Dr. de Villa: You misled the Fluoridation Committee: Health Canada Guidelines do NOT ensure safety

From: Christine Massey
Date: Tue, Dec 6, 2016 at 8:57 PM
Subject: You misled the Fluoridation Committee: Health Canada Guidelines do NOT ensure safety
To: “de Villa, Eileen”

Dear Dr. de Villa,

You have been advising/encouraging Peel Councillors to violate Canada’s Food and Drugs Act and Section 20 of Ontario’s Safe Drinking Water Act which states that “no person shall cause or permit any thing to enter a drinking water system if it could result in … a drinking water health hazard….” and “Dilution No Defence”. 

Violation of Section 20 is deemed a criminal offence (as explained is this legal opinion that was formally presented to the Region by lawyer Nader Hasan in June 2014: http://fluoridealert.org/wp-content/uploads/peel.june2014.pdf).

Proof that arsenic and lead are found in the Region’s fluoridation chemical, industrial grade HFSA, which is not even graded for purity (as confirmed by the Region of Peel’s Supervisor of Water Quality and Compliance, Justyna Burkiewicz) is shown in this certificate of analysis from Lakeview Water Treatment facility in Mississauga (ON; As = arsenic, Pb = lead), which you have been provided repeatedly over recent years: http://www.fluoridefreepeel.ca/wp-content/uploads/2013/07/20130705121108426.pdf)

At the Fluoridation Committee’s last meeting, you insisted that industrial grade HFSA (toxic waste) added to municipal drinking water is safe for public consumption, based on guidelines for individual contaminants established by Health Canada.  You misinformed the Committee.

Please note the following:


  • Health Canada’s guideline for arsenic, classified as a human carcinogen (maximum acceptable concentration, MAC, 0.01 mg/L ALARA as low as reasonably achievable), also states “MAC based on treatment achievability;  … levels should be kept as low as reasonably  achievable”.
  • The EPA’s Public Health Goal / Maximum Contaminant Level Goal (MCLG) for arsenic is zero.  “Definitions:  Maximum Contaminant Level Goal (MCLG)—The level of a contaminant in drinking water below which there is no known or expected risk to health. MCLGs allow for a margin of safety and are non-enforceable public health goals.”  https://www.epa.gov/ground-water-and-drinking-water/table-regulated-drinking-water-contaminants#one

You misled the Fluoridation Committee of the basis of Health Canada’s guideline for arsenic (it is not based on safety), and you failed to advise the Committee of Health Canada’s advice to keep arsenic levels as low as reasonably achievable.

Further, the Province of Ontario’s enforceable standard (the enforceable allowed limit) allows 2.5 times more arsenic than Health Canada’s guideline.  You did not advise the Committee of this either.

Standard (expressed as a maximum concentration in milligrams per litre): 0.025

The Ontario Drinking Water Advisory Council recommended to the Ministry in 2006 that the arsenic standard be brought in line with Health Canada’s guidelines (see attached letter), as did the Canadian Environmental Law Association (CELA) in 2015, but the province has thus far failed to amend the provincial standard.

According to CELA, the estimated lifetime risk of excess internal organ cancers for the current enforceablestandard is 3 to 39 additional cancersYou did not advise the Committee of this either.


  • Health Canada’s guideline for lead (MAC 0.01 mg/L) has not been re-assessed since 1992, and it states “Exposure to lead should nevertheless be kept to a minimum.”
  • The World Health Organization states that “There is no known level of lead exposure that is considered safe”  http://www.who.int/mediacentre/factsheets/fs379/en/
  • The EPA’s Public Health Goal / Maximum Contaminant Level Goal (MCLG) for lead is zero.  “Definitions:  Maximum Contaminant Level Goal (MCLG)—The level of a contaminant in drinking water below which there is no known or expected risk to health. MCLGs allow for a margin of safety and are non-enforceable public health goals.”  https://www.epa.gov/ground-water-and-drinking-water/table-regulated-drinking-water-contaminants#one
  • The (10 parts per billion threshold) is obsolete,” says Dr. Bruce Lanphear, a health sciences professor who specializes in lead exposure in children at Simon Fraser University. “We’ve got science that is conclusive, definitive and evaluated by independent advisory boards but policy hasn’t kept up with that.”  …  Kathleen Cooper, senior researcher and lead expert with the Canadian Environmental Law Association, says there is “incredibly solid evidence to say there is no safe level (of lead).”  http://www.thestar.com/news/gta/2014/05/20/water_quality_tests_data_shows_elevated_lead_levels_in_toronto_homes.html

You misled the Fluoridation Committee regarding Health Canada’s guideline for lead in 1) neglecting to inform them of the advisory to keep lead levels to a minimum and 2) in neglecting to inform them that this guideline is grossly outdated.

