Kia ora Spencer

 

 

Thank you for your request under the Official Information Act 1982 (the
Act) on 11 December 2025:

 

1. End-to-end supply-chain documentation (import → storage → dosing)

 

Please provide all information (held by MoH or held on MoH’s behalf)
regarding the supply chain for fluoridation chemicals used in New Zealand,
including:

 

1.1 Identity of chemicals and suppliers

 

a. The exact chemical substances currently used for water fluoridation
(e.g., hydrofluorosilicic acid (HFA), sodium fluorosilicate, sodium
fluoride).

b. All suppliers, importers, manufacturers, or distributors contracted by
councils or their agents for these chemicals since 2018.

c. Any Ministry documents, contracts, audits, specifications, or
product-safety assurances provided by suppliers to MoH, ESR, Taumata
Arowai, or any public authority.

 

1.2 Chain-of-custody and verification

 

a. Any documents describing how chain-of-custody for fluoridation
chemicals is maintained from point of import to delivery at treatment
plants.

b. Any requirements, standards, or expectations issued by MoH (or Taumata
Arowai, ESR, or predecessor agencies) regarding chain-of-custody, batch
testing, or verification of purity.

 

⸻

 

2. Chemical composition, contaminants, and testing

 

2.1 Certificates of Analysis (CoAs) and contaminant testing

 

a. All Certificates of Analysis (CoAs) provided to the Ministry (or to
ESR, Taumata Arowai, or councils but copied to MoH) for fluoride products
used in New Zealand since 2018.

b. Any internal reports or assessments regarding contaminants detected in
fluoride chemicals, including but not limited to:

• arsenic, lead, cadmium, mercury

• radionuclides

• polonium

• silica by-products

• industrial manufacturing residues.

 

2.2 Standards for contaminants

 

a. Any Ministry-held documents specifying allowable levels of contaminants
in fluoridation chemicals.

b. Any correspondence between MoH and suppliers or councils regarding
non-conformance or marginal results.

 

If any contaminants exceed WHO or NZ guideline values, please provide the
Ministry’s risk assessment and decision-making documents.

 

⸻

 

3. Regulatory responsibility, oversight failures, and internal knowledge

 

3.1 Who is responsible?

 

Please provide documents clarifying which entity (MoH, councils, ESR,
Taumata Arowai, or suppliers) is legally responsible for:

 

a. verifying chemical purity;

b. approving suppliers;

c. ensuring no harmful contaminants exceed safety thresholds; d. ensuring
chemicals comply with public-health requirements; e. ensuring that
fluoridation substances meet the statutory test of being “safe, effective,
and demonstrably justified” under NZBORA s11 and s5.

 

If no such documents exist, please confirm this explicitly.

 

3.2 Internal risk discussions

 

Please provide any internal Ministry briefings, emails, risk assessments,
or advice (2018–2025) relating to:

 

a. risks associated with contaminants in fluoridation chemicals; b.
supply-chain vulnerabilities; c. regulatory oversight gaps; d. concerns
raised by councils or water operators about product quality; e. the
implications of non-oral exposure pathways (inhalation, dermal absorption,
bathing/showering, dialysis).

 

If no assessments exist on non-oral exposures, please confirm this
explicitly.

 

⸻

 

4. NZ-specific evidence base for safety and medical justification

 

Please provide any documents (internal or external) that contain New
Zealand–specific evidence relating to:

 

a. neurotoxicity research (including any reference to NTP evaluations); b.
endocrine, thyroid, renal, or developmental risks; c. sensitive-population
risks (pregnant women, infants, kidney disease, thyroid disorders, at-home
medical equipment); d. comparison between actual NZ population exposure
versus guideline calculations.

 

If the Ministry holds no NZ-specific evidence for any category above,
please state this clearly.

 

⸻

 

5. Post-High-Court judgment work

 

Following the High Court judgment (New Health / BORA), please provide:

 

a. Any discussions, legal advice, internal reviews, or policy work about
how to ensure fluoridation decisions remain demonstrably justified.

b. Any analysis regarding how supply-chain transparency impacts the
rights-based justification process.

c. Any risk assessments commissioned or conducted regarding the scientific
uncertainty or contested evidence around neurodevelopment.

