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with William Hirzy, PhD


Bill Hirzy Melissa Gallico fluoride acne

Former president of the EPA union, Dr. William Hirzy, discusses the scientific fraud that occurred at the Environmental Protection Agency in the 1980s and 1990s that keeps the practice of public water fluoridation in place today.

Ep5 with William Hirzy, PhD

The EPA's Role in the Pollution Story Behind Fluoridation (Part II)

In June 2000, Dr. William Hirzy testified on behalf of the EPA Union of Professional Employees in front of the U. S. Senate Subcommittee on Fisheries, Wildlife, and Drinking Water regarding the union's unanimous decision to call for an immediate moratorium on artificial water fluoridation in the united States. In this interview, author Melissa Gallico interviews Dr. Hirzy, about his historic congressional testimony and how the union fought to expose the scientific fraud at EPA that allows the reckless practice of public water fluoridation to continue to this day.



Dr. J. William Hirzy worked in environmental and human health risk assessment for 35 years. In addition to his position as a senior risk assessment scientist at EPA Headquarters, he served four terms as president of the EPA union of professional employees and was a Chemist In Residence and adjunct professor at American University. He has a PhD in chemistry from the University of Missouri.


Melissa Gallico is a former FBI analyst and military intelligence officer. She is also author of The Hidden Cause of Acne, illustrator of F Is for Fluoride, and host of the #Fpollution podcast, dedicated to exposing the pollution story behind fluoridation. She has a degree in science and technology in international affairs (STIA) from Georgetown University and a master's in international security studies from the University of St. Andrews in Scotland where she spent a year as a Fulbright scholar to the United Kingdom.



This podcast is produced by Gallico Studios, a multimedia effort supported by a community of activists who share the goal of ending artificial water fluoridation. To join the studio or learn more, visit our website at

Melissa Gallico: Welcome to the #Fpollution podcast. I'm your host, Melissa Gallico, author of The Hidden Cause of Acne: How Toxic Water is Affecting Your Health and What You Can Do About It and F Is for Fluoride: A Feasible Fairytale for Freethinkers 15 and Up.

In previous episodes, we discussed the pollution scandal at the heart of artificial water fluoridation and spoke with Dr. Robert Carton, the former president of the EPA union of professional employees, about how, in the 1980s, union members worked to expose the fraudulent science—and I don’t use that term lightly—that keeps fluoridation in place to this day.


In this episode, we’ll hear from Dr. William Hirzy, a senior EPA scientist who served as president of the union during multiple terms in the 1990s and testified in front of the U.S. Senate in June 2000 calling for an immediate moratorium on public water fluoridation after EPA union members voted unanimously to oppose the practice over concerns that fluoride is a carcinogen.


Dr. J. William Hirzy worked in environmental and human health risk assessment for 35 years. In addition to his position as a senior risk assessment scientist at EPA Headquarters, he served four terms as president of the EPA union of professional employees and was a chemist-in-residence and adjunct professor at American University. He has a PhD in chemistry from the University of Missouri.


Dr. Hirzy, welcome to the show.


Dr. Hirzy: Glad to be here, Melissa.


Melissa Gallico: Before we get into your experience at the Environmental Protection Agency, I’m curious to know what your thoughts were about fluoridation before then. Do you recall, maybe, hearing about fluoridation as a kid growing up or just what you thought of the practice before you learned about it through your work with the EPA union?


Dr. Hirzy: Well, hadn't really thought very much about it. I had, like many people I guess, got the word that this was good for your teeth. Basically, I thought it was an okay thing. And then we eventually came to learn otherwise.


Melissa Gallico: In our last episode, we heard from your former colleague, Dr. Robert Carton, about how the union came to be involved in the issue of artificial water fluoridation in the mid-1980s after a scientist complained to the union that EPA was ignoring established protocol when calculating the safety standards for fluoride in drinking water. How and when in that story line did you enter the scene?


Dr. Hirzy: Maybe something you've already heard from Dr. Carton which was that after we organized the union at EPA headquarters and got into a public spat with management over some rules banning and phasing out asbestos-use consumer product, that fight got out into the media. The New York Times published an article about that and folks who were interested in this fluoride question learned that there were employees at EPA headquarters organized in the union that really cared about the agency's mission. And they got in touch with us and asked us if we'd like to hear a seminar by Dr. John Yiamouyiannis about fluoride toxicity. And being science wonks as we were, we said ‘look, sure, we would like to hear that.’ And on hearing Dr. Yiamouyiannis, the scales fell from my eyes as well as from the eyes of other EPA employees who were there at that meeting and we began to get into the science behind or, actually, the toxicology of fluoride. And that's how we got interested in it and how I lost my enthralled nature about how wonderful water fluoridation was.


