2014 Health Select Committee - Limiting mercury exposure in the human population Submission 21 January 2014

21 January 2014

The Clerk and Members of the Health Select Committee

c/o Parliament Buildings

Private Bag 18 888

WELLINGTON 6160

Dear Clerk and Committee Members

Submission on limiting Mercury exposure in the human population

Mercury toxicity poses a serious threat to public health.

Regulating bodies often give approvals based on official acceptable daily intake level of mercury. Unfortunately, such decisions rarely if ever take into account the cumulative effects over time of the application in question, of like applications, other sources of mercury, and/or the interaction with other elements. Despite daily doses for methyl mercury being calculated (US EPA figures), the fact remains that they are calculated on an ‘average’ human when no two human subjects would be the same. The figure takes no account of bio-accumulative effects from multiple sources.

Chronic mercury toxicity is claimed by some to have reached epidemic proportions. A study by New Zealander Dr Damian Wojcik[1] indicates the current common occurrence of chronic mercury toxicity in this country. In his medical practice, he checked 864 patients seen consecutively and found 30.3% of them had evidence consistent with chronic mercury toxicity[2], close to one in three New Zealanders.

Mercury can be absorbed through the skin and mucous membranes, mercury vapours inhaled, and ingested methyl mercury is readily absorbed by the gastrointestinal tract. Any of these processes test all members of society, especially the elderly, the very young and those with an already challenged immune system. Based on the number of births annually, research estimated that more than 75,000 newborns in the US each year may have increased risk of learning disabilities associated with in-utero exposure to methyl mercury.[3] Methyl mercury exposure in adults has been linked to increased risk of cardiovascular disease including heart attack. Some evidence suggests that methyl mercury can cause autoimmune effects.

Mercury and most of its compounds are extremely toxic. The most toxic forms are its organic compounds; e.g. dimethyl mercury and methyl mercury. Methyl mercury comprises a dangerous family of compounds.[4] Mercury can cause chronic and acute poisoning and there is no safe level of mercury intake. Methyl mercury is a bio-accumulative environmental toxicant. While almost everyone has trace amounts of methyl mercury in their bodies, related to its pervasive presence in the environment, people are potentially exposed to multiple contamination events; for example, by eating contaminated fish and from dental amalgam fillings.

Mercury can be emitted from power plants and be deposited on land, in water or seawater. This establishes the potential for bio-accumulation in fish, wildlife, and human food crops and animals.

The sources of mercury / methyl mercury affecting the human population are multitudinous and the human body also bio-accumulates mercury. Sources include, for example, Thiomersal (Thimerosal) - a preservative in vaccines (now used to a lesser degree). Thiomersal is metabolised to ethyl mercury. Mercury compounds are constituents in some over-the-counter drugs; e.g. a mercury compound (Mercurochrome) as a topical antiseptic. Mercury also features in stimulant laxatives, nappy rash ointments, eye drops and nasal sprays. The US Food and Drug Administration (FDA) has admitted to having inadequate data to establish general recognition of the safety and adverse reactions of the mercury ingredients in these products.[5]

Of particular concern is the mercury in dental amalgams which commonly consist of mercury (50%), silver (~22-32% ), tin (~14%), copper (~8%), and other trace metals. New Zealand’s large ‘baby boomer’ demographic has one of the highest rates internationally of mercury amalgam fillings and research points to mercury amalgam dental fillings as the main source of mercury exposure in those affected by chronic mercury toxicity, up to 17ug/day vs. 2.6ug/day from all other combined sources.[6]

The public health risk from amalgam fillings has been acknowledged in public policy by Norway and Sweden, which countries have banned mercury amalgam use. The FDA has acknowledged the neuro-toxicity of mercury amalgams.

Amalgam dental fillings discharge a significant amount of mercury into the body. Brain mercury levels are directly proportional to the number of fillings. Why continue this use when there are safe, durable and cost effective alternatives to amalgam fillings.

It is an indication of the lack of an effective, independent toxicological regulatory framework in New Zealand, that the Health Department pays for mercury amalgam fillings to be placed in children’s teeth, while similar amounts of the same material from old fillings and the crumbs of new fillings are categorised as toxic waste. Dentists are required to prevent its spillage into municipal sewers by environmental health authorities.

Another lack of regulatory protection is the practice of looking for expert opinion on the safety of mercury amalgam dental fillings within the dental profession. In common with many other sector groups, be it doctors, architects or engineers, for example, members have a practical working knowledge of the toxic substances they work with, but no training in metal toxicology. To base public health on sector opinion is flawed governance. It denies the New Zealand public, including those sector groups who control toxic substances, the information and regulatory support they need to protect human and environmental health from environmental toxins.

The primary pathway through which toxic heavy metals such as mercury produce disease is excessive oxidation creating inflammation. It is recognised that many diseases are caused by inflammation, most especially the so-named ‘degenerative diseases’. Inflammation-related diseases include asthma, arthritis, autoimmune disorders, cancer, cataracts, cardiovascular disease, cerebrovascular disease, dementia, dermatitis, diabetes, gastro-oesophageal reflux, inflammatory and irritable bowel disease and macular degeneration.

Without a radical new approach to health, even the impact of one chronic mercury toxicity related disease, Alzheimer’s-senile-dementia, is projected to make the health budget fiscally unsustainable.[7]

We are not available to speak to the committee in support of this submission.

As we have shown, the sources of mercury are multiple and in view of Dr Wojcik’s research a serious health risk for New Zealanders. As a means of eliminating a major contributor, we ask the Committee to endorse the Minamata Treaty and include a direction to the Minister to have a complete ban placed on the use of mercury amalgam dental fillings in the ban on mercury.

The Trustees Physicians and Scientists for Global Responsibility New Zealand Charitable Trust

[1] Damian Wojcik, BSc, MBChB, Dip.Rel.Studies, Dip.Obst., DCH, FRNZCGP, FIBCMT (USA), FACNEM, Director and founder of the Northland Environmental Health Clinic, Whangarei, New Zealand.

[2] (Neuro-Endocrinology Letters 2006; 27(4): 415–423)

[3] Martin et al, 2012, Final data for 2010. National vital statistics reports; vol 61 no 1. Hyattsville, MD: National Centre for Health Statistics. Also Environmental Protection Agency. Office of Water. Trends in Blood Mercury Concentrations and Fish Consumption Among US Women of Childbearing Age NHANES, 1999-2010. Washington, DC. 2013. EPA-823-R-13-002. Centres for Disease Control and Prevention. National Centre for Health Statistics (NCHS). National Health and Nutrition Examination Survey Data. Hyattsville, MD: S. Department of Health and Human Services, Centres for Disease Control and Prevention, 2009-2010.

[4] National Research Council (US) Board on Environmental Studies and Toxicology (2000). Toxicological effects of methylmercury. National Academies Press. ISBN 978-0-309-07140-6.

[5]"Title 21—Food and Drugs Chapter I—Food and Drug Administration Department of Health and Human Services Subchapter D—Drugs for Human Use Code of federal regulations". US Food and Drug Administration.

[6] The WHO Environmental Health Perspectives 118, 1991).

[7] Godfrey et al J. Alzheimer’s Dis.2003

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