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For twenty years, PSGR have occupied a unique space, focussing on the provision of scientific and medical information in often contested political environments, where commercial interests habitually shape, and often control the provision of science information into policy and regulatory environments.

In 2025-2026 we're focusing on cumulative carbohydrate burdens (which include ultraprocessed foods) as the key modifiable determinant that is driving New Zealand’s mental and metabolic illness tsunami.

In December 2025 lead researcher Jodie Bruning presented two papers at the Sociology Association of Aotearoa New Zealand (SAANZ) December 3-5, 2025 conference, Wellington, NZ. They are published on PSGRNZ's Substack (blog).

Session 2.4: Mental Health and Wellbeing. Exposing the treatment gap: When New Zealand’s long-term mental wellbeing strategy ignores the role of nutrition in protecting and sustaining mental health. (Transcript).
Session 8.5: Food and Health. Building in policy for ‘fantastically cheerful medicine’. (Transcript).

Read our review of these books on PSGRNZ.Substack.com

THE WORRYING GAP IN NEW ZEALAND'S HEALTH GOVERNANCE

Hundreds of epidemiological studies and meta-analyses have reported associations between ultra-processed food consumption and adverse health outcomes. The literature is increasing - the evidence - is pointing to the fact that poor diets with high levels of ultraprocessed foodstuffs, not only drive diabetes - but most illnesses that are common New Zealand. Ultraprocessed foods are low in bioavailable nutrients, frequently high in carbohydrates, and contain high levels of manmade chemicals and high levels of chemically refined (as opposed to naturally refined or cold pressed) vegetable oils. Synthetic chemicals and vegetable oils are recognised as drivers of inflammation, while refined carbohydrates (or starches) drive insulin resistance. Nutritionally bioavailable vitamins and minerals are critical to all body functions, often acting as important co-factors in critical biological processes, from growth, to sleep, to brain health (memory, cognition and resilience and positivity), to reproduction and energy. Low levels of vitamins and minerals, systemic inflammation and insulin resistance are commonly recognised drivers of chronic and communicable illnesses. When people are unwell with inflammation or an illness, they more rapidly vitamin and mineral levels.

PSGR have identified a worrying gap in New Zealand's health governance. The Public Health Agency was established in 2022 to guide health decision-making, including to advise the Director-General and the Minister of Health. As with all agencies operating under the Health Act 1956 (s3A), the PHA must work to improve, promote, and protect public health. The PHA are focussed on equity but are not focussed on dietary nutrition. There is information or advice that states that dietary nutrition is outside the scope of the PHA, however, dietary nutrition and diet and nutritional deficiency as a driver of chronic disease is not in the work programme of the PHA. This was further confirmed via four Official Information Act requests, made in December 2023, and answered in February 2024, to the key members of the Senior Leadership Team (at that time) that this work was not being undertaken:

An Expert Advisory Committee on Public Health (PHAC) was established (Pae Ora (Healthy Futures) Act 2022 [s93]). The terms of reference for this Advisory Committee does not include any requirement to review dietary guidelines or nutrition standards (including to assess the literature on optimum levels of vitamins and minerals) and the position statement on Māori Health does not refer to diet and nutrition. Poor diets and sub-optimum nutrition are recognised drivers of risk for an extraordinary range of chronic and communicable disease, and poor diets will be more commonly experienced by low-socioeconomic groups.

There appears to be no other agency tasked with this responsibility, inside the Ministry of Health. The PHA in the role of advising the Director-General and Minister, and updating guidelines and regulations, should be reviewing best practice nutrition to increase knowledge on poor diets and nutrition, and to ensure that our regulations and guidelines do not drive disease but that they improve, promote, and protect public health, due to the regulations and guidelines being outdated. But this work is not being undertaken.

Drawing attention to poor diets, and sub-optimum nutrition is a big focus for PSGR.

We're looking for scientists and doctors to interview to support massive efforts already underway across New Zealand, working to bring this environmentally-driven sickness epidemic into public view in New Zealand. PSGR recently published a Substack article reviewing three groundbreaking books on the evidence that poor diets not only drive mental illness, but that dietary and nutritional changes can exert profound improvements in mental health.

We recently interviewed Professor Julia Rucklidge on amazing outcomes for high dose nutrients for pregnant mothers taking higher dose multinutrient formulations, where the nutrient levels are higher than (what appear to be) out-dated guideline and regulatory levels. We’ve reviewed three game changing books on diet, nutrition and mental health on Substack, interviewed Professor Ashley Gearhardt on ultraprocessed foods meeting the benchmarks for an addictive substance, psychologist Dr Jen Unwin on recognising food addiction as a substance use disorder, Professor Grant Schofield on health reform, epidemiologist Dr Simon Thornley on locked in medical school paradigms and the starch problem, Dr Glen Davies on reversing diabetes, Professor Pablo Gregorini on the ethics of meat, Dr Emma Sandford on nutritional medicine and eye health, and how high carbohydrate diets are driving poor vision, and oncologist Dr Anna Goodwin on cancer and the role of diet and nutrition in not only supporting cancer recovery, but improving clinical treatment outcomes, which we published as a two-part series (Part 1 and Part 2). Interview list here.

Audios version available @PSGRNZ on Spotify/Apple/Substack, with interviews published on YouTube.

In early 2024 academics from Australia, the US and France reviewed the evidence for diseases associations and ultraprocessed food across 45 meta-analyses. These meta-analyses covered some 10 million participants. Melissa Lane and colleagues identified direct associations between exposure to ultra-processed foods and health conditions which included mortality, cancer, and mental, respiratory, cardiovascular, gastrointestinal, and metabolic ill health. As the paper stated:

Overall, direct associations were found between exposure to ultra-processed foods and 32 (71%) health parameters spanning mortality, cancer, and mental, respiratory, cardiovascular, gastrointestinal, and metabolic health outcomes. Based on the pre-specified evidence classification criteria, convincing evidence supported direct associations between greater ultra-processed food exposure and higher risks of incident cardiovascular disease related mortality and type 2 diabetes, as well as higher risks of prevalent anxiety outcomes and combined common mental disorder outcomes. Highly suggestive evidence indicated that greater exposure to ultra-processed foods was directly associated with higher risks of incident all cause mortality, heart disease related mortality, type 2 diabetes, and depressive outcomes, together with higher risks of prevalent adverse sleep related outcomes, wheezing, and obesity.

