Dear Ministry of Health,

This is an urgent request under section 12(3) of the Official Information Act. I set out below the information I am seeking, and then I state my reasons for asking the Ministry to make a decision on my request urgently.

In 2021 the Select Committee consideration stated:

'We understand that the total costs for the capital component of fluoridation are estimated at $61 million. Some funding will be available to support local authorities to fluoridate their water supplies—$8.3 million in 2021/22 and $3 million a year in subsequent years. The funding will cover some, but not all, of the capital costs.'

[a] Please supply total funding directed to support local drinking water suppliers fluoridate local water, and details of which councils received a particular funding injection.
- 2021/2022
- 2022/2023

and

[b] current proposed budget for 2023/2024 by council and in total.

[c] It is unclear from appropriations budgets how financial costs for fluoridation are categorised. Please show/advise how financial ledgers categorise Ministry costs for fluoridation.

[d] It is understood that fluoridation does not completely prevent caries but that there may be an uncertain marginal benefit to the DMFT (HNZ00030962). Please advise the budgeted costs savings to treatment of dental caries for the public health sector from this initiative in the 0-7 (or - 0-10) age group.

[e] Please forward all advice and analysis sent to the Director General and/or the Minister of Health reviewing or discussing any draft version of the NTP Monograph on the State of the Science Concerning Fluoride Exposure and Neurodevelopmental and Cognitive Health Effects: A Systematic Review. US National Toxicology Program - from March 2021 onwards.
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-> My reason for seeking the information urgently is to enable the public to understand the cost-benefit ratio of fluoridation of drinking water supplies at a time when the Director General has imposed deadlines, such as the demand that Rotorua Lakes implement water fluoridation by April 2024.
https://www.health.govt.nz/about-ministr...

Ministry of Health and Select Committee processes may be insufficiently robust - deficient - at judging risk and harm, when there is a claimed marginal benefit, but there is commensurately a neurodevelopmental risk, particularly in the first seven years. This concerns the injection of a known neurotoxin, which is not a nutrient (EFSA 2019) into water supplies.

1. Local water supplies face a cost of $200,000 for failure to implement fluoridation by the allocated time and $10,000 per day thereafter. We understand that Councillors will be under immense pressure to submit to the directive, even if they are concerned that in doing so they may fail to protect health.

2. The US National Toxicology Program (September 2022) is the most comprehensive document on neurodevelopmental risk to be released globally. The NTP document reveals that the scientists will not state categorically that the claimed safe (or 'optimum') level of 0.7 gm/l is safe. The reviews by the Office of the Prime Minister's Chief Science Advisor did not review the available data to any comparable extent as the NTP document.

3. In such an uncertain environment the Ministry of Health has not set aside funding to conduct studies at this level to shed light on this situation, despite fluoridation commencing in Auckland and Wellington in the 1960s. Risk to the brain has been understood since this time and the Ministry of Health has capacity to require that independent research is undertaken locally (including meta-analyses of the evidence on cognitive risk and risk to IQ) yet have not done so.

4. The EPA has not carried out a risk assessment, as would normally occur for a substance that is exposed to the children at all life stages, as well as being released into water bodies. Water suppliers and Taumata Arowai remain unclear on the fluoride formulation that will be added.

5. Despite a 2018 paper being released that looked at present urine levels in the population, and which showed that children's levels are higher than adults, this document and any analysis of total fluoride exposure has not been undertaken, yet 'safe' in the Water Services Act s7ii. requires that all exposures are considered 'other causes together with the consumption or use of drinking water.

6. All public comments to the 2021 Inquiry discussing the potential risk were ignored and dismissed by the Select Committee as being out of scope and covered by the 2017 Select Committee. ' However, in our report we have not commented on submissions that were supportive of, or opposed to, fluoridation generally, but that did not provide specific feedback on changes to the bill proposed by the SOP.' (page 3)
https://selectcommittees.parliament.nz/v...

However, the earlier 2017 consultation did not concern the transference of powers to the Director General. I.e., the removal of local decision-making powers. So, issues of risk and benefit had potential to be addressed at the local level.

7. The 2017 Select Committee process did not address public concerns of safety either:
'We acknowledge that the majority of submitters expressed concern about the safety and efficacy of water fluoridation. Medical and dental associations and representative bodies, and most doctors and dentists, spoke in support of fluoridating water. However, we consider these issues beyond the subject matter of the bill, which is about giving DHBs the power to make a direction about fluoridation.' (page 208-3)
https://selectcommittees.parliament.nz/v...

Yet the public, including local councils have a right to understand both the financial cost and benefit, and the extent to which risk at levels of exposure have been considered by officials - particularly with drinking water suppliers facing extensive fines if they do not comply with the D-G's request.

This public interest is explicitly recognised in section 4(a)(i) of the OIA, which says that the purpose of that Act is ’to increase progressively the availability of official information to the people of New Zealand in order to enable their more effective participation in the making and administration of laws and policies.'

I look forward to receiving the Ministry’s decision and the information sought as soon as reasonably practicable and certainly no later than 20 working days after receipt of this request due to the pressure exerted by the Director General of Health on local authorities to commence fluoridation.

Thank you.

Yours faithfully,

J Bruning