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Evidentiary Basis for the 2017 Fluoride UL Update

Alisha Riley made this Official Information request to Health New Zealand

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From: Alisha Riley

Dear Health New Zealand,

Under the Official Information Act 1982, I request the specific evidentiary and toxicological foundation used to justify the 2017 update to the Nutrient Reference Values (NRVs), specifically the decision to increase the Tolerable Upper Intake Level (UL) of fluoride for children aged 0–8 to 0.20 mg/kg bw/day.

Please provide the following official information:

1. Skeletal Retention & Demographic Modeling:
Please provide all internal risk assessments, toxicological modeling, or equity evaluations conducted prior to the 2017 UL increase that analysed chronic bioaccumulation risks for exclusively formula-fed infants. Please specify if these assessments explicitly accounted for the disproportionate cumulative exposure on ethnic cohorts with statistically higher formula-feeding rates (specifically Māori and Pacific infants).

2. The Under-8 Evidentiary Baseline:
Given that the 2009 New Zealand Oral Health Survey excluded children under 8 from fluorosis diagnostic reporting, please provide the specific contemporary domestic clinical datasets or epidemiological studies relied upon in 2017 to conclude that doubling the UL would not inflict severe structural harm (hypomineralization) on this unmonitored demographic.

3. Safety Benchmarks and Margins:
Please provide the internal policy documents or scientific guidelines justifying the use of "severe dental fluorosis" as the primary or sole biological benchmark for defining the UL, including documentation explaining why standard toxicological safety margins (e.g., 10x or 100x below the LOAEL) were not applied to the 2017 update.

4. Internal Communications:
Please provide all internal memoranda, meeting minutes, and communications between policy/science teams, the NHMRC, and Crown Law between January 2016 and December 2017 referencing the fluoride UL/NRV update. I specifically request any communications within this timeframe that concurrently reference the pending New Health New Zealand Inc v South Taranaki District Council litigation.

Thank you for your time.

Alisha Riley

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From: hnzOIA

Tçnâ koe,

 

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Ngâ mihi,
Health NZ | Te Whatu Ora

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