Dr. Haley Rebuts the American Dental Association Position on Mercury
Amalgam Safety on Mercury Amalgam Safety


23 May 2001


The Honorable Dan Burton
Chairman
Committee on Government Reform
U.S. House of Representatives
Washington, D.C.



RE: May 11th letter by Robert M. Anderton, D.D.S., J.D., LL.M. and
President of the ADA, challenging my statement to the Committee on
Government Reform looking at the topic, Autism-Why the Increased
Rates? A One Year Update.

Dear Mr. Chairman:

At the April 25th meeting of your committee I gave testimony that the
President of the American Dental Association (ADA) takes exception to
in a letter sent to you dated 11 May 2001. Quoting from that letter
the testimony the ADA dislikes is "that elementary mercury from
dental amalgam could work synergistically with other ethyl-mercury
sources and have a cumulative toxic effect on the body. Dr. Haley
postulated that this could be a potential cause of autism and
Alzheimer's disease." I stand by my statement as a sensible concern
based on published scientific research regarding synergist toxicities
caused by two very toxic agents, mercury and the organic mercury
compound thimerosal. This concern is elevated since mercury exposure
from amalgams to a pregnant mother concentrates in the fetus and a
single vaccine given to a six-pound newborn is the equivalent of
giving a 180-pound adult 30 vaccinations on the same day. Include in
this the toxic effects of high levels of aluminum and formaldehyde
contained in some vaccines, and the synergist toxicity could be
increased to unknown levels. Further, it is very well known that
infants do not produce significant levels of bile or have adult renal
capacity for several months after birth. Bilary transport is the
major biochemical route by which mercury is removed from the body,
and infants cannot do this very well. They also do not possess the
renal (kidney) capacity to remove aluminum. Additionally, mercury is
a well-known inhibitor of kidney function. Common sense indicates
that the concern I expressed should be taken seriously since we do
not know how combined toxicities effect humans, especially in utero.
Consider the current epidemic death on birth of over 500 foals from
apparently healthy mares around Lexington, KY. These deaths were
identified as being due to a low level toxicity delivered by
caterpillars eating poison plants and later, on migration, depositing
their waste products on grass being eaten by the mares. The point
being it is the infant in utero that suffered most on exposure to low
level, toxins, not the mother. Combined mercury toxicities can be
devastating as I reference below and in the many references available
on the www.altcorp.com website. What is needed is research by non-
biased scientists to clarify this, something our FDA and NIDCR have
refused to do. As the American public find out what has happened
regarding this issue, they will be quite angry. This is a biomedical
science issue that should have been resolved a long time ago by the
responsible federal agencies.

Below I present detailed and referenced information supporting my
case and respond to various statements made by the ADA President that
I believe to be misleading and sometimes flagrantly wrong. The ADA
seems to think it has the right to select which research it believes
and to trash that research that says it is wrong, even though the
latter represents the bulk of published research. To address the
issues raised by the ADA President in his letter I will go in
sequential order of the comments made in the letter placing the ADA
comments in italics and providing scientific references for my
conclusions.

"There is no scientifically valid evidence linking either autism or
Alzheimer's disease with dental amalgam". First, mercury is a well-
known, potent neurotoxicant, and common sense would lead to the
conclusion that severe neurotoxins would exacerbate all neurological
disorders, including Parkinson's, ALS, MS, autism and AD. Several
research papers in refereed, high quality journals and scientific
publications have shown that mercury inhibits the same enzymes in
normal brain tissues as are inhibited in AD brain samples (1a-c, 2,
3). AD is pathologically confirmed post-mortem by the appearance of
neuro-fibillary tangles (NFTs) and amyloid plaques in brain tissue.
Published research, within the past year, has shown that exposure of
neurons in culture to sub-lethal doses of mercury (much less than is
observed in human brain tissue) causes the formation of NFTs (4), the
increased secretion of amyloid protein and the hyper-phosphorylation
of a protein called Tau (5). All three of these mercury-induced
aberrances are regularly identified as the major diagnostic markers
for AD. In the manuscript published in the J. of Neurochemistry (5)
the authors state "These results indicate that mercury may play a
role in the patho-physiological mechanisms of AD." In most of these
experiments, mercury and only mercury among the several toxic heavy
metals tested, caused the AD related responses reported. Many
medically trained individuals would agree that if something causes
the appearance of the pathological hallmarks confirming the disease
then it likely causes the disease. I at least have limited my claims
to exacerbation of these diseases to err on the side of caution.

Further, consider this about AD. A study of 500 sets of identical
twins from World War II era lead to the conclusion that sporadic AD
which represents 90% of the cases was not a directly inherited
disease. In many cases one twin would get AD and the other would not.
Genetic susceptibility is involved, but a toxic exposure is required
(e.g., if you are genetically susceptible to being an alcoholic you
still need to be exposed to alcohol to become one). The work by
Rose's group at Johns Hopkins University implicates APO-E genotype as
a "risk" factor with APO-E2 being protective and APO-E4 being a major
risk factor. APO-E2 has the ability to protect the brain from mercury
by having two additional thiol-groups to bind mercury appearing in
the cerebrospinal fluid whereas APO-E4 does not have this additional
capability (1). This may explain the proven genetic susceptibility to
AD of the APO-E4 carriers.

NIH has spent hundreds of millions of dollars to find a causal factor
for AD. Yet, no virus, yeast or bacteria has been identified so the
cause remains unknown to general science. The rate of AD per 1,000
population is nearly the same in California, Michigan, Maine, North
Carolina, Florida, Texas, etc. It is not significantly different for
rural versus urban individuals, or factory workers versus those with
outside jobs. So the primary toxicant that may be involved is most
likely not environmental. Therefore, it must be a very personal
toxicant, like what you put in your mouth. Since we place grams of a
neurotoxic metal, mercury, in our mouths in the form of dental
amalgam this makes it a good suspect for the exacerbation of AD---not
that all would be affected, just those that are genetically
susceptible, or those who become ill enough to fall prey to the
toxicity, or those that are also exposed to another synergistic toxin
(see below).

The one fact that ties mercury into a major suspect for AD is the
fact that most of the proteins/enzymes that are inhibited in AD brain
are thiol-sensitive enzymes. Mercury is one of the most potent
chemical inhibitors of thiol-sensitive enzymes and mercury vapor
easily penetrates into the central nervous system (2). Mercury is not
the only toxicant to inhibit thiol-sensitive enzymes. Thimerosal and
lead will do this also as well as reactive oxygen compounds created
in oxidative stress and many other industrial compounds. However,
mercury has been reported to be significantly elevated in AD brain
(14a,b, 15). Mercury is in many mouths being emitted from dental
amalgam and absolutely would exacerbate the clinical condition
identified as AD. Therefore, mercury should be considered as a causal
contributor since mercury can produce the two pathological hallmarks
of the disease and inhibits the same thiol-sensitive enzymes that are
dramatically inhibited in AD brain.

It is documented by a 1991 World Health Organization report that
dental amalgams constitute the major human exposure to mercury. Grams
of mercury are in the mouths of individuals with several amalgam
fillings. Further, the level of blood and urine mercury positively
correlates with the number of amalgam fillings. This was confirmed by
a recently published NIH funded study (6). Therefore, I fail to see
the ADA's viewpoint that there is no scientifically valid evidence
linking mercury from amalgams to exacerbating AD, especially since
mercury produces the diagnostic hallmarks of AD (4,5). The ADA hides
behind the fact that there has not been an epidemiological study to
attempt to correlate mercury exposure and AD. However, absence of
proof is not proof of absence. This also begs the question why the
ADA, the FDA and the National Institutes of Dental Craniofacial
Research (NIDCR) have not pushed for such a study? These agencies
know this would be immensely expensive and only the U.S. government
could afford to support any reliable long-term study. Yet, these same
responsible agencies have failed to confirm as safe the placing into
the mouth of Americans grams of the most toxic heavy metal Americans
are exposed to. The dental branch of the FDA has steadfastly refused
to investigate the toxic potential of dental amalgam.

Look at the references in the ADA letter! Even they must quote
Scandinavian literature to support their contentions of safety, and
even then they have to reference papers on fertility instead of
neurotoxicity! Where is the ADA, FDA and NIDCR supported U.S.
research in this area? Go to the NIH web-sites and look for research
on the safety of mercury from amalgams, or try to find an NIH study
concerning possible mercury involvement in any common neurological
diseases. NIH does support research on methyl-mercury, as we seem to
like beating up on the fishing industry whilst leaving the dental
industry alone. However, according to the NIH study about 90% of the
mercury in our bodies is elemental mercury, not methyl-mercury,
showing the exposure is more likely from dental amalgams rather than
fish (6). Support at NIH has been very sparse for investigating the
relationship of elemental mercury exposure to neurological diseases.

