Kia ora Spencer,

 

Thank you for your request under the Official Information Act 1982 (the
Act), received by the Ministry of Health on 4 June 2025. You requested:

 

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://aus01.safelinks.protection.outlo...),
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
([http://]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.

 

The reference number for your request is H2025068090. As required under
the Act, the Ministry will endeavour to respond to your request no later
than 20 working days after the day your request was received:
http://www.ombudsman.parliament.nz/.   

 

If you have any queries related to this request, please do not hesitate to
get in touch ([1][email address]).

 

 

Ngā mihi 
 
OIA Services Team 
[2]Ministry of Health information releases 

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