Refute of Anti Fluoridation Letter to Governors Association

By Steven D. Slott, DDS
Information Director
American Fluoridation Society


Fluoridation opponents seem fond of sending letters, riddled with misinformation, to various organizations, then publicly proclaiming that “Organization X has been put on notice”  by such and such fluoridation opponent.  It seems not to matter to them that, for obvious reasons,  these letters seem never to gain any traction with the organizations to which they are sent

The following is a response to a letter Attorney James Deal has posted on his antifluoridation website.  Deal is a fluoridation opponent who has apparent close ties to the New York antifluoridationist group, “FAN”.  He pops up in comment sections every now and then putting forth naive and erroneous information on fluoridation, and in the occasional live presentation to decision-makers in which he does the same.  True to form, this letter he has posted is riddled with misinformation.  My response is lengthy, due to the length of Deal’s letter and the amount of misinformation to be addressed point-by point.  Readers desiring to read the entire refutation can do so by clicking on the “Read More” button at the end of this excerpt.  

1.  Deal:  “In April 2015, the national Department of Health (DHHS) recommended a .7 ppm fluoridation level as ‘optimal,’ a reduction from a range of .7 ppm to 1.2 ppm”. My state of Washington has proposed to blindly  accepted that recommendation under WAC 246-290-460. Ostensibly, this reduction is to reduce the level of fluoride poisoning which per CDC records afflict 41% of children raised in communities with artificial water fluoridation.”


A.  The optimal level was reset from a range of 1.2 ppm to 0.7 ppm to simply the low end of that range, 0.7 ppm.  This was done due there no longer being a necessity for a range, and the greater availability of fluoride from many sources now, than when the optimal was originally set.   

The optimal level of fluoride in drinking water was originally set by the US Public Health Service in 1962, as a range of 0.7 ppm to 1.2 ppm. It was set as a range in order to allow for different amounts of water consumption between different climates. Recent scientific evidence has demonstrated that, due to air-conditioning and other modern amenities, there no longer exists any significant difference in water consumption due to climate differences. Thus, there is no longer a need for a range.

B.  There is no valid, peer-reviewed scientific evidence of  “poisoning” of anyone from optimal level fluoride.

C.  The CDC does not “record” poisoning of anyone from optimal level fluoride.  The “41%” noted by Deal  is in reference to a 2010 CDC study by Beltran-Aguilar in which 41% of adolescents they examined were found to have signs of dental fluorosis.. This 41% was composed of 37.1% with mild to very mild dental fluorosis, both of which are barely detectable, benign effects requiring no treatment, and which have no effect on cosmetics, form, function, or health of teeth….with the other 3.8% being those with moderate dental fluorosis, attributable to improper ingestion of toothpaste and/or exposure to abnormally high levels of environmental or well-water fluoride during the teeth forming years of 0-8.

—Prevalence and Severity of Dental Fluorosis in the United States, 1999-2004Eugenio D. Beltrán-Aguilar, D.M.D., M.S., Dr.P.H.; Laurie Barker, M.S.P.H.; and Bruce A. Dye, D.D.S., M.P.H.

2.  Deal:  “Because fluoridation is illegal – and for many other reasons – the new level of fluoridation which may be added to or brought up to is zero. No fluoride should ever be added to drinking water.  See the proposed Department of Health rule here:


A.  There is nothing illegal about the public health initiative of water fluoridation. 

B.  Fluoride has always existed in water.  Humans have been ingesting it in water since the beginning of time. Fluoridation simply adjusts that existing fluoride to the level where maximum dental decay prevention will occur, while strictly maintaining that level well below the threshold of adverse effects.  There is, therefore, no good reason not to add fluoride to drinking water for that purpose. 

C. There is nothing out of the ordinary about either the adopted rule, or supporting document.

3.  Deal:  “WAC 246-290-220 is a typical fluoridation enabling law. It says that fluoridation may be done in Washington only with fluoridation materials which “comply with” the National Sanitation Foundation NSF Rule 60 standard. NSF 60 requires 1) that some 20 toxicological studies be done on drinking water additives and 2) that a risk estimation test must be done. The toxicological studies are not being done. The risk estimation tests are not being done, but it is easy to calculate that the fluoridation materials would fail the risk estimation tests if they were done.”


From the NSF:

“Fluorosilicates do not require a toxicological assessment specifically for the fluorosilicate ion, because measurable levels of this ion do not exist in potable water at the fluoride concentrations and pH levels typical of public drinking water.1 There is currently no US EPA- derived MCL for silicate in drinking water. NSF established a SPAC for silicate at 16 mg/L based on the typical use level of sodium silicate in Table 5.1 of NSF/ANSI 60, which was based on the value from the Water Chemicals Codex.2 A fluorosilicate product, applied at its maximum use level, results in silicate drinking water levels that are substantially below the 16 mg/L SPAC established by NSF. For example, a sodium fluorosilicate product dosed at a concentration into drinking water that would provide the maximum concentration of fluoride currently permitted by the Standard (1.2mg/L) would only contribute 0.8 mg/L of silicate – or five percent of the SPAC allowed by NSF 60.”