"And there is no scientifically valid evidence demonstrating in vivo
transformation of inorganic mercury into organo mercury species in
individuals occupationally exposed to amalgam mercury vapor". There
was a paper published entitled "Methylation of Mercury from Dental
Amalgam and Mercuric Chloride by Oral Streptococci in vitro" (19).
This strongly indicates that "organo mercury species" are indeed
capable of being made in the human body and may explain the
appearance of methyl-mercury in the blood and urine of individuals
who don't eat seafood.

Further, periodontal disease is considered one of the major risk
factors for stroke, heart and cardiovascular disease and late onset,
insulin independent diabetes. Many studies of the toxicants produced
in periodontal disease have identified hydrogen sulfide (H2S) and
methane-thiol (CH3SH) as major toxic products of infective anerobic
bacteria in the mouth metabolizing the amino acids cysteine and
methionine, respectively. These volatile thiol-compounds are what
cause bad-breath! Methane-thiol (CH3SH) would react immediately and
spontaneously in the mouth with amalgam generated mercury cation to
produce the following two compounds, CH3S-HgCl and CH3S-Hg-SCH3,
which are organo-mercurial compounds (check this out with any
competent chemist). They are also very similar in structure to methyl-
mercury (CH3-HgCl) and dimethyl-mercury (CH3-Hg-CH3), the latter
which caused the highly publicized death of a University of Dartmouth
chemistry professor 10 months after she spilled two drops on her
gloved hand. We have synthesized CH3S-HgCl and CH3-Hg-CH3 in my
laboratory and tested their toxicity in comparison to Hg2+. As
expected, they were both more toxic than Hg2+ and this data is
available on the www.altcorp.com web-site. Therefore, the ADA
President is badly misinformed on this issue. Additionally, I am
amazed that the researchers at the ADA and NIDCR did not previously
report on this obvious chemistry as I would imagine this is the kind
of topic they should be addressing.

"Based on currently available scientific evidence, the ADA believes
that dental amalgam is a safe, affordable and durable material for
all but a handful of individuals who are allergic to one of its
components. It contains a mixture of metals such as silver, copper
and tin, in addition to mercury, which chemically binds these
components into a hard, stable and safe substance." This is a totally
wrong statement unless you underline the "ADA believes" and define
how big is a "handful of individuals". Sensible people
want "believes" replaced with "knows" and a "handful" replaced with
a "hard number". Amalgams emit dangerous levels of mercury and the
ADA absolutely refuses to accept this fact or even to study the
possibility. Otherwise, the ADA administrators seem to be unable to
separate fact from fiction. Consider, if they wanted to destroy my
argument on amalgam toxicity they would reference several solid,
refereed publication showing that mercury is not emitted from dental
amalgams---but they cannot do this with even one article. They always
state the "estimate" is that a very, very, very small amount.
Competent, well-informed researchers don't use the evasive language
used in the ADA President's letter. They would state the amount is so
many micrograms mercury released per centimeter squared amalgam
surface area and a "handful of individuals" would be a percentage of
our population! Lets look at the published literature.

First, careful evaluation of the amount of mercury emitted from a
commonly used dental amalgam in a test tube with 10 ml of water was
presented in an article entitled "Long-term Dissolution of Mercury
from a Non-Mercury-Releasing Amalgam". This study showed that "the
over-all mean release of mercury was 43.5 ± 3.2 micrograms per
cm2/day, and the amount remained fairly constant during the duration
of the experiments (2 years)" (7). This was without pressure, heat or
galvanism as would have occurred if the amalgams were in a human
mouth. Further, research where amalgams containing radioactive
mercury were placed in sheep and monkeys, showed the radioactivity
collecting in all body tissues and especially high in the jaw and
facial bones. (8,9). Another publication, from a major U.S. School of
Dentistry, stated that solutions in which amalgams had been soaked
were "severely cytotoxic initially when Zn release was highest" (13).
Zn is a needed element for body health and is found in very low
percentages in dental amalgams when compared to mercury and why
mercury was not mentioned in the abstract of this publication baffles
me. Why would the statement be true? Because Zn2+ is a synergist that
enhances mercury toxicity! However, does this sound like amalgams are
a safe, stable material? We have repeated similar amalgam soaking
experiments in my laboratory and the results can be seen at
www.altcorp.com. Cadmium (from smoking), lead, zinc and other heavy
metals enhanced mercury toxicity as expected (this research is
currently being prepared for publication).

