The main quote from Dr Connett is:

“It was an awful study, it has been debunked, because there was practically no control, you had 1400 people living in the fluoridated community and less than 100, and also the kids were taking fluoridated supplements, a lousy lousy study.”

Below is a point by point refutation, which should show that Dr Connett’s arguments do not hold water.

“It was an awful study…. a lousy lousy study”

Broadbent et al. (2014) is the currently the best paper on IQ at the recommended levels of fluoride in water. It used data from the Dunedin Multidisciplinary Study, which is world-renowned for the quality of its data and the rigour of its analysis.

The strict 2015 ‘Health effects of water fluoridation‘ review by the Health Research Board said of the study

“…the current review identified one original paper in a non-endemic area (New Zealand) that aimed to clarify the relationship between CWF and IQ by Broadbent et al. This is a high-quality prospective cohort study of a general population sample…”.

“Practically no control”

The study controlled childhood factors associated with IQ variation, such as socio-economic status of parents, birthweight and breastfeeding, secondary and tertiary educational achievement and sources of fluoride exposure other than community water fluoridation (CWF). They also controlled for a similar set of confounders to those controlled by Meier et al (2012) in their study of cannabis exposure and IQ, which found that persistent cannabis users show neuropsychological decline. Does Dr Connett have a problem with this study?

“You had 1400 people living in the fluoridated community and less than 100”

The number of study members who had never resided in a fluoridated area was 99, and the number who had, was 891, but this does not indicate a low ability to detect an effect. There is no such thing as no fluoride exposure; that is, fluoride is naturally present in both soil and water. The study had more than enough power to conduct analyses that distinguished between high and low fluoride exposure, and to model the relation with IQ.

“The kids were taking fluoridated supplements”

This was controlled for, and no significant differences in IQ were found. Those with high total fluoride intake had slightly higher IQs than those with low total fluoride intake. The authors of the study released this graph (below).

 

“It has been debunked”

It hasn’t. The Fluoride Action Network released a press release criticising the study and calling it “flawed”:
However, maybe Dr Connett never got the memo, as the authors of the study debunked every main point in the ‘On Tap’ issue 10.

The authors have also written in response to criticism in Journals, here and here. They re-ran their analysis, taking into account both suburb and distance from the city centre, more details on total fluoride intake, the interaction between breastfeeding (including duration), etc. The results were no meaningful change of significance, effect size, or direction to their original findings.

The conclusion of the study still holds up:

“The findings do not support the assertion that fluoride exposure in the context of CWF can affect neurologic development or IQ. Study members who lived in areas with CWF before age 5 years had slightly higher IQs (on average) in adulthood than those who had not, but this difference was non-significant”

On top of this conclusion, the study also had sufficient power to explore differences in the experience of dental caries. The study observed significantly fewer caries-affected teeth in both childhood and adulthood among those who resided in CWF areas as children.

Steve Slott’s reply

Paul, you are claiming authoritative, factual information from the American Dental Association, and the United States Centers for Disease Control, two of the most highly respected healthcare entities in the world… to be “propaganda”, when, in reality, the problem is your lack of understanding of fluoridation, not with the information provided by these entities.

First, for the sake of disclosure, it must be noted that the existence of your “Fluoride Action Network”, its reportedly $150,000 annual budget, the salaries/stipends paid to you, your family, your paid lobbyist, William Hirzy, and whatever may be paid to others within your organization …whatever expenses “FAN” pays for your repeated visits to Australia, New Zealand, Europe, Canada, and all over the United States and sales of your non peer-reviewed book are all dependent on your ability to keep the fluoridation issue alive, and create “controversy” where none exists.

With that gross conflict of interest aside, let’s look at your comments.

1. “According to WHO data the so-called “gains” from the American fluoridation program have been no greater than those obtained in the vast majority of countries that are unfluoridated, including 97% of Europe.”

The cause and preventive measures involved in dental decay are myriad and diverse. The attempt by you and your followers to gauge the effectiveness of but one preventive measure, fluoridation, based on snapshots of WHO data which control for no confounding factors, is ludicrous.

2. “The Globe’s claim that ‘It would require chugging gallon after gallon of fluoridated water to reach even a potentially dangerous level’ is utter nonsense”

No, not as much as you like to portend.

