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This article is drawn from PSGR's larger paper:

PSGRNZ (2024) Stepping Back from the Brink: The Programmable Ledger. Four democratic risks that arise when Digital IDs are coupled to Central Bank Digital Currencies. Chapter 8. An Influence Web. Bruning, J.R., Physicians & Scientists for Global Responsibility New Zealand. ISBN 978-0-473-71618-9.

The Stepping Back from the Brink paper outlines the democratic risk presented by digital ID and CBDC currencies. The problem of regulatory capture concerns not just a Reserve Bank that defers to a conflicted management consultancy to develop policy, but more broadly reflects the risks of government agencies and regulators when they are faced with highly resourced industries that seek to achieve and maintain market access for their technologies and substances.

AN INFLUENCE WEB: REGULATORY CAPTURE

Quis custodiet ipsos custodes. "Who will guard the guards themselves?"

The absence of domestic academics researching the constitutional dilemma of regulatory capture in New Zealand might help explain why no academic or legal experts have yet considered the potential for undue corporate industry influence when it comes to policy and regulation of CBDCs, Digital IDs, and the relationships therein. The classic explanation of regulatory capture is[1]:

‘the process through which special interests affect state intervention in any of its forms, which can include areas as diverse as the setting of taxes, the choice of foreign or monetary policy, or the legislation affecting R&D. According to the narrow interpretation, regulatory capture is specifically the process through which regulated monopolies end up manipulating the state agencies that are supposed to control them.’

The classic model outlined by George Stigler presumes that regulatory capture involves incentives provided to a single regulator where:

‘regulation is acquired by the industry and is designed and operated primarily for its benefit.’[2]

This includes the revolving door problem, where people move between industry and government; and the problem of strategic influence where over time, generations of regulator-firm overlap and interdependencies can shift the regulator closer to the regulated industry, resulting in ‘too much’ of an incentive to co-operate.[3]

Consider the questionable ‘revolving-door’ practice where the regulated become the regulator. In 2019 Christian Hawkesby commenced as assistant governor for economics, financial markets and banking. Hawkesby had been part of a team which established Harbour Asset Management, which is owned by Jarden Wealth and Asset Management. [4] [5]

Public understanding of regulatory capture has changed in both scope and influence. Regulatory capture can occur via expertise and/or political lobbying through broader mechanisms which are not necessarily directed to a single regulator. Industry experts can lead, control and shape the design of policy to influence the policy decisions of governments regulatory authorities. In recent years scholars and researchers have drawn attention to the role of corporate industries in influencing nation state policy through the supply of expertise, through informational literature, communications and networking processes.[6]

Industry representative groups frequently take steps to develop a policy and informational narrative that reflects and supports their desired trajectory and business aims. Repeated interactions with the regulated industry have been described as cognitive or cultural capture, with the effect that regulators think like the industry. The threat posed by regulatory legislation can dissolve as regulations reflect private sector, rather than public sector interests and values, while industry can point to the legitimacy of the regulations that they ‘agree’ to.[7]

Industry influence and power has consolidated through globalisation, lobbying and networking, through the supply of private sector services and expertise, and the increasing adoption of private sector values inside governments and the influence of global management consultancy firms. Corporations exercise their political agency through political engagement, institutional participation, and provision and production of resources and services.[8] [9]

Industry funding is used to supply hard infrastructure, including conference and meeting premises to support elite networks and promote collegial relations and ensure access by industry leaders and firms to public officials.[10] However these industry organisations also provide the soft infrastructure – global and domestic thinktanks, communications and policy development researchers to shape political debate.

The consequence is a complex web of influence that extends far beyond the power of individual citizens. This is how stakeholder conversations concerning the adoption of technologies occur at pace behind doors, setting values and principles, language and framing. It’s simply business that industries use their resources to secure take-up by nation-states.

Industries will imagine, encourage and incentivise new roles for technology inside governments and then take action to ensure that government policy and resourcing decisions make a space for private industry-developed resources and services. This is good business practice.

John Finch and colleagues have suggested three processes used to stymy environmental regulation: industry groups formulating regulatory principles, operationalising these principles through technical documentation and calculation, and incremental innovation inside industry sectors to address the problems faced by industry regulators.[11]

Scholars argue that such strategies are not separate from the broader operations of industries, but integrated and centrally directed. ‘Corporations seek to dominate the information and decision-making environments to pursue their interests’, they achieve this by not merely influencing policy but through the co-creation and delivery of policy. The consequence for governments is that:

‘governance is a matter not simply of power or struggle but of communication, ideas and ideology.’ [12]

In 2022 Andrea Saltelli and colleagues summarised these processes as a range of tactics used by industry lobbyists to influence the way governments think about scientific and technical knowledge.

Three stages are suggested. Industry agents (lobbyists) influence the methods by which the policy-relevant evidence is produced. They then delegitimise or appropriate the role of the institutional settings which produce the evidence. Through these processes they change the:

‘the framework or the worldview, to the effect of removing those elements of regulation and evidence which are seen as undesirable by the private interests.’[13]

Fintech industries, and perhaps even the BIS, can be envisaged as democratic ‘erosion agents’ who purposefully drive institutional change and hence, the regime transformation. These are actors with agency – Marianne Kneuer considers that they are able to act on three conditions requiring:

the power to change the rules of the game;
the intention to change the rules of the game; and
the ability to organize relevant groups of followers to change the rules of the game.[14]

Kneuer notes:

‘erosion agents try to fly below the radar as long as possible – they avoid hard and open repression of citizens as well as the massive limitation of political rights, instead relying more on loopholes, selective and event-driven measures, and subtle control.’ [15]

Where stakeholder consultation has taken place it has been secretive and confined. With regards to Digital ID and CBDC policies the principles and frameworks might be claimed to arise from ‘stakeholder consultation’. The DIA and RBNZ have intensively engaged in stakeholder consultation with small groups of stakeholders that appear to disproportionately contain industry actors and marginalised communities while being unavailable to the general public.[16] [17] They’ve then created principles that reflect the stakeholder engagement, but which also mirror industry derived principles[18]. Industry groups often lead by establishing principles that are then adopted by nation states, as is discussed below.

