NHMRC: NO safety studies

Overview

In two comprehensive published reviews on water fluoridation in 1991 and 1999, Australia’s National Health and Medical Research Council (NHMRC) included numerous recommendations for safety studies and trials to be conducted. These responsible recommendations were especially relevant given the already significant body of research showing potential damage to various aspects of our physiology as a result of the low-level ingestion of fluoridation chemicals.

In about 2004, both of these substantial reviews – with their serious health recommendations – were “archived” or “rescinded”. The 1991 review was archived – purportedly no longer relied on by NHMRC; while the 1999 review was rescinded due to being purportedly “unfinished”, and since then has not been publicly distributed or validated by NHMRC. Other researchers do refer to both the 1991 and 1999 reviews.

Nevertheless, to this day, NONE of these significant recommended safety studies have been undertaken by NHMRC and nor have the serious matters raised in those reviews been specifically investigated by them.

It is therefore reasonable to ask if NHMRC has in fact rescinded or archived these documents specifically to hide its own previous recommendations regarding the need for specific investigations into potential adverse health effects, thereby protecting its own reputation and this popular, entrenched policy.

The two fluoridation reviews examined

The two fluoridation reviews we refer to, and provide excerpts from, were published by NHMRC, as follows;

1. “The Effectiveness of Water Fluoridation”; NHMRC, March 1991 (available here); and
2. “Review of Water Fluoridation and Fluoride Intake from Discretionary Fluoride Supplements”; NHMRC, 1999 (available here).

1. “The Effectiveness of Water Fluoridation”; NHMRC, March 1991.

Note:   Two versions of the 1991 review are available – one originally provided by NHMRC in 2004 (available here), and a ‘rescinded’ version provided to PMHC in April 2016 (available here.)
Both versions appear to have the same content, but their pagination is different.

• Page references for the original 1991 document appear below in (round brackets); and
• Page references for the rescinded 1991 document appear below in [square brackets].

Health Study Recommendations

B. Review of evidence (p 14) [p 6]

9. “However, there have been no systematic epidemiological studies of skeletal fluorosis in fluoridated and non-fluoridated areas … the Working Group recognises that the deposition of fluoride in bone provides a reason for monitoring the future bone cancer rates in human populations in relation to their fluoride exposure.”

Our summary of the recommendations:

• The incidence of bone cancer should be monitored in relation to fluoride exposure.

D. Recommendations (p 18) [p 10]

3. “That proposals be developed to: develop monitoring mechanisms to document total fluoride intakes by adults with a view to estimating levels of deposition in bone, bearing in mind that water fluoridation at around 1 ppm appears, on present evidence, to be the main single source of fluoride intake in adults.”

Our summary of the recommendations:

• There should be careful and systematic analysis of fluoride accumulation in bone.

6. Considerations of possible toxicity and of safety margins

6.1 Introduction (p 78-79) [p 79]

“It is important to consider safety margins in relation to more than the ‘average exposure’, since individuals may vary substantially in the total external dose of exposure that they receive and in their biological susceptibility to that exposure. With respect to daily ingestion of fluoride, a 10- to 20-fold variation has been estimate between adult individuals. A safety factor of 10 is normally assumed to provide protection for high-risk groups. Any other major uncertainties must be compensated for by increasing this safety factor.

“The human and animal databases on fluoride toxicology are extensive. Therefore, despite the uncertainties inherent in the approach described above, some aspects of fluoride toxicity in man may be evaluated with a degree of confidence usually not available with other food-borne or environmental chemicals.”

Our summary of the recommendations:

• Existing human and animal fluoride toxicological studies should be mined, and a safety factor of at least 10x adopted to provide protection for high-risk groups.

6.4 Skeletal fluorosiss (p 84) [p 84]

“Approximately 50 per cent of ingested fluoride is excreted by the kidneys (if they are healthy) and almost all of the remainder is deposited in the skeleton. Although this skeletal deposition is not permanent (being subject to dynamic equilibrium between intake and excretion) the net effect is a tendency for fluoride to cumulate in bones with increasing age (Murray, 1986).”

“It also seems that fluorosis is more likely in populations which are malnourished (Srikantia, 1985). Theoretically, people with impaired renal function are at greater risk of developing skeletal fluorosis and two US cases of skeletal fluorosis are recorded in patients who had been exposed to water fluoride levels of 1.7 and 2.6 ppm, Juncos and Donadio (1972).”