Let me explain:

Simply put, water is fluoridated at 0.7 mg/liter (ppm=mg/liter). Thus, for every liter of fluoridated water consumed, the “dose” of fluoride intake is 0.7 mg. The average daily water consumption by an adult is 2-3 liters per day. So, let’s go to an extreme and double that to an excessive 6 liters of fluoridated water consumption per day. This translates to 4.2 mg “dose” of fluoride intake per day from the water. The CDC estimates that of the total daily intake, or “dose”, of fluoride from all sources including dental products, 75% is from the water. Thus as 4.2 mg is 75% if the total daily intake from all sources, the total daily intake, or “dose” from all sources would be 5.6 mg for an individual who consumed an excessive 6 liters of fluoridated water per day.

The Institute of Medicine has established that the daily upper limit for fluoride intake from all sources, for adults, before adverse effects will occur, short or long-term, is 10 mg. Thus, even the excessive 6 liter per day consumer of water will still only take in a daily “dose” of fluoride that is slightly more than half the upper limit before adverse effects.

The range of safety between the miniscule few parts per million fluoride that are added to existing fluoride levels in your water, is so wide that “dose” is not an issue. Before the UL of 10 mg could be reached, water toxicity would be the concern, not fluoride.

3. “A Harvard meta-analysis (Choi et al, 2012) shows that the mean value of 20 studies associating a lowering of IQ with consumption of fluoride in water is less than the EPA’s current safe drinking water standard of 4 ppm. This leaves no margin of safety to protect all American children drinking fluoridated water and getting fluoride from other sources”.

A. The Harvard study was actually a review of 27 Chinese studies found in obscure Chinese scientific journals, of the effects of high levels of naturally occurring fluoride in the well water of various Chinese, Mongolian, and Iranian villages. The concentration of fluoride in these studies was as high as 11.5 ppm. By the admission of the Harvard researchers, these studies had key information missing, used questionable methodologies, and had inadequate controls for confounding factors. These studies were so seriously flawed that the lead researchers, Anna Choi, and Philippe Grandjean, were led to issue the following statement in September of 2012:

“–These results do not allow us to make any judgment regarding possible levels of risk at levels of exposure typical for water fluoridation in the U.S. On the other hand, neither can it be concluded that no risk is present. We therefore recommend further research to clarify what role fluoride exposure levels may play in possible adverse effects on brain development, so that future risk assessments can properly take into regard this possible hazard.”

–Anna Choi, research scientist in the Department of Environmental Health at HSPH, lead author, and Philippe Grandjean, adjunct professor of environmental health at HSPH, senior author

As it seems there have been no translations of these studies into English by any reliable, objective source, it is unclear as to whether they had even been peer-reviewed, a basic for credibility of any scientific study.

B. Seventy years of fluoridation, hundreds of millions having chronically ingested fluoridated water during that time, and no proven adverse effects. Clearly the “margin of safety” has been entirely sufficient.

4. “The very last children who need their IQ lowered are those from low-income families and yet they are the children being targeted by fluoridation promoters.”

There is no valid, peer-reviewed scientific evidence that optimally fluoridated water “lowered IQ” of anyone.

5. “With so many risks involved and with no randomized control trial (RCT) after 70 years demonstrating fluoridation’s effectiveness it is time to end this outdated and unethical practice”.
A. There is no “risk” of adverse effects from optimal level fluoride.

The 2006 NRC Committee on Fluoride in Drinking Water was charged to evaluate the adequacy of the EPA primary and secondary MCLs for fluoride, 4.0 ppm and 2.0 ppm respectively, to protect against adverse effects. The final recommendation of this Committee was for the primary MCL to be lowered from 4.0 ppm. The sole reasons cited by the Committee for this recommendation were the risk of severe dental fluorosis, bone fracture, and skeletal fluorosis, with chronic ingestion of water with a fluoride content of 4.0 ppm or greater. Nothing else. Had this Committee deemed there to be any other concerns with fluoride at this level, it would have been responsible for stating so and recommending accordingly. It did not.

Additionally, the NRC Committee made no recommendation to lower the secondary MCL of 2.0 ppm. Water is fluoridated at 0.7 ppm. one third the level which the 2006 NRC Committee on Fluoride in Drinking Water made no recommendation to lower.