The ADA claim that a zinc oxide layer is formed on the amalgams that
decreases mercury release is true, if you don't use the teeth. The
zinc oxide layer would be easily removed by slight abrasion such as
chewing food or brushing the teeth. Further, my laboratory has
confirmed that solutions in which amalgams have been soaked can cause
the inhibition of brain proteins that are inhibited by adding mercury
chloride, and these are the same enzymes inhibited in AD brain
samples.

Further, mercury emitting from a dental amalgam can be easily
detected using the same mercury vapor analysis instrument used by
OSHA and the EPA to monitor mercury levels. Anyone who does not
believe mercury is emitted from amalgams should consider doing the
following. Have your local dentist make 10 amalgams using the same
material he/she places in your mouth. Take these 10 amalgams to your
nearest research university's department of chemistry or toxicology
department and have them determine how much mercury is being emitted.
For example, have them calculate how long it would take a single
spill of hardened amalgam to make a gallon of water too toxic to pass
EPA standards as drinking water. You will then have an answer from an
unbiased, solid group of scientists who are trained to do such
determinations. Also, remember the level of mercury they measure
would not include the increase that would occur with amalgams in the
mouth where chewing, grinding your teeth, drinking hot liquids and
galvanism greatly increase the release of mercury. Since this
approach can be easily done by anyone don't you think the ADA, FDA
and other amalgam supporters would have this published by now if the
level of mercury released was below the danger level?

Here is their attempt. According to an ADA spokesman he
has "estimated" that only 0.08 micrograms of mercury per amalgam per
day is taken into the human body. Applying simple math to
this "estimate" of 0.08 micrograms/ day one would divide this amount
by 8,640 (24 hours/day X 60 minutes/hour X 6 ten second
intervals/minute) to determine the amount of mercury in micrograms
available for a ten second mercury vapor analysis. Consider that
somewhere between one-half to five-sixths of the mercury released
would be into the tooth (that area of the amalgam that exists below
the visibly exposed amalgam surface) and not into the oral air. In
addition, some mercury in the oral air would be rapidly absorbed into
the saliva and oral mucosa (mercury loves hydrophobic cell membranes)
and also not be measured by the mercury analyzer. Further, as the
mercury analyzer pulls mercury containing oral air into the analysis
chamber, mercury free ambient air rushes into the oral cavity
decreasing the mercury concentration. Taking all of this into account
you can calculate that most mercury analyzers could not detect
this "estimated" 0.08 micrograms/day level of mercury even if you had
several amalgams. However, the fact is that it is quite easy to
detect mercury emitting from one amalgam using these analyzers.
Therefore, the "estimate" by this ADA spokesman is way to low. Also,
if you gently rub the amalgam with a tooth-brush the amount of
mercury emitted goes up dramatically. This is a test anyone can do
and demonstrate to any group. The ADA spokesmen state that the
mercury vapor analyzer is not accurate at determining oral mercury
levels and they are quite correct. However, using this instrument
would greatly underestimate the amount of mercury exiting the
amalgam. The very fact that the mercury analyzer detects high levels
of oral mercury strongly indicates the emitted amount of mercury is
too high to be acceptable.

Mercury release from dental amalgams is also the reason OSHA has used
this analyzer to make the dentists place unused amalgam in a sealed
container under liquid glycerin. This is done so that the mercury
vapors from the amalgams will not contaminate the dental office
making it an unsafe place to work. This is also the reason the EPA
insists that removed amalgam filling and extracted teeth containing
amalgam material be picked up and disposed of as toxic waste.
Apparently, the only safe place for amalgams is in the human mouth if
you believe what the ADA believes.

"Amalgams have been used for 150 years and, during that time, has
established an extensively reviewed record of safety and
effectiveness." First, what other aspect of industry or medicine is
still using the same basic manufactured material that they used 150
years ago? One has to ask the question as to what has hindered the
progress of development of better and safer dental materials? Also,
consider that in the early 1900s the average life expectancy of most
Americans was about 50 years of age and most of them could not afford
dental fillings. Fifty to sixty years is much less than the average
age of onset of AD. Further, amalgams became more available to most
working class Americans after World War II, or in the early 1950s.
The greatest increase in the use of amalgam occurred at about this
time and these 'baby boomers are the great ongoing amalgam
experiment'. They are now reaching the age where AD appears and have
lived most of their lives carrying amalgam fillings. They also wonder
what is causing their chronic fatigue as the physicians can find
nothing systemically wrong with them. I would encourage all concerned
to contact the health experts on the rate of increase of AD in the
U.S.A. at this time. Consider the cost it will place on the taxpayer
and how much we would save if we could even remove the exacerbation
factors that might speed up the onset of AD. I must point out that
the "extensively reviewed record of safety" mentioned in the ADA
letter was mostly done by dentists and committees dominated by ADA
dentists. Also, much of the "safety opinion" was developed long
before words like Alzheimer's disease and chronic fatigue were
commonplace. Further, these were "reviews" and not carefully
documented studies based on scientific experimentation and done by
unqualified dentists, not medical scientists. Dentists are not
trained to do basic research, nor are they trained in toxicology.
Furthermore, the ADA does have a vested interest in keeping amalgam
use legitimate. The ADA was founded on using amalgam technology and
participated in patenting and licensing amalgam technology. One has
to question why there has not been a general outcry by the bulk of
well-meaning dentists and their patients and this question should be
addressed. The International Association of Oral Medicine and
Toxicology, started by American & Canadian dentists, does adamantly
disagree with the ADA on the issue of safety of dental amalgams and
this organization has the mantra of "Show me your science" with
regards to all dental issues.

