Members of Parliament
23rd May 2018
AUTHORITATIVE REFERENCE MATERIAL FROM
Physicians and Scientists for Global Responsibility (PSGR) …………………………………………………………………………………………………….
on the matter of
INTRINSIC & BIOACCUMULATIVE TOXICITY IN PEOPLE & THE ENVIRONMENT OF A MINISTRY OF HEALTH POLICY TO FLUORIDATE PUBLIC WATER SUPPLIES
Implications for regulatory policy & progressing the current Bill that is before the House
- CURRENT REGULATORY POLICY DANGERS
1.1 The still-current Ministry of Health (MoH) policy in favour of adding industrial grades of fluoride to public water supplies was established over 50 years ago. However, recent research indicates that this policy has never undergone required policy assessment consistent with requirements of administrative law (i.e. identification and due consideration of and due weight given to all relevant safety of peoples’ health and material environmental safety ‘relevant considerations’).
1.2 Nor has the MoH current policy ever been evaluated with thorough and required Regulatory Impact Assessments (RIA) and Regulatory Impact Statements (RIS) consistent with Cabinet Manual; OECD standards; and Legislative Advisory Committee Guidelines.
1.3 On any assessment of the MoH papers available, there has also been a blatant disregard by MoH of Legislative Advisory Committee (LAC) Guidelines.
1.4 These MoH regulatory deficiencies and MoH abuse of policy-making powers threaten the peoples’ confidence in the MoH; in the processes of NZ government; and in the Parliament that is supposed to act only in the public interest.
1.5 In effect, MoH has been misleading Parliament for decades – and it currently strives to do so further in its current pursuit of statutory powers to replace its long-established policy of many decades.
1.6 This PSGR paper sets out some of those ‘relevant considerations’ that have not been identified and assessed by MoH so as to inform Members when faced, shortly, with further readings of the MoH-proposed Bill that seeks Parliamentary statutory powers to require (via DHB regimes) local authorities to place fluoride-containing industrial effluent into public water supplies.
2.1 The recent case of the MoH ‘instructing’ a DHB what to state in a report so as to apparently mislead its Minister and Parliament could be regarded as evidence to any reasonable person that the MoH is not to be trusted with administering any statutory powers.
2.2 The recent case of excess fluoride being added to a public water supply because of inadequate controls attaching to its “fluoride policy’ is another example of a cavalier and casual approach to MoH policy formulation.
On April 3rd Palmerston North City Council (PNCC) and Public Health Services of MidCentral Health (PHS) revealed that due to a failure in the water fluoridation system, the fluoride level in the Longburn area had exceeded 8mg/L since the previous testing on March 28th. Thus, the population had been subjected to over 10 times the recommended level for potentially 6 days. Notwithstanding the local MoH claim (unsubstantiated and without supporting reason) that this would have no ill-effects, the foetus of any woman especially in the first third of pregnancy would have been exposed to abnormally high fluoride levels with an elevated risk of neurological impairment (loss of IQ). Notably, these failures are not that rare as thirty-four mechanical failures resulting in over-dosing were notified during a 20-year period in the USA with at least one confirmed subsequent death in Alaska (1992). Likewise, documentation reveals similar failures are regularly being reported in New South Wales and Queensland.
- EVIDENCE AND PROBABILITIES OF HARM
3.1 Evidence of harm from fluoridation of public water supplies was presented by PSGR to the former Health Select Committee that heard submissions on this topic last year (2017).
3.2 Now, new evidence is to hand indicating harms from fluoride at low levels consistent with those now being found in the NZ population. Notably, this toxic element accumulates in body tissues as only 50% is excreted.
3.3 The attached has just been published in the NZ Medical Journal revealing what could very easily be occurring in the middle-aged and elderly with public health professionals not having done any investigations over the past 50 years.
3.4 The following fluoride associated facts are all supported by robust, peer-reviewed research. Whilst association does not prove causation, there is only one logical common denominator.