B. Given that the only substances ingested as a result of fluoridation are fluoride ions, identical to those which have always existed in water, and trace contaminants in amounts far below EPA mandated maximum allowable levels of safety, the question is… on what exactly do you wish there to be a “randomized control trial”? Fluoride ions which most people fave ingesting their entire lives, fluoridated water or not… or barely detectable trace contaminants in amounts which have already been deemed safe by the United States Environmental Protection Agency?

C. There is nothing “unethical” about local officials authorizing the raising of existing fluoride ions in public water systems under their jurisdiction, by a minuscule amount to a level which has been observed to provide maximum benefit, with no adverse effect. If anything, it is unethical for you to constantly insist that citizens of communities do not obtain the maximum benefit from a substance which they will ingest anyway.

6. “Fluoridation is a red herring. The real cause of tooth decay is too much sugar, not enough fruit and vegetables and too little education on dental hygiene”

The causes of dental decay are myriad. You haven’t the education, training, experience, or knowledge to credibly assess what is “the real cause of tooth decay”. Addressing the causes of dental decay, as has been done for at least the past century, certainly does not preclude the need for viable preventive measures of this disorder, as is the public health initiative of water fluoridation. Fluoridation strengthens teeth against the assault of acid secreting bacteria fed by sugar. In an ideal world, diets would be perfect, oral hygiene habits would be perfect, and access to proper dental care would be readily available to everyone. Given that we don’t live in an ideal world, we cannot simply stick our heads in the sand and ignore the lifetimes of devastating effects of untreated dental decay simply because you, or anyone else, erroneously assumes that the causes of dental decay are not being “tackled head on”.

7. “I first questioned fluoridation while I was teaching environmental chemistry and toxicology at St. Lawrence University 19 years ago. The first fact that struck me was that, despite its abundance, nature had not used fluoride in any biological process in the body. It is not an essential nutrient. No disease occurs from fluoride deficiency. On the other hand there are plenty of biological molecules and processes that are harmed by fluoride. So why are we being forced to swallow it?”

A. The purpose of water fluoridation has never been intended to be to correct any sort of fluoride deficiency. It is simply to provide additional strength to the teeth enabling them them to better resist the devastating effects of untreated dental decay.

B. Exactly how are you being “forced to swallow” fluoridated water? Does someone tie you down, pry your mouth open, and pour it down your throat? If so, you should report this to the appropriate authorities. No one is “forced” to do anything in regard to fluoridation. People are entirely free to consume it or not, their choice.

If fluoridation opponents truly believed all of the ridiculous claims they make about fluoridated water, assuming they are otherwise sane, they would not go within a mile of it, much less drink it. That you freely consume and otherwise utilize fluoridated water belies the claims of “concern” with safety which you constantly disseminate.

8. “Perhaps the most telling fact of all is the level in mothers’ milk. It is remarkably small compared to the level used in fluoridation programs: 0.004 versus 1 ppm. In my view, nature is protecting the baby from fluoride, and water fluoridation removes that protection. This is a reckless thing to do.”

Your personal opinion on what you deem,”nature to be doing”, notwithstanding, the content of “mother’s milk” is nothing but your own “red herring”.

“Mother’s milk” is deficient in Iron, Vitamin D, and Vitamin K to the point of breastfed infants requiring supplements. By your logic, “nature” intends for infants to be anemic, free bleeders, who develop Ricketts.

Steven D. Slott, DDS

He goes on to say in a further comment:

Paul Connett and his followers attempt to impose upon entire populations, their ideology against fluoridation by portraying it as a complex process involving the addition to drinking water of “foreign substances”, “medication”, etc. which have never had “clinical trials”, and other such nonsense, while intentionally using inflammatory terms such as “toxic waste” to erroneously describe the fluoridation compounds.

In actuality, however, fluoridation is simply the determining of the existing fluoride content of a water supply, adding whatever minuscule amount of fluoride ions it takes to raise that level up to the optimal level of 0.7 ppm at which maximum dental decay prevention will occur with no adverse effects, then strictly monitoring and maintaining that fluoride at that optimal level. In those water supplies which already have an existing fluoride content at or above the optimal level, fluoridation is not needed and is not done. In instances where the existing level of fluoride is found to be excessively high, not only is fluoridation not done, but the recommendation, or sometimes mandate, is made to lower that existing level, through filtration.

Thank you Steve for this long reply and your continued work of reducing the misinformation on the internet. For those who don’t know who Steve is, you will find him debunking misinformation around fluoridation in many of the comment sections on media websites. If you see one of his comments, go say thanks.