The ADA, through state dental boards stacked with ADA members, has
instigated a "gag order" preventing dentists from even mentioning to
their patients that amalgams are 50% mercury. Dentists cannot state
that mercury is neurotoxic and emits from amalgams and that the
dental patient should consider this as they select the tooth filling
material they want used. If a dentist informs a patient of these very
truthful facts he will be consider not to be practicing good
dentistry and his license will be in jeopardy. Attacking a person's
freedom of speech because he is telling the truth and causing serious
questions to be asked about the protocols pushed by a bureaucracy
(the ADA) makes me seriously question the commitment the ADA has for
the health of the American people. The negative stand taken by many
state dental boards against even informing the patients about the
mercury content of amalgams and the other filling choices they have
does not speak well for the organized dental profession. What medical
group would give a treatment to a patient without telling them of the
risks involved?

"Issued late in 1997, the FDI World Dental Federation and the World
Health Organization consensus statement on dental amalgam stated "No
controlled studies have been published demonstrating systemic adverse
effects from amalgam restorations."" My first comment would be to
question "who staffed these committees and what percentage were
connected to the ADA though the NIDCR or the FDA dental materials
branch or other relationships?" We appear to have the foxes guarding
the henhouse! Then I would again point out that "absence of proof is
not proof of absence". I would then ask 'have any controlled studies
been done and if not, why not?' If the ADA dentists insist on placing
amalgams in the mouth, are they not required to show it is safe, not
the other way around? Should not the ADA and others concerned push to
require the FDA to prove amalgams are safe instead of totally ducking
this issue. Go to the FDA dental materials web-site and try to find
any evaluation of amalgam safety---you will not succeed. The dental
branch of the FDA refuses to do a safety study on amalgams and this
is shame on our government.

"the small amount of mercury released from amalgam restorations,
especially during placement and removal, has not been shown to cause
anyadverse effects." This increase in mercury exposure has also not
been shown to be safe by proving it does not cause any adverse
effects! Are we to believe this elevated exposure to a toxic metal is
good for us? If one were in a building that caused the rise in
blood/urine mercury that appears after dental amalgam removal, then
OSHA would shut the building down. In fact, no study by the ADA or
NIDCR has been completed that specifically and accurately addresses
this issue. Yet, the ADA leads us to believe that additional exposure
to toxic mercury from these procedures is not dangerous to our
health. Mercury toxicity is a retention toxicity that builds up
during years of exposure. The toxicity of a singular level of mercury
is greatly increased by current or subsequent, low exposures to lead
or other toxic heavy metals (12). Therefore, the damage caused by
amalgams could occur years after initial placement and at mercury
levels now deemed safe by the ADA.

Our ability to protect ourselves from the toxic damage caused by
exposure to mercury depends on the level of protective natural
biochemical compounds (e.g. glutathione, metallothionine) in our
cells and the levels of these protecting agents is dependent upon our
health and age. If we become ill, or as we age, the cellular levels
of glutathione drop and our protection against the toxic effects of
mercury decreases and damage will be done. This is strongly supported
by numerous studies where rodents have been chemically treated to
decrease their cellular levels of protective glutathione and then
treated with mercury, always with dramatic injurious effects when
compared to controls. Therefore, published science indicates that
mercury toxicity is much more pronounced in infants, the very old and
the very ill.