“The advent of fluoridated toothpastes in Australia has almost certainly increased fluoride deposition in the bones of some Australians. It would not be surprising if there were some undetected cases of skeletal fluorosis in the Australian population in individuals with pathological thirst disorders and/or impaired renal function. However, the matter has not been systematically examined. This matter should be the subject of careful and systematic review.”

Our summary of the recommendations:

• There should be careful and systematic analysis of fluoride accumulation in bone, skeletal fluorosis, and any relationship with impaired renal function.

6.6 Carcinogenicity (p 89) [p 86]

“The current NHMRC Working Group also concurs with the Knox Report which noted in its conclusions: “It is desirable, nevertheless, that cancer rates should continue to be examined in fluoridated areas; even though there is no reason to anticipate that fluoridation will influence cancer rates, such surveillance should, out of prudence, be a routine.” (Knox, 1985).”

Our summary of the recommendations:

• There should be routine surveillance of cancer rates in fluoridated areas.

8. Future monitoring and research in Australia

8.1 Introduction (p 105-106) [p 110]

“It has been a surprise to members of the Working Group to discover that, on the one hand, Australian and New Zealand critics of fluoridation have been at the forefront of the international debate on this public health measure while, on the other hand, the profluoridation argument has relied extensively on overseas studies and data. Australia has, more than most countries, invested heavily in fluoridation as a public health measure (and this has achieved beneficial results), but it has contributed less to the fundamental body of knowledge which is, and will continue to be, essential if water fluoridation is to continue as a national and regional preventive strategy.”

“It is a matter for concern that the Working Group cannot point to a single ongoing Australian study which monitors adequately the impact and possible adverse consequences of this policy, and that in its pursuit of the terms of reference, the Working Group has had to rely on: indirect analyses of very inadequate datasets, collected not for the monitoring of this policy but for other purposes; a limited number of Australian studies; and upon overseas investigations of these matters. The Working Group’s recommendations and conclusions are the consequence of its attempts to arrive at the best possible assessment of the likely risks and benefits of continuing fluoridation at the present level, or of adopting alternative policies. Those recommendations and conclusions must be qualified by emphasising the current dearth of an adequate evaluative Australian database.

“The fact that substantial (but possibly lesser) improvements in dental public health are being achieved in other countries through the application of discretionary fluorides, and without the necessity for mass supplementation through water supplies, makes it particularly important that the NHMRC establish an effective monitoring and research programme in relation to its water fluoridation policy. This programme must extend beyond the dental public health domain, and should include a consideration of the broad impact of fluoride supplementation on human health and ecology. The opportunity offered by the differential timing and variable use of water fluoridation in different Australian cities should be used to design studies which will inform the debate not only here but overseas.

“Accordingly, the Working Group proposes to the NHMRC that it should take immediate steps to rectify this. Serious deficiency, and that it should take the lead in commissioning or inviting expressions of interest to study the following aspects of the question.”

Our summary of the recommendations:

• Water fluoridation must be accompanied by active research. Australia – as a major fluoridating nation – should be a leader in monitoring and research across all aspects: water fluoridation and its dental alternatives, and also fluoride’s effect on human health more generally.
• Use should be made of differential fluoridation status in different parts of Australia, to make comparisons of effects.

8.3 Total fluoride intake and public health (p 107) [p 112]

“There are no Australian reports which permits the Working Group to precisely estimate, with confidence, the current intake of fluoride which various aged individuals are ingesting, nor the differential amount of fluoride which is being stored in Australian skeletons, in fluoridated and unfluoridated areas. Australia is reliant on overseas studies for assumption that these amounts are likely to be small enough to present no risk to long term health.

“The evidence arising from the NTP studies which have led the NHMRC Committee on Toxicity to classify fluoride as an “equivocal” carcinogen in high dosage in rats makes it imperative that public health recommendations in the future be based on accurate knowledge of the total fluoride intake of Australians. Accordingly, the Working Group believes that proposals to monitor this load should be developed for various indicator populations within Australia and that these studies should take account of the range of deliberative and involuntary intakes which are occurring in both normal and susceptible individuals, in both fluoridated and unfluoridated areas.”

Our summary of the recommendations:

• There must be accurate knowledge and monitoring of fluoride intake from all sources and of fluoride storage in bone, in various indicator and susceptible populations and for the range of fluoride intake.