TLDR:

• Dr Paul Connett scaremongers.
• Science shows fluoridation is safe and effective.
• Dr Steve Slott is a fluoridation myth buster.

 

Edit:

We contacted Dr Paul Connett for a possible online debate against Dr Steve Slott. He refused saying “Please do not contact me again”.

When the doors to Hamilton’s first Carl’s Jr. franchise finally swung open on a dreary autumn day in 2013, I made my way to the first available counter and ordered up my own grease filled fantasy. I grinned as a bubbly Waikato Times journalist (a high school friend) approached and remarked, “I didn’t think you’d do it, the first customer in Hamilton! I guess we’ll have to make a celebrity out of you,” all the while barely controlling her laughter. Indeed, for the next few days, I was somewhat of a minor Facebook celebrity as the story began to circulate among friends, students and otherwise bored and easily entertained Hamiltonians.

 

With the exception of those that abstain from meat for ethical or cultural reasons, the act of revelling in fast food folklore would probably be considered a rather innocuous pastime of a graduate student with too many spare hours in a day. After all, as skeptics, what else we choose to pursue in our spare time is hardly as important as the research we cite or write, right?

Well, maybe or maybe not. I, for one, have a growing feeling we need to seriously reconsider how we approach public engagement, who we approach, and what we present them with. Google-proficient anti-fluoridationists have also enjoyed my Carl’s Jr. adventure, although for different reasons. But their cynical take on my stunt – copying and pasting the article each and every time we cross paths on the internet – should give some necessary pause to our current approach.

 

The pretext to this view is derived from what we’ve recently digested in the field of political psychology. Nythan’s paper Effective Messages In Vaccine Promotion: A Randomized Trial (2014) lends to the hypothesis that individuals are even less likely to adjust their pre-existing world views in the light of new evidence. As I flicked through the paper I found myself nodding as I recalled numerous instances where, as a society, we had attempted to correct the misinformation online regarding water fluoridation, only to find that the person presenting such information becomes even more enamoured with pseudo-scientific beliefs.

 

Freelance political philosopher Eric Hoffer referred to those persons with rigid and polarised views as ‘True Believers’. Indeed, I would contend that opponents of water fluoridation are the gold standard of true believer, and like the aforementioned anti-vaccinator, they’re increasingly likely to dig their heels in when faced with conflicting evidence. Which perhaps suggests that engaging with them is practically useless, unless our engagement is accessible by those who are yet to develop an opinion on the matter and have a sufficient level of scientific literacy.

For the anti-fluoridationist, ‘minor’ details matter little. It does not matter that I acknowledged my choice of burger was an artery thickener any more than when Harvard researcher Anna Choi publicly stated that her meta-analysis into the neurotoxicity of fluoride was not related to community water fluoridation.

 

Referenda in Hamilton, Whakatane and Hastings, despite all returning a positive outcome for water fluoridation policy, have all had one other common theme: low participation. It’s perhaps this frontier, those non-voters, rather than the True Believer, that deserve a greater level of attention by skeptics, particularly as low participation rates can often produce undesirable electoral results.

Political scientist Philip Converse first introduced the concept of a ‘non-opinion’ after an analysis of electoral surveys in his seminal work The American Voter. The varying degrees of a ‘non-opinion’, according to Converse, often make up the majority of the electorate. The non-opinion is someone who will either not vote or not strongly consider the candidate or subject matter before voting. In the instance of water fluoridation, it could be someone who has not been sufficiently compelled to seriously consider the argument being made before them. Later research, in particular that by Conover and Feldman theorised that the non-opinion is susceptible to four categories:

• Existing position
• Ideology predisposition
• Party cues
• ‘Candidate’ Characteristics

 

Call me a pessimist, but I would be inclined to argue that carefully explaining to a ‘non-opinion’ that hydrofluorosilicic acid dissociates in water and becomes the fluoride ion, the same fluoride ion found ‘naturally’ in New Zealand waterways, is about as useful as explaining to a bunch of young parents the complexities of ethnic rivalries among Kyrgyz and Uzbeks in the Central Asian Plateau. A complete lack of literacy in the most basic principles of toxicology (existing position), borne in part out the of the dismantling of compulsory science education in senior high school has made even the most nuanced discussion about ‘how things work’ the modern-day pipe dream of science communicators.

