue of fluoride in drinking water was not discussed at all within the main WHO report; the only reference noted was in section 1.6 FLUORIDE IN REMINERALIZED DRINKING-WATER where the following text is provided.

“The recommended value for artificial fluoridation of water supplies is generally between 0.5 and 1.0 mg/l and depends upon the volume of drinking water consumed daily and the uptake of and exposure to fluoride from other sources. The WHO drinking-water guideline value for fluoride is 1.5 mg/l. Where dental caries risk is high or increasing, authorities may consider addition of fluoride to the demineralized public water supply to between 0.5 and 1.0 mg/l, but other factors should also be considered. In countries where dental health awareness in the public is very high and alternative vehicles for fluoride (e.g. fluoridated toothpaste) are widely available and widely used, a decision to not fluoridate the water would likely be of little consequence. On the other hand, in developing and developed countries where public dental health awareness in some population groups (e.g. lower income) might be much lower, drinking water containing fluoride at concentrations of 0.5–1.0 mg/l would be important for dental health.”

In examining this statement it is also important to note that the WHO have consistently and correctly stated in their Drinking Water Guidelines that

"in the assessment of the safety of a water supply with respect to the fluoride concentration, the total daily fluoride intake by the individual must be considered."

The WHO Guidelines for Drinking Water similarly recommend that:

 “when setting national standards for fluoride that it is particularly important to consider volume of water intake and intake of fluoride from other sources.”

Unfortunately as noted in the Authors main report these recommendation were not applied by the Health Authority or the Expert Body in Ireland when considering water fluoridation in Ireland.

Without following the WHO guidelines and recommendations the Expert Body continue to misrepresent the WHO recommendations by stating that the WHO have found fluoridation of drinking water to be safe in Ireland, without acknowledging that the WHO also clearly state that this cannot be found as fact unless the total daily fluoride intake by the individual is first considered.

The Irish Expert Body or HSE do not know what the total fluoride intake is of consumers in Ireland and have never undertaken a comprehensive dietary survey of foods, medication or beverages in this country.

The Expert Body have further failed to acknowledge the findings of both the WHO which found that subgroups of the population remain susceptible to the toxic effects of fluoride, even at relatively low concentrations.

What is at issue however, is that the Expert Body have alleged that by the Author referencing this document, with regard to the importance of calcium and magnesium in drinking water and its implications for human health, that he misrepresented the findings of the WHO. This WHO document was clearly not about fluoride at all and the only reference to fluoride was in regard to FLUORIDE IN REMINERALIZED DRINKING-WATER. Therefore it can be clearly seen that the allegation by the Expert Body is entirely false and misleading.

The WHO have elsewhere highlighted  that in countries where public dental awareness is very high and alternative vehicles for fluoride (e.g. fluoridated toothpaste) are widely available and widely used, public authorities do not fluoridate drinking water.

In Ireland fluoride intake is from BOTH water fluoridation and the use of fluoridated toothpaste, which were introduced into Ireland in the late 1960‘s after water fluoridation began.

What my report attempted to highlight was that through pursuing both public health policies, the HSE and Expert Body is placing a wide sector of society at risk from over-exposure to fluoride.

The Expert Body further alleged that I have misrepresented the WHO by referencing this statement.

“Where the risk for skeletal and dental fluorosis is high as a consequence of excess fluoride intake from drinking water, fluoride levels in drinking-water should be reduced to safe levels, or a lower - fluoride source used, especially for young children.”

This is in fact a direct quotation from the WHO report.  It does not in any way misrepresent what the WHO stated.

My contention was that given that dental fluorosis had now reached endemic proportions in Ireland with approximately forty percent of children now presenting with dental fluorosis and given that citizens in Ireland are exposed to fluoride systemically from fluoridated water in addition to fluoride based toothpastes and other dietary sources with high fluoride content such as teas, and the lack of available information on total fluoride dietary intakes  in Ireland that is was time to reconsider the issue of water fluoridation.

How these facts can be presented by the Expert Body as a deliberate misrepresentation of scientific facts is clearly not factual or correct and without any basis.

It is important to note however this report  also noted that

“Formula-fed infants are also a group at risk for excess intake of potentially toxic elements in drinking water.”

It is a scientific fact that silicofluorides and fluoride are toxic substances. Fluoride has been shown to be toxic, not only to the skeletal tissues, but also to the non-skeletal tissues such as the brain, liver, pancreas, endocrines and the kidney.  ,

Fluoride is a neurotoxin and it makes a serious adverse impact on the developing brain. ,  Fluoride exerts its toxic effects on the brain by multiple mechanisms; the primary phenomenon which is involved in the neurotoxicity of fluoride appears to be oxidative stress.

Importantly the report also stated  that

“Consumption of moderately hard water containing typical amounts of calcium and magnesium may provide an important incremental percentage of the daily dietary requirement. Inadequate total dietary intakes of calcium and magnesium are common worldwide, therefore, an incremental contribution from drinking water can be an important supplement to approach more ideal total daily intakes.  If low mineralized water were used for food and beverage production, reduced levels of Ca, Mg, and other essential elements would also occur in those products. Low intakes would occur not only because of the lower contribution of these minerals from water used in beverages, but also possibly because of higher losses of the minerals from food products (e.g., vegetables, cereals, potatoes or meat) into water during cooking”

The report attempted to address some of these important issues and the interaction and bioavailability of fluoride in soft water given the large numbers of consumers who are provided with very low calcium and magnesium drinking water in Ireland. All of these matters have been dealt with scientifically and accurately within the report by the Author and in no way misrepresent scientific facts. Furthermore it should be noted that peer reviewed sources have been provided to support any claims within the report.

It is important to note the following information from the WHO which the Irish Expert Body has declined to acknowledge regarding the safety of Fluoride for all sectors of society, including sensitive subgroups of the population.

The WHO have clearly stated  that

“Patients with kidney dysfunction may be particularly susceptible to fluoride toxicity.”

And further the WHO has stated  that:
“It is known that persons suffering from certain forms of renal impairment have a lower margin of safety for the effects of fluoride than the average person.”

Alarming there is no safety margin provided for the estimated 400,000 people in Ireland who suffer from diabetes within the population.

The rebuttal by Waugh continues with 51 pages of detailed objective scientifically referenced facts that completely destroy the credibility of the so called 'expert body on fluorides'. To read the remainder please you can download the full rebuttal at

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