Questions for AQWEST

Letter and questions for Aqwest

7 July 2022

Mr Gary Hallsworth
Chief Executive Officer
And Board of Directors
AQWEST
5 MacKinnon Way, Bunbury WA 6230
By Email: Gary.Hallsworth@aqwest.com.au

Dear Mr Hallsworth

Re: Questions and complaints regarding the scheduled fluoridation of Bunbury’s water supplies

In relation to the scheduled fluoridation of Bunbury’s water supply, as announced by WA Department of Health (WA Health) in January 2021, Fluoride Free Australia Inc., Children’s Health Defense Ltd., and Fluoride Free Western Australia Inc., would like to ask you several questions.

We believe the implementation of water fluoridation in Bunbury will affect the health and wellbeing of all residents of the City of Bunbury. Therefore we feel these questions are very important and relevant and we would appreciate your response at your earliest convenience.

As a preface to these questions, we would like to remind you that under federal Consumer Law, a retailer must answer all questions and complaints and the customer cannot be directed to a third party. All of these questions relate specifically to Aqwest, not WA Health.

Contract Law

Under Contract Law, a contract exists between Aqwest and your customers, where Aqwest supplies drinking water and your customers pay for this water. Given the substantial body of scientific evidence demonstrating this “health” treatment and intervention is NOT safe and NOT effective in reducing tooth decay[1] [2] [3], we believe the addition of fluoridation chemicals to this drinking water will constitute a major and unacceptable change in this contract.

Q1: Why should any of your customers, who have not, and will not, provide their consent to a change of contract for fluoridation chemicals being added to their drinking water, or to the supply of fluoridated drinking water, continue to pay for this water after fluoridation commences?

Consumer Law

Under Consumer Law, the water supplier has an obligation to provide a product with Consumer Guarantees and a product that is fit for purpose. Many studies over the last 50 years or more show that the “fluoride” used in water fluoridation systems cause various damage or risks of harm to our physiology. Numerous substantial studies have proven these chemicals are a protoplasmic poison, an endocrine and hormone disruptor, a vitamin and mineral inhibitor, a developmental neurotoxin, a nephrotoxin, and a bio-cumulative substance. It is well documented that around 50 percent of fluoride accumulates in a healthy adult, and around 80 percent accumulates in an infant or child.

Q2: Are you and Aqwest Directors willing to provide a personal guarantee that the fluoridated water you intend to supply in 2023 will be 100 percent safe for ALL of your customers, for a lifetime, and will also be effective in reducing tooth decay? If not why not?

Q3: Why should any of your customers, who believe that fluoridated water will not be fit for their purpose, be required to pay for a product without a guarantee of safety and efficacy?

Code of Conduct and Consent

Under a Council of Australian Governments (COAG) approved Code of Conduct for Healthcare Workers, by definition, the fluoridated water to be supplied by Aqwest next year will be a Healthcare Service being supplied by Healthcare Workers. In this case, Clause 2 of this Code states that individual consent is required.

Q4: Why should any of your customers pay for a Healthcare Service which violates a COAG Code of Conduct?

Medical ethics

Water fluoridation is a violation of medical ethics because it:

• deprives the individual of their basic right to informed consent to medication;
• provides an uncontrolled dose;
• does not involve a personal prescription according to the individual’s circumstances. In particular, those most susceptible are:
  • Individuals with poor kidney function are not able to process and excrete as much fluoride as a healthy person, so more fluoride will accumulate in their bones causing fluoride-induced bone damage. Fluoride is also nephrotoxic so it will continue to reduce the kidney’s functioning;
  • Diabetes and pre-diabetes patients;
  • Individuals with hypersensitivity to fluoride’s toxic effects (sometimes misnamed as ‘fluoride allergy’)—fatigue, headaches, depression, skin rashes, respiratory distress and more;
  • Infants and bottle-fed babies. They are at the most sensitive stage of their life; hence recommendations by many dental researchers that young infants should not consume fluoridated water;
  • Individuals with iodine deficiency. There is compelling research showing that they are more susceptible to neurological damage or under active thyroid from low levels of fluoride exposure;
  • Individuals who are deficient in calcium, vitamin C, and/or vitamin D as fluoride’s toxic effects on bone tissue are amplified in these individuals. The elderly and very-low income groups are particularly prone to these conditions;
  • Individuals who drink large quantities of water, including athletes, manual labourers, tradesmen and those with polydipsia (excessive thirst or excess drinking).
• does not involve a medical expert’s ongoing monitoring;
• effectively robs people of their choice;