Lane M M, Gamage E, Du S, Ashtree D N, McGuinness A J, Gauci S et al. Ultra-processed food exposure and adverse health outcomes: umbrella review of epidemiological meta-analyses BMJ 2024; 384 :e077310 doi:10.1136/bmj-2023-077310

WHAT ARE ULTRA-PROCESSED FOODS?

What contributes to my chronic condition? There is compelling evidence that diet is the main driver of health status.[i][ii] [iii] The last 30 years of gene science has demonstrated that while individuals may be predisposed to a genetic condition, it is predominantly environmental drivers, or stressors, that tip people into health or disease.

Stressors can be acute or chronic. If people are (acutely) exposed to large amounts of poison, trauma, stress and pollution bodies can reasonably quickly tip into with a long-term illness or condition. However, if people are exposed long-term to food that wouldn't cause harm if we had a little bit every now and then. However, if we are chronically exposed to poor diets that promote inflammation, insulin resistance and poor nutrition - people can also tip into a long-term illness or condition. Frequently, chronic exposures promote multimorbidity. Chronic conditions can include a metabolic illness, such as pre-diabetes and Type 2 diabetes, heart disease, cancer, chronic pain. But also mental illness, included depression, anxiety and many other brain-related conditions, that might have previously been regarded as exclusively a neurotransmitter problem.

When infants, children and young people consume 40-60% of their diets as ultraprocessed foods, they may be expected to tip into a range of conditions, earlier than their ancestors.

By contrast - if food is nourishing and health promoting, bodies and minds[iv] [v] - are more resilient. Resilience means people recover better from the challenges, and insults of daily life. Even after trauma - we return to healthy sleeping patterns more quickly.

There is increasing evidence (as we discuss here) - that healthy diets can reverse many chronic mental health conditions.

Traditional (historic) diets depended on what food-types were seasonally available a person's region, and what skills human ancestors had to prepare and store food over colder months. Today people are generally sicker at an earlier age with long-term ‘chronic’ diseases and diagnoses. Studies of cellular biology, nutrition, case studies and large analyses demonstrably pattern the origin of these diseases, all too frequently, to poor diets.

These are generically referred to as ‘lifestyle diseases’, but the way people and families consider, cook and consume food is influenced by cultural, historic, social and economic factors which shape knowledge and capacity.[vi] [vii] [viii] [ix] Health is part of a big picture.

Human ancestors did not consume ultra-processed foods which promoted insulin resistance and inflammation.

Ultra-processed foods (UPFs) are industrial formulations of processed food substances (oils, fats, sugars, starch, and protein isolates) that contain little or no whole food.[x] UPFs typically include flavours, colourings, emulsifiers, as well as other cosmetic additives to make them taste better.[xi] UPFs contain many more industrial ingredients than traditional, lightly processed foods such as cheese; tinned fruit, beans, and vegetables.

Monteiro, C.A., Cannon, G., Lawrence, M., Costa Louzada, M.L. and Pereira Machado, P. 2019. Ultra-processed foods, diet quality, and health using the NOVA classification system. Rome, FAO.

UPFS: MIXTURES OF REFINED INDUSTRIAL INGREDIENTS

How are UPFs different? UPFs deprive your body of complex nutrient mixtures. Formulation ingredients can be derived from a remarkably small range of ingredients. Manufacturers do add nutrients – but these cannot reflect the complex nutrient and fibre bioavailability of, for example, a single vegetable. When you eat lots of these foods, you can end up eating a narrow range of ingredients all day, just in different formulations. So, you don’t get the nutrients which are required to keep you humming along.

UPFs increase exposures to complex synthetic chemical mixtures.

These industrial formulations include synthetic chemicals, as well as genetically modified and chemically refined cereals and oilseeds. These additives are less likely to nourish us, and at times may harm us, and drive disease. These chemical mixtures are not assessed for risk, and the science to consider how mixtures might drive inflammation and drive disease, for example, is poorly funded, in comparison to science to drive drug development for those same diseases.

UPFs deprive the microbiome of complex fibre mixtures.

UPFs are ‘smoother’ and less challenging to eat than foods with fibre. This is a problem, because without healthy fibre, people can’t sustain a healthy gut microbiome. The human gut microbiome is ground zero for human health. Health journeys are personal because of job type, exercise level, genes; nutritional intake, age; gut health, gender; financial status, address and parents’ history. While stress always was part of life, human ancestors were not exposed to the range of environmental pollutant emissions that appear to reduce our resilience to stress, at younger and younger ages.

Cumulative lifetime environmental exposures – and humans' biological responses make up what is termed the ‘exposome’.[xii] Governments do not prioritise the monitoring and risk assessment of toxic exposures to synthetic chemicals, drugs, genetically modified foods, heavy metals and radiation. This can be undertaken through biomarker monitoring and testing, for example, of hair and serum. Monitoring, risk assessment and regulation lags behind the release of technologies onto the market.[xiii]

ADDICTIVE PROPERTIES ARE FREQUENTLY 'BUILT-IN' TO UPFS

Change is especially difficult when industrial food scientists build temptation into the industrial formulations. Industrial food formulations are frequently designed to make the UPF really, really tasty – hyper-palatable. Yes. Some foods possess addictive properties.[xiv] [xv] Scientists have theorised that refined carbohydrates trigger the addiction responses in ultraprocessed foods. They’re the addiction agent.[xvi] As people have more of an addictive substance our dopamine receptors down-regulate. The body digests and absorbs refined carbohydrates rapidly. We do the same with potatoes, particularly if they are peeled.