—-NSF Fact sheet on Fluoridation Substances

NSF International

4.  Deal: “Fluoridation should stop until NSF or the suppliers produce their toxicological studies and they are approved by state boards of health and after proper risk estimation tests are done.”


As no Toxicological studies or risk estimation tests are required, or needed for fluoridation substances, there is no foundation for the demand that “fluoridation should stop”.

5.  Deal:  “Supporters of fluoridation say that NSF 60 as revised, has waived the requirement that toxicological studies be done. This is not so for the reasons given below. Even if NSF has waived waives the requirement to do toxicological studies, it has not waived the risk estimation tests.”


The NSF has not “waived” anything in association with baseless demands for toxicological studies.  It has clearly stated it policies and regulations regarding Standard 60 requirements and fluoridation substances.

6.  Deal:  “This is a partial list of the toxicological studies which the 2009 version of NSF 60 says must be done:”


There are no requirements for toxicological studies on fluoridation substances under Standard 60 of NSF International.

7.  Deal:  “According to the NSF 2008 Fluoride Fact Sheet, ‘The SPAC, as defined in NSF/ANSI Standard 60, is one tenth of the US EPA’s MCL’ ”.

‘Let’s do the math: The EPA MCL [maximum contaminant level] for fluoride is 4.0 ppm. Divide 4.0 ppm by the number of fluoride sources, which NSF assumes to be one. The result is 4.0 ppm. Then multiply 4.0 ppm by 10%. The result is .4 ppm. The current .7 ppm for fluoride is higher than .4 ppm. Thus, fluoridation at .7 ppm fails the risk estimation test. Therefore, fluoridation at .7 ppm does not ‘comply with’ NSF 60.”

“Even if the toxicological studies are not done, fluoridation materials still do not “comply with” NSF 60.”


To what Deal refers is the “NSF Fact Sheet on Fluoridation Products”

Deal fails to include the following from this  Fact Sheet:

“A lower or higher number of sources can be specified if data are available to warrant deviating from the default. It is required by Standard 60 that a comprehensive risk assessment be conducted if the US EPA has not established a Maximum Contaminant Level (MCL) for a chemical. Under these circumstances, the evaluation procedures contained in Annex A of NSF 60 are followed to derive the SPAC.”

“As noted above, NSF/ANSI Standard 60 requires, when available, that the US EPA MCL be used to determine the acceptable level for a chemical of interest. The EPA MCL for fluoride ion in water is 4 mg/L. The data-derived SPAC for fluoride ion in drinking water from NSF Certified treatment products is 1.2 mg/L, or less than one-third of the EPA’s MCL. Based on the SPAC for fluoride ion, the allowable maximum use levels (MUL) for NSF 60 Certified fluoridation products are:”

1. Fluorosilicic Acid: 6 mg/L

2. Sodium Fluorosilicate: 2 mg/L

3. Sodium Fluoride: 2.3 mg/L

“The US Department of Health and Human Services recently made the recommendation that the current optimal range of water fluoridation of 0.7 to 1.2 ppm (mg/L) be updated to an optimal dose of 0.7 ppm (mg/L) due to observations of increasing amounts of fluoride in food that is processed with fluoridated drinking water. Although this recommendation is still under review, some US states have elected to adopt this new optimal dose for fluoridation of community water supplies. At some point in the future, NSF/ANSI 60 may be revised to reflect this lower maximum use level. However, testing these chemicals at the higher use level of 1.2 ppm (as is currently done) provides a more conservative screening for contaminants in or associated with use of these products.”

—Fact Sheet on Fluoridation Substances

NSF International

The NSF deemed that the data on the fluoride ion warranted “deviating from the default”, the default being 10%.  The SPAC for the fluoride is 1.2 ppm, not 0.4 ppm as Deal erroneously claims.  Therefore, at 0.7 ppm, optimal fluoridation does indeed comply with Standard 60. 

8.  Deal:  “And we are not done yet with the risk estimation test. Notice that the denominator in the above formula: “estimated number of drinking water sources”. This should have been worded to say “estimated # of drinking water sources (or other sources of fluoride)”. The denominator would be 1.0 ppm in a district with no other sources of fluoride in the human diet.”


What Deal personally deems “should have been worded”, what he claims “the denominator would be”, and all of his unsubstantiated speculation and claims as to what he deems are sources of fluoride……are obviously irrelevant.

9.  Deal:  “The 4.0 ppm MCL is much too high. The NRC in its 2006 report stated clearly that the 4.0 ppm level was not protective and should be lowered. For this reason, fluoridation at .7 ppm is even more likely to fail the risk estimation test. Fluoride is of roughly the same toxicity as lead and arsenic, and the MCLs for them are 15 ppb and 10 ppb. The 4.0 ppm level was picked out of the air. There is  no scientific explanation whatsoever for why this level of fluoride poisoning was set. According to one report South Carolina had drinking water which contained naturally occurring fluoride at slightly under 4.0 ppm, and authorities there did not want to have to install expensive de-fluoridation equipment. So the MCL was set at 4.0 ppm.”


