April 22, 2019

The role of professional engineers in maintaining the policy of municipal water fluoridation in Ontario

COF-COF Waterloo Ontario Hydrofluorosilicic Acid Feed Station 340 x 255By: Gerald W. Cooper, MBA, P.Eng., Vladimir Gagachev, P.Eng., and Chris Gupta, P.Eng., Engineering Dimensions, 11-Sep-2013 – Fluoridation is the controlled addition of hazardous and inherently contaminated industrial fluoride chemicals into a municipal drinking water system (Brenntag Canada Inc.).

The chemicals are not for water treatment assuring potability, but for human treatment assuring increased fluoride intake for the purported purpose of controlling tooth decay.

In 1957, the Supreme Court of Canada ruled that this added fluoride is medication for a special health purpose and the law then did not allow the use of municipal water supplies for this intent and delivery (Supreme Court of Canada).

To this day, no provincial law–not the Safe Drinking Water Act, Public Health Act or the Fluoridation Act–authorizes the use of public drinking water to deliver any substance meant to treat or prevent disease when consumed. This fact alone calls for an immediate review of PEO’s current policy (or lack thereof) that enables and condones municipal water fluoridation in Ontario on the basis of reports from professional engineers.

Historically, the operations managers and professional staff of large metropolitan drinking water systems in Ontario were often mechanical, electrical and/or chemical engineers. It takes engineering expertise to build systems that remove contaminants and pathogens from source water and make safe, high-quality, municipal drinking water and then install a post-disinfection fluoridation system in the treatment plant (Canadians Opposed to Fluoridation). The fluoridation station must be contained, ventilated and separated from the filtration and disinfection area due to hazardous and corrosive vapour from the most frequently used fluoridation agent, hydrofluorosilicic acid (HFSA), which can compromise the health and cognitive acuity of staff and the mechanical function of equipment for disinfection and potability (Centers for Disease Control and Prevention, US Department of Health and Human Services).

Fluoridation and disinfection were often seen as one goal. Consequently, 70 per cent of Ontario’s people received artificially fluoridated municipal water by the 1980s. This portion has recently declined due to a number of community councils deciding not to start or continue fluoridation of their drinking water systems.

When the idea of “certified operators” became a reality as a result of Walkerton, treatment plant operators took on greater responsibility and, now, liability. Today, most engineers involved in the design of drinking water quality and distribution are administrators and consultants but are not liable as overall responsible operators.

This has important implications for the continuation of fluoridation in Ontario. Under Ontario’s Safe Drinking Water Act, municipal councillors can be held personally liable for decisions that lead to infractions of the act (Ontario Ministry of the Environment). As explained on page 8 of Taking Care of Your Drinking Water: A Guide for Members of Municipal Councils:

“You are not expected to be an expert in the areas of drinking water treatment and distribution. Section 19 allows for a person to rely in good faith on a report of an engineer….”(Drinking Water Ontario)

An engineer’s report is assumed to be accurate on technical data from applied science and free of bias. Safety is established and doubt erased by calculation, not faith. For water potability measures, this is the case. However, fluoridation has historically been recommended to municipal councils on a tautological basis rather than an empirical, evidence-based one.

Scientific reports made available to the province (Ontario Ministry of Health) and City of Toronto (Azarpazhooh) from Canada and beyond show that fluoridation is ineffective as a dental health program and unnecessary as a means of providing fluoride to consumers.

The application of engineering principles reveals that fluoridation with HFSA is unwise, uneconomic, unsafe and unethical in terms of water quality and system performance. The Quebec association of water quality professionals takes this position (Réseau Environnement). Ontario water quality professionals have also spoken out (Van Caulart, Thomas).

The Chemical
The material safety data sheet (MSDS) reveals that HFSA is extremely hazardous and toxic. Manufacturers’ shipment assays show it to be inherently contaminated with arsenic at 25 to 90 mg/L and other toxins. HFSA does not meet its own certification to Standard 60 by the National Sanitation Foundation International (NSFI) due to lack of toxicological data, as admitted by NSFI officials giving testimony under oath. Although dilution samples meet standards, dilution of HFSA’s contaminants in drinking water is no defense under Ontario law (Ontario Ministry of the Environment). As well, upon being added to drinking water at water treatment plants, HFSA produces hydrogen fluoride (HF) gas, which is both corrosive to plant equipment and toxic to humans and other life forms in the environment.

HFSA is being used as medication contrary to manufacturers’ specifications, and is not specified for use as a disinfection or potability agent or distribution system conditioner. Furthermore, in the MSDSs, manufacturers typically disown any liability for such usage.

Citizens rely on elected councillors, who rely on engineers, who assume public health officials have independent proof that the fluoridation materials meet human safety requirements, specification for use and certification standards, and do not degrade water quality. However, despite recommendations from all levels of government and health regulatory officials that HFSA should be verified as meeting certification standards for safety and health claims efficacy, certification has not been verified. No force of law is applied to correct this.

