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Draft NHMRC Public Statement 2017: Water fluoridation and human health in Australia submission

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Question 1
Q1. A. The draft Public Statement is presented in a format and manner that is useful, and is easy to read and understand: 
Overarching/General comments on the Public Statement: 

The draft Public Statement is false and misleading. Fluoridation of public water supplies is:

1. well recognized by clinicians and researchers to be medically unsafe, e.g. due to fluoride's proven effect as a neurotoxin;

2. known, based on comparison among country-level DMFT-12 outcomes compiled by WHO since 1960, to be ineffective for preventing dental caries; and therefore

3. cannot reasonably be described as "ethical".

Comments on a particular section of the Public Statement: 
Health outcomes

NHMRC's use of the qualifying phrase "at current Australian levels" appears to be deliberately misleading.

In the course of the prior public consultation process NHMRC, used this qualification to exclude extensive medical evidence showing that exposure to fluoride is hazardous. For example, NHMRC relied on this filter to exclude approximately 40 literature citations in relation to renal effects of fluoride submitted by well-qualified members of the public.

NHMRC's refusal to consider extensive clinical notes offered to it by [NHMRC has removed third party information] would appear to constitute criminal negligence at common law.

Question 2
Q2. A. The boxed ‘NHMRC statement’ (page one) in the draft Public Statement is justified and supported by the evidence in the Information Paper: Effects of Water Fluoridation on Dental and Other Human Health Outcomes : 
Q2. B. If disagree or neutral, please provide recent scientific evidence not previously submitted to NHMRC. Refer to what is ‘Out of scope for this public consultation’ below: 

NHMRC's purported limitation of evidence to "recent evidence" is scientifically unsupportable. Application of the scientific method would require that NHMRC consider all evidence, whether "recent" or not.

In relation to the well-known lack of efficacy of water fluoridation in preventing tooth decay, see e.g.

(a) M. Diesendorf, “The mystery of declining tooth decay”, Nature, 322:125-129, 1986.

(b) K. Cheng et al., “Adding fluoride to water supplies”, BMJ, 2007; 335; 699-702.

Question 3
Q3. A. For policy makers, the draft Public Statement provides sufficient information to support decision making in your jurisdiction or local area: 
Overarching/General comments on the Public Statement: 

Issuing a statement in the form of the draft Public Statement would be much worse than doing nothing because the draft Public Statement is false and misleading. In my opinion, the CEO of NHMRC and the members of NHMRC are well aware of this circumstance.

Comments on a particular section of the Public Statement: 
Question 4
Q4. How could the Public Statement be effectively disseminated?: 
General comments

NHMRC should not disseminate any statement to the effect of the Draft Public Statement.

NHMRC should instead develop, and the CEO of NHMRC should proceed to make, a regulatory recommendation to the effect that fluoridation of public water supplies in Australia cease immediately because:

(a) it is known not to be effective for preventing dental caries; and

(b) it exposes the public, particularly persons with special vulnerabilities such as chronic kidney disease, to serious health risks.

Question 5
Q5. Is there any other information that may be useful to include in the draft Public Statement? If so, please provide details: 

See response to Question 4.

Page reviewed: 9 November, 2017