Can the NHMRC be trusted?

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The National Health and Medical Research Council is Australia’s peak funding body for medical research with an aim to develop and maintain health standards in Australia. But as far as fluoridation is concerned, it seems their methodology is somewhat questionable. Merilyn Haines examines our national health body’s modus operandi.

NHMRC’s agenda and approach to fluoridation is so biased and so misleading, it is verging on fraud."

In its review process, NHMRC:

  1. Stacked the review committee only with pro-fluoride advocates;
  2. Broke a commitment to include experts opposed to fluoridation;
  3. Secretly commissioned a new study because the Cochrane review found that there were no high-quality studies;
  4. Was untruthful about a major thyroid study, then suppressed the results;
  5. Falsely claimed an IQ study was high quality;
  6. Downplayed, dismissed or excluded other IQ studies showing fluoride’s neurotoxicity;
  7. Excluded a significant study linking fluoridation to ADHD;
  8. Deceptively asserted there is no link between fluoridation and cancer;
  9. Selected a publication cut-off date for studies for its 2007 review, to intentionally exclude a major review by the US NRC (2006) and the Bassin study (2006);
  10. Essentially based its claims of safety on its 2007 review;
  11. Obfuscated on chronic kidney disease;
  12. Endorsed DOUBLING children’s upper safety limits for fluoride ingestion;
  13. Abandoned the GRADE evaluation method to disguise the very low quality of studies included;
  14. Rated tooth decay and dental fluorosis as more important than cancer and children’s cognitive performance;
  15. Used strict and highly-biased restrictions for acceptable evidence, then included unpublished work, favourable narrative and an abstract;
  16. Attempted to diminish known dental fluorosis harm by manipulating fluorosis ratings and raising the threshold of concern;
  17. Mislead the public and decision-makers by claiming fluoridation reduces tooth decay by 26 to 44%, without indicating this is a measurement in relative terms. In absolute terms the average absolute difference is VERY small;
  18. Dishonestly claims fluoridation is safe by excluding important studies on spurious grounds, ignoring many others, and even cherry-picking weak studies that serve their purpose;
  19. Doesn’t understand (or ignores) basic principles of toxicology – concentration is not the same as dose;
  20. Perverted the principles of medical ethics by presenting a bogus ethical claim constructed by lobbyists rather than ethicists;
  21. Gave an incomplete project of dubious quality a prestigious NHMRC award;
  22. Engaged public consultations that have been shams;
  23. Made an extraordinary effort to maintain the dubious claims that fluoridation is safe, effective and ethical;

It would appear – at least to many – that Australia’s National Health and Medical Research Council (NHMRC) is a highly-reputable body that can be relied upon by decision makers and the public at large to provide thorough and objective analysis of government health policies. But with a little examination it is clear that NHMRC’s past reviews of the safety, effectiveness and ethics of water fluoridation are at best unprofessional and at worst unscientific, biased, highly selective, restrictive of relevant and meaningful public input and deeply flawed in its methodology. In fact NHMRC’s agenda and approach to fluoridation is so biased and so misleading, it is verging on fraud.

Is NHMRC objectively analysing the safety of fluoridation, or propping up a house of cards?

Considering the manner in which the fluoridation review panellists were selected, the way studies were chosen or excluded, the very limited opportunities for public participation and the distinct, consistent lack of independent scientific input, it is hard to come to any conclusion other than the recent fluoride reviews conducted by NHMRC were designed simply to defend a long-standing government policy rather than to genuinely examine the science (or lack of science) on which they are based. This is not the first time this has happened.

In 2007, NHMRC produced a very poor review and report on fluoridation which received extensive criticism from independent scientists. In 2016, in lieu of new (or updated) science published since 2007, NHMRC produced two more heavily-biased and restrictive reports. This compounding result was egregious to say the least.

These two reports (Health Effects of Water Fluoridation: Evidence Evaluation Report and Health Effects of Water Fluoridation: Technical Report, both dated 24 August 2016; available here) and a subsequent report (Information Paper – Water Fluoridation: dental and other human health outcomes, dated July 2017; available here) were the source of material used to create the 2017 Public Statement on Water Fluoridation.

Before examining the blatant flaws in these reports more thoroughly, it is worth mentioning that the 2015 Cochrane review (generally regarded as a gold standard when it comes to meta-analysis of global health research) found little in the way of high quality studies to demonstrate the effectiveness of fluoridation. In fact not a single published fluoridation study conducted in Australia met the Cochrane Review’s relaxed inclusion criteria. This should immediately place a caveat on studies relied on by NHMRC and indeed their methodology.

There have also been thousands of studies published demonstrating the harms or potential harms of fluoride, but specifically on the subject of neurotoxicity, more than 300 human and animal studies have been published indicating that fluoride can cause neurological damage. This large body of evidence was largely ignored in the 2017 NHMRC review, even though it is currently being evaluated by the National Institute of Health Sciences (NIEHS) and the National Toxicology Program (NTP) in the USA.

"Working to build a healthy Australia" by recommending toxic industrial waste chemicals be added to our drinking water.

Since the 2017 Public Statement was published, the results of a major 12-year, multi-million dollar study were published in Environmental Health Perspectives journal in September 2017. This study, commonly referred to as the Bashash study, confirmed the link between ingestion of fluoride by pregnant mothers and reduced IQ in their offspring. So far NHMRC and respective state governments have either dismissed or ignored this significant study.

It is also worth noting that despite the substantial and steadily-growing body of international research indicating the harms of fluoride and despite NHMRC claiming to be “Australia’s peak funding body for medical research, with a budget of roughly $900 million a year”, NHMRC has not funded one single study evaluating the potential harms of fluoride (other than dental fluorosis). If NHMRC genuinely regards the public’s health as a priority, shouldn’t objective scientific research of this nature be one of its key responsibilities?

As far as the 2016 and 2017 reports and the final 2017 Public Statement are concerned, there are 23 specific examples of NHMRC’s unacceptable manipulations, omissions and obfuscations that should be identified. Many of these in isolation should disqualify NHMRC’s 2017 review from serious consideration, but in combination should question the very existence of this national health body.

“…it is hard to come to any conclusion other than the recent fluoride reviews conducted by NHMRC were designed simply to defend a long-standing government policy rather than to genuinely examine the science (or lack of science) on which they are based.”

The 23 examples are as follows:

1. NHMRC stacked the fluoride review committee with fluoridation lobbyists and advocates.

NHMRC appointed at least 10 known fluoridation advocates and lobbyists to its Fluoride Reference Group (FRG) that conducted the 2016 Health Effects of Water Fluoridation. Four of the committee members (dentists Professors John Spencer and Kaye Roberts-Thomson from Adelaide University, Colgate Professor and Dentist Mike Morgan from Melbourne University and former NSW Chief Dental Officer Clive Wright) are well known fluoridation lobbyists who have all received significant grant funding from NHMRC and have all used their own publications to promote fluoridation.

Two of NHMRC’s FRG members; Professors John Spencer and Clive Wright, have even participated in court cases to help fluoridation be forced on NSW residents.

An additional six members of the FRG committee are also known to have publicly advocated for water fluoridation. This means at least two thirds of the 15-member NHMRC committee were admittedly fluoridation lobbyists and advocates. NHMRC deliberately stacked the FRG committee with members extremely biased towards fluoridation. Additionally, when the names of the FRG members were first publicly listed (well after the FRG had already started meeting) the listing of the FRG’s committee member’s conflicts of interests were delayed and severely downplayed. The name of one FRG appointee (Professor Corbett) a fluoridation advocate from as early as 1993, was not even listed on NHMRC website until after the 2014 public call for evidence had already closed.

For more details of the FRG’s known conflicts of interest, click here.

2. NHMRC broke a commitment that it would include experts opposed to fluoridation.

Right from the very beginning, NHMRC was misleading about its proposed review committee. Before NHMRC appointed the FRG members, NHMRC had privately communicated to a few members of the public that a new fluoride review committee, when set up, would include representation of people opposed to fluoridation. As an example, an extract of an email from NHMRC on 15 Jan 2014 stated:

“We aim to include representation from the relevant areas of science, public health, policy area, consumer/community views and as we have discussed, from those opposed to population level fluoridation”

However, NHMRC was misleading because they never allowed that promised representation. In 2006 the US National Research Council reviewed the health effects of fluoride for the US Government’s National Academy of Science, with a balanced panel comprising experts in favour of fluoridation and also experts who were opposed to fluoridation. In contrast, NHMRC would not allow anyone who was opposed to fluoridation to be on its FRG committee. It is also worth noting that the US National Research Council (NRC) Review 2006 resulted in major doubts and warnings about the process of fluoridation.

“NHMRC would not allow anyone who was opposed to fluoridation to be on its FRG committee”
3. NHMRC secretly commissioned a new study on dental effects (previously listed as “out of scope”), when the 2015 Cochrane Collaboration found that there were few, if any, high-quality studies that were supportive of fluoridation).

Because the Cochrane Collaboration was already examining fluoride’s dental effects, the new NHMRC review was only to examine health effects other than dental. In August 2014 when the public were invited to submit evidence for NHMRC to review, dental effects were listed as strictly “out of scope” with NHMRC review only to examine other health effects of fluoridation. NHMRC was only to “critically appraise” the Cochrane review on tooth decay and fluorosis – NHMRC were not to do their own review on dental effects.

