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Say No to Fluoride

New Health Submission
MAKE a SUBMISSION
INFORMATION about the PROPOSAL
New Health Inc FLUORIDE LITIGATION
NEWS and MEDIA Information

Submission By New Health New Zealand Inc on Health (fluoridation of Water) Amendment Bill

 

2nd Feb 2017

New_Health_submission_to_Health_Select_Committee.pdf

New_Health_submission_Appendix_A.pdf

New_Health_submission_Appendix B.pdf

 

 
   

MAKE a SUBMISSION

   Click here to send your email submission to Medsafe

Clicking the above link will open a new email on your computer with the medsafe email addresses and subject.
Below is the content you can copy and paste into the email. Please feel free to change and add reasons as you see fit. Submissions are due by 9 January 2015.

--------------- copy below here ------------

Dear Medsafe

SUBMISSION ON PROPOSAL THAT HFA AND SSF ARE NOT MEDICINES FOR THE PURPOSES OF THE MEDICINES ACT WHEN THEY ARE MANUFACTURED AND SUPPLIED OR DISTRIBUTED FOR THE PURPOSE OF FLUORIDATING COMMUNITY WATER SUPPLIES

QUESTION 1: DO YOU SUPPORT THE PROPOSED AMENDMENT? IF NOT, WHY NOT?

ANSWER TO QUESTION 1

I oppose the proposed amendment for the following reasons:

1 = No Regulation should be made exempting HFA and SSF from being medicines until the Court of Appeal has determined whether or not HFA and SSF are medicines under the Medicines Act.

2 = If HFA and SSF are medicines they should not be exempt from the Medicines Act.

3 = If HFA and SSF are not medicines there is no need for the exemption.

4 = The Medicines Act is designed to ensure the safety, quality and efficacy of medicines.  HFA and SSF should be subject to these controls. 

5 = These controls will ensure that people are not exposed to uncontrolled doses of fluoride from an industrial grade and heavy-metal contaminated fluoride substance.

6 = If fluoride tablets are not recommended for babies, toddlers and pregnant women, these sub-populations should not be ingesting fluoridated water.

7 = No protection against dental decay is provided by swallowing fluoride; consequently HFA and SSF should not be swallowed.

8 = Those people who believe there is a benefit in ingesting fluoride can buy sodium fluoride tablets from a pharmacy.


QUESTION 2: ARE THERE ANY OTHER FLUORIDE-CONTAINING COMPOUNDS USED TO TREAT COMMUNITY WATER SUPPLIES THAT SHOULD BE SPECIFICALLY IN THE REGULATION? IF SO, WHAT ARE THEY?

ANSWER TO QUESTION 2:   NO.

I do not give permission for my personal details to be released to persons under the Official Information Act 1982.

Yours sincerely

-------- copy above here ---------

 

 

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INFORMATION ABOUT THE PROPOSAL

 

MINISTRY OF HEALTH PROPOSE TO EXEMPT TOXIC INDUSTRIAL WASTE PRODUCTS USED IN WATER FLUORIDATION FROM THE MEDICINES ACT 1981

If you are concerned about the risks of water fluoridation to human health, you need to act now to have your say.

The Ministry of Health is consulting on a proposal to exempt the water fluoridating chemicals Hydrofluorosilicic acid (HFA) and Sodium Silico Fluoride (SSF) from being medicines under the Medicines Act 1981. Submissions are due by 9 January 2015.

HFA and SSF are toxic by-products of the superphosphate industry that may also contain arsenic, mercury and lead. This point is not disputed by the Ministry of Health.  

Fluoridated water delivers uncontrolled doses of HFA and SSF to entire populations without informed consent. The effect of exempting these products, which are currently being used as medicines (to prevent dental decay) from being medicines under the Act, regularises this.

As the Ministry of Health itself acknowledges in its consultation document, there is “no universal acceptance of the positive health effects of the addition of fluoride to drinking water supplies”. While there is some scientific evidence that the topical use of fluoride (i.e. on the tooth surface) helps prevent dental decay, the weight of scientific evidence is that ingesting (swallowing) fluoride does not provide any protection against tooth decay.

Fluoride risks

Excessive ingestion of fluoride has been linked to a number of health harms including dental fluorosis, skeletal fluorosis, bone fractures, IQ deficits, osteosarcoma, and thyroid impairment.