However, as discussed, stakeholder consultations for the Digital Identity Services Trust Framework Bill (which sets up a governance framework for the corporations that use digital identity or provide technical services) broadly excluded the general public. The government framed Digital ID stakeholders as the public agencies who would have oversight over the greater digital infrastructure, the private sector industries who would supply the Digital ID technologies and services, and a minor group representing Māori interests.

The Digital ID framework policy-framing and legislation, and the April 2024 CBDC white papers mirror priorities, pre-prepared principles and discursive narratives already preprepared in white papers prepared by the Central banks, transnational consultancy firms and industry-funded non-government organisations.

I suggest that the cultural capture has resulted in a necessary achievement. Prima facie, it is not Parliament or The Treasury that appear to have responsibility for deciding whether the RBNZ should issue a digital currency – it is the RBNZ appear to have granted themselves this power, through their control of framing, risk assessment and discourse. The institutional setting has been appropriated.

These tactics, by directly targeting the societal functions of science, have effectively reshaped the social, ethical and cultural attitudes to policy making in favour of the Fintech industries and agencies who favour greater surveillance of citizens.[19]

Saltelli et al (2022) describe this as a two-pronged approach:

‘The first prong is a substitution of collusive activities, by removing the traditional separation between regulators and regulated. This process is built on ‘institutional carriers’ such as official statements and normative and ethical principles, stated by document agreed upon by different stakeholders. This allows for a formally neutral and legitimate conduit of industrial interests.’

Once these processes are in place, the regulator and regulated relationship is supplanted by a relationship of mutual support and through this process the governments’ values are captured and reframed -

‘The second prong is a process of reframing and rescaling values and the vision of the relationship among science, society and politics.’

Government discourse around ‘inclusion’, previously discussed, imitates the broader, global messaging, and fails to appreciate the perspective indigenous populations might have if they were asked to consider the harsh reality of increased control through Digital IDs and CBDC ledger technologies, of panopticon-like surveillance.

The global Fintech industry have embedded themselves in domestic surveillance and banking policy through their leadership in the development of Digital IDs and CBDC policy and infrastructure. It’s easy to be unaware of, and dismiss, the long-term collegiality; overlapping relationships; and ongoing crosstalk that has occurred for years between the World Economic Forum and the Bank of International Settlements[20], and the International Monetary Fund[21]. The World Economic Forum:

‘is mostly funded by its 1,000 member multi-national companies.[22]

Then there are the ‘top 100 strategic partners’ of the World Economic Forum (WEF), which include the dominant players in the Fintech system and all of the major consultancy firms that governments habitually bring in to government agencies to develop policy and oversee campaigns. The mission of the WEF states:

‘The World Economic Forum is the International Organization for Public-Private Cooperation. It provides a global, impartial and not-for-profit platform for meaningful connection between stakeholders to establish trust, and build initiatives for cooperation and progress.

In a world marked by complex challenges, the World Economic Forum engages political, business, academic, civil society and other leaders of society to shape global, regional and industry agendas.’

These WEF Strategic Partners are corporations, not governments, and they:

‘believe in the power of collaboration to drive positive change, and work closely with the World Economic Forum to help shape industry, regional and global agendas’. [23]

The Fintech sector and the individuals in the DIA and RBNZ who are dedicated to locking policies and law in place have another advantage. The technologies involved in Digital IDs and CBDCs are so new that they are not well-studied. Therefore, the political ramifications are not well known. The potential to undermine human, civil and constitutional rights have not been fleshed out by constitutional and administrative law experts.

The Fintech sector, the government actors who are committed to the policy, and the global management consultancies who network across government, Fintech and the World Economic Forum stand to benefit from the novelty of this process. It’s not surprising then, that as their power and influence is growing and as governance arrangements in favour of greater Fintech power are advancing at pace, trust in the tech sector is commensurately declining at pace.[24]

It is difficult not to see that the RBNZ, together with its policy co-developer Accenture, are conflicted, and unable to stand back and consider the broader digital ecosystem with any impartiality, and the policy documents suggest this.

Backing out of CBDC issuing powers may be extraordinarily difficult, as Central banks and the huge Fintech industry will use their financial and political influence to prevent what they would view as inappropriate regulation. Once policies and legislation are in place, if public opinion, or the social and scientific literature start to express concern about risk that might result in regulation, a large body of literature demonstrates that industry sectors double-down and invest in product defence.

RBNZ’s already close relationship with Accenture suggest that if negative or worrying information is revealed as CBDC infrastructure develops, that the RBNZ will be reluctant to step back. The RBNZ may be so immersed in BIS and Fintech culture, it may struggle to consider the problem from a constitutional or public interest perspective.

Dr David Michaels, Professor at George Washington University, has described industry’s legacy not as a product, but rather, the legacy is based on the success in maintaining public belief, and hence regulatory concern, on how safe or effective a product. Industries legacy is in product defence.

Dr David Michaels, former head of the U.S. workplace regulator, the Occupational Safety and Health Administration considers that product defence distorts the capacity for governments to act in the best interests of the public.

