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From the Townsend Letter
June 2008


Fluoride Petition
submitted by Charles Weber

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Citizen's petition to the FDA to make fluoride a prescription drug for use in tooth applications, tooth paste and bottled water.

1. Docket number 2007P-0070/CP1






7. _____________________________________ (date)
Dockets Management Branch, Food and Drug Administration, Department of Health and Human Services, Room 1-23, 12420 Parklawn Dr., Rockville, MD 20857.

The undersigned submits this petition under the Federal Food, Drug, and Cosmetic Act, the Public Health Service Act, or any other statutory provision for which authority has been delegated to the Commissioner of Food and Drugs (under 21 CFR, Part 5.10) to request the Commissioner of Food and Drugs make fluoride a prescription drug for use in tooth application and toothpaste, and in bottled water

Fluoride is used both internally and as an application under the supposition that it poisons tooth cavity bacteria and decreases enamel solubility. However, it is only marginally useful for that purpose, decreasing cavities less than 50%. At the same time, fluoride adversely affects health. Fluoride interferes with collagen formation, damages the kidneys, causes irreversible bone deformation [Reddy] [Susheela and Mohan], increases bone fractures [Orcel], causes teeth to mottle [Pendrys], causes lower intelligence in children [Lu], has been found to inhibit the immune system's white blood cell's ability to destroy pathogens [Weisman], and, synergistically with aluminum, causes nerve degeneration similar to Alzheimer’s disease. It has been found that behaviors associated with lead neurotoxicity are more frequent in communities using silicofluorides than in comparable localities that do not use these chemicals [Masters]. Rats fed amounts of fluoride similar and also slightly higher to that found in artificially fluoridated drinking water suffered from impaired central nervous system functioning and poorer memory. There was more malaise and fatigue and significant alteration of enzyme functioning. Some researchers have concluded that there is a mechanism by which fluoride can contribute to many neurological problems in children. Thus, links of fluoridated water to decreased intelligence, increased incidence of ADD and ADHD, lowered cognitive ability, poorer memory, and other related problems might be correct.

Three studies were done on rats by Varner, all of which showed fluoride to be a significant neurotoxin. This was especially true in the presence of aluminum. Varner found that when fluoride with just 1 ppm fluoride (the amounts used for artificially fluoridated water) was used in the presence of aluminum sulfate (frequently used to improve the appearance of drinking water), the results were disastrous. Aside from brain and kidney damage, there was an 80% mortality rate in the animals fed doses of sodium fluoride and aluminum similar to those found in artificially fluoridated water. The original Varner et al. study was designed to determine whether aluminum and fluoride (AlF3) in drinking water plays a role in age-related neurological damage similar to Alzheimer's disease. Although claims of fluoride increasing the uptake of aluminum have been made before, this was the first scientific study designed to look at this specific interaction.

Animals fed the aluminum/fluoride-laced water developed sparse hair and abnormal, copper-colored underlying skin, which is related to premature aging. Mostly, the researchers related these effects to chronic kidney failure. Further autopsy results showed serious kidney abnormalities in animals that drank water containing both sodium fluoride and aluminum fluoride. The Varner team said that "striking parallels were seen between aluminum-induced alterations" in cerebral blood vessels that are associated with Alzheimer's disease and other forms of pre-senile dementia. They concluded that the alterations of the blood vessels might be a primary event triggering neuro-degenerative diseases. [Varner].

Fluoride interferes with the hydroxylation of proline to hydroxyproline. Fluoride exposure disrupts the synthesis of collagen and leads to the breakdown of collagen in bone, tendon, muscle, skin, cartilage, lungs, kidney, trachea, and arteries. [Susheela and Sharma] [Sharma] [Susheela and Mukerjee] [Marian Drozdz et al.].

Proteins are kept in a three-dimensional structure by weak bonds between adjacent proteins called hydrogen bonds. Emsley et al. found that fluoride disrupts this hydrogen bonding within proteins by virtue of an unusually strong bond between the fluoride ion and the NH group of amides [Emsley]. In other words, it changes some associated proteins and enzymes from the exact shape they're suppose to be in.

At the same time, other substances exist that give far more protection to teeth than fluoride, especially while children are growing, such as vitamin D, copper, and magnesium, with no adverse effects in reasonable amounts. These substances also strengthen bone [Holick]. There is also a substance present in cashew nuts [Weber] and mango fruit, anacardic acid, which is far more lethal to cavity gram-positive bacteria than fluoride [Eichbaum]. Fluoride is not more lethal to cavity bacteria than conventional mouthwash [Bibby].

In addition to the above circumstances mildly adversely affecting health – i.e., "mildly," if applied properly in minute amounts – fluoride enters the individual bodies in wildly varying amounts. Fluoride is applied largely for the purpose of protecting children. But to expect small children to apply this toothpaste poison correctly without medical instruction or, for that matter, even with instruction, is inane. There is also the danger that some parts of the adult population will have more than small intakes. Many municipal water supplies have added fluoride, so people who must drink large amounts of water, such as people with damaged kidneys, or who do drink large amounts of water because of recommendations of health purists will receive large amounts. Richmond says that fluorinating water has no perceptible affect on kidneys in children, but that fluoride in water for dialysis should be controlled [Richmond]. Another group at risk are people who eat large amounts of dried food that must be reconstituted with water. This group might include babies and possibly soldiers. All this risk occurs with no or little reduction of tooth caries from water fluoridation [Seppa].

This increased fluoride intake is also true for people who drink much tea [Gulati], since tea leaves pick up large amounts from some soils and probably other plants do as well [Xie]. Coffee contains high amounts of fluoride from insecticides. Fluoride compounds are applied to plants as insecticides. Most of these fluorides end up in the soil and therefore probably in many plants.

