FLUORIDATED DRINKING WATER

The potential cognitive and IQ risk from exposure to fluoridated drinking water has not been sufficiently impartially assessed by New Zealand government agencies. What does this mean?

Fluoride is a hazardous substance. Good practice should require that the lowest level of safe exposure (the benchmark dose) is defined, and then a margin of error (uncertainty factor) must be built in to allow for biological difference. This has not happened for this hazardous substance.
The lowest safe exposure is based on total dietary exposures, per day. Toothpaste ingestion plus fluoridated water ingestion.
No risk assessment has occurred in New Zealand to assess the combined risk of daily exposures of fluoridated drinking water and fluoride in toothpaste for children under age 10.
Instead of risk assessment, politically timed 'proxy' position papers have been released. They do not conform to good regulatory science. These papers do not contain methodologies to show that the collection and evaluation of data has been impartially undertaken.
The NZ EPA have completely stepped away from risk assessment of human health or environmental risk. Remember - fluoridated drinking water is emitted in waste streams from local councils, wherever municipal water is fluoridated.
Ironically, NZ would by convention turn to US EPA decisions. Yet the US EPA were recently found to have failed to follow their own risk assessment guidelines, in a recent court case discussed below.
The Health Minister continues to say it's safe even though no risk assessment ever occurred.

Conclusion: New Zealand health and environmental agencies have (demonstrably) stepped away from their duties to protect the health of people and their environment.

New Zealand's Ministry of Health are just a court case away from being found out! The big question is, will the judges make an effort to recognise that good practice and regulatory convention have been set aside? Will the courts be able to take into account this deviation from good practice (i.e. ignoring risk assessment which can identify the lowest level of safe exposure of a hazardous substance) the current goings on are neither fair nor just?

PSGR, FluorideFree and many others have worked to highlight to scientists, doctors and the general public that there are too many ‘blind spots’ and that benefit (of a potential marginal alteration in caries outcome) may not outweigh risk (in early childhood, to cognition and IQ).

PSGRNZ's Fluoride Timeline (updated October 2024 ) helps concerned institutions and the public to understand how fluoride is regulated, and how the scientific evidence on the neurodevelopmental toxicity has been presented in New Zealand, and understood by other prominent institutions.

On September 24, 2024 U.S. Federal Judge Edward Chen ruled that the US EPA can no longer ignore the risk of fluoride to children's IQ, and that it must take regulatory action. In making his decision, the judge applied the standard risk assessment framework to fluoride.

Judge Chen identified a preponderance of risk. Chen noted that studies which did not show risk do not negate the high proportion of studies which do show risk. Chen emphasised the risk from a total dose.

'Background exposure sources include ‘naturally occurring fluoride in food and beverage, fluoride in food and beverage made with fluoridated water, and other products, like toothpaste.’

Judge Chen determined that weight of the scientific evidence regarding fluoride’s association with reduced IQ was sufficient to proceed to the dose-response assessment, something which has not been undertaken in New Zealand. A benchmark dose was then identified.

Regulatory risk assessment requires that there is an appropriate margin between an exposure and when the risk becomes hazardous. This is referred to as the benchmark margin of exposure, and installs a safe margin. 'The BMD/BMC is the dose of a substance that produces a “predetermined change in the response rate of an adverse effect.”' (Chen 41/80) By convention, an uncertainty factor of 10 is often a default to allow for human variability. While the NZ EPA’s Methodology does not discuss this, the ‘uncertainty factor concept is integrated into health risk assessments for all aspects of public health practice’. Exposures may be calculated from urinary fluoride levels. The level at which a chemical becomes hazardous is referred to as the point of departure, or hazard level.

Judge Chen at 5/80: The pooled benchmark dose analysis concluded that a 1-point drop in IQ of a child is to be expected for each 0.28 mg/L of fluoride in a pregnant mother’s urine. This is highly concerning, because maternal urinary fluoride levels for pregnant mothers in the United States range from 0.8 mg/L at the median and 1.89 mg/L depending upon the degree of exposure. Not only is there an insufficient margin between the hazard level and these exposure levels, for many, the exposure levels exceed the hazard level of 0.28 mg/L.

Work undertaken by Professor Philippe Grandjean and colleagues was central to the judge's decision around a benchmark dose (See discussion [67] 43/80.) In 2023 PSGR interviewed Professor Grandjean (listen on Spotify or Substack) on the scientific work and the benchmark dose calculations which had recently enabled Grandjean and colleagues to arrive at this finding.

Evidence published in New Zealand in 2018 demonstrates that young children have higher urinary fluoride levels than adults.