‘The basic principle of the regulatory system holds that decisions must be made on the basis of the best evidence available at the time. Product defense science doesn’t just game our free-market system; it prevents our government from accomplishing one of the reasons for its very existence. It is often unrecognised because it is so ingrained in our understanding that a primary government function is to facilitate some individuals (including the owners of corporations) to benefit by producing or performing something that does not impinge on the freedom and well-being of other individuals… We want stronger regulations not because we don’t care about freedom, but because we cannot be free without the states protection from harm.’[25]

Constitutional and administrative law and human rights experts, for example, who might consider the broader infrastructure of overlapping Digital ID-CBDC relations, and the implications for the public, were not included in stakeholder conversations, and certainly haven’t drafted any publications which suggest they have had access and insight into these frameworks, and the legislation that supports the regulations.

The effect has been to move governance models to more broadly reflect private sector values of innovation and efficiency, altering the political agency of Western governments. Academic institutions have reflected this priority change (the neoliberal turn) following government shifts in policy and research funding trajectories.[26] This has created information asymmetries, reducing the pool of public law, social science and ethics experts that might critically analyse the implications of close government relations, regulatory capture and the implications for representative democracies. The informational gap has increased the potential for governments to lean on industry expertise.

REFERENCES

[1] Dal Bó, E. (2006). Regulatory capture: A review. Oxford Review of Economic Policy, 22, 203–225. https://doi.org/10.1093/oxrep/grj013

[2] Stigler, G. J. (1971). The theory of economic regulation. The Bell Journal of Economics and Management Science, 2(1), 3. https://doi.org/10.2307/3003160

[3] Dal Bó, E. (2006). Regulatory capture: A review.

[4] Acknowledged in 2022 address: Prior, M. (2022) Our Transformation as a Prudential Regulator. A speech delivered to the Financial Services Council in Auckland on 22 September 2022 Address by Christian Hawkesby, Deputy Governor and General Mananger Financial Stability. https://www.bis.org/review/r220922a.pdf

[5] Business Desk, People Explorer. https://businessdesk.co.nz/people/christian-hawkesby Accessed April 19, 2024.

[6] Saltelli A. et al (2022). Science, the endless frontier of regulatory capture. Futures 135:102860 DOI 10.1016/j.futures.2021.102860

[7] Kwak, J. (2013). Cultural capture and the financial crisis. In Daniel Carpenter, & David A. Moss (Eds.), Preventing Regulatory Capture: Special Interest Influence and How to Limit it (Vol. 9781107036, pp. 71–98). Cambridge University Press.

[8] Farnsworth, K; Holden, C (2006) The Business-Social Policy Nexus: Corporate Power and Corporate Inputs into Social Policy. Journal of social policy, 35 (3). pp. 473-494. ISSN 0047-279

[9] Lewis N, Baker T, Prince R. (March 13 2023) The real problem is consultants' influence, not their cost. Newsroom. https://newsroom.co.nz/2023/03/13/the-real-problem-is-consultants-influence-not-their-cost/

[10] Scott, J. (1991), Who Rules Britain, Oxford: Polity Press.

[11] Finch J et al (2017). Captured by technology? How material agency sustains interaction between regulators and industry actors. Research Policy 46 (2017) 160–170, DOI 0.1016/j.respol.2016.08.002

[12] Miller D. and Harkins C. (2010). Corporate strategy, corporate capture: Food and alcohol industry lobbying and public health. Critical Social Policy, 0261-0183 101; Vol. 30(4): 564–589;376805. P.582 DOI: 10.1177/0261018310376805

[13] Saltelli A. et al (2022). Science, the endless frontier of regulatory capture. Page 9.

[14] Kneuer, M. (2021). "Unravelling democratic erosion: Who drives the slow death of democracy,

and how?" Democratization 28(8), 1442-1462 [Abstr. 72.1651].

[15] Kneuer, M. (2023). Trends on Democratic Erosion: The Role Of Agency And Sequencing. International Political Science Abstracts, 73(6), 837-847. Page 845. https://doi.org/10.1177/00208345231218076

[16] Department of Internal Affairs. Regulatory Impact Statement: Additional policy decisions for the Digital Identity Services Trust Framework Bill https://www.dia.govt.nz/diawebsite.nsf/Files/detailed-policy-for-the-digital-identity-trust-framework/$file/RIS-Additional-policy-decisions-for-the-Digital-Identity-Services-Trust-Framework.pdf

[17] RBNZ CDC Forum Members. https://www.rbnz.govt.nz/-/media/project/sites/rbnz/files/publications/oias/2024/oia2324-050-part4-information-about-the-cbdc-stakeholder-engagement-forum.pdf

[18] Bank of International Settlements (2020) Central bank digital currencies: foundational principles and core features. Report no 1 in a series of collaborations from a group of central banks. https://www.bis.org/publ/othp33.pdf

[19] Saltelli A. et al (2022). Science, the endless frontier of regulatory capture. Page 9.

[20] World Economic Forum. Search. https://www.weforum.org/search/?query=bank+of+international+settlements

[21] World Economic Forum. Search https://www.weforum.org/search/?query=international+monetary+fund

[22] Wikipedia. https://en.wikipedia.org/wiki/World_Economic_Forum

[23] WEF. Strategic Partners. https://www.weforum.org/communities/strategic-partnership-b5337725-fac7-4f8a-9a4f-c89072b96a0d/

[24] Edelmans Trust Barometer. Trust in Tech Sector 2012-2021. https://www.edelman.com/trust/2021-trust-barometer/trust-technology

[25] Michaels, D. (2020). The Triumph of Doubt. Oxford University Press. P.271

[26] Bruning J. (2021) Innovation and Ignorance: How Innovation Funding Cultures Disincentivise Endocrine Disruption Research. Thesis. Master of Arts (Sociology). University of Auckland. https://researchspace.auckland.ac.nz/handle/2292/57929

Regulators and government departments that are keen on deregulation haven't meaningfully address the potential risk from scalability, when governments and industries commercially release new technology into the environment. There's a big reluctance in regulatory circles to discuss what companies don't know when they release a new organism. Off-target and unintended mutations can be almost impossible to detect as they are not predictable. They do happen and they will happen. As releases into the environment increase, so will the likelihood of modified organisms that might carry an effect that presents harm to the surrounding environment. The risks will therefore scale up as development and release of the technology, scales up. Case by case analysis is also difficult - because of the extraordinary difficulty to identify a potential unintended change. Companies aren't likely to spend months and years testing for such elements, when they have already invested large amounts in product development.