Guidelines for Canadian Drinking Water Quality – Summary Table

“Acronyms… ALARA as low as reasonably achievable”


The screenshots below are taken from the pdf Guidelines for Canadian Drinking Water Quality Summary Table, October 2014, accessed November 25, 2016  http://www.hc-sc.gc.ca/ewh-semt/alt_formats/pdf/pubs/water-eau/sum_guide-res_recom/sum_guide-res_recom_2014-10_eng.pdf

Inline image 1

Further, you consistently ignore the issue of synergistic effects between HFSA and other contaminants.

Please let me know whether you plan to advise the fluoridation committee with this critical information.

Best wishes,

Christine Massey
Fluoride Free Peel



From: Christine Massey
Date: Mon, Jan 30, 2017 at 8:53 PM
Subject: no evidence that HFSA dissociates 100% in municipal water
To: “de Villa, Eileen” <Eileen.deVilla@peelregion.ca>,
“Lockyer, Kathryn” <Kathryn.Lockyer@peelregion.ca>,
“ZZG-Regionalclerk@peelregion.ca” <ZZG-Regionalclerk@peelregion.ca>,
“Smith, Janette” <Janette.Smith@peelregion.ca>,
“patrick.o’connor@peelregion.ca” <patrick.o’connor@peelregion.ca>,
“Szwarc, David” <David.Szwarc@peelregion.ca>,”Dale, Frank” <frank.dale@mississauga.ca>


Dear Dr. de Villa, Ms. Lockyer, Ms. Smith, Mr. O’Connor, Mr. Szwarc and Mr. Hennings,

It has been approximately 8 months since Councillor Sprovieri informed Dr. de Villa that the cited 2006 study by Finney et al is not remotely generalizable to water fluoridation, as per my emails sent to all of you on September 6, 2016, October 18, 2016, and November 21, 2016, below.

Have any of you done your due diligence on this urgent matter relating to both the safety and legality of the Region’s water fluoridation program?

Please note that Dr. de Villa repeated her insistence that HFSA dissociates 100%, and made many other unsubstantiated claims, during recent presentations to the Fluoridation Committee which took up the entire meeting and allowed no time for questions from Committee Members.

Dr. de Villa made reference to “studies” but provided no references on this topic whatsoever.  She stated that “most studies” had been carried out using “distilled water” and claimed that ph level is the crucial factor in determining HFSA’s behaviour in drinking water.

Dr. de Villa, please provide all of the “studies” you rely upon when insisting that industrial waste HFSA dissociates 100% in our drinking water.  Further, please provide all studies relied upon if you also insist that HFSA stays dissociated even in acidic conditions such as coffee, tea and GI tracts.

Best wishes,
Christine Massey
Fluoride Free Peel

From: Christine Massey
Date: Tue, Jan 31, 2017
Subject: “pitted brown staining” in most severe form of dental fluorosis
To: Eileen.deVilla@peelregion.ca

Dear Dr. de Villa,

According to your department’s 2012 “Immigrant and Ethnocultural Health” report: https://www.peelregion.ca/health/resources/pdf/immigrant-ethno-health.pdf

“Fluorosis  is caused by excessive  exposure to fluorides during early  childhood. Fluorosis results in tooth  discolouration, which may range  from patchy white staining of the  tooth enamel in its mildest form,  to pitted brown staining in its most  severe form.

This is quite different from the description provided on your department’s webpage:

Dental fluorosis is largely a cosmetic condition and occurs when too much fluoride is ingested by children during the early stages of tooth formation. In Peel, dental fluorosis typically occurs in its mildest forms and can result in the discolouration of the tooth surface. This is often only detectable by a trained professional and does not impact the tooth’s function.

Surely all Peel residents deserve to know that pitted brown staining can result from fluoride overdose. Will you please update your website with this information?

We already know that in Peel Region, in 2001/2002 the prevalence of moderate and severe dental fluorosis among surveyed children was 4% (3% with moderate fluorosis, 1% with severe).  See page 14: https://www.peelregion.ca/health/health-status-report/dental-health/pdfs/dh-full.pdf.