There is no documentation, or evidence that the “4.0 ppm  is much too high”.  The 2006 NRC Committee made the recommendation to lower the EPA primary MCL of fluoride from its current 4.0 ppm.  The only reasons cited for this recommendation were the risk of severe dental fluorosis, bone fracture, and skeletal fluorosis with chronic consumption of water with a fluoride level of 4.0 ppm or higher.  Skeletal fluorosis is so rare in the US as to be non-existent, and severe dental fluorosis does not occur attributable to water with a fluoride level of 2.0 ppm or lower.  Additionally, the NRC Committee was also charged to evaluate the adequacy of the EPA secondary MCL of 2.0 ppm to be adequately protective against adverse effects.  This Committee made no recommendation to lower the secondary MCL down from 2.0 ppm.  Water is fluoridated at 0.7 ppm, one third the  level which the 2006 NRC Committee made no recommendation to lower. 

In March of 2013, Dr. John Doull, one of the most highly respected toxicologists in the country, and Chair of the 2006 NRC Committee on Fluoride in Drinking Water, made the following statement:

“I do not believe there is any valid, scientific reason for fearing adverse health conditions from the consumption of water fluoridated at the optimal level”

—John Doull, MD, PhD, Chair of the National Academy of Sciences, National Research Council 2006 Committee Report on Fluoride in Drinking Water

B.  The claim that “fluoride is more toxic than lead and just slightly less toxic than arsenic” is frequently put forth by antifluoridationists as an argument against water fluoridation. This claim is based upon toxicity ratings of industrial commercial products to which humans may be exposed in very large quantities at a given time. In actuality, when one views such toxicity charts it can be seen that caffeine is also “more toxic than lead and slightly less than arsenic”, and that common table salt is equally as toxic as lead. Attempting to associate the minuscule amount of fluoride in optimally fluoridated water with the toxicity of arsenic and lead is entirely misleading, and yet one more example of the manner in which fluoridation opponents dishonestly utilize out-of-context and/or incomplete information to induce unwarranted fear about this public health initiative.

According to Gosselin, et al., both fluoride and caffeine have a toxicity rating of 4 (Very Toxic). Substances at this classification are toxic to humans at the level of 50-500mg/kg. As 1 kg = 2.2 pounds, a 200 pound individual would weigh 90.7 kg. Therefore, the range of toxicity for a substance at the industrial toxicity level of 4 would be 4,535 mg – 45,350 mg. One would have to ingest over 6,000 liters of optimally fluoridated water in a short period of time to even reach the threshold of toxicity of fluoride. As can plainly be seen, the level of daily fluoride intake is so minuscule that a comparison of such toxicity ratings is entirely irrelevant to optimally fluoridated water.

For this reason, the EPA sets maximum allowable levels of substances in drinking water based on the observed level at which adverse effects are known to occur, not on misleading industrial toxicity ratings.

—Gosselin, et al. (1984) Clinical Toxicology of Commercial Products

C.  Deal’s claim that the EPA MCLs are “picked out of the air” is, of course, ludicrous.

“After reviewing health effects data, EPA sets a maximum contaminant level goal (MCLG).  The MCLG is the maximum level of a contaminant in drinking water at which no known or anticipated adverse effect on the health of persons would occur, allowing an adequate margin of safety.

MCLGs are non-enforceable public health goals. MCLGs consider only public health and not the limits of detection and treatment technology effectiveness. Therefore, they sometimes are set at levels which water systems cannot meet because of technological limitations.”

—-How EPA Regulates Drinking Water Contaminants

US Environmental Protection Agency

The MCLG for fluoride was set at 4.0 ppm because that was the level below which no known adverse effects on the health of humans would occur.  It was not set at 4.0 ppm  for  the anecdotal reason Deal puts forth.

If Deal has valid, peer-reviewed scientific evidence of any adverse effects of fluoride at the optimal  of 0.7 ppm, he needs to produce it, properly cited from original sources.  As none exists, he will be hard pressed to do so.

10.  Deal:  “Likewise, the 10% multiplier used in the NSF risk estimation test was picked out of the air. There is no scientific basis for presuming that adding a toxin at an arbitrary 10% of an arbitrary 4.0 ppm MCL is harmless.”


There is nothing “arbitrary” about the regulatory level (MCL).  It is that level below which no adverse effects are known to occur.  In order to provide an adequate allowance for multiple  sources of ingestion of a contaminant, the EPA only allows 10% of that regulatory level of a contaminant in drinking water.  A ten fold margin is entirely acceptable and protective.  Given that, in the 71 year history of fluoridation with  hundreds of millions having ingested optimally fluoridated water during that time, there have been no proven adverse effects, this 10% margin has proven to be entirely adequate for fluoridation substances. 

11.  Deal:  “The current text of A.2.3 includes a blanket waiver for doing toxicological studies for all additives or contaminants for which there is an EPA MCL. However, in the original 1988 edition of NSF 60 there was no such blanket waiver. It was in 1988 that the EPA was putting NSF into the fluoride certifying business.”


The EPA determines the MCL, not the NSF.  The NSF simply requires independent testing for those contaminants for which the EPA has not established a maximum safety level.  It is ironic that antifluoridationists  erroneously claim the need for “pharmaceutical grade” fluoride for fluoridation.  Such fluoride is under the jurisdiction of the FDA, which does not mandate independent testing for contaminants.  It relies on information supplied by the manufacturer of the substances. So while those such as Deal make unsubstantiated claims about the competence of an accredited, independent testing organization utilized by the EPA, they are perfectly fine with manufacturers doing such testing on their own “pharmaceutical grade” fluoride.