Melissa Gallico: So, did you drink fluoridated water at that time?


Dr. Hirzy: Yeah, and didn't even know it at the time. I think when I was growing up in St. Louis they probably started fluoridating maybe even after I left St. Louis and went off to the university. But it just wasn't on my intellectual radar to be thinking about fluoridation other than, you know, what one generally heard about it being good for one's teeth. And like I said, I didn't really think about it until 1985 when we were invited to hear Dr. Yiamouyiannis.


Melissa Gallico: Dr. Carton left the EPA in 1992 and even though the union was very active in opposing fluoridation up until that time, even attempting to join a lawsuit with the Natural Resources Defense Council against the EPA, it seems like the union’s opposition to fluoridation increased even more throughout the 1990s. The union formally voted to oppose artificial water fluoridation and also published a white paper outlining their reasoning for their opposition to the practice. Tell us the details surrounding that vote. When did it occur, what exactly were the members voting on, and what was the result?


Dr. Hirzy: We were contacted by California Citizens for Safe Water who were organizing a referendum on the statewide mandate in California to put fluoride in all the drinking water supplies in California, and they asked us to support their effort. We discussed that in the executive board at the union and we decided, ‘Well, we can't make a decision on that. We have to put this out to the membership.’ So, at the annual meeting of the... this actually was the meeting at which we were going to vote on the collective bargaining agreement with the agency so this was a big meeting in terms of attendance by employees. We decided to invite Dr. Carton who was at that point the environmental officer for the U. S. Army Medical Research Command up at Fort Detrick to come back and speak to the union and speak to the employees about this. And we also invited Dr. Paul Connett to come and talk about it as he had started being interested in this issue. And after presentations by Dr. Carton and Dr. Connett, we held a vote and the vote was unanimous that we would support the efforts of people in California who were trying to keep fluoride out of the drinking water. That's how that all came about.


Melissa Gallico: In the white paper, the union describes a number of concerns from fluoride toxicity, including an acute toxic hazard for people with impaired kidney function, for example, as well as chronic toxic hazards such as gene mutations, cancer, reproductive effects, neurotoxicity, bone pathology and dental fluorosis. It’s hard for a lot of people to understand why fluoride would have such a wide range of adverse health effects that are not acknowledged by government health organizations. Can you help us wrap our brains around that? Why are there so many negative health effects of fluoride?


Dr. Hirzy: Well, fluoride is an interesting creature. The fluoride ion is the atom of fluorine with an acquired electron. Fluorine is the most electronegative element on the periodic table. That is, the fluorine atom will steal electrons from any other atom. The issue is, the shape of a protein is affected by these hydrogen bonds. And when a fluoride ion kind of waltzes into a protein, all of a sudden the hydrogen atom... Visualize it this way, in order for a protein to do its thing, it has to have a certain kind of shape. Proteins do a lot of different things in the body including catalyzing (making reactions) that have to take place in order for the body to function, to happen very smoothly and very rapidly. And the shape of the proteins that do this kind of thing is critical. The shape of the protein molecule is very critical for making this kind of process work for metabolism and to work for other kinds of physiological functions. And when a fluoride ion wanders into a protein that has a particular shape, all of a sudden the hydrogen atoms in that protein perk up and say, ‘there's a negative thing. I'd like to go over and be by that negative fluoride ion.’ And the shape of the protein—boom—changes. And this is a problem. That protein will not be able to do its normal kind of function. Whether that is catalyzing reactions, helping to transmit nerve signals, helping a muscle to function in a certain way, and so forth. It is fundamentally the fact that, as I said, a fluoride ion with that big fat negative charge on it, when it gets close to proteins it changes the shape of the proteins and that's a big problem.


Melissa Gallico: One of the main points I want to get across with this entire podcast series is that fluoridation is—at its heart—a pollution scandal. Most people are unaware that over 90 percent of the fluoride added to public water supplies in the United States comes from the phosphate fertilizer mining industry in central Florida. Government officials refer to hydrofluorosilicic acid as a  “byproduct” of phosphate fertilizer mining, but is it also accurate to describe this chemical as a hazardous waste product of fertilizer mining?


Dr. Hirzy: Oh yes. This is one of my favorite aspects of this whole problem is talking about hydrofluosilicic acid. Hydrofluosilicic acid is, under the criteria for hazardous waste that are laid out in the Resource Conservation and Recovery Act of toxicity, reactivity, and corrosivity... hydrofluosilicic acid meets all three of those criteria. It is very toxic. It is very reactive. It is very corrosive. But, under the code of federal regulations, a law was passed that excepts products that are recyclable from mineral processing and that's what’s involved with producing this hydrofluosilicic acid.