Accordingly, fluoridation expressly contradicts the Australian Medical Association’s Code of Ethics, the Australian Medical Council’s Code of Conduct and the National Code of Conduct for Health Care Workers.

In a journal article titled “Fluoridation: A Violation of Medical Ethics and Human Rights”[4] the authors stated:

“Silicofluorides, widely used in water fluoridation, are unlicensed medicinal substances, administered to large populations without informed consent or supervision by a qualified medical practitioner. Fluoridation fails the test of reliability and specificity, and, lacking toxicity testing of silicofluorides, constitutes unlawful medical research. It is banned in most of Europe; European Union human rights legislation makes it illegal.

Silicofluorides have never been submitted to the U.S. FDA for approval as medicines. The ethical validity of fluoridation policy does not stand up to scrutiny relative to the Nuremberg Code and other codes of medical ethics, including the Council of Europe’s Biomedical Convention of 1999. The police power of the State has been used in the United States to override health concerns, with the support of the courts, which have given deference to health authorities.”

Q5: Why should any of your customers pay for fluoridated water if water fluoridation is a violation of medical ethics and human rights?

Duty of Care and Due Diligence

Corporations have a Duty of Care to do their own due diligence on the product they sell.

Q6: Has Aqwest or WA Health conducted any Health Safety studies? If so can you please supply the results of these studies?

Q7: Why should any of your customers pay for a product if Aqwest or WA Health have not conducted any health safety studies?

Q8: Given that less than five percent of the world receives artificially fluoridated water and 98 percent of Europe has ceased, rejected or banned fluoridation based on lack of safety, lack of efficacy and lack of ethics, and in light of the substantial body of evidence showing fluoridation chemicals damage the developing brain, bones, kidneys, thyroid and pineal gland and even the teeth, do you think it is reasonable for this Duty of Care to include comprehensive health safety studies?

The National Health and Medical Research Council (NHMRC) is responsible for the Australian Drinking Water Guidelines (ADWG). We bring your attention especially to the last sentence in the Disclaimer contained within these Guidelines:

Australian Drinking Water Guidelines (Version 2.0 Updated December 2013 ii.)

Disclaimer

The contents of this document have been compiled using a range of source material and while due care has been taken in its compilation, the Commonwealth, member governments of NHMRC and NRMMC and the organisations and individuals involved with the compilation of this document shall not be liable for any consequences which may result from using the contents of this document. You should therefore make independent inquiries, and obtain appropriate advice, before relying on the information in any important matter.

We also feel it is relevant that about 20 years ago, Rand Water, owned by the South African Government, conducted their own due diligence for water fluoridation and decided against fluoridation.[5]

Q9: In light of NHMRC’s Disclaimer statement in the ADWG, and in light of Rand Water’s findings, do you feel Aqwest should conduct an independent Due Diligence investigation for water fluoridation?

Q10: Why should any of your customers pay for fluoridated water if no independent Due Diligence has been conducted by Aqwest?

Monitoring of ingested fluoride levels

With existing natural fluoride levels in the water bores supplying Bunbury, precise dosing will be required to attain a desired fluoride concentration of 0.8mg/litre and not exceeding 1.0mg/litre. Of course it is therefore expected that fluoride concentrations supplying Bunbury in Aqwest’s extensive pipeline infrastructure will be constantly monitored to ensure the ideal level is constantly maintained and the maximum level is not exceeded.