When the Cochrane Collaboration review (1) was published in June 2015 it was not flattering to fluoridation. The review found little evidence to support fluoridation being effective. An overview was published in Newsweek Magazine.

For tooth decay, the Cochrane Review used a high standard protocol, it only used studies looking at tooth decay in both fluoridated and non-fluoridated communities, with measures taken at least at two different points in time. This protocol would provide controls to take into account temporal decreases in tooth decay that could not be attributed to fluoridation. This is important as large decreases in tooth decay in non- fluoridated communities have been seen world-wide.

The published Cochrane review findings did not fit NHMRC’s apparent agenda of protecting fluoridation. In response to this, NHMRC secretly commissioned their own review of tooth decay where they could include dental publications that were unsuitable for the Cochrane review. Many publications that NHMRC then allowed to be included in their secretly commissioned review had been written by Australian fluoridation lobbyists who were members of NHMRC FRG committee. NHMRC’s 2017 Information Paper cites 24 dental publications co-authored by FRG member John Spencer, eight publications co-authored by FRG member Kay Roberts-Thomson, two publications co-authored by FRG member Mike Morgan and two publications co-authored by FRG member Clive (aka Frederick) Wright.

“The published Cochrane review findings did not fit NHMRC’s apparent agenda of protecting fluoridation. In response to this, NHMRC secretly commissioned their own review of tooth decay where they could include dental publications that were unsuitable for the Cochrane review.”
4. NHMRC first misled about its knowledge of a new thyroid study (Peckham et al., 2015) and then dismissed its findings, reaching a biased and false position that there is no evidence that fluoride interferes with thyroid function.

On 24 February 2015 (with the new NHMRC fluoride review barely underway) a Fairfax journalist sent NHMRC information about a new study from the UK by Peckham et al (2) which was still media embargoed. This study linked water fluoridation to hypothyroidism. Very early the following day NHMRC published a statement from the CEO re-affirming the 2007 NHMRC’s recommendation and claimed that based on the work conducted in the review so far, NHMRC was expected to maintain its support for fluoridation as effective and safe.

In later correspondence NHMRC staff claimed that NHMRC had not known about this new thyroid study until 25 February 2015 and in other correspondence also claimed that the new thyroid study was not the reason for the release of the CEO’s Statement. NHMRC claimed:

“NHMRC first became aware of the Peckham et al 2015 study on 25 February 2015, one day after it was first published online. A Member of the Fluoride Reference Group (FRG) informed the Fluoride Project Team (FTP) that there had been some media activity surrounding its release”.

Copies of emails obtained via Freedom of Information (FOI) submissions revealed that NHMRC knew about the Peckham thyroid study earlier than they claimed. Apart from being misleading about when NHMRC knew about this thyroid study, NHMRC was also misleading about the source that informed them of the study. It was obvious the study had triggered the release of the CEO’s Statement and it was written in a defensive manner with a biased intention of protecting fluoridation – without adequately evaluating this significant study. Apart from denying awareness of this study and its potential implications, NHMRC breached its obligations by publishing a statement asserting that fluoridation was safe. This statement was made some 18 months before NHMRC published even its draft Information Paper in 2017.

When NHMRC eventually published its 2017 Information Paper, instead of acknowledging concerns about possible adverse thyroid health effects it severely downplayed the Peckham thyroid study.

The downplaying by NHMRC’s FRG was largely based on two fact-poor commentaries (rather than scientific studies), particularly one written by a Queensland Health dentist who is a very active lobbyist for mandatory fluoridation. Instead of investigating further, or even acknowledging potential risk of harm to thyroid function, NHMRC claimed fluoridation was safe by misleadingly claiming this new study was “unreliable evidence“.

Additionally, NHMRC is well aware that the 2006 US National Research Council report “Fluoride in Drinking Water” NRC 2006 (3) acknowledged risk for thyroid harm, specifically stating:

“In humans, effects on thyroid function were associated with fluoride exposures of 0.05-0.13 mg/kg/day when iodine was adequate and 0.01-0.03 mg/kg/day when iodine intake was inadequate.”

Despite knowing this, NHMRC has denied fluoridation poses a risk to thyroid function.

Read more about fluoride’s potential damaging effect on the thyroid and endocrine system here.

5. NHMRC falsely claimed a low-quality IQ study was a high-quality study.

NHMRC falsely claimed that a study (4) conducted by New Zealand dentist/ fluoridation lobbyist Jonathon Broadbent was a high quality study. Broadbent claimed that the study showed no link between fluoridation and IQ deficit.

NHMRC only had to read the opening paragraphs of Broadbent study to see that he was clearly a protagonist in the fluoridation debate, with a keen interest in how the practice was being pursued in New Zealand.

“Community water fluoridation (CWF) is a cost- effective,1,2 safe,3 and environmentally friendly4 means of reducing dental caries rates3 and social inequalities.5 However, CWF has recently been criticized as a cause of IQ deficits among children,6 despite a lack of evidence to support that claim. This claim was considered pivotal in the recent rejection of CWF by voters in Portland, Oregon,7 and by local government politicians in Hamilton, New Zealand. It is likely that such claims may continue to be lobbied against CWF worldwide…”

“Hamilton city (New Zealand’s fifth-largest metropolitan area) has had CWF since 1966 and has recently become a target for CWF opponents. Despite a binding 2006 referendum that showed 70% support for CWF among voting Hamiltonians,10 Hamilton’s City Council chose to relitigate CWF and held a tribunal on fluoridation in early 2013. The councillors voted to cease CWF, leading to an outcry from members of the public and health officials. A new referendum was then held (accompanying a local government election), which again showed 70% support for CWF among voting Hamiltonians.11 The Hamilton City Council elected to await the outcome of a High Court ruling on a challenge to the legality of CWF in another New Zealand city (New Plymouth) before reinstating CWF…(Broadbent et al., 2014)”

With such a clear pro-fluoridation agenda at stake NHMRC should have been far more cautious about labelling this as a “high-quality” study and using it to dismiss or downplay other IQ studies.

If NHMRC had read the Broadbent study more carefully they would have found it was actually a low-quality study. For example, in the study there were approximately 1,000 children who had lived in the fluoridated community but only about 100 in the non- fluoridated community – and of these about half were likely to have taken fluoride tablets. This complete lack of control for obvious confounding factors severely compromised Broadbent’s study as there would be little difference in fluoride intake between the two groups. This study did not have the scientific power to find a significant difference in IQ between the fluoridated and non- fluoridated area. These criticisms were published in the same journal where Broadbent published his article (Osmunson et al, 2016: Letters and Responses, American Journal of Public Health, February 2016, Vol 106, No. 2) and should have been cited by NHMRC.

Broadbent et al also did not consider a number of other important confounders such as lead, iodine, arsenic and Maternal IQ. This is ironic and hypocritical given that Broadbent had been critical of authors of other IQ studies for not considering these confounders. NHMRC was advised in 2016 of these and other severe limitations of this study and yet ignored this information and still claimed in 2017 that Broadbent’s study was a high-quality study. This was a glaringly unacceptable double standard.

“NHMRC was advised in 2016 of these and other severe limitations of this study and yet ignored this information and still claimed in 2017 that Broadbent’s study was a high-quality study. This was a glaringly unacceptable double standard.”
6. NHMRC downplayed, dismissed or excluded most other IQ studies and evidence of fluoride’s neurotoxicity.

NHMRC is well aware of a 2012 Harvard University Meta-analysis and Systematic review (5) by Choi et al of 27 human IQ- fluoride studies that indicated IQ was lowered in children exposed to fluoride. Overall, there was a drop of nearly 7 IQ points with higher exposures to fluoride. Many of the water fluoride concentrations in studies in the Harvard review that were associated with lower IQ were only 2, 3 or 4 times that of Australian fluoridated water. Despite this, NHMRC designed their latest fluoridation review with such severe limitations so that this review and the primary studies included in this review would not be taken into consideration. There is not even a mention of this review in NHMRC’s Information Paper.

In February 2014, the British Medical Journal Lancet Neurology published a paper (6) on developmental neurotoxicants and classified fluoride as a substance that can harm children’s developing brains. In other words the Lancet classified fluoride as a neurotoxin. NHMRC also ignored this.

There are now 53 published human studies indicating fluoride exposure can reduce IQ and 45 animal studies have found that fluoride exposure impairs learning and /or memory capacity. However NHMRC has callously dismissed all of these studies. All citations for the human and animal studies can be found here.

Due to increasing scientific evidence about fluoride neurotoxicity, the US National Toxicology Program (NTP) has commenced further animal studies to investigate this issue. NHMRC had advance and detailed knowledge that this research was to commence when NHMRC was consulting with the US Governments National Toxicology Program and National Institute of Environmental Health Services on how to conduct a systematic review of animal studies.

Despite NHMRC’s knowledge that fluoride neurotoxicity was of enough concern that the NTP had commenced expensive and protracted animal studies and was finding some results of concern, NHMRC irresponsibly continued to deny that fluoride poses any risk to IQ and cognitive function.

Read more about the neurotoxicity of fluoride here.

Read about the latest Canadian IQ study here.