September 2024: Food Standards Australia New Zealand (FSANZ) P1055 2nd Consultation proposal to deregulate (perhaps up to 94%) of GMOs by changing the definition - FSANZ Submission PDF or scrollable on Substack. We consider that mainstream media have inadequately discussed the biosecurity risk presented by scalable GMO technology. Worryingly, neither Australian or New Zealand media discussed the P1055 FSANZ consultation to inform the public that a 'paradigm shift' in GMO/GE regulation, from process-based to outcomes-based was being proposed by the food safety authority. If the public do not know, they cannot comment.

February 2025: Submission to the Health Select Committee on the Gene Technology Bill 2024. PSGR’s submission is in two parts (PDF):

Part I: Deficient Policy Formulation: details ways in which the Bill’s drafters have drafted text to narrowly restrict Regulatory powers and prevent wider regulatory scrutiny. This not only leaves New Zealand vulnerable to slow moving problems, it would result in the Regulator having insufficient scope and inadequate information in emergency situations that would enable the Regulator to assure the health and safety of people.
Part II: Recommendations including critical analysis of Bill text: Makes in-depth recommendations and outlines problems and gaps in the Bill text.

March 2025: Presentation to the Health Subcommittee, on behalf of the Physicians and Scientists for Global Responsibility (PSGR) (2:30:00-2:40:00). PSGR’s presentation concerned the Gene Technology Bill that is currently before that select committee.

April 2025: Release of paper - PSGR (2025) When powerful agencies hijack democratic systems. Part I: The case of gene technology regulatory reform. Bruning, J.R., Dommisse, E.. Physicians & Scientists for Global Responsibility New Zealand. ISBN 978-1-0670678-0-9

PSGR emailed New Zealand's Chief Ombudsman to request a formal Inquiry:

'The Physicians and Scientists for Global Responsibility (PSGR) are writing to request that the Ombudsman convene an Inquiry into conduct of the Ministry of Business, Innovation, and Employment (MBIE) and the Hon. Judith Collins, Kings Counsel and Attorney-General, in regard to their work on gene technology regulatory reform over the period 2023-2025. That the Ombudsman consider evidence that this body of persons acted improperly in their duties, directly undermining public law conventions, in order to expedite policies and laws in favour of the deregulation of gene editing technology.'

PSGR also emailed Members of Parliament (see also accompanying press release)- because:

'PSGR believe that there is significant evidence that actions of the Ministry of Business, Innovation, and Employment (MBIE) officials and the Minister in charge, Judith Collins may have undermined good process to drive outcomes that would severely restrict the capacity of the new gene technology regulator to safely regulate gene edited technologies and organisms.'

There is evidence that most gene edited organisms could evade pre-market risk assessment and avoid being labelled a GMO/GE product. A European study showed that 94% of current GM/GE plant applications affected by the European GE (new genomic techniques) proposal would not be classified as a GMO. For more information please scan our Fact Checking 101 page and consider reading our 2023 review paper which outlines where New Zealand stands currently on biotechnology and gene editing.

New Zealand has a low tolerance for unwanted and invasive species. Wilding or volunteer GMO species are a massive problem in north and south America. It is not easy to estimate how highly scalable GMO technologies could themselves become a biosecurity risk for future generations. This was not considered in FSANZ 2024 consultation and we are yet to see a risk assessment for the gene technology reform process by the Ministry of Business, Innovation and Employment, who are currently attempting to deregulate many gene editing techniques and organisms.

If you think it is 'over the top' that PSGR state that MBIE are working to deregulate gene editing techniques and organisms, our recent paper PSGR (2025) When powerful agencies hijack democratic systems. Part I: The case of gene technology regulatory reform reveals how MBIE's problem definition, shown in their Regulatory Impact Statement was focussing on - not the safety of GMOs - but the deregulation of them. MBIE then commenced to use scientists they funded to produce GMOs and gene edited organisms, and people and organisms with biotech investments or partnerships to develop biotech - to act as the 'experts' for the consultation for the new regulations and laws.

PSGR's new paper (April 2025) shows the paper trail and reveals the extraordinary conflicts of interest at play.

If you are interested in why GMO/GE organisms require a different regulatory approach from conventionally bred plants, we recommend you listen to this interview with Professor Jack Heineman on the risk that arises when we scale up technologies.

'Where harm can accumulate at scale transition, that's precisely where regulation is a solution to mitigate risks.'

PSGR (2025) When powerful agencies hijack democratic systems. Part I: The case of gene technology regulatory reform. Bruning, J.R., Dommisse, E.. Physicians & Scientists for Global Responsibility New Zealand. ISBN 978-1-0670678-0-9

Hundreds of epidemiological studies and meta-analyses have reported associations between ultra-processed food consumption and adverse health outcomes. The literature is increasing - the evidence - is pointing to the fact that poor diets with high levels of ultraprocessed foodstuffs, not only drive diabetes - but most illnesses that are common New Zealand. Ultraprocessed foods are low in bioavailable nutrients, frequently high in carbohydrates, and contain high levels of manmade chemicals and high levels of chemically refined (as opposed to naturally refined or cold pressed) vegetable oils. Synthetic chemicals and vegetable oils are recognised as drivers of inflammation, while refined carbohydrates (or starches) drive insulin resistance. Nutritionally bioavailable vitamins and minerals are critical to all body functions, often acting as important co-factors in critical biological processes, from growth, to sleep, to brain health (memory, cognition and resilience and positivity), to reproduction and energy. Low levels of vitamins and minerals, systemic inflammation and insulin resistance are commonly recognised drivers of chronic and communicable illnesses. When people are unwell with inflammation or an illness, they more rapidly vitamin and mineral levels.

