SCIENTIFIC MISCONDUCT IN THE FLUORIDE IN DRINKING WATER REGULATION by Robert J. Carton, Ph.D., Vice-President, NFFE Local 2050
August 19, 1991
The fluoride in drinking water standard, or Recommended Maximum Contaminant Level (RMCL), published by EPA in the Federal Register on Nov. 14, 1985, is a classic case of political interference with science. The regulation is a fraudulent statement by the Federal Government that 4 milligrams per liter (mg/l) of fluoride in drinking water is safe with an adequate margin of safety. There is evidence that critical information in the scientific and technical support documents used to develop the standard was falsified by the Department of Health and Human Services and the Environmental Protection Agency to protect a long-standing public health policy. EPA professionals were never asked to conduct a thorough independent analysis of the fluoride literature. Instead, their credentials were used to give the appearance of scientific credibility. They were used to support the predetermined conclusion that 4 mg/l of fluoride in drinking water was safe.
Ethical misconduct by EPA management included the following: they ignored the requirements of the law to protect sensitive individuals such as children, diabetics or people with kidney impairment. Contrary to law, they made the criteria for considering health data so stringent that reasonable concerns for safety were eliminated. Data showing positive correlations between fluoride exposure and genetic effects in almost all laboratory tests were discounted. By selective use of data, they fit science to the desired outcome. They reported to the Administrator data demonstrating that dental fluorosis was an adverse health effect, but then hid this information from the pubic when the Administrator decided to call dental fluorosis a "cosmetic" effect. The National Institute for Dental Research had warned EPA that admitting dental fluorosis was an adverse health effect would be contrary to the long standing policy of the Public Health Service that fluoridation at 1 mg/l is totally safe. EPA had already admitted in the Federal Register that objectionable dental fluorosis can occur at levels as low as 0.7 mg/l.
EPA management based its standard on only one health effect: crippling skeletal fluorosis. In setting the safe level at 4 mg/l, however, they ignored data showing that healthy individuals were at risk of developing crippling skeletal fluorosis if these individuals happened to drink large quantities of water at the "safe" level of 4 mg/l. EPA's own data showed that some people drink as much as 5.5 liters/day. If these people ingested this amount of water containing 4 mg/l of fluoride, they would receive a daily dose of 22 mg. This exceeds the minimum dose necessary to cause crippling skeletal fluorosis ("20 mg/day for 20 years") according to EPA and the Public Health Service. This situation is made worse by the fact that there are additional sources of fluoride exposure, such as toothpaste, tea, etc. Even more unsettling is the fact that there is not sound scientific basis for a 20 mg/day threshold. The threshold is probably lower. there is evidence, ignored by EPA, that exposure to fluoride at 1 mg/l in drinking water over a long period of time may calcify ligaments and tendons causing arthritic pains (the earliest clinical signs of skeletal fluorosis).
EPA management also relied upon a report from the Surgeon General which they knew was false. This report claimed to represent the conclusions of an expert panel (on which EPA was an observer) when, in fact, the concerns of this panel was for the effects of fluoride in the bones of children, for its effects on the heart, for dental fluorosis, and for the overall lack of scientific data on the effects of fluoride in U.S. drinking water were deleted. There are indications that a number of important conclusions of the panel were altered without their knowledge or approval.
This instance of scientific fraud is one example of the unethical and unprofessional atmosphere existing at EPA. There are many others. The fluoride standard however is particularly deplorable because of the widespread complicity of a number of different Federal agencies at the very highest levels in distorting the assessment of fluoride's health effects, and thus threatening public health. The Union's involvement in this is not a matter of meddling in the rights of management to dictate policy. We are attempting to correct a clear cut example of management abuse of authority. We insist that professionals have a right to an ethical and professional workplace.
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