“Despite NHMRC’s knowledge that fluoride neurotoxicity was of enough concern that the NTP had commenced expensive and protracted animal studies and was finding some results of concern, NHMRC irresponsibly continued to deny that fluoride poses any risk to IQ and cognitive function.”
7. NHMRC, on flimsy grounds, excluded a significant study linking fluoridation to ADHD – then failed to even acknowledge its existence.

In 2016 NHMRC became aware of a study by Malin and Till (7) published in February 2015, that linked American water fluoridation to higher rates of medically diagnosed Attention Deficit Hyperactivity Disorder (ADHD). This study fulfilled NHMRC criteria to be included in NHMRC review however because the FRG did not like the implications of this peer reviewed study that had been published in Environmental Health, there was absolutely no mention of this study in NHMRC’s 2017 Information Paper. This could be considered as lying by omission.

“…because the FRG did not like the implications of this peer reviewed study that had been published in Environmental Health, there was absolutely no mention of this study in NHMRC’s 2017 Information Paper. This could be considered as lying by omission.”
8. In 2007, NHMRC used a promised study in a Letter-to-the-Editor to negate an unrefuted Osteosarcoma study (Bassin, 2006) to claim there was no link to cancer. Then in its 2017 review NHMRC failed to acknowledge that the promised study failed to refute the Bassin study but still continued to maintain that there was no evidence of a link between fluoridation and cancer.

When NHMRC published their previous fluoride review (in 2007), NHMRC knew of a significant 2006 study by Bassin et al (8) linking age-related water fluoridation exposure to Osteosarcoma (a rare but frequently fatal form of cancer) in boys and young men. Instead of giving this study due consideration, NHMRC effectively avoided it and unscientifically deferred to a Letter-to-the-Editor by fluoridation lobbyist Chester Douglas in the same journal in which Bassin had published. Douglas had promised that his study would show that Bassins’s thesis didn’t agree with the larger database. Bassin’s hypothesis – based on her data – involved a critical issue of the timing of exposure of young boys to fluoridated water. Namely, that young boys exposed to fluoride at age six, seven and eight, had a five to seven-fold increased risk of succumbing to osteosarcoma by the age of 20. First, it was a glaring double standard on the part of NHMRC, which had been so fussy about which studies they would accept for their review, to accept as evidence the “promise” of the results of a yet unpublished study. This is not a trivial issue – if Bassin was correct, fluoridation might actually be the underlying cause of death of a few young men each year.

However, by 2011, when Douglass’s promised study appeared (five years after the promised date) it didn’t even examine Bassin’s hypothesis. Kim et al (2011) study(9) used fluoride bone levels at diagnosis or autopsy as the metric of exposure. There is no way that such bone levels could gauge exposure of fluoride at critical years of exposure (6th, 7th and 8th years) found by Bassin. Thus, as of 2017 no scientist in the world – including Kim et al. (2011), has refuted Bassin.

NHMRC’s appalling conclusion “that there was no association between fluoridation and osteosarcoma” is at least highly misleading. To make matters worse NHMRC offered no analysis of the quality of the Kim et al. paper, which had other serious flaws, for example they used other bone cancer patients as controls without ruling out that some of these other bone cancers were not caused by fluoride exposure, which might well be the case. Kim et al also included older patients over 20.

For more information on the weaknesses and flaws of the Kim et al Osteosarcoma study and why it does not and could never refute the Bassin study, click here.

Through various submissions, NHMRC are fully aware of these obfuscations and aware that the findings of the Bassin Osteosarcoma study have never been refuted. In 2017 this was a splendid opportunity for NHMRC to put the record straight on this issue, but NHMRC chose not to do so. NHMRC still deceptively asserts there is no link with cancer and water fluoridation.

“NHMRC’s appalling conclusion “that there was no association between fluoridation and osteosarcoma” is at least highly misleading.”
9. For its 2007 review NHMRC selected a publication cut-off date for studies (to be considered for inclusion) that would intentionally exclude a major review by the US NRC (2006) and the Bassin (2006) study.

The cut-off date NHMRC selected for submissions for its 2007 review looks very suspicious and self-serving for those wishing to exonerate fluoridation of any harm. In 2014 NHMRC selected 1 October 2006 as the earliest publication date for studies to be included in the new NHMRC review. This date was almost certainly selected by NHMRC so that they could exclude both the 2006 NRC review and the Bassin Osteosarcoma study which were both published earlier in 2006, but, were never given proper consideration in the 2007 NHMRC review. To help dismiss the NRC 2006 from consideration in its 2007 review NHMRC had claimed that the NRC 2006 report was only about adverse health effects with 2 – 4 mg /L fluoride concentrations and that Australian fluoridation was in the range 0.6 – 1.1 mg/L.

There were a number of studies included in the 2006 NRC report which had lower concentrations than 2 mg /L. One example was a 1998 rat study by Varner et al (1998 Brain Res. 784 (1 -2) 284- 298) that showed rats drinking water fluoridated at 1mg /L for one year had kidney damage, brain damage, a greater uptake of Aluminium into the brain and Beta amyloid deposits thought characteristic of Alzheimer’s. Although the 2007 NHMRC review mentioned the 2006 NRC report, NHMRC apparently dismissed it from any consideration because not all the studies were at 0.6 – 1.1 mg /L. This demonstrated either a blatant lack of understanding of toxicology or an action that was intentionally designed to mislead and cover up the facts. When considering harm it is not the concentration that is the critical comparison but DOSE. Some of the studies that have found harm in fluoride studies have found harm at doses which can be easily exceeded especially for high water consumers and those ingesting fluoride from other sources such as dental products, tea- drinking and pesticide residues. In fact considering all the sources of fluoride, it is normal for Australians to consume between 1.5 and 6 mg/L of fluoride per day, and sometimes more.

“This demonstrated either a blatant lack of understanding of toxicology or an action that was intentionally designed to mislead and cover up the facts.”
10. NHMRC’s 2017 review based its claims of safety largely on its 2007 review; however, its 2007 review was essentially a copy of the 2000 York University review, which according to the York Review’s Professor Sheldon did NOT show fluoridation to be safe!

In 2000 the York University published a review of water fluoridation (10) by McDonagh et al that had been commissioned by the UK government. Professor Trevor Sheldon, as Chair of the review’s Advisory Committee later wrote to the House of Lords advising that the review did not find water fluoridation to be safe. Professor Sheldon’s letter can be seen here.

Professor Sheldon advised that there was little evidence in the York review to show that water fluoridation has reduced social inequalities in dental health and that the review did not find water fluoridation to be safe, with the quality of the research being too poor to establish with confidence whether or not there are potentially important adverse effects in relation to the high levels of fluorosis.

In 2007 NHMRC published their previous fluoride review. NHMRC 2007 review’s section on water fluoridation was largely a copy of the 2000 York University review. The York University review was titled “A Systematic Review of Water Fluoridation”. Despite the obvious copying, NHMRC cleverly, and grandly, titled their review as “A Systematic Review of the Efficacy and Safety of Fluoridation.” The 2007 NHMRC review was then used to claim fluoridation was safe. In NHMRC’s recent 2017 review, NHMRC has still not produced good quality research or evidence, instead claiming that fluoridation is safe. It was a serious act of concealing and misleading when this occurred in 2007, but to repeat their misleading claims in 2017 after the public had pointed out Sheldon’s commentary was remarkable.

“NHMRC has still not produced good quality research or evidence, instead claiming that fluoridation is safe. It was a serious act of concealing and misleading when this occurred in 2007, but to repeat their misleading claims in 2017 after the public had pointed out Sheldon’s commentary was remarkable.”
11. NHMRC obfuscated on chronic kidney disease even though it is aware that poor kidney function increases uptake of fluoride into the bones poses risks over a lifetime. Such cumulative risks – and the special plight of those with poor kidney function – have never been investigated by NHMRC.

In 2007, NHMRC released a public statement (NHMRC Recommendation) as part of a brochure. Draft versions of the brochure (obtained via FOI) show that a warning for people with kidney impairment was included – at least until two dentists (FRG member John Spencer was one of the two dentists) and two South Australian water quality advisors reviewed the brochure. Following this review NHMRC removed the kidney warning and any reference to fluoridated water and kidney impairment.

Although the current and past NHMRC Australian Drinking Water Guidelines (Part 5: Fact Sheets Fluoride) acknowledges risk from fluoridated water for those with kidney impairment, “People with kidney impairment have a lower margin of safety for fluoride intake. Limited data indicate that their fluoride retention may be up to three times normal”, NHMRC’s 2017 Fluoridation Information Paper makes no mention of kidney impairment. This is a major omission.

The 2017, NHMRC Public Statement claims fluoridation is safe, but NHMRC has totally ignored any potential harm to those individuals in our society with kidney impairment. NHMRC has never investigated cumulative effects of fluoride on people with kidney impairment even though a NHMRC File Note in NHMRC documents (also obtained via FOI in 2008) confirms that such an investigation was a requirement of NHMRC’s 2007 fluoride review.

Recent Australian data indicates that 10 % of Australian adults aged 18 years and older have biomedical signs of Chronic Kidney Disease (CKD); those in the 65-74 age group have a CKD prevalence of 21 % and those 75 years and above 42 % prevalence of CKD. This data has major implications, highlighting further NHMRC’s irresponsible failure to conduct appropriate investigations.