However, it is highly unlikely the total dietary intake of fluoride (including fluoride from fluoridated water, food and beverages and other sources such as toothpaste and some medications) will be monitored in the general population of Bunbury. It should also be noted that pathology laboratories normally charge around $110 per blood or urine fluoride test to monitor ingested fluoride levels.

On 6 November 2000, the Fluoridation of Public Water Supplies Committee (FPWSC) held its 31st committee meeting in Perth to discuss the fluoridation of Bunbury and Busselton. In the minutes of that meeting, obtained via a Freedom of Information (FOI) submission, it was stated:

“[Redacted Name] believes many areas almost comply with fluoride requirements. He believes that residents may be receiving adequate fluoride levels, especially when taking into account consumption of imported foods and beverages containing fluoride (for example, a sample of Pepsi Cola revealed a fluoride level of 0.85mg/L).”

“[Redacted Name] believes there is no merit in requesting [Redacted Name] direct Bunbury and Busselton to fluoridate, because:

i) the natural fluoride levels in water supplies almost comply;

ii) there is continued resistance in the community in these two towns to have their water fluoridated;

iii) the fluoride debate in the South West could spread to the rest of Western Australia to areas that are currently fluoridated. This may generate anti-fluoride views across Western Australia as similar to what happened in Ireland.”

Apart from the scientifically-proven lack of safety and efficacy of water fluoridation, with the admission of FPWSC more than 20 years ago that natural fluoride levels almost comply and that Bunbury residents may be receiving “adequate fluoride levels” when considering total fluoride exposure, it is staggering that this outrageously expensive fluoridation project is even going ahead. But especially given that acknowledgement, it would be egregious, and perhaps even negligent, of Aqwest’s Directors not to conduct a detailed blood/fluoride and/or urine/fluoride monitoring program amongst Bunbury residents to monitor total fluoride exposure.

Q 11: Why should any of your customers pay for water containing a hazardous waste chemical, when there is a substantial body of science showing the long-term adverse consequences of consuming fluoridated water every day, if you will not be conducting a detailed monitoring program to monitor total fluoride exposure in your customers?

 Risk Assessment

The following is an excerpt from a document titled Environmental Health Risk Assessment – Guidelines for human health risks from environmental hazards (2012), written and published by the Federal Department of Health.[6]

What is Risk Assessment?

Risk assessment is the process of estimating the potential impact of a chemical, physical, microbiological or psychosocial hazard on a specified human population or ecological system under a specific set of conditions and for a certain time frame. The scope of Environmental Health Risk Assessment (EHRA) can cover health impacts of:

• • • chemical pollutants and contaminants in air, water, soil and food
    • pathogenic microbiological contaminants in food and water
    • radiation sources
    • electromagnetic fields (EMFs)
    • climate and climate change

In all cases of the above impacts, priority is attached to evaluating the potential human health impacts.

This update of “enHealth” guidance on EHRA focuses primarily on hazardous chemicals (and to a lesser extent, microbiological hazards). Risk assessment relating to radiation hazards, EMFs and climate change are covered elsewhere. Risk assessment is intended ‘to provide complete information to risk managers, specifically policymakers and regulators, so that the best possible decisions are made’ (Paustenbach 1989 p. 28).

A similar document is also available from WA Health, titled Health Risk Assessment in WA.

Q12: In light of a substantial body of scientific evidence, especially the studies published since NHMRC’s cut-off date of October 2014 for their last fluoridation review, showing compelling evidence of damage to the developing brain of the fetus, infant and child, and especially given NHMRC has NEVER conducted ANY health safety studies, do you feel it would be appropriate for WA Health to conduct a Risk Assessment of water fluoridation for its existing water fluoridation program in Perth and Western Australia, PRIOR to the implementation of a new fluoridation system for Bunbury’s water supplies?

