Dear Ministry of Health,

Under the Official Information Act 1982, I request the following information regarding fluoride in drinking water under the Fluoridation of Drinking Water Amendment Act 2021, specifically relating to the Director-General of Health’s responsibilities under Section 116C. This request addresses deficiencies in your response (H2025065288, 9 May 2025) and incorporates recent scientific and legal developments.

1. Detailed Review of NTP Reports (2024–2025):
• Provide the full review, analysis, or evaluation document conducted by the Ministry or Director-General of the National Toxicology Program’s August 2024 Monograph and January 2025 meta-analysis (https://ntp.niehs.nih.gov/publications/m...), which found a moderate confidence link between fluoride exposure above 1.5 mg/L and lower IQ in children, with effects suggested below this level.
• Clarify whether the consideration cited in H2025065288 (www.health.govt.nz/information-releases/director-general-of-health-consideration-of-community-water-fluoridation-under-the-new-zealand-bill) includes a specific assessment of New Zealand’s 0.85 mg/L exposure level and multi-source risks (e.g., toothpaste, tea). If not, provide this assessment.
• Explain the scientific methodology and evidence supporting your conclusion that these reports do not alter safety assessments, addressing the 95% consistency of 52/55 studies showing IQ reduction.

2. Post-August 2024 Scientific Reviews:
• Provide copies of all reviews, studies, or analyses conducted or commissioned since August 2024 on fluoride in drinking water, including the October 2024 Cochrane Review and the Ministry’s 2024 evidence review (www.health.govt.nz, 2024-12-04).
• Include any assessments of neurodevelopmental risks, dental fluorosis trends, or transdermal absorption, given noncompliance with targets (Belotti et al., 2024) and public health concerns.
• If no such reviews exist, confirm this and justify the absence despite international developments (e.g., EPA reassessment, Utah ban).

3. Decision-Making Process Under Section 116C:
• Detail the criteria, methodologies, and guidelines used to evaluate “relevant evidence” under Section 116C(4), including how the NTP findings and High Court rulings (2023–2024) were incorporated.
• Provide the cost-benefit analysis for New Zealand’s 0.85 mg/L level, weighing IQ risks against dental benefits, and address equity impacts in high-deprivation areas.

4. Transdermal Absorption and Health Risks:
• Provide studies or risk assessments on fluoride absorption through the skin from fluoridated drinking water, given its use in showers and anecdotal reports of adverse effects.
• If none exist, explain why this exposure route has not been evaluated, despite its relevance to compulsory treatment debates.

5. Correspondence and Monitoring Data:
• Provide copies of internal/external correspondence (e.g., emails, meeting minutes) since August 2024 regarding NTP reports, neurotoxicity, or Bill of Rights compliance.
• Supply fluoride concentration data (1992–2025) for all 25 supplies studied by Belotti et al. (2024), detailing compliance with 0.7–1.0 mg/L targets and exceedances above 1.5 mg/L.

6. Legal and Ethical Compliance:
• Provide the full Bill of Rights Act 1990 analysis (Section 11) supporting the 2024 directive reconfirmation, including how NTP evidence and public inquiry demands (e.g., FFNZ) were considered.
• Explain any plans to align with EPA’s reassessment (2025-04-08) or respond to the 2023 High Court ruling’s process error.

7. Response to Legislative Reform – Fluoridation (Referendum) Legislation Bill 2025:
• Provide any internal correspondence, legal advice, or briefing papers held by the Ministry relating to the introduction of the Fluoridation (Referendum) Legislation Bill by New Zealand First in 2025.
• Include assessments of how repeal of the 2021 Amendment Act would affect the Director-General’s current fluoridation directives and Ministry public health policy.
• Confirm whether the Ministry has prepared contingency plans or legal risk advice in relation to this Bill and its potential implementation.

Please ensure responses are specific to drinking water as defined in the Fluoridation of Drinking Water Amendment Act 2021. If any requested information does not exist, please explicitly state this and provide reasons. If any information is withheld, please specify the grounds under the Official Information Act 1982. I also request this response be published online at www.health.govt.nz with personal identifiers removed.

Yours faithfully,

SPENCER JONES