NHMRC deliberately muddies the waters claiming in NHMRC’s Evidence Statement (a statement written by the FRG which was two-thirds comprised of fluoridation lobbyists and activists) “There is no reliable evidence of an association between water fluoridation at current Australian levels and chronic kidney disease.”

NHMRC’s FRG apparently are claiming that fluoridation doesn’t cause kidney disease. However NHMRC have totally ignored the real issue of concern that if you have impaired kidney function and therefore can’t excrete as much fluoride from your body, your rate of fluoride bio-accumulation will be higher – and NHMRC have never investigated the cumulative effects. This issue, in recent years has been the subject of correspondence with NHMRC so they are well aware of it, but still do not acknowledge any risk.

Aboriginals are a group that have much higher rates of CKD than other Australians and Diabetics also have a much higher risk of CKD. But NHMRC has not considered the health effects of consuming fluoridated water for people with kidney disease, Aboriginals, Diabetics or other vulnerable population sub- groups. NHMRC has also not considered adverse health effects for people with Diabetes insipidus even though it is known that they are at a higher risk of developing dental fluorosis.

By totally ignoring the issue that people with kidney impairment have potential risk from fluoridated water NHMRC are also arrogantly ignoring conflicting advice from various health professionals, like this statement from a kidney specialist at the University of Munich:

“A fairly substantial body of research indicates that patients with chronic renal insufficiency are at an increased risk of chronic fluoride toxicity. These patients may develop skeletal fluorosis even at 1 ppm fluoride in the drinking water.” – Dr. Helmut Schiffl, MD (2008)

Also, by not allowing animal studies to be included in the review NHMRC will ignore evidence like this:

“….the WHO’s recommended concentrations in drinking water become nephrotoxic to CKD rats, thereby aggravating renal disease and making media vascular calcification significant.” – A. Martín-Pardillos et al. in Effect of water fluoridation on the development of medial vascular calcification in uremic rats. Toxicology. 2014 Apr 6;318:40-50

By ignoring risks for those with impaired kidney function and then dishonestly claiming water fluoridation is safe, NHMRC has totally ignored its duty of care to people with kidney impairment.

“By ignoring risks for those with impaired kidney function and then dishonestly claiming water fluoridation is safe, NHMRC has totally ignored its duty of care to people with kidney impairment.”
12. NHMRC endorsed doubling children’s upper safety limits for fluoride ingestion (using data from the 1930s), almost certainly anticipating that the pre-existing limits would be exceeded by bottle-fed infants consuming formula reconstituted using fluoridated tap-water.

Although this item exceeds NHMRC 2017 review, it is representative of NHMRC’s ongoing bias in its continued promotion and defence of water fluoridation. Despite the steadily increasing number of human studies indicating fluoride is a developmental neurotoxin, NHMRC has recently approved the doubling of the upper safety limits of fluoride ingestion for children up to eight years of age. The new children’s fluoride intake safety limits recently endorsed by NHMRC are now twice as high as the European and USA Upper Tolerable Intake Limits. Apparently NHMRC thinks that Australian children are biologically different to other children and can safely ingest and tolerate twice as much fluoride as their international counterparts. These new doubled upper safety limits were constructed by a committee of eight members, including a Queensland Health dentist who is a lobbyist for forced fluoridation, together with five Adelaide University Dental School staff. At least six out of the committee of eight who have doubled the previous Australian fluoride intake safety limits are extremely biased towards fluoridation. The Queensland Health dentist who was on this committee has been repeatedly reported by Australian media as saying that people who are opposed to fluoridation are nutters, conspiracy theorists and flat-earthers. Why was someone with such a blatantly biased attitude even a member of this committee? And since when did dentists become experts in nutrition and toxicology?

This group based their recommendations to double children’s fluoride ingestion safety limits on their chosen extreme endpoint of severe dental fluorosis and then, for their calculations, heavily relied on fluorosis data collected in the late 1930s from 273 American children in an area where drinking water naturally contained 1.9 mg of fluoride per litre. A total of 75% of the children in that group had some level of dental fluorosis but the committee who doubled Australian safety limits totally ignored that data. NHMRC cannot possibly care about the safety of children when it endorses such shoddy and extremely unprofessional work.

The committee who doubled the upper safety limits for children used the fluoride content of processed foods as measured by Food Standards Australia New Zealand in Brisbane – just prior to Brisbane being fluoridated – thus minimising the measured food/fluoride content. This committee also ignored any current contribution to the total fluoride burden by foods fumigated with the pesticide Sulfuryl Fluoride (AKA Profume). Sulfuryl Fluoride was approved for use in Australia in early 2008 and by now could have widespread use in Australia, as in the USA. Regardless of this, NHMRC still endorsed the doubling of upper safety limits for fluoride ingestion by children up to eight years of age.

Via two published studies, one conducted in Australia and published in 2009 (11) and another conducted in New Zealand and published 2010, (12) NHMRC is aware that the fluoride intake of bottle-fed infants (where infant formula is reconstituted with water fluoridated at 1.0 mg/Litre) breaches NHMRC’s previous upper safety limits. These studies are almost certainly why NHMRC was so determined to endorse doubling fluoride upper safety limits for children. NHMRC is aware that it is the fluoride content of the water added to infant formula that is the issue of concern – but NHMRC obfuscates saying that the fluoride content of infant formula powder is safe. Again, NHMRC seems to want to protect fluoridation more than it wants to protect children.

“Apparently NHMRC thinks that Australian children are biologically different to other children and can safely ingest and tolerate twice as much fluoride as their international counterparts.”
“NHMRC cannot possibly care about the safety of children when it endorses such shoddy and extremely unprofessional work.”
“NHMRC seems to want to protect fluoridation more than it wants to protect children.”
13. NHMRC abandoned the normal GRADE evaluation method for studies of fluoride’s effectiveness almost certainly in an effort to disguise the fact that most of the studies reviewed were of low or very low quality.

The following paragraph is obtained from NHMRC 2016 Technical Report, page 54:

“The GRADE (Grading of Recommendations Assessment Development and Evaluation) system for assessing evidence was not originally designed to consider evidence for public health interventions. Consequently, for public health interventions like water fluoridation, where evidence of efficacy comes from observational studies, much of the evidence will ultimately be rated as ‘low’ or ‘very low’ quality. Due to concerns that the potential pejorative connotations of these descriptors may result in the evidence being disregarded and/or misinterpreted, the Fluoride Reference Group decided to omit the descriptors and describe the evidence in terms of the confidence in the reported results.”

Essentially the Fluoride Reference Group rejected the standard terms for evidence quality in the assessment system they were using because they would make the evidence look too poor. Those terms are “low” and “very low” quality, and they predicted that the majority of the effectiveness studies would achieve these low ratings. A study that would have been rated as “a low quality study” could then become graded by NHMRC as “Our confidence in the reported associations is limited”. This helped disguise the fact that most of the studies used by NHMRC were low quality, or very low quality.

NHMRC then adopted some very flexible criteria for accepting or rejecting a study into their review. Basically, the person reviewing a particular study has no clear and sharp guidelines; they can use their flexibility and pretty much just say “I don’t think this study is good enough” and reject it. This is shown in the CEO’s Administrative Report where in 2016 -17 the FRG used extremely flimsy reasons to refuse the inclusion of many applicable studies that indicated harm.

For example, the 2015 study by Malin and Till (7) linking US water fluoridation to ADHD was excluded by the FRG because: (a) they didn’t like the hypothesis in the published paper; and (b) the FRG hadn’t included it in the 2016 draft information paper – so they wouldn’t include (or even mention it) in the 2017 information paper. This is a total farce by NHMRC!

“Essentially the Fluoride Reference Group rejected the standard terms for evidence quality in the assessment system they were using because they would make the evidence look too poor.”
“This is a total farce by NHMRC!”
14. NHMRC 2017 rates tooth decay and dental fluorosis as more important end point than other health issues, including cancer and IQ.

As shown in NHMRC review’s Technical Report 2016 (page 53) before NHMRC 2017 review started, the Fluoride Reference Group classified the importance of health outcomes for its decision making. The Fluoride Reference Group classed dental caries and dental fluorosis as “Critical for decision making.” The Fluoride Reference Group then classed all other health outcomes, including neuro-cognitive effects, renal effects, cancer, thyroid dysfunction etc., as “Important, but not critical.” The priorities of NHMRC and the FRG are seriously questionable if they consider tooth decay to be a more important health issue than cancer, damage to the thyroid, the effect on those with reduced renal function or harm to children’s IQ.

15. NHMRC commenced reviews with strict and highly-biased restrictions for acceptable evidence, then included unpublished work, favourable narrative and an abstract.

