# HOLISTIC DENTAL ASSOCIATION

P. O. Box 5007

Durango, CO 81301

Phone/FAX: 970-259-1091

e-mail: <hda@frontier.net>

September 14, 2002

Food & Drug Administration

Dockets Management Branch

5630 Fishers Lane, Room 1061-HFA-305

Rockville, MD 20852

Dear Sirs:

This letter is in response to:

> **Docket \# 01N-0067 -- AGAINST the FDA Rule on Mercury Dental
> Fillings**

The Holistic Dental Association, founded in 1978, is a national
organization of dental healthcare professionals whose members believe
that the accepted concepts in modern dentistry are, unfortunately,
limited in scope, do not recognize the physiologic effects, and
unintentionally cause harm to a significant number of individuals.
Virtually all HDA members do NOT place mercury (amalgam) fillings in
their patient's mouths because of this potential risk.

It is difficult to understand how intelligent and educated healthcare
professionals can ignore the large amount of existing science and
clinical observations that cast doubt on the safety of mercury in
amalgam fillings. Dentistry has alternatives to mercury fillings, and
every dentist knows about them. And even though there is controversy
about the use of mercury fillings, shouldn't the public be adequately
and objectively informed and given the option of choosing what materials
are used to restore their teeth? Most patients are uninformed about the
materials used and the benefits/risks of each. The American Dental
Association, to its credit, very recently produced an informational
brochure about dental materials, but it is inadequate because it doesn't
address the potential problems of toxicity and oral galvanism.

I am sure others have informed the FDA about the health issues of
mercury, but I would like to reiterate some basic, but key facts:

1\. There is overwhelming scientific evidence to support that mercury is
a toxin. It is

regulated as such, the exception being when used as a dental restorative
material. It is

classified as hazardous before placement in the mouth and after its
removal from the mouth,

but not while in the mouth. Where is the logic in this?

2\. It is a proven fact that mercury is not chemically bound in amalgam
fillings as was believed

in the recent past, and therefore mercury vapor is constantly released
into the mouth.

3\. There is scientific research indicating a possible link between
mercury and chronic illness.

4\. Children and fetuses are highly susceptible to mercury toxicity.

-2-

Some references that support these statements:

Web site: www.dams.cc

Web site: www.amalgam.org

Web site: www.icnr.com/uam/MercuryCourse.html

Web site: www.vimy-dentistry.com

Web site: www.cfsn.com/dental.html

Web site: www.fplc.edu/risk/vol2/spring/royal.htm

Web site: vest ab.gu.se/\~bosse/Mercury/Mouth/Mail/gammalcontra.html

Web site: www.listserv.gmd.de/archives/amalgam.html

Book: The Mercury in Your Mouth: The Truth About \"Silver\" Dental
Fillings

> by Quicksilver Associates

Book: Toxic Metal Syndrome by Drs. H. Richard Casdorph & Morton Walker

Book: It\'s All in Your Head by Hal Huggins, DDS

Book: Mercury Free by James E. Hardy

Book: Solving the Puzzle of Mystery Syndromes by Mary Davis

Book: Amalgam Illness: Diagnosis and Treatment by Andrew Cutler

Book: 150 Years of Amalgam by Fredrik Berglund, M.D., Ph.D.

Book: Book: ABC's of Mercury Poisoning from Dental Amalgam Fillings
Handbook for

Victims of Mercury Poisoning by Mats Hanson, Ph.D.

Book: Chronic Fatique -- Poisoned by the Mercruy in Your Mouth? by
Annika and John

McClintock and Christer Malmström DDS

Book: [Does Mercury From Dental Amalgams Influence Systemic
Health?](http://www.bioprobe.com/shopping/product_description.asp?sku_num=B42&d=1)
by Gary A. Strong,

D.D.S.

Book: [Infertility & Birth Defects - Is Mercury From Silver Dental
Fillings A Hidden
Cause?](http://www.bioprobe.com/shopping/product_description.asp?sku_num=B22&d=9)
by

Sam Ziff and Dr. Michael F. Ziff.

Book: [Mercury Poisoning from Dental Amalgam - A Hazard to Human
Brain](http://www.bioprobe.com/shopping/product_description.asp?sku_num=B20&d=9)
by Patrick

Störtebecker, M.D., Ph.D.

Book: [Silver Dental Fillings - The Toxic Time
Bomb](http://www.bioprobe.com/shopping/product_description.asp?sku_num=B19&d=9)
by Sam Ziff

Book: The Missing Link? -- A Persuasive New Look at Heart Disease as it
Relates to

Mercury by Michael F. Ziff, D.D.S. and Sam Ziff.

**Please realize this letter represents about 160 dentists and their
staffs who deal with these problems firsthand, almost everyday.** For
us, it is not just an academic discussion or a debate of scientific
research, it is up close and personal! I think it is accurate to say
that those dentists, staffs, professional dental organizations, and
educational institutions who argue the opposite point of view, or are
silent on the issue, have little experience treating this type of
patient and/or have not *personally* read the literature referenced.

The FDA takes great care in not approving products that pose a potential
risk to the health of its citizens. All we ask is that you use the same
objectivity and due diligence when deciding this issue.

Sincerely,

Ronald L. King, DDS

President, Holistic Dental Association

Member, Minnesota Board of Dentistry