Fluoridation of drinking water: 2023/24 F/Y Budget calculations including revisions

J Bruning made this Official Information request to Ministry of Health

The request was successful.

From: J Bruning

Dear Ministry of Health,

This is an urgent request under section 12(3) of the Official Information Act. I set out below the information I am seeking, and then I state my reasons for asking the Ministry to make a decision on my request urgently.

In 2021 the Select Committee consideration stated:

'We understand that the total costs for the capital component of fluoridation are estimated at $61 million. Some funding will be available to support local authorities to fluoridate their water supplies—$8.3 million in 2021/22 and $3 million a year in subsequent years. The funding will cover some, but not all, of the capital costs.'

[a] Please supply total funding directed to support local drinking water suppliers fluoridate local water, and details of which councils received a particular funding injection.
- 2021/2022
- 2022/2023

and

[b] current proposed budget for 2023/2024 by council and in total.

[c] It is unclear from appropriations budgets how financial costs for fluoridation are categorised. Please show/advise how financial ledgers categorise Ministry costs for fluoridation.

[d] It is understood that fluoridation does not completely prevent caries but that there may be an uncertain marginal benefit to the DMFT (HNZ00030962). Please advise the budgeted costs savings to treatment of dental caries for the public health sector from this initiative in the 0-7 (or - 0-10) age group.

[e] Please forward all advice and analysis sent to the Director General and/or the Minister of Health reviewing or discussing any draft version of the NTP Monograph on the State of the Science Concerning Fluoride Exposure and Neurodevelopmental and Cognitive Health Effects: A Systematic Review. US National Toxicology Program - from March 2021 onwards.
-------------------------------------------------------------------------------------------------------------------
-> My reason for seeking the information urgently is to enable the public to understand the cost-benefit ratio of fluoridation of drinking water supplies at a time when the Director General has imposed deadlines, such as the demand that Rotorua Lakes implement water fluoridation by April 2024.
https://www.health.govt.nz/about-ministr...

Ministry of Health and Select Committee processes may be insufficiently robust - deficient - at judging risk and harm, when there is a claimed marginal benefit, but there is commensurately a neurodevelopmental risk, particularly in the first seven years. This concerns the injection of a known neurotoxin, which is not a nutrient (EFSA 2019) into water supplies.

1. Local water supplies face a cost of $200,000 for failure to implement fluoridation by the allocated time and $10,000 per day thereafter. We understand that Councillors will be under immense pressure to submit to the directive, even if they are concerned that in doing so they may fail to protect health.

2. The US National Toxicology Program (September 2022) is the most comprehensive document on neurodevelopmental risk to be released globally. The NTP document reveals that the scientists will not state categorically that the claimed safe (or 'optimum') level of 0.7 gm/l is safe. The reviews by the Office of the Prime Minister's Chief Science Advisor did not review the available data to any comparable extent as the NTP document.

3. In such an uncertain environment the Ministry of Health has not set aside funding to conduct studies at this level to shed light on this situation, despite fluoridation commencing in Auckland and Wellington in the 1960s. Risk to the brain has been understood since this time and the Ministry of Health has capacity to require that independent research is undertaken locally (including meta-analyses of the evidence on cognitive risk and risk to IQ) yet have not done so.

4. The EPA has not carried out a risk assessment, as would normally occur for a substance that is exposed to the children at all life stages, as well as being released into water bodies. Water suppliers and Taumata Arowai remain unclear on the fluoride formulation that will be added.

5. Despite a 2018 paper being released that looked at present urine levels in the population, and which showed that children's levels are higher than adults, this document and any analysis of total fluoride exposure has not been undertaken, yet 'safe' in the Water Services Act s7ii. requires that all exposures are considered 'other causes together with the consumption or use of drinking water.

6. All public comments to the 2021 Inquiry discussing the potential risk were ignored and dismissed by the Select Committee as being out of scope and covered by the 2017 Select Committee. ' However, in our report we have not commented on submissions that were supportive of, or opposed to, fluoridation generally, but that did not provide specific feedback on changes to the bill proposed by the SOP.' (page 3)
https://selectcommittees.parliament.nz/v...

However, the earlier 2017 consultation did not concern the transference of powers to the Director General. I.e., the removal of local decision-making powers. So, issues of risk and benefit had potential to be addressed at the local level.

7. The 2017 Select Committee process did not address public concerns of safety either:
'We acknowledge that the majority of submitters expressed concern about the safety and efficacy of water fluoridation. Medical and dental associations and representative bodies, and most doctors and dentists, spoke in support of fluoridating water. However, we consider these issues beyond the subject matter of the bill, which is about giving DHBs the power to make a direction about fluoridation.' (page 208-3)
https://selectcommittees.parliament.nz/v...