Following are some of the ways NHMRC excluded relevant studies:

  1. A study must be published in English. NHMRC thus eliminated many published Chinese and other non-English studies on fluoride and IQ.
  2. No animal studies were accepted, even though such studies are required by government regulatory agencies such as the US’s EPA and FDA. Animal studies are an essential component of a “weight of evidence” evaluation of the toxicity of a chemical substance or medical intervention. Standard toxicology assessments of a drug or a chemical always start with animal experiments. These can provide more reliable information than human experiments because they can tightly control all the variables except exposure to the chemical in question. You can control everything. The only downside is extrapolating the results from animals to humans, but that is considered an acceptable limitation for important regulatory decisions.
  3. Exposure could only be from fluoride in drinking water. NHMRC even rejected studies which used drinking water F exposure when the study additionally considered exposure from other sources such as swallowed toothpaste. This is ridiculous, since it is clearly total exposure that is of interest for both effectiveness and safety studies.
  4. For safety studies, NHMRC adopted criteria that if the water F concentration is more than 1.5 mg/L, the study will be downgraded or even rejected because it is claimed to be inapplicable to Australia. This ignores the obvious point that when studying adverse health effects, it is often necessary to study higher exposures than commonly occur to tease out effects in relatively small samples. Furthermore, this ignores the fact when other exposures are included, the total F exposure in Australia may be within the range of total F exposure in these (ignored) studies even though the water F level is above 1.5 mg/L.

To fully protect a human population from harm from a known toxic substance a “weight of evidence analysis” is essential. This was one of the key differences between the US NRC review of 2006 and NHMRC reviews of 2007. This severe limitation of NHMRC 2007 review was pointed out by scientists in 2007, and it is therefore surprising that they have reproduced their un-protective analysis in 2017. So far NHMRC has offered no reason to exclude animal studies. This is strange as we know that NHMRC was in correspondence with the US NIEHS/NTP agencies on how a systematic review of animal studies on fluoride should be conducted. We suspect that it was because in their review these agencies reported that they found low to medium quality animal studies that indicated that fluoride is neurotoxic.

When NHMRC review commenced, the allowable scope NHMRC would accept as evidence was severely limited. Evidence of harm via medical notes, case histories, animal studies, non- English text studies and narratives were not to be accepted by NHMRC for the review. NHMRC would only accept full published studies (not abstracts). Any such evidence was also extremely restricted by time frame and scope. It was the heavily biased FRG committee that was the final gatekeeper and arbiter of what evidence would and would not be accepted for the review.

Half way through NHMRC’s review, probably at the request of the FRG – the rules on what evidence was acceptable for the review were changed; NHMRC’s bar was lowered significantly to allow publications other than scientific studies to be included. As can be shown in the Administrative report for NHMRC CEO, in late 2016 the FRG included in NHMRC’s review a narrative (a report favourable to fluoridation, titled “State of the Science Community Water Fluoridation”, Colorado Water Research 2015 Cornwell DA, Ozekin K, McTigue NE, Hayes S) as evidence. Additionally, the FRG even included an unpublished consulting report by Jaguar Consulting (Impact Analysis: Expanding Water Fluoridation in Victoria: Unpublished). Jaguar Consulting are economists with no scientific qualifications.

NHMRC FRG even included an abstract into NHMRC review – under “Additional Considerations”. This dental Abstract was co-authored by FRG members Mike Morgan, Kay Roberts Thomson and (F) Clive Wright.

NHMRC CEO’s Administrative report shows however, that the FRG, as the 2017 Information Paper’s final gatekeeper, excluded all submitted IQ studies and all dental fluorosis studies that were received by the September–August 2016 public consultation. Including these would probably have been damaging to NHMRC’s claim that fluoridation was safe.

NHMRC’s Administrative report also shows that a study linking USA water fluoridation to increased age adjusted incidence of diabetes in 22 states (13) was excluded by the FRG. There is not even a mention of this diabetes study in the 2017 NHMRC’s Information paper, even though this study had been submitted to NHMRC within the September-August 2016 public consultation window. Although this is a published study that had resulted from an approved Thesis, the FRG claimed they had trouble understanding it. The main reason that the FRG gave for the study’s exclusion from the final NHMRC Information paper (published 4 July 2017) was that it hadn’t been included in the 2016 draft NHMRC information paper (published 14 September 2016), so they wouldn’t include in the final Information paper. In 2016, diabetes had not even been included as an outcome in the 2016 draft paper. A word search for “diabetes” in NHMRC’s 2017 Information paper returns zero finds. With the FRG excluding and censoring studies at their whim made a mockery of both NHMRC’s public consultation process and NHMRC’s whole research and evaluation process.

“NHMRC’s Administrative report also shows that a study linking USA water fluoridation to increased age adjusted incidence of diabetes in 22 states (13) was excluded by the FRG.”
“A word search for “diabetes” in NHMRC’s 2017 Information paper returns zero finds. With the FRG excluding and censoring studies at their whim made a mockery of both NHMRC’s public consultation process and NHMRC’s whole research and evaluation process.”
16. NHMRC attempted to diminish known dental fluorosis harm by manipulating fluorosis ratings and raising threshold of concern.

Data from the NSW 2007 Child Dental Health Survey shows that 25% of children aged 11 – 12 years in NSW fluoridated areas had some level of dental fluorosis with 3.3 % of them having moderate fluorosis (TF3) and a further 0.5 % having moderate – severe fluorosis (TF4 and above). NHMRC is now claiming that with expansion of fluoridation dental fluorosis has fallen – from 25 % in 2007 down to 16.8 % in 2012 – 2014; now with only 0.8% of children having a fluorosis score of TF3 (with NHMRC also now claiming TF3 is only mild fluorosis not moderate fluorosis). The way NHMRC has claimed fluorosis rates are now lower is by manipulation by NHMRC. NHMRC has diluted down the rate of fluorosis by now combining fluoridated with non-fluoridated areas. To claim that fluorosis is decreasing NHMRC has switched goalposts – the previous rate of fluorosis in NSW fluoridated areas is now being compared to an overall whole of Australia rate which could include areas fluoridated as low as 0.6 mg/l and also totally non-fluoridated areas. NHMRC is now comparing apples to oranges and this is extremely misleading. It is also worth asking why Australia’s rate of dental fluorosis would decline when fluorosis rates in the US especially have continued to increase substantially.

According to the latest national survey conducted by the US Centers for Disease Control (CDC review 2010), 41% of American adolescents now have some form of fluorosis — an increase of over 400% from the rates found 60 years ago.

Adding to these clearly misleading tactics, NHMRC has also downplayed and diminished rates of dental fluorosis by allowing a change to the way fluorosis is graded. Previously in Australia very mild fluorosis was graded as TF 1 (Thylstrup Fejerskov index of 1), mild fluorosis as TF 2, and moderate fluorosis as TF3, moderate-severe fluorosis as TF 4 and above. For this NHMRC review a fluorosis grading of TF 3 (previously acknowledged as moderate fluorosis – eg, as in the 2007 NSW child dental survey) is now downgraded by NHMRC and claimed by them to be only mild fluorosis. NHMRC also simultaneously upgraded the threshold level for fluorosis of aesthetic concern from TF 3 up to a level of TF 4. Dental Fluorosis rates pose a serious risk for fluoridation programmes, so by downplaying fluorosis and then claiming fluorosis is not a concern, NHMRC masks the real effects of fluorosis and thereby helps protect fluoridation. This is another example of manipulation.

In the 1998 Australian Institutes of Health and Welfare (AIHW) “Review of Water Fluoridation: New Evidence in The 1990s: Final Report April 1998” FRG member Prof John Spencer (as Executive of that AIHW review) had reported on page 106:

“Hoskin and Spencer (1993) found that children affected by fluorosis and their parents are able to perceive the presence of fluorosis at a very mild level. They concluded that children with mild fluorosis showed a significant adverse psychological response to their dental appearance” (this was from findings on the personal perceptions of dental fluorosis of South Australian children as reported to a Dec 1993 Consensus Conference in Perth West Australia).

NHMRC FRG is now asserting that children with mild and even moderate dental fluorosis perceive no problems with the appearance of their teeth with fluorosis, despite this being completely contradictory to what FRG member John Spencer had previously found and reported.

NHMRC claims that fluorosis rates have decreased, claiming that Australian child fluorosis is now 16.8 %. This figure of 16.8 % is from the 2012 –14 National Child Oral Health Survey that was co-edited by FRG member John Spencer. NHMRC provided a large part of the funding for the survey. Tooth decay and dental fluorosis data was collected on every child in the survey, yet while tooth decay was compared by every state and territory in the survey report, the editors did not report fluorosis data this way.

There is a dearth of Australian fluorosis data and this was a perfect opportunity to compare child fluorosis rates in the states and territories, but instead, the authors chose to withhold. This is considered as censorship. The current NHMRC CEO Prof Anne Kelso should never have signed off on this NHMRC funded survey when the editors did not even report child fluorosis data by each state and territory.

Dental fluorosis data was also collected on adults in every state and territory for the 2004- 2006 National Adult Oral Health Survey (NAOHS 2004 – 6) which was also funded by an NHMRC grant. FRG member John Spencer was a lead author of the adult survey report. To the best of our knowledge the adult dental fluorosis data that FRG member Prof John Spencer had collected in that survey has been withheld for over 10 years and has never been publically reported.

Dental fluorosis is a sign of fluoride toxicity, a biomarker of over exposure to fluoride among young children. NHMRC would be aware that even the very mildest level of dental fluorosis is proof that children have been over-exposed to fluoride when their teeth are forming in their gums. It is commonly accepted that children’s permanent teeth are forming in their gums until they are around 8 years of age – therefore they are risk of developing dental fluorosis until they are 8 years old. NHMRC, however, claims that this risk is only until they reach 6 years of age!

