Dental amalgam, misleadingly marketed as "silver fillings," is a risky filling material containing 50% mercury — a neurotoxin. Consumers for Dental Choice, led by executive director Charlie Brown, has a track record of success in fighting these mercury fillings, succeeding in:
- Abolishing the gag rule that prohibited dentists from discussing amalgam's mercury with their patients
- Winning back the dental licenses of persecuted mercury-free dentists
- Convincing the U.S. Environmental Protection Agency to mandate amalgam waste control measures
- Getting an amalgam reduction requirement into an international treaty, the Minamata Convention on Mercury
But there was always one major barrier to mercury-free dentistry in the U.S.: the U.S. Food and Drug Administration. For three decades, the FDA had been dodging its duty to classify — that is, issue a rule for — amalgam. Then Consumers for Dental Choice took action.
After assembling plaintiffs, Consumers for Dental Choice sued the FDA to classify amalgam in 2008. The judge agreed and told the FDA to sit down with Consumers for Dental Choice to determine a deadline. After the FDA committed to classifying amalgam by July 2009, the case was settled.
When July 2009 came around, however, it was clear the FDA had not considered the science in its abysmal amalgam rule. FDA's dental amalgam rule did acknowledge some of the risks: "The developing neurological systems in fetuses and young children may be more sensitive to the neurotoxic effects of mercury vapor."
And it did admit that there is no proof of amalgam's safety for these populations: "Very limited to no clinical information is available regarding long-term health outcomes in pregnant women and their developing fetuses, and children under the age of six, including infants who are breastfed." But FDA did not do anything about it.
Challenging FDA's Amalgam Policy
Consumers for Dental Choice knew it would take a lot to turn around the FDA's entrenched amalgam policy. So, they took a five-pronged approach: building a formidable lineup of support from organizations, demonstrating that the emerging science is now against amalgam, mobilizing the grassroots, bringing the international successes home and linking the experts to FDA advisers and staff.
1. Gain Organizational Support — Consumers for Dental Choice unveiled the Chicago Declaration to End Mercury Use in the Dental Industry at the University of Illinois School of Public Health in 2018.
This declaration, signed by more than 50 heavy-hitter environmental groups, called on the FDA "to bring its policies in line with the Federal Government as a whole and with its responsibilities under the Minamata Convention and to publicly advise a phase down of the use of mercury amalgams with the goal of phasing out entirely."
Furthermore, it recommended immediately ceasing amalgam use in children, pregnant women and breastfeeding mothers. Working with some key signatories to the Chicago Declaration, Consumers for Dental Choice sent the declaration to FDA — and their team got meetings with the top of the agency.
2. Show the Science — Consumers for Dental Choice presented the FDA with new science showing amalgam's harmful effects. Having reached the top of the agency, Consumers for Dental Choice could submit scientific studies that someone at the FDA would read. As a result, FDA's most recent scientific review of amalgam (2019) flips the FDA's position on a major issue.
FDA now recognizes evidence that shows once dental amalgam is implanted in the human body, its elemental mercury can convert to toxic methylmercury — the same type of mercury that the FDA warns about in fish. Of course, this mercury contributes to total mercury body burden in humans and, even at low levels of exposure, amalgam's mercury can cross the blood-brain barrier and raise concerns about toxic effects on the neurological system.
3. Mobilize the Grassroots — Consumers for Dental Choice organized a strong showing of public support from you. Do you remember its online petition that more than 80,000 of you signed? Consumers for Dental Choice presented it to the FDA in person (prepandemic) at its first meeting with the agency and has continued to make sure your voice is heard via such means as the public comments it asked you to submit to the FDA.
As one article described the result, "FDA gets mouthful on mercury dental fillings after requesting public comment on device regulation."
4. Demonstrate International Momentum — Consumers for Dental Choice knows that real world examples of successful amalgam bans can go a long way in helping policymakers envision a future of mercury-free dentistry.
With executive director Charlie Brown also serving as president of the World Alliance for Mercury-Free Dentistry, a coalition with projects working to stop amalgam use in more than 50 countries, there was no shortage of success stories to share with the FDA.
For example, Czech Republic, Denmark, Finland, Ireland, Italy, Japan, Moldova, Nepal, Netherlands, New Caledonia (in France), Norway, Philippines, Slovakia, Sweden and Suriname have already phased out amalgam use, and announced plans for phasing out amalgam use or use de minimis amounts of amalgam.
Additionally, the entire European Union, Mauritius, Tanzania and Vietnam have ended or are ending amalgam use in children and other vulnerable populations.
5. Bring in the Experts — Consumers for Dental Choice was ready when the FDA made its next move: On November 13 to 14, 2019, an FDA scientific advisory committee met to discuss metal implants and specifically dental amalgam. First, the committee heard from the public, primarily the experts assembled by Consumers for Dental Choice.
Executive director Charlie Brown was honored to testify alongside heavy hitters with expertise in dentistry, medicine, ethics and environmental justice. Then the FDA advisory committee members discussed amalgam among themselves — and recommended that the agency provide information to patients about the risks of dental amalgam, especially for vulnerable populations.
