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Draft NHMRC Information Paper: Effects of water fluoridation on dental and other health outcomes submission

This submission reflects the views of
Individual Background: 
Retired Medical Laboratory Scientist with long standing concerns with potential for harm with water fluoridation, with concerns that it is unethical mass medication and who has family member who was harmed by water fluoridation
Personal Details
First Name: 
Last Name: 
Specific Questions
Q1. B) Please provide details regarding your response to Question 1A: 
Q5. Is there additional evidence on any other health effects of water fluoridation that should be considered in the draft Information Paper?: 

The 2 listed papers ( on ADHD in USA by Malin and Till and on Hypothyroidism in UK by Peckham et al ) were both published in Feb 2015 – the NHMRC draft information paper was not published until the 14 September 2016 – the NHMRC had plenty of time to analyse and include them – or if to reject them – advise the justification. The NHMRC must include an explanation in it’s final publications of why it ignored these papers in its draft information paper when every member of the NHMRC FRG would have known about them in Feb 2015 • Exposure to fluoridated water and attention deficit hyperactivity disorder prevalence among children and adolescents in the United States: an ecological association Author: Malin AJ, Till C. Journal Name:Environmental Health Publish Date:February 27, 2015 Volume/Page:[Epub ahead of print] Type:Human Study, Epidemiology Categories:Brain, Behavior, Cognitive Function • Are fluoride levels in drinking water associated with hypothyroidism prevalence in England? A large observational study of GP practice data and fluoride levels in drinking water Author: Peckham S, Lowery D, Spencer S. Journal Name:Journal of Epidemiology and Community Health Publish Date:February 24, 2015 Volume/Page:[Epub ahead of print] Type:Human Study, Epidemiology Categories:Thyroid Gland, Thyroid Hormones

Q6. Is there any other supporting material relevant to making decisions on water fluoridation in the Australian context that should be considered in the draft Information Paper?: 

The NHMRC claims that it is “Australia’s leading expert body for; supporting health and medical evidence, developing health advice for the Australian community health professionals; providing advice on ethical behaviour in health care and in the conduct of health and medical research” https://www.nhmrc.gov.au/ Unfortunately, the behaviour of the NHMRC in the conduct of its 2016 draft information paper on water fluoridation and health effects has brought the NHMRC into disrepute and has done a great disserve to the Australian public. Its activities has shown the NHMRC to be grossly biased and non- impartial in its actions. Below - follows evidence of NHMRC’s biased and unethical actions and demonstrates how the NHMRC has perverted science to protect water fluoridation. NHMRC’s extremely biased FRG committee guiding / controlling the published 2016 NHMRC review. In 2014 the NHMRC appointed ten known fluoridation Lobbyists/ Fluoridation supporters to the Fluoride Reference Group (FRG). Those FRG members have serious conflicts of interest and with 10 of them included it makes two thirds of the FRG who are fluoridation lobbyists or supporters. The FRG had been stacked and the NHMRC had only advised of one additional member by placing his name on the website only AFTER the 2014 Public Call for Evidence had already closed. The NHMRC draft paper ( page 54 ) claims “ No unmanageable conflicts were identified by the Fluoride Reference Group…“ this is hardly surprising considering two-thirds or more of the FRG were known to be very Pro – fluoridation. The NHMRC did not invite anyone who is opposed to fluoridation to join the FRG committee, DESPITE the NHMRC claiming verbally in late 2013 to a former Dental Association president and in early 2014 ( in emailed communication with myself ) that the NHMRC review process would be open and transparent and would include anti-fluoride representatives. The NHMRC had already appointed the FRG members in May 2014 and they had already started meeting in June 2014 – however even when the public Call for Evidence started on the 23rd July 2014, the NHMRC had still not published FRG members “ interests” – AKA Conflicts of Interests. In the end the FRG members “interests” published by the NHMRC was overall grossly inadequate in its disclosing. See table below for some information on the conflicts of interests on 10 FRG members. NHMRC Fluoride Reference Group Committee Member ( FRG ) 2014- 2017 KNOWN CONFLICTS OF INTEREST ( known lobbyist for fluoridation / fluoridation supporter) 1 Dr Meenakshi Arora Supporter of fluoridation – as cited in interview by Bundaberg News Mail Dec 2009 “ Dr Meenakshi Arora, University of Melbourne research fellow for chemical and biomolecular engineering and a supporter of fluoridation, told a press conference on the subject: “It definitely and significantly reduces the risk of dental caries. But we need to be careful not to overdose people, especially kids in the age range of two to seven years.” http://fluoridealert.org/news/bundaberg-region-fluoride-in-two-years/ 2 Assoc Prof Stephen Corbett Corbett’s paper “Fluoride : Benefits Far Outweigh Risks” published in 1993 NSW Health Public Health Bulletin can be downloaded here – http://www.health.nsw.gov.au/phb/Documents/1993-08.pdf