Once phosphate fertilizer is manufactured, the way that’s done is (again, I'm doing this in a very condensed way) phosphate ore is dug up out of the ground. In addition to phosphate, there is also calcium fluoride and a bunch of other stuff, other kinds of minerals as you can imagine in solid ore material, they put this in a big reactor and cook it with sulfuric acid. And when they do that, the object is to turn the phosphate into phosphoric acid. But in addition to that chemical process which is taking place, fluoride which came along with the phosphate rock is converted to hydrogen fluoride and silicon tetrafluoride. Silica is one of the most dominant chemical elements in the Earth's crust. So, silicon tetrafluoride and hydrogen fluoride are byproduced while making this phosphoric acid. And in the old days, silicon tetrafluoride and hydrogen fluoride are both gases which were vented to the atmosphere and it caused enormous environmental damage. They're both toxic and very reactive.


Under the Clean Air Act and the Clean Water Act, EPA required that this kind of emission be stopped. And in essence, what happens is, when these gases are produced during the processing, the gas stream is passed through a column counter-current with a water stream. The gases bubble up and the water stream comes down. And what happens is, the water converts the silicon tetrafluoride and hydrogen fluoride (the hydrofluosilicic acid for the chemical wonks in the crowd; SiF4 is silicon tetrafluoride and HF is hydrogen fluoride), and when water reacts with these two gases what is produced is H2SiF6 which is hydrofluosilicic acid. And the stream containing that stuff then is what's collected and it is impossible to discharge that into streams because of the Clean Water Act regulations that limit the amount of fluoride that can be in water effluent streams coming out of that kind of production facility.


And in fact, one of the things that got our attention in the union was a letter by Rebecca Hamner who was the deputy assistant administrator for water in the 1980s. She responded to an inquiry from a citizen asking about hydrofluosilicic acid. And she writes back to this person, "This agency finds that the recovery of [what she called] fluosilicic acid [this stuff goes under a couple different names, fluosilicic acid is the name she used in this letter] as an ideal solution to a long-standing environmental problem. By recovering fluosilicic acid from phosphate production, air and water pollution are minimized and water authorities have a low-cost source of fluoride for water fluoridation." So, it doesn't take too much reading between the lines to see that this stuff... if the silicon tetrafluoride and the HF went up the stack it’d be an air pollutant that was toxic and you couldn't do that. And if you just discharged the H2SiF6 out into the river, you couldn't do that either. Air and water pollution laws prevent that. So what happened?


I did some research back in 2012 and went into the database of the U. S. Geological Survey which keeps track of how much hydrofluosilicic acid is produced and how much goes into water fluoridation. And it turns out that in (and I looked at the numbers in 2011 and I've also looked at the numbers and subsequent years back up and through 2016; the amount of this stuff that is produced varies on the demand for phosphate fertilizer) but in a typical year, there would be about 260,000 tons of this stuff in the concentration that goes into water fluoridation which is about 260,000 tons of that 24 percent solution is produced every year. And of that 260,000 tons, about 13,000 tons, a very small fraction, is used for things like sterilizing brewing equipment, hardening concrete, and making ceramic, and the rest of it, about 245,000 to 250,000 tons go straight into drinking water supplies. It’s sold as a product from the phosphate industry at prices that range anywhere from about $500 a ton to $2,000 a ton. If they couldn't sell it to water authorities, they would have to pay to dispose of it in a hazardous waste facility because of the criteria of corrosivity, reactivity, and toxicity. What the water fluoridation program is, is a way for the phosphate industry to get rid of almost all of this toxic, corrosive, reactive stuff by selling it to water authorities for a fantastic price. If you run the numbers, it comes out to be around $200 million dollars a year pure profit—ching, ching—every year. Not to mention the avoidance of other disposal means costs, but pure profit for the phosphate industry.


Melissa Gallico: One event I’d like to ask you about in particular from your time at the EPA is the firing in 1994 of a senior toxicologist at the EPA’s Office of Drinking Water, Dr. William Marcus. This was an important case because it was the first time that the whistleblower provisions in the Safe Drinking Water Act were used to protect a federal employee. Can you tell us that story?


Dr. Hirzy: Yes. Back in 1978 or ‘79, which was the last time that Congress looked at the whole program of promoting water fluoridation on a nationwide basis, in the testimony back in the late ‘70s, a number of people including...the name escapes me and I'll have to go back to that, he was the chief chemist at the National Cancer Institute, and Attorney John Graham presented testimony on an epidemiology study that showed water fluoridation was linked to an increase in cancer. And…


Melissa Gallico: I believe those hearings were held with Dean Burk, the head of the cytochemistry department at the National Cancer Institute.


