From: Dr. Jacques Imbeau [Dr.Imbeau@xtra.co.nz]
Sent: Thursday, August 24, 2006 10:07 PM
To: Adjodha, Michael E
Cc: charlie@toxicteeth.org
Subject: Mercury / dental amalgam

Dear Mr. Adjodha;

I have been informed of the possibility of bias in the upcoming FDA review of dental amalgam. I sincerely hope that this is not the case.

The public should be properly informed about dental amalgam and the fact that an amalgam is by definition a mercury-based compound. Government in various countries have advised against the use of amalgam in children and pregnant women. 
Some countries, such as Japan, Norway, and Sweden, have banned or stringently regulated the use of mercury in dental amalgams, citing health concerns. The Swedish Chemicals Inspectorate (KemI) maintains a web site containing a report on the investigation for a general ban on mercury on which it states, "KemI judges that there are strong grounds for banning amalgam for environmental reasons. From a health point of view there is every reason to apply a precautionary approach." Some countries, notably Austria and Germany, have some restrictions on dental amalgam, such as permitting its use for the general population, but not for children, pregnant women, people with kidney problems, when in contact with other metals, such as braces, and in people with mercury sensitivity. Surely the scientific evidence upon which these actions are based is as valid in the USA as it is overseas.

It is important that the FDA perform is regulatory function in a transparent manner and that qualified scientists, not only dentists, are invited to testify on this important subject.  While dental amalgam has been in use for over a century, it was mainly initially adopted by craftsman-dentists with little or no training in medicine while those with medical training were strongly opposed to it's use. In fact at the time, most dentists with medical training were outraged to find their patients turning to opportunists using untested and potentially dangerous materials. Dr. Chapin Harris, who in 1840 co-founded the first dental school in the US, the Baltimore College of Dental Surgery, said in his opening address: "It is one of the most objectionable articles for filling teeth that can be employed, and yet from the wonderful virtues ascribed to this pernicious compound by those who used it, thousands were induced to try its efficacy"

The ADA maintained until 1984 that mercury was bound in amalgam and did not release mercury vapor. It is interesting to note however that in the 1970's numerous studies demonstrated that a small amount of mercury vapor was constantly being released from amalgam, corroborating the first such study published in 1882 in the Ohio State Journal of Dental Science by Dr. Eugene S. Talbot. A good example of you valid scientific evidence can be ignored when it does not support the objective of a group or organization. Needless to say the fact that the ADA maintained a wrong position from 1882 to 1994 ( since Dr. Talbot proved that mercury vapor escaped constantly from amalgam - http://art-bin.com/art/otalbot1882.html ) should be a warning sign.

Sincerely;


Jacques Imbeau D.M.D., FACNEM (Dent), NZDREX


C.C.  Mr. Charles G. Brown, National Counsel, Consumers for Dental Choice