or just the 2 actual pages here - http://www.publish.csiro.au/?act=view_file&file_id=NB93040.pdf Claimed that fluorosis in NSW in 1993 was only 3 % ( he didn’t specify that that would only be Moderate fluorosis ) NOTE – Ass Prof Corbett name only appeared as a FRG member AFTER the NHMRC 2014 Call for Evidence had closed 3 Ass Prof Sharon Goldfeld Associate Professor Sharon Goldfeld, Chair of the P&CHD Paediatric Oral Health Working Group. (RACP Paediatric & Child Health Division (P&CHD) – “The RACP and the RACDS, through their Child Oral Health Statement, have called for oral health awareness in the training of all health professionals who work with children. Collaborative public health approaches have also been identified, including healthcare professional training and public water fluoridation for all communities with populations greater than 1,000 people. The RACP and RACDS intend to partner around many of these issues to effect more positive outcomes on the oral health of children and young people. Source - Bite Magazine 20th Sept 2012 - Member of Public Health Association of Australia (PHAA) joined in 2000. PHAA has for many years actively lobbied for fluoridation – particularly for Qld. 4 Prof Alison Jones As part of NSW Health team presented the Yes case for fluoridation at Byron Bay public information evening - 16th October 2013. Was also part of NSW Health team earlier in 2013 giving briefing sessions promoting fluoridation to Lismore and Ballina Councils http://www.abc.net.au/news/2013-10-17/byron-fluoro-meeting/5028058 “ But a medical specialist has described the mythology and fears around fluoridation of drinking water as 'nonsense'. Wollongong University's Dean of Medicine and Toxicology, Professor Alison Jones told the crowd that there was no evidence to support such claims.” 5 Dr Frederic Leusch “Too little fluoride, less than 0.1 mg/L in drinking water, leads to poor dental health and high incidence of dental decay” plus other quotes in May 27 2014 SunCoast News http://www.suncoasttimes.com.au/features/something-in-the-water/ 6 Prof Mike Morgan NHMRC Podcast 19 Feb 2009 - And the downsides? “Extremely minimal,” Professor Mike Morgan, Colgate Chair of Population Oral Health at the Melbourne Dental School tells interviewer Stuart Cameron. http://www.nhmrc.gov.au/media/podcasts/2009/we-know-fluoride-saves-teeth... Part of Clive Wright’s team which won NHMRC 10 of the Best Research Projects of 2008 NHMRC article titled “ Linking water fluoridation with good dental health “ http://www.oralhealthcrc.org.au/content/professor-mike-morgan-0 “Professor Morgan’s principal teaching responsibility is in population oral health, focusing on oral disease causation in relation to common risk factors and disease prevention at a population level - with an emphasis on community water fluoridation” “He has been a consultant to the Victorian Government in areas such as the Auditor General’s review into public dental services and the recent Victorian Government’s expansion of community water fluoridation in Victoria.” 7 Dr Katherine O ‘Donoghue President, Indigenous Dentists' Association - an association which wants all Indigenous communities of more than 500 people fluoridated “Indigenous Dentists’ Association of Australia - Indigenous Oral Health Goals” – extract Goal 1. Community water fluoridation Target All indigenous communities with a population of more than 1000 will have a fluoridated water supply by 2015. All indigenous communities with a population of more than 500 will have a fluoridated water supply by 2020 Qld Health dental employee - Service Line Director of Oral Health, Oral Health Services, Queensland Health ( Qld Health actively promotes fluoridation ) 8 Prof Kaye Roberts-Thomson Interim Dean and Head of School of Dentistry and Director, Dental Practice Education Research Unit, Australian Research Centre for Population Oral Health, The University of Adelaide – has continuously promoted fluoridation for years. Recipient of grant money from AIHW and NHMRC - has used emanating publications to promote fluoridation ( child dental health surveys, national adult oral health survey) 9 Emeritus Prof A. John Spencer Participated in two NSW Land and Environment court cases - (1) to help Rous Water, Lismore and Ballina Councils be able to fluoridate their jurisdictions (2011) (2) to assist continued fluoridation by Eurobodalla Council (2013) Former director of Australian Research Centre for Population Oral Health, The University of Adelaide – has continuously promoted fluoridation for years. Recipient of grant money from AIHW and NHMRC – has used emanating publications to promote fluoridation (child dental health surveys, national adult oral health survey). His 1996 study comparing fluoridated Townsville to unfluoridated Brisbane children was used by Bligh govt in 2007 to mandate Qld fluoridation. More recently recipient of approx $900, 000 from Qld Health to analyse data report on baseline of fluoridation in Qld 10 Prof Clive Wright As NSW Chief Dental Officer participated in 2011 NSW Land and Environment court cases to help Rous Water, Lismore and Ballina Councils be able to fluoridate their jurisdictions. Recipient of NHMRC grants which he has used to promote fluoridation -Chief Investigator of team which won NHMRC 10 of the Best Research Projects of 2008 NHMRC article titled “ Linking water fluoridation with good dental health” NHMRC CEO Warwick Anderson issued a Media Statement on