12.  Deal’s claims about previous guidelines and his personal opinions about the meaning of this word, or that, are simply the same sort of irrelevant conspiracy nonsense that antifluoridationists have been attempting to use against fluoridation since the very beginning of the initiative 71 years ago.  It seems that Deal advocates:

A.  Reliance on manufacturer testing of the safety their own products in lieu of independent testing by qualified testing entities, and

B.  No review, update, and revision as necessary  of policies and regulations by government agencies.

13. Deal:  “Many think that because the SDWA [Safe Drinking Water Act] has a 4 ppm maximum contaminant level (MCL) for fluoride, that the SDWA authorizes the insertion of fluoride up to a 4 ppm maximum. This is not so. The SDWA requires removal of fluoride if it exceeds 4 ppm. It does not authorize adding fluoride up to the 4 ppm level or adding any fluoride at all.”


It is unclear as to whom is this “many” Deal to whom Deal refers, but the SWDA did not establish a MCL for fluoride, or any other substance, and it does not require “removal of fluoride if it exceeds 4 ppm”.  The SWDA authorizes the EPA to set standards and policies in regard to drinking water and gives it the authority to enforce these policies and regulations.

“The Act authorizes EPA to establish minimum standards to protect tap water and requires all owners or operators of public water systems to comply with these primary (health-related) standards. The 1996 amendments to SDWA require that EPA consider a detailed risk and cost assessment, and best available peer-reviewed science, when developing these standards. State governments, which can be approved to implement these rules for EPA, also encourage attainment of secondary standards (nuisance-related). Under the Act, EPA also establishes minimum standards for state programs to protect underground sources of drinking water from endangerment by underground injection of fluids.”

—Summary of the Safe Drinking Water Act

US Environmental Protection Agency

14.  Deal:  “It is important to make the distinction that EPA’s standards are guidelines for restricting the amount of naturally occurring fluoride in drinking water; they are not recommendations about the practice of adding fluoride to public drinking-water systems.”


This is true.  So what?  The only restriction on the amount of fluoride in drinking water are  the EPA primary MCL of 4.0 ppm, which is enforceable by law, and the EPA  recommended secondary MCL of 2.0 ppm, which is not enforceable by law.

This does not prohibit fluoridation of water at 0.7 ppm.  As long as the fluoride level does not exceed 4.0 ppm, it is in compliance with EPA regulations.

What Deal fails to understand is that fluoridated systems strictly maintain the level of fluoride in their drinking water at the optimal level of 0.7 ppm.  Non-fluoridated systems do not do so and are bound only by the EPA maximum of 4.0 ppm.  Thus in advocating against fluoridation, Deal is arguing for less control over the level of fluoride in drinking water, not more. 

15.  Deal:  “Arguably the type of fluoride referred to in the EPA MCL and MCLG list is “naturally occurring fluoride”, not man-made fluorosilicic acid intentionally added. This is what the National Research Council said, as noted above. See NRC 2006, Page 13:”

“It is important to make the distinction that EPA’s standards are guidelines for restricting the amount of naturally occurring fluoride in drinking water….”

“There is a big difference between naturally occurring calcium fluoride and the man-made forms. Calcium fluoride is the naturally occurring fluoride found most frequently. Calcium binds to fluoride and reduces its reactivity. Calcium fluoride is not as immediately poisonous as is fluorosilicic acid. The LD 50 for calcium fluoride is 3,750 mg/kg; for fluorosilicic acid it is 125 mg/kg.”


Fluoride is the anion of the naturally occurring element, fluorine.  An anion is a negatively charged atom.  As groundwater flows over rocks, it picks up fluoride ions which have been leached from the compound calcium fluoride and fluorosilicate compounds in those rocks.  These fluoride ions are to what is commonly referred as being “naturally occurring fluoride”, and are to what the 2006 NRC referred when discussing “naturally occurring fluoride”.  These fluoride ions are identical to those added through fluoridation.  The EPA regulations are not concerned with the source of fluoride ions in water, simply that their level does not exceed 4.0 ppm. 

Fluorosilic acid is just a vehicle which delivers fluoride ions into water.  Once added to drinking water, due to the pH of that water, the FSA is immediately and completely hydrolyzed (dissociated) into fluoride ions, identical to those “naturally occurring” fluoride ions, and trace contaminants in barely detectable amounts far below EPA mandated maximum allowable levels of safety.  After this point, FSA no longer exists in that water.  It does not reach the tap.  It is therefore not ingested.  Calcium fluoride does not exist in drinking water. There is therefore of no relevance as to what is the LD 50 for calcium fluoride and fluorosilic acid.  Neither are ingested in fluoridated water. 

—-Reexamination of Hexafluorosilicate Hydrolysis By F NMR and pH Measurement

William F. Finney, Erin Wilson, Andrew Callender, Michael D. Morris, and Larry W. Beck

Environmental Science and Technology/ Vol 40, No. 8, 2006

16.  Deal:  11) “Section A.3.2 is poorly worded, even nonsensical. A.3.2 says:”

  “If a substance is regulated under the USEPA’s National Primary Drinking Water Regulations and USEPA has finalized a Maximum Contaminant Level (MCL) or other means of regulation such as a treatment technique (see Annex A, Section A.2.18) no additional collection of toxicological data shall be required prior to performance of the risk estimation.”