A person living in a fluoridated community has no choice but to consume fluoridated water. One litre of fluoridated water contains up to 1 mg of fluoride, which is the stated maximum  medicinal dose of fluoride for an adult consuming fluoride tablets. Given that a person’s dose of fluoride from water fluoridation depends on how much fluoridated water they consume, many people would exceed this dosage:

  • The stated maximum medicinal dose of fluoride for infants and toddlers and pregnant women is zero. Any baby or toddler or pregnant woman drinking fluoridated water instantly exceeds this dose. 
  • The  stated maximum medicinal dose of fluoride for 6 to 8 year olds is 0.5 mg. A child in this age group drinking 1.2 litres (the recommended daily fluid intake for a 6-8 year old) of fluoridated water receives twice the stated maximum medicinal dose of fluoride.
  • Any adult drinking more than 1 to 1.5 litres of water a day will exceed the stated maximum medicinal dose of fluoride.

Anyone who believes ingesting fluoride is beneficial can buy sodium fluoride tablets from a pharmacy.

Exercise your right to independent scrutiny of fluoridation

It’s important for you to make your views known. The Ministry of Health’s determination to seek an exemption for HFA and SSF under the Medicines Act pre-empts the outcome of an Appeal against a recent High Court decision New Health NZ Inc v Attorney General, which held that HFA and SSF are not medicines. Should the Appeal succeed, and find that they are medicines for the purposes of the Act, they should not be exempted. 
The link to the Ministry of Health’s consultation document can be found at:
http://www.medsafe.govt.nz/consultations/medicine-regulations-fluoride-in-drinking-water.asp

Fluoride Risk Comparing SSF and HFA chart

 

Sodium fluoride tablets (pharmaceutical grade)

HFA and SSF (industrial waste)

Claimed Purpose

Prevent tooth decay

Prevent tooth decay

Status

Medicine: Pharmacy-only medicine (ie illegal to be supplied by councils) subject to purity and other manufacturing standards set out in Medicines Act and Regulations

Hazardous substance: Toxic by-product of the superphosphate industry that may also contain arsenic, mercury and lead.
NB this fact is not disputed by the Ministry of Health

Concentration

Each tablet contains 0.5 mg of fluoride

Up to 1 mg of fluoride per litre of water

Recommended Maximum Dose of Fluoride

Not to be taken by children under 3 or during pregnancy.
3 to 5 years: half a tablet daily
6 to 8 years: 1 tablet daily
Adults: Two tablets daily. 

Dose is uncontrolled and depends on how much water is drunk by each individual.  Many children and adults will exceed maximum daily recommended medicinal doses.  Babies, infants and pregnant women should not be drinking any fluoridated water.

Informed consent

Yes

No

 

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NEW HEALTH INC FLUORIDE LITIGATION

 

5th Jan 2015

Exposed - the real reason the MOH wants urgent amendment to the medicines regulations.

read the PDF click here


Submission from New Health NZ Inc to Medsafe 24th Dec 2014

click here for the PDF


 

Fluoride litigation (Medicines Act) – New Health NZ Inc v Attorney-General (High Court)

  1. Judgment
    Decision of David Collins J dated 9 October 2014
  2. Pleadings
    Statement of claim
    Statement of defence
  3. Plaintiff’s evidence (New Health)

1st Affidavit of David Sloan
2nd Affidavit of David Sloan
3rd affidavit of David Sloan
1st affidavit of David Menkes
2nd affidavit of David Menkes

  1. Defendant’s evidence (Attorney-General)
    Jessamine affidavit
    Prendergast affidavit
  2. Plaintiff’s submissions
    Defendant’s submissions



 

 
 

Fluoride Litigation – New Health NZ Inc v South Taranaki District Council (High Court)

click the links below for the PDF's
  1. Judgment
    Decision of Rodney Hansen J dated 7 March 2014
  2. Pleadings
    Amended statement of claim
    Statement of defence to amended statement of claim
  3. Attorney-General’s application to intervene
    Application to intervene
    Memorandum in support of application
    Minute of Heath J (No 3)
  4. Plaintiff’s evidence (New Health)
    1st Affidavit of David Menkes
    2nd Affidavit of David Menkes
    Affidavit of Martin Ferguson
    Affidavit of David Sloan
    Affidavit of Kathleen Thiessen
    Affidavit of Stamoulis Litras
    Affidavit of Mark Atkin
    Paul Connett’s affidavit
  5. Defendant’s evidence (South Taranaki District Council)
    Whyman affidavit
    Wilkinson affidavit
    Pryor affidavit
    Simmons affidavit
    McMillan affidavit
    Haisman-Welsh affidavit
  6. Attorney-General (intervener’s) evidence
    Affidavit of Stewart Jessamine
  7. Submissions
    Plaintiff’s submissions
    Defendant’s submissions
    Attorney-General’s submissions
   
 

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NEWS and MEDIA information

 

19th May 2015

Here is a video of a fluoridation debate on East Brunswick TV in which Paul Connett PhD participated yesterday (May 14 2015). His opponent was past president of the NJ Dental Association

http://vp.telvue.com/preview?id=T01258&video=236578


 

Anti-fluoridation lobby chews out "sneaky" Crown

The Crown was "sneaky and self-serving" in the way it regulated in an attempt to cut off an avenue of challenge for anti-fluoridation campaigners, the Court of Appeal has been told.

In the court on Wednesday, lawyer Lisa Hansen said New Health NZ had significant concerns about the way a regulation was made exempting fluoridation chemicals from being "medicines".

read full article

Date of Hearing: 29 April 2015

CA615/2014 New Health New Zealand Incorporated v Attorney-General for and on behalf of The Minister of Health

MINUTE OF THE COURT

Judges: Randerson, Miller and Cooper JJ

This is an appeal from a judgment of Collins J delivered on 9 October 2014, in which he held that hydrofluorosilicic acid (HFA) and sodium silico fluoride (SSF) are not medicines under the Medicines Act 1981 (the Act).1 HFA and SSF are currently used to fluoridate domestic water supplies in New Zealand.

attached PDFs
Minute of the Court
Newspaper article Dominion Post


 

21st April 2015

Amendment of submission to Greater Wellington Regional Council on the 10 Year Plan 2015-2025

I refer to the submission below and wish to correct an error.

The calculation of 39 tonnes of SSF powder should read 64 tonnes. 

The reference to 39 tonnes related to elemental fluorine.


20th April 2015

Submission to Greater Wellington Regional Council on the 10 Year Plan 2015-2025

-------------------------------------------------

While the Council was not expressly addressing the issue of fluoridation, New Health has made a submission asking for it to revisit its policy.

A link to the consultation document is attached.  Consultation closed at 4 pm on 20 April 2015

http://www.gw.govt.nz/10-year-plan-2015-2025/

attached PDF with submission
Open letter from New Health NZ Inc to Sir Peter Gluckman and Sir David Skegg.pdf

-------------------------------------------------

This submission is made on behalf of New Health New Zealand Inc. 

New Health requests the Council to revisit its fluoridation policy and practice.

It is New Health’s submission that fluoridation:

  1. Is unnecessary and anachronistic;
  2. Constitutes mass medication without consent;
  3. Provides little or any benefit – at best half a filling saved by age 12 or 13;
  4. Poses real risks of harm to health;
  5. Uses the water supply to dispose of a highly toxic industrial waste product where the relative environmental impacts of disposing of such a substance are unknown.

One of the key issues identified in the consultation document “Shape Your Region”, is a “Healthy Environment”.  There is a reference to “proactive steps to reduce long-term risks”, and “best practice science information to assist decision-making”.

Applying these tenets to fluoridation, New Health makes two points.

First, for the reasons set out in the attached letter to Sir Peter Gluckman and Sir David Skegg, applying the precautionary principle to fluoridation would justify its immediate cessation.

Secondly, the environmental impacts of disposing of HFA and SSF through the water supply is unknown. Again a precautionary approach would require this unnecessary practice to stop.

The volume of fluoride disposed of through the water supply each year is enormous. 

According to the WRC’s Water Supply Annual Report for the year ended 20 June 2014, there is approximately 140 million litres of water supplied per day and 51.1 billion litres per year.  On the basis of fluoridation at 0.75 mg/l this amounts to 38.325 billion mg of fluoride per year.  On New Health’s calculations that would amount to approximately 39 tonnes of SSF powder.

As the WRC is aware most fluoridated water is not drunk but is used for other domestic purposes in kitchens and bathrooms, and for watering gardens, washing cars etc.  Most will end up in the environment on the land or in the water.

It is telling that the relative environmental impacts of the discharge of this amount of fluoride into the environment is unknown: refer p 17 of the Water Supply Annual Report.

If an SSF producer wanted to discharge 39 tonnes of SSF into the environment, it would need a number of different consents.  Why is this substance able to be disposed of through the water supply with no consideration given to the adverse environmental effects of such disposal and with no resource management oversight?

New Health wishes to be heard in support of its submission.



 


26th Feb 2015

New Health is concerned that the recent Gluckman/Skegg report has attempted to dismiss and even trivialise a potential 7 point shift in IQ as a result of increased fluoride ingestion. It has written to Sir Peter Gluckman asking for an explanation. It has also sent the letter to all Councils and DHBs. New Health has asked health officials to start ask themselves the following question: Can the purported benefits of fluoridation – a possible saving of half a filling by age 12 to 13 – outweigh the possible risks of a reduction in IQ.

Gluckman Review downplays risk to IQ from fluoridation.pdf

Open letter from New Health NZ Inc to Sir Peter Gluckman and Sir David Skegg.pdf


4th Jan 2015

Fluoride critics slam law 'rush'

http://i.stuff.co.nz/national/health/64640651/Fluoride-critics-slam-law-rush


3rd Jan 2015

Fluoride critics slam law 'rush'

https://nz.newshub.org/fluoride-critics-slam-law-rush-8839562.html


19th Dec 2014

New code of practice for fluoridation

A new code of practice for the use of fluoride in drinking water supplies has been released by Water New Zealand.

http://www.radionz.co.nz/national/programmes/morningreport/audio/20161706/new-code-of-practice-for-fluoridation click link to listen to audio

RadioNZ web site article below

http://www.radionz.co.nz/news/national/262175/new-code-for-water-fluoridation


18 December 2014

New Health NZ Inc.

Media Statement

Fluoride risks whitewashed in rushed Ministry of Health consultation
Ministry of Health propose to exempt toxic industrial waste products used in water fluoridation from the Medicines Act 1981

New Health NZ urges anyone who is concerned about the risks of water fluoridation to human health, to have their say on a Ministry of Health proposal that is out for public consultation over the Christmas break.

The Ministry’s proposal is to exempt the water fluoridating chemicals Hydrofluorosilicic acid (HFA) and Sodium Silico Fluoride (SSF) from being medicines under the Medicines Act 1981. Submissions are due by 9 January 2015.

“We question the timing of this as it pre-empts the outcome of an Appeal against a recent High Court decision New Health NZ Inc v Attorney General, which held that HFA and SSF are not medicines. Our view is that should the Appeal succeed, and find that they are medicines for the purposes of the Act, they should not be exempted,” says New Health NZ chairman David Sloan.   

Fluoridated water delivers uncontrolled doses of HFA and SSF to entire populations without informed consent. The effect of exempting these products, which are currently being used as medicines (ostensibly to prevent dental decay) from being medicines under the Act, regularises this. HFA and SSF are toxic by-products of the superphosphate industry that may also contain arsenic, mercury and lead.

“A significant number of New Zealanders are already hugely concerned by this issue. Our decision to pursue the Appeal, and to encourage people to make their views known to the Ministry of Health about its proposal, reflects the importance of ensuring we all have the basic human right of choosing what goes into our bodies,” says Mr Sloan.

A person living in a fluoridated community has no choice but to consume fluoridated water. Excessive ingestion of fluoride has been linked to a number of health harms including dental fluorosis, skeletal fluorosis, bone fractures, IQ deficits, osteosarcoma, and thyroid impairment.

One litre of fluoridated water contains up to 1 mg of fluoride, which is the stated maximum medicinal dose of fluoride for an adult consuming fluoride tablets.

“Given that a person’s dose of fluoride from water fluoridation depends on how much fluoridated water they consume, many people would exceed this dosage. For example, any adult drinking more than 1 to 1.5 litres of water a day, not to mention babies/toddlers and pregnant women whose stated maximum medicinal dose of fluoride is zero,” says Mr Sloan.

While there is some scientific evidence that the topical use of fluoride (i.e. on the tooth surface) helps prevent dental decay, the weight of scientific evidence is that ingesting (swallowing) fluoride does not provide any protection against tooth decay. For those who believe there is a benefit in ingesting fluoride, there is the option of buying sodium fluoride tablets from a pharmacy.

