Response to Washington State Dental Assoc. testimony at
Washington State Senate's Health & Long Term Care Committee on
SB 5066 January 30, 2003

Prepared: February 1, 2003 by Sandra Duffy, Esq. E-mail: gruffy3@aol.com

The Mercury Awareness Team (MAT), Consumers for Dental Choice Northwest (CDCNW) and the Coalition to Abolish Mercury Dental Fillings submit, a rebuttal to the misleading information (testimony and documentary submission) provided by the WSDA at the hearing on SB 5066 on Thursday, January 30, 2003.

Dr. Robert Shaw, DDS: said that the use of mercury amalgam is not controversial. He also stated that all federal government agencies say amalgam is safe and there are no credible studies to the contrary. He claims mercury-free activists "pretend" that mercury amalgam is dangerous for people.

Mercury-free activists' response:

• Dr. Paul Rubin, DDS, told the Committee that there is a controversy in the dental profession and over one-fourth of dentists are mercury-free
• No government agency claims that mercury amalgam has been proven safe. The FDA claims it has not been proven unsafe. Shouldn't manufacturers of mercury amalgam have to prove the safety of its product rather than dental consumers having to prove it is unsafe? (To see what government agencies actually say, see Section 8 of the side-by-side table comparing the positions of pro-amalgam and mercury-free dentists, also attached.)
• There are 1000's of studies on the health hazards of mercury generally and amalgams specifically. Have your legislative assistant perform an internet search on PubMed website (www.ncbi.nlm.nih.gov/entrez/query) and type in the search words "mercury amalgam." Just reading the titles of the research articles would give a reasonable person grave cause for concern. We are not "pretending" mercury amalgam is dangerous - it IS dangerous.

Dr. Craig Ellinger, DDS: general practice, Farmworkers Clinic, stated that if mercury amalgam is banned fewer indigent workers will receive dental care because alternatives are so much more expensive and "patients can't afford anything else."

Mercury-free activists response:

• There is no excuse for putting a toxic product in the human body - least of all economics. Lead is cheaper than mercury and is a pliable, serviceable material, but no one would even consider such a move to save money. Yet mercury is more toxic than lead and it has been impossible to get the dental profession to rethink its treatment protocol.
• The medical profession is finally challenging the use of mercury in health care. In 2002 the AMA House of Delegates passed a Resolution to seek alternatives to mercury-containing devices.
• Safe and effective alternatives to amalgam exist. See www.biodent.com.au/diamondlite.html.
• The National Dental Advisory Service Dental Economics, Annual Dental Fees Survey, 1998 published May, 1999 indicates the following retail costs:
1. Amalgam filling:
• One surface - $115
• Two surfaces - $150
2. Composite filling
• One surface - $140
• Two surfaces - $165

Those cost differences are too small to justify the compromises of ethics and health necessary for placement of toxic mercury in human mouths. The healthcare costs associated with the health harm from mercury far outweigh the small cost savings on dental care.

Dr. Werner Geurtsen, DDS, PhD (WG): made the following statements (and the mercury-free activists [M-FA] comments will follow each of Dr. Geurtsen's statements):

(1) WG: All data says mercury amalgams are safe.
M-FA: No data (other than perhaps Dr. G's own 1991 [sic] publication: Amalgam discussion. Question of amalgam toxicity and allergy, Phillip J 1990 Jun;7(3):121-8 which is published in German and for which there is no abstract) concludes amalgam is safe. Mercury amalgam is implicated in gingivitis and periodontal disease, neurological diseases, kidney disease, learning disabilities, depression, diabetes, reproductive impairment, behavioral disturbances, mental illness, serious dermatological disorders, thyroid and pituitary failures and much other health harm. See generally: www.altcorp.com, www.amalgam.org, www.mercola.com, www.dentistry-toothtruth.com, www.toxicteeth.org

(2) WG: The amount of mercury vapor released from amalgams (cited by Dr. G as 5 mcg/day for 40 amalgam surfaces) is far below the WHO threshold of 117 mcg/d for a 165 pound person.
M-FA: The US Environmental Protection Agency (EPA) Health Standard for daily elemental mercury vapor exposure is 0.3 mcg/cm3 of air. The US Agency for Toxic Substances and Disease Registry (ATSDR) health standard (minimum risk level, MRLs) for mercury vapor is 0.2 mcg/cm3. For the average person breathing 20 meters cubed of air per day, this amounts to 4 or 6 ug/day, respectively, for these two standards, according to Dr. Boyd Haley, the preeminent researcher on mercury toxicity from University of Kentucky. He has repeatedly demonstrated that 7.54 mcg/day/sq cm is emitted from undisturbed amalgam surface and 45.49 mcg/day/sq cm for a disturbed surface. This is 758 times higher than ADA's estimate (.057-.067 mcg/day/cm sq). Haley's work confirmed an earlier study by Chew, CL et al, Long term dissolution of mercury from a non-mercury-releasing amalgam, Clinical Preventative Dentistry, 13(3)P:5-7 May-June (1991) (43.5 [+ or - 3.5] mcg/cm sq/day). (Declaration of Boyd E. Haley, PhD, in support of Plaintiff's Opposition to Defendant ADA's Special Motion to Strike. Tibau, et al, v. ADA, California Dental Association, Does 1-2000 [dentists], Superior Court of the State of California, County of San Francisco, Case #322110 [Complaint filed 6-12-00]; see Curriculum Vitae of Boyd Haley, PhD, www.toxicteeth.org)

A World Health Organization (WHO) Scientific Panel in 1995 concluded that there is no safe level of mercury exposure. Friberg, LT, Status Quo and perspectives of amalgam and other dental materials, International Symposium proceedings, G Thieme Verlag Struttgart, 1995. Therefore, there is a quite serious disconnect between the findings of the WHO Scientific Panel and the WHO standard as identified by Dr. G.

(3) WG: There are different kinds of mercury. Amalgams release inorganic mercury and it is the organic mercury in fish that is much more toxic.
M-FA: The inorganic mercury from dental fillings is methylated into the more toxic organic mercury by the bacteria in the mouth and gut of the bearer. Yannai, S et al, Transformations of Inorganic Mercury by Candida Albicans and Saccharomyces Cerevisiae, Applied and Environmental Microbiology, Jan 1991, 57:1:245-247; Rowland, IR et al, The Methylization of Mercuric Chloride by Human Intestinal Bacteria, Experentia, 31(9); 1064-5, Sep 15, 1975; Heintze, et al, Methylation of Mercury from Dental Amalgam and Mercuric Chloride by Oral Streptococci in-vitro, Scandinavian J Dental Research 91(2):150-152 (1983).

(4) WG: You have to distinguish between mercury and amalgam - they are completely different (i.e. mercury is toxic and dangerous and amalgam is not). Amalgam is like table salt which is made of two toxic substances - sodium and chlorine but becomes safe when combined.
M-FA: The mercury in amalgam is identical to elemental mercury. Amalgam is a mixture in which each component retains all of its properties. The mercury in amalgam is highly toxic and vaporizes and leaches out of the amalgam. Table salt is a compound which has properties that are different than its components. Guzzi, et al, The Lancet, 360:2081, Dec 21/28, 2002; David M. Eide, (Grant High School, Portland, OR), The Oregonian, Letters to the Editor, Dec. 30, 2000.

(5) WG: A nurse tried to commit suicide by swallowing mercury and the mercury was not absorbed and she was not harmed. (Presumably this comment was intended to infer that ingesting mercury is not dangerous.)
M-FA: Dr. G rebutted his own statement in his next comment: mercury vapor is absorbed at 80% while ingested mercury has low absorption.

