2021 Inquiry - Director-General to have power to direct local drinking water suppliers to add fluoride to water

Submission by PSGR to the Parliamentary Inquiry into Supplementary Order Paper No. 38 on the Health (Fluoridation of Drinking Water) Amendment Bill.

Link to the June 18th 28 page Submission (PDF) available here .

Link to June 28th the PSGR oral presentation to the Parliamentary Health Committee available here and commences at 39min 37sec

The submission of the PSGR focussed on the gaps in existing policy and toxicology documents where relevant issues including the neurodevelopmental risk of fluoride, the fact that younger children already have higher levels of fluoride than New Zealand adults; and the endocrine disrupting potential of fluoride - have been minimally discussed or neglected. Neurodevelopmental risk is particularly acute during vulnerable developmental periods, such as in pregnancy and throughout childhood, yet this has not been considered in any analysis of fluorides toxicological risk.

NB: (2023) Following this consultation process, the Health (Fluoridation of Drinking Water) Amendment Act 2021 was passed. This gives the Director-General of Health power to direct local authorities to add – or not to add – fluoride to a drinking-water supply. No review of the neurodevelopmental potential was undertaken. The Director-General has since directed 14 local authorities to fluoridate.

Natural fluoride levels in New Zealand are around 0.2mg/L. The Ministry of Health requires water suppliers adjust fluoride levels to between 0.7 and 1.0 mg/L in drinking water.

Since this time, more evidence has surfaced, demonstrating that the neurodevelopmental risk potential of fluoride will continue to contradict government claims of safety. Evidence demonstrates that there is a very narrow window for drinking suppliers. The U.S. National Toxicology Program released a draft Monograph on the State of the Science Concerning Fluoride Exposure and Neurodevelopmental and Cognitive Health Effects in September 2022. The review included 19 studies which consistently demonstrated the risk potential. The NTP study confirmed that there was evidence that exceedance of 1.5 mg/L of fluoride is consistently associated with lower IQ in children, while the notes in the draft document indicate that scientists could not confirm an obvious threshold of risk.

In November 2022 one of the papers we cited, relating to fluoride's potential neurodevelopmental risk was retracted. However, in June 2023 a meta-analysis was published by Jayanth Kumar et al., Association between low fluoride exposure and children's intelligence: a meta-analysis relevant to community water fluoridation. This meta-analysis does include the retracted paper. The meta-analysis drew attention to a range of evidence that where fluoride levels exceeded ~1.5 mg/l F, there was evidence of fluorosis and IQ impairment in children. There is evidence that the lead author on this paper holds a pre-established cognitive bias concerning the safety of water fluoridation which may bias the meta-analysis findings.

This body of evidence demonstrates there is little leeway for water suppliers to mistakenly exceed established levels, and that suppliers must have state of the art equipment, with constant monitoring capability.

The PSGR also expressed concern that the expert scientific consultants have, for some years, not included experts with scientific expertise into the endocrinologic and endocrine disrupting potential of fluoride. Experts in toxicology and dental and oral health do not represent sufficient expertise when the anticipated medication (as fluoride is not a nutrient, and the dose-risk scenarios reflect toxicological parameters).

The PSGR referred to the European 2013 EFSA Scientific Opinion on Dietary Reference Values for fluoride which appears to be downplayed in the New Zealand and Australian literature.

The EFSA is clear, fluoride is not a nutrient, having no nutritional value. New Zealand policy is yet to focus on key nutrients vital to dental health, identified in the scientific literature. Many of these key nutrients are also important wider physiological and mental health parameters.

The EFSA in the Scientific Opinion, spent some time illustrating the importance of dietary prevention. Policies that increase access to healthy food, while decreasing the appeal of high sugar/ high carbohydrate ultraprocessed low-nutrient product have not been discussed in relation to protection of health - and teeth in New Zealand.

The PSGR expressed concern that by omission of certain relevant factors, that Parliament may have been misled by officials as to both the benefits and health risk of fluoride. We note that risk as an endocrine disruptor is similar to all vertebrates, and that ongoing fluoride emissions from wastewater would contaminate surrounding waterways. Therefore tuna (eel), fish, and other water vertebrates would be similarly at risk, especially during vulnerable developmental periods, from constant (non-seasonal) emissions.

Introduction (as in the document):

1. PSGR considers that the Supplementary Order Paper (SOP) amendment to confer power to the Director-General of Health to direct local drinking-water suppliers to add (or not to add) fluoride is unreasonable because it gives powers for one public servant in one department to require known bio-accumulative toxins to be put into public water supplies. To do so, when the claimed benefits of doing that are so minor as to be de minimis; seems to be absurd; especially when compared with the probabilities of harm to people and the environment are proportionately unacceptable.

2. Such action seems to assume that a medical treatment - the adding of sodium silicofluoride (SSF), or similar - will be of approximately equal benefit or risk to all citizens. However, to not take into account individual vulnerability is unacceptable and extremely hazardous. This appears to be absurd.

2.1. PSGR observes that the Office of the Prime Minister’s Chief Science Advisor documentation refers to many studies that consider the data on claimed benefits to be inconclusive and that many newer studies on risks to health were excluded from that documentation.
2.2. From this, the Health Committee can infer that there is no consensus on whether fluoride is harmful, and in particular, whether fluoride presents a neurodevelopmental risk.
2.3. Conversely, no conclusion may be drawn on absence of harm.
2.4. Experts in oral health, clinical dentistry and toxicology appear to have applied a somewhat narrow view of toxicology around single substances. This appears to have tainted the current policy formulation approach; and that includes the associated peer review.
2.5. The issue of potential neurotoxicity of fluoride may have more relevance to endocrine pathways, yet no experts in endocrinology, including neurodevelopmental endocrinology, appeared to participate in either analysing the data or in the peer review process or in the policy formulation process.
2.6. While this submission predominantly concerns the human health risk, we note the potential for fluoridation of community water supplies to present a long-term environmental health risk. PSGR are unable to identify forecast modelling on the potential for firstly, the potential for fluoridation of drinking water to accelerate the bioaccumulation of fluoride in the environment, following release through liquid and solid waste streams. Secondly, PSGR have been unable to identify analysis exploring the efficacy of treatment in existing fluoridated regions. This is of concern as there is potential for fluoride bioaccumulation in fresh and groundwater beyond the capacity of the environment to degrade.

3. What does that mean for the Health Committee?

3.1. The principal Act, the Health Act, directs decision-makers to act to protect public health.
3.2. With a lack of scientific consensus, with evidence of potential for harm, we recommend a precautionary approach is adopted, and that power to fluoridate remains a local, democratic project and is not transferred to the Director-General of Health.

Link to the PDF submission:

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