HomeMy WebLinkAbout09242012 City Council Work Session Notes - Drinking Water [r......_=..._.—=:0RK
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TO: Mayor Seaward
City Council Members:Jean Bardarson,Ristine Casagranda,Marianna Keil,Christy Terry,Vanta
Shafer,Robert Valdatta,
City Manager,Jim Hunt
FROM: Maya Moriarty,Lead,Oral Health,Seward Wellness For All
DATE: September 23,2012
RE: Ordinance 2012-009
In reference to the above Ordinance scheduled for public hearing on September 24,2012,please consider
the following for discussion.
BACKGROUND: In October 2009,the Seward community voted in favor of implementing community
water fluoridation. On February 22,2010,City Council approved Resolution 2010-015 in support of the
community vote and also directed the city manager to conduct a feasibility study concentrating on
"equipment, training, infrastructure, and safeguards of adding fluoride to the City's water system" This
information would be used to make a final determination prior to the appropriation of funds.
http://history.cityofseward.net/Weblink8/DocView.aspx?id=18005&searchid=8eb294dc-85c9-427d-8e60-
de04e81673d1
The feasibility study will most likely occur after improvements are made to Seward's water infrastructure,
which is sound economics.
ORDINANCE 2012-009 JUSTIFICATION STATEMENT: This ordinance is about establishing
criteria for substances added to public drinking water for purposes unrelated to potability.
As Lead to the Oral Health subgroup,I ask Council to read the fine print of this proposed ordinance very
carefully and conduct your own research as to the viability of this proposal as written. Dr.John French,a
doctorate of toxicology,warned that the ordinance is not all that it appears to be. In addition,Resolution
2010-015's feasibility study will satisfy Ms. Casagranda's concerns regarding due diligence from a cost
standpoint. From a safety standpoint,Ms.Casagranda is providing false statements with the purpose of
persuading the public to her opinion(which is not factually supported)and pursue a personal agenda.
I have reviewed the Ordinance in detail and have also requested assistance from experts in the field. Here
are the most egregious points which are phrased in the complete paragraph in such a way to incite fear.
1st WHEREAS—the Evironmental Protection Agency gave up all enforceable oversight responsibilities
for direct water additives in 1988 and there are now no federal safety standards.
Fluoride used in drinking water is tested for toxins,monitored,and certified annually. It must meet
American Water Works Association(AWWA)and National Sanitation Foundation(NSF) standards for
purity,which are stricter than pharmaceutical grade.The Environmental Protection Agency(EPA)
regulates fluoride additives in drinking water,and has had a Memorandum of Understanding with the
Food&Drug Administration since 1979 recognizing this authority. Standard 60 mentioned in the 2"d
WhereAs continues to be under annual EPA oversight and review.
http://www.cdc.gov/fluoridation/fact sheets/engineering/wfadditives.htm#3
The Food&Drug Administration regulates additives to food including the addition of fluoride to water.
Fluoride was added to the FDA's GRAS list in 1975. GRAS stands for Generally Recognized As Safe
which means that fluoride is recognized by qualified experts as having adequately shown to be safe under
the conditions of its intended use.
http://www.fda.gov/Food/FoodIngredientsPackaging/GenerallyRecognizedasSafeGRAS/default.htm
Consequently, the 1"WhereAs statement is untrue.
2°d WHEREAS—ANSI/NSF Standard 60 is established and administered by a nongovernmental body
with no direct responsibility to health agencies or consumers.
With the intention of replacing its `in-house' approval process,the EPA in 1984 contracted for the
development of external standards and certification program for products intended to be in contact with
drinking water. The contract was awarded to a consortium of stakeholders,which included the AWWA
(American Water Works Association),AWWARF(AWWA Research Fund),the ASDWA(Association
of State Drinking Water Authorities,and the National Sanitation Foundation(NSF).Three years later,
EPA announced that the new National Sanitation Foundation/American National Standards Institute
(NSF/ANSI)Standard 60 was functioning. (Overview of National and International Guidelines and
Recommendations on the Assessment and Approval of Chemicals Used in the Treatment of Drinking
Water)http://www.nhmrc.gov.au/_filesnhmrc/file/publications/synopses/watergde.pdf
Standard 60 is not a voluntary standard but is mandated by 47 states,including Alaska.