In August 2024 the U.S. National Toxicology Program published their Monograph on the State of the Science Concerning Fluoride Exposure and Neurodevelopment and Cognition: A Systematic Review. NTP Monograph 08. National Toxicology Program Public Health Service U.S. Department of Health and Human Services.

This review finds (moderate confidence) that higher estimated fluoride exposures (... drinking water fluoride concentrations that exceed WHO Guidelines for Drinking-water Quality 1.5mg/L of fluoride) are consistently associated with lower IQ in children
Associations between lower total fluoride exposure [e.g., as in approximations of exposure such as drinking water fluoride concentrations that were lower than the WHO Guidelines for Drinking-water Quality of 1.5 mg/L of fluoride (WHO 2017)] and children’s IQ remain unclear.
However, because people receive fluoride from multiple sources (not just drinking water), individuals living in areas with optimally fluoridated water can have total fluoride exposures higher than the concentration of their drinking water.
Additional exposures to fluoride from other sources increase total F exposure. Moderate confidence conclusions may be relevant to people living in optimally fluoridated areas of the US depending on the extent of their additional exposures to F from sources other than drinking water.
Seven meta-analyses found statistically significant inverse associations between fluoride assessment measures and children’s IQ. Many studies lacked the information necessary to evaluate study quality, and most used group-level estimates of fluoride exposure.
Although the use of various effect measures and methods makes comparison of the magnitude of the associations difficult across meta-analyses, there is a consistent reporting of inverse associations between fluoride exposure assessment measures and children’s IQ.
NTP Review (2024) concludes with moderate confidence: higher estimated fluoride exposures consistently associated with lower IQ in children. Studies identified in the updated literature search had similar study designs and patterns of findings.
Concludes: Recent meta-analyses of the inverse association between children’s IQ and fluoride exposures provide additional evidence of a dose-response relationship. However, uncertainty remains in findings at the lower fluoride exposure range.
Concludes: As this body of evidence matures, consideration for upgrading the moderate confidence conclusion to high confidence based on additional evidence of dose-response relationships at lower fluoride levels may be warranted.

Findings that demonstrate vague efficacy, are also being released. A recent Cochrane review that was released in October 2024, where the sole risk denominator was fluorosis (i.e. where cognitive neurodevelopmental risk was not considered as a risk factor) of 157 studies concluded that:

‘There is insufficient evidence to determine the effect of cessation of CWF on caries and whether water fluoridation results in a change in disparities in caries according to socioeconomic status.’

Iheozor-Ejiofor Z, Walsh T, Lewis SR, Riley P, Boyers D, Clarkson JE, Worthington HV, Glenny A-M, O'Malley L. Water fluoridation for the prevention of dental caries. Cochrane Database of Systematic Reviews 2024, Issue 10. Art. No.: CD010856. DOI: 10.1002/14651858.CD010856.pub3. Accessed 15 October 2024. 157 studies reviewed. (WF= Water fluoridation)

Water fluoridation initiation (21 studies): Low certainty evidence WF may lead to a slightly greater change over time in the proportion of caries‐free children with primary dentition.
Water fluoridation cessation (1 study): low‐certainty evidence. Could not be determined if cessation affected levels of decay, and of missing & filled teeth.
Association of water fluoridation with dental fluorosis (135 studies): With a fluoride level of 0.7 parts per million (ppm), approximately 12% of participants had fluorosis of aesthetic concern, and approximately 40% had fluorosis of any level. Because of very low‐certainty evidence, we were unsure of other adverse effects (including skeletal fluorosis, bone fractures and skeletal maturity).

THE DIRECTOR-GENERAL OF HEALTH - PREVARICATING ON FLUORIDE RISK?

Many New Zealand councils had been directed by the Director-General of Health to fluoridate their water by a nominated date.

Fluoridation is a limit on the right in s 11 of the New Zealand Bill of Rights Act 1990 (BORA) to refuse medical treatment. A recent judgement permitted the Director-General of Health to continue to order to fluoridate municipal water – with no time limit on a legal obligation of the Director-General Diane Sarfati to assess whether the directions under section 116E of the New Zealand Bill of Rights Act 1990 (BORA) were a reasonable limit on s11 on the right to refuse medical treatment. Judge Radich’s November 2023 decision that that the D-G was required to turn his mind to the potential impact on rights was amended by a later February 2024 Relief Judgement where Judge Radich pivoted to state that the D-G’s orders to fluoridate would continue to ‘have effect unless and until it is revoked or amended by the Director-General’ without a time limit on the D-G’s deliberation being prescribed.

