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March 11, 2016 (Revised March 18, 2016)


Washington State Office of the Insurance Commissioner

Attention: Michael Kreidler

PO Box 40255

Olympia, WA 98504-0255


Phone: 360-725-7080

Fax: 360586-2018


Dear Mr. Kreidler,


To make it easy for you to follow the links in this letter, I am posting it on my web site at the following location:




I am writing to you regarding Delta Dental, an insurance company which delivers little benefit to consumers in return for the premiums they pay and spends insurance premiums collected for purposes other than repairing teeth.


Delta Dental’s plans are not really insurance. Enhanced plan costs an individual $600 per year but will pay out an absolute maximum of $1,000 per year. This is poor coverage. See:


Instead of using consumer premiums to pay for dental services, Delta Dental squanders enormous sums building drinking water fluoridation facilities across the country and promoting drinking water fluoridation.


Delta Dental of Washington finances the Washington Dental Foundation, which is an advocate for fluoridation. The Washington Dental Foundation home page is on the Delta Dental web site. See:

Secure Arkansas considers Delta Dental to be part of a fluoridation racket. See:


It is difficult to convince a water district to begin fluoridation when the cost of modifying existing facilities and adding fluoridation equipment can cost millions of dollars. Well organized pro-fluoridation groups, financed by Delta Dental and the CDC, convince city councils and water commissioners to enact fluoridation. One technique is to channel donations to politicians through dental PACs. See:


Delta Dental in Arkansas and other states including Washington is waiting in the wings with its offer to pay for expensive new fluoridation equipment.


Port Angeles, Washington is a good example. Port Angeles voters had voted three times in referendums not to fluoridate their water, but the city council went against the voters wishes and in 2006 initiated fluoridation. Delta Dental made the transition easier by paying for the fluoridation facilities. Delta Dental’s contract with the city included a clause which required that if Port Angeles terminated fluoridation within ten years, the city would have to repay Delta Dental’s investment.


In 2016 the city of Port Angeles conducted a non-binding election to determine public opinion. The majority voted to terminate fluoridation. The Port Angeles City County again chose to ignore the will of the people and to continue fluoridation. It is not clear who will pay for needed improvements to water facilities now corroded by fluoridation. See:


Both Bellingham and Olympia fought expensive fluoridation initiatives in past two decades, and in both cases fluoridation efforts were turned back. In both cases Delta Dental was available to pay for new fluoridation equipment. The pressure in Spokane to fluoridate is relentless.

Delta Dental finances the new American Fluoridation Society, which pressures water districts either to start fluoridating or not to end fluoridation. See:

Delta Dental is doing this all across the country. An Arkansas group known as Secure Arkansas has documented the wrongdoings of Delta Dental and other pro-fluoridation groups. See:


If fluoridation were a magic remedy which eliminated tooth decay and caused no adverse reactions, this might make sense. However, it is clear that this is not so. There is overwhelming evidence in the documents cited in this letter that fluoridation is both ineffectual and harmful to health. I will make a few points here which provide clear proof of this. These points come not from me but from fluoridation supporters. The CDC web site itself makes the following admissions:


that fluoridation reduces caries only 18% to 25% (Other evidence says it does not reduce caries at all);

that 41% of adolescents suffer from some degree of dental fluorosis, with around 12% of adolescents suffering from mild, moderate, and severe fluorosis, which is noticeable, embarrassing, and ugly;

that “fluoride prevents dental caries predominately after eruption of the tooth into the mouth, and its actions primarily are topical for both adults and children”.

According to CDC’s own admission then, fluoridation would not seem to be a good bargain. 

Next, come the admissions made by the National Sanitation Foundation, NSF, the trade association authorized and financed by the EPA to approve and set safety standards for fluoridation materials. The NSF website admits that tanker loads of fluoridation materials can and do contain arsenic, lead, mercury, and cadmium. See:  

Add to this the studies which indicate that there are much more effective ways to reduce and even eliminate tooth decay than fluoridation. The fixation on fluoridation distracts the dental profession from teaching methods which really do reduce caries and do so without any harm.

The fixation of fluoridation as the solution to tooth decay distracts from the teaching of other dental care procedures which really would prevent tooth decay.


Add to this the fact that the fluoridation materials used in Washington do not meet the standards set forth in Washington law. RCW 246-290-220 says that fluoridation may be done in Washington only with fluoridation materials which “comply with” the National Sanitation Foundation NSF Rule 60 standard. NSF 60 requires that some 20 toxicological studies be done on drinking water additives and that a risk estimation test be done. The toxicological studies are not being done, and the fluoridation materials do not pass the risk estimation test.


I filed a petition with the Board of Health, showing that the fluoridation materials do not “comply with” NSF 60 and therefore do not “comply with” RCW 246-290-220. The Board of Health denied my petition without addressing all the issues I presented. I appealed the Board decision to Governor Inslee. He denied my appeal without addressing all the issues I presented. I made a motion for reconsideration, which was also denied without addressing the legal and scientific issues I raised. I sent Governor Inslee a final rebuke for his failure to enforce the law and failure to consider the overwhelming evidence that fluoridation is ineffectual and harmful to health. It appears to me that Governor Inslee is relying on pro-fluoridation * so-called experts to ghost write his response. See:

The consumption of around 2 milligrams of fluoride per day from conception until death does significant harm to health. Fluorosilicic acid leaches lead from plumbing. See:


Studies from Harvard and other sources show that fluoride reduces IQ. See:


Fluoride displaces iodine and reduces thyroid function. See:


Fluoridation causes or exacerbates ADHD. See:


Please see the following online documents for more about the health problems cause by fluoridation in the materials I am submitting:


Delta Dental and the Fluoride Exposure


Safewater Overview of Fluoridation


In conclusion, I urge you to investigate the misbehavior of Delta Dental and order Dental Delta to spend consumer premiums on direct dental care instead of financing fluoridation facilities which do little or nothing to prevent tooth decay and which harm health and on the financing of false fluoridation propaganda. I also urge you to require Delta Dental to repay to consumers the premiums they paid but which were misused on fluoridation equipment and false propaganda.



James Robert Deal, Attorney

WSBA Number 8103


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