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
From: hnzOIA
Tçnâ koe,
Thank you for your email.
Under the Official Information Act (OIA), agencies are required to respond
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We appreciate your understanding and patience during this time.
Ngâ mihi,
Health NZ | Te Whatu Ora
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From: hnzOIA
Kia ora Alisha,
Thank you for your request of 25 March 2026 for the following information:
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.
Your request asks for information which is more closely aligned with the
functions of the Ministry of Health.
For this reason, Health New Zealand has decided to transfer your request
in full to under section 14(b)(ii) of the Official Information Act (OIA).
You can expect a response from the Ministry of Health in due course.
Under section 28(3) of the OIA you have the right to ask the Ombudsman
to review any decisions made under this request.
The Ombudsman may be contacted
by email at: [1][email address] or by calling 0800 802 602.
If you have any queries related to this request, please do not hesitate to
get in touch.
Ngā mihi
Michael
Government Services (OIA)
[2][email address]
Health New Zealand | Te Whatu Ora
Statement of confidentiality: This email message and any accompanying
attachments may contain information that is IN-CONFIDENCE and subject to
legal privilege. If you are not the intended recipient, do not read, use,
disseminate, distribute or copy this message or attachments. If you have
received this message in error, please notify the sender immediately and
delete this message
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2. mailto:[email address]
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