Fra: Poul Mřller <poulmoeller@mail1.stofanet.dk>
Dato: lřr 31 maj 2003 23:07:28 Europe/Copenhagen
Til: fdadockets@oc.fda.gov
Emne: Paper to FDA on amalgam, (sent in RTF-format to save the bold letters)

Dockets Management Branch (HFA-305), May 31, 2003.
Food and Drug Administration,
5630 Fishers Lane, rm. 1061,
Rockville, MD 20852 by e-mail with copy to relevant persons.

Updated version of the peer-reviewed paper sent by post May 23rd, 2003:

Name of Author: Poul Mřller, independent retired Chemist, M.Sc
Title: Mercury in Amalgam: The cause of chronic Diseases, Mental
Retardation in the Next Generation and Accelerated Aging.
Journal: Clinical Practice of Alternative Medicine,
Year 2001,
Vol. 2, Number 3
Pages 181-187, 44 references.


THE REAL SCIENTIFIC TRUTH OF AMALGAM, THE BEHAVIOUR OF MERCURY IN THE BODY CAUSING CHRONIC DISEASES.

A. INTRODUCTION.
Amalgam is the largest non controlled experiment ever, completely out of step with medical standards. To observe what happens to a cohort of humans, now close to old age, forced to go through life with implants in their mouths leaking mercury, Hg, in intolerable amounts with open access to the brain. Their teeth contain up to 10 grams of Hg, while poisoning requires micrograms, only. Authorities do not worry about people getting sick, how to help them; some of their diseases are not even accepted. That experiment must be stopped and systematic restoration started.
While the results of fighting infectious diseases and of surgery are excellent, chronic diseases lag in spite of enormous efforts. They accelerate in both the old (1) and in the young generations, and innovative thinking is urgent. This paper deals with the problem of amalgam in the correct way, different to that of the Establishment: To study the impact of amalgams is to study Hg-chemistry. Logically it starts with the chemical and physical properties of Hg laid down by Nature, it uses Science of Nature and logical thinking to betray its attacks and its pathogenesis. It ends with methods of cure. This science is unchangeable, non disputable, its validity is similar to that of e.g. the law of gravity. Thus man-made clinical results are wrong, when diverging. It calls the attention to the fact, that some of the claims of mercury being safe are based on scientific blunders. Conclusion: The claims of ADA are wrong.
Most of the chemistry of mercury, Hg, has been documented 100 years ago and needs no further documentation. It includes:
1. Amalgam is claimed a stable alloy. No, it is highly unstable above the melting point of Hg, –39oC.

2. It is a liquid with a significant vapour pressure. Air saturated with Hg holds about 50.000 µg/m3 at 37oC, 2.000 - 5.000 times the limit for working areas. Although the vapour pressure of amalgam is lower and the inhaled air does not get saturated, vapours from fillings have a terrible impact on a person, not 5 x 8, but 7 x 24 hours a week, life long from the first filling until its removal. Hg-vapours in the mouth are easily measured and made visible.
3. All amalgam constituents corrode when more noble metals as gold, platinum or palladium are present in the same mouth. The electric element generated together with the saliva provides for that. The toxicity of more heavy metals is highly synergistic. Every pipe fitter knows not to mix different metals to avoid corrosion.
4. All transition metals, able to exist in more valencies, generate a large number of free radicals, including the most powerful ones, the hydroxyl radicals. So does Hg.
5. Hg shows an extreme affinity with sulphur containing compounds, most important are the amino acids cysteine and methionine placed in active centres of life important compounds and in proteins.
6: Bacteria of the streptococcus family in plaque, i.e. in direct contact with the fillings, too, and in the GI-tract transform Hg to fat soluble methyl-Hg, MeHg, considered 100 times more toxic than Hg itself. This process is common to Nature from algae upwards and the reason, why marine animals are always contaminated with MeHg, not with elementary Hg.