Now the question was: Would FDA listen to Consumers for Dental Choice, the Chicago Declaration signatories, the science, the grassroots, other countries, the experts and its own advisory committee?
FDA's New Amalgam Policy
When the history of the campaign to defeat amalgam is written, the date of September 24, 2020, will mark its watershed event. On that day, the FDA issued its groundbreaking safety communication, recommending against amalgam use in:
Pregnant women and their developing babies |
Women who are planning to become pregnant |
Nursing women and their newborns and infants |
Children, especially those younger than 6 years of age |
People with preexisting neurological disease |
People with impaired kidney function |
People with known heightened sensitivity (allergy) to mercury or other components of dental amalgam |
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This list, of course, encompasses a significant part of the American population. As such, the FDA's action has the potential to protect well over 100 million Americans (at least) from mercury in their mouths.
Instead of amalgam, the FDA now "recommends that non-mercury restorations (fillings) such as composite resins and glass ionomer cements be used, when possible and appropriate, in people who may be at higher risk for adverse health effects from mercury exposure."
Of course, it is always possible to use mercury-free fillings — and mercury-free dental fillings offer many advantages because in addition to not containing mercury, they are:
- Environment-friendly — Composites and glass ionomers are mercury-free, and there is no evidence of environmental toxicity.
- Helpful for preserving teeth — The placement of mercury-free fillings allows for less tooth destruction, which preserves more natural tooth structure. Composites fillings can also strengthen and enhance biomechanical properties of the restored tooth. As a result, the tooth itself can survive longer.
- Easier to repair — Composite fillings are easier to repair than composites — which can save you both tooth structure and money.
- Durable — Recent studies show that properly placed composite fillings can last just as long as — or even longer than — amalgam fillings.
- User-friendly — All properly trained dentists can place mercury-free fillings in any tooth requiring a filling. If a dentist tells you he or she has to use amalgam because it is too hard to use a mercury-free filling in your tooth, find a more competent dentist.
Is Mercury Still Used in Dentistry?
With all this success, Charlie is frequently asked, "Is mercury still used in dentistry?" Unfortunately, the answer is yes.
While many middle-income people can now get mercury-free fillings, many lower-income families, people in developing nations, military personnel, prisoners and people with disabilities are still subjected to amalgam. In his testimony before Congress, a former Virginia state NAACP president described this injustice as "choice for the rich, mercury for the poor."
Even if you do not get amalgam fillings yourself, you might still be at risk from amalgam's mercury. Amalgam pollutes:
- Water via dental clinic releases and human waste
- Air via cremation, dental clinic emissions, sludge incineration and respiration
- Land via landfills, burials and fertilizer
Once in the environment, dental mercury converts to its even more toxic form, methylmercury, and becomes a major source of mercury in the fish people eat. Consuming this mercury can cause brain damage and neurological problems, especially for children and unborn babies.
Building on FDA's New Amalgam Policy Worldwide
While we've made substantial progress in moving the FDA's policy away from amalgam, we absolutely must not rest now. After all, no government initiative is self-enforcing; it requires an engaged and outspoken citizenry. Consumers for Dental Choice is continuing to engage the FDA.
Showing its interest in the public learning about its recommendation against amalgam use in children, young women and people with kidney and neurological disease (plus others), the FDA has released two infographics to reinforce its point.1
They're now part of Consumers for Dental Choice's full-court press to create both awareness of the FDA recommendation and momentum to see it implemented, which has included reaching out to patient groups, health professionals and dental schools.
Now Consumers for Dental Choice has a new opportunity to fight amalgam use and perhaps end it once and for all. The Minamata Convention on Mercury already requires parties — including the U.S. — to reduce their amalgam use. But now several countries have proposed two amendments that would go much further:
- The Africa Region proposes the treaty be amended to phase out all amalgam
- The European Union proposes the treaty be amended to end amalgam for children, pregnant women and breastfeeding women
Consumers for Dental Choice and their international allies will be there to urge the parties to adopt an amendment ending amalgam use.
You Can Make a Difference
With FDA's new recommendations against amalgam use, Consumers for Dental Choice has achieved a great milestone in the fight for mercury-free dentistry, and you can help this effective advocacy organization build on this victory to win mercury-free dentistry for all worldwide.
Will you consider a donation to this 501(c)(3) nonprofit organization dedicated to advocating mercury-free dentistry? I will match all donations during Mercury Awareness Week (September 5 to 11, 2021) up to $150,000.
Donations are tax-deductible and can be made online at Consumers for Dental Choice. Checks can be mailed to:
Consumers for Dental Choice
316 F St., N.E., Suite 210
Washington DC 20002
Thank you for helping us build on the FDA success to make mercury-free dentistry a reality for everyone!
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And remember, you don't need to wait to make mercury-free dentistry a reality for you and your children — you can choose a mercury-free dentist right now. Check out Consumers for Dental Choice's listing of mercury-free dentists.2