(6)WG: Even though mercury vapor is absorbed at 80% (as opposed to low absorption from ingested mercury), the vaporized mercury is oxidized by the blood (implying the body detoxifies the vaporized mercury).
M-FA: Studies consistently show that people with amalgams have mercury body burden that correlates with the number of amalgams in the mouth and is the main source of mercury in the body. WHO Document #118, p36 (1991); Kingman A, et al, National Institute of Dental Research [NIDR], Mercury concentrations in urine and blood associated with amalgam exposure in the US military population, Dent Res, 1998, 77(3):461-71. NIDR has paid for over 250 scientific studies on mercury amalgam. This study by Kingman is the only one that has been published. One can only conclude that these studies do not exonerate mercury amalgam, and, in fact, confirm its toxicity.

The above-cited evidence shows that mercury bioaccumulates in the bodies of those with amalgams, i.e. the body's detoxing mechanisms cannot keep up with the constant exposure from amalgams.

(7) WG: Cited a Scandinavian study of 1600 women in which it was not possible to correlate between their mercury amalgams and their specific diseases.
M-FA: Lack of a correlation does not equate to proof of safety for amalgam. There are many studies which do correlate diseases to mercury amalgams

Dr. Murray Vimy, Clinical Associate Professor, Faculty of Medicine, University of Calgary, prepared a document which sets out dental journal articles from 1957 to 1984 which very clearly show that mercury amalgams cause gingivitis and periodontal disease. This document can be downloaded: www.testfoundation.org/vimyresponds.html. In turn, periodontal disease has been linked to cardiovascular disease and pre term, low birthweight babies. Greenwell H, et al, Emerging concepts in periodontal therapy, Drugs, 2002;62(18):2581-7.

A 2001 scientific study corroborates the role of mercury in Alzheimer's. The researchers concluded: "…that this visual evidence [of neurodegeneration] and previous biochemical data strongly implicate mercury as a potential etiological factor in neurodegeneration." Leong, CW, et al, Retrograde degeneration of neurite membrane structural integrity of nerve growth cones following in vitro exposure to mercury, NeuroReport, 12(4):733-37, March 2001.

The "previous data" included a study in which the authors concluded that: "We believe one …[theory of the pathogenesis of Alzheimer's] could be mercury vapor to which the majority of individuals are continuously exposed [from dental amalgam]. By reducing levels of viable brain tubulin, mercury vapor could exacerbate the conditions related to the onset of symptoms identified with Alzheimer's." Pendergrass, JC, et al, Mercury vapor inhalation inhibits binding of GTP to tubulin in rat brain: similarity to a molecular lesion in Alzheimer diseased brain, NeuroToxicology 18(2):315-324 (1997).

Mercury is a potent neurotoxin and many peer reviewed scientific studies have found evidence that amalgam fillings may play a major role in central nervous system diseases such as depression, schizophrenia, memory problems, ALS and Parkinson's, www.home.earthlink.net/~berniew1/amalg6.html.

A Canadian study found that blood levels of five metals, including mercury, were able to predict with 98% accuracy which children were learning disabled. Other studies found mercury causes learning disabilities and impairment, and lowers IQ. Marlowe, M, et al, "Main and interactive effects of metallic toxins on classroom behavior", J Abnormal Child Psychol, 1985, 13(2):185-98; Moon C et al, "Main and Interactive Effect of Metallic Pollutants on Cognitive Functioning," Journal of Learning Disabilities, April, 1985; Pihl, RO et al, "Hair element content in Learning Disabled Children", Science, Vol 198, 1977, 204-6; Gowdy JM et al, "Whole blood mercury in mental hospital patients", Am J Psychiatry, 1978, 135(1):115-7. Also see website in paragraph above.

There are many other studies showing adverse health effects from mercury in general, and amalgam in particular. www.altcorp.com, www.bioprobe.com, www.iaomt.com, www.home.earthlink.net/~bernie1/amalg6.html

The removal of amalgams often results in significant health improvements. Jones, Linda, Dental Amalgam and Health Experience; Exploring Health Outcomes and Issues for People Medically Diagnosed with Mercury Poisoning, The New Zealand Psychological Society Inc., The Bulletin, No. 97, Dec. 1999, ("Health outcomes were experienced as positive and enduring once deamalgamation [removal of mercury fillings] and detoxification were complete for the majority of participants.") This is corroborative of the causative role amalgam plays in causing adverse health effects.