Dr. Hirzy: Yeah, it was Dean Burk. That's right, Burk. The Congress was taken back by that and said, ‘Well, hey. We can't be putting a known carcinogen in the drinking water. Let's get the National Toxicology Program to do a study on the toxicity of fluoride, the carcinogenicity of fluoride.’ And so that started back in the ‘80s. Ultimately, after a few false starts because the animals were dying because of other causes, we can go into that, but the bottom line was that by 1990/1991, the research was done on this carcinogenicity study and it showed that an increase in osteosarcoma in male rats was linked with the fluoride exposure. And the first finding, the first publication coming out was a finding from the toxicologists (the study toxicologist and the review toxicologist) looking at the slides of these cancers and said there is “clear” evidence of carcinogenicity of sodium fluoride in male rats. Well, clear evidence of carcinogenicity in male rats in the substance that we put in drinking water would have been the end of water fluoridation. So, a review of that study was undertaken and after a lot of to-ing and fro-ing the classification came back to “equivocal” evidence of carcinogenicity in male rats.


In order to sustain the original finding of clear evidence, not only was there osteosarcoma in these male rats but there was also a rare liver tumor in rats and in mice. And having carcinogenic lesions in two different organ systems was the basis of that clear carcinogenicity finding, the liver tumors and the osteosarcoma. Well, when they went back and did reviews, like magic all of those liver tumors were downgraded to non-carcinogenic lesions. Basically, they were classified as benign, benign lesions and not carcinogenic lesions. And because of that, the clear evidence of carcinogenicity was changed to equivocal.


Well, Bill Marcus was very close to the toxicologist who was the guy who first discovered this rare liver tumor, and that person and Marcus were aghast at the fact that all of these liver cancers were downgraded to benign lesions. And so they basically... Bill went public with his concern, and the concern of Mel Reuber, I think, who was the guy who was the discoverer of that lesion, and actually talked about it at the National Press Club. Well, EPA was not happy with that. And so they ginned up an excuse to fire him, because Bill was also an expert witness, he was one of the world's experts on lead toxicity. Fluoride wasn't his big thing but he was just an ethical guy. He was, in fact, the union treasurer at the time. But they ginned up some phony charges that he was using official time, that is, that he would go and testify on some of these other toxicology issues in court on government time and on that basis they fired him.


Well, Bill, obviously with the help of the union and a lot of other people, fought that and when the defense went to the EPA inspector general which was the office that was the chief executioner, if you will, in this firing exercise, and demanded to have the time cards that they alleged Bill submitted with respect to these expert witness testimonies, the response of the inspector general was, ‘Oops, sorry. We destroyed all of those cards.’ What?! The evidence that was the basis of firing this man, the inspector general shredded that stuff and discarded it? That was one of the main reasons why Bill was able to—and it was all phony—was able to win his lawsuit and was reinstated back in his position and received a $50,000 compensatory damages award and some other things. But that was how that all worked out. Bill basically stood up for scientific integrity and basically got hammered for it.


Here's an interesting wrinkle on that. I was at another meeting at the National Academy of Sciences right when all of that stuff was happening, when that finding of clear evidence of carcinogenicity came out. And there was a big hall halfway down in this auditorium and an aisle that runs across the auditorium, and I was sitting in the first row. And I don't know who the two guys were who came strolling down the center aisle, but one of them commented, “Have you seen that sodium fluoride bioassay result?” And the other guy said to him, “Don't worry about it. It's all under control.”


Melissa Gallico: Oh, wow.


Dr. Hirzy: That's the honest to God's truth. I will take a lie detector test on that. I don't know who they were, but that was the essence of the conversation between those two guys. “Have you seen the sodium fluoride bioassay result?” And the other guy says, “Don't worry about it. It's under control.” Boom. That gives you an idea of how corrupt this whole shtick is. I mean, there's like I said, $200 million a year to the phosphate industry goes a long way in keeping that hazardous waste disposal stream flowing through our nation's drinking waters.


Melissa Gallico: During the court case that followed Marcus’ firing, his lawyers went through an extensive discovery process that uncovered improper communications between chemical companies and EPA managers that prove these companies orchestrated Marcus's removal. It was ultimately very embarrassing for the EPA because the case revealed, as you mentioned, that EPA managers shredded document in violation of a subpoena. Marcus won his lawsuit on every count and was ordered to be reinstated with full back pay. He was also awarded for damages and for all his legal fees and the judge concluded that he was indeed fired because of his position that fluoride is a carcinogen. After Marcus was reinstated to his job at the office of drinking water, did EPA managers ever address his concerns about the cancer studies?