Examples of NHMRC’s double standards can be found in Appendix B of NHMRC CEO’s Administrative report which can be found here. This Administrative report lists five additional Dental Fluorosis studies that met the advertised scope for the September–August 2016 public consultation on the draft Information Paper and the Fluoride References Group’s assessment. Astoundingly, all of these were excluded by the FRG.

Furthermore, even though NHMRC had included three Brazilian tooth decay studies for its review and Information paper, the Fluoride Reference Group excluded three Brazilian dental fluorosis studies, stating that each study was “Based in Brazil so lacks relevance /not applicable to dental fluorosis in Australia”. Data on tooth decay in Brazil was included in the 2017 NHMRC review on the claim that it was relevant to Australia, but data on dental fluorosis in Brazil was excluded from NHMRC review on the claim that it was not relevant to Australia.

The FRG also excluded a Colombian dental fluorosis study, partly because it did not take into consideration confounders such as the straightness of teeth. The FRG then also excluded an American dental fluorosis study claiming “Lacks relevance / not applicable to perceptions of dental fluorosis in Australia. Not just about fluorosis but the shape of the teeth”. The FRG thus excluded one fluorosis study party because it also took into account the shape of children’s teeth, while simultaneously excluding another fluorosis study because it didn’t also take into account the shape of children’s teeth. This is another perverse example of double standards to manipulate an outcome.

“Adding to these clearly misleading tactics, NHMRC has also downplayed and diminished rates of dental fluorosis by allowing a change to the way fluorosis is graded.”
“Astoundingly, all of these were excluded by the FRG.”
17. NHMRC misleads the public and decision-makers by claiming fluoridation reduces tooth decay by 26 – 44 % – but without indicating that this is a measurement in relative terms. In absolute terms the average absolute difference is actually only a very small difference – often less than one tooth surface out of over 100 tooth surfaces in a child’s mouth!

As referred to in item 3, after the Cochrane Collaboration review on dental effects was published, NHMRC secretly commissioned their own review of dental effects and NHMRC’s FRG added in several publications that some FRG committee members had themselves authored. Based on NHMRC’s secretly commissioned review and by including many publications authored by FRG members, NHMRC is now claiming that water fluoridation reduces tooth decay by 26% to 44 % in children and adolescents and 27 % in adults. There are many, many factors involved in how much tooth decay any individual may, or may not have. Some simple but very important factors are how much an individual brushes their teeth, how much sugar they consume, how often they visit a dentist, their ability to visit a dentist, whether can they afford  to visit a private  dentist (or how long do they have to wait to visit a public dentist), if they live in a city or a country town, if there are in fact any dentists practising in a country town,  their family’s financial status, their level of education, their general health, etc., etc. Despite this the NHMRC intimates that whether you have tooth decay or not is mostly about whether you drink fluoridated water.  Apparently the NHMRC has not heard that correlation is NOT causation, yet they are making an overreaching claim that fluoridation reduces tooth decay by 26 % up to 44%, as if it was proven absolutely with any doubt. The NHMRC claim is  especially incredulous considering that  no double blind Random Controlled Trials on water fluoridation  have ever been conducted anywhere in the world and almost every study NHMRC used in its 2017 review was a low quality, observational ecological study.

A decline in decay rates of 26% to 44% in relative percentage terms is vastly different to a rate in real terms (i.e. the actual absolute difference). A large claimed percentage difference can actually be a very small and often statistically insignificant in absolute difference. In the prelude to mandatory fluoridation being introduced in Queensland, fluoridation lobbyists, the Australian Dental Association (Qld) and Queensland Health in newspaper advertisements were claiming that children in fluoridated Townsville had 65 % less tooth decay than children from non-fluoridated Brisbane. This was based on a large study (14) published in 1996 that had been co–authored by FRG member John Spencer. This study had measured tooth decay in tooth surfaces. The original study publication shows that the 65% less tooth decay that was claimed by fluoridation advocates was based on a single data point: an absolute difference of only 0.17 tooth surfaces out of over 100 tooth surfaces present in a child’s mouth at age 7 years. This study reported children aged 6 to 12 years, who were life-time residents of fluoridated Townsville had an average difference only 0.23 tooth surfaces less decay in their permanent teeth, compared to children of the same age who were life-time residents of non- fluoridated Brisbane. To keep this in perspective – in this much lauded study used to force fluoridation on Queensland for a life time of exposure to fluoridated water, the average difference in tooth decay for children’s permanent teeth aged 6 to 12 years was only 0.23 tooth surfaces (that’s less than one quarter of one single tooth surface on average). Depending of the type of tooth it is (incisor, molar, bi-cuspid) each tooth has either 4, or 5 surfaces.  By the time a child is 3 years of age, there are over 100 tooth surfaces in a child’s mouth and such a minor difference in decay can easily be attributed to socio-economic or other major confounding factors. To use this methodology is not only misleading it is verging on scientific fraud.

Relative percentages can obviously give a very misleading picture. And yet NHMRC’s Information Paper has only published claimed differences in tooth decay as relative percentages, but not as absolute differences. When fluoridation lobbyists have in the past claimed 65% less tooth decay for an average absolute difference of less than one quarter of a tooth surface we do not know how small the absolute differences in tooth decay may be to be able to gain a true perspective and NHMRC certainly do not show their calculations how they came up with those figures of 26% to 44 %.

State and Territory data from the 2004 – 2006 Australian National Adult Oral Health Survey (NAOHS 2004-2006) shows that adults from then virtually non-fluoridated Queensland, when compared to all the other states and territories which are heavily fluoridated, did not have the most tooth decay in any of the four adult age groups examined.

In March 2013 some of the authors of the 2004 – 2006 NAOHS (who are also members of NHMRC FRG) using the data from the adult survey, published a paper (15) comparing tooth decay in adults who had lived in fluoridated and non-fluoridated areas, for varying lengths of their lives. Looking at the generation born between 1960 and 1990 (those born after water fluoridation) comparing adults with more than 75 % of lifetime exposure to fluoridated water to those with less than 25 % exposure to fluoridated water, it was found that those who had prolonged exposure to fluoridated water had nearly eight teeth with decay, while those who had very little exposure to fluoridated water had nearly nine teeth with decay. For near lifetime exposure to fluoridated water the difference was only 1.14 teeth (approximately 11 % difference in tooth decay). For both a pre-1960s born cohort and post cohort there was an approximately 11 % relative difference comparing prolonged versus negligible lifetime fluoridation exposure. An important confounder – access to dental care (e.g., ability to access dentists in more rural areas compared to city areas) was not even considered, so the real difference may have been even less.

But that’s not all. The 11 % difference in adult tooth decay had been measured using the most common standard of measuring tooth decay DMFT – the number of Decayed, Missing and Filled Teeth. However, by using a less common way of measuring decayed tooth surfaces – Decayed Missing Filled (tooth) Surfaces DMFS (with four or five tooth surfaces per tooth depending on the type of tooth) AND, by totally ignoring or excluding the number of Missing teeth from the equation (changing DMFS to only DFS) the authors then claimed the difference in tooth decay from fluoridation in the pre-1960 cohort was 30% and in the post 1960 cohort was 21 % less decay. This is how 11 % difference in tooth decay in adults can be doubled or even tripled purely by the manipulation of removing some data and this can explain how NHMRC can misleadingly claim at least 26% less tooth decay for adults from fluoridation.

NHMRC uses relative percentages when making claims of large reductions in tooth decay, but gives little mention of what can be very small absolute differences. Once again, large relative percentages usually translate to very small absolute differences – often less than a fraction of one tooth on average.

“The NHMRC claim is  especially incredulous considering that  no double blind Random Controlled Trials on water fluoridation  have ever been conducted anywhere in the world and almost every study NHMRC used in its 2017 review was a low quality, observational ecological study.”
“NHMRC uses relative percentages when making claims of large reductions in tooth decay, but gives little mention of what can be very small absolute differences. Once again, large relative percentages usually translate to very small absolute differences – often less than a fraction of one tooth on average.”
“To use this methodology is not only misleading it is verging on scientific fraud.”
18. NHMRC dishonestly claims fluoridation is safe by excluding important studies on spurious grounds, ignoring many others, and even cherry-picking weak studies that serve their purpose (e.g. Broadbent on IQ).

NHMRC structured their review so that many studies and evidence could not be included. Even with the studies that remained, overall, for both dental benefits and for adverse health effects, the quality of evidence was low or very low.

For adverse effects, these low ratings applied equally to studies claiming no adverse effects as to studies claiming to find an adverse effect. The NHMRC reviews could therefore not rule out adverse effects with any degree of confidence.

Here is a quote from the Executive Summary Conclusions:

“There is limited evidence that there is no association between water fluoridation at Australian levels and the IQ of children and adults. There is also limited evidence that there is no association between water fluoridation at Australian levels and the outcomes of delayed tooth eruption, tooth wear, osteosarcoma, Ewing sarcoma, total cancer incidence, hip fracture and Down syndrome. The review also identified evidence suggesting that water fluoridation at Australian levels are associated with a small reduction in all-cause mortality; however, our confidence in this association is limited, and this small reduction may be due to chance. For all other outcomes canvassed in this review, the evidence was of insufficient quality to draw any conclusions.”

