Methodology of demographic assessment in the November 2024 NZBORA analysis

Alisha Riley made this Official Information request to Ministry of Health

Currently waiting for a response from Ministry of Health, they must respond promptly and normally no later than (details and exceptions).

From: Alisha Riley

Kia ora,

I am writing to request some information under the Official Information Act to help me better understand the methodology used to assess safety in the "Community water fluoridation: New Zealand Bill of Rights Act analysis" (Appendix 1, dated November 2024).

On page 13 of this November 2024 analysis, the document assesses the safety of the mandate, stating that "The Oral Health Survey indicated that fluorosis prevalence is not increasing" and concludes that the policy "does not give rise to significant health risks." To ensure I am reviewing the correct data methodology that informed this specific conclusion, could you please provide the following:

1. Clarification of Source Data:
Please explicitly confirm the specific year and publication title of the "Oral Health Survey" that the Director-General is referencing in the above quote on page 13 to conclude that fluorosis prevalence is not increasing. (e.g., Is this referencing the 2009 New Zealand Oral Health Survey, or a different dataset?)

2. Internal Briefings Provided TO the Director-General:
Assuming the reference points to the 2009 Oral Health Survey (where clinical decay was surveyed from ages 2 to 75+, but fluorosis data was restricted solely to ages 8–30), please provide any internal memo or working document submitted to the Director-General prior to the finalisation of the November 2024 analysis that explains how the safety of the mandate was assessed for children aged 0–7 and adults aged 31+.

3. Location within the Published November 2024 NZBORA Analysis:
I am unable to locate where this specific demographic data exclusion (the absence of fluorosis data for the 0–7 and 31+ cohorts) is disclosed to the public. If this methodological limitation is recorded within the final published November 2024 analysis, please provide the exact page and paragraph numbers where it can be found.

4. Confirmation of Omission:
If the exclusion of the 0–7 and 31+ demographics from the primary fluorosis safety data was neither briefed internally to the Director-General (as per Question 2) nor recorded in the final published November 2024 NZBORA analysis (as per Question 3), please explicitly confirm this omission.

5. The Longitudinal Safety Data (The "Not Increasing" Metric):
To establish that a prevalence is "not increasing" requires a comparative longitudinal assessment between at least two points in time. Please provide the specific subsequent clinical survey, dataset, or contemporary surveillance reporting from between 2010 and November 2024 that the Director-General compared against the 2009 baseline to legally conclude on page 13 that the prevalence "is not increasing." If no such contemporary comparative dataset was provided to the Director-General, please explicitly confirm this omission.

Thank you for your time and help in clarifying this.
Alisha Riley

Link to this

From: OIA Requests


Attachment image.png
25K Download


Kia ora Alisha,

  

Thank you for your request under the Official Information Act 1982 (the
Act), received by the Ministry of Health - Manatû Hauora on 21 March 2026.
You requested:

 

“Information under the Official Information Act to help me better
understand the methodology used to assess safety in the "Community water
fluoridation: New Zealand Bill of Rights Act analysis" (Appendix 1, dated
November 2024).

On page 13 of this November 2024 analysis, the document assesses the
safety of the mandate, stating that "The Oral Health Survey indicated that
fluorosis prevalence is not increasing" and concludes that the policy
"does not give rise to significant health risks." To ensure I am reviewing
the correct data methodology that informed this specific conclusion, could
you please provide the following:

1. Clarification of Source Data:
Please explicitly confirm the specific year and publication title of the
"Oral Health Survey" that the Director-General is referencing in the above
quote on page 13 to conclude that fluorosis prevalence is not increasing.
(e.g., Is this referencing the 2009 New Zealand Oral Health Survey, or a
different dataset?)

2. Internal Briefings Provided TO the Director-General:
Assuming the reference points to the 2009 Oral Health Survey (where
clinical decay was surveyed from ages 2 to 75+, but fluorosis data was
restricted solely to ages 8–30), please provide any  internal memo or
working document submitted to the Director-General prior to the
finalisation of the November 2024 analysis that explains how the safety of
the mandate was assessed for children aged 0–7 and adults aged 31+.

3. Location within the Published November 2024 NZBORA Analysis:
I am unable to locate where this specific demographic data exclusion (the
absence of fluorosis data for the 0–7 and 31+ cohorts) is disclosed to the
public. If this methodological limitation is recorded within the final
published November 2024 analysis, please provide the exact page and
paragraph numbers where it can be found.

4. Confirmation of Omission:
If the exclusion of the 0–7 and 31+ demographics from the primary
fluorosis safety data was neither briefed internally to the
Director-General (as per Question 2) nor recorded in the final published
November 2024 NZBORA analysis (as per Question 3), please explicitly
confirm this omission.

5. The Longitudinal Safety Data (The "Not Increasing" Metric):
To establish that a prevalence is "not increasing" requires a comparative
longitudinal assessment between at least two points in time. Please
provide the specific subsequent clinical survey, dataset, or contemporary
surveillance reporting from between 2010 and November 2024 that the
Director-General compared against the 2009 baseline to legally conclude on
page 13 that the prevalence "is not increasing." If no such contemporary
comparative dataset was provided to the Director-General, please
explicitly confirm this omission.”
 

The reference number for your request is H2026080414. We will endeavour to
respond to your request as soon as possible and in any event no later than
21 April 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. 

 

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.

 

 

Ngâ mihi, 
 
OIA Services Team

Ministry of Health | Manatû Hauora

 

M[3]inistry of Health information releases

 

 

show quoted sections

References

Visible links
1. mailto:[email address]
mailto:[email address]
2. mailto:[email address]
mailto:[email address]
3. https://www.health.govt.nz/about-ministr...
https://www.health.govt.nz/about-ministr...

Link to this

Things to do with this request

Anyone:
Ministry of Health only: