You can find the Draft Policy and the form for making a submission, by the deadline of October 1^st, on the Department of Environment’s website at http://www.environ.ie/en/Environment/Waste/News/MainBody,23402,en.htm

So SCHER’s landmark opinion on 14^th June 2010 completely vindicates the position of the Directing Board of the 25,000 member International Society of Doctors for Environment (ISDE), who warned the European Commission in May 2009 that fluoridation is a medical matter which SCHER is not qualified to risk assess.  This view is now supported by SCHER itself whose ‘Pre-Consultation Opinion’ asking for yet further public comment reveals the dilemma of its position.

When the European Commission’s Health & Consumer Protection directorate, SANCO, rejected the advice of ISDE doctors, it relied on a number of the Commission’s own answers to repeated questions from MEPs in Ireland and England, the only two widely-fluoridated areas in the EU. Now that one of Europe’s top scientific committees has stated that fluoridation constitutes ‘systemic fluoride treatment’, the Commission’s answers have been exposed at best as misinformed and at worst misleading. Campaigners and MEPs in England and Ireland have invoked at length the many ECJ rulings which amply clarify what constitutes a medicine, of which the Commission and especially SANCO’s Food Law section are fully aware but which they continue to ignore.

“We also rejected SANCO’s mandate to SCHER last year for another glaring error, namely that a non-food scientific committee with a remit to deal with assessment of environmentally polluting existing substances, was assigned the task instead of EMEA, the European medicines regulator” said VOICE campaigner Robert Pocock. He added “To hide this major flaw, SCHER was instructed to collaborate with the food safety watchdog (EFSA) even though fluoride is a) not an essential nutrient and b) it must be regulated as a medicine under EU legislation because a medical claim is made for it”.

As EFSA is demonstrating right now to many health-food operators, no food may make a health claim unless fully substantiated scientifically, however SCHER has stated (p27) that ‘the caries preventive effect of systemic fluoride treatment is rather poor’ so fluoride in drinking water, could not even be approved under the Health Claims Directive.

SCHER’s intractable problems become all too evident when it states that ‘it is assumed that all ingested fluoride (ion) is 100% bioavailable’. Yet the immediately preceding section notes that not all forms are equally bioavailable and very little (naturally-occurring) calcium fluoride is absorbed or retained in the body. It has been known for seventy-five years (Kick et al) that at least a third of the soluble fluoride from drinking water is retained versus very little calcium fluoride, almost all of which is excreted.

The EFSA input to this SCHER offering is immediately recognisable as when daily safe fluoride intake is calculated with remarkable accuracy for various ages from 1 yr old to 15yrs. Yet when it comes to the safe intake for vulnerable infants –up to 1 yr old — no scientific substantiation is offered even though the infant intake is double the safe dose for older children and adults. While EFSA’s recent opinions on ingested fluoride have been widely rejected not least because of its  failure to distinguish the very different toxicology of different fluoride forms, where SCHER does name the most commonly used fluoridating chemical, it notes that ‘the toxicology of hexafluorosilicates is incompletely investigated’ (3.1.).

Since however SCHER has had the courage to admit there are huge gaps in the toxicology of  these same  fluoride chemicals used to treat people, it is now incumbent on the European Commission to immediately assign this assessment to the proper authority with the competence and expertise to evaluate the safety of treatment chemicals (ie medicines) which is EMEA. This pre-consultation opinion is a brave admission by SCHER that it is simply not qualifed for the task.

The final embarrassment for SANCO must surely be the reason it gave for dismissing VOICE’s appeal for Rapid Response to the dental fluorosis epidemic among children in Ireland, where every month some sixty teenagers in fluoridated areas get moderate or severe dental fluorosis from this crude one-size-fits-all treatment.

SANCO rejected our appeal on the basis that there was allegedly a substantial body of scientific evidence supporting fluoridation, a claim that SCHER has now shown to be false. And instead of dragging European scientists into further embarrassment, the Commission must invoke an immediate investigation by the proper agency, EMEA under Rapid Response. Otherwise each month, hundreds of Irish children (and many more in England) will remain unprotected from an illegal, crude and ineffective systemic fluoride treatment which carries a high risk of dental fluorosis.

ENDS            Info on 086 811 3071

NOTES

1. Pre-consultation Opinion is on :

http://ec.europa.eu/health/scientific_committees/consultations/public_consultations/scher_cons_05_en.htm <http://ec.europa.eu/health/scientific_committees/consultations/public_consultations/scher_cons_05_en.htm>

All interested parties are invited to submit their comments and proposals on the preliminary opinion to the following website <http://ec.europa.eu/yourvoice/ipm/forms/dispatch?form=Fluoride> by 15 Sept. 2010.

2. International Doctors for Environment letter to SCHER http://www.ideaireland.org/isdeletter30052009.htm

3. While exposure to systemic fluoride is acknowledged by SCHER to carry a risk of dental fluorosis in children, the more severe forms (euphemistically called ‘mild’, ‘moderate’ and ‘severe’) are nowhere illustrated  or even defined in the opinion but are illustrated below.

Moderate dental   fluorosis

Mild dental fluorosis

Severe dental fluorosis

Normal enamel

By the age of 15 yrs, approx 1,100 children in Ireland have developed ‘mild’ dental fluorosis. Only 63% of 15 yr olds resident in fluoridated areas of ROI have ‘normal’ enamel.

Pics also from Oral Health Services Research Centre, Cork.

Fluorosis of the severity shown below is entirely absent from unfluoridated N.Ireland per the same North South Survey. [There is some mild' fluorosis in N.I. but no 'moderate' or 'severe' types]

Co Kildare GP Dr Andrew Rynne told IMN last week that he reported an adverse reaction of dental fluorosis, under Recital 9 of Directive 2001/20/EC (Clinical Trials on Medicinal Products for Human Use), known as the Clinical Trials Directive, from the intake of hydrofluorosilicic acid, which is not on the Community Register of Medicinal Products.

Citing a 2002 survey which identified a 37 per cent incidence of dental fluorosis in children residing in fluoridated areas in the South versus 14 per cent in Northern Ireland (unfluoridated water), Dr Rynne claimed that in the six years since the clinical trials regulations came into effect, 15,000 minors in Ireland have suffered dental fluorosis. He alleges, in the report dated June 1, that the fluoridisation of water is an unauthorised, obsolete and repetitive clinical trial on at least 70 per cent of the Irish population.

Since the sole reason for the administration of hydrofluorosilicic acid, an active substance also used for electroplating and refining lead, to drinking water is to prevent dental caries, it satisfies the definition of a medicinal product in Article 1(2) of Directive 2001/ 83/EC, charged Dr Rynne.

He alleges, “Neither the daily dose which is delivered via public drinking water, nor interactions with other drugs are known. Control of administration … is impossible because there is no control of individual consumption of public drinking water. The relevant medical history of all those subjected to this active substance is currently unknown since the product is administered from birth.” For more see http://www.imn.ie/index.php/news/3707-thousands-of-suspected-fluorosis-cases-reported

For more information on the regulation of clinical trials in Europe please see http://voiceireland.org/water/fluoridation/fluoridation-slammed-for-adverse-reactions-in-paediatric-clinical-trial/

The Irish Climate Bill represents real and definite change for Ireland. With its passing, the bill with elevate the climate change issue to a national priority and put Ireland’s international obligations into law. It will require an 80% reduction in greenhouse gas emissions by 2050 and establish a Climate Change Committee to oversee the task of reaching such targets. The Carbon budget, which has been in place since 2007, will take on new roles of measuring the progress of the country. A 3% average annual reduction rate in greenhouse gasses will be implemented to make sure future targets are met.

The proposed Irish Climate Bill is similar to bills passed in Scotland and England. Yet weaknesses exist in the bill that could lead to it loosing effectiveness in the future. Loose targets like the 3% average reduction are by no means mandatory and can result in the big polluters neglecting to make reductions immediately by claiming they will make up for gaps in the future. There currently is no stated guideline on how the ambitious 80% reductions target will be met and it is the only target of its kind stated in the bill. What is needed are a set of baseline targets to be met, much like the UK Bill which dictates benchmark goals every ten years. The Carbon Budget is currently nothing more than a non-binding progress report, instead of a yearly binding cap on total emissions. The bill also needs to ensure that carbon offsetting and the purchasing of carbon credits is not part of the 3% annual reduction but that Ireland’s emissions reductions need to be actual reductions here in Ireland. We also asked that aid going to developing countries for climate change adaptation is not taken from the existing pool of Irish aid but that is was additional and sufficient.