Dr. Hirzy: Not to my knowledge, no. What eventually flowed from that though is that it kind of leads into another aspect of the cancer issue which was that in 2003, EPA undertook what's called a 6-year review of their drinking water standards for a number of water pollutants, including fluoride. And they asked the National Academy of Sciences to undertake this review. And for the first time... I sat it on a previous review back in 1990 and the people who are doing the review then were basically all people who were on the record as being pro-fluoridation, as getting grant money from various sources to do research on fluoride and so forth and so on. But when the National Academy asked the National Research Council to convene a committee to conduct this review in 2003, it was for the first time a balanced panel that had people on the record as being pro-fluoridation and other people who were very much concerned about the toxicity of fluoride, including Dr. Hardy Limeback and Dr. Kathleen Thiessen, among others who were concerned about various aspects of fluoride toxicity.


During that review, when the issue of carcinogenicity came up, there came to light a document called Final Report on an epidemiological study of osteosarcoma in young boys. This so-called final report was literally one page, one side of one page, 8.5 x 11, that was titled, Final Report. This was conducted by a guy named Professor Douglass at Harvard. He said the preliminary results showed (what’s called in epidemiology) an odds ratio of 1.2 to 1.4. An odds ratio of 1.2 would mean there would be a possible 20 percent increase due to the substance which was under study. Or 1.4 would mean a 40% increase of the cancer incidence, in this case.


And on the back page, on the reverse side of that, of that final report there was reference to a PhD thesis by a person named, a woman named Bassin. And the folks who were interested in this went to Harvard and it was basically, her PhD thesis was the study that was funded by this NIEHS grant. Groups who were concerned about fluoride toxicity went to Harvard and they couldn't find it. They were told it was in the rare books section and it was restricted. They said that you couldn't see it. And they said, “Well, wait a minute.” And then they finally said, “Well, you can see it but you can't make a copy of it.” “Well, you can make a copy but you can only make a 6-page copy at a time.”

Well, our folks went back and, copying six pages at a time, eventually got ahold of the whole thesis of Elise Bassin. And lo and behold, it wasn't a 40 percent increase that was found. It was more like a 400 to 500 percent increase in osteosarcoma in young boys who were drinking water that was fluoridated at the so-called optimum level versus fluoride down around 0.2 or 0.3 parts per million. That is, drinking water at 1 ppm versus 0.2 ppm, the odds were that they were four to five times more likely to get osteosarcoma with that higher fluoride exposure.


Well, a number of things flowed from that. The Environmental Working Group, an environmental integrity organization based here in Washington DC, filed a complaint against Dr. Douglass for basically research misconduct because he testified, Douglass testified before the committee that was doing the review of EPA's drinking water standards and testified to the fact that there was, you know, the difference between the odds ratio was no different than one. In other words, there wasn't any statistically significant increase in cancer in osteosarcoma in these young boys—there wasn't any significantly significant difference. Elise Bassin's piece that he had signed off on, that Douglass had signed off on, said it's a factor of 4 to 5 not 1.2 to 1.4. It’s a factor of 4 to 5 at age 7 (it peaks at age 7). And Bassin’s thesis eventually was published in Cancer Causes & Control which is a peer-reviewed journal. So Environmental Working Group filed this complaint with Harvard University against Douglass, Chester Douglass is his name, and Harvard eventually came back and said, “Well, we find that Chester Douglass was not guilty of research misconduct and oh by the way, the fact that he gave a million dollars to Harvard University and its dental research operation had no role in our decision to whitewash this.” No, Harvard didn't exactly come out and say that. Harvard came out and said he was not guilty of research misconduct and they didn't mention the fact that Douglass had literally donated $1 million to Harvard’s dental research institute.


Melissa Gallico: Why would this Harvard Professor want to conceal evidence that fluoride causes bone cancer in young boys? Did he have a financial stake in fluoridation or any conflicts of interest with the dental industry?


Dr. Hirzy: Well, he was also the editor of a newsletter that was published by Colgate company which is the producer of fluoridated toothpaste. He was the editor of a magazine that was published monthly, I think.


Melissa Gallico: For anyone who wants to learn more about the Bassin study or William Marcus and his lawsuit against the EPA, I'll put some links in the show notes including to the National Whistleblower Center's website where you can read the court documents about Marcus' case, view news stories, and even watch a video of Dr. Marcus speaking at a press conference following the court's decision to reinstate him to his job at the EPA.


But now I'd like to talk about your testimony in front of the United States Senate in June 2000. That must have been a surreal experience and possibly the closest the anti-fluoridation movement has come since the 1970s in getting the attention of Congress. How did the presentation come about and how were you selected for it?

Dr. Hirzy: Some anti-fluoridation activist in New Hampshire went to their Senator, Senator Smith, and asked him to look into this and gave my name to him. So Senator Smith contacted me and asked me to come to testify at a hearing in which the subcommittee was looking at some drinking water regulation issues. They were focusing on arsenic. So I was invited to give testimony on fluoride, which I did.