New Health NZ Inc has asked the Ministry of Health to extend the timeframe for public submissions, given it is not considered best practice to offer a limited timeframe for public consultation over the Christmas and New Year holidays.

For more information and to make a submission, go to www.newhealth.co.nz/sayno.php. The Ministry of Health’s consultation document and any updates on its consultation timeframes are available at www.medsafe.govt.nz/consultations/medicine-regulations-fluoride-in-drinking-water.asp.

ENDS


17th Dec 2014

Thames to determine fluoridation by referendum

Thames-Coromandel Council, Fuseworks December 17, 2014, 2:30 pm

Thames Ward voters will have a binding referendum in 2015 to determine whether or not their water supply will continue to have fluoride added. read full article


9th Oct 2014

Anti-fluoride bid fails

http://www.stuff.co.nz/national/health/10599033/Anti-fluoride-bid-fails
A High Court Judge has thrown out an application by opponents of fluoride trying to force the Ministry of Health to treat it as a medicine and regulate the amount added to tap water.
Anti-fluoride group New Health New Zealand had claimed it was absurd that fluoride tablets were deemed a medicine under the act but fluoride added to tap water was not.
However, Justice David Collins ruled when Hydrofluorosilicic Acid (HFA) and Sodium Silico Fluoride (SSF) were added to domestic water supplies in New Zealand to produce fluoride concentrations within the current allowable level of 1.5 milligrams per litre they were not medicines within the meaning of the Act.
read full article


3rd Oct 2014

Fluoride opponents continue the fight

Dominion Post 3rd Oct 2014

Opponents of fluoride are trying to force the Ministry of Health to treat it as a medicine and regulate the amount added to tap water, the High Court at Wellington has been told.

But even should they succeed, the ministry plans to exempt immediately fluoride added to public water supplies from the Medicines Act.

Lisa Hansen, for anti-fluoride group New Health New Zealand, told the court yesterday it was absurd that fluoride tablets were deemed a medicine under the act but fluoride added to tap water was not.

read full article or download PDF paper clipping from Dominion Post here


26th March 2014

Media statement on behalf of David Sloan, Chairman of New Health New Zealand Inc. 

download Media Statement 26th March 2014 PDF

Fight to remove fluoride taken to Court of Appeal

-NZ Herald

A group fighting the fluoridation of New Zealand water supplies is taking its battle to the Court of Appeal.
New Health NZ Inc today filed a notice of appeal against a recent High Court decision upholding the lawfulness of water fluoridation by councils.
read article here

Media statement on behalf of David Sloan, Chairman of New Health New Zealand Inc. 

New Health has read the decision and respectfully disagrees with the judge’s interpretation of the Local Government Act, Health Act and NZ Bill of Rights Act.  In particular it disagrees with the judge’s view that fluoridation is not medical treatment for the purposes of s 11 of the Bill of Rights.

It will appeal the decision.

There is a persuasive and respectable body of scientific and medical evidence that water fluoridation is of doubtful benefit and there are risks of harm.

In today’s consumer-enlightened era, people should have the choice whether or not to ingest something that has a claimed therapeutic purpose.

No other public health measure removes a person’s choice in the same way as fluoridation. 

Comparing water fluoridation with water chlorination and iodised salt is simply wrong.  Iodine is an essential nutrient but fluoride is not.  Further people have a choice whether to buy iodised or non-iodised salt.

Water chlorination treats the water by eliminating bacteria, whereas fluoride claims to treat dental decay.  These purposes are quite different.

New Health is concerned at some of the implications of the decision.  For example on its face it permits councils to put medicines such as the claimed mood-enhancer lithium in the water supply.  Additionally the water supply potentially could be a delivery system for vaccines. 

Delivering medication this way is contrary to medical ethics as its fails to control for dose, individual need and sensitivities, and overrides individual consent. 

Kind regards

Dave Sloan

New health NZ Inc


2013

New Health New Zealand Incorporated has employed Wellington Barrister Lisa Hansen to challenge the South Taranaki District Council on their decision to fluoridate the water supply. The hearing is scheduled for 25-26 November 2013. Further updates will be posted on the website after the hearing.


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