Yet the public, including local councils have a right to understand both the financial cost and benefit, and the extent to which risk at levels of exposure have been considered by officials - particularly with drinking water suppliers facing extensive fines if they do not comply with the D-G's request.

This public interest is explicitly recognised in section 4(a)(i) of the OIA, which says that the purpose of that Act is ’to increase progressively the availability of official information to the people of New Zealand in order to enable their more effective participation in the making and administration of laws and policies.'

I look forward to receiving the Ministry’s decision and the information sought as soon as reasonably practicable and certainly no later than 20 working days after receipt of this request due to the pressure exerted by the Director General of Health on local authorities to commence fluoridation.

Thank you.

Yours faithfully,

J Bruning

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Kia ora

Thank you for your request under the Official Information Act 1982 (the
Act) on 30 October 2023:

[a] Please supply total funding directed to support local drinking water
suppliers fluoridate local water, and details of which councils received a
particular funding injection.
- 2021/2022
- 2022/2023

and

[b] current proposed budget for 2023/2024 by council and in total.

[c] It is unclear from appropriations budgets how financial costs for
fluoridation are categorised. Please show/advise how financial ledgers
categorise Ministry costs for fluoridation.

[d] It is understood that fluoridation does not completely prevent caries
but that there may be an uncertain marginal benefit to the DMFT
(HNZ00030962). Please advise the budgeted costs savings to treatment of
dental caries for the public health sector from this initiative in the 0-7
(or - 0-10) age group.

[e] Please forward all advice and analysis sent to the Director General
and/or the Minister of Health reviewing or discussing any draft version of
the NTP Monograph on the State of the Science Concerning Fluoride Exposure
and Neurodevelopmental and Cognitive Health Effects: A Systematic Review.
US National Toxicology Program - from March 2021 onwards.

We will endeavour to respond to your request as soon as possible and in
any event no later than 27 November 2023, being 20 working days after the
day your request was received. If we are unable to respond to your request
by then, we will notify you of an extension of that timeframe.

If you have any queries regarding your request, please feel free to
contact the OIA Services Team on [1][email address]. If any
additional factors come to light which are relevant to your request,
please do not hesitate to contact us so that these can be taken into
account. 

Under section 28(3) of the Act you have the right to ask the Ombudsman to
review any decisions made under this request. The Ombudsman may be
contacted by email at: [2][email address] or by calling 0800
802 602.
 

OIA Services Team
[3]Manatû Hauora information releases
[4][IMG] [5][IMG] [6][IMG] [7][IMG]

 
 

------------------- Original Message -------------------
From: J Bruning <[FOI #24587 email]>;
Received: Mon Oct 30 2023 14:56:00 GMT+1300 (New Zealand Daylight Time)
To: OIA Requests <[email address]>; OIA <[email address]>;
Subject: Official Information request - Fluoridation of drinking water:
2023/24 F/Y Budget calculations including revisions

Dear Ministry of Health,

This is an urgent request under section 12(3) of the Official Information
Act. I set out below the information I am seeking, and then I state my
reasons for asking the Ministry to make a decision on my request urgently.

In 2021 the Select Committee consideration stated:

'We understand that the total costs for the capital component of
fluoridation are estimated at $61 million. Some funding will be available
to support local authorities to fluoridate their water supplies—$8.3
million in 2021/22 and $3 million a year in subsequent years. The funding
will cover some, but not all, of the capital costs.'

[a] Please supply total funding directed to support local drinking water
suppliers fluoridate local water, and details of which councils received a
particular funding injection.
- 2021/2022
- 2022/2023

and

[b] current proposed budget for 2023/2024 by council and in total.

[c] It is unclear from appropriations budgets how financial costs for
fluoridation are categorised. Please show/advise how financial ledgers
categorise Ministry costs for fluoridation.

[d] It is understood that fluoridation does not completely prevent caries
but that there may be an uncertain marginal benefit to the DMFT
(HNZ00030962). Please advise the budgeted costs savings to treatment of
dental caries for the public health sector from this initiative in the 0-7
(or - 0-10) age group.

[e] Please forward all advice and analysis sent to the Director General
and/or the Minister of Health reviewing or discussing any draft version of
the NTP Monograph on the State of the Science Concerning Fluoride Exposure
and Neurodevelopmental and Cognitive Health Effects: A Systematic Review.
US National Toxicology Program - from March 2021 onwards.
-------------------------------------------------------------------------------------------------------------------
-> My reason for seeking the information urgently is to enable the public
to understand the cost-benefit ratio of fluoridation of drinking water
supplies at a time when the Director General has imposed deadlines, such
as the demand that Rotorua Lakes implement water fluoridation by April
2024.
[8]https://www.health.govt.nz/about-ministr...