8.4 Monitoring for toxicity (p. 108) [p 112-113]

“Dental fluorosis is a sensitive indicator of storage of fluoride in teeth during the developmental stages of tooth formation, but does not indicate the amount of fluoride which is being incorporated into bone throughout adult life. The Working Group has no evidence that this latter amount is rising to troublesome levels, but neither has the issue been studied in any systematic way. If skeletal fluorosis is occurring at all in Australians, it is likely to be slight, and will most likely occur in those who drink large amounts of fluoridated water, or whose renal function is impaired. Studies of bone fluoride collected at autopsy in selected individuals could provide needed reassurance that the current policy is not resulting in hazardous levels of bone accumulation.

“The Working Group remains unconvinced by very limited published reports in the overseas literature, and sporadic claims by Australian individuals, of a significant problem with allergy or hypersensitivity to fluoride in the water supply. It is desirable to explore in a rigorous fashion whether the vague constellation of symptoms which are claimed to result from ingestion of fluoridated water can be shown to be reproducibly developed in these “susceptible” individuals. These claims are being made with sufficient frequency to justify well-designed studies which can properly control for subject and observer bias.

“Community concerns at the possibility that fluoride might, in certain circumstances, act as a carcinogen have surfaced repeatedly and have been heightened by the “equivocal” findings in the NTP rodent studies discussed elsewhere in this report. Fluoride intake of some degree is universal, and discretionary intakes of added fluoride are very widespread in the Australian population. During the conduct of any future epidemiologic studies, it will be very difficult to determine the levels of fluoride to which cancer sufferers and selected controls have been exposed, but systematic efforts to determine this are highly desirable.

“These issues also deserve the attention of a multidisciplinary group, backed by sufficient funds to initiate rigorous studies which can contribute information to the international knowledge base on these matters.”

Our summary of the recommendations:

• There should be bone fluoride analysis on autopsy of individuals selected so as to assess fluoride accumulation over a lifetime, e.g. individuals with renal impairment or high volume water consumers.
• The potential for fluoride hypersensitivity should be rigorously examined.
• Ways should be found to study the relationship between degree of individual fluoride exposure and the incidence of cancer, using a multi-disciplinary approach.

8.5 Costs and benefits of different approaches to caries protection (p 109) [p 113]

“The final judgement about the value of a fluoridation program cannot be made exclusively in economic terms. However, a comprehensive review of the economic consequences of maintaining fluoridation is required and the Working Group believes that an updated approach using more conservative assumptions about the level of protection which water fluoridation now provides, should be attempted, as an adjunct to decision-making on this matter.”

Our summary of the recommendations:

• There should be a comprehensive analysis of the economic consequences of fluoridation, using different assumptions of the dental effectiveness of fluoridation.

9. Conclusions and recommendations

9.1 Historical background and general summary (p 109-110)

“There have been two long-standing public concerns over the addition of fluoride to drinking water. One concern is that fluoride at raised levels of intake may have adverse effects upon health. The other is that water fluoridation encroaches upon civil liberties, since it entails an involuntary exposure.”

“Considerations of effectiveness, cost-effectiveness and population coverage all continue to favour water fluoridation as the preferred primary source of supplementary fluoride. However, the fact that fluoride in drinking water constitutes an involuntary exposure necessitates a particular requirement for public health policy on this matter to be both up to-date and prudent.

“While, on the available evidence, there is no justification for lowering the fluoride concentration in drinking water, public health prudence requires that this option be kept in mind in the course of future public health surveillance and evaluation. Whereas avoidance of excessive individual exposure in young childhood is best approached by controlling the intake of discretionary fluoride, avoidance of excessive exposure of the community to lifetime cumulation of fluoride would, if required, be best approached by reducing the concentration of fluoride in drinking water.”

Our summary of the recommendations:

• Water fluoridation is a convenient method to deliver supplementary fluoride, but involves involuntary (compelled) exposure. Therefore it is essential that policy be informed by the best available evidence.
• Policy-makers must always remain open to the option of lowering the fluoride concentration in drinking water to reduce fluoride intake, especially for adults based on lifetime consumption. (See also p 104)

9.2 Major conclusions (p 110-112) [p 114-115]

“The major conclusions from the above review are:

4. “The recent equivocal evidence of increased risk of bone neoplasms in one species of experimental animals exposed to very high doses of fluoride indicates a need for a raised and ongoing attentiveness to these (and any other) possibilities of adverse effects in human populations experiencing lifelong exposure to fluoride supplementation.”
5. “If, in the light of future health surveillance, there were any future need for a community-wide reduction in long-term exposure to fluoride in adults, this would be best achieved by reduction in the concentration of fluoride in drinking water.”