The councils of Hamilton and the Region of Peel voted in 2012 to request that HFSA be regulated by Health Canada as a drug to provide public reassurance that Canada’s highest health authority has scientifically determined that it is safe and effective for the specific health purpose claimed for it. However, Health Canada has declined to regulate HFSA.

Thus, it is apparently now up to a professional engineer to tell a municipal council whether HFSA is a certified health product, a potability treatment or a contaminant in drinking water. In an October 2011 report for the town of Lakeshore in Windsor-Essex, John Kehoe, P.Eng., accurately stated, “Fluoridation is a process that does not contribute to the municipality’s objective of providing safe drinking water.” Consequently, Windsor passed a five-year moratorium on fluoridation in January 2013.

Dose and safety
Dosage of fluoride from drinking water is calculated as concentration multiplied by volume of water consumed for each unit of body weight. One litre of fluoridated water provides the same dose of 0.6 milligrams to Toronto
Mayor Rob Ford as to a small infant who consumes it in formula. Sodium fluoride supplements of 0.25 milligrams are not approved as safe for infants and Health Canada recommends against fluoride supplements for infants.
Safety of the highly variable chronic fluoride dosage from water fluoridation with HFSA has not been established by toxicological and pharmacological methods. Toxicity from fluoridated water depends on the vulnerability of the consumers of drinking water, not the fluoride level. The primary variable, water intake, cannot be controlled.

Health Canada states that fluoride is not a nutrient, but has set adequate intake (AI) of fluoride for infants from ages birth to six months at 0.01 mg a day, the amount from mother’s milk. This intake is reached from one tablespoon of water fluoridated at 0.6 mg/l. Infants fed formula reconstituted with fluoridated tap water typically consume at least 50 tablespoons, grossly exceeding the AI.

Infants are most at risk for the long-term developmental endocrine-disrupting effects of daily overdose on brain and teeth (National Research Council). Fluoride in tap water used to mix infant formula is the primary cause of dental fluorosis (Fluoride Action Network), an irreversible scarring of tooth enamel seen in permanent front teeth at about age 7 (Fluoride Action Network). Dental fluorosis now affects 40 per cent of children raised in the fully fluoridated greater Toronto-Hamilton area but is downplayed as cosmetic and justifiable by Ontario’s public health officials. American dental and pediatric authorities have now advised that fluoridated water should not be used to mix formula for infants under six months of age but such Canadian associations have not done so.

Water Quality
HFSA dissociates to release free fluoride anion but can form silicate oligomers, HF and other fluoride compounds inside the system in reaction with potability treatment chemicals (Urbanksy). Interaction of dissociated silicofluorides with chloramine, source water chemistry and distribution systems has resulted in leached lead in residential tap water exceeding Ontario’s regulatory standard of 10 ppb. When Thunder Bay’s chartered chemist conducted research (Vukmanich), he confirmed published findings that HFSA addition would increase lead in tap water (Maas et al.). Thunder Bay council proceeded to reject fluoridation.

Every litre of HFSA pumped into the water treatment plant becomes fluoride pollution of the downstream environment in the Great Lakes and St. Lawrence River that reduces availability of free calcium to freshwater organisms. This was reported in April 2011 by Toronto’s Medical Officer of Health to range from 0.12 to 0.17 mg/l in Toronto harbour. The MSDS warns that HFSA is environmentally harmful. In tertiary municipal effluent, the fluoride level averages 0.6 mg/l, exceeding the Canadian Water Quality Guideline of 0.12 mg/l and Species At Risk Act limit.

However, even if HFSA were regulated, approved, free of arsenic and other co-contaminants, and harmless to infants and the ecosystem; even if it did not cause dental fluorosis; and even if it were an essential nutrient or effective drug, it would still be unethical to deceive the public into consuming it as a medication and disease treatment without their full and informed consent (Service Ontario).

The material fact is that a fixed rate of fluoridation of a drinking water system results in a fixed rate of fluoride pollution of the ecosystem. Even though done “in good faith,” it results in variable, incalculable fluoride overdose to vulnerable consumers. This should not be any engineer’s professional or ethical legacy.

PEO, in its ongoing quest to be recognized as an informed and conscientious source of public policy advice to the Ontario government and in its oversight role of the conduct of its members, should immediately develop a policy to remind its members of the limits of their professional licences in providing reports to municipal councils that assume evidence of safety, efficacy for cavity prevention and proof of certified standards for HFSA that do not exist. PEO should guide members so they do not allow the misuse of their expertise or reputation in producing and delivering the safest, highest-quality municipal drinking water in Canada.

Gerald W. Cooper, MBA, P.Eng., has been a federal government executive involved in public policy and program development on exporting, product/process innovation, municipal infrastructure and investment attraction for more than 20 years. Vladimir Gagachev, P.Eng., is an electrical engineer involved with product safety and standards. Chris Gupta, P.Eng., is CEO of Gupta Research (Alternate Energy and Health) in London, Ontario.