Melissa Gallico: I’ll put a link in the show notes for any of our listeners who want to watch the video of your congressional testimony on fluoridation on behalf of the EPA union of professional employees, but can you summarize for us what you said in that hearing?


Dr. Hirzy: Well, among other things, I called for certain things to take place. I wanted to have a reopening of those slides on the liver tumors in the National Toxicology Program bioassay where I ask for a toxicity study on hydrofluosilicic acid. I asked for a joint Congressional review of the whole water fluoridation program. At that time it had been a long time since 1979, since Congress had looked at it, and here we were 21 years later rolling right along and Congress hadn't looked at that stuff in any kind of detail. And I pointed out that when independent... there were three lawsuits testing the constitutionality and the validity of putting fluoride in drinking water. Three judges independently in Pennsylvania, Illinois, and Texas, after listening to weeks of testimony from both sides, all three found that putting fluoride in drinking water basically shouldn't be done. I pointed out the significance of that, that here are these judges who had no dog in the fight and they listened to testimony from both sides of the issue, and when someone with an open mind hears both sides of the issue on this subject—this is a very important point—they came to the same conclusion, that this is not a good thing to do. This has adverse health effects. It has no beneficial effects and it has adverse health effects. We should stop it. But those decisions by those judges were obviously challenged by interests who benefit by being able to put fluoride in drinking water or who are teaching students that that's a good idea. And on the basis of police power, the fact that legislators can mandate this kind of thing, they overturned those decisions of those judges and allowed fluoridation to continue in those jurisdictions in Pennsylvania, Illinois, and Texas. At that point, we hadn't gotten into the cancer stuff as deeply as we subsequently did with the Bassin work but I did point out that at that time there were only a couple of studies in China showing fluoride to be neurotoxic in children and that has subsequently gotten a whole lot more significant in recent years.


Melissa Gallico: I wanted to ask you about that. You retired from the EPA in 2004 but you're still active with the effort to research and bring awareness to the health risks of fluoridation. In December 2016, I believe, you co-authored a risk analysis of fluoride as a neurotoxin in children and briefed officials at the Office of Drinking Water at EPA headquarters on that topic on multiple occasions. What was the goal of that study and how did the officials react to the information you provided?


Dr. Hirzy: Jumping to the last part first, they said, “Well, we'll take this under consideration in our next six-year review.” So, we can figure in 2022, EPA might think about it. (laughing)


So, that came about because in 2012, a study was published by researchers at Harvard in Environmental Health Perspectives that showed that children exposed to higher levels of fluoride had lower IQ than children with lower exposures. It was a meta-analysis of a number of studies in which they looked at some 35 or 37 studies altogether, of which 26 met their criteria for validity. And of the 26, or it might have been 25 studies, that met the criteria, 24 of the 25 found that higher fluoride exposures were linked to lower IQ. And what I and my fellow authors on this did—Paul Connett, David Kennedy, Bruce Spittle and  Quanyong Xiang from China—we looked at the dose-response information that was published in that meta study. We assumed conservatively, which means we looked at what we thought would be the lowest fluoride exposure that cause this kind of problem which was 3 parts per million. Some of the studies had fluoride levels as high as 11 parts per million. Most of the studies were much lower than that and we figured, “Well, let's takes 3 ppm as a place where this adverse effect kicks in.” And what we did was then to apply standard risk assessment methodology to calculate what would be a safe dose at which one would expect to have no effect on IQ. And we came up with a level that would be about 0.05 parts per million which is well below the recommended level which is now at 7 parts per million. It's more than ten times below that so-called safe level.


Melissa Gallico: How interesting that the number you came up with in your study is the exact same number that I've seen in studies where they've calculated the mean fluoride content of fresh surface water. Proponents of fluoridation like to point out that fluoride occurs naturally in high amount in some water supplies. And that's true, but it's usually from deep water wells or wells at the base of large mountain chains where the geologic movement of the Earth has pushed fluoride up to the surface. Or maybe around volcanoes, because fluoride is a common emission from volcanic eruptions which is one of the reasons they are so dangerous. But the mean fluoride content of freshwater—the kind of water that humans have been drinking, for the most part, throughout human evolution—is 0.05 parts per million, the exact number that you came up with when you used the correct processes to identify the safe amount of fluoride in drinking water. So, maybe Mother Nature knows what she's doing after all.


Dr. Hirzy: (laughing) Yeah. Well, that was applying two different kinds of risk analysis methodologies. One is a method in which one applies safety factors to the effect level to account for diverse responses in human beings. And we applied the safety factors and came up with about 0.05. And then we also used a computer program that looked at the dose-response information that was available, a couple of the studies provided really good dose-response data, that is, they had kids who were exposed at around 4.5 ppm, 3 ppm., 2 ppm., and around 0.7 ppm. And the IQs, the mean IQs that kids had at those levels, you got a curve basically, or a graph. And by extrapolating on that graph we came up with again, a figure of around 0.05.


