This letter is to the White House Council of Environmental Quality asking them to assure that government agencies (Indian Health Services, Department of Defense, Bureau of Prisons, and the VA as well as Medicare and Medicaid programs) implement the new FDA recommendations on amalgam. We want the CEQ to tell federal agencies to immediately cease placing amalgam in high-risk populations, as identified by the FDA, i.e. (1) children (2) women who are pregnant, breastfeeding, or planning pregnancy; (3) patients with kidney disease; and (4) patients with a neurological disease.

To sign-on to this letter as a health or science professional, please fill out the form below. If you have any questions, you can email Sylvia Dove at sdove001@gmail.com, Charles Brown charlie@mercury-free.org or Mark Mitchell, MD at mmitch3@gmu.edu.

Please note, if you are an organization signing on, please use this form instead: https://docs.google.com/forms/d/e/1FAIpQLSeBYEDM_M87SznVylSdbbg_7iYpf9Ex8z8I4W0Wyha00e6E4A/viewform

Deadline September 17th to sign-on.

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Brenda Mallory, Chair, White House Council on Environmental Quality
Cecilia Martinez, Senior Director for Environmental Justice, The White House  
   
September 2021

Dear Chair Mallory and Dr. Martinez:

Ten months ago, the Food and Drug Administration’s safety communication called for dentists to cease use of dental amalgam in children, most women of childbearing age, and people with either kidney impairments or neurological disorders – deeming each to be “high-risk populations” for mercury toxicity from amalgam exposure.  Federal agencies which provide dental care of millions of Americans have not yet implemented the FDA recommendations – even continuing amalgam to children.
 
In light of the health and equity concerns posed by amalgam, we the undersigned (insert #) health and science professionals urge the White House Council on Environmental Quality to insist on full compliance with the FDA recommendations by the Indian Health Service, the Department of Defense, the Bureau of Prisons, the Veterans Administration, and the Center for Medicare and Medicaid Services.  

Composed of 50% mercury, a well-known neurotoxicant, dental amalgam is a potential health risk for children and other vulnerable populations, and results in a significant release of mercury pollution.  Once dominant in dentistry, amalgam has been surpassed in technology by non-bioaccumulative, non-polluting, tooth-friendly, and comparably-priced alternatives.

As noted in the Journal of the National Medical Association commentary “Is Amalgam Toxic to Children of Color?” the risks of mercury exposure falls most heavily on children of color.  Amalgam’s mercury disproportionately pollutes the lower-income and Black and Brown neighborhoods often located near remaining sources of mercury, including waste incinerators, coal-fired power plants and crematoria.  The 2016 National Congress of American Indians resolution calling for the cessation of amalgam use on tribal lands, is being ignored by Indian Health Services.  

One would hope that the government agencies providing dental care would be first in line to comply with FDA’s recommendations – instead of the contrary.  Thus “high-risk” consumers – including pregnant and breastfeeding women and children; soldiers, sailors, airmen and Marines and their families; Native American and Indigenous peoples; veterans; incarcerated persons; people with neurological or kidney disease; and families receiving dental care via Medicaid – continue to receive mercury-laden dental fillings in contradiction to FDA’s recommendations.

It is not just exposure to mercury in the amalgam itself, but also the life cycle of amalgam that adds to cumulative and disproportionate impacts on communities of color.  These communities already face higher exposure to mercury and other harmful chemicals where they live, learn, and work – such as dietary mercury from fish, crematoria, and toxic waste facilities.  

Recognizing the paramount role of CEQ to correct environmental injustices heretofore ignored, we ask you to insist that the Indian Health Services, Department of Defense, Bureau of Prisons, and the VA immediately cease placing amalgam in (1) children; (2) women who are pregnant, breastfeeding, or planning pregnancy; (3) patients with kidney disease; and (4) patients with a neurological disease – and that the Center for Medicare and Medicaid Services change its financing system accordingly.  

Sincerely,

(Note: Still collecting names and will update sign-ons here weekly)

Mark A. Mitchell, MD, MPH; Co-Chair Commission on Environmental Health, National Medical Association*
Linda S. Birnbaum, PhD, DABT, ATS; Scientist Emeritus and Former Director, National Institute of Environmental Health Sciences and National Toxicology Program*
David C. Bellinger, PhD. MSc, Professor of Neurology, Harvard Medical School*
Jerome A. Paulson, MD, FAAP; Professor Emeritus of Pediatrics and Environmental & Occupational Health George Washington University School of Medicine and Health Sciences and George Washington University Milken Institute School of Public Health*
Irva Hertz-Picciotto, M.P.H., Ph.D.; Professor, Department of Public Health Sciences University of California, Davis, School of Medicine*
Aimin Chen, MD, PhD; Professor University of Pennsylvania*
Veena Singla, PhD; Senior Scientist Natural Resources Defense Council*
Arthur Lavin, MD, Associate Clinical Professor of Pediatrics, Case Western Reserve University School of Medicine*
Susan Schantz, PhD, Professor Emerita, University of Illinois at Urbana-Champaign*
Margaret R. Karagas, MS, PhD; Professor and Chair of Epidemiology, Dartmouth College*
Beate Ritz, MD, PHD; Professor of Epidemiology, Environmental Health,and Neurology, FSPH, SOM, UCLA*
John R. Balmes, MD; Professor Emeritus, University of California, San Francisco and Berkeley*
Tanya Khemet Taiwo, MPH PhD; Co-Director Community Engagement Core, UC Davis Environmental Health Science Center*
Shanda Demorest, DNP, RN, PHN; Strategic Sustainability Manager, Practice Greenhealth*
Dr. Anne Ness, DNP, MAHS, RN, PHN; Director of Nursing, Alliance of Nurses for a Healthy Environment*
Olga Naidenko, PhD; Vice President, Science Investigations, Environmental Working Group*

* organization/university for identification purposes only
Claude J. Tellis, MD
Carla Campbell, MD, MS; Retired Pediatrician
Lindsay Burner, DNP, FNP-C, RN
Nicole Rendall, BSN, RN, CWOCN
Alexa Fay, BSN, RN
Linda Nelson, DNP, MPH, APRN
Lori Wilson-Hopkins, RN, MSN
Emily Little, RN
Deborah Moscufo-Barner, RN,MSN Ed, CDP
Kenra Brewer, BSN, RN-BC

Also represent affiliations listed:
Ted Schettler, MD, MPH, Science Director, Science and Environmental Health Network
Rueben C. Warren, D.D.S., M.P.H., Dr. P.H., M.Div., Professor and Director, National Center For Bioethics In Research And Health Care at Tuskegee University
Robert M. Gould, MD; Director, San Francisco Bay Physicians for Social Responsibility