(8) WG: Patients want white fillings for aesthetic reasons but no filling material is inert and mercury amalgam is no worse than other filling material.
M-FA: The composite called DiamondLite, toxicity rating of "0" (nontoxic) by the ADA/ANSI rating scale of 0-5. Materials under 2 are considered acceptable. Thus, at least this material appears to be biocompatible. www.biodent.com.au/diamondlite.html

If you go to PubMed and place "Geurtsen W" in the search window, 103 studies appear. Only two of them relate to amalgam. Most of them relate to biocompatibility of composites and root canal materials which brings into question Dr. G's expertise on the toxicity of mercury amalgams. The results of these studies are generally quite frightening. One could reasonably conclude after perusing the abstracts that most dental materials are quite hazardous for human use. So, not only is FDA failing the American public in protecting it from toxic mercury amalgams, but most dental materials appear to present very real toxic risks.

The rebuttals below are based on information contained in the Geurtsen Powerpoint Presentation which was not given, however a document with the slides was submitted into the record and copies provided to the public.

(9) WG: A zinc oxide layer forms on amalgam fillings which protects it from corrosion (implying less mercury vapor release).
M-FA: Zinc is listed at trace levels in most amalgams. How can a "trace" cover all of a material (mercury) which comprises 50% of the filing? To the extent a zinc oxide layer exists, it is easily removed by slight abrasion such as chewing food or brushing teeth. (Declaration of Boyd E. Haley, PhD, supra.)

(10) WG: Amalgam is easier to work with for the dentist and each filling takes much less time.
M-FA: This is true. There is an economic incentive for dentists to continue to place amalgams despite their toxicity. Dentists can place more amalgams per day than composites and can realize more net income.

(11) WG: Amalgam is more durable than other "direct" filling materials.
M-FA: This is an inaccurate statement. DiamondLite composite is more durable than amalgam and bests amalgam in all other categories of comparison. For example: for wear, a natural tooth abrades 3-5 microns per year; amalgam abrades 22 microns per year; DiamondLite abrades 7 microns per year. Charisma composite (by Kulzer) abrades 22 microns per year. Other relevant categories include: fracture toughness, hardness, shrinkage, co-efficient of thermal expansion, diametral tensile strength, compressive strength and flexural strength. DiamondLite bests amalgam in every category. See www.biodent.com.au/diamondlite.html

(12) WG: More toxicological data is available about amalgam than for the alternative materials.
M-FA: It is true that there is a large body of toxicological data about the toxicity of amalgams. I don't know how much data there is about composites, but Dr. G. has made a substantial contribution to that data which raises serious questions about the safety of composites and the FDA oversight of all dental materials.

(13) WG: States that only the unset amalgam releases very much mercury vapor. Admits that brushing, chewing and hot beverages increase mercury release. Also claims that the amount of mercury decreases over time and must cease eventually or the filling would be destroyed.
M-FA: Each large amalgam (0.5 to 1.0 grams of mercury) contain 500,000 to 1,000,000 micrograms of mercury. If mercury is released at a conservative rate of 10 mcg per day from each amalgam, it would take from 137-274 years before any individual amalgam would be depleted of mercury. (Declaration of Boyd Haley, PhD, p. 6).

(14) WG: Claims zinc, tin and copper are released from the amalgam due to corrosion.
M-FA: Well, yes. However, Dr. G forgot to mention that the primary component of amalgam - mercury - also is released from the amalgam due to corrosion.

(15) WG: Dr. G's PowerPoint document states: "Metallic mercury: may penetrate blood-brain barrier and placenta," while Dr. G's actually testimony indicated that it did not.
M-FA: This is another example of the inconsistent positions taken by the pro-amalgam dentists.

(16) WG: Claims methlymercury is much more toxic than oxidized or metallic mercury because it easily penetrates the blood-brain barrier and the placenta. Claims it almost exclusively comes from food, especially fish.
M-FA: See section #3 above (inorganic mercury is methylated in the body).

(17) WG: Cites Kleeman, et al, 1990, for the proposition that "mercury content in blood and amniotic fluid of mothers and in the blood of newborns: no correlation with amalgam surfaces." Also cites Stoz, et al, 1995, for the proposition that there is no correlation between a mother's amalgams and mercury content of mothers blood and newborn children.

(18) WG: Cites Drasch, et al 1998, Drexler and Shaller 1998, Kleeman et al, 1990, for the proposition that there was only a correlation between mothers' amalgams and mercury in breast milk for the first week after delivery and thereafter it only correlated to fish consumption. Dr. G concludes fish is the primary mercury for newborns.

(17) (18) M-FA: There is an accumulation of mercury from maternal amalgams in both maternal and fetal tissues to a steady state with advancing gestation and is maintained. Mercury amalgam also is found in the maternal breast milk providing a source of mercury exposure to the newborn. Vimy, M.J., et al, Maternal-fetal distribution of mercury released from dental amalgam fillings, Am J Physiol, 1990 Apr, 258 (4 Pt 2):R 939-45, (authors conclude: dental amalgam usage as a tooth restorative material in pregnant women and children should be reconsidered.)

This study was confirmed by Drasch in 1994 where he found that the amount of mercury in children and fetuses' livers, kidneys and brains, correlated significantly with the number of dental amalgams of the mother. Drasch, G, et al, Mercury burden of human fetal and infant tissues, Eur J Pediatr 1994, Aug; 153(8):607-10. (The authors concluded that "future discussions on the pros and cons of dental amalgam should not be limited to adults and children with their own amalgam fillings, but also include fetal exposure. The unrestricted application of amalgam for dental restorations in women before and during the childbearing years should be reconsidered.")

The 1998 Drasch study which Dr. G cited, concluded: "The mercury in breast milk samples correlates positively with the number of maternal teeth with dental amalgam … the higher mercury burden of infants' tissues from mothers with dental amalgams … must be explained (1) by a prenatal transfer of mercury from the mothers' fillings through the placenta to the fetus … and (2) an additional burden via breast milk." This study is much more significant and serious than Dr. G asserted.

Oskarsson's study in 1996 also found a transfer of inorganic mercury from maternal blood to breast milk and, it was found that the main source of the mercury was the mothers' amalgams. Oskarsson, A, et al, Total and inorganic mercury in breast milk in relation to fish consumption and amalgam in lactating women, Arch Environmental Health, 1996 May-June; 51(3):234-41, (the authors conclude that "efforts should be made to decrease mercury burden in fertile women").

(19) WG: Claims there is no proof that amalgam fillings in mothers may cause injuries or diseases to their children (citing Drexler and Schaller, 1998).
M-FA: Charles Williamson, MD, co-director of the Toxic Studies Institute in Boca Raton, FL, has this to say about mercury amalgams and their effect on in utero fetuses: "Once mothers realize the fillings in their teeth damage the development of their babies' brains while they're in the womb, and once these women understand this damage can result in low IQ, learning and behavioral problems after birth, then we'll see a public outcry against the use of mercury amalgam…

"Mercury vapor is toxic, period. The fetus is especially vulnerable to that toxicity, which can cause brain damage. Specifically, mercury vapor can cause learning disabilities, autism and attention deficit disorder in unborn children. How will parents feel when they grasp that?" O'Brien, Jim, Amalgam Toxicity: your next visit to the dentist may not be as innocent as you think, Life Extension Magazine, May 2001, with scientific citations.

(20) WG: Concludes that amalgam can be considered a safe filling material.
M-FA: Dr. G cites himself (1991 [sic]). The published article is a "discussion" not a clinical trial or scientific research. It is in German and PubMed provides no abstract. If this article truly does conclude that amalgam is safe, it is unique since no other publication has ever done so. Geurtsen W., Amalgam discussion. Question of amalgam toxicity and allergy, Phillip J 1990, Jun;7(3):121-8.