A recent NIH study on 1127 military men showed the major contributor
to human mercury body burden was dental amalgams. The amount of
mercury in the urine increased about 4.5 fold in soldiers with the
average number of amalgams versus the controls with no amalgams. In
extreme cases it was over 8 fold higher. Since the total mercury
included that from diet and industrial pollution are we to expect
that this 4.5 to 8 fold average increase in mercury is not
detrimental to our health? Does this indicate that amalgams are
a "safe and effective restorative material"? Is the public and
Congress expected to be so naïve as to believe that increased
exposure above environmental exposure levels is not damaging? Then
why are pregnant mothers told to limit seafood intake when mercury
exposure from amalgams is much greater? Then why is the EPA pushing
regulations to force the chloro-alkali plants and fossil fuel plants
to clean up their mercury contributions to our environment?
Obviously, from this study most of the human exposure to mercury is
from dental amalgams, not fossil fuel plants. Yet, the FDA lets the
dental profession continue to expose American citizens to even
greater amounts of mercury. They do this by refusing to test amalgam
fillings as a source of mercury exposure. Also, remember that the
amalgam using ADA dentists are a major contributor to mercury in our
water and air through mercury leaving the dental offices, and even
when we are cremated.

"The ADA's Council on Scientific Affairs 1998 report on its review of
the recent scientific literature on amalgam states: "The Council
concludes that, based on available scientific information, amalgam
continues to be a safe and effective restorative material."
and "There currently appears to be no justification for discontinuing
the use of dental amalgam." What would you expect an ADA Council to
say? The ADA, as evidenced in the current letter by the President of
the ADA, only quotes and considers valid the published research that
supports their desire to continue placing mercury containing amalgam
fillings in American citizens. When were dentists trained to evaluate
neurological and toxicological data and manuscripts? What is needed
is an international conference where both the pro- and anti-amalgam
researchers show up and present their data in front of a world-class
scientific committee. I would challenge the ADA to line up their
scientists and supporters to participate in such a conference. This
could be held in Washington, D.C. so the FDA officials could easily
attend. Perhaps we could persuade the FDA to sponsor such a
conference. However, this is unlikely since a recent written request
to have a conference to evaluate the safety of amalgams was rejected
in a letter from the FDA and signed by three FDA/ADA dentists who
presented the ADA line on this issue. Doesn't it seem a bit
fraudulent to have FDA/ADA dentists deciding on whether or not a
safety study should be done on mercury emitting amalgams being placed
in human mouths with the blessing of the ADA? This does seem like a
conflict in interest that Congress should address.

"In an article published in the February 1999 issue of the Journal of
the American Dental Association, researchers report finding "no
significant association of Alzheimer's disease with the number,
surface area or history of having dental amalgam restorations." This
research was lead by a dentist, Dr. Sax. It was submitted to the J.
of the American Medical Association and rejected. It was then
submitted to the New England Journal of Medicine and rejected. It was
then published in the ADA trade journal, JADA, that is not a
refereed, scientific journal. JADA is loaded with commercial
advertisements for dental products. They even called a "press
conference" announcing the release of this article! Calling a press
conference for a twice-rejected publication that is to appear in a
trade journal is playing politics with science at its worst! At this
press conference two of the authors made unbelievable statements that
were not supported by any of the data in the article and conflicted
with numerous major scientific reports, including the 1998 NIH study
(6). Some of these were high-lighted in the side-bars of the ADA
publication. I would suggest that those concerned with this article
visit Medline and look at the publication records of the two
individuals who made these statements. Also, look at the three
earlier excellent publications in refereed journals by some of the
other authors showing significant mercury levels in the brains of AD
subjects compared to controls (14a,b, 15). However, put a dentist in
charge of the project and the data gets reversed!

Apply some common sense. The ancillary comments by some of the
authors and the results of the JADA publication are in total
disagreement with the vast majority of research published that looks
at elevated mercury levels in subjects with amalgam fillings. For
example, the NIH study on military men discussed above showed a very
significant elevation of mercury in the blood that correlated with
number of dental amalgams (6). Another recent publication
demonstrated elevated mercury in the blood of living AD patients in
comparison to age-matched controls (10). These studies clearly show
that there should be increased mercury in your blood if you have
amalgams and especially if you have AD and amalgams (6,10). Does not
the brain have blood in it? This makes it a total mystery as to how
could the authors of the JADA article not find elevated brain mercury
levels in patient with existing amalgams and/or AD. Even cadavers
have brain mercury levels that correlate with the number of amalgam
fillings they had on death.