For most adverse outcomes there was “limited evidence that there is no association” with fluoride; and for others the quality of evidence was so low that no conclusions could be drawn.

Far from this NHMRC review being a resounding rebuttal of the evidence that fluoridation causes harm; it actually concludes there is insufficient quality evidence to rule out harm. Not a single adverse outcome has sufficient quality evidence to rule it out. Because the onus is on those promoting fluoridation of public water to prove with sufficient confidence that it is safe, this report is a resounding indictment against fluoridation promoters, because it concludes they do not have sufficient quality evidence to confidently conclude it is either safe or effective.

It is shameful that NHMRC should continue to waste taxpayers’ money on reviews like this and instead should fund or invest in well-designed studies in Australia or better still in reviewing the successful methods being used to fight tooth decay in children (including children from low-income families) in non-fluoridated countries.

“…this report is a resounding indictment against fluoridation promoters, because it concludes they do not have sufficient quality evidence to confidently conclude it is either safe or effective.”
19. NHMRC doesn’t understand (or ignores) basic principles of toxicology – concentration is not the same as dose!

Concentration and dose are vastly different measurements. Concentration is the measure of fluoride in milligrams per litre of water (expressed as mg/L). NHMRC has specified an acceptable concentration range in Australia of 0.6 to 1.1mg/L and also allows (via its Australian Drinking Water Guidelines) a maximum of 1.5mg/L. The dose, on the other hand, is the concentration of fluoride in water multiplied by the volume of water consumed by an individual per day. A person drinking two litres of water fluoridated at 1mg/L therefore ingests around 2mg of fluoride. Even more relevant is the TOTAL DOSE – the amount of fluoride received each day from all sources of fluoride, including water, tea, many processed foods, some commonly-prescribed medication, Teflon-coated cookware, dental treatments, pesticide residues and possibly even air pollution and fluoride absorbed through the skin when showering.

When the NHMRC began its review in mid 2014  it stubbornly restricted the health studies it would accept only to studies that involved fluoride concentration up to a maximum of 1.5 mg/L. By rejecting studies conducted on fluoride exposures at higher levels than those used for fluoridation in Australia, NHMRC ignored the effect of dose for many people who drink more water (eg, sportspeople, athletes, outdoor workers, people on certain medications, people with Diabetes insipidus or Diabetes mellitus), people who retain more fluoride (eg, people with impaired kidney function or kidney disease) and infants receiving formula made with fluoridated water. They also ignored fluoride received from other sources (as above). A discussion of fluoride dosage and a higher-than-average ingestion according to total dose is glaringly lacking.

Dr. Kathleen Thiessen, Risk Assessment Scientist on the 2006 National Research Council panel (NRC 2006) has stated –

“The range of individual fluoride exposures at 1 mg/L will overlap the range of individual exposures at 2 mg/L or even 4 mg/L. Thus, even without consideration of differences in individual susceptibility to various effects, the margin of safety between 1 and 4 mg/L is very low”

NHMRC either ignores, or does not seem to understand both the issue of dose, and also the issue of individual susceptibility. This methodology is blatantly and irresponsibly deficient.

“NHMRC either ignores, or does not seem to understand both the issue of dose, and also the issue of individual susceptibility. This methodology is blatantly and irresponsibly deficient.”
20. NHMRC perverted the principles of medical ethics by presenting a bogus ethical claim constructed by lobbyists rather than ethicists.

Water fluoridation is the addition of fluoride chemicals to public drinking water with the sole aim of treating people against a condition or disease, namely tooth decay. Water fluoridation, therefore, by its very nature is mass medication. Many countries do not undertake this practice for this very reason – that it is highly unethical because apart from the toxicity and lack of efficacy, they regard it as unethical. Read why most European countries have rejected or banned fluoridation here. Additionally, the Queensland government in its official 2003 Position Statement acknowledged that without the express consent of the community, fluoridation is in fact unethical mass medication.

“…it is a principle of ethical public health that mass, involuntary medication must never proceed without the express consent of the community”.

Fluoridation is both mass medication and medical treatment through public water supplies without the individual’s consent. In early 2013 Cairns Council ended fluoridation acknowledging the 2012 position of the Local Government Association of Queensland that without the express consent of the community, fluoridation is unethical mass medication. NHMRC would be aware since 2012, there have been 29 Queensland Councils that have formally rejected fluoridation with this matter weighing heavily on their decision. Some of the Queensland Councils that ended fluoridation did so after commissioning surveys that found approximately 50 % up to 70 % of those surveyed did not support fluoridation. A Referendum in Mount Isa found 89 % of voters did not want fluoridation. Knowing that there is individual and community opposition to fluoridation, NHMRC still claims fluoridation is ethical. It is worth noting here that given the general lack of awareness in Australia about the very small number of people consuming fluoridated water worldwide (less than 5%), the rejection of fluoride by many countries and the reasons for their rejection, the major studies clearly showing that fluoridation is ineffective at reducing dental decay, the substantial and growing body of research showing the potential harms of fluoride, along with other incidental items such as the source of fluoridation chemicals and the tactics used by NHMRC to defend fluoridation, we believe that the above figures are very low and with more education would be higher.

Nevertheless, NHMRC believes it is ethical to force a medication or treatment on non-consenting individuals.

In 2005 – 2006 NHMRC endorsed and published Nutrient Reference Values for Australia and New Zealand. In 2006 NHMRC maintained that fluoride was classed as essential to human health and included it in the new nutrients values. Nutrients however are substances which feed, nourish and sustain growth.

In 2017 NHMRC FRG intimated that fluoridation is the same as adding the nutrient Iodine to salt, or the nutrient Folic acid to bread. This is deliberate obfuscation as Iodine and Folic acid are proven nutrients and sufficient intake is essential for life, whereas fluoride is not a nutrient. NHMRC would be unable to provide information on a single biological process within the human body that requires fluoride, because there are none, yet NHMRC still claims that fluoride is a nutrient.

Fluoride is NOT under any circumstances a nutrient and any claim or implication by NHMRC that it is a nutrient is not only an obfuscation it is deception.

Despite NHMRC endorsing fluoridation since 1953, NHMRC had never examined the ethics of fluoridation. Nevertheless, NHMRC suddenly stated in its 2017 Fluoride Information Paper that fluoridation is ethical based on the claim that it is safe. The way NHMRC claims fluoridation is safe is by unreasonably denying any fluoride risk to thyroid function, significant association with Osteosarcoma (bone cancer), excluding, ignoring or downplaying links to ADHD and IQ deficit, and totally ignoring the risk of cumulative effects for people with kidney impairment.

As part of their reasons for claiming that fluoridation is ethical the FRG, in the ethics section of the information paper, claimed that it “It is not possible to buy fluoride supplements.” Apparently NHMRC’s FRG has never heard about eBay where it is easy to buy fluoride tablets (supplements). However it should be mentioned that fluoride supplements have never been approved as either effective or safe by the US Federal Drug Administration.

Freedom of Information documents (NHMRC FOI 2016-17/019) indicate fluoridation lobbyists in NHMRC’s FRG committee played a large part in writing the Ethics section of the 2017 NHMRC’s Fluoridation Information Paper. It appears that apart from requesting some small cosmetic changes, NHMRC’s Australian Ethics Committee mostly just signed off on what the FRG had constructed.

“Fluoride is NOT under any circumstances a nutrient and any claim or implication by NHMRC that it is a nutrient is not only an obfuscation it is deception.”
21. NHMRC gave an incomplete project of dubious quality a prestigious NHMRC award

In August 2008 NHMRC awarded Professors Clive Wright and Mike Morgan a prestigious NHMRC award – “One of the Ten Best Research Projects 2008” for their research project on water fluoridation and cost effectiveness. By 2011 NHMRC had marked the status of Professors Wright and Morgan’s project as complete – yet apparently only one published article (16) has ever resulted from this project and that was published two years after Profs Wright/Morgan were given NHMRC award. Their article was published only in the Australian Dental Journal in 2010, not in any international dental journal of higher ranking. It is interesting that the Wright/Morgan project’s lead researcher died in May 2008 and therefore it was unlikely that any other publications would ever eventuate. In 2014 NHMRC appointed both Clive Wright and Mike Morgan to NHMRC Fluoride Reference Group to conduct NHMRC’s upcoming review on fluoridation.

The Wright/ Morgan project was supported by a NHMRC grant. The project’s Progress Reports to NHMRC (obtained through Freedom of Information – NHMRC FOI 2011-00643) did not inspire any confidence in the quality of the project data that had been collected [why? It would be good to give some details] – yet NHMRC still gave its prestigious award to Profs Wright and Morgan for an unfinished project of dubious quality.

It is also worth noting that all cost-effectiveness figures compiled to defend fluoridation have always been extremely biased and unreliable as they:

  1. never include the cost of treatment of dental fluorosis;
  2. understate the total cost of fluoride chemicals;
  3. Either understate or completely omit the cost of installing and maintaining required infrastructure and dosing systems; and
  4. of course they do not consider the cost of any other potential adverse health effects.
22. NHMRC’s fluoridation public consultations have been shams.

