Comment to Dkt #2006N0352, Mercury Fillings
Charles G. Brown, National Counsel
Consumers for Dental Choice
charlie@toxicteeth.org
October 30, 2006
Special Controls of Draft Amalgam Regulation
Disclose Zinc In Order to Cover Up the Mercury
FDA’s draft regulation intentionally covers up the mercury. In the Special Controls, incorporated by FDA’s in-house dentist and mercury fillings advocate Susan Runner, the mandated disclosure is of ZINC. Dentists are allowed to hide the presence of mercury. Yet amalgam is 50% mercury, a neuro-toxin for which there is no safe level. Zinc is not a toxin.
Repeat: FDA proposes to tell consumers that amalgam has non-toxic zinc, while allowing the pro-mercury dentists to hide the mercury. The only justification here is to hide the mercury, the goal of the pro-mercury Dental Devices Branch and apparently the Director and Deputy Director of the Center on Devices who signed onto this draft regulation.
Even though testifying unequivocally for this pro-mercury regulation, Assistant Commissioner Alderson told me he was not aware of this fact, nor did he support disclosing zinc while hiding the mercury, he said. For this FDA official to stand before two scientific panels and blindly defend what he has not carefully read is a dereliction of his responsibilities.
The Special Controls, drafted two decades ago by dentists and devoid of scientific basis, are in place to protect dentists who continue to expose pregnant women and children, unknowingly, to mercury. For a proud agency like FDA to lower itself to kowtowing to the one special interest group that advocates mercury in health care is indicative that politics, not science, rules at the Center on Devices & Radiological Health.