PSGR have identified a worrying gap in New Zealand's health governance. The Public Health Agency was established in 2022 to guide health decision-making, including to advise the Director-General and the Minister of Health. As with all agencies operating under the Health Act 1956 (s3A), the PHA must work to improve, promote, and protect public health. The PHA are focussed on equity but are not focussed on dietary nutrition. There is information or advice that states that dietary nutrition is outside the scope of the PHA, however, dietary nutrition and diet and nutritional deficiency as a driver of chronic disease is not in the work programme of the PHA. This was further confirmed via four Official Information Act requests, made in December 2023, and answered in February 2024, to the key members of the Senior Leadership Team (at that time) that this work was not being undertaken:

An Expert Advisory Committee on Public Health (PHAC) was established (Pae Ora (Healthy Futures) Act 2022 [s93]). The terms of reference for this Advisory Committee does not include any requirement to review dietary guidelines or nutrition standards (including to assess the literature on optimum levels of vitamins and minerals) and the position statement on Māori Health does not refer to diet and nutrition. Poor diets and sub-optimum nutrition are recognised drivers of risk for an extraordinary range of chronic and communicable disease, and poor diets will be more commonly experienced by low-socioeconomic groups.

There appears to be no other agency tasked with this responsibility, inside the Ministry of Health. The PHA in the role of advising the Director-General and Minister, and updating guidelines and regulations, should be reviewing best practice nutrition to increase knowledge on poor diets and nutrition, and to ensure that our regulations and guidelines do not drive disease but that they improve, promote, and protect public health, due to the regulations and guidelines being outdated. But this work is not being undertaken.

Drawing attention to poor diets, and sub-optimum nutrition is a big focus for PSGR.

We're looking for scientists and doctors to interview to support massive efforts already underway across New Zealand, working to bring this environmentally-driven sickness epidemic into public view in New Zealand. PSGR recently published a Substack article reviewing three groundbreaking books on the evidence that poor diets not only drive mental illness, but that dietary and nutritional changes can exert profound improvements in mental health.

We recently interviewed Professor Julia Rucklidge on amazing outcomes for high dose nutrients for pregnant mothers taking higher dose multinutrient formulations, where the nutrient levels are higher than (what appear to be) out-dated guideline and regulatory levels. We've previously interviewed Professor Ashley Gearhardt on how ultraprocessed foods likely meet the category for an addictive substance, and Dr Jen Unwin on reversing type-2 diabetes and the challenge of food addiction. We have also interviewed Dr Glen Davies on his work reversing type-2 diabetes, and we also interviewed Dr Emma Sandford on nutritional medicine and eye health, and how high carbohydrate diets are driving poor vision. We've also interviewed Dr Anna Goodwin on cancer and the role of diet and nutrition in not only supporting cancer recovery, but improving clinical treatment outcomes, which we published as a two-part series (Part 1 and Part 2).

In early 2024 academics from Australia, the US and France reviewed the evidence for diseases associations and ultraprocessed food across 45 meta-analyses. These meta-analyses covered some 10 million participants. Melissa Lane and colleagues identified direct associations between exposure to ultra-processed foods and health conditions which included mortality, cancer, and mental, respiratory, cardiovascular, gastrointestinal, and metabolic ill health. As the paper stated:

Overall, direct associations were found between exposure to ultra-processed foods and 32 (71%) health parameters spanning mortality, cancer, and mental, respiratory, cardiovascular, gastrointestinal, and metabolic health outcomes. Based on the pre-specified evidence classification criteria, convincing evidence supported direct associations between greater ultra-processed food exposure and higher risks of incident cardiovascular disease related mortality and type 2 diabetes, as well as higher risks of prevalent anxiety outcomes and combined common mental disorder outcomes. Highly suggestive evidence indicated that greater exposure to ultra-processed foods was directly associated with higher risks of incident all cause mortality, heart disease related mortality, type 2 diabetes, and depressive outcomes, together with higher risks of prevalent adverse sleep related outcomes, wheezing, and obesity.

Lane M M, Gamage E, Du S, Ashtree D N, McGuinness A J, Gauci S et al. Ultra-processed food exposure and adverse health outcomes: umbrella review of epidemiological meta-analyses BMJ 2024; 384 :e077310 doi:10.1136/bmj-2023-077310

WHAT ARE ULTRA-PROCESSED FOODS?

What contributes to my chronic condition? There is compelling evidence that diet is the main driver of health status.[i][ii] [iii] The last 30 years of gene science has demonstrated that while individuals may be predisposed to a genetic condition, it is predominantly environmental drivers, or stressors, that tip people into health or disease.

Stressors can be acute or chronic. If people are (acutely) exposed to large amounts of poison, trauma, stress and pollution bodies can reasonably quickly tip into with a long-term illness or condition. However, if people are exposed long-term to food that wouldn't cause harm if we had a little bit every now and then. However, if we are chronically exposed to poor diets that promote inflammation, insulin resistance and poor nutrition - people can also tip into a long-term illness or condition. Frequently, chronic exposures promote multimorbidity. Chronic conditions can include a metabolic illness, such as pre-diabetes and Type 2 diabetes, heart disease, cancer, chronic pain. But also mental illness, included depression, anxiety and many other brain-related conditions, that might have previously been regarded as exclusively a neurotransmitter problem.