B. THE BEHAVIOUR OF MERCURY IN THE BODY.
1.
The release by vaporization and corrosion takes place from all visible and invisible surfaces, that are 3 - 5 times larger. There is sufficient room between the filling and the tooth to allow for the transport. It is increased by heat, acid liquids and the electric current generated by noble metals. Gold tendoubles the breakdown. Moreover wear adds heavily: Chewing, chewing gum, bruxism, tooth brushing, cleaning and polishing.
2. Most Hg is released through the larger invisible surfaces via the teeth and jawbone directly into the blood. 20% of the vapour is expired, the rest is swallowed as is the corroded Hg. Metallic Hg is short-lived. It is either oxidized to Hg++ in blood or changed into MeHg. A minor portion of Hg-salts remain in the intestines for excretion, the urine carries what has been able to pass the kidneys. Hg++ attacks in 2 ways:
a. Among the sources of free radicals, heavy metals are the only ones acting perpetually, and Hg from amalgam is by far the dominating source. It generates one radical/atom, often the most aggressive and most toxic hydroxyl type, which splits any substance hit. It recycles all the time: Hg++ --> Hg+ --> Hg++ a.s.o. The effect is increased multiple times and the person gets “oxidative stress”.
b. It is the metal fixing most avidly to sulphur in the SH-group of cysteine in DNA and other proteins; they may be deformed and lose their function. Also in enzymes, glutathione, one of our most potent antioxidants, in some hormones etc.
Tragedy No. 1: Cysteine is placed just in the active sites of enzymes etc. controlling our metabolism and all biological reactions in the body. Hg immobilizes them and their activity gets lost.

c. We have no protection against MeHg. It penetrates cell membranes and barriers blood/brain, blood/retina, in the placenta and the mammary glands. It shows many destructive properties, i.a. a strong affinity for brain tissue and its ability of cell killing should be emphasized.
Tragedy No. 2: The fetus/infant gets MeHg during the pregnancy and the nursing period and never more. It is the time of the formation of the brain and, if a girl, of her eggs. Just as bad: Hg in mothers´ blood concentrates in the umbilical cord and breast milk up to 8 times, as demonstrated by indisputable radioactive analyses.
The small being gets Hg in proportion to the amount of blood and milk, but the damage is per unit of brainweight, so development is extremely affected during the first months of the pregnancy. It is evident that Hg blocking active sites in the fast cytogenesis of the brain will change or stop the process: The brain will be more or less incomplete. Ethyl-Hg ex thimerosal in vaccines behaves likewise. Its relation to autism has been made probable. The reagent contains 50%Hg, the same as amalgam, .
d. The load on the population differs widely and two age groups are severely hit: The victims of the systematization in the 1930´es to 1960´es - now old age - got 12-14 fillings on average, in extreme cases 22 with up to 10 - 12 g Hg a few cm. below the brain with open access to it. Do dentists not learn anatomy? During the 1960´es protection against caries was successful. However, in the late 1970´es unstable high copper amalgam came into use, and the advantage of few fillings got lost. This type was preferred due to convenience and used in children, ”it kills bacteria better”. It was the most fatal and non controlled decision ever: The girls now transfer methyl-Hg to the brains of their children and the mental defects in the next generation and their escalation are explained.
Tragedy No. 3: All of it escalates contemporarily in both ends of the ages and the damage is going to remain during the new century if not counteracted now by rational means.
The final pollutants, Hg-cysteine and MeHg are extremely insoluble in our body liquids and our biological problem is that we have no means to get rid of them. The half times are very long, in the CNS > 25 years. Such a simple analysis as determining the rest of Hg in old fillings shows that half of Hg has disappeared in 10 -15 years, i.e. >1.000 µg/day. 3 grams are still in depots, i.e. > 100m. Hg-atoms in every single cell on average, mainly in the brain, the CNS, the pituitary, thyroid, other glands, kidneys, liver, lungs and heart. The immune system, sex cells, ovaries, testes and retina are also affected. Such a load suspending the actvity of vital substances controlling our health may interfere with all processes, and Hg ought to be hypothesis number one for any non explained disease.