It is important that these loopholes be closed as they represent a real problem to the climate bill’s effectiveness and could jeopardize the ability for the bill to grow and strengthen over time. Voice of Irish Concern for the Environment (VOICE) along with the other groups in the Stop Climate Chaos Coalition are working hard to put the pressure on the government to take action and strengthen the bill. On June the 2^nd in Buswells Hotel in Dublin City centre individuals from all across the country, with the support of the members of SCC met their TDs (MPs) and voiced their concerns in person. This was a dynamic event where local constituents got to meet their local TDs and tell them directly how serious they are that the up coming climate bill is strong enough so it has lasting implications for big polluters as well as moves Ireland towards a sustainable future. The event was preceded by an e-action where constituents sent emails to their TDs and asked them to meet them on June 2^nd. The day kicked off with a training session hosted by various speakers from Friends of the Earth Ireland, Trócaire and Oxfam. The training day was intended to help the constituents understand what the climate bill means for Ireland, its targets and objectives and its many shortfalls. Over 150 people and 86 members of the Parliament made it out on the day and 70 TDs signed a ‘Climate Commitment’ that showed their dedication to ensuring the Bill is loophole free. VOICE and the Stop Climate Chaos coalition has kept the pressure up on the Irish government and eagerly awaits the Heads of Bill due in the next few weeks.

By VOICE volunteer Nick Chiumenti and VOICE campaigner Ciara Aucoin

]]> http://voiceireland.org/climate-change/ireland-on-it%e2%80%99s-a-way-to-a-low-carbon-future/feed/ 0 http://voiceireland.org/water/seas-at-risk-and-low-impact-fisheries/ http://voiceireland.org/water/seas-at-risk-and-low-impact-fisheries/#comments Tue, 15 Jun 2010 11:57:17 +0000 http://voiceireland.org/?p=556 Brussels, 8th June, 2010. A new report by Seas At Risk highlights a number of ways that fisheries across Europe can reduce their greenhouse gas emissions while simultaneously reducing their damaging impact on the marine environment. The report – titled ‘Moving Towards Low Impact Fisheries in Europe: Policy Hurdles & Actions’, undertaken by the independent fisheries consultancy MacAlister Elliott and Partners – finds that through changing the type of fishing gear, the fishing industry can decrease the damage it inflicts on marine ecosystems, reduce its greenhouse gas emissions and lower its fuel costs.

Coinciding with World Oceans Day and European Fish Week, the study also identifies reasons as to why fishermen are not shifting gears even with high energy prices on the horizon – reasons that include a lack of knowledge and inflexible EU fisheries management.

Monica Verbeek, Executive Director of Seas At Risk, said: “This comprehensive report shows both fishers and the environment will benefit from a shift to low impact fisheries. The 2012 reform of the Common Fisheries Policy provides a unique opportunity to adopt well designed policy measures to promote such a shift.”

The report makes the following key points:

• Heavy trawls and dredges that scrape over or dig into the bottom have most impact on the environment, both in terms of habitat destruction and selectivity and in terms of carbon emissions. Less impacting alternative gears include traps and lines.
• Although data on carbon emissions are not straightforward, in general, demersal trawl fisheries and offshore longline fisheries perform badly in terms of carbon emissions per unit catch, passive gears like nets and traps perform better than towed gears, and small vessels perform better than medium sized and large vessels.
• Where fish stocks are depleted and poorly managed, fisheries have bigger negative impacts than those fisheries on well-managed stocks.
• Common problems fishermen face when trying to switch to less damaging fishing techniques include costs, a lack of knowledge on best practices, gear conflicts (passive gear cannot be used where a large number of towed gears are in operation), and practicalities (less harmful gear can be more difficult to use than harmful gear).
• Policy can also acts as a hurdle to a shift to more sustainable fisheries. Currently, the most serious policy hurdle to low impact fisheries is the inflexible nature of the EU fisheries management system. The current short-term micro-management system based on TACs, quotas and effort should therefore be replaced by a more flexible and long-term management system, which supports low impact fisheries.

Based on this report, Seas At Risk calls for the reformed Common Fisheries Policy to promote a shift to low impact fisheries through:

• Preferential access to fish resources for low impact fisheries;
• Elimination of overcapacity using environmental and social criteria, ensuring that the most sustainable vessels remain in the fleet;
• Phase-out of fuel tax exemptions and other perverse subsidies;
• Redirection of subsidies to training/education programs promoting low impact fisheries;
• Introduction and promotion of spatial planning, with zones set aside for low impact fisheries, especially those using passive gears.

A selection of the report’s findings can also be viewed in the accompanying brochure. It is available on the Seas At Risk website in English, French, Dutch, Spanish, Portuguese and Danish at www.seas-at-risk.org

Dublin, 11 June 2010

Clane GP, Dr Andrew Rynne, alerted the European medicines regulator (EMEA), and all other national competent medicinal authorities across the EU, on 1^st June 2010 to the adverse reaction of dental fluorosis in the paediatric population in Ireland. The alert was issued under rules governing adverse reactions to medicines in Europe (EudraCT) and is linked to the use of the industrial chemical hydrofluosilicic acid in drinking water. Administration of hydrofluosilicic acid is not medically authorised and continues despite flagrant infringement of theClinical Trials Directive (2001/20/EC). Recital 18 of this directive requires the Irish medicines regulator to issue a notice of suspension to cease the trial because its continuation involves an unacceptable level of risk.