Our summary of the recommendations:

• There should be more attention to the possibility of adverse health effects over a lifetime of fluoride exposure. The best way to reduce long-term exposure would be to lower the concentration of fluoride in drinking water.

9.3 Recommendations (p 112) [p 117]

“develop monitoring mechanisms to document total fluoride intakes by adults with a view to estimating levels of deposition in bone, bearing in mind that water fluoridation at around 1 ppm appears, on present evidence, to be the main single source of fluoride intake in adults.”

Our summary of the recommendations:

• In designing fluoride intake monitoring, recognise that water fluoridation appears to be the main single source pf fluoride intake. (That may seem obvious, but NHMRC fluoridation reviews have not expressed consistent statements on this topic).

Our conclusion – 1991 Review

It is clear that the 1991 reviewers intended that NHMRC should adopt a pro-active approach to the investigation of potential or even possible adverse health effects from fluoride consumption, with a significant number of specific recommendations for action.

It is therefore of great concern that NHMRC has purported to “rescind” the 1991 fluoridation review.

2. “Review of Water Fluoridation and Fluoride Intake from Discretionary Fluoride Supplements”; NHMRC, 1999 (three versions, see below).

Health Study Recommendations

Since its publication, distribution and indeed its use as a source of published reference (Spencer letter attached, see page 5), NHMRC have advised that the 1999 review document was never “finalised”, and should not be relied upon.

FFA is in possession of three (3) versions, all apparently with the same content:

• one version as originally published, (available here).
• one version marked “archived” and received from Mid North Coast Area Health in about 2005 (copy available if required); and
• one version marked “DRAFT REPORT – RELEASED FOR PUBLIC CONSULTAION (sic) IN APRIL 1999. THIS REPORT WAS NEVER FINALISED OR ENDORSED BY THE COUNCIL OF NHMRC”. (Copy available if required. This version was sent to PMHC by NHMRC in/around April 2016).

Extracts from the 1999 review:

“The purpose of this review is to gather and evaluate the scientific evidence since 1990 in relation to the health effects of fluoridated water and fluoride from other sources, and based on this evaluation, formulate recommendations to the Health Advisory Committee (HAC) of the NHMRC on the appropriate use of fluoride.” (p ii)

Comment: The focus is on fluoride and dental effects, with recommendations regarding fluoride supplements. There is some minimal discussion on general health effects, concluding that there is insufficient evidence to recommend a lowering of the fluoride concentration in water.

It is nevertheless recommended (Chapter 8, page 10) that “9. In relation to Fact Sheet 51 (ADWG), while maintaining the optimal levels of fluoride in drinking water between 0.6 and 1.1 ppm subject to climatic variation, and in consideration of the availability of discretionary sources of fluoride exposure, we recommend a revision of the Guideline Value from 1.5 mg/L to 1.2 mg/L. This value is recommended to protect against the occurrence of dental fluorosis in children aged from birth to six years.” The same recommendation appears in Chapter 9, summary.

Comment: Unfortunately that change is unlikely to have any actual protective effect on the population as, even prior to 1999, no artificial fluoridation is conducted in Australia at >1mgF/L. So we are perplexed as to the intended efficacy of the recommendation.

Infants

In Chapter 2 (p. 3), it is noted that infants under six months should receive no supplementary fluoride even if local water is not artificially fluoridated.

In Chapter 8 (p. 9) it is recommended that no supplementary fluoride should be given to children under 3 years, even if they live in an unfluoridated area.

The reasoning behind those changes are cited at Chapter 6, page 2):

“Recommendations from professional bodies regarding fluoride intake:

“In 1986, the American Academy of Paediatrics stated that for optimal dental health benefits the total daily intake of fluoride should be 0.05-0.07 mg fluoride per kg bodyweight.”

Those recommended total daily intakes for infants and children are long-standing and clinically-based. Yet at Chapter 6, page 10, NHMRC states that acceptable intake for infants should be set at 0.1mg/kg/day.