 

⸻

 

6. Communications with councils and suppliers (2018–2025)

 

All communications (emails, memos, letters, briefings) between the
Ministry and:

                •              territorial authorities,

                •              water operators,

                •              ESR,

                •              Taumata Arowai,

                •              fluoridation chemical suppliers,

 

relating to:

 

a. chemical supply issues;

b. purity concerns;

c. import shortages;

d. contaminant warnings;

e. questions about product safety.

 

⸻

 

7. Please do NOT transfer without justification

 

Given repeated transfers in other OIAs, please:

                •              Provide a written s14 analysis before any
transfer.

                •              Confirm which parts you consider “more
closely connected with the functions” of another agency.

                •              Provide partial answers for any elements
MoH can answer.

 

This request explicitly seeks information held by the Ministry and held on
the Ministry’s behalf.

 

⸻

 

Format requested

 

Please supply all information in:

                •              searchable PDF,

                •              original file formats where possible,

                •              and with an index of documents if exceeding
30 pages.

 

⸻

 

Public interest

 

This request raises substantial public-interest issues, including:

                •              medical-treatment rights under NZBORA

                •              environmental contamination concerns

                •              transparency in government-mandated mass
interventions

                •              safety of vulnerable populations

                •              scientifically contested evidence

                •              public-health accountability.

 

Any withholding under ss 9 or 18 must consider the overriding public
interest in disclosure.

 

We will endeavour to respond to your request as soon as possible and in
any event no later than 30 January 2026, 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. 

 

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------------------- Original Message -------------------
From: SPENCER JONES <[FOI #33235 email]>; 
Received: Thu Dec 11 2025 21:26:27 GMT+1300 (New Zealand Daylight Time)
To: OIA Requests <[email address]>; OIA <[email address]>; 
Subject: Official Information request - Fluoride Supply Chain – End-to-End
Traceability, Contaminant Testing, and Regulatory Oversight

Dear Ministry of Health,

I request the following information relating to the fluoride compounds
used for community water fluoridation in New Zealand, with a focus on
end-to-end supply-chain integrity, contaminants, regulatory oversight, and
public-health accountability.

This request is made in light of:
        •       multiple recent OIA responses showing fragmented
responsibility between MoH, councils, ESR, contractors and suppliers;
        •       repeated statements that key information “is not held” by
any agency; and
        •       the High Court’s findings that fluoridation engages the
right to refuse medical treatment and therefore must be demonstrably
justified.

Because this is a national, central-government public-health directive, I
ask that the Ministry of Health refrain from automatically transferring
questions to councils unless a legal analysis under ss 12, 13, 14 and 18A
of the OIA is provided. Please treat the Ministry as the lead agency for
responses unless a transfer is strictly required.

⸻

1. End-to-end supply-chain documentation (import → storage → dosing)

Please provide all information (held by MoH or held on MoH’s behalf)
regarding the supply chain for fluoridation chemicals used in New Zealand,
including:

1.1 Identity of chemicals and suppliers

a. The exact chemical substances currently used for water fluoridation
(e.g., hydrofluorosilicic acid (HFA), sodium fluorosilicate, sodium
fluoride).
b. All suppliers, importers, manufacturers, or distributors contracted by
councils or their agents for these chemicals since 2018.
c. Any Ministry documents, contracts, audits, specifications, or
product-safety assurances provided by suppliers to MoH, ESR, Taumata
Arowai, or any public authority.

1.2 Chain-of-custody and verification

a. Any documents describing how chain-of-custody for fluoridation
chemicals is maintained from point of import to delivery at treatment
plants.
b. Any requirements, standards, or expectations issued by MoH (or Taumata
Arowai, ESR, or predecessor agencies) regarding chain-of-custody, batch
testing, or verification of purity.

⸻

2. Chemical composition, contaminants, and testing

2.1 Certificates of Analysis (CoAs) and contaminant testing

a. All Certificates of Analysis (CoAs) provided to the Ministry (or to
ESR, Taumata Arowai, or councils but copied to MoH) for fluoride products
used in New Zealand since 2018.
b. Any internal reports or assessments regarding contaminants detected in
fluoride chemicals, including but not limited to:
• arsenic, lead, cadmium, mercury
• radionuclides
• polonium
• silica by-products
• industrial manufacturing residues.

