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

ID: 
42
This submission reflects the views of
Individual Background: 
I worked in the field of Urban and Regional Planning
Personal Details
First Name: 
Jennifer
Last Name: 
Doran
Specific Questions
Q1. A) Is the draft Information Paper presented in a manner that is easy to understand? : 
Disagree
Q1. B) Please provide details regarding your response to Question 1A: 
Plain Language Summary

As a mother of young children, carer for my extended family and active participant
in my community, I look to the NHMRC to provide me and all Australians with
frank and fearless advice on health issues such as fluoridation. lt was therefore,
greatly disappointing to realise that this latest review of fluoridation is just another
whitewash and irrelevant document ignoring the needs of the Australian
community. NHMRC has apparently abandoned the holy grail of independent,
objective, scientific analysis in favour of "consistenc/ in supporting the
government policy of fluoridation. I sincerely hope that every member of the
[NHMRC has removed offensive information].
The Draft Information Paper is irrelevant to the needs of the Australian audience
because it provides only half the story. lt is written from a perspective of support
for fluoridation and its conclusions are not objective, failing to acknowledge
potential risks arising from a lack of information due to the poor quality of the
studies identified in the database search. lt was the recommendation of NHMRC
in t991that the organisation conduct its own research to investigate potential
adverse health effects and not simply rely on studies instigated by others. lt is
disappointing the NHMRC seems willing to rely on the excuse of "no available
evidence", rather than performing due diligence on behalf of the Australian
community - arguabfy not the most fluoridated nation on earth.
The Draft Information Paper is additionally irrelevant to the audience because it
assumes - wrongly - that the general health effects from fluoridation can only be
studied in the same manner as studies into dental effects. Rather, the study of
general health effects demands a "weight of evidence" approach - identifying
likely effects such as on kidney function and bone health and accumulating
evidence from a range of sources including in-vitro and animal studies but also
clinical trials. That sort of approach has been recommended in numerous
fluoridation reports: NHMRC 1991, US National Research Council 1993, NHMRC
1999, UK Medical Research Council 2002, WHO Environmental Health Criteria 227
2002, and US Nation Research Council 2006. lt is the only approach logically likely
to produce the sort of targeted results that will be needed to clearly identify
Lowest Observable Effect Levels so that proper safety factors can be applied.

The Draft Information Paper is irrelevant to an intelligent Australian population
because it fails to give the whole story, purporting that fluoridation is safe while
utterly failing to acknowledge the poor quality of evidence on which its conclusions
are based and in consequence the hidden risks, as well as NHMRC's refusal to act
responsibly by doing the necessary studies.

Q2. A) Is it clear how NHMRC reviewed the health and dental effects of water fluoridation? : 
Disagree
Q2. B) Please provide details regarding you response to Question 2A: 

The process is not clear because the Draft lnformation Paper glosses over the poor quality of evidence upon which it is based. The Paper also fails to identify that the NHMRC itself recommended that tactual research be done by and for Australia in order to clarify questions about potential risks to health from fluoridation - but this recommendation has never been followed up. Additionally, the Paper fails to acknowledge that health effects are not best studied in the same ecological manner as decay statistics, and demands a weight of evidence approach, drawing results from the full range of trials available, including in-vitro and animal studies and a variety of clinical interventions.

Q3. A) Is the Fluoride Reference Group’s interpretation of the evidence clearly described in the draft Information Paper?: 
Disagree
Q3. B) Please provide details regarding your response to Question 3A: 

No. For the same reasons as listed in Question 2.8.

Q4. Is there additional evidence on the dental effects of water fluoridation that should be considered?: 

NHMRC has dismissed and therefore, prohibited comment on many peer reviewed, scientific studies written in English that determine that any beneficial dental effects from fluoride occurs through topical application and not through ingestion. The benefit to dental health through fluoridation of drinking water is negligible, only a reduction of decay in one fraction of one tooth per child, far more benefit is to be gained from using fluoridated toothpaste. Yet NHMRC seems determined to support fluoridation of drinking water despite the evidence and is prohibiting comment on the studies that oppose this act. I am very disappointed with this consultation process.

Q5. Is there additional evidence on any other health effects of water fluoridation that should be considered in the draft Information Paper?: 

NHMRC has already dismissed concerns outlined in several peer reviewed, scientific studies written in English and has further instructed these are not to be commented upon. Furthermore, NHMRC has failed to undertake the extensive studies that were recommended over two decades ago. Therefore, it seems that NHMRC strongly supports water fluoridation despite evidence showing Fluoride can have significant negative impacts on human health. I am so very disappointed.

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 several reports from authority organisations mentioned in 1.8, including recommendations made by NHMRC, stating that a holistic look into the potential health effects of water fluoridation must be revisited and the recommended approach must be applied. This current "investigation" is inadequate, disappointing and biased without the necessary evidence. Furthermore, NHMRC's blatant disregard for more holistic studies on this matter is appalling and irresponsible, and we the Australian public deserve more.

Page reviewed: 4 July, 2017