And what was really interesting and extremely gratifying was, we published this in December 2016. The following year, in September of 2017, an epidemiological study funded by none other than the U. S. Environmental Protection Agency and the National Institute of Environmental Health Sciences and the Mexican Government in which they measured fluoride urine levels in pregnant women and then measured the intellectual development of the children who are born of these women. And, let me back up just a second, in our study that I and my fellow authors produced, we predicted the difference between high fluoride and low fluoride exposures in the U. S., we figured the low fluoride exposure would be around .5 milligrams a day and high exposure about two milligrams a day, a factor of 4 basically, that we would see about a five IQ point difference in kids between those two fluoride levels, all other factors being equal. It's a very... IQ is responsive to a whole lot of different things besides fluoride levels, but with all other things being equal, based on the dose-response relationship we predicted about a five IQ point difference. This other study that was funded by the EPA, NIEHS, and the Mexican Government showed that the difference between high fluoride urine levels in moms and low fluoride levels in moms—and the high fluoride levels were equivalent to the urine fluoride levels in women in the U. S. who live in fluoridated communities. The children who were born of the higher fluoride level in moms were about three IQ points below the low fluoride urine moms. And the difference between the prediction that we made of five IQ points versus three IQ points we figured was, as we used to say when I worked in the private sector, close enough for government work. So, we were very gratified to see that result. There have been some subsequent studies which further fit into this pattern of higher fluoride exposures in utero, the kids that are born have lower IQs. They measured them in this particular study at ages six and thirteen.


Melissa Gallico: These studies are really important, not just at the individual level when you think about how these chemicals that the government is advocating for the public water supply are having a negative impact on the neurodevelopment of your child and the IQ of your child, but also at the societal level because a difference of three IQ points on a national level means we have that many fewer geniuses in the society or that many more people with mental challenges.


Dr. Hirzy: That's exactly right. When we did our estimate of five IQ point differences the bell curve in the population as it existed in 2016, it would be around about four million fewer geniuses and about the same number of people whose IQs would be below 80. And in addition, there are a number of studies, mostly done on mercury pollution, that have been done showing what the economic impact is on an individual basis. And in essence, pretty much the peer-reviewed agreed-upon numbers are that for a male, a one IQ point drop cost about $20,000 lifetime income and for a female it's about $24,000 lower lifetime income. So that's for one IQ point drop. So if you look at three IQ points, you know, you multiply those numbers and it's not only at a population level difference it's an economic difference. The average birth cohort is around three million males and females born every year and if you start looking at one IQ point drop in that number of individuals, it is a significant blow to the national economy.


Melissa Gallico: In addition to your ongoing research, you're also currently serving as a volunteer science and regulatory affairs adviser to the Fluoride Action Network, one of the most prominent nonprofit groups dedicated to ending artificial water fluoridation around the world. FAN, as it's known, is currently engaged in a lawsuit against the EPA and they're arguing that the EPA’s fluoridation policy is in violation of the Toxic Substances Control Act. Can you tell us more about that lawsuit?


Dr. Hirzy: Okay. Back in 1985 when Bob Carton and I first started worrying about the EPA’s science behind the proposed regulation for fluoride in drinking water, we went to the inspector general (IG) and said, ‘This is fraudulent stuff’ and the IG said, ‘Oh, well, we don't really get into science.’ And so we noodled on this and said let's go talk to Ralph Nader about this. And so we went over to see Ralph across town. And he said, ‘Well, I've never had a really warm feeling about water fluoridation and one of my guys, one of the old original Nader's Raiders is Jim Turner who's got an office across the street. Why don't you go talk to Jim.’ So we did. And we talked to him a number of times about different ways to approach this and I said, ‘You know, the way to really deal with this is section 21 of the Toxic Substances Control Act (Tosca) with its citizens’ petition where we petition the agency to stop putting this stuff in drinking water because of the science as it existed back in 1985. And so we talked about that and we eventually moved on to other things and it never went out of my consciousness. Then the neurotoxicity data came to the fore in 2012 and it really kicked the Tosca section 21 back into the forefront of everybody's thinking, mine and the leadership of FAN in general. And Michael Conant who had been following the science on fluoride, all kinds of toxicology information that was being published, Michael really glommed onto that. He went off to law school and got his law degree.


Melissa Gallico: Wow, talk about the long view.


Dr. Hirzy: Oh, big time. I mean, really big time. Ellen has spent time in prison over this stuff. But anyway, be that as it may, Michael picked up on the section 21 stuff and ran with that and so, in the fall of... oh, let's see, I guess, it was the fall of 2016, FAN and some other folks filed a petition with EPA based largely on the neurotoxicity information as it existed, that EPA should ban the addition of fluoride-containing chemicals in the drinking water. EPA has 90 days to respond to Tosca section 21 petitions and 90 days later they denied the petition which was pretty much expected. So, at that point, section 21 has a remedy. If the agency doesn't respond within 90 days or if it denies a petition, that the petitioners can file a lawsuit in a federal district court for a trial de novo, that is, from the beginning based on just the facts. So within 30 days of the denial, FAN filed such a petition. The agency took its time, eventually filed a motion to dismiss, we filed counter motions, and back and forth we went. The lawsuit is filed in the northern US District Court, federal district court in Northern California and a trial date is set for this August. There have been depositions of EPA people. Bob Carton and I are to be deposed in May at some point, and we will be going forward with this lawsuit. We think we have the facts on our side.


We are very sanguine about our chances but one of the things that would really... it costs a fair amount to do this kind of thing, to deal with all of the expenses. I don't know if this is the place to make a pitch for help from the outside but if anybody is interested in helping to stop the practice of putting this toxic material in our drinking supply, get in touch with the Florida Action Network and put whatever resources you can spare into this Tosca filing. It would really help. We are optimistic about being able to win.

Melissa Gallico: Yes, this is the perfect place to make a pitch for that. And so to anyone listening who wants to help bring an end to this dangerous practice of putting fluorosilicic acid in public water supplies, I'll leave a link in the show notes to where you can donate money to help with the lawsuit.


We ended Dr. Cartons interview talking about a quote attributed to him about the scientific fraud surrounding fluoridation, but I have to tell you that you were the source of my favorite quote about this whole controversy when you said, “They’re riding a tiger and they can't get off.” I just think that is such a descriptive way to explain why the federal government continues to promote fluoridation despite decades of dissent from toxicologists, from world-renowned dental experts like Dr. Limeback who we heard from back in our first episode, from the public, from their own scientists... and I think public health officials are afraid that if they admit they were wrong about fluoridation, the tiger will eat them. Are you able to envision a time when this practice of adding fluorosilicic acid to public water supplies is no longer endorsed and promoted by government institutions and if so, what do you think it will take to bring about that kind of change?


Dr. Hirzy: My hope is on this lawsuit. If the past is prologue, the three trials that I referenced in my testimony in 2000 before the Environment and Public Works Subcommittee of the Senate, in those three trials, the judges listen to testimony for weeks, both sides testifying, and came to the conclusion that putting fluoride in drinking water is not a beneficial practice. And the strength of our position has only gotten better and better and better over the years. I mean, these were trials that took place as early as the late 1970s. And now with this neurotoxicity data, including studies that were funded by the National Institute of Environmental Health Sciences and the U. S. Environmental Protection Agency, showing the adverse effect of in utero exposure to children’s intellectual development, how in the world can we possibly lose except for... I don't see how we can lose. I mean, they are always weird technicalities possibly but on the facts, we must prevail.  And that's where my hope lies. Because fighting this on an individual city or state basis, it is effective to some degree. I mean, I have testified from California to Colorado to Texas to Florida to Massachusetts numbers of different times.... Arkansas... Paul and I have been together in a number of these places. Hardy Limeback has been to these places. It is a wearying and expensive difficult process, but it's effective because people are educated. But to put the hemlock stake into the heart of this monster, this Federal lawsuit, I think, is the way to do it. I've always thought that and my hope is by sometime this fall we will finally prevail.


Melissa Gallico: Dr. Hirzy, it was an honor to speak to you today. You are such a dedicated public servant and truly one of America’s great science heroes. Thank you so much for being on the show.


Dr. Hirzy: My pleasure, indeed. My pleasure, indeed.

Melissa Gallico: My guest, Dr. J. William Hirzy worked in environmental and human health risk assessment for 35 years. In addition to his position as a senior risk assessment scientists at EPA headquarters, he served four terms as president of the EPA union of professional employees and was a chemist-in-residence and adjunct professor at American University. He has a PhD in chemistry from the University of Missouri. To learn more about the union's historic opposition to artificial water fluoridation, visit


If you enjoyed this episode of the #Fpollution podcast, please subscribe—and leave a review. It really helps other listeners find the show. This episode was executive produced by Linda Peterson, Scott Cousland, Linda Palmisano, and Kristie Lavelle. To find out how you can support the show by becoming a producer at Gallico Studios, or to sign our petition to end fluoridation, visit our website at


Thanks for listening.

*The information presented in this episode reflects the views and opinions of the host and guests invited to appear on the show. It is not intended as medical advice and does not represent the views of the FBI, the U. S. government, or any other individuals or organizations.



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