“What the amateurs who wrote A.3.2 were trying to say is:

“If a substance is regulated under the USEPA’s National Primary Drinking Water Regulations and USEPA has finalized a Maximum Contaminant Level (MCL) or other means of regulation such as a treatment technique (see Annex A, Section A.2.18), and if the MCL does not exceed 10% of the MCL set by the USEPA, no additional collection of toxicological data shall be required ….


Obviously, Deal is the “amateur” here, as evidenced by his erroneous  claim as to what regulators “were trying to say.”   The statement by the regulators is perfectly clear.  It is Deal’s lack of understanding of plain English and his garbled “interpretation” of the statement by the regulators, that are totally nonsensical. 

17.  Deal’s convoluted claims about Standard 60, toxicological tests, etc. are all predicated on his misinterpretation  of Standard 60.

18.  Deal:  “With water now fluoridated at .7 ppm instead of 1.0 ppm, the effective level of arsenic added by the fluoridation materials would be 1.66 ppb x .7 = 1.16 ppb, which is still more than 10% of the 10 ppb MCL. Arsenic from fluorosilicic acid added to water at .7 ppm fails the risk estimation test.”


Drinking water quality standards begin with water at the tap.  Under EPA mandated stringent testing of fluoridated water at the tap, utilizing ten times the normal single use amount of  fluoridation substance, the maximum level arsenic detected is 0.6 ppb, or but 60% of the Standard 60 maximum allowable amount.  The average amount of arsenic detected is only 0.17 ppb.  In addition, any arsenic at all was detected in less than 50% of the random samples. 

A complete list of the contents of fluoridated water at the tap, including precise amounts of any detected contaminants, may be found on the “Fact Sheet on Fluoridation Substances” on the website of the National Sanitary Foundation. 

All of Deal’s “facts” about arsenic are irrelevant.  The level of arsenic in fluoridated water is so minuscule, so far below EPA mandated maximum levels of safety, that it is of absolutely no concern, whatsoever. 

19.  Deal:  “However, the MCLG, maximum contaminant level lead, is zero. If your goal is zero, you do not get closer to that goal by adding any amount of lead. In effect, the MCLG of zero prohibits fluoridation because the fluoridation materials contain arsenic.”


The MCLG is an ideal set by the EPA.  As a matter of policy, the EPA sets an MCLG at zero for any contaminant which may be carcinogenic, regardless the amount of that substance it takes to be carcinogenic.  The MCL is that level deemed safe which the EPA sets as close to the MCLG as possible, and which can actually be attained utilizing current technology.

The EPA MCL for lead is 15 parts per billion.  Thus the EPA maximum allowable level of lead in drinking water under Standard 60 is 1.5 ppb.  Under EPA mandated stringent testing of fluoridated water at the tap, utilizing ten times the normal single use amount of  fluoridation substance, the maximum level of lead  detected is 0.088 ppb, or but 6% of the Standard 60 maximum allowable amount.  The average amount of lead detected is only 0.037 ppb.  In addition, any lead at all was detected in less than 1% of the random samples. 

Obviously, lead is of no concern in fluoridated water at the tap.

—-NSF Fact Sheet on Fluoridation Substances

NSF International

20.  Deal:  “But our consideration of lead is not over. Fluorosilicic acid not only contains lead, it leaches lead from plumbing.”


The theory of lead leaching by fluoridation substances has no merit.  It was debunked by Urbansky/Schock in 2000 and by Macek in 2006. 

A.  “Overall we conclude that no credible evidence exists to show that water fluoridation has any quantifiable effects on the solubility, bioavailability, bioaccumulation or reactivity of lead (0) or lead (II) compounds.  The governing factots are the concentrations of a number of other species such as (bi)carbonate, hydroxide, or chloride, whose effects far exceed those of fluoride or fluorosilicates under drinking water conditions. “

—-Can Fluoridation Affect Lead (II) In Potable Water? Hexafluorosilicate and Fluoride Equilibria In Aqueous Solution

Urbansky, E.T., Schocks, M.R.Intern. J . Environ. Studies, 2000, Voi. 57. pp. 597-637

B.  “Our analysis does not offer support for the hypothesis that silicofluorides in community water systems increase PbB concentrations in children. On the other hand, given the limitations of our data, our analyses cannot refute a possible link between water fluoridation method and lead uptake in children, particularly among those who live in older dwellings. Although other ecologic studies might allow another opportunity to test the relation between water fluoridation method and PbB concentrations in U.S. children, such analyses are likely to have similar limitations. Ultimately, the hypothesis that one or more fluoride compounds is associated with enhanced lead leaching or increased lead absorption is best addressed via systematic study of lead concentrations in drinking water, experimental chemical investigations, and studies of animal toxicology. Efforts to decrease exposure to lead among children by targeting prevention efforts at high-risk communities and/or populations as well as efforts to prevent dental caries via the use of fluoridated drinking water should continue unless a causal impact of certain fluoridation methods on PbB concentration is demonstrated by additional research.”