Refined carbohydrates include sugar, white flour and white rice. These foods are metabolised similarly in the body. Refined carbohydrates together add up to a glycaemic load. They make blood glucose rise quickly. Sugar is the worst culprit. When sugar consumption exceeds our liver’s capacity to clear and metabolise sugar, sugar ends up in the brain, driving reward. [xvii]

Ingredients in UPFs are traditionally low-cost. UPFs are specially designed for travelling long distances. They have to store well. UPFs are generally low in fibre, because fibre as an ingredient in food starts to break down, or go ‘off’. The food substances are often obtained from a few big high-yield crops (corn, wheat, soya, cane or beet). UPFs contain chemically refined, vegetable oils (such as canola, corn and soybean) rather than olive oil or coconut oil or butter, which are not chemically refined.

Corn and wheat might be synthesised into many different ‘ingredients’ - but the body is only consuming two food types. It is difficult for people on a high-wheat, high UPF diet to remain healthy over time.

As UPF exposures increase, industrial chemical exposures increase, while nourishing bioavailable nutrition & fibre decrease.

Change is never convenient when a person can’t sleep, when a person is hurt, fatigued and suffering.

Understanding these factors, and particularly, how addictive properties are embedded into the products, can create challenges to change, but also can help individuals and families reconsider things. This includes stopping blaming yourself, or the household cook, and realising that addiction is a product property to drive re-purchase. Addictive properties are critical to marketing. When individuals and families recognise that industrial commercial foods are cunningly designed for repurchase, this can help in the shifting of gears away from addiction-driven habits.

Often, it can be surprising that shifting the body away from food with addictive properties, is like any magnet. The pull is stronger in the short term, while over the long term, skills and strategies can be implemented, and new, body-habits nourished, to reduce that magnetic 'pull'. Withdrawal feelings are normal, and regression is normal, as prompts and triggers are embedded in daily life, from advertising signs to shops, to digital media.

Recognising that 'this is business' can help shift dietary habits (loyalty to a product) and purchase-decisions support your body, particularly the brain, with the safe and nutritious food human bodies really need. Many people are on similar journeys, and people find that they are not alone.

When governments don’t fund independent science, in the knowledge gap, the public can be sceptical of the safety claims of large, private companies. They can be aware of the advertising dollar in mainstream media, and the lack of focus on the addictive properties of UPFs - from toast to noodles to commercial fast food.

Key to this long journey, is becoming determined to relearn the skills of our ancestors.

Healthy diets can be remarkably cheap and simple to prepare.
As skills develop, cooking becomes efficient, planned, but also creative.
When addictive impulses are removed, and insulin levels are healthy - money can be saved, and snacks reduced, as the body doesn't have to negotiate fatigue and sugar spikes.
But like recovering from alcohol addiction - recovery is often best in community and group environments, to promote learning but also to gain support to navigate the daily hurdles that can drive .

REFERENCES

[i] Lane M M, Gamage E, Du S, Ashtree D N, McGuinness A J, Gauci S et al. Ultra-processed food exposure and adverse health outcomes: umbrella review of epidemiological meta-analyses BMJ 2024; 384 :e077310 doi:10.1136/bmj-2023-077310

[ii][ii] Lane MM et al (2020) Ultra-processed food and chronic non-communicable diseases: A systematic review and meta-analysis of 43 observational studies. Obesity Reviews. 22(3):e13146. doi: 10.1111/obr.13146.

[iii] González Olmo GM et al 2021. Evolution of the Human Diet and Its Impact on Gut Microbiota, Immune Responses, and Brain Health Nutrients 2021, 13, 196. https://doi.org/10.3390/nu13010196

[iv] Rucklidge JJ et al (2021) Nutrition Provides the Essential Foundation for Optimizing Mental Health. 6:1, 131-154, DOI: 10.1080/23794925.2021.1875342

[v] Martínez EE et al (2020) Effect of ultra-processed diet on gut microbiota and thus its role in neurodegenerative diseases. Nutrition 71:110609 doi.org/10.1016/j.nut.2019.110609

[vi] Venn et al (2017) Social determinants of household food expenditure in Australia: the role of education, income, geography and time. Public Health Nutrition: 21(5), 902–911 doi:10.1017/S1368980017003342

[vii] Daniel C. (2016) Economic constraints on taste formation and the true cost of healthy eating. Social Science & Medicine 148:34-41. http://dx.doi.org/10.1016/j.socscimed.2015.11.025

[viii] Neuwelt-Kearns C. (2021) The realities and aspirations of people experiencing food insecurity in Tāmaki Makaurau. Kotuitui: New Zealand J Soc Sci Online. https://doi.org/10.1080/1177083X.2021.1951779

[ix] Vandevijvere S et al (2021) Food cost and adherence to guidelines for healthy diets: evidence from Belgium. Eur J Clin Nutrition (2021) 75:1142–1151

[x] Monteiro, C.A., Cannon, G., Lawrence, M., Costa Louzada, M.L. and Pereira Machado, P. 2019. Ultra-processed foods, diet quality, and health using the NOVA classification system. Rome, FAO.https://www.fao.org/3/ca5644en/ca5644en.pdf

[xi] Monteiro CA, Cannon G, Levy RB, Moubarac JC, Louzada MLC, Rauber F et al (2019) Ultra-processed foods: What they are and how to identify them. Public Health Nutr 22(5):936–941

[xii] Karlsson et al (2020). Opinion. The human exposome and health in the Anthropocene. International Journal of Epidemiology, 2020, 1–12 doi: 10.1093/ije/dyaa231

[xiii] Persson L et al. (2022) Outside the Safe Operating Space of the Planetary Boundary for Novel Entities. Environmental Science & Technology 56 (3), 1510-1521 DOI: 10.1021/acs.est.1c04158

[xiv] Praxedes DRS et al (2022). Prevalence of food addiction determined by the Yale Food Addiction Scale and associated factors: A systematic review with meta-analysis. European Eating Disorders Review, 30:2;85-95 https://doi.org/10.1002/erv.2878

[xv] Moss, M. (2021) Hooked. Random House.