It is nearly one year later and the Director-General has yet to make this decision while at the same time, the Director-General has turned down requests for an extension. The question may be asked, is the Director-General of Health's conduct fair or reasonable?

PDF: Fluoride Timeline - New Zealand Decisions & Key International Findings.

The legislation that permits fluoridation of drinking water follows an amendment to the Health (Fluoridation of Drinking Water Amendment Bill) Act 1956. However, in both the 2016/17 Select committee report, and a later 2021 Health Committee report, all public concerns about the safety of the fluoridation of drinking water were dismissed as they did not speak directly to the bill content.

For 50+ years, 50% of the population has been exposed to fluoridated water, and consequently, local authorities have released fluoridated council water into the environment. Yet the New Zealand Environmental Protection Authority has never monitored fluoride/ hydrofluorosilicic acid (HFA) emissions to understand environmentally relevant levels, nor conducted a risk assessment to identify the changing science on human and/or environmental health risk.

HFA is not a pharmaceutical grade chemical, but a highly corrosive compound. What occurs when emissions increase when community water is dosed with hydrofluorosilicic acid (HFA)? We don’t know!

However, with no formal (and impartial) regulatory process, it appears that all claims that the benefits outweigh the risks are flimsy. The primary ‘scientific’ source arises from claims by the Office of Prime Minister & Cabinet (OPMCSA). However, no methodological review was undertaken in 2021 and all peer review committees were highly biased towards the safety of fluoridated water.

The Water Services Act 2021 states that ‘safe’ drinking water can only be established when other causes are considered together with the consumption or use of drinking water. Children in New Zealand have higher levels of fluoride in their urine than adults, but this has not been considered by the OPMCSA, nor policy, nor in legislative processes. This was confirmed through an Official Information Act request response. The response confirmed that the Ministry of Health did not take into account (as a relevant consideration) existing urinary fluoride levels in children, which are higher than adults. Details were published in the 2018 paper by Andrea ‘t Mannetje and colleagues:

‘t Mannetje A, Coakley J, Douwes J. (2018) Report of the Biological Monitoring of Selected Chemicals of Concern. Results of the New Zealand biological monitoring programme, 2014-2016. Technical Report 2017-1. March. Centre for Public Health Research. Massey University. Wellington

As PSGR considers that the risk to children was downplayed by government agencies. For example, the OPMCSA engaged peer reviewers who were favourable to fluoridation of drinking water, while at the same time downplaying the assertions of scientists in the globally authoritative US National Toxicology Program (NTP) Assessment for Developmental Neurotoxicity.

See YouTube presentation: NZ Councils instructed to fluoridate water - was risk to kids downplayed by government agencies?

Where the NTP stated more evidence was required to confirm safety, the OPMCSA stated there was ‘no convincing evidence’ of risk. The OPMCSA dismissed an earlier 2019 draft and then failed to remain updated on the NTP draft and information release process and adequately inform policy-makers and the public on the uncertainty concerning risk, that the NTP toxicologists were highlighting. We believe the NTP is the more authoritative institution and should not be so lightly dismissed. We note that the OPMCSA appeared to lack a quorum of experts on this matter.

FLUORIDE PRESENTATIONS

August 26, 2024: Jodie Bruning presented to Tauranga City Council, along with 2 other presenters, Dr Alanna Ratna and Robert Coe on the subject of the safety of fluoridation of municipal water. (PSGRNZ version of Bruning presentation here). Powerpoint PDF. Presentation notes sent to elected members & provided to media.

Topic: TCC Ordinary Council Meeting. Presentation of Report: Fluoridation of Tauranga city's water supply. File Number: A16415420. Link to August 26 meeting. Elected members voted to seek an extension to defer the fluoridation of Tauranga’s water supply.

September 28, 2023: Dr Damian Wojcik presented to the Whangarei District Council. Video with references available here.

October 27, 2023: Jodie Bruning (MA Sociology) presented to the Bay of Plenty Regional Council (28 mins). Video with PowerPoint slides available here (0-28 mins). Transcript available here.

November 6, 2023: Jodie Bruning (MA Sociology) presented to the Tauranga City Commissioners and management. The talk was titled: Uncertainty about pending challenges to the lawfulness of Ministry of Health fluoride directives to TLAs. However, the public are only permitted 5 minutes to present, and the talk was cut short by the Commissioner at 7 minutes. YouTube video (5.30-13.00). Warning: poor sound quality. Link: Reference paper (PDF) handed to staff and commissioners and tabled by TCC.