—-Blood Lead Concentrations in Children and Method of Water Fluoridation in the United States, 1988-1994

Environ Health Perspec. 2006 January; 114 (1): 130-134

Mark D. Macek, Thomas D. Matte, Thomas Sinks, and Delores M. Malvitz


21.  Deal:  “See Dr. Richard Sauerheber explanation of the process whereby fluorosilicic acid breaks down into silicic acid and then leaches lead”


Sauerheber is Deal’s “Scientific Consultant” in his class action endeavors.  Sauerheber has no better understanding of fluoridation and fluoridation substances than does Deal.  They both put out the same erroneous information.

Sauerheber’s open access paper was completely debunked by noted researcher, Dr. Gary Whitford.  This may be found on the website “fluoridescience” under the “Resources” tab.

22.  Deal:  “We drink and cook with maybe one percent of the water that flows through our homes. The other 99 percent goes down the shower, sink, and commode or out of the washing machine and then to the treatment facility. The treatment facility is unable to filter out the tiny fluoride ion, and so fluoride flows into our rivers. Four cities dump their fluoridated sewer water into the Snohomish River: Monroe, Snohomish, Everett, and Marysville. The fluoride content of sewer effluent is high enough to repel salmon and cause salmon runs to crash, as has happened in the Snohomish, Columbiaand Sacramento Rivers.”


Peer-Reviewed science has demonstrated there to be no adverse effect on the environment from optimally fluoridated water.

“Fluoridated water losses during use, dilution of sewage by rain and groundwater infiltrate, fluoride removal during secondary sewage treatment, and diffusion dynamics at effluent outfall combine to eliminate fluoridation related environmental effects. In a literature review, Osterman found no instance of municipal water fluoridation causing recommended environmental concentrations to be exceeded, although excesses occurred in several cases of severe industrial water pollution not related to water fluoridation. Osterman found that overall river fluoride con centrations theoretically would be raised by 0.001-0.002 mg/l, a value not measurable by current analytic techniques. All resulting concentrations would be well below those recommended for environmental safety.”

—Water Fluoridation and the Environment: Current Perspective in the United States

Howard F. Pollick, BDS, MPH

Int J Occup Environ Health 2004;10:343–350

—–Osterman JW. Evaluating the impact of municipal water fluoridation on the aquatic environment. Am J Public Health. 1990; 80:1230-5.



The CDC has never made any such “admission”.

24.  Deal:  “Why should you believe me instead of guys in white coats?”


We should not believe Deal instead of “guys in white coats” because:

A.   ……as I have clearly demonstrated, Deal is completely uninformed on this issue.

B.  ……..Deal hasn’t the education, training, experience, or knowledge to provide credible opinions, or make credible recommendations on this healthcare issue.

C. ……….”guys in white coats” do have the education, training, experience  and knowledge to provide credible opinions and recommendations on this healthcare issue.

25.  Deal:  “that fluoridation reduces caries only 18% to 25% which is only one or two cavities per lifetime. (Other evidence says it does not reduces caries at all);”


Deal’s attempt to trivialize dental disease is a common tactic of antifluoridationists who fail to understand the overwhelming magnitude we have with untreated dental decay in this country.

A.  In 2007 a 12 year old Maryland child died as a direct result of but one untreated cavity in one tooth.

B.  One untreated cavity can lead to a lifetime of extreme pain, debilitation, black discoloration and loss of teeth, development of serious medical conditions, and life-threatening infection. 

Deal’s unsubstantiated claim about “other evidence” is meaningless.  Countless peer-reviewed scientific studies clearly demonstrate the effectiveness of fluoridation in the prevention of dental decay in entire populations.  I will gladly provide him with as many as he would reasonably care to read.

26.  Deal:  “that 41% of adolescents suffer from some degree of dental fluorosis, with around 12% of adolescents suffering from mild, moderate, and severe fluorosis, which is noticeable, embarrassing and ugly; and”


The “41%” Deal notes is in reference to a 2010 CDC study by Beltran-Aguilar in which 41% of adolescents they examined were found to have signs of dental fluorosis.  This 41% was composed of 37.1% with mild to very mild dental fluorosis, both of which are barely detectable, benign effects requiring no treatment, and which have no effect on cosmetics, form, function, or health of teeth….with the other 3.8% being those with moderate dental fluorosis, attributable to improper ingestion of toothpaste and/or exposure to abnormally high levels of environmental or well-water fluoride during the teeth forming years of 0-8.

—–Prevalence and Severity of Dental Fluorosis in the United States, 1999-2004

Eugenio D. Beltrán-Aguilar, D.M.D., M.S., Dr.P.H.; Laurie Barker, M.S.P.H.; and Bruce A. Dye, D.D.S., M.P.H. 

Deal’s hypocrisy is clearly evident by his  attempt to induce unwarranted fear about benign, barely detectable mild dental fluorosis while he ignores the lifetimes of extreme pain, debilitation, development of serious medical conditions, loss of teeth, and life-threatening infection directly resultant of untreated dental decay which can be, and is, prevented by water fluoridation.

27.  Deal:  “that ‘fluoride prevents dental caries predominately after eruption of the tooth into the mouth, and its actions primarily are topical for both adults and children’ “.


The effects of fluoride are both topical and systemic.  The systemic effects are demonstrated in the mild to very mild dental fluorosis which is the only dental fluorosis in any manner associated with optimally fluoridated water.  Mild to very mild dental fluorosis is a barely detectable effect which causes no adverse effect on cosmetics, form, function, or health of teeth.  As Kumar, et al. have demonstrated mildly fluorosed teeth to be more decay resistant, many consider this effect to not even be undesirable, much less adverse.  Dental fluorosis can only occur systemically. 

—-The Association Between Enamel Fluorosis and Dental Caries in U.S. Schoolchildren Hiroko Iida, DDS, MPH and Jayanth V. Kumar, DDS, MPH

J Am Dent Assoc 2009;140;855-862

Additionally, saliva with fluoride incorporated into it provides a constant bathing of the teeth in a low concentration of fluoride all throughout the day, a very effective means of dental decay prevention. Incorporation of fluoride into saliva occurs systemically.

From the CDC:

“Fluoride works to control early dental caries in several ways. Fluoride concentrated in plaque and saliva inhibits the demineralization of sound enamel and enhances the remineralization (i.e., recovery) of demineralized enamel. As cariogenic bacteria metabolize carbohydrates and produce acid, fluoride is released from dental plaque in response to lowered pH at the tooth-plaque interface. The released fluoride and the fluoride present in saliva are then taken up, along with calcium and phosphate, by de-mineralized enamel to establish an improved enamel crystal structure. This improved structure is more acid resistant and contains more fluoride and less carbonate.. Fluoride is more readily taken up by demineralized enamel than by sound enamel.. Cycles of demineralization and remineralization continue throughout the lifetime of the tooth.”

——–Recommendations for Using Fluoride to Prevent and Control Dental Caries in the United States

United States Centers for Disease Control

Recommendations and Reports

August 17, 2001/50(RR14);1-42

 Additionally, in a 2014 study Cho, et al. found:

“Conclusions: While 6-year-old children who had not ingested fluoridated water showed higher dft in theWF-ceased area than in the non-WF area, 11-year-old children in theWF-ceased area who had ingested fluoridated water for approximately 4 years after birth showed significantly lower DMFT than those in the non-WF area. This suggests that the systemic effect of fluoride intake through water fluoridation could be important for the prevention of

dental caries.”

—–Systemic effect of water fluoridation on dental caries prevalence

Cho HJ, Jin BH, Park DY, Jung SH, Lee HS, Paik DI, Bae KH.

Community Dent Oral Epidemiol 2014; 42: 341–348.


“Evidence also supports fluoride’s systemic mechanism of caries inhibition in pit and fissure surfaces of permanent first molars when it is incorporated into these teeth pre-eruptively.”

—Buzalaf MAR (ed): Fluoride and the Oral Environment. Monogr Oral Sci. Basel, Karger, 2011, vol 22, pp 97–114

28.  Deal:  “Fetuses are highly sensitive to fluoride and its co-contaminants because their cells are rapidly dividing. Fluoride and its co-contaminants pass the placental barrier and lower IQ. The FDA banned prenatal supplementscontaining fluoride. Babies too are highly sensitive. Their cells too are still dividing, and they drink four times as much fluids per their body weight as do adults. Babies’ kidneys are not mature and excrete only 20% of fluoride consumed.”


Deal presents no valid, peer-reviewed scientific to support his claims here, in regard to optimally fluoridated water.  Why?  Because none exists.

29.  Deal: ” CDC, ADA, AMA, and the surgeon general have advised that if formula is mixed using fluoridated water, fluorosis will result, an admission that other harms are being done.”


What these entities have advised is that due to the existing fluoride content of powdered infant formula, the use of optimally fluoridated water to reconstitute it risks mild to very mild dental  fluorosis in developing teeth of the infant.  Mild to very mild dental fluorosis is a barely detectable effect which has no adverse effect on cosmetics, form, function, or health of teeth.  As peer-reviewed science has demonstrated mildly fluorosed teeth to be more decay resistant, this effect is not  even considered undesirable, much less adverse. 

For those parents concerned with even mild to very mild dental fluorosis, in spite of the decay resistance benefit, the ADA and the CDC have suggested they use non-fluoridated bottled water to reconstitute powdered formula, or simply use pre-mixed formula, most, if not all, of which is made with low fluoride content water. 

30.  Deal:  ” Fluoride builds up in kidneys, reducing ability to excrete. Water used for dialysis must be fluoride free. After drinking fluoridated water for years, bone will contain 3,000 to 12,000 ppm fluoride, depending on water hardness and diet. At 3,000 ppm bones weaken and become brittle. Fractured pelvises are twice as common in fluoridated areas. All fluorides affects bones, joints, and tendons and exacerbate arthritis.”


A.  There is no valid, peer-reviewed scientific evidence of any adverse effect of optimally fluoridated water on the kidneys, as evidenced by Deal’s inability to provide any such evidence.

“Because the kidneys are constantly exposed to various fluoride concentrations, any health effects caused by fluoride would likely manifest themselves in kidney cells. However, several large community-based studies of people with long-term exposure to drinking water with fluoride concentrations up to 8 ppm have failed to show an increase in kidney disease.”

