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Dr. Boyd E. Haley
Chair, Department of Chemistry
University of Kentucky
www.altcorp.com
3 January 2002
The following is my comments on the content and specific statements made in the
Sept. 29th Florida Dental Board where the FDA presented "Amalgam Related
Material" to support their proposed rule. Please feel free to share it with
whomever you wish and especially the Florida Dental Board (FDA). Sincerely,
Boyd Haley
With regards to statements made by Dr. Baratz. First, to be an esteemed
academic as claimed one should hold an academic position and publish articles
in refereed journals on his subject of expertise. I have been unable to find a
single research article on mercury or amalgams or about anything authored by
Dr. Baratz. I further could not find any source of academic appointments in
tenure leading positions. With my personal knowledge of numerous outstanding
and productive academic research scientists available to the FDA for
consultation I am somewhat perplexed that they would select someone with such
weak credentials---unless they were searching for someone who would adamantly
support their preconceived position of amalgams being totally safe. Dr. Baratz
is evidently well known for taking that position. Finally, statements made by
Dr. Baratz concerning amalgams and chemistry in general are so pathetic that
they almost defy sensible analysis. I WOULD CHALLENGE THE FDA TO TRY TO GET THE
DEPARTMENT CHAIRS OF CHEMISTY AT THE UNIVERSITY OF FLORIDA AND FLORIDA STATE
UNIVERSITY TO AGREE WITH DR. BARATZ'S COMMENTS REGARDING THE CHEMISTRY OF
AMALGAMS AND MERCURY. However, knowing this is unlikely I will deal as best I
can with Dr. Baratz's statements one at a time in order of presentation.
Page 6, line 27-28. Dr. Baratz has no published basis for making this
statement. Absence of proof is not proof of absence. How can Dr. Baratz say
that a patient on a kidney dialysis program is not further injured by
additional mercury (a potent kidney toxicant) exposure from their amalgams? I
don't think such a study has ever been undertaken. When exposing a person to
years of a chronic level of toxic mercury it is the responsibility of the
pro-amalgam group to prove it does no harm, not vice-versa. Can Dr. Baratz or
the FDA confirm that the 22,000-fold increased mercury levels in the hearts of
inter-city young men who die of Idiopathic Dialated Cardiomyopthy did not come
from dental amalgams? { Frustaci, A., Magnavita, N., Chimenti, C., Caldarulo,
M., Sabbioni, E., Pietra, R., Cellini. C., Possati, G. F. and Maseri, A. Marked
Elevation of Myocardial Trace Elements in Idiopathic Dilated Cardiomyopathy
Compared With Secondary Dysfunction. J. of the American College Cardiology
v33(6) 1578-1583, 1999,}
Page 6, lines 31-32. One grain of standard sucrose does not weigh near one
milligram. Therefore his visual aid is totally misleading and indicates that he
has not, or does not, remember experiments where weighing small amounts was
involved.
Page 6, lines 37-41. Sodium metal when added to water burns {*filter*}ly, but it
does not explode when added to a glass of water. I have done this as a
demonstration so I know the results first-hand. No one would be killed or even
injured unless they touched the burning metallic sodium. Yes, chlorine gas is
toxic and is a man-made material (as is metallic sodium) that does not exist
naturally. Dr. Baratz wants to claim that metallic sodium and chlorine gas are
toxic but become non-toxic on conversion to a compound, sodium chloride, and
therefore, mercury in an amalgam is not toxic because it is surrounded by other
(toxic) metals that he feels produces something that is not mercury. This is
banal.
Reactivity and biological compatibility is the essence of the amalgam issue.
Human {*filter*} contains about 140 millimolar chloride anion and 124 millimolar
sodium cation. This ions are not toxic because they are not very reactive with
biomolecules. These ions are used to perform many biological functions
necessary for life, including maintaining the ionic gradient and electrical
potential across cell membranes. However, mercury is not found to serve any
useful purpose in human tissues and is a well known inhibitor of many enzymes,
including the enzyme that transports sodium across cell membranes. In contrast
to sodium cation, mercury cation, produced from mercury vapor by a {*filter*}
enzyme, is very reactive and inhibits almost every biological pathway or enzyme
driven function in man. To compare amalgam material to sodium chloride in the
manner Dr. Baratz has chosen to reveals a total misunderstanding of chemistry
and biochemistry of heavy metal toxicity.