 

In his blog Dr Ken Perrott, science advisor for Making Sense of Fluoride, has sought to neutralize the ideological predispositions of anti-fluoridationists, pointing out that ‘choice’ can indeed be exercised and the provision of a ‘social good’ (such as a reduction of tooth decay via water fluoridation) is part of the very fabric of a modern progressive society. Furthermore, it’s perhaps quite remarkable that no political party currently represented in the New Zealand parliament has opportunistically latched onto an opposition of community water fluoridation.

This then leaves the skeptic with only one remaining consideration when engaging a non-opinion: candidate characteristics. Skeptics have a long and proud tradition of pointing out fallacious arguments as an important fundamental of critical thinking. An ad hominem based on someone’s circumstances, even their penchant for a delicious burger, is clearly a fallacious argument. But to dismiss the relevance of someone’s extra-curricular activities in the court of non-opinion would be to deny the ability of an emotional argument to trump a rational one.

So let them talk about my/our affection for burgers, let’s not rise above it, let’s not sit on our pedestal and point out an error in reasoning. We can leave that to our academic institutions and our government agencies. As skeptics, let’s remind the public of where the greater level of credibility can be sought. Aisling Fitzgibbon (The Girl Against Fluoride) is a ‘qualified’ angel healer with a marketing strategy that involves stripping down to her underwear during protests; and Paul Connett is a retired professor who accepts funding from an internet entrepreneur who also just happens to sell water filters and fluoride-free toothpaste and claims that cancer is a fungus that can be cured with baking soda. Enough said.

 

Politics is no respecter of rationality. It’s an often arbitrary process of deciding “who gets what, when and how”. Helping those with no opinion identify the characteristics of those at the forefront of anti-fluoride movements is often the single most useful tactic we will ever have at our disposal.

 

MSOF Resume

At MSoF we have several dentists, scientists and other health experts helping us out. We have many people who have more experience in terms of their degrees, the number of peer-reviewed papers written and even the number of hours of research than Dr Connett. Most of our experts like to stick to the background because they do not want to be attacked by anti-fluoridationists; some are even worried about their own children if they speak out. MSoF gives these experts a way to speak out behind a respected society to remove the misinformation around fluoridation.

While Dr Connett might be a good chemist and we are not denying this, he can’t call himself a toxicologist, a dentist, a general practitioner, etc. Even if we didn’t have any experts behind us, we are not the ones going against the scientific consensus, unlike Dr Connett.

Cherishes Science

Dr Connett’s organisation, FAN, has close financial links to Joseph Mercola and is part of his “Health Liberty” organisation. And Mercola makes all sorts of ‘illogical and erroneous’ claims about science e.g. that statins and vaccines are bad, and that HIV does not cause AIDS. If he “cherishes science” he wouldn’t be working with Mercola. Skeptoid voted Mercola to be one of the top 10 anti-science websites around.

Science

Precautionary Principle

I feel you are abusing the precautionary principle. As you should know dental decay remains the single most prevalent common chronic (and irreversible) disease among all ages, and disparities still exist in oral health. Consequences include; pain, infection, bad breath and foul tastes, impaired chewing ability, tooth loss, compromised appearance, decreased the quality of life, personal financial costs as well as indirect costs to society. Without fluoridation, you are knowingly putting unnecessary suffering on children.

Flaws in Papers

No peer-reviewed paper is perfect, but that is no reason to ignore the hierarchy of scientific evidence. We shouldn’t be focusing on low-quality research when there have been better studies written. The anti-fluoride groups do this all the time. There have been 17 major peer-reviews of fluoridation undertaken across the world by recognised academic authorities in the past twenty years, all showing the safety and efficiency of fluoridation. There is no respected health organisation that is against fluoridation.

Recently, dental leaders, representing over one million dentists in 134 countries, reaffirmed their strong support for fluoridation as essential in promoting oral health. The assembly of the annual meeting of the FDI, world dental federation, reaffirmed its strong support for fluoridation. They stated that:

• — Over seventy years of research and recent systematic reviews have shown that water fluoridation is an effective public health measure for the prevention of dental decay in children and adults.
• — Water fluoridation is particularly appropriate for populations demonstrating moderate to high risk of dental decay.
• — Water fluoridation confers positive health savings and contributes to reducing disparities in the rates of dental decay in communities.
• — At the fluoride concentrations recommended for the prevention of dental decay, scientific research and reviews show that human general health is not adversely affected.
• —The public health benefits of water fluoridation in the prevention of dental decay far outweigh the possible occurrence of very mild/mild dental fluorosis.