Comment: FFA is of the view that some NHMRC review teams are adopting a dangerously cavalier approach to their favoured chemical, by arbitrarily setting their own standards in ignorance of well-established safety considerations. 

The review further notes (Chapter 6, page 7) that “b. water intake for 6, 9, and 12-month-old estimated to be 60, 90 and 120 mL/day, respectively (adapted from Levy et al, 1995).”

Comment: That is a dangerous misrepresentation, obvious error, and gross under-estimation of infant needs.

Water fluoridated at 1ppm contains 1mgF/L, thus 0.15mg F per 150ml. 

Infants actually need on average 150 ml fluid per kg bodyweight daily (120 -180 ml/kg).

So an infant receiving all their fluids from fluoridated tap water (without considering any fluoride in formula) will be consuming 0.15mgF per kg bodyweight daily.  That is 2.5 times the purported safe dose (of 0.05-0.07 mg fluoride per kg body weight).

Disturbingly, Chapter 5, page 2 reports that “8. Some evidence exists that tooth eruption is delayed in fluoridated areas. It has been suggested that a proper comparison of caries rates should involve children one year older in fluoridated areas than in non-fluoridated areas.”

Comment: The review makes no recommendation for follow-up investigations to clarify this worrying claim.

Kidney Function

Chapter 4, page 9 reports that “Fluoride is largely excreted via the kidneys. Patients with renal failure have plasma levels three times higher than normal individuals from the same region. The effect of such high plasma levels on bone merits investigation,”

However, that recommendation does not appear in the executive summary or conclusions.

In is reported in the Summary to Chapter 4 that:

“A wide range of plasma concentrations have been observed which may indicate inter-individual differences in fluoride pharmacokinetics.

• Fluoride is highly concentrated in bone and teeth and has a biological half-life of years in these tissues. This may result in relatively high plasma concentrations in an individual who previously had high fluoride exposure some months or even years after the high exposure has ceased.
• Fluoride is largely excreted via the kidneys. Patients with renal failure have plasma levels three times higher than normal individuals from the same region. The effect of such high plasma levels on bone merits investigation.”

Again, that recommendation does not appear in the executive summary or conclusions.

Chapter 5, page 2 reports that “9. Unless these confounding factors are determined accurately it is not possible to take them into account in statistical analysis.”

No recommendation can be found for confounding factors (such as renal insufficiency) to be better investigated.

Chapter 5, page 72 reports: “Since 1991 there have been 16 studies of water fluoridation and its effects on bone either BMD or fracture incidence. The pivotal cohort study of fluoridated water exposure and fractures or BMD demonstrated a trend for a decreased risk of hip fracture in France for water fluoride levels from 0.11ppm to 0.7ppm and an increase at 1ppm (Jacquim-Gadda, 1998.)”

No recommendation can be found for this worrying finding to be better investigated.

Dental Fluorosis

Chapter 8, page 1 reports:

“2. The prevalence of fluorosis in the 1990s is much higher than it was in the prefluoridation era. In Australia, a number of studies have examined the prevalence and severity of fluorosis. The reported prevalence of fluorosis in fluoridated areas is 40% for 12 year-olds in Perth, 56.8% for 10-16+ year-olds in South Australia and a Dean’s Index of 0.26 for 12 year-olds in Melbourne. Figures for non-fluoridated areas include 33% for Bunbury, 29.3% for 10-16+ year-olds in South Australia and the Melbourne report does not include a non-fluoridated comparison area.”

Regarding that matter, it is stated in Chapter 7, page 16 that: “The public perception of fluoridation as a health benefit may be endangered if the prevalence of fluorosis continues to increase at its current rate.”

Comment: FFA is seriously concerned that “perceptions” appear more important to NHMRC than the actual adverse health effects of artificial fluoridation.

At Chapter 6, page 17, it is recommended that “infant formula is reconstituted with low-fluoride water in a fluoridated area. This may add to the cost of feeding if distilled or mineral water has to be purchased.”

Comment: If such action is necessary to protect infants from excess fluoride consumption, then on what basis can it continue to be said that fluoridation is universally of assistance when families with bottle-fed infants must purchase fluoride-free water to prevent damage to those infants?