2.2 Standards for contaminants

a. Any Ministry-held documents specifying allowable levels of contaminants
in fluoridation chemicals.
b. Any correspondence between MoH and suppliers or councils regarding
non-conformance or marginal results.

If any contaminants exceed WHO or NZ guideline values, please provide the
Ministry’s risk assessment and decision-making documents.

⸻

3. Regulatory responsibility, oversight failures, and internal knowledge

3.1 Who is responsible?

Please provide documents clarifying which entity (MoH, councils, ESR,
Taumata Arowai, or suppliers) is legally responsible for:

a. verifying chemical purity;
b. approving suppliers;
c. ensuring no harmful contaminants exceed safety thresholds;
d. ensuring chemicals comply with public-health requirements;
e. ensuring that fluoridation substances meet the statutory test of being
“safe, effective, and demonstrably justified” under NZBORA s11 and s5.

If no such documents exist, please confirm this explicitly.

3.2 Internal risk discussions

Please provide any internal Ministry briefings, emails, risk assessments,
or advice (2018–2025) relating to:

a. risks associated with contaminants in fluoridation chemicals;
b. supply-chain vulnerabilities;
c. regulatory oversight gaps;
d. concerns raised by councils or water operators about product quality;
e. the implications of non-oral exposure pathways (inhalation, dermal
absorption, bathing/showering, dialysis).

If no assessments exist on non-oral exposures, please confirm this
explicitly.

⸻

4. NZ-specific evidence base for safety and medical justification

Please provide any documents (internal or external) that contain New
Zealand–specific evidence relating to:

a. neurotoxicity research (including any reference to NTP evaluations);
b. endocrine, thyroid, renal, or developmental risks;
c. sensitive-population risks (pregnant women, infants, kidney disease,
thyroid disorders, at-home medical equipment);
d. comparison between actual NZ population exposure versus guideline
calculations.

If the Ministry holds no NZ-specific evidence for any category above,
please state this clearly.

⸻

5. Post-High-Court judgment work

Following the High Court judgment (New Health / BORA), please provide:

a. Any discussions, legal advice, internal reviews, or policy work about
how to ensure fluoridation decisions remain demonstrably justified.
b. Any analysis regarding how supply-chain transparency impacts the
rights-based justification process.
c. Any risk assessments commissioned or conducted regarding the scientific
uncertainty or contested evidence around neurodevelopment.

⸻

6. Communications with councils and suppliers (2018–2025)

All communications (emails, memos, letters, briefings) between the
Ministry and:
        •       territorial authorities,
        •       water operators,
        •       ESR,
        •       Taumata Arowai,
        •       fluoridation chemical suppliers,

relating to:

a. chemical supply issues;
b. purity concerns;
c. import shortages;
d. contaminant warnings;
e. questions about product safety.

⸻

7. Please do NOT transfer without justification

Given repeated transfers in other OIAs, please:
        •       Provide a written s14 analysis before any transfer.
        •       Confirm which parts you consider “more closely connected
with the functions” of another agency.
        •       Provide partial answers for any elements MoH can answer.

This request explicitly seeks information held by the Ministry and held on
the Ministry’s behalf.

⸻

Format requested

Please supply all information in:
        •       searchable PDF,
        •       original file formats where possible,
        •       and with an index of documents if exceeding 30 pages.

⸻

Public interest

This request raises substantial public-interest issues, including:
        •       medical-treatment rights under NZBORA
        •       environmental contamination concerns
        •       transparency in government-mandated mass interventions
        •       safety of vulnerable populations
        •       scientifically contested evidence
        •       public-health accountability.

Any withholding under ss 9 or 18 must consider the overriding public
interest in disclosure.

⸻

Closing sentence

I am happy to refine or narrow this request if genuinely required under
s13 of the OIA, but I ask that any such request explain precisely which
clause of the OIA is engaged and why the information cannot be provided in
its current form.

Kind regards,
Spencer Jones

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