TLDR

MSoF will stick with the scientific consensus and best evidence instead of following the views of the founder and leading protagonist of ‘Fluoride Action Network – a single-issue activist group.

We thank Stan and Ellen for the criticism.

[sudden infant death syndrome], seizures, allergies, asthma, autism, diabetes, and meningitis. The posting was introduced on Ms Fitzgibbon’s Girl against Fluoride Facebook page by the alarming sentence: “Vaccines are so last year.”

 

I need hardly add that not a single one of Ms. Fitzgibbon’s outlandish anti-vaccination claims are even remotely true. One might be tempted to give Ms Fitzgibbon some benefit of doubt upon learning that she is a qualified therapist but alas, her therapy skills relate solely to the manipulation of one’s angels (it’s often called Angel Healing) whom, it is said, she can persuade to act positively on one’s behalf. She also recently acquired the status of an alternative lifestyle “GAPS” nutritionist. Her qualification came courtesy of a correspondence course offered by a Russian doctor, Natasha Campbell-McBride, who is not qualified to practice in Europe, or the USA.

 

Campbell-McBride has nonetheless managed to discover a new disease she calls “Gut and Psychology Syndrome” (GAPS). Unusually, Campbell-McBride has registered the name of the newfound disease as a trade mark, something I’ve never encountered before in many years of writing about science and which probably means nobody else can offer a competing cure, no matter how effective. For fear of being held in breach of copyright by her I’ll very briefly list some of the diseases she claims her diet can treat. They include autism, ADHD/ADD, dyslexia, dyspraxia, depression and schizophrenia. I’ve yet to encounter any medical specialists who agree with her unique methods (but if you know of any do please let me know).

 

But back to Paul Connett. On his Fluoride Action Network website he publishes what he calls the “largest scholarly database for fluoride related contaminants.” However using it we failed to unearth any of several Irish studies which confirmed fluoridation posed no health risk.

 

Connett’s database greatly misrepresents the limited science it does present. An example is a doctoral thesis by a young US scientist called Bassin who discovered what she thought was a link between fluoridation and osteosarcoma, an extremely rare bone cancer in males. As doctoral theses often are, this was described by some as an “exploratory” study. Even Bassin herself admitted that the link might be tenuous because she could find no similar association in females and said it required further research. Subsequent research in the US, and also in Ireland, has failed to support her contention and concluded there is no link between the two.

 

However, the Fluoride Action Network went into typical “Shoot the Messenger” mode and, while it continued to praise and promote Bassin’s now firmly rebutted research, accused the lead researcher on one study disproving Bassin’s thesis of massive breaches of scientific ethics. Another even more convincing 2011 osteosarcoma study, by Kim et al, also failed to find an association between osteosarcoma and fluoridation, in addition to another 11 studies which also failed to find any link with fluoridation. But Fluoride Action Network says Kim merely “purported” to find no association and then went on to complain about things it said should have been studied instead. Not only does Connett assassinate the messenger, he manages to convincingly muddy the waters too.
And so it goes.

 

It has been said that restricting the flow of external information to one’s adherents is one of the hallmarks of a cult.
You might say that, but I couldn’t possibly comment.

 

Gerry Byrne,
Science Journalist

PS: I shortly hope to deal with Mr Boyden’s recent points in another email.

 

APPENDIX

Dr. Joseph Mercola has been the subject of a number of United States Food and Drug Administration Warning Letters related to his health advocacy activities:

02/16/2005 – Living Fuel RX(TM) and Coconut Oil Products – For marketing products for a medical use which classifies those products as drugs in violation of 201(g)(1) of the Federal Food, Drug, and Cosmetic Act.[51]

09/21/2006 – Optimal Wellness Center – For both labeling / marketing health supplements for purposes which would render them to be classified as regulated drugs as well failing to provide adequate directions for use upon the label in the event that they were legally sold as drugs.[52]

03/11/2011 – Re: Meditherm Med2000 Infrared cameras – For marketing a telethermographic camera for medical purposes which have not been FDA approved.[53]

12/16/2011 – Milk Specialties Global – Wautoma – Failure to have tested for purity, strength, identity, and composition “Dr. Mercola Vitamin K2” and others.[54]