3rd WHEREAS—Products are not tested.
All products must be certified in strict accordance with Standard 60 requirements including batch
testing. The 3'1 WhereAs is misleading and false.
NSF toxicology staff review the product/material information submitted by a manufacturer to
identify all potential contaminants that may be added to drinking water resulting from the
material's use. A factory audit is used to confirm manufacturing processes. During the audit,
formulations and suppliers are verified, QA/QC records are audited, and the product/material and
raw materials are sampled by NSF staff for testing in the NSF labs. The sampled
product/material is tested according to the protocols outlined in the ANSI/AWWA Standards.
Following laboratory testing, contaminant concentrations are "normalized" or converted to at-
the-tap concentrations and compared to the standard's maximum allowable level (MAL). If
the results are acceptable, NSF and the manufacturer enter into a contractual agreement and
the product is certified and listed by NSF. The NSF authorized formulations are retained at
the product facilities. Manufacture of the authorized formulation may only be changed by
advance written notice and approval by the NSF.
After the initial certification, production facilities are audited unannounced and certified
products are tested and/or evaluated on a periodic basis (typically annually). This ensures
continued compliance with the requirements of the standard, and confirms that the
manufacturer continues to operate in accordance with NSF's general and program specific
certification policies(Overview of National and International Guidelines and Recommendations on the
Assessment and Approval of Chemicals Used in the Treatment of Drinking Water)
http://www.nhmrc.gov.au/ files nhmrc/file/publications/synopses/watergde.pdf
ANSI/NSF Standard 60 is outlined on page 43,Table 7.1,in the Overview of National and International
Guidelines and Recommendations on the Assessment and Approval of Chemicals Used in the Treatment
of Drinking Water. The standards are very detailed and stringent.
http://www.nhmrc.gov.au/ files nhmrc/file/publications/synopses/watergde.pdf
5th WHEREAS—Licensed water operators unable to measure results.
Licensed water operators would be fully trained and have safety mechanisms in place to ensure optimal
levels of fluoridation. It is not their job to measure efficacy. The efficacy of community water
fluoridation has been proven for over 65 years and for decades longer in naturally occurring areas. The
preponderance of evidence supports the safety and effectiveness of water fluoridation.
http://www.cdc.gov/fluoridation/safety/systematic.htm
In addition, water additives have many uses in addition to disinfection and pH balance,including
oxidation-reduction potential and corrosion control. This ordinance directly,or indirectly,applies to
those additives.
The 5`h WhereAs statement is misleadine.
6th WHEREAS—Identification.
The City of Seward already complies with any regulatory requirements with the current water additives.
All fluoride products meet DOT requirements on product labeling and Material Safety Data Sheets for
emergency response teams.
Sect. 1-14.10.090.A—Accountability-asking for a 100%guarantee over a lifetime.
The argument for a 100%guarantee is unrealistic. Would Ms.Casagranda's business provide a 100%
guarantee that her food products would never result in anaphylactic shock or any other illness over the
lifetime of an individual? There is no product on the market that would provide such a guarantee. That's
why there are strict guidelines regarding labeling and Material Safety Data Sheets(MSDS).
As evidenced under the ANSI/NSF Standard 60,there are already stringent tests that water additives have
to comply with. In addition,please see the response to the 1S`WHEREAS.
Sect. 1-14.10.090.B—Disclosure.
Sect. 1-14.10.090.C.—Compliance.
Sect. 1-14.10.090.D.—Conformance.
Please review the response to the 1g`,2"d, and 5th WHEREAS. There are over 30,000 fluoride-related
studies in the National Library of Medicine. I cannot state how many there are for statin drugs or lithium.
Per the CDC,they are unaware of any policy discussions by any governmental public health entity on the
use of lithium and statins in drinking water.
Why would the City of Seward wish to duplicate efforts of more qualified organizations and expend staff
and other resources to ensure compliance? And would staff be qualified to evaluate the list of documents
received?
With the strict requirements of Standard 60,why would a manufacturer or supplier wish to add to their
costs by supplying"any and all published and unpublished" studies on their products AND that of a
"different manufacturer/supplier of a similar product."
Section I-14.10.090.1). is incongruous.
Sect.2—Effective Date.