When do you plan to release updated statistics on dental fluorosis in Peel children?  I find it exceedingly odd that after having an CWF committee for 2 years and continually hearing that your department is monitoring the fluoridation situation so carefully you still haven’t provided updated local statistics.  Surely the statistics on our own children right here in fluoridated Peel are more relevant that the Canada-wide statistics on moderate and severe dental fluorosis that you quoted to the CWFC, especially since most Canadians do not have fluoridated tap water.

Also, I’m not sure that you mentioned to the CWFC that 40% of Canadian kids now have some form of dental fluorosis even though most Canadians do not have fluoridated tap water (Table 39, page 107: http://publications.gc.ca/collections/collection_2010/sc-hc/H34-221-2010-eng.pdf).  Maybe I just missed that part.  Did you tell them this?

What other forms of fluorosis and signs of fluoride toxicity is you department monitoring?  Fluorosis can manifest in many different ways, as Dr. Susheela so clearly explained to the CWFC. http://www.fluoridefreepeel.ca/wp-content/uploads/2016/11/Fluorosis-and-Associated-Health-Issues.pdf


Your department’s 2012 “Immigrant and Ethnocultural Health” report also says that:

Oral infections can affect a person’s psychological and social well-being

Do you suppose that pitted brown staining from fluoride overdose might affect psychological and social well-being as well?

Best wishes,
Fluoride Free Peel

Date: Wed, Feb 1, 2017
To: Eileen.deVilla@peelregion.ca
Ontario Public Health Standards & Fluoride: professionally applied only?

Dear Dr. de Villa,
At one of the recent CWFC meetings, I believe you referenced the Region’s obligation under the Ontario Public Health Standards to provide residents access to fluoride. I am concerned that you gave Committee Members a false impression that fluoride in drinking water satisfies a statutory requirement.
Please note that the following information was pointed out to you, Dr. David Mowat, Health Commissioner Janette Smith, and Councillor Moore, by me via email, back in January of 2014.
Regarding fluoride, the Ontario Public Health Standards, 2008 only states:
The board of health achieves timely and effective detection and identification of communities with levels of fluoride outside the therapeutic range.”
The board of health shall review drinking water quality reports for its municipal drinking water supply(ies) where fluoride is added. These reports shall be reviewed at least monthly and, where necessary, action shall be taken in accordance with the Protocol for the Monitoring of Community Water Fluoride Levels, 2008 (or as current).”
It also states that “children in need of preventive oral health services receive essential clinical preventive oral health services”… not toxic industrial waste in tap water.
The Protocol for the Monitoring of Community Water Fluoride Levels states:
This protocol applies to boards of health whose jurisdiction includes community water systems to which fluoride is added.”
When fluoridation ceases in Peel Region, this protocol will no longer apply. While it does apply, it requires scientific evidence and local surveillance data.
The Preventive Oral Health Services Protocol states:
Professionally applied topical fluoride (PATF)
The board of health shall:
a) Offer PATF to children where two or more of the following criteria apply….”
[Professionally applied topical fluoride, not toxic waste in tap water. Forced drugging via artificial water fluoridation cannot satisfy the above.]
“...i) Water fluoride concentration is less than 0.3 ppm
ii) Past history of smooth surface decay
iii) Presence of smooth surface decay
The Preventive Oral Health Services Protocol appears to discriminate against children living in areas with high fluoride concentration in tap water. Children in high fluoridate areas must have both a history of smooth surface decay and current presence of smooth surface decay in order to qualify for PATF, whereas children in areas with low fluoride concentration in their tap water need only one or the other.
All children deserve legitimate dental care. As far as I can tell, the fluoridation of our drinking water ensures that fewer Peel children legally qualify for professionally applied topical fluoride. Please confirm whether this is true, and also whether the Region of Peel gives equal access to PATF for children in both low and high fluoride areas.
Please also confirm my understanding of the Region’s statutory requirements regarding the provision of fluoride. Is it true that the only statutory requirement is professionally applied topical fluoride for qualifying children?
Please note that forcing our entire community to deal with neurotoxic, carcinogenic, endocrine-disrupting, enzyme-inhibiting industrial waste in our drinking water only widens the gap between rich and poor because the poor are far less able to afford a safe water source and professional dental care.
Best wishes,
Christine Massey

Update February 1, 217: Dr. Eileen de Villa appointed Toronto’s new medical officer of health

After turning a blind eye on the overdosing of babies, Dr. de Villa is  “…described as a “distinguished scholar and physician”…

God help the people of Toronto.

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