the 25th Feb 2015 to protect fluoridation - even though the review of scientific evidence had only recently commenced and the draft paper was not published until the 14th Sept 2016 – over 18 months later. In Feb 2015 a study by Peckham et al, a UK fluoride – hypothyroidism study (SEE QUESTION 5 FOR CITATION) had been released on 24th Feb 2015. Prof Anderson’s media statement starts “in response to recent media” he then reaffirmed the NHMRC position and stated “Based on the work already conducted in the review, NHMRC is expected to maintain its support for fluoridation as effective and safe” (THE PECKHAM THYROID PAPER HAD ONLY BEEN PUBLISHED THE DAY BEFORE! ) Prof Mike Morgan who is a member of the FRG and who has a confidential contract with Colgate was interviewed in an article in THE CONVERSATION and he had stated “To do a study like this and say there’s an association without taking into account other factors, and then say, we should reduce the levels of fluoride, well it beggars belief that they should be able to say that in a reputable publication,” he added. In the end the NHMRC FRG and the University of Sydney team apparently forgot that this landmark paper had been published, because no mention of it occurs in any of NHMRC’s three 2016 publications. It is this apparent that the then NHMRC CEO and FRG [NHMRC has removed third party information] will do anything to protect fluoridation. The NHMRC CEO making a Media Statement on 25 Feb 2015 is akin to a judge at the beginning of a trial – with new evidence still coming in, saying to the jury – don’t worry about the new evidence – the defendant is innocent! The only evidence the NHMRC would accept from the public in 2014 and again in 2016 were papers published since the 1st October 2006 and then only if they fit the full and almost impossibly restrictive criteria demanded by the NHMRC. In 2014 – public submissions to the NHMRC could not even exceed 500 words. The NHMRC public consultation pages were unnecessarily obstructive in their difficulty in the public using. Members of the public could not see the scope of the review in 2014, or in 2016 view the queries to be answered in submissions to the NHMRC unless they had registered an account and started a submission. When the NHMRC released a public Call for Evidence on 23 July 2014, studies on dental effects (caries and dental fluorosis) were “ OUT OF SCOPE “ as the Cochrane Collaboration ( which the NHMRC helps fund ) were already doing a review on water fluoridation looking at dental caries and dental fluorosis. The public were not allowed to submit papers on dental effects and it was also out of scope for the Sydney University team. A report (which morphed into “critical appraisal”) was to be written on the Cochrane report and it was to be placed on the NHMRC website. What transpired was, after the Cochrane review was published in June 2015, the NHMRC were obviously not happy with the unflattering to fluoridation results and the NHMRC secretly commissioned the Sydney University to do two more reviews – these being on dental caries and fluorosis. This was done secretly as the public were not advised, a new public Call for Evidence was not published. What was originally “out of scope“ for the review – but by secretly commissioning 2 additional reviews (that the public knew nothing about) dental issues then became “ in scope” . Very cunning, but to me this smacks of corruption. The NHMRC’s 2014 and 2016 extremely restrictive criteria for acceptable public submissions meant many significant studies could not be considered - Study must be published after 1 Oct 2006 Study must be published in English Study must only be a human study – animal studies not accepted No medical histories Study must only be about fluoride in water – no toothpaste or any other source of fluoride exposure was to be considered Total exposures – not considered – no exposure analysis was done If water fluoride concentration was more than 1.5 mg per litre, the study was downgraded or rejected because it was claimed not relevant to Australia. The 2006 Elise Bassin et al Osteosarcoma study and the EPA’s National Academy of Science “Fluoride in Drinking Water – A Review of EPA’s Scientific Standards”(NRC 2006) were not given proper consideration in NHMRC’s 2007 Review. The NHMRC, instead of giving proper consideration to the Bassin study, instead deferred to a Letter to the Editor by Chester Douglas promising a larger study. This study took 5 years to eventuate, was smaller, had a completely different Hypothesis to Bassin and did not in any way refute the key finding of the Bassin case control study (age related fluoride exposure – greater risk of developing Osteosarcoma in young men to 20 years of age) The 2006 Bassin study was not included in the 2016 NHMRC review – because it was published just before the NHMRC self-imposed deadline on 1 Oct 2006. This Osteosarcoma study was a very significant study and should now be considered in this review seeing as it was not given proper consideration in the 2007 review. The NHMRC 2007 review also inferred that the 2006 National Research Council report “Fluoride in Drinking water – A review of EPA’s scientific standards” (NRC 2006) was only about studies with water containing 4 mg per litre fluoride. This is absolutely incorrect and misleading. As the 2006 NRC study was a significant review and did an exposure analysis (Chapter 2) and the NHMRC did not consider in the 2007 review – it should