When infants, children and young people consume 40-60% of their diets as ultraprocessed foods, they may be expected to tip into a range of conditions, earlier than their ancestors.

By contrast - if food is nourishing and health promoting, bodies and minds[iv] [v] - are more resilient. Resilience means people recover better from the challenges, and insults of daily life. Even after trauma - we return to healthy sleeping patterns more quickly.

There is increasing evidence (as we discuss here) - that healthy diets can reverse many chronic mental health conditions.

Traditional (historic) diets depended on what food-types were seasonally available a person's region, and what skills human ancestors had to prepare and store food over colder months. Today people are generally sicker at an earlier age with long-term ‘chronic’ diseases and diagnoses. Studies of cellular biology, nutrition, case studies and large analyses demonstrably pattern the origin of these diseases, all too frequently, to poor diets.

These are generically referred to as ‘lifestyle diseases’, but the way people and families consider, cook and consume food is influenced by cultural, historic, social and economic factors which shape knowledge and capacity.[vi] [vii] [viii] [ix] Health is part of a big picture.

Human ancestors did not consume ultra-processed foods which promoted insulin resistance and inflammation.

Ultra-processed foods (UPFs) are industrial formulations of processed food substances (oils, fats, sugars, starch, and protein isolates) that contain little or no whole food.[x] UPFs typically include flavours, colourings, emulsifiers, as well as other cosmetic additives to make them taste better.[xi] UPFs contain many more industrial ingredients than traditional, lightly processed foods such as cheese; tinned fruit, beans, and vegetables.

Monteiro, C.A., Cannon, G., Lawrence, M., Costa Louzada, M.L. and Pereira Machado, P. 2019. Ultra-processed foods, diet quality, and health using the NOVA classification system. Rome, FAO.

UPFS: MIXTURES OF REFINED INDUSTRIAL INGREDIENTS

How are UPFs different? UPFs deprive your body of complex nutrient mixtures. Formulation ingredients can be derived from a remarkably small range of ingredients. Manufacturers do add nutrients – but these cannot reflect the complex nutrient and fibre bioavailability of, for example, a single vegetable. When you eat lots of these foods, you can end up eating a narrow range of ingredients all day, just in different formulations. So, you don’t get the nutrients which are required to keep you humming along.

UPFs increase exposures to complex synthetic chemical mixtures.

These industrial formulations include synthetic chemicals, as well as genetically modified and chemically refined cereals and oilseeds. These additives are less likely to nourish us, and at times may harm us, and drive disease. These chemical mixtures are not assessed for risk, and the science to consider how mixtures might drive inflammation and drive disease, for example, is poorly funded, in comparison to science to drive drug development for those same diseases.

UPFs deprive the microbiome of complex fibre mixtures.

UPFs are ‘smoother’ and less challenging to eat than foods with fibre. This is a problem, because without healthy fibre, people can’t sustain a healthy gut microbiome. The human gut microbiome is ground zero for human health. Health journeys are personal because of job type, exercise level, genes; nutritional intake, age; gut health, gender; financial status, address and parents’ history. While stress always was part of life, human ancestors were not exposed to the range of environmental pollutant emissions that appear to reduce our resilience to stress, at younger and younger ages.

Cumulative lifetime environmental exposures – and humans' biological responses make up what is termed the ‘exposome’.[xii] Governments do not prioritise the monitoring and risk assessment of toxic exposures to synthetic chemicals, drugs, genetically modified foods, heavy metals and radiation. This can be undertaken through biomarker monitoring and testing, for example, of hair and serum. Monitoring, risk assessment and regulation lags behind the release of technologies onto the market.[xiii]

ADDICTIVE PROPERTIES ARE FREQUENTLY 'BUILT-IN' TO UPFS

Change is especially difficult when industrial food scientists build temptation into the industrial formulations. Industrial food formulations are frequently designed to make the UPF really, really tasty – hyper-palatable. Yes. Some foods possess addictive properties.[xiv] [xv] Scientists have theorised that refined carbohydrates trigger the addiction responses in ultraprocessed foods. They’re the addiction agent.[xvi] As people have more of an addictive substance our dopamine receptors down-regulate. The body digests and absorbs refined carbohydrates rapidly. We do the same with potatoes, particularly if they are peeled.

Refined carbohydrates include sugar, white flour and white rice. These foods are metabolised similarly in the body. Refined carbohydrates together add up to a glycaemic load. They make blood glucose rise quickly. Sugar is the worst culprit. When sugar consumption exceeds our liver’s capacity to clear and metabolise sugar, sugar ends up in the brain, driving reward. [xvii]

Ingredients in UPFs are traditionally low-cost. UPFs are specially designed for travelling long distances. They have to store well. UPFs are generally low in fibre, because fibre as an ingredient in food starts to break down, or go ‘off’. The food substances are often obtained from a few big high-yield crops (corn, wheat, soya, cane or beet). UPFs contain chemically refined, vegetable oils (such as canola, corn and soybean) rather than olive oil or coconut oil or butter, which are not chemically refined.

Corn and wheat might be synthesised into many different ‘ingredients’ - but the body is only consuming two food types. It is difficult for people on a high-wheat, high UPF diet to remain healthy over time.

As UPF exposures increase, industrial chemical exposures increase, while nourishing bioavailable nutrition & fibre decrease.

Change is never convenient when a person can’t sleep, when a person is hurt, fatigued and suffering.