In 2016, NHMRC advised that a public consultation would occur when the Information Paper was released. However, rather astoundingly, it later restricted public consultation submissions ONLY in relation to the two-sentence Public Statement itself and to specifically answering NHMRC’s five very self-serving questions. It clearly stated that submissions involving criticism of the actual Information paper, published 4 July 2017, would NOT be accepted. Within this already severely constrained “public consultation process” the public were also not permitted to submit abstracts or narrative reviews – despite the FRG including an abstract and narrative they had selected.

Looking back, in NHMRC’s 2014 public call for evidence, NHMRC had limited all public submissions to 500 words. This ludicrous action by NHMRC created some outrage. Then in 2016 NHMRC would also not accept any submissions or criticism of the 2016 Technical Report, or the 2016 Evidence Evaluation report.

In other words, NHMRC has given the public the opportunity to “vent off steam” but throughout the process has denied independent scientists a genuine opportunity to address the many flaws and weaknesses in this review in a substantial way.

On 13 September 2016, NHMRC held a Webinar for journalists about NHMRC’s draft Information Paper that was to be released the following day. The speakers were NHMRC CEO Anne Kelso and FRG member Professor Clive Wright. NHMRC had prepared a PowerPoint presentation for the media with key messages that Australian fluoridation was safe and was not linked to any harm. Public consultation, restricted only to NHMRC’s draft Information paper, opened on 14 September 2016, yet NHMRC had already broadcast via Australian media that fluoridation was safe. The 2016 public consultation then was a total sham – there really was no point in letting the public submit contrary evidence when it was going to make no difference to NHMRC’s published claim that fluoridation was safe. In the end when the Information Paper was released on the 4 July 2017, NHMRC would not even allow the public to make any submissions regarding its content.

NHMRC’s farcical public consultations are an insult to the many Australian citizens and scientists who have many years researching this subject in depth. This disdainful approach to seeking genuine and meaningful input is highly suggestive that NHMRC knows that it is defending a very poor review on a very poor practice. These actions show that NHMRC’s public consultation process on fluoridation has not only been highly unprofessional, it has been a complete sham and a farce.

“These actions show that NHMRC’s public consultation process on fluoridation has not only been highly unprofessional, it has been a complete sham and a farce.”
23. NHMRC’s extraordinary effort to maintain the dubious claims that fluoridation is safe, effective and ethical, are becoming more and more desperate by the year. NHMRC’s 2007 review was very bad, however NHMRC’s 2017 review is verging on fraud.

NHMRC administers nearly a BILLION dollars in taxpayer funds every near, yet its fluoridation reviews have employed biased, misleading, even corrupt practices that ignore public health risks and attempt to conceal an extremely unprofessional review process by grossly limiting genuine input from the public – especially from those with a scientific background who have studied the issue closely.

NHMRC’s 2007 Public Statement summary recommendation was:

“Fluoridation of drinking water remains the most effective and socially equitable means of achieving community wide exposure to the caries prevention effects of fluoride. It is recommended that water be fluoridated in the target range of 0.6 to 1.1 mg/l depending on climate to balance reduction of dental caries and occurrence of dental fluorosis”. (Our emphasis added).

NHMRC’s 2017 Public Statement summary recommendation was:

“NHMRC strongly recommends community water fluoridation as a safe, effective and ethical way to help reduce tooth decay across the population. NHMRC supports Australian states and territories fluoridating their drinking water supplies within the range of 0.6 to 1.1 milligrams per litre (mg/L)”. (Our emphasis added)

In a giant leap, after its biased 2007 review, NHMRC in their 2017 summary recommendation state that water fluoridation is “safe”, yet they have ignored the neurotoxic and nephrotoxic effects of fluoride, along with potential risks of cancer, diabetes and damage to the thyroid gland. In 2007 there was a substantial body of evidence showing that fluoridation is not safe. Ten years later, in response to a range of additional studies published showing potential harms of fluoride; they escalate their recommendation to “safe”!

Despite violating medical ethics on several counts, NHMRC inserted a claim that water fluoridation is “ethical”, however this claim was constructed by fluoridation lobbyists within NHMRC and NHMRC FRG.

In response to political pressure exerted upon State governments to abandon water fluoridation, NHMRC now “supports” State governments fluoridating public water supplies.

To shore up their public statement NHMRC even censored any reference to climate and the balance relating to fluoridation causing dental fluorosis. In fact NHMRC has never considered differential susceptibility and vulnerability that occurs within the Australian population, which is a gross omission.

“NHMRC administers nearly a BILLION dollars in taxpayer funds every near, yet its fluoridation reviews have employed biased, misleading, even corrupt practices that ignore public health risks and attempt to conceal an extremely unprofessional review process by grossly limiting genuine input from the public – especially from those with a scientific background who have studied the issue closely.”
CONCLUSION:

NHMRC has ignored its Duty of Care and betrayed the Australian public with its poor and perverted reviews of fluoridation that are extremely misleading – in frequency and severity – to the extent of verging on fraud.

Given NHMRC’s sustained incompetence and highly-unprofessional methodology, the only viable solution is for a new review to be commissioned by the Federal government, to be carried out by an independent non-government organization, with a panel comprised of impartial scientists and professionals, who are also independent of government influence. Ideally such a panel would consist of experts drawn from both sides of the issue in question and also those who have not taken a previous position on the issue. A good model would be the panel selected by the US National Research Council for its review of fluoride’s toxicity in 2006.

And finally, NHMRC’s 2017 Public Statement reveals that our national health body is becoming less and less concerned about science – and therefore its own credibility – and more concerned about defending its out-dated views, while at the same time acting overtly politically. 

Such biased, self-serving, irresponsible behavior clearly shows that Australia’s NHMRC cannot be trusted.

“Such biased, self-serving, irresponsible behavior clearly shows that Australia’s NHMRC cannot be trusted.”

References

  1. Iheozor-Ejiofor Z, Worthington HV, Walsh T, O’Malley L, Clarkson JE, Macey R et al. Water fluoridation for the prevention of dental caries. The Cochrane Database of Systematic Reviews, 2015;6:CD010856.
  2. Peckham S, Lowery D, Spencer S. Are fluoride levels in drinking water associated with hypothyroidism prevalence in England? A large observational study of GP practice data and fluoride levels in drinking water. J Epidemiol Community Health, 2015; 69(7): 619-24
  3. Fluoride in Drinking Water: A scientific Review of EPAs Standards; National Research Council (NRC) 2006 of the National Academy of Sciences
  4. Broadbent, JM, Thomson, WM et al 2014. Community Water Fluoridation and Intelligence. Prospective Study in New Zealand, American Journal of Public Health, 105(1) 72-76
  5. Anna L. Choi, Guifan Sun, Ying Zhang, and Philippe Grandjean Developmental Fluoride Neurotoxicity: A Systematic Review and Meta-Analysis; Environ Health Perspect;
  6. Grandjean & Landrigan (2014); Neurobehavioral effects of developmental toxicity; The Lancet Neurology, 13(3) 330 – 338, March 2014.
  7. Malin AJ, Till C. Exposure to fluoridated water and attention deficit hyperactivity disorder prevalence among children and adolescents in the United States: an ecological association. Environ Health, 2015; 14: 17.
  8. Bassin, EB, Wypij, D et al 2006. Age-specific fluoride exposure in drinking water and osteosarcoma (United States), Cancer Causes & Control, 17 (4), 421-428
  9. Kim, F.M., C. Hayes, P.L. Williams, G.M. Whitford, K.J. Joshipura, R.N. Hoover, and C.W. Douglass. 2011. “An assessment of bone fluoride and osteosarcoma.” Journal of Dental Research, 90(10): 1171 – 1176.
  10. McDonagh M, Whiting P, et al; A systematic review of public water fluoridation 2000. United Kingdom: University of York, NHS Centre for Reviews and Dissemination, 2000. (AKA York University 2000 review)
  11. Clifford, H., H. Olszowy, et al. (2009). “Fluoride content of powdered infant formula meets Australian Food Safety Standards.” Aust N Z J Public Health 33(6): 573-576
  12. Cressey P (2010). Dietary fluoride intake for fully formula-fed infants in New Zealand: impact of formula and water fluoride, J Public Health Dent; 70(4): 285–291.
  13. Fluegge K. Community water fluoridation predicts increase in age adjusted incidence and prevalence of diabetes in 22 states from 2005 and 2010. J Water Health , 2016; 14 (5) : 864-77
  14. AJ Spencer, GD Slade, Davies M ; Caries experience among children in fluoridated Townsville and non-fluoridated Brisbane; Aust N Z J Public Health 1996;20;623-9
  15. GD Slade, AE Sanders, L Do, K Roberts Thomson, and AJ Spencer. Effects of Drinking Fluoridated Drinking Water on Dental Caries in Australian Adults; J Dental Res March 2013
  16. Campain AC, Marino RJ, Wright FAC et al ; The Impact of changing dental needs on cost savings from fluoridation; Australian Dental Journal 2010; 55: 55:37-44
FRG’s  conflicts of interest

For examples of some of the known conflicts of interests of 10 members of NHMRC’s Fluoride Reference Group (FRG), click here.

Queensland Government’s 2003 Position Statement

Queensland Government’s 2003 Position Statement acknowledges; “it is a principle of ethical public health that mass, involuntary medication must never proceed without the express consent of the community.”
Copy available here.