Further, if you are addressing the contribution of amalgams to brain
mercury and AD wouldn't it be important to divide the AD and control
subjects into those with and without existing amalgams on death? In
the JADA article this was not done and represents a major research
flaw! That this was not done also arouses suspicion. I participated
in submitting a letter pointing out this flaw to editors of JADA but
they refused to acknowledge the letter and did not publish our
comments. It is my opinion that the entire situation around this
singular supportive publication of the ADA position on amalgams,
brain mercury levels and AD represents a weak attempt at controlling
the mind-set of well-meaning dentists, scientists, physicians and
medical research administrators. It definitely impedes honest
scientific debate. It also explains the cavalier attitude of the ADA
and NIDCR about elemental mercury exposure and toxicity when compared
to the more serious approaches taken by the EPA and OSHA.

With regards to the JADA article summary that "no statistically
significant differences in brain mercury levels between subjects with
Alzheimer's disease and control subjects." Here I must quote Mark
Twain on honesty, "There are liars, damned liars and statisticians."
Comparing the level of mercury in the AD versus control alone using
straight-forward statistics previously showed a significant
difference on mercury levels in AD versus control subjects (14a,b,
15). However, there are anomalies, confounders and other factors that
can be considered in this situation, especially if you don't like the
initial results. This allows one to invoke a Bon-Feroni statistical
manipulation. With Bon-Feroni you include the comparison of one pair
of data (that may be statistically significantly different taken
alone, e.g. mercury levels in the brains of AD versus control
subjects) with several other pairs of data rendering the difference
statistically insignificant. One known weakness of the Bon-Feroni
treatment of several coupled pairs of comparisons is that one very
likely will miss a single comparison that is significantly different,
and clever people know this. It is my opinion that application of the
Bon-Feroni manipulation is what happened in this JADA study that
reversed the previous significance of the mercury levels in AD versus
control brain previously reported. Research previously reported by
some of the very same researchers involved in the JADA study
consistently indicated that mercury levels were higher in AD versus
age-matched control brains (14a,b, 15). Only when an ADA dentist
became involved did the results change to being insignificant. I
think the data used in this JADA article and funded by NIH needs to
be re-evaluated by a different statistician if we are to ever really
know if the mercury levels in the AD brains differed significantly
from controls.

The letter from the ADA President then lists four publications as
proof of amalgams having no statistically significant negative
effects. Two of these were published in Scandinavian Journals,
another was a review of the literature in a Dental Journal, and one
was the JADA article mentioned above. Sweden is well known to have
lead the world in the restriction and replacement of dental amalgams
with non-mercury containing materials. Forces are pushing hard to get
the use of amalgams accepted again in Sweden to eliminate this
embarrassment to our ADA. The current situation in Sweden and some
other European countries, Canada and Japan seriously questions the
ADA contention of amalgam safety. What if people in Sweden become
healthier without amalgams?

Additionally, the studies quoted by the ADA President were
epidemiological studies. These are very complex as many confounders
are included which make finding a statistically significant
difference very difficult. So the results are negative, nothing
found, and not surprising. However, they are in disagreement with
numerous other similar reports and appear to be hand-selected to
support the ADA position. One has to wonder, since the ADA President
seemed to visit Swedish journals to support the ADA position, how he
missed the research of the Nylander group in Sweden that showed
increased mercury content in brains and kidneys of humans in
relationship to exposure to dental amalgams (17,18). Also, the
referenced studies in the ADA letter did not involve neurotoxicity,
autism or neurological disease---which is the question at hand.
Rather, they addressed fertility, reproduction and other systemic
illnesses. Could not the ADA find references to focus on
neurotoxiological studies? What about the 1989 study that showed
elevated levels of mercury in 54 individuals with Parkinson's disease
when compared to 95 matched controls (16)? Further, one ought to
consider who was doing these touted ADA studies and any vested
interest they may have in the outcome. I am also aware of studies
done in the U.S.A. by major research universities that would disagree
with the conclusions drawn by the ADA on this subject yet these
articles are not considered in the ADA letter.

At the end of the last publication the quote "Conclusions: No
statistically significant correlation was observed between dental
amalgam and the incidence of diabetes, myocardial infarction, stroke,
or cancer." How does this relate to an article published in the J. of
the American College of Cardiology where the mercury levels in the
heart tissue of individuals who died from Idiopathic Dilated
Cardiomyopathy (IDCM) contained mercury levels 22,000 times that of
individuals who died of other forms of heart disease? Where did this
tremendous amount of mercury come from? Even a Bon-Feroni
manipulation could not make this difference insignificant! Many who
die of IDCM are well-conditioned, young athletes who drop dead during
sporting events---and they live in locations and in economic
environments where sea-food is not a dietary mainstay. Perhaps the
victims of IDCM are within the ADA Presidents "handful of individuals
who are allergic to one of its components."