Understanding these factors, and particularly, how addictive properties are embedded into the products, can create challenges to change, but also can help individuals and families reconsider things. This includes stopping blaming yourself, or the household cook, and realising that addiction is a product property to drive re-purchase. Addictive properties are critical to marketing. When individuals and families recognise that industrial commercial foods are cunningly designed for repurchase, this can help in the shifting of gears away from addiction-driven habits.

Often, it can be surprising that shifting the body away from food with addictive properties, is like any magnet. The pull is stronger in the short term, while over the long term, skills and strategies can be implemented, and new, body-habits nourished, to reduce that magnetic 'pull'. Withdrawal feelings are normal, and regression is normal, as prompts and triggers are embedded in daily life, from advertising signs to shops, to digital media.

Recognising that 'this is business' can help shift dietary habits (loyalty to a product) and purchase-decisions support your body, particularly the brain, with the safe and nutritious food human bodies really need. Many people are on similar journeys, and people find that they are not alone.

When governments don’t fund independent science, in the knowledge gap, the public can be sceptical of the safety claims of large, private companies. They can be aware of the advertising dollar in mainstream media, and the lack of focus on the addictive properties of UPFs - from toast to noodles to commercial fast food.

Key to this long journey, is becoming determined to relearn the skills of our ancestors.

Healthy diets can be remarkably cheap and simple to prepare.
As skills develop, cooking becomes efficient, planned, but also creative.
When addictive impulses are removed, and insulin levels are healthy - money can be saved, and snacks reduced, as the body doesn't have to negotiate fatigue and sugar spikes.
But like recovering from alcohol addiction - recovery is often best in community and group environments, to promote learning but also to gain support to navigate the daily hurdles that can drive .

REFERENCES

[i] Lane M M, Gamage E, Du S, Ashtree D N, McGuinness A J, Gauci S et al. Ultra-processed food exposure and adverse health outcomes: umbrella review of epidemiological meta-analyses BMJ 2024; 384 :e077310 doi:10.1136/bmj-2023-077310

[ii][ii] Lane MM et al (2020) Ultra-processed food and chronic non-communicable diseases: A systematic review and meta-analysis of 43 observational studies. Obesity Reviews. 22(3):e13146. doi: 10.1111/obr.13146.

[iii] González Olmo GM et al 2021. Evolution of the Human Diet and Its Impact on Gut Microbiota, Immune Responses, and Brain Health Nutrients 2021, 13, 196. https://doi.org/10.3390/nu13010196

[iv] Rucklidge JJ et al (2021) Nutrition Provides the Essential Foundation for Optimizing Mental Health. 6:1, 131-154, DOI: 10.1080/23794925.2021.1875342

[v] Martínez EE et al (2020) Effect of ultra-processed diet on gut microbiota and thus its role in neurodegenerative diseases. Nutrition 71:110609 doi.org/10.1016/j.nut.2019.110609

[vi] Venn et al (2017) Social determinants of household food expenditure in Australia: the role of education, income, geography and time. Public Health Nutrition: 21(5), 902–911 doi:10.1017/S1368980017003342

[vii] Daniel C. (2016) Economic constraints on taste formation and the true cost of healthy eating. Social Science & Medicine 148:34-41. http://dx.doi.org/10.1016/j.socscimed.2015.11.025

[viii] Neuwelt-Kearns C. (2021) The realities and aspirations of people experiencing food insecurity in Tāmaki Makaurau. Kotuitui: New Zealand J Soc Sci Online. https://doi.org/10.1080/1177083X.2021.1951779

[ix] Vandevijvere S et al (2021) Food cost and adherence to guidelines for healthy diets: evidence from Belgium. Eur J Clin Nutrition (2021) 75:1142–1151

[x] Monteiro, C.A., Cannon, G., Lawrence, M., Costa Louzada, M.L. and Pereira Machado, P. 2019. Ultra-processed foods, diet quality, and health using the NOVA classification system. Rome, FAO.https://www.fao.org/3/ca5644en/ca5644en.pdf

[xi] Monteiro CA, Cannon G, Levy RB, Moubarac JC, Louzada MLC, Rauber F et al (2019) Ultra-processed foods: What they are and how to identify them. Public Health Nutr 22(5):936–941

[xii] Karlsson et al (2020). Opinion. The human exposome and health in the Anthropocene. International Journal of Epidemiology, 2020, 1–12 doi: 10.1093/ije/dyaa231

[xiii] Persson L et al. (2022) Outside the Safe Operating Space of the Planetary Boundary for Novel Entities. Environmental Science & Technology 56 (3), 1510-1521 DOI: 10.1021/acs.est.1c04158

[xiv] Praxedes DRS et al (2022). Prevalence of food addiction determined by the Yale Food Addiction Scale and associated factors: A systematic review with meta-analysis. European Eating Disorders Review, 30:2;85-95 https://doi.org/10.1002/erv.2878

[xv] Moss, M. (2021) Hooked. Random House.

[xvi] Gearhardt AN & Schulte EM (2021). Is Food Addictive? A Review of the Science. Annu. Rev. Nutr. 2021. 41:387–410. P.393

[xvii] R.H. Lustig. “Fructose: It’s Alcohol without the “Buzz”,” Adv. Nutr. 4 (2013): 226.

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New Zealand charity seeks public inquiries to investigate the conduct of the Ministry of Business, Innovation and Employment (MBIE) and the responsible Minister, the Hon Judith Collins in their undertaking of Gene Technology Regulatory reform and Science System reforms.

PRESS RELEASE: Physicians & Scientists for Global Responsibility New Zealand (PSGR). (PDF)

April 16, 2025.

Note. April 27, 2025 - Relatedly - Link to PSGR's submission to the Royal Commission COVID-19 Lessons Learned, Phase 2 Consultation.

