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 25 March 2026.
You requested:

 

“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 Mâori 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.”
 

The reference number for your request is H2026080565. We will endeavour to
respond to your request as soon as possible and in any event no later than
24 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

 

 

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References

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