[xvi] Gearhardt AN & Schulte EM (2021). Is Food Addictive? A Review of the Science. Annu. Rev. Nutr. 2021. 41:387–410. P.393

[xvii] R.H. Lustig. “Fructose: It’s Alcohol without the “Buzz”,” Adv. Nutr. 4 (2013): 226.

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The potential cognitive and IQ risk from exposure to fluoridated drinking water has not been sufficiently impartially assessed by New Zealand government agencies. What does this mean?

Fluoride is a hazardous substance. Good practice should require that the lowest level of safe exposure (the benchmark dose) is defined, and then a margin of error (uncertainty factor) must be built in to allow for biological difference. This has not happened for this hazardous substance.
The lowest safe exposure is based on total dietary exposures, per day. Toothpaste ingestion plus fluoridated water ingestion.
No risk assessment has occurred in New Zealand to assess the combined risk of daily exposures of fluoridated drinking water and fluoride in toothpaste for children under age 10.
Instead of risk assessment, politically timed 'proxy' position papers have been released. They do not conform to good regulatory science. These papers do not contain methodologies to show that the collection and evaluation of data has been impartially undertaken.
The NZ EPA have completely stepped away from risk assessment of human health or environmental risk. Remember - fluoridated drinking water is emitted in waste streams from local councils, wherever municipal water is fluoridated.
Ironically, NZ would by convention turn to US EPA decisions. Yet the US EPA were recently found to have failed to follow their own risk assessment guidelines, in a recent court case discussed below.
The Health Minister continues to say it's safe even though no risk assessment ever occurred.

Conclusion: New Zealand health and environmental agencies have (demonstrably) stepped away from their duties to protect the health of people and their environment.

New Zealand's Ministry of Health are just a court case away from being found out! The big question is, will the judges make an effort to recognise that good practice and regulatory convention have been set aside? Will the courts be able to take into account this deviation from good practice (i.e. ignoring risk assessment which can identify the lowest level of safe exposure of a hazardous substance) the current goings on are neither fair nor just?

PSGR, FluorideFree and many others have worked to highlight to scientists, doctors and the general public that there are too many ‘blind spots’ and that benefit (of a potential marginal alteration in caries outcome) may not outweigh risk (in early childhood, to cognition and IQ).

PSGRNZ's Fluoride Timeline (updated October 2024 ) helps concerned institutions and the public to understand how fluoride is regulated, and how the scientific evidence on the neurodevelopmental toxicity has been presented in New Zealand, and understood by other prominent institutions.

On September 24, 2024 U.S. Federal Judge Edward Chen ruled that the US EPA can no longer ignore the risk of fluoride to children's IQ, and that it must take regulatory action. In making his decision, the judge applied the standard risk assessment framework to fluoride. Judge Chen identified a preponderance of risk. Chen noted that studies which did not show risk do not negate the high proportion of studies which do show risk. Chen emphasised the risk from a total dose.

'Background exposure sources include ‘naturally occurring fluoride in food and beverage, fluoride in food and beverage made with fluoridated water, and other products, like toothpaste.’

Judge Chen determined that weight of the scientific evidence regarding fluoride’s association with reduced IQ was sufficient to proceed to the dose-response assessment, something which has not been undertaken in New Zealand. A benchmark dose was then identified.

Food & Water Watch, Inc., et al., (plaintiffs) v. United States Environmental Protection Agency, et al. (defendants). United States District Court. Northern District of California. Case 3:17-cv-02162-EMC. Judge Edward M. Chen.

Regulatory risk assessment requires that there is an appropriate margin between an exposure and when the risk becomes hazardous. This is referred to as the benchmark margin of exposure, and installs a safe margin. 'The BMD/BMC is the dose of a substance that produces a “predetermined change in the response rate of an adverse effect.”' (Chen 41/80) By convention, an uncertainty factor of 10 is often a default to allow for human variability. While the NZ EPA’s Methodology does not discuss this, the ‘uncertainty factor concept is integrated into health risk assessments for all aspects of public health practice’. Exposures may be calculated from urinary fluoride levels. The level at which a chemical becomes hazardous is referred to as the point of departure, or hazard level.

Judge Chen at 5/80: The pooled benchmark dose analysis concluded that a 1-point drop in IQ of a child is to be expected for each 0.28 mg/L of fluoride in a pregnant mother’s urine. This is highly concerning, because maternal urinary fluoride levels for pregnant mothers in the United States range from 0.8 mg/L at the median and 1.89 mg/L depending upon the degree of exposure. Not only is there an insufficient margin between the hazard level and these exposure levels, for many, the exposure levels exceed the hazard level of 0.28 mg/L.

Work undertaken by Professor Philippe Grandjean and colleagues was central to the judge's decision around a benchmark dose (See discussion [67] 43/80.) In 2023 PSGR interviewed Professor Grandjean (listen on Spotify or Substack) on the scientific work and the benchmark dose calculations which had recently enabled Grandjean and colleagues to arrive at this finding.

Evidence published in New Zealand in 2018 demonstrates that young children have higher urinary fluoride levels than adults.

In August 2024 the U.S. National Toxicology Program published their Monograph on the State of the Science Concerning Fluoride Exposure and Neurodevelopment and Cognition: A Systematic Review. NTP Monograph 08. National Toxicology Program Public Health Service U.S. Department of Health and Human Services.

This review finds (moderate confidence) that higher estimated fluoride exposures (... drinking water fluoride concentrations that exceed WHO Guidelines for Drinking-water Quality 1.5mg/L of fluoride) are consistently associated with lower IQ in children
Associations between lower total fluoride exposure [e.g., as in approximations of exposure such as drinking water fluoride concentrations that were lower than the WHO Guidelines for Drinking-water Quality of 1.5 mg/L of fluoride (WHO 2017)] and children’s IQ remain unclear.
However, because people receive fluoride from multiple sources (not just drinking water), individuals living in areas with optimally fluoridated water can have total fluoride exposures higher than the concentration of their drinking water.
Additional exposures to fluoride from other sources increase total F exposure. Moderate confidence conclusions may be relevant to people living in optimally fluoridated areas of the US depending on the extent of their additional exposures to F from sources other than drinking water.
Seven meta-analyses found statistically significant inverse associations between fluoride assessment measures and children’s IQ. Many studies lacked the information necessary to evaluate study quality, and most used group-level estimates of fluoride exposure.
Although the use of various effect measures and methods makes comparison of the magnitude of the associations difficult across meta-analyses, there is a consistent reporting of inverse associations between fluoride exposure assessment measures and children’s IQ.
NTP Review (2024) concludes with moderate confidence: higher estimated fluoride exposures consistently associated with lower IQ in children. Studies identified in the updated literature search had similar study designs and patterns of findings.
Concludes: Recent meta-analyses of the inverse association between children’s IQ and fluoride exposures provide additional evidence of a dose-response relationship. However, uncertainty remains in findings at the lower fluoride exposure range.
Concludes: As this body of evidence matures, consideration for upgrading the moderate confidence conclusion to high confidence based on additional evidence of dose-response relationships at lower fluoride levels may be warranted.

Findings that demonstrate vague efficacy, are also being released. A recent Cochrane review that was released in October 2024, where the sole risk denominator was fluorosis (i.e. where cognitive neurodevelopmental risk was not considered as a risk factor) of 157 studies concluded that:

‘There is insufficient evidence to determine the effect of cessation of CWF on caries and whether water fluoridation results in a change in disparities in caries according to socioeconomic status.’

Iheozor-Ejiofor Z, Walsh T, Lewis SR, Riley P, Boyers D, Clarkson JE, Worthington HV, Glenny A-M, O'Malley L. Water fluoridation for the prevention of dental caries. Cochrane Database of Systematic Reviews 2024, Issue 10. Art. No.: CD010856. DOI: 10.1002/14651858.CD010856.pub3. Accessed 15 October 2024. 157 studies reviewed. (WF= Water fluoridation)

Water fluoridation initiation (21 studies): Low certainty evidence WF may lead to a slightly greater change over time in the proportion of caries‐free children with primary dentition.
Water fluoridation cessation (1 study): low‐certainty evidence. Could not be determined if cessation affected levels of decay, and of missing & filled teeth.
Association of water fluoridation with dental fluorosis (135 studies): With a fluoride level of 0.7 parts per million (ppm), approximately 12% of participants had fluorosis of aesthetic concern, and approximately 40% had fluorosis of any level. Because of very low‐certainty evidence, we were unsure of other adverse effects (including skeletal fluorosis, bone fractures and skeletal maturity).

THE DIRECTOR-GENERAL OF HEALTH - PREVARICATING ON FLUORIDE RISK?

Many New Zealand councils had been directed by the Director-General of Health to fluoridate their water by a nominated date.

Fluoridation is a limit on the right in s 11 of the New Zealand Bill of Rights Act 1990 (BORA) to refuse medical treatment. A recent judgement permitted the Director-General of Health to continue to order to fluoridate municipal water – with no time limit on a legal obligation of the Director-General Diane Sarfati to assess whether the directions under section 116E of the New Zealand Bill of Rights Act 1990 (BORA) were a reasonable limit on s11 on the right to refuse medical treatment. Judge Radich’s November 2023 decision that that the D-G was required to turn his mind to the potential impact on rights was amended by a later February 2024 Relief Judgement where Judge Radich pivoted to state that the D-G’s orders to fluoridate would continue to ‘have effect unless and until it is revoked or amended by the Director-General’ without a time limit on the D-G’s deliberation being prescribed.

It is nearly one year later and the Director-General has yet to make this decision while at the same time, the Director-General has turned down requests for an extension. The question may be asked, is the Director-General of Health's conduct fair or reasonable?

PDF: Fluoride Timeline - New Zealand Decisions & Key International Findings.

The legislation that permits fluoridation of drinking water follows an amendment to the Health (Fluoridation of Drinking Water Amendment Bill) Act 1956. However, in both the 2016/17 Select committee report, and a later 2021 Health Committee report, all public concerns about the safety of the fluoridation of drinking water were dismissed as they did not speak directly to the bill content.

For 50+ years, 50% of the population has been exposed to fluoridated water, and consequently, local authorities have released fluoridated council water into the environment. Yet the New Zealand Environmental Protection Authority has never monitored fluoride/ hydrofluorosilicic acid (HFA) emissions to understand environmentally relevant levels, nor conducted a risk assessment to identify the changing science on human and/or environmental health risk.

HFA is not a pharmaceutical grade chemical, but a highly corrosive compound. What occurs when emissions increase when community water is dosed with hydrofluorosilicic acid (HFA)? We don’t know!

However, with no formal (and impartial) regulatory process, it appears that all claims that the benefits outweigh the risks are flimsy. The primary ‘scientific’ source arises from claims by the Office of Prime Minister & Cabinet (OPMCSA). However, no methodological review was undertaken in 2021 and all peer review committees were highly biased towards the safety of fluoridated water.

The Water Services Act 2021 states that ‘safe’ drinking water can only be established when other causes are considered together with the consumption or use of drinking water. Children in New Zealand have higher levels of fluoride in their urine than adults, but this has not been considered by the OPMCSA, nor policy, nor in legislative processes. This was confirmed through an Official Information Act request response. The response confirmed that the Ministry of Health did not take into account (as a relevant consideration) existing urinary fluoride levels in children, which are higher than adults. Details were published in the 2018 paper by Andrea ‘t Mannetje and colleagues:

‘t Mannetje A, Coakley J, Douwes J. (2018) Report of the Biological Monitoring of Selected Chemicals of Concern. Results of the New Zealand biological monitoring programme, 2014-2016. Technical Report 2017-1. March. Centre for Public Health Research. Massey University. Wellington

As PSGR considers that the risk to children was downplayed by government agencies. For example, the OPMCSA engaged peer reviewers who were favourable to fluoridation of drinking water, while at the same time downplaying the assertions of scientists in the globally authoritative US National Toxicology Program (NTP) Assessment for Developmental Neurotoxicity.