A New Zealand charity, the Physicians & Scientists for Global Responsibility New Zealand (PSGR), has reviewed official documents involved in the production of the Gene Technology Bill and New Zealand’s recent science system reforms and have published two white papers that call for two separate public inquiries.

PSGR have written to the Ombudsman asking that they convene a public inquiry to assess whether officials directly undermined public law conventions and processes to pursue policies and laws in favour of the deregulation of gene editing technology. PSGR have emailed members of Parliament to advise them of the complaint to the Ombudsman.

Secondly, PSGR are also calling for a ‘transparent and public inquiry’ that can (a) identify the factors leading to the collapse of the capacity of New Zealand’s research, science, innovation and technology system to be adequately resourced to meet the objectives of society at large; and (b) recommend how to transform it into having that capacity, and in doing so serve the public purpose and support the wellbeing of New Zealand, her people, resources and environment.

PSGR is open on the issue of whether the second, science system enquiry should be a formal inquiry or a Royal Commission but believes that people should be asking why the important role of science and research in producing knowledge for the maximum benefit of society, has been perverted by prioritising commercial returns.

PSGR have published two papers under the title: ‘When powerful agencies hijack democratic systems.’ The papers allege that government documents suggest that the Minister and MBIE officials may have acted to drive policy and legislative outcomes in a manner which may be neither fair nor impartial, but biased and potentially misleading. MPs have been sent these papers and advised of the complaint to the Ombudsman.

PSGR are concerned that officials may have sidelined and undermined important issues and conventions that are essential to sustain a robust, healthy, accountable democratic nation-state, in their haste to push through gene technology and science system reforms.

Lead researcher Jodie Bruning stated:

‘Evidence points to these reforms severely restricting the capacity of the new gene technology regulator, and the New Zealand science system, to conduct activities intended to serve the public good and supporting constitutional and democratic government.’

The Part I paper, The case of gene technology regulatory reform, recommends that the Gene Technology Bill is placed on hold and that the Ombudsman undertakes a formal review into the official conduct of MBIE and Judith Collins, to establish whether this body of officials directly undermined public law conventions and processes to pursue policies and laws in favour of the deregulation of gene editing technology.

Co-author and former Crown Research Institute researcher, Dr Elvira Dommisse stated:

‘The evidence suggests that the MBIE- funded Royal Society undertook research to communicate the benefits of new gene editing technologies, and used them to provide ideas for law reform. The National Party then took these recommendations and ran with them. MBIE and Judith Collins subsequently oversaw the drafting of legislation that excluded a wide range of these technologies from their proposed Bill. However, at no stage was there any formal process of assessing the risks of these excluded technologies.'

This is of particular concern because if the Bill were passed, these technologies could be ramped up commercially, and released at scale. No-one would know’

PSGR are concerned that if members of Parliament (MPs) believe MBIE’s assurances that the legislation is fit for purpose, that they may be being misled. There has been little or no scientific evaluation to assure MPs that the risks can ever be managed in such a way that will fulfil the purpose of the Bill, which is to ‘protect the health and safety of people; and the environment’.

The Part II paper, The case of science system reform, draws upon official documents to show how the science system reforms that are currently underway (2023-2024) have excluded any evaluation of the role of public good research in meeting the objectives of society at large. Instead, the current reforms will likely direct the RSI&T system away from optimising science and research to solve domestic problems and challenges.

Lead researcher Jodie Bruning stated:

‘MBIE officials know very well that ‘innovation’ is a proxy term for patents. They’ve directed the entire science system to promise a patent first, and then if we’re lucky this might trickle down into some other benefit. It’s the wrong way round. New Zealand has a very big problem when the Ministry responsible for innovation and economic growth controls the science system.’

The papers point to the extraordinary conundrum New Zealand is in. The conflict-of-interest which arises when the agency for economic growth, which controls the policy and funding for the entire science system, then takes action to secure control of legislative reforms that would reduce regulatory barriers to the very ‘innovations’ or technologies that that agency directly funds scientists to produce.

Jodie Bruning added that:

‘We’ve got an instance where one Ministry has extraordinary political and financial conflicts of interest, while also exercising effective control over how and what knowledge is produced for New Zealand as a nation. When that Ministry secured that massive control of the science system, it did not achieve this through an Act of Parliament, but via secondary legislation. This is an untenable situation for our science and research system, for the New Zealand people, and for our elected members.’

END.

For inquiries please email:

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The Hijacking Democracy papers (released April 2025):

PSGR (2025) When powerful agencies hijack democratic systems. Part II: The case of science system reform. Bruning, J.R.. Physicians & Scientists for Global Responsibility New Zealand. April 2025. ISBN 978-1-0670678-1-6

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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.

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

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For over 20 years the Physicians and Scientists for Global Responsibility New Zealand Charitable Trust (PSGR) has produced reports and submitted to government Bills and Inquiries.

We’ve been extraordinarily busy over the past 2 years with our work.

This Update aims to inform members and colleagues – and act as a go-to summary of our recent work.

2022 UPDATE - PDF

As well as our recent work All PSGR’s submissions are available to the public on our Submissions pages. In addition, we are now on LinkedIn, Twitter, Odysee & Instagram.

MEMBERSHIP

Please – without your support and membership PSGR cannot do this work. We’ve kept our fees deliberately low because your membership is important to us.

MOVING FORWARD 2022+

The PSGR recognise that the perspectives that have been expressed by the PSGR from 2020 onwards will not necessarily reflect the perspectives of all trustees and all members.

However, we sincerely hope that PSGR’s perspectives are more likely to reflect the perspectives of the majority of our membership and of collegial organisations – which represents a diverse quorum of inquiring minds.

We hope that we have demonstrated a consistency to our work, that reflects and upholds the principles reflected in 20 years of research, information communications and submissions to policy

Reports and Papers

Royal Commission

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