“People exposed to optimally fluoridated water will consume 1.5mg of fluoride per day. Available studies found no difference in kidney function between people drinking optimally fluoridated and non-fluoridated water. There is discrepant information in studies relating to the potential negative effects of consuming water with greater than 2.0ppm of fluoride.”

“Available literature indicated that impaired kidney function results in changes in fluoride retention and distribution in the body. People with kidney impairment showed a decreased urine fluoride and increased serum and bone fluoride correlated with degree of impairment; however, there was no consistent evidence that the retention of fluoride in people with stage four or stage five CKD, consuming optimally fluoridated water, resulted in negative health consequences.”

—–Ludlow M, Luxton G, Mathew T. Effects of fluoridation of community water supplies

for people with chronic kidney disease. Nephrol Dial Transplant 2007; 22:2763-2767 

B.  There is no valid, peer-reviewed scientific evidence of any adverse effects on bones from optimal level fluoride. 

C. In regard to Deal’s unsubstantiated claim about “fractured pelvises”:

“Overall, we found no association between chronic fluoride exposure and the occurrence of hip fracture. The risk estimates did not change in analyses restricted to only low-trauma osteoporotic hip fractures. Chronic fluoride exposure from drinking water does not seem to have any important effects on the risk of hip fracture, in the investigated exposure range.”

—–Estimated Drinking Water Fluoride Exposure and Risk of Hip Fracture

A Cohort Study

P. Näsman, J. Ekstrand, F. Granath, A. Ekbom, C.M. Fored

Journal of Dental Research

2013 Nov;92(11):1029-34.

D.  There is no valid, peer-reviewed scientific evidence that optimal level fluoride “exacerbates arthritis”.

31.   Deal:  “Now that I have completed my analysis of fluoridation and NSF 60, I should add that EPA should never have privatized the regulation of fluoridation by passing its own responsibility off to a trade association where the industries regulated by NSF sit on the NSF board. And the FDA should be enraged that NSF has usurped is role by approving a drug to be safe for human consumption when only the FDA is authorized to do that.”


A.  As I have clearly demonstrated, Deal’s “analysis of fluoridation and Standard 60” is completely erroneous, and indicative of a profound lack of understanding of fluoridation, the science of fluoridation, and the laws applicable to fluoridation.

B.  NSF International is not a “trade organization”.  It is  an independent accredited organization, which  develops standards, tests and certified products and systems. It provide auditing, education and risk management solutions for public health and the environment.

—NSF International

About NSF

C.  The NSF has not “usurped” the role of anyone. 

The EPA and the FDA entered into a mutual  agreement that, under the SDWA,  the EPA has complete jurisdiction and regulatory authority over public drinking water supplies.

“On June 22, 1979, the U.S. Food and Drug Administration (FDA) and the EPA entered into a Memorandum of Understanding (MOU) to clarify their roles and responsibilities in water quality assurance. The stated purpose of the MOU is to ‘avoid the possibility of overlapping jurisdiction between the EPA and FDA with respect to control of drinking water additives. The two agencies agreed that the SDWA’s passage in 1974 implicitly repealed FDA’s jurisdiction over drinking water as a ‘food’ under the Federal Food, Drug and Cosmetic Act (FFDCA). Under the agreement, EPA enjoys exclusive regulatory authority over drinking water served by public water supplies, including any additives in such water. FDA retains jurisdiction over bottled drinking water under Section 410 of the FFDCA and over water (and substances in water) used in food or food processing once it enters the food processing establishment.’ “

—ADA Fluoridation Facts.

American Dental Association. 2005

D.  There are no drugs involved in water fluoridation.  There are simply fluoride ions, identical to those which have always existed in water.  To suddenly proclaim these ions to be a drug, as antifluoridationists constantly attempt to do, is obviously ludicrous.  No US court of last resort has ever affirmed the “forced medication” argument which has been repeatedly attempted by antifluoridationists through the decades.

32.  Deal:  “Add to this the studies which indicate that there are much more effective ways to reduce and even eliminate tooth decay than fluoridation, and the issue becomes even clearer. The fixation on fluoridation distracts the dental profession from teaching methods which really do reduce caries and do so without any harm.”


A.  Deal provides no valid studies which  “indicate that there are much more effective ways to reduce and even eliminate tooth decay than fluoridation”. Why?   Because at less than $1 per person, per year fluoridation, there is no dental decay preventive measure which even nears the cost-effectiveness of this public health initiative. 

B.  Deal’s personal, opinion on teaching methods and curricula of dental schools is unsubstantiated, unqualified, and irrelevant.

33.   Deal:  ” Fluoridation is a maze of half-truths and lies, and for some people it is hard to find the exit.”


Deal presents no valid evidence to support this slanderous statement.

34.  Deal:  “The right thing for you to do would be to put a halt to fluoridation and initiate a state class action suit against NSF and Simplot. The suit would be first for the money which rate payers have paid for unnecessary and harmful fluoridation chemicals and next for physical harm incurred.”


Given that Deal maintains a website brazenly  called ““, and given that he is an attorney who assumedly profits from class action lawsuits, it is not a stretch to clearly understand his motives for this ridiculous suggestion.