The City of Seward currently does not add fluoride,lithium,or statin drugs to the water system.
OTHER RESOURCES
The U.S.-population served by fluoridated public water increased from 72.4%in 2008 to 73.9% in 2010.
That's over 200 million people with another 10 million served by naturally occurring fluoride water
systems. Add another 1 million people to that as the city of Portland,OR,just voted to implement
community water fluoridation. http://news.yahoo.com/portland-fluoride-debate-ideological-clash-
092904229.html
Please read Mayor Sam Adams letter(of Portland). Mayor Adams does a thorough job of answering his
constituents' questions and provides factual data including Medicaid issues,cost savings,and also
provides informative links. Per Mayor Adams,"Every respected scientific committee or health
organization that has reviewed the evidence on the safety and effectiveness of fluoridation has concluded
that fluoridation is a healthy and effective public health practice." In addition,Council did not find that
the evidence presented by anti-fluoride advocates to be credible.
http://www.portlandonline.com/mayor/index.cfm?c=49522&a=410028
Other considerations: Canada recently completed a comprehensive study on fluoridation which states that
mild and very mild dental fluorosis are not considered to be adverse effects and...the weight of evidence
from all currently available studies does not support a link between exposure to fluoride in drinking water
at 1.5 mg/L and any adverse health effects." (2009 Guidelines for Canadian Drinking Water Quality:
Guideline Technical Document)
The European Union commissioned a task force in 2011 to also conduct a comprehensive study. The
summary conclusion regarding fluoride and water fluoridation found no occurrence of skeletal fluorosis,
insufficient evidence linking fluoridation to osteosarcoma,it does not hamper children's
neurodevelopment and IQ levels,there is no link to adverse thyroid effects,no adverse influence to the
reproductive system,and it does not pose a risk to the environment. (Arguments have been made that
European countries reject water fluoridation when in truth, their water systems are very complicated and
other mechanisms are used to introduce fluoride and oral health programs to the community which are
easier with socialized medicine(i.e.)sealant programs,fluoridated salt, etc.)
Some of the reasons why the Portland Council voted for fluoridation were the comparisons of oral health
in their community as compared to neighboring cities and states that did fluoridate. While 73 percent of
the U.S.population drinks water treated with fluoride,the rate is less than 25 percent in Oregon.
http://news.yahoo.com/portland-fluoride-debate-ideological-clash-092904229.html
http://www.hss.state.ak.us/dph/wcfh/Oralhealth/docs/AKReport 3rd%20Grade.pdf
Deserving review is the 2011 CDC publication on an Alaska Native village study on oral health issues.
The region included 52 villages or about 25,000 people. This study found:
• 4-5 year old children had an average of 2.6 times more decayed and filled primary teeth in non-
fluoridated villages than in fluoridated villages;and
• Children aged 12-15 years old in non-fluoridated villages had more than double the number
decayed,missing,and filled permanent teeth than children in that age group living in fluoridated
villages. http://www.hss.state.ak.us/press/2011/DentalStudy PR 09222011.pdf
Impacts of dental decay in children can include problems with speech development,difficulty chewing,
poor weight gain,missed school hours,pain,infection,and more expensive dental treatment if it is not
caught early. Decay in primary(baby)teeth is a predictor of future dental decay in later life. National
expenditure information finds dental expenses are second only to prescription drugs in out-of-pocket
expenditures in the U.S. Nationally,more attention is being focused on dental care for older Americans.
National studies show adults aged 65 years and older have as much untreated dental decay as children.
Medicare,the primary insurance for many in this age group,does not cover routine dental care.
On the Kenai Peninsula,Medicaid dental expenditures totaled over 4.6 million dollars! When broken
down by age group,under 21 year olds accounted for 57%of the costs,21-50 year olds for 29%,and
over 50 year olds for 14%. When we look at Seward,a total of$208,936 was spent and our percentages
by age group are different than the Peninsula's as a whole. Seward spends more on Medicaid dental
benefits in the 21-50 and 50 year old age groups: 50%,31%,and 19%respectively. One would
conclude that Seward adults are undergoing more costly procedures than other Peninsula adults and need
to practice more preventative measures. Adults are keeping their teeth longer,have gum recession,gum
disease,and other oral health issues.