See YouTube presentation: NZ Councils instructed to fluoridate water - was risk to kids downplayed by government agencies?

Where the NTP stated more evidence was required to confirm safety, the OPMCSA stated there was ‘no convincing evidence’ of risk. The OPMCSA dismissed an earlier 2019 draft and then failed to remain updated on the NTP draft and information release process and adequately inform policy-makers and the public on the uncertainty concerning risk, that the NTP toxicologists were highlighting. We believe the NTP is the more authoritative institution and should not be so lightly dismissed. We note that the OPMCSA appeared to lack a quorum of experts on this matter.

FLUORIDE PRESENTATIONS

August 26, 2024: Jodie Bruning presented to Tauranga City Council, along with 2 other presenters, Dr Alanna Ratna and Robert Coe on the subject of the safety of fluoridation of municipal water. (PSGRNZ version of Bruning presentation here). Powerpoint PDF. Presentation notes sent to elected members & provided to media.

Topic: TCC Ordinary Council Meeting. Presentation of Report: Fluoridation of Tauranga city's water supply. File Number: A16415420. Link to August 26 meeting. Elected members voted to seek an extension to defer the fluoridation of Tauranga’s water supply.

September 28, 2023: Dr Damian Wojcik presented to the Whangarei District Council. Video with references available here.

October 27, 2023: Jodie Bruning (MA Sociology) presented to the Bay of Plenty Regional Council (28 mins). Video with PowerPoint slides available here (0-28 mins). Transcript available here.

November 6, 2023: Jodie Bruning (MA Sociology) presented to the Tauranga City Commissioners and management. The talk was titled: Uncertainty about pending challenges to the lawfulness of Ministry of Health fluoride directives to TLAs. However, the public are only permitted 5 minutes to present, and the talk was cut short by the Commissioner at 7 minutes. YouTube video (5.30-13.00). Warning: poor sound quality. Link: Reference paper (PDF) handed to staff and commissioners and tabled by TCC.

The text (transcript available here) presented to Tauranga City Commissioners was re-presented with references in a YouTube video (14 minutes). This has been sent in an email to elected members in all councils affected by the Director-General's order to fluoridate water. In the talk Jodie Bruning stated:

When did the Ministry of Health consider the lowest safe level of exposure of fluoride in drinking water in combination with existing levels of fluoride? Are you aware that fluoride exposures in 5-7 year olds are higher than older age groups? That’s a 2018 study that was ignored by agencies and the 2021 Inquiry committee. How much fluoride should be added to prevent harm from prenatal exposures to 7-year-olds, based on Bay of Plenty data?

Following the Tauranga presentation Jodie Bruning agreed to an interview on Reality Check Radio to discuss the topic presented to Tauranga City Commissioners: Uncertainty about pending challenges to the lawfulness of Ministry of Health fluoride directives to TLAs.

PSGR welcomes interviews from all media in New Zealand on the topics we cover.

INTERVIEWS

PSGR trustee Jodie Bruning (MA Sociology) participated in the 2024 documentary by Reality Check Radio: Fluoride on the Brain. August 2024 interview with Reality Check Radio on the Tauranga City Council decision to defer fluoridation of municipal water.

Professor Philippe Grandjean is a professor of environmental medicine at the University of Southern Denmark and a research professor at the University of Rhode Island. Jodie Bruning interviewed Professor Grandjean October, 2023. Interview at @PSGRNZ on YouTube or Spotify.

‘We have to do everything we can to remove toxic exposures to support brain development.’

LISTEN TO: FULL INTERVIEW OR SHORT EXCERPT.

This study led by Grandjean brought together 3 cohort studies, from Mexico (ELEMENT study), Canada (MIREC) and Denmark (OCC) of mothers and infants. With over 1500 mother child pairs participating, this study was highly powered. The dose levels overlapped.

• Maternal urine-fluoride concentrations were measured, and child IQ was determined at age 7 years

• Regulators need to know the lowest level at which harm (a lowered IQ as a result of exposure) might commence, the approximate threshold for fluoride neurotoxicity, benchmark dose confidence level. In this study it was found to be at 0.33 mg/l fluoride in urine.

• The WHO's guideline value in drinking water is 1.5 mg/l (1500 µg/l). This was set in 1984.

• Background levels are found at low levels in nature. Fluoride is not a nutrient, rather it is a toxicant. Humans might have evolved a degree of tolerance at lower levels.

• This study contributes to 20 years of research into developmental neurotoxicity and fluoride.

• Developmental exposures which alter intelligence impact the capacity of that child to progress in life.

• The 'optimal level' for addition to drinking water has been in place since the 1950's. In areas with a hot climate, the "optimal" fluoride concentration is below 1 mg/litre while in cold climates it may be up to 1.2 mg/litre (Galagan & Vermillion, 1957). See 1984 WHO EHC 36.

Philippe Grandjean and Jodie Bruning discussed the unfortunate 40-year history of stacking scientific committees considering fluoride and health, with oral and dental experts. Oral and dental experts, rather than medical experts who take the whole body's health into account, may be more likely to support fluoridation of water, and thus have a bias, or weight their decision-making to support fluoridation.

FOR MORE INFORMATION: Grandjean P, Meddis A, Nielsen F, Beck IH, Bilenberg N, Goodman CV, Hu H, Till C, Budtz-Jørgensen E. (2023) Dose dependence of prenatal fluoride exposure associations with cognitive performance at school age in three prospective studies. Eur J Public Health. 2023 Oct 5:ckad170. doi: 10.1093/eurpub/ckad170. Epub ahead of print. PMID: 37798092

University of Southern Denmark press release: https://www.sdu.dk/en/om_sdu/fakulteterne/sundhedsvidenskab/nyheder/fluor-paavirker-intelligensen (in English)

PDF copy of the references cited at the end of the interview.

Interview with Prof Philippe Grandjean: 2023 study on fluoride & IQ contradicts so-called 'safe' levels in drinking water. Grandjean et al.

Download

FLUORIDE PRESENTATIONS

September 28, 2023: Dr Damian Wojcik presented to the Whangarei District Council. Video with references available here.

October 27, 2023: Jodie Bruning (MA Sociology) presented to the Bay of Plenty Regional Council (28 mins). Video with PowerPoint slides available here (0-28 mins). Transcript available here.

November 6, 2023: Jodie Bruning (MA Sociology) presented to the Tauranga City Commissioners and management. YouTube video (5.30-13.00). Warning: poor sound quality. Link: Reference paper (PDF) handed to staff and commissioners and tabled by TCC.

The text presented to Tauranga City Commissioners was re-presented with references in a YouTube video (14 minutes). This has been sent in an email to elected members in all councils affected by the Director-General's order to fluoridate water.

PSGR welcomes interviews from all media in New Zealand on the topics we cover.

INTERVIEW

‘We have to do everything we can to remove toxic exposures to support brain development.’

LISTEN TO: FULL INTERVIEW OR SHORT EXCERPT.

This study lead by Grandjean brought together 3 cohort studies, from Mexico (ELEMENT study), Canada (MIREC) and Denmark (OCC) of mothers and infants. With over 1500 mother child pairs participating, this study was highly powered. The dose levels overlapped.

• Maternal urine-fluoride concentrations were measured, and child IQ was determined at age 7 years

• Higher-level fluoride exposures in North America and lower-level exposures in Denmark gave the researchers a broad basis to arrive at a joint benchmark dose level, where at that level one IQ point would be lost. This was 0.45 mg/l fluoride in urine. • Regulators need to know the lowest level at which harm (a lowered IQ as a result of exposure) might commence, the approximate threshold for fluoride neurotoxicity, benchmark dose confidence level. In this study it was found to be at 0.33 mg/l fluoride in urine.

• The WHO's guideline value in drinking water is 1.5 mg/l (1500 µg/l). This was set in 1984.

• Background levels are found low level in nature. Fluoride is not a nutrient, rather it is a toxicant. Humans might have evolved a degree of tolerance at lower levels.

• This study contributes to 20 years of research into developmental neurotoxicity and fluoride.

• Developmental exposures which alter intelligence impact the capacity of that child to progress in life.

• The 'optimal level' for addition to drinking water has been in place since the 1950's 'In areas with a hot climate, the "optimal" fluoride concentration is below 1 mg/litre while in cold climates it may be up to 1.2 mg/litre (Galagan & Vermillion, 1957). See 1984 WHO EHC 36: https://iris.who.int/bitstream/handle/10665/37288/9241540966-eng.pdf?sequence=1

• Philippe Grandjean and Jodie Bruning discussed a 40-year history of stacking scientific committees considering fluoride and health, with oral and dental experts. Oral and dental experts may be more likely to support fluoridation of water, and thus have a bias, or weight their decision-making to support fluoridation.

FOR MORE INFORMATION: Grandjean P, Meddis A, Nielsen F, Beck IH, Bilenberg N, Goodman CV, Hu H, Till C, Budtz-Jørgensen E. (2023) Dose dependence of prenatal fluoride exposure associations with cognitive performance at school age in three prospective studies. Eur J Public Health. 2023 Oct 5:ckad170. doi: 10.1093/eurpub/ckad170. Epub ahead of print. PMID: 37798092

University of Southern Denmark press release: https://www.sdu.dk/en/om_sdu/fakulteterne/sundhedsvidenskab/nyheder/fluor-paavirker-intelligensen (in English)

PDF copy of the references cited at the end of the interview.

Download

Providing scientific & medical information & analysis in the service of the public's right to be independently informed on issues relating to human & environmental health.

New Zealand ‘does not pay sufficient attention to the future or guard against risks that can be readily foreseen.’ (Palmer and Butler 2018)

EXCERPT FROM THE 2023 PAPER: Deregulation? Biotechnology & gene editing: New Zealand context. PDF

INTRODUCTION

This 2023 report summarises key issues relating to science, stewardship and risk of biotechnologies in New Zealand.

In Aotearoa New Zealand there are gaps and barriers to effective stewardship, science and regulation regarding biotechnology. This includes the regulation of newer technologies such as gene editing and penetrator technologies.[i] The barriers arise from governance structures, political cultures, science policy and lack of funding pathways which deter independent research and science and expert knowledge.

GMOs and gene edited organisms, together with chemicals and increased use of trace or heavy metals, are known as novel entities:

“new substances, new forms of existing substances and modified life forms that have the potential for unwanted geophysical and/or biological effects… These potentially include chemicals and other new types of engineered materials or organisms not previously known to the Earth system as well as naturally occurring elements (for example, heavy metals) mobilized by anthropogenic activities”.

Stockholm Environment Institute scientists recently proposed that

‘annual production and releases [of novel entities] are increasing at a pace that outstrips the global capacity for assessment and monitoring.’

Current regulatory protocols fail to require independent reviews of the changing scientific literature which might contradict biotechnology-as-safe narratives; and the absence of funding ensure appropriate feedback loops are not established which could funnel monitoring and research information back into the regulatory environment concerning novel entities that are currently released into the environment and into human bodies.

The effect is that the government can neither predict risk or harm, nor steward these technologies precautionarily, in order to ensure that the principles of the Treaty of Waitangi are upheld.

REGULATING PROCESS

Despite media rhetoric, our legislation is good, as it recognises the simple fact that scientists, lawmakers and the public simply do not know what new techniques lie around the corner.

New Zealand’s existing legislation augmented with local government involvement in key regions of genetically modified organisms (GMOs), including newer gene editing technologies, is robust and fit for purpose.