Our conclusion – 1999 Review

In general, the 1999 review appears to give no credence to the 1991 review suggestion that a reduction in fluoride concentration in water should be considered if fluoride intake is to be reduced. That is despite finding an increase in the incidence of dental fluorosis. All attention in the 1999 review is on how to control fluoride intake from discretionary sources, when clearly the easiest way to reduce fluoride consumption would be by lowering (or eliminating) the fluoride concentration of artificially fluoridated water.

It is evident from the 1999 review that NHMRC were not proactively pursuing matters of health safety, despite the numerous 1991 recommendations. 

That conclusion has been confirmed by various items of correspondence from NHMRC, as below:

1. NHMRC to John Irving, NSW Health, 24 February 2005 (attached) which states that:

“In 1998, HAC (Health Administration Commission, commissioned a review of fluoride use in Australia. It had been intended that this review would update NHMRC advice on the topic. However, in December 2002, it became apparent that the review was deficient in a number of areas including consideration of fluoride intakes in different age groups, sources of fluoride, and fluoride and oral health. HAC recognised that there were insufficient resources available to complete the additional work required to finalise the report. Consequently HAC agree it was necessary to discontinue this work and has no plans to recommence at this stage.”

Comment: It is of grave concern that NHMRC/HAC considers this work to be of such low priority, despite their continuing assertions of safety and despite endorsing nation-wide water fluoridation thus involuntary fluoride consumption.

2. NHMRC to PMHC, 29 April 2016 (attached) which states:

“NHMRC awarded funding to a project investigating the risk and long term impact of dental fluorosis as a result of exposure to fluoride. Apart from this research, there have been no projects funded by NHMRC prior to or after 2000 that investigated potential negative effects from fluoride or fluoridation.”

Comment: Despite the many 1991 NHMRC recommendations, sometimes for “urgent” and “imperative” health safety actions, NHMRC evidently has not funded any investigations into potential negative effects beyond dental fluorosis. From the following paragraphs below, it is also apparent that nor has NHMRC any intention to do so.

“In regard to fluoride consumption in Australia, NHMRC’s role is restricted to delivering health advice on the effectiveness and safety of water fluoridation to achieve dental health benefits, balanced with the need to ensure the safety and quality of public drinking water supplies as set out in the 2011 Australian Drinking Water Guidelines (ADWG). NHMRC does not have a role beyond this in monitoring fluoride intake from other sources.

Comment: The need for monitoring fluoride intake arises directly from and for no other reason than the intentional mass fluoridation of drinking water, which NHMRC pro-actively promotes and endorses. NHMRC declines to admit any other possible adverse health effect than “very mild or mild dental fluorosis” (NHMRC letter page 2), and that despite many published studies reporting that dental fluorosis is just the most visible symptom of fluoride over-exposure. It also seems important to note that even the ADWG note that drinking water fluoridation has never been studied or assessed for health effects over a “lifetime” (ADWG 2021, p. 166).

“In the ADWG, safety factors have been applied in order to take into account the uncertainty when extrapolating from animal studies to humans, or to account for variation between humans when only small human studies are available. The information used to set the guideline value for fluoride in drinking water comes directly from human studies and therefore the use of safety factors was not considered necessary.” (NHMRC letter, page 2)

Comment: By their own admission in para 1 above, NHMRC have never funded or undertaken a toxicological assessment of fluoride ingestion, and it is grossly misleading to suggest here that “human studies” have been conducted.

Our overall conclusion

The 1991 NHMRC fluoridation review makes significant and strongly-worded recommendations for health safety studies. The 1999 NHMRC fluoridation review fails to follow-up on those recommendations, for reasons of lack of resources.

In their 2007 and 2016 fluoridation reviews, NHMRC make no recommendations for any health safety studies to be conducted. Rather, they conclude and advise the nation without any scientific justification that water fluoridation is perfectly, incontrovertibly, unconditionally “safe and effective”.

In fact, despite these significant safety recommendations made more than 30 years ago, and despite a substantial and steadily accumulating body of rigorous scientific toxicity research, not only has NHMRC egregiously ignored these safety recommendations, but in their 2017 Public Statement, they actually strengthened their official recommendation for water fluoridation as “safe and effective”.

For the health of this nation, it is past time for fluoride and fluoridation to be taken from the ‘authority’ of NHMRC and properly assessed for toxicity and adverse health effects. When a truly independent review of this nature occurs, we are confident water fluoridation will cease due to its uncontrollable risk.