The text (transcript available here) presented to Tauranga City Commissioners was re-presented with references in a YouTube video (14 minutes). This has been sent in an email to elected members in all councils affected by the Director-General's order to fluoridate water. In the talk Jodie Bruning stated:

When did the Ministry of Health consider the lowest safe level of exposure of fluoride in drinking water in combination with existing levels of fluoride? Are you aware that fluoride exposures in 5-7 year olds are higher than older age groups? That’s a 2018 study that was ignored by agencies and the 2021 Inquiry committee. How much fluoride should be added to prevent harm from prenatal exposures to 7-year-olds, based on Bay of Plenty data?

Following the Tauranga presentation Jodie Bruning agreed to an interview on Reality Check Radio to discuss the topic presented to Tauranga City Commissioners: Uncertainty about pending challenges to the lawfulness of Ministry of Health fluoride directives to TLAs.

PSGR welcomes interviews from all media in New Zealand on the topics we cover.

INTERVIEWS

PSGR trustee Jodie Bruning (MA Sociology) participated in the 2024 documentary by Reality Check Radio: Fluoride on the Brain. August 2024 interview with Reality Check Radio on the Tauranga City Council decision to defer fluoridation of municipal water.

Professor Philippe Grandjean is a professor of environmental medicine at the University of Southern Denmark and a research professor at the University of Rhode Island. Jodie Bruning interviewed Professor Grandjean October, 2023. Interview at @PSGRNZ on YouTube or Spotify.

‘We have to do everything we can to remove toxic exposures to support brain development.’

LISTEN TO: FULL INTERVIEW OR SHORT EXCERPT.

This study led by Grandjean brought together 3 cohort studies, from Mexico (ELEMENT study), Canada (MIREC) and Denmark (OCC) of mothers and infants. With over 1500 mother child pairs participating, this study was highly powered. The dose levels overlapped.

• Maternal urine-fluoride concentrations were measured, and child IQ was determined at age 7 years

• Higher-level fluoride exposures in North America and lower-level exposures in Denmark gave the researchers a broad basis to arrive at a joint benchmark dose level, where at that level one IQ point would be lost. This was 0.45 mg/l fluoride in urine.

• Regulators need to know the lowest level at which harm (a lowered IQ as a result of exposure) might commence, the approximate threshold for fluoride neurotoxicity, benchmark dose confidence level. In this study it was found to be at 0.33 mg/l fluoride in urine.

• The WHO's guideline value in drinking water is 1.5 mg/l (1500 µg/l). This was set in 1984.

• Background levels are found at low levels in nature. Fluoride is not a nutrient, rather it is a toxicant. Humans might have evolved a degree of tolerance at lower levels.

• This study contributes to 20 years of research into developmental neurotoxicity and fluoride.

• Developmental exposures which alter intelligence impact the capacity of that child to progress in life.

• The 'optimal level' for addition to drinking water has been in place since the 1950's. In areas with a hot climate, the "optimal" fluoride concentration is below 1 mg/litre while in cold climates it may be up to 1.2 mg/litre (Galagan & Vermillion, 1957). See 1984 WHO EHC 36.

Philippe Grandjean and Jodie Bruning discussed the unfortunate 40-year history of stacking scientific committees considering fluoride and health, with oral and dental experts. Oral and dental experts, rather than medical experts who take the whole body's health into account, may be more likely to support fluoridation of water, and thus have a bias, or weight their decision-making to support fluoridation.

FOR MORE INFORMATION: Grandjean P, Meddis A, Nielsen F, Beck IH, Bilenberg N, Goodman CV, Hu H, Till C, Budtz-Jørgensen E. (2023) Dose dependence of prenatal fluoride exposure associations with cognitive performance at school age in three prospective studies. Eur J Public Health. 2023 Oct 5:ckad170. doi: 10.1093/eurpub/ckad170. Epub ahead of print. PMID: 37798092

University of Southern Denmark press release: https://www.sdu.dk/en/om_sdu/fakulteterne/sundhedsvidenskab/nyheder/fluor-paavirker-intelligensen (in English)

PDF copy of the references cited at the end of the interview.

Toxic to Kids? Combined fluoride exposures

PDF: Fluoride Timeline - New Zealand Decisions & Key International Findings.

See YouTube presentation: NZ Councils instructed to fluoridate water - was risk to kids downplayed by government agencies?

FLUORIDE PRESENTATIONS

INTERVIEWS

Interview with Prof Philippe Grandjean: 2023 study on fluoride & IQ contradicts so-called 'safe' levels in drinking water. Grandjean et al.

Information

Providing scientific & medical information & analysis in the service of the public's right to be independently informed on issues relating to human & environmental health.