Ministry of Health and Select Committee processes may be insufficiently
robust - deficient - at judging risk and harm, when there is a claimed
marginal benefit, but there is commensurately a neurodevelopmental risk,
particularly in the first seven years. This concerns the injection of a
known neurotoxin, which is not a nutrient (EFSA 2019) into water supplies.

1. Local water supplies face a cost of $200,000 for failure to implement
fluoridation by the allocated time and $10,000 per day thereafter. We
understand that Councillors will be under immense pressure to submit to
the directive, even if they are concerned that in doing so they may fail
to protect health.

2. The US National Toxicology Program (September 2022) is the most
comprehensive document on neurodevelopmental risk to be released globally.
The NTP document reveals that the scientists will not state categorically
that the claimed safe (or 'optimum') level of 0.7 gm/l is safe. The
reviews by the Office of the Prime Minister's Chief Science Advisor did
not review the available data to any comparable extent as the NTP
document.

3. In such an uncertain environment the Ministry of Health has not set
aside funding to conduct studies at this level to shed light on this
situation, despite fluoridation commencing in Auckland and Wellington in
the 1960s. Risk to the brain has been understood since this time and the
Ministry of Health has capacity to require that independent research is
undertaken locally (including meta-analyses of the evidence on cognitive
risk and risk to IQ) yet have not done so.

4. The EPA has not carried out a risk assessment, as would normally occur
for a substance that is exposed to the children at all life stages, as
well as being released into water bodies. Water suppliers and Taumata
Arowai remain unclear on the fluoride formulation that will be added.

5. Despite a 2018 paper being released that looked at present urine levels
in the population, and which showed that children's levels are higher than
adults, this document and any analysis of total fluoride exposure has not
been undertaken, yet 'safe' in the Water Services Act s7ii. requires that
all exposures are considered 'other causes together with the consumption
or use of drinking water.

6. All public comments to the 2021 Inquiry discussing the potential risk
were ignored and dismissed by the Select Committee as being out of scope
and covered by the 2017 Select Committee. ' However, in our report we have
not commented on submissions that were supportive of, or opposed to,
fluoridation generally, but that did not provide specific feedback on
changes to the bill proposed by the SOP.' (page 3)
[9]https://aus01.safelinks.protection.outlo...

However, the earlier 2017 consultation did not concern the transference of
powers to the Director General. I.e., the removal of local decision-making
powers. So, issues of risk and benefit had potential to be addressed at
the local level.

7. The 2017 Select Committee process did not address public concerns of
safety either:
'We acknowledge that the majority of submitters expressed concern about
the safety and efficacy of water fluoridation. Medical and dental
associations and representative bodies, and most doctors and dentists,
spoke in support of fluoridating water. However, we consider these issues
beyond the subject matter of the bill, which is about giving DHBs the
power to make a direction about fluoridation.' (page 208-3)
[10]https://aus01.safelinks.protection.outlo...

Yet the public, including local councils have a right to understand both
the financial cost and benefit, and the extent to which risk at levels of
exposure have been considered by officials - particularly with drinking
water suppliers facing extensive fines if they do not comply with the
D-G's request.

This public interest is explicitly recognised in section 4(a)(i) of the
OIA, which says that the purpose of that Act is ’to increase progressively
the availability of official information to the people of New Zealand in
order to enable their more effective participation in the making and
administration of laws and policies.'

I look forward to receiving the Ministry’s decision and the information
sought as soon as reasonably practicable and certainly no later than 20
working days after receipt of this request due to the pressure exerted by
the Director General of Health on local authorities to commence
fluoridation.

Thank you.

Yours faithfully,

J Bruning

-------------------------------------------------------------------

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Kia ora Mr Bruning,
Please find attached a response to your request for official information.

Ngā mihi 

  

OIA Services Team

Manatū Hauora | Ministry of Health

M[1]inistry of Health information releases 
U[2]nite against COVID-19 

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Statement of confidentiality: This e-mail message and any accompanying
attachments may contain information that is IN-CONFIDENCE and subject to
legal privilege.
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Kia ora J Bruning,
Please find attached a response to the remaining parts of your request for
official information.

Ngā mihi 

  

OIA Services Team

Manatū Hauora | Ministry of Health

M[1]inistry of Health information releases 
U[2]nite against COVID-19 

****************************************************************************
Statement of confidentiality: This e-mail message and any accompanying
attachments may contain information that is IN-CONFIDENCE and subject to
legal privilege.
If you are not the intended recipient, do not read, use, disseminate,
distribute or copy this message or attachments.
If you have received this message in error, please notify the sender
immediately and delete this message.
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