This is an HTML version of an attachment to the Official Information request 'Fluoride Supply Chain Information'.









12 December 2025
Sharna Sovereign
[FYI request #32674 email]
Kia ora Sharna,
Local Government Official Information Request – Fluoride Supply Chain
I refer to your official information request received by Ministry of Health on 26 October 2025
and partially transferred to Western Bay of Plenty District Council (Council) on 5 December
2025, where you have requested information pertaining to the fluoride supply chain.
The answers to your questions which Council can answer are set out below:
Question 3: Provide the full chemical composition, including chemical names, chemical
formulae, and concentrations of all fluoride compounds added to the public water supply.
Council does not hold detailed manufacturing-level chemical composition, formulation
records, or production chemistry for fluoride compounds.
The only chemical information held by Council are the Safety Data Sheets (SDS) provided
by the approved chemical supplier for the fluoridation upgrade project (see attached).
These SDS documents describe:

the chemical name,

the CAS number,

the general composition range,

safety classifications,

handling and storage requirements.
Council does not hold laboratory analyses, raw manufacturing data, or concentration
formulation beyond what is included in the SDS.
Question 5: Provide details of any chemical by-products, waste, or residues generated
during production, storage, transport, or dosing, including their environmental and human
health impacts.
Council does not hold information relating to:

manufacturing by-products,

upstream waste materials,

production-related residues, or
A7068769



health impact assessments.
These matters sit with:

chemical manufacturers,

Worksafe (for hazardous substances), and

the Ministry of Health or Taumata Arowai (for public health oversight).
Council only holds information relating to on-site storage and dosing at the water
treatment plant. This is limited to SDS sheets and operational procedures that apply to
storage and dosing at the facility. These documents do not address manufacturing waste
streams or chemical by-products.
Question 10 (transferred from MoH): Include all applicable laws, licenses, and regulatory
frameworks under which these transporters operate, particularly regarding hazardous
substances.
Council does not hold licences, approvals, or regulatory documents for companies
transporting fluoride chemicals. Transport of hazardous substances is regulated nationally
under:

the Land Transport Rule: Dangerous Goods 2005,

HSNO and EPA requirements,

Worksafe hazardous substances regulations.
These documents are not held by Council. For authoritative information you may wish to
contact Waka Kotahi or WorkSafe New Zealand.
Question 15: Include all corporate affiliations, financial interests, and advisory bodies that
influence decisions regarding fluoride.
Council does not hold information on corporate affiliations or financial interests of any
external organisations influencing national fluoridation policy. Council’s role is limited to
implementing fluoridation as required under the Health Act and following direction from
the Director-General of Health.
Internally, any Council staff involved in procurement or project decisions are required to
complete conflict of interest declarations, which are held for internal administrative
purposes. These records do not relate to national fluoride policy and do not contain the
types of corporate or financial information sought in your request. Council holds no other
information relevant to this question.
Question 16: Provide copies of all risk assessments, environmental impact statements,
monitoring reports, and internal or external evaluations regarding fluoride safety, dosing,
and public health.
Council does not hold public health or toxicological risk assessments relating specifically
to fluoride safety. These assessments are carried out by the Ministry of Health and
Taumata Arowai.



The only risk-related information held by Council relates to:

the construction project risk register for the fluoridation and WTP upgrade works,

operational risk assessments for handling hazardous substances at the treatment
plant (e.g. storage, dosing equipment, spill response), and

Taumata Arowai compliance monitoring for the broader drinking water supply.
These documents address operational hazards and water treatment plant safety, not the
health effects of fluoride itself. Council does not hold environmental impact statements
relating to fluoride.
Question 18: Disclose any incidents, complaints, or breaches relating to fluoride chemical
safety, handling, or dosing.
Council has reviewed its incident and complaint registers. At the time of writing, Council
holds no records of incidents, complaints, or breaches relating to fluoride chemicals,
handling, or dosing within its water treatment operations.
Matters relating to workplace safety incidents involving hazardous substances are
overseen by WorkSafe New Zealand, and any such notifications would be held by them.
Question 20: Include international case law, peer-reviewed studies, legal decisions, or
environmental assessments showing health or environmental risks, chemical by-
products, or public health outcomes linked to fluoride.
Council does not hold this information. International case law, scientific research, and
global policy analyses are not part of Council’s operational functions and are not held in
Council’s records. These matters fall within the responsibility of:

the Ministry of Health,

Taumata Arowai, and

international health agencies such as WHO.
Council therefore refuses this part of the request under section 17(g) of LGOIMA, as the
information is not held by the Council.
You have the right to seek an investigation and review by the Ombudsman of this decision.
Information about how to make a complaint is available at
www.ombudsman.parliament.nz or freephone 0800 802 602.
Ngā mihi
Brad Singh
General Manager
Infrastructure Services