3.4.1 Statistically significant impaired neurological development (lowered IQ) when maternal urine fluoride level exceeded 0.8mg/L (note: similar levels were found in pregnant women in Palmerston North in 2015)
3.4.2 Lowered thyroid function (hypothyroidism) widespread in fluoridating countries including Ireland and NZ leading to: –
- a) Obesity and neurological impairment (at worst cretinism).
- b) Diabetes (note 136% increased incidence between 1998 and 2015 in Ireland with mandatory nationwide water fluoridation for 50 years).
3.4.3 Asthma and COPD (Chronic Obstructive Pulmonary Disease) statistically elevated in all fluoridating countries and especially Ireland and New Zealand when compared with other relevant countries.
3.4.4 Arthritis with a probability of multiple joint replacements.
3.4.5 Diffuse gastro-intestinal inflammation (first documented in 1937).
3.4.6 Dental fluorosis (currently exceeding 40%). This is not “just cosmetic” but evidential proof of systemic toxicity in young children.
3.5 The only fluoride dental benefit if any, is topical and not by ingestion.
3.6 Dental decay is a socio-economic systemic disease caused by excessive sugar ingestion and malnutrition including vitamin D deficiency.
- A FLAWED POLICY
4.1 The fluoridation policy established over 50 years ago with neither adequate regard to other sources nor any subsequent biomonitoring by the Ministry of Health, has now been shown by scientific evidence to be ill-founded in fact and reason; ineffective; and a danger to public health.
4.2 For the purpose of its current application for a statutory amendment (the current Bill before the House) the Ministry of Health (MOH) compiled a required Regulatory Impact Assessment (RIA) that indicates that the MoH did not consider many ‘relevant considerations’ that are required by Cabinet Guidelines; by Legislative Committee Guidelines and by the principles of administrative and constitutional law.
4.3 The Ministry has claimed that a report that it commissioned from the Royal Society endorsed both efficacy and safety of its policy to fluoridate public water supplies: however, any reasonable assessment of that report would conclude that:
4.3.1 the authors of the report failed to consider many adverse effects material to health and safety of people;
4.3.2 failed to consider other material sources of dietary fluoride when considering public dosage levels of fluoride;
4.3.3 failed to consider municipal waste-water disposal safety of a very dangerous element that is highly-toxic in its own right but has bio-accumulative other toxins that include arsenic, mercury and lead;
4.3.4 failed to consider material waste-water disposal risks to the environment;
4.3.5 failed to consider and give due weight to alternative dental health options and initiatives (e.g. the Child Smile initiative in Scotland);
4.3.6 failed to recognise that the MoH claims of the degree of efficacy of its policy for fluoridation of public water supplies were grossly exaggerated by being apparently derived from a misleading and deceptive manipulation of generally-accepted statistical methods; and
4.3.7 failed to consider that the policy would make an absurdity of the purposes of existing statutes that are required to be observed by local authorities.
4.4 Such bad government conduct by MoH and incompetent performance by the Royal Society cannot be allowed by MPs to infect, by endorsement in the House, the taking of statutory powers sought by the MoH to require fluoridation of public water supplies in NZ.
4.6 MPs and parties that endorse the Bill will be setting aside both the precautionary principle and the public interest principle that are supposed to constrain their actions in government.
4.7 The consequences will be very serious because government and Parliament will lose the confidence and the trust of a large part of the NZ public. Government will be seen to have abandoned the required precautionary principle and the principle that requires government to comply with the public interest – and to be seen to be doing so transparently, with due diligence and otherwise according to law.
4.8 In summary of the available evidence, the MoH’s policy to deliberately add fluoride to public water supplies poses considerable risks to the health of the population and damage to the NZ environment.
4.9 It would therefore be unconscionable for any MP or political party to support further readings of the MoH Bill that is currently in the schedule for a second reading in the House.
4.10 The PSGR team offers to provide further briefings on this issue.
- E. Godfrey MB.BS.
For Physicians & Scientists for Global Responsibility (PSGR)
23rd May 2018
Physicians and Scientists for Global Responsibility
New Zealand Charitable Trust
PO Box 9446
+64 7 544 5515