Page 6 line 42 to page 7 line 2. Since all of the metal components of amalgam
are basic metallic elements with no charge how can someone make the inept
statement that there is no mercury in amalgams. It is an "element" and the fact
that elements cannot be broken down or changed is a basic tenant of chemistry.
The metals in amalgams have no net charge and therefore form only metallic
bonds. Mercury is a liquid at room temperature and quite volatile because it
forms weak metallic bonds with itself. This makes mercury unlike all other
metals. The metallic bonds formed between mercury and other metals in amalgams
are stronger and a solid phase is produced---but the bonds between mercury and,
say silver, are weaker than silver-silver metal bonds and therefore break
easier releasing elemental mercury vapor at a regular rate. This is why you can
heat a gold ring covered with mercury and rapidly make it gold again and why
dimes made silvery with mercury soon resort to their old form. The bottom line
is that inclusion of mercury into an amalgam reduces its vapor pressure but it
does not reduce it to the point that mercury cannot be significantly emitted.
Dr. Baratz states that if you detect traces of mercury from amalgams it is
because that material has been decomposed by heat and friction. How does he
explain the observations of the release of 43.5 micrograms mercury per cm2
surface area per day for two years straight in a test tube without additional
heat and no friction? {Chew, C. L., Soh, G., Lee, A. S. and Yeoh, T. S.
Long-term Dissolution of Mercury from a Non-Mercury-Releasing Amalgam. Clinical
Preventive Dentistry 13(3): 5-7, May-June (1991).} Bottom line is that it is
quite easy to demonstrate mercury release from a dental amalgam. I suggest the
FDA not believe either Dr. Baratz or myself but instead make 20-30 amalgams and
send them to the state universities in Florida and have them determine how long
a single amalgam must be in a gallon of water before the water is considered
unsafe to drink by OSHA or EPA standards. Then the FDA can then make a decent
decision on the mercury release and toxicity of amalgams using data from an
unbiased source.
Page 7, lines 10-13. Sodium chloride intake is necessary for life. Mercury is
toxic to every type of cell. Dr. Baratz's comparison amalgams to sodium
chloride is ridiculous. Amino acids contain carbon, hydrogen and nitrogen and
so does cyanide but the difference is how these molecules react in the
body---one is a cooking.net">food and the other a lethal toxin. Amalgams release mercury and
other metal ions and solutions in which amalgams are soaked are cytotoxic! {
Wataha, J. C., Nakajima, H., Hanks, C. T., and Okabe, T. Correlation of
Cytotoxicity with Element Release from Mercury and Gallium-based Dental Alloys
in vitro. Dental Materials 10(5) 298-303, Sept. (1994)}
Page 7, lines 15-18. Yes, everything is toxic if an overdose is obtained---that
is common sense. However, mercury has no cooking.net">food or biological function and is
toxic at concentrations much lower than even most other toxicants. Low levels
of mercury have been shown to inhibit the same enzymes/proteins that are found
inhibited in Alzheimer's diseased brain. { Pendergrass, J.C. and Haley, B.E.
Mercury-EDTA Complex Specifically Blocks Brain -Tubulin-GTP Interactions:
Similarity to Observations in Alzheimer"s Disease. pp98-105 in Status Quo and
Perspective of Amalgam and Other Dental Materials (International Symposium
Proceedings ed. by L. T. Friberg and G. N. Schrauzer) Georg Thieme Verlag,
Stuttgart-New York (1995). Pendergrass, J. C., Haley, B.E., Vimy, M. J.,
Winfield, S.A. and Lorscheider, F.L. Mercury Vapor Inhalation Inhibits Binding
of GTP to Tubulin in Rat Brain: Similarity to a Molecular Lesion in Alzheimer's
Disease Brain. Neurotoxicology 18(2), 315-324 (1997). Pendergrass, J.C. and
Haley, B.E. Inhibition of Brain Tubulin-Guanosine 5'-Triphosphate Interactions
by Mercury: Similarity to Observations in Alzheimer's Diseased Brain. In Metal
Ions in Biological Systems V34, pp 461-478. Mercury and Its Effects on
Environment and Biology, Chapter 16. Edited by H. Sigel and A. Sigel. Marcel
Dekker, Inc. 270 Madison Ave., N.Y., N.Y. 10016 (1996)}
Later research with neurons in culture nanomolar (10-9M) levels of mercury
caused cell destruction and formation of three of the widely accepted
diagnostic hallmarks of Alzheimer's disease. { Olivieri, G., Brack, Ch.,
...
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Dr Baratz a part of the ILK Team (Quack Quack Quack)