This is where New Zealand stands:

Gene editing processes trigger regulation. Regulation of technology in relation to airlines, chemicals, cars etc is common^[ii] and important.
Our regulation aligns with a recent European Union court decision. It has been held that newer gene editing technologies require regulation, just like the older techniques of genetic modification.
Our legislation is precautionary which thus does not permit automatic releases into the environment. As many unanticipated problems continue to arise with both the older techniques and with new techniques, the precautionary principle continues to be the best mechanism to protect human and environmental health.
Our oversight can improve – to recognise the risk from the potential for technologies to quickly scale up.

By regulating the process (as opposed to a product or novelty), New Zealand should have across the board transparency as we regulate all genetic engineering processes – as do the majority of countries in the world which are united under the Cartagena Protocol for Biosafety.

As our monitoring is limited, public discussions are often weighted to industry-based perspectives, bioethics issues remain out in the cold. Similarly, our regulation can be improved, and take into account the scalability of technologies.

THE SCALABILITY IMPACT

Biotechnologies continue to require regulation and oversight because of their potential to be emitted or deployed at scale, whether in medicine, personal care, agriculture in pest control or for other applications. However, current regulatory triggers don’t allow for risk from release or deployment at scale, and scientists have proposed that a scale trigger can be embedded in regulation. [iii] Scale is explained here:

‘Scale is a complex concept that differs in meaning across disciplines. It is not exclusively a measure of distance, area, volume, and time but also a mixture of these and their relationship with human activity. Where human activity intersects with the environment, there is risk, putting the intersection at the place where we may best control risks of our own making. The highest priority for technology regulation, after deciding to adopt a technology, are harmful or beneficial effects that scale up quickly and/or widely as a result of human activity.’[iv]

However, as the ‘scale of control afforded by science advances, so does the domain of uncertainty and potential risk.’[v] The rationale for continued oversight of biotechnology was outlined by Professor Jack Heinemann, from the Centre for Integrated Research in Biosafety, in a 2021 submission [vi] which looked at definitions of gene technology:

‘Describing techniques of gene technology by their biochemistry, whether it be the reactions that lead to the insertion of a ‘transgene’ and the reactions that lead to genome editing, provides little clarity for technology governance.

The characteristic of the technology that justifies social governance through legislation is that it can amplify the rate and magnitude of harm by increasing the ease of use, number of people using it, range of types of organisms and numbers of individuals it is used on, and the number of environments where it can be applied.’

Heinemann’s work on scalability and uncertainty complements Dr Jan Wright’s criteria[vii] in for judging the for an environmental threat to cause harm, the degree to which it might be:

irreversible
cumulative – building up over time
large in scale or pervasive
increasing or even accelerating in scale and/or distribution
likely to tip a natural system over a threshold into another state

Another problem when it comes to ensuring the safe regulation of biotechnology is the persistent dilemma (with all environmental harms) that harm and risk are difficult to predict. In such an environment, decision-making using the precautionary principle can aide officials. However, in New Zealand, implementation of the precautionary principle is inconsistent and poor, and there has been little work undertaken to develop frameworks and understandings that might support officials.

Continue reading here.

REFERENCES

Glossary

[i] Described in this new paper from the University of Canterbury the New Zealand Defence Agency

Heinemann, J.A.; Walker, S. Environmentally applied nucleic acids and proteins for purposes of engineering changes to genes and other genetic material. Biosafety Health 2019;1:113-123

^[ii] Heinemann, JA. Is product-based regulation of biotechnology code for no regulation? Rightbiotech. https://rightbiotech.tumblr.com/post/178959072080/is-product-based-regulation-of-biotechnology-code

[iii] Heinemann, JA, Paull DJ, Walker S, Kurenbach B. 2021. Differentiated impacts of human interventions on nature: Scaling the conversation on regulation of gene technologies. Elem Sci Anth, 9: 1. https://doi.org/10.1525/elementa.2021.00086

[iv] Heinemann, JA, Paull DJ, Walker S, Kurenbach B. 2021. Differentiated impacts of human interventions on nature: Scaling the conversation on regulation of gene technologies. Elem Sci Anth, 9: 1. https://doi.org/10.1525/elementa.2021.00086

[v] Montenegro de Wit, M. 2020. Democratizing CRISPR? Stories, practices, and politics of science and governance on the agricultural gene editing frontier. Elementa: Science of the Anthropocene 8: 9. DOI: http://

dx.doi.org/10.1525/elementa.405.

[vi] Heinemann JA. 2021. Submission on Proposal P1055 Definitions of Gene Technology. November 2021. Technical Report. DOI:10.13140/RG.2.2.26196.32647

[vii] Parliamentary Commissioner for the Environment (2010). How clean is New Zealand? Measuring and reporting on the health of our environment https://pce.parliament.nz/media/kcvdylib/how-clean-is-new-zealand3.pdf

Subcategories

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For over 20 years the Physicians and Scientists for Global Responsibility New Zealand Charitable Trust (PSGR) has produced reports and submitted to government Bills and Inquiries.

We’ve been extraordinarily busy over the past 2 years with our work.

This Update aims to inform members and colleagues – and act as a go-to summary of our recent work.

2022 UPDATE - PDF

As well as our recent work All PSGR’s submissions are available to the public on our Submissions pages. In addition, we are now on LinkedIn, Twitter, Odysee & Instagram.

MEMBERSHIP

Please – without your support and membership PSGR cannot do this work. We’ve kept our fees deliberately low because your membership is important to us.

MOVING FORWARD 2022+

The PSGR recognise that the perspectives that have been expressed by the PSGR from 2020 onwards will not necessarily reflect the perspectives of all trustees and all members.

However, we sincerely hope that PSGR’s perspectives are more likely to reflect the perspectives of the majority of our membership and of collegial organisations – which represents a diverse quorum of inquiring minds.

We hope that we have demonstrated a consistency to our work, that reflects and upholds the principles reflected in 20 years of research, information communications and submissions to policy

Reports and Papers

Royal Commission

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