C. WHY DO DENTISTS NOT LEARN THESE BASICS TO KNOW WHAT THEY HAVE TO DO WITH?
I.a. because the teachers at the Universities are dentists, chemistry is not in vogue or its impact is not understood. Why have they forgotten the way of scientific thinking learned at Grammar school and used in this paper? Why has dentistry not studied Hg-chemistry before 1000´s of tons were implanted two inches below the brain with open access through the olfactory bulb. Do dentists really trust that the mouth is the only spot, where Hg is safe, while it is supertoxic anywhere else. It speaks for itself.
Dentists are left in the lurch by this lack of education: While e.g. boring out old fillings, they inhale vapours and dust through the nose, that reach their brain as demonstrated by prof. Alfred Stock, Germany, in the 1930´es. Dentists show the highest rate of suicide in this country.
Often dentistry substantiates the safe claim on analyses of blood and urine, but these media are for transport, the pathogenic Hg has been fixed elsewhere. Claiming amalgam safe because “Hg-levels are below values causing diseases”, without considering the depots is a scientific blunder, and dental science based on it is open to criticism or useless. Analyses of depots, e.g. part of the brain will not be available until post-mortem, unless biopsies are possible. Causal clinical trials are limited to the hypotheses
looked for. Is Hg not included, the relationship will never be found. It may be due to professional policy, ignorance or no research money to this controversial topic. Such "science" has no sense.
Absence of proof is no proof of absence!

D. GENERATED SYMPTOMS AND DISEASES.
Hg accumulates from the first filling and nervous tissue is the main target. When hurt some get ill insidiously, some at once. Some mental symptoms of this origin are well-known to poisoned patients and after replacement they disappear over the years. An incomplete list is:
Depression anxiety shyness suicidal thoughts headache fatigue
tremor muscle and joint pain nervousness vertigo numbness
tingling of lips and fingers irritability visual disorders lack of concentration
loss of memory cold extremities. frequent colds -> sinusitis insomnia
loss of appetite -> loss of weight increased blood pressure and cholesterol
heavy menstrual pains
This relationship appears to be unknown. The patients having these chronic disorders are not hypochondriacs, they are Hg-poisoned. Very often our papers are dealing with one or the other of these problems and the experts interviewed have no explanation.
It is remarkable that highly qualified biochemical science has documented antioxidants to help chronically ill in general. The connection was confirmed in two JAMA-reviews (2)-(3) and (4). Thus the following diseases are mostly a consequence of “oxidative stress”:.
senile dementia Parkinson´s and Alzheimer´s dz. MS and ALS,
schizophrenia fibromyalgia epilepsy migraine
tinnitus chronic fatigue atherosclerosis cancer
osteoporosis some rheumatic dz some allergies: asthma and psoriasis
cataract, AMD other age-related eye diseases reduced quality of sperm.
Bacterial resistance to antibiotics due to Hg has been found. Several excellent investigations indicate a strong relation to Alzheimer´s disease. An aorta from a by-pass operation had > 3.000 times, and a biopsy of a patient with idiopatic dilated cardiomyopathy showed 20.000 times the normal Hg-figure (5). How much is needed for a proof or a simple suspicion?
The mental retardation
of many children, reduced IQ, demand for social assistance and special education, DAMP-children, autism, diabetes-2 at school age, hyperactivity, violence and criminality.
Dr. Hal Huggins, the US-dentist most experienced in correct amalgam replacement, reports to have cured i.a. leukemia, epilepsy, fibromyalgia, hypertension and hypercholesterolemia. Hypertension may appear as a result of Hg blocking some of the oxygen transport. The body creates more red blood cells to replace the capacity lost, viscosity increases and so does the pressure necessary for the circulation;
Summing up the numbers of patients suffering from the diseases above will show some 20% of the population. 80% seem genetically resistant, i.e. they do not feel worse, than they think it belongs to life. It is very urgent to find out why, because the tremendous number of people to be restored requires priorities. Some ideas of the genetic difference are at hand.
Hg is not claimed the only cause of chronic illness, but the major contributor. Thus many of these sufferings are man-made and per se superfluous. Our health depends on the power of attack and defence, and a disease develops depending just upon which part of the individual defence, that has been overrun.
More than half of the brain weight consists of lipids, many of which highly unsaturated and therefore specially susceptible to attack by free radicals. This is in line with the response of neurologic diseases to antioxidants. Add to this cysteine-destruction, cell killing MeHg. Damage of DNA by free-radical-splitting and Hg blocking its cysteine may lead to mutations, the first step on the way to cancer. A review on wildlife also tells of humans: Cromosome breakage, demyelination, dosedependent reductions in T-cell proliferation and constriction of the visual field. In mammals it concentrates selectively in the fetal brain, causes mental defects reduced fertility, fetal malformation and death (6). Is human Hg-chemistry different? Hardly.
The other amalgam metals, silver, copper and tin, are released due to corrosion and their chemistry and impact are similar, but less considered. They show strong synergy. Methyltin comes into existence similarly to MeHg. It is related to killing agents as TBT in boat paintings and is much more toxic.
Dentistry says: “During 150 years no diseases have been scientifically documented due to amalgam”. This reasoning is baseless. A mistake is a mistake irrespective of age. It is correct to say: “For 150 years we have not understood the problem, but have unintentionally poisoned our patients incl. children having got Hg from their mothers”. Universities are to blame. It has lead to an enormous waste of ressources: Wrong treatment and medication, hospitalization and operations, absence from work, too early ageing and retirement, misdirected medical research, neglected biochemical science a.s.o. The study reveals a majority of our most serious and costly health problems: Escalating amalgam toxicity occupies about half the expenditure of the health and care sectors. The Laws of Nature cover the whole area. Diseases of chemical origin are to be cured by removing the source and administering drop of chelating substances for the Hg++-compounds to be removed from depots, unfortunately only partly, and suitable sulphur and selenium containing supplements. So simple and yet a revolution.
About 1960 chemistry showed its relentless power, as thalidomide caused birth of 10.000 malformed children. The eternal and ubiquitous Laws of Physics and Chemistry controlling health, now show up again. The target is keeping people mentally alert and healthy until the end. The biochemists consider this a short time goal, see fig. Correct, provided the problem of Hg is tackled in the right way.

