NHMRC Public Consultations

The ADA recognises that the Information Paper is not within the scope of public consultation. It is provided for information only. That said, the ADA can state that the ADA guidelines relating to water fluoridation found in its Policy Statement 2.2 Community Oral Health Promotion; Fluoride Use [including ADA Guidelines on the Use of Fluoride] (https://www.ada.org.au/Professional-Information/Policies/Policy-Index/ADAPolicies_Index) matches the information provided in the information paper.

The ADA supports the draft Public Statement’s reference to evidence that fluoridated areas experience lower rates of potentially preventable hospitalisations for tooth decay. 

Regarding tooth decay, the draft Public Statement says that "Recent Australian research suggest that access to fluoridated water from an early age is associated with less tooth decay in young and middle-aged adults." While this is correct, the implication is that people older than this or people who did not have access to fluoridated water from an early age will not benefit from water fluoridation. The ADA infers that the NHMRC is being cautious as the total of all permanent teeth surfaces that are decayed (D), missing (M) due to decay, or filled (F) due to decay (DMFS) scores for older Australians do not show much difference.[1] The probable reasons for caution are outlined by Loc Do in the paper referred to in the first footnote. 

However, current evidence and biological plausibility strongly suggest that adults of all ages have stronger, more decay resistant teeth as a result of fluoridated drinking water, and this benefit also applies to people from the pre-fluoride generation who grew up prior to the common use of fluoride toothpaste and fluoridated water.[2] Access to optimally fluoridated water from an early age confers lifelong benefits and reduced decay rates at any age. Water fluoridation in Australia has been highly successful with very significant reductions in dental disease because many natural water supplies in Australia have naturally low fluorine levels.

With respect to dental fluorosis, the draft Public Statement implies that water fluoridation poses a risk for the development of moderate or severe dental fluorosis, but this risk is extremely low. The draft Public Statement fails to stress the impact of inappropriate uses of fluoride toothpaste or supplements or, more rarely, high levels of fluoride occurring naturally in a very small number of water supplies in the development of aesthetically concerning dental fluorosis.[3] All sources of fluoride ingestion at critical ages can contribute to dental fluorosis.[4] The potential for an inappropriately high fluoride intake is clearly greater from sources such as (unsupervised) toothpaste and supplements than from fluoridated drinking water. Mild and very mild dental fluorosis diminishes over time but, does not adversely affect oral health or perceptions of oral health. On the contrary, mild and very mild dental fluorosis is associated with stronger, healthier teeth and a better appearance and oral health related quality of life.[5]

Should you require further comment regarding the ADA’s feedback, please contact, the ADA Chief Executive Officer, [NHMRC has removed contact information].

Yours sincerely

Dr Hugo Sachs

Federal President

Australian Dental Association