There is a growing trend towards implementing community water fluoridation. Fourteen states,the
District of Columbia,and Puerto Rico have state-wide mandates. 42 out of 50 of the largest U.S.cities
are supplied with fluoridated water(add Portland to the list soon). And more Alaskan communities
have implemented community water fluoridation than those that have ceased(ANTHC statistics).
For those who didn't understand Dr.John French's statement regarding dosage,a visual image may help.
The average adult has to drink 15,000 liters of fluoridated water in one sitting to have an adverse effect
from the fluoride whereas one only has to drink 4 liters in one sitting to experience water toxicity. The
water itself will cause death by only drinking 4 liters in one sitting! As stated by Paracelsus,"All things
are poison and not without poison;only the dose makes a thing not a poison."
To further visualize,the optimal level of fluoride is 0.7 parts per million which is almost the equivalent
of an inch in 14 miles.
Of final note is a link to Fluoridation Facts,question 52,page 47. Information is provided on the type of
misinformation,misleading comments,and other tactics that are used by anti-fluoridation groups. Of
special note is the 1993 U.S. Supreme Court decision regarding"junk science." This decision is a prime
reason why no city or municipality has ever been successfully litigated against. Figure 7 outlines specific
tactics that you've already been exposed to. The letter to Council sent by Matt Hershock and this
ordinance are examples of Targeting Politicians and Community Leaders. The verbiage was"cut and
pasted"together and customized for Seward.
Finally,the letter that Ms.Casagranda sent to"all of the fluoride suppliers"with no response was
inaccurate,misleading,and an attempt to cause unnecessary alarm. See responses to the 1st,2"d,and 3'd
WhereAs'. Standard 60 was created by a panel of experts from various professional and governmental
associations in accordance to a solicitation by the EPA for a system to assure quality and safety products,
and has been peer reviewed to be validated as an effective system. Standard 60 reports annually on the
certification of products. As this letter request is a well-known tactic used by anti-fluoride activists,no
response is given by the supplier/manufacturer.The most egregious part of the letter was the focus on
fluorosilicic acid when there is no fluorosilicic acid used in Alaska. So this is a generic letter and not
really a community focused letter.
SUMMARY
The safety and efficacy of community water fluoridation has been proven for over 65 years by the
preponderance of scientific evidence.
Over 200 million people in the U.S.are served by fluoridated water systems. That's 73.9% of the
population.
The State of Alaska's untreated dental caries rates are higher than the national averages.
Seward's adult Medicaid dental expenditures are higher than the average Kenai Peninsula adult Medicaid
dental expenditure.
Fluoride used in drinking water is tested for toxins,monitored,and certified annually. It must meet
American Water Works Association(AWWA)and National Sanitation Foundation(NSF)standards for
purity,which are stricter than pharmaceutical grade.ANSI/NSF Standard 60 is stringent and involves
detailed testing,documentation,auditing,and reporting.
The City of Seward requires Industry Compliance on current additives and such requirements should be
standardized for all additives. A special Ordinance going over and above is not necessary.
The Seward community voted in favor of community water fluoridation and City Council passed
Resolution 2010-015 in support of the vote.
CONCLUSION
Given the facts outlined above, the only reasonable action is to not pass the ordinance further than the
work session.
In addition,it is evident from fact checking that this ordinance does not present factual information and
should never have been presented to Council in the first place. This should be a good example of why
Council should change its policies to only allow an Ordinance sponsored by two Council representatives
and only after fact checking from reputable sources.
Ordinance 2012-009 was introduced without proper fact checking,was an abuse of resources,and an
attempt to circumvent our democratic political process. It should be thrown out and Ms. Casagranda
should be reprimanded for her actions.
Sources:
❖ Dr.Brad Whistler,Dental Official,DPH Oral Health Program,Department of Health and Social
Services, State of Alaska
❖ LCDR Troy Ritter,REHS,MPH,DAAS,Applied Sciences Manager,Environmental Health
Support,Alaska Native Tribal Health Consortium
❖ Kip Duchon,P.E.,National Fluoridation Engineer,Centers for Disease Control
❖ Jane McGinley,RDH,MBA,Manager,Fluoridation and Preventive Health Activities Council on
Access,Prevention and Interprofessional Relations,American Dental Association