"The National Institute of Dental and Craniofacial Research is
currently supporting two very large clinical trials on the health
effects of dental amalgam. Studies underway for several years each in
Portugal and the Northeastern United States involve not only direct
neurophysiological measures but also cognitive and functional
assessments." Do we really think that the NIDCR and associated ADA
personnel are going to deliver up a conclusion to American parents
saying "we put a mercury containing toxic material in your child's
mouth that lowered his/her I.Q. and made him more susceptible to
neurological problems in comparison to the children whom we selected
to not get exposed to this toxic material"? It is my opinion that
most bureaucracies don't have a brain or a heart, but they do have a
very strong survival instinct. Therefore, the results presented from
this study will likely follow previously ADA supported research, i.e.
no significant results.

Since the NIDCR started this project only 4 years ago one has to ask
why it took so long for them to get involved since the "amalgam wars"
have been going on for scores of years? Was it the overwhelming
amount of modern science showing mercury from amalgams being a major
part of the daily exposure that forced their hand and they had to
develop a defense? Would I trust the conclusions of this study
without knowing who put it together and who did the statistics? Not
any more than I trust the conclusions of the JADA article mentioned
in the ADA letter that stupendously concludes that mercury from
dental amalgams does not get into the brain.

As was proven by the tobacco situation, trying to find any
significant negative effect of one product (amalgams) related to any
disease through epidemiological studies is very difficult and
complex. To do this with mercury would be difficult because of the
synergistic effect two or more toxic metals or compounds (e.g.
cadmium from smoking) may have on the toxicity of the mercury emitted
from amalgams. For example, one publication showed that combining
mercury and lead both at LD1 levels caused the killing rate to go to
100% or to an LD100 level (12). An LD1 level is where, due to the low
concentrations, the mercury or the lead alone was not very toxic
alone (i.e., killed less than 1% of rats exposed when metal were used
alone). The 100% killing, when addition of 1% plus 1% we would expect
2%, represents synergistic toxicity. Therefore, mixing to non-lethal
levels of mercury plus lead gave an extremely toxic mixture! What
this proves is that one cannot define a "safe level of mercury"
unless you absolutely know what others toxicants the individual is
being exposed to. The combined toxicity of various materials, such as
mercury, thimerosal, lead, aluminum, formaldehyde, etc., is unknown.
The effects various combinations of these toxicants would have is
also not defined except that we know they would be much worse than
any one of the toxicants alone. So how could the ADA take any
exception, based on intellectual considerations, to my contention
that combinations of thimerosal and mercury could exacerbate the
neurological conditions identified with autism and AD? Autism and AD
have clinical and biological markers that correspond to those
observed in patients with toxic mercury exposure. Why would the ADA
take this position? I personally feel like I have been in a ten year
argument with the town drunk on this issue. Facts don't count and
data is only valid if it meets the pro-amalgam agenda.

The ADA was founded on the basis that mercury-containing amalgams are
safe and useful for dental fillings. This may have been an acceptable
position in 1850. However, modern science has proven that amalgams
constantly emit unacceptable levels of mercury. Especially as the
average life span has increased from 50 to 75-78 years of age where
AD and Parkinson's become prevalent diseases. The ADA can try to
verify its position using selected epidemiological studies. But the
bottom line is that amalgams emit significant levels of neurotoxic
mercury that are injurious to human health and would exacerbate the
medical condition of those individuals with neurological diseases
such as ALS, MS, Parkinson's, autism and AD.

I am hoping that the ADA sent this letter to your committee and also
placed it on the ADA web-site to indicate that they are now willing
for a wide-open discussion to take place on the issue of dental
amalgams. I, for one, would welcome a major scientific conference on
this issue. The ADA should feel free to post my letter in response
and address any issue they feel that I am mistaken about. However, in
closing I urge your committee to push forward on the study of the
potential dangers of mercury in our dentistry and medicines. This
includes mercury exposures from amalgams, vaccines and other
medicaments containing thimerosal. The synergistic effects of mercury
with many of the toxicants commonly found in our environment make the
danger unpredictable and possibly quite severe, especially any
mixture containing elemental mercury, organic mercury and other heavy
metal toxicants such as aluminum.

Sincerely,



Boyd E. Haley
Professor and Chair
Department of Chemistry
University of Kentucky



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