Fluoride is an unessential poisonous mineral, so there is no disadvantage to making it difficult to obtain. There is no financial disadvantage because it is added to toothpaste, etc., and so there is no removal cost. It conveys no advantage in color or taste. The only problem is that there might be strong political pressure from vested interests [Bryson].

Fluoride will eventually end up in the soil in the form of processed sewage, so this is another reason for using this poison sparingly. It will also end up in the soil in massive amounts when city water is used for irrigation uses. In the course of a million years, the soil will be badly contaminated. The contamination of alkaline soil is especially likely. Fluoride effects will include poisoning the soil's microorganisms [Dhruva]. Fluoride will also probably make aluminum poison more available to plants [Arnesen].

None required.

Arnesen AKM. Effect of fluoride pollution on pH AND solubility of Al, Fe, Ca, Mg, K
and organic matter in oil from ˜rdal (Western Norway). Water Air and Soil Pollution. 1998;103 (1-4):375-378.

Bibby BG, Zander HA, McKelleget M, Labunsky B. Preliminary reports on the effect on dental caries of the use of sodium fluoride in a prophylactic cleaning mixture and in a mouthwash. J Dent Res. 1946;25(4): 207-211.

Bryson C. 2004 The Seven Stories Press.

Rao1 DN, Pal D. Effect of fluoride pollution on the organic matter content of soil. Plant and Soil. 1978;49: 653-656.

Eichbaum FW 1946 Biological properties of anacardic acid (O- pentadeca dienylsalicylic acid) and related compounds. General discussion-bactericidal action. Memorias do Instituto Butanen. 1946;19:71-86.

Emsley J, et al. An unexpectedly strong bond: Ab initio calculations and spectroscopic studies of amide fluoride systems. Journal of the American Chemical Society. 1981;103: 24-28.

Gulati P, et al. Studies on the leaching of fluoride in tea infusions. The Science of the Total Environment. 1993;138 (1-3): 213-221.

Holick MF 2004 Sunlight and vitamin D for bone health and prevention of autoimmune diseases, cancers, and cardiovascular disease. American Journal of Clinical Nutrition. 2004;80: (6, 1678S-1688S.

Lu Y, Sun ZR, Wu LN, Wang X, Lu W, Liub SS. Effect of high fluoride water on intelligence in children. Fluoride. 2000;33; 74-78.

Marian Drozdz, et al. Studies on the influence of fluoride compounds upon connective tissue metabolism in growing rats. Effect of sodium fluoride with and without simultaneous exposure to hydrogen fluoride on collagen metabolism. Journal of Toxicological Medicine. 1984; 4:151-157.

Masters RD and Coplan M 1998 Water Treatment with Silicofluorides and enhanced lead uptake. Fluoride. 1998;31(3).

Orcel P, et al. Stress fractures of the lower limbs in osteoporotic patients treated with fluoride. Journal of Bone and Mineral Research. 1990; 5 Suppl 1:S191-4.

Pendrys DG, Katz RV. Risk of enamel fluorosis associated with fluoride supplementation, infant formula and fluoride dentifrice use. American Journal of Epidemiology. 1989;130:1199-1208.

Reddy GB, Arjun L. Khandare P, Yadagiri Reddy, Shankar Rao G, Balakrishna N, Srivalli I. Antioxidant defense system and lipid peroxidation in patients with skeletal fluorosis and in fluoride-intoxicated rabbits. Toxicological Sciences. 2003;72: 363-368.

Richmond VL. Thirty years of fluoridation: a review. American Journal of Clinical Nutrition. 1985;41:129-138.

Seppa L, Karkkainen S, Hausen H. Caries trends 1992-1998 in two low-fluoride Finnish towns formerly with and without fluoridation. Carries Research. 2000;34(6):462-8.

Sharma YD. Effect of sodium fluoride on collagen cross-link precursors. Toxicological Letters. 1982;10:97-100.

Susheela SK, Jha M. Effects of fluoride on cortical and cancellous bone composition. IRCS Medical Sciences: Library Compendium. 1981; 9 (11):1021-1022.

Susheela AK, Mukerjee D. Fluoride poisoning and the effect of collagen biosynthesis of osseous and nonosseous tissue. Toxicological European Research. 1981; 3 (2): 99-104.

Susheela AK, Sharma YD. Fluoride poisoning and the effects of collagen biosynthesis of osseous and non-osseous tissue. Toxicological European Research. 1981; 3 (2): 99-104.

Varner JA, et al. Chronic administration of aluminum-fluoride or sodium fluoride to rats in drinking water: Alterations in neuronal and cerebrovascular integrity. Brain Medicine.1984; 4:151-157.

Weber CE. Eliminate infection (abscess) in teeth with cashew nuts. Medical Hypotheses. 2006;65:1200.

Weisman G, et al. Leukocyte proteases and the immunologic release of lysosomal enzymes. American Journal of Pathology. 1972;68:539-569.

Xie ZM, Ye ZH, Wong MH. Distribution characteristics of fluoride and aluminum in soil profiles of an abandoned tea plantation and their uptake by six woody species. Environmental International. 2001;26; (5-6) 341-346.

The undersigned certifies that, to the best knowledge and belief of the undersigned, this petition includes all information and views on which the petition relies, and that it includes representative data and information known to the petitioner that are unfavorable to the petition.


Charles E. Weber
Name of Petitioner

1908 Country Club Road, Hendersonville NC 28739
(Mailing Address)

828 692 5816


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