Tuesday, April 26, 2016

Open letter to Dr Pamela Byrne CEO Food Safety Authority of Ireland and Dr Leo Varadkar Minister for Health

Dr Pamela Byrne, CEO Food Safety Authority of Ireland and Dr Leo Varadkar, Minister for Health

In 2013, I wrote to the CEO of the FSAI and the Minister for Health addressing inaccuracies and scientific irregularities in the total diet survey published by the FSAI in 2010. My concerns specifically addressed how the data on fluoride content in tea products, as well as other beverages such as beers and stouts sold in Ireland where incorrect and significantly under-represented the fluoride concentration, and thus, exposure of consumers to dietary sources of fluoride.

In my previous communications with the FSAI, I forwarded literature specific to risk assessments of fluoride intake from tea undertaken internationally. However, as noted, per capita tea consumption is Ireland is the highest in the world, therefore, the risk of chronic fluoride intoxication is significantly higher in the Republic of Ireland compared to other tea consuming nations. This is particularly the case as drinking water is artificially fluoridated in the RoI, a policy that is not supported in the vast majority of countries internationally. 

Three years ago the FSAI informed me that a second dietary intake study was to be completed in 2013. In undertaking this assessment, the FSAI informed me that they would address my concerns regarding previous methodologies undertaken by the FSAI and in which the fluoride content in tea products, beverages and foods prepared with fluoridated public water supplies would be examined.

As of April 2016, the results of this assessment have yet to be published. In the interim, due primarily to concerns regarding the long term health implications of chronic fluoride intake and lack of available data on fluoride content in Irish tea products, I undertook along with Professor Hardy Limeback, Professor William Potter, and Dr Mike Godfrey, a risk assessment measuring the fluoride content in 54 black tea products for sale in the RoI. This study was published in the International Journal of Environmental Research and Public Health [Int. J. Environ. Res. Public Health 2016, 13(3), 259; doi:10.3390/ijerph13030259].  We have undertaken a similar study for tea products in New Zealand, which is currently being peer reviewed for publication. The findings of this study further support the observations and conclusions of our original study specific to Ireland.

It has recently come to my attention that the FSAI have examined our study on fluoride intake from tea in the RoI and suggested that the intakes of tea examined in our study overestimate the contribution of tea to fluoride intakes in the Irish population. The opinion of the FSAI is based on data on tea consumption from the Irish Universities Nutrition Alliance (IUNA) national dietary surveys. The FSAI noted that the IUNA assessment measured tea consumption in age groups from 1 to 90 years.  The FSAI should be aware, that the IUNA 2001 study did not measure tea consumption in persons 1-90 years of age. It had a statistical number of 1379 persons and only asked people aged 18-64yrs, excluding the highest tea consumers in Ireland who are the elderly. It did also not include pregnant women.

The IUNA study reported that among the age group 18-64yrs, ninety one percent of the sample drank tea with an average daily consumption of 619 ml. However, it should be noted that the IUNA study was undertaken over a 7 day period and did not differentiate whether individuals drank tea from a mug or cup. Moreover, the study did not disclose what season the survey was undertaken. International studies have shown that since the 1980s tea is predominantly consumed in mugs by individuals in western countries. A mug size is substantially larger in volume compared to a cup. In addition, hot beverages such as tea are consumed in greater quantities in the period September to May, when temperatures are colder than the summer months.  From the case studies of habitual tea drinkers I have documented in the RoI, I have personally met numerous individuals who consume up to ten mugs of tea daily. In almost every instance, these individuals reported suffering from multiple morbidity of chronic diseases including chronic pain, diabetes or hypothyroidism.

Moreover, in comparison to the IUNA study, the Australian dietary study of 2008, based on a sample size of over 13,000 subjects reported that the mean consumption of tea for males aged 30-49years was 1004 ml and 1090ml for males aged 50-69years. For females the figures were 984 and 1018 mls respectively. Considering that Ireland has a 3 fold higher per capita consumption of tea than Australia, and the statistically higher quality of the Australian study, this suggests that data on tea consumption in Ireland as noted by the IUNA study is inaccurate. 

In our study, four scenarios were examined, consumption of 250 mL (about 1 cup) per day, 1 litre per day (4 cups or 3 mugs of tea per day), 1.5 L per day (6 cups or 4 mugs per day) and a reasonable maximum intake of 3.8 L per day (15 cups or 10 mugs per day). Based on the available evidence, for the FSAI to suggest that the intakes examined in our study overestimate the contribution of tea to fluoride intake is not based on any rigorous science based assessment or evaluation and is therefore flawed. 

The principal function of the Food Safety Authority of Ireland is to take all reasonable steps to ensure that food consumed, produced, distributed or marketed in the State meets the highest standards of food safety and to ensure that food complies with legal requirements. As noted in our study, the fluoride content in tea products for sale in Ireland do not comply with the requirements of the General Food law Regulation. Moreover, in preparing tea infusions with fluoridated water the risk of cumulative toxic effects increases for consumers. In addition, as noted in our study, evidence suggests that there is a large subgroup of the population particularly susceptible to the adverse effects of chronic fluoride intake due to low iodine intake, malnutrition, Vitamin D deficiency, calcium deficiency and diabetes prevalence.

In conclusion, the FSAI are responsible for putting consumer interests first and foremost. Thus, there is an urgent need for the FSAI to protect public health and consumer interests using the latest and best scientific advice available. Failure to act raises a significant danger to public health. In the current context, the delays in completion of the studies which were to be completed in 2013 are inexcusable and the consequences of this inaction is contributing to the high prevalence of chronic disease in our population. 

Yours sincerely
Declan Waugh
EnviroManagement Services

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