be considered in the 2016 review. The 2007 NHMRC review did not consider (or even mention) cumulative effects of fluoride. Freedom of Information documents show that HT Analysts in a Conference call phone meeting with NHMRC executive staff, immediately prior to commencing the review for the 2007 NHMRC review, agreed that cumulative effects needed to be covered in their review for the NHMRC (particularly for kidney dysfunction) as per the NHMRC’s requirements - however nothing appears in the final 2007 NHMRC. There is also nothing on cumulative effects (particularly for kidney dysfunction) in the 2016 NHMRC paper – even though the NHMRC had personally advised me that this issue would be covered in the new review. The NHMRC rejected the standard terms for evidence quality by abandoning descriptors and deciding to describe evidence in terms of their confidence - See Page 54 – Technical report as follows - "The GRADE system for assessing evidence was not originally designed to consider evidence for public health interventions. Consequently, for public health interventions like water fluoridation, where evidence of efficacy comes from observational studies, much of the evidence will ultimately be rated as ‘low’ or ‘very low’ quality. Due to concerns that the potential pejorative connotations of these descriptors may result in the evidence being disregarded and/or misinterpreted, the Fluoride Reference Group decided to omit the descriptors and describe the evidence in terms of the confidence in the reported results." The NHMRC probably took this action pre-emptively because they knew that the quality of effectiveness studies would all be very poor and by doing this they could make the studies seem to be of better quality. With the NHMRC and Sydney University team declaring that the 2014 Jonathon Broadbent New Zealand IQ study was of “ high quality” and in fact, the only quality study found, is what actually beggars belief. In the 2014 public Call for Evidence, when putting the Broadbent IQ study forward for consideration, a warning was also put forward about the serious flaws in this study, particularly that there was no real control group as there more children taking fluoride tablets than there were children in the small control group. There were other issues too with the satellite suburb Mosgiel where the supposed control group children lived, having had the most corrosive ground water in New Zealand, known to leach copper from plumbing ( and most likely lead too ) however Broadbent did not control for this or some other significant confounders. Importantly, lead was not considered, even though Broadbent criticizes other F-IQ studies for not considering lead. Similarly, neither arsenic nor iodine are considered. Broadbent did not account for maternal IQ (although data had been collected) and only very crudely controlled for - SES socioeconomic circumstances. Apparently the FRG only provided the Broadbent IQ study citation to the Sydney University team and did NOT pass on the valid criticisms of the flaws of that study. It appears that the Sydney University team did not pick up that there probably little difference in fluoride exposure between the 2 groups and that could be why there was little difference in IQ found. The Cochrane Review says that it can be difficult to do a Randomised Controlled Trial (RCT) of water fluoridation. The NHMRC implies that RCTs are impossible. Not true! In Sept – Oct 2016 the Public not being able to submit comments on the Evidence Evaluation and the Technical Report – a bit like a country going to war on evidence that there were weapons of mass destruction – but no-one being allowed to criticise the evidence – how biased it was, how flawed it was or how incorrectly interpreted and falsely claimed what high quality evidence it was ( eg Broadbent study falsely being claimed high quality) Melbourne University’s involvement in NHMRC’s methodological review of fluoride’s health effects not acknowledged in any of the 3 NHMRC publications - yet - AusTender shows Melbourne University having had two contracts with the NHMRC (CN3312653 for the value of $16,709 with Contract Period 21 Dec 2015 to 30 June 2016) and (CN3296435 for the value of $ $13,864 with Contract Period 1 July 2015 to 31 Dec 2015. Why did the NHMRC in its recent 3 publications related to its fluoride review not ever disclose the Melbourne University’s involvement, what its role was for the not inconsiderable payment of over $30, 000 to that University? While in my own correspondence with the NHMRC my questions have been answered, although some, on first attempt somewhat vaguely and on my request, some docs have been provided ( eg Jurisdiction Fluoridation Meeting Outcome Notes - 20 June 2013.docx was provided to me on request on 13 Jan 2014) – however it has been discovered that when a colleague had later submitted an FOI to the NHMRC, the NHMRC requested an approximate payment of $500 to obtain that same 9 page document – even though the submitted FOI request made clear that no names or personal information was requested. This appears to be unnecessary obstruction by the NHMRC. I and others I have spoken too, believe that the NHMR’s actions and its perceived protection of water fluoridation apparently at any cost, is corrupt and worthy of a Royal Commission, or at the very least a Senate Inquiry into the NHMRC’s activities promoting and protecting water fluoridation no matter what.

Page reviewed: 4 July, 2017