The off-hand change to the unstable type was a turning point. Now the young generation and their children are hit, so the problem will stay during the whole new century. It is the last minute to turn around, ban the poison and start the tremendous clean-up. The correct procedure must be used and learned. Some know how to do.
It will be an unpleasant decision, but the horror of to-day is self-inflicted.

E. THE OFFICIAL DEFENCE FOR AMALGAM IS UNDER PRESSURE.
In response to my questions to the Danish government it admits: “Inorganic Hg is neurotoxic, organic Hg strongly neurotoxic causing extensive damages to the CNS and peripheral nerves. But these severe chronic toxicities cannot be compared to the minimal amounts released from fillings and stored in the organism”.This reservation is not correct. In 1981 the controlling authority NIOM, Oslo, Norway, found the new
high copper type to break down 50 times faster, releasing cadmium, too. The stability of amalgam became a disclosed lie. Since the late 70´s it has been popular due to convenience. New guidelines in Norway advise against amalgam, because Hg was found in unwanted places: In the brains of dead people, in the fetus and in breast milk it correlates with the number of fillings of the mother. Acceptable composites exist for all teeth and purposes. The Danes say: There is a demonstrable relation between Hg in the fetus and infant and the number of fillings of the mother. Prof. Maths Berlin described his conclusions at the Congressional Hearings on May 8. Recently UNEP expressed very serious concerns on all uses of Hg including amalgam. In a short time the defence of amalgam is going to vanish and the authorities border on criminality when not stopping its use now.



Ref.
(1) Editorials. The global response to mental illness, BMJ, 2002; 325: 608-609.
(2) Fairfield KM, Fletcher RH, Harvard, Vitamins for Chronic Disease Prevention in Adults, Scientific Review, JAMA, 2002; 287: 3116-26. Covering 1966-Jan 11,2002, 152 ref.
(3) Fletcher RH, Fairfield KM, Ditto, Clinical Applications, ibid. 3127-29.
33 ref.
(4) Ames BN et al. High-dose vitamin therapy stimulates variant enzymes with .... relevance to genetic disease and polymorphisms. Am J Clin Nutr, 2002; 75: 616-58. 377 ref.
(5) Frustaci A et al. Marked Elevation of Myocardial Trace Elements in Idiopathic Dilated Cardiomyopathy Compared With Secondary Dysfunction. J Am Coll Cardiol. 1999; 33: 1578-1583.
(6) Wolfe MR et al. Effects of mercury on wildlife, a comprehensive review. Environ Toxic Chem 1998; 17: 146-60.
(7) Mřller P. Mercury Amalgam: The Cause of Chronic Diseases, Mental Retardation in the Next Generation and Accelerated Aging. Clin Pract Altern Med, 2001; 2: 181-187. 44 ref.

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