Since the directive came into effect in Ireland in 2004, some 12,000 children in fluoridated parts of Ireland have had an adverse reaction in the form of ‘severe, moderate or mild’ dental fluorosis with another 50,000 children affected by milder, but still permanent, forms of dental fluorosis. VOICE campaigner Robert Pocock commented, “many teenagers are fluoride’s unfortunate victims because fluorosis is irreversible”.

The Clinical Trials Directive and a follow up Directive (2003/94/EC) require all unauthorised substances used in trials as investigational medicinal products to demonstrate good manufacturing practice. Since hydrofluosilicic acid is simply an industrial chemical, whose main use is to etch glass or metal, it will never meet good manufacturing criteria for medicinal products. These include a pharmaceutical quality assurance system to protect trial subjects, which is mandatory for all clinical trials of human medicines.

In order to guarantee the quality of all investigational medicinal products, yet another Directive (2005/28/EC) sets down minimum requirements for and management of authorisations to manufacture or import such products—none of these directives have been complied with by the Irish health minister. It is also not surprising that hydrofluosilicic acid is not on the Community Register of Medicinal Products.

Dr Rynne has also quoted Regulation (EC 1901/2006) on medicinal products for paediatric use, which warns of the increased risks of adverse reactions due to inadequate dosage information. The adverse reactions in the paediatric population confirms that the dosage in Ireland is too high. The Regulation also warns of not subjecting the paediatric population to unnecessary clinical trials, especially in cases where no application for a paediatric use marketing authorisation has ever been submitted in the European Union.

With such cavalier disregard for legislation on clinical trails of human medicines, the Irish Government can only be brought to book by the European Commission, which is little comfort.  The medicinal regulation of hydrofluosilicic acid in Europe has to-date, been of the light-touch, Irish variety. However, now that European regulation of medicines has been assigned to the new Commissioner for Health and Consumer Protection (DG SANCO), it is incumbent on new commissioner, John Dalli, to face up to the effects of this non-enforcement. The clinical trial involving children treated with an industrial, not a pharmaceutical substance, in a one-size-fits-all dosage has been fully exposed. The unacceptably high risks of non-regulation demand nothing less than an immediate prohibition on administering hydrofluosilicic acid to public drinking water.

As the Government negotiates the text of this forthcoming legislation, we must send them a clear message that we expect the bill to be strong, with real enforceable targets that ensure Ireland plays its part in delivering climate justice and a fair and safe future for all.

As part of the Stop Climate Chaos coalition, VOICE, is organising an event which will allow you to meet your TDs. This will be giving you the opportunity to tell them directly that you expect them to support a strong Irish climate law.

When: Wednesday 2 June ,11am to 7pm,
Where: Buswells Hotel, 26 Molesworth Street, Dublin 2
How: Visit www.stopclimatechaos.ie/takeaction, select your constituency and invite your TD to come and meet you.

VOICE will be there on the day to support you. We’ll also send you an information pack and give you a call before the event to answer any questions you might have. Sign-up today and meet your TDs – this is your chance to tell them directly, that you expect strong action on climate change. We must not allow the failure in Copenhagen to become an excuse for not taking action on climate change at home.

We look forward to seeing you on 2nd of June! Use the Stop Climate Chaos website to arrange to meet your TD. Its time to act!

The 15th Convergence Festival started yesterday May 26th and runs until Tuesday the 1st of June. It is run by The Village Project in Cloughjordan, Cultivate,  Transition Ireland and many more and it features talks, conferences, workshops and world café discussions on how urban and rural communities can adapt and thrive in these uncertain times. This festival brings together people from a wide variety of sectors to strategise on how we develop the resilience of our communities. The events explore new ideas for going ‘green’, demonstrating local food growing projects, and best practices in reducing our fossil energy use and carbon emissions. There will also be opportunities to learn from the global South and from innovative Irish and international initiatives. Discussions will be hosted on energy smart communities, smart grids, smart transport systems, energy efficiency, carbon reduction and community energy supply. The festival will also explore how sustainable regeneration, energy descent, the green economy, low carbon cities, and transition towns can all contribute to the development of local resilience and community based livelihoods and jobs.

For more see Cultivate’s website and for the full schedule for the festival click here.