Q13: In light of the above mentioned science, and also the particular sensitivity of minority groups to fluoridation chemicals such as pregnant mothers, parents using reconstituted baby formula made with fluoridated water, individuals with impaired kidney function or with diabetes, individuals with fluoride hypersensitivity issues, and individuals consuming large quantities of water, especially outdoor labourers, athletes and sportspeople, do you feel it would be appropriate for Aqwest to conduct a Risk Assessment of water fluoridation BEFORE continuing any further capital works on this fluoridation project and BEFORE commencing fluoridation in 2023?

Q14: Why should any of your customers pay for fluoridated water if no risk assessments have been conducted for the safety of fluoridation chemicals for both humans and animals, by NHMRC, WA Health, Aqwest, or by any other government health department or water supplier in this country?

Efficacy

Supporting fluoridation, NHMRC has relied on many poor to extremely poor-quality studies, none of which were even good enough for the relaxed inclusion criteria of the Cochrane Review (2015)[7], the largest and most comprehensive fluoridation efficacy review ever conducted. On the other hand, there are around 20 rigorous, large-scale, population-based studies clearly showing there is no difference in tooth decay between fluoridated and non-fluoridated countries, cities and regions. In fact many large-scale studies only show a correlation between fluoridation and dental fluorosis, i.e. damage to the teeth!

Approximately 90 percent of the Australian population receives fluoridated water, however Australia is facing a dental decay epidemic with more than 40 per cent of all children aged 5 to 10 with decay in their primary teeth, about 25 per cent of children aged 6 to 14 with decay in their permanent teeth and 90 per cent of adults have some form of tooth decay. Most states are reporting a record number of hospitalisations involving major dental procedures under general anaesthesia.[8] Fluoridation is clearly not working.

Q15: in light of the extensive and especially large-scale evidence of the lack of effectiveness of water fluoridation in reducing tooth decay, why should any of your customers pay for fluoridated water?

Allergy and Hypersensitivity to fluoride

It is well documented that up to five percent of people experience allergic or hypersensitivity reactions to fluoridated water and other fluoride exposure.

From the 1950s, the renowned allergist George Waldbott discovered that some individuals are hypersensitive to ingested fluoride.[9] In a series of case reports and double-blind studies, Waldbott and other doctors found relatively small doses of ingested fluoride, including the consumption of fluoridated water, could induce side effects that would quickly reverse upon cessation of fluoride exposure. Consistent with Waldbott’s research, the largest ever government-funded clinical trial of fluoride supplements reported that one percent of the children taking the 1 mg fluoride tablets exhibited hypersensitive reactions (Feltman & Kosel 1961).[10]

Numerous other studies have also shown this hypersensitivity reaction to fluoridation chemicals.[11] Case reports of hypersensitivity to ingested fluorides are also available here.

Q16: Why should any of your customers, especially those with allergy or hypersensitivity issues with fluoride, pay for fluoridated water when it is known that even a small percentage of the population is hypersensitive to fluoride?

 Water filtration and removal of fluoride

The great majority of common gravity jug filters, as used in many homes in Australia and no doubt Bunbury, do not remove fluoridation chemicals. Many people, if not most, are not aware of this fact. More expensive and complex Reverse Osmosis (RO) filters are normally required to remove fluoride from drinking water. These RO filters can range from several hundred dollars for a basic system supplying only drinking water, to several thousand dollars for larger systems that remove fluoride for a whole house.

Q17: Why should any of your customers pay for fluoridated water, and then have to pay extra to filter the tap water for human consumption, bathing and for their animals?

Adequate warnings

To date there are 58 studies, involving more than 25,000 children, showing fluoride ingestion is associated with reduced intelligence (IQ) in humans. More than 60 animal studies, even at very moderate dose rates, have also found that fluoride exposure impairs the learning and/or memory capacity of animals.[12]

Amongst these studies, 25 were rated high[er] quality by the US National Toxicology Program and 11 studies involved fluoride exposures at or below those used in Australia.[13] These include several large, rigorous, multi-million-dollar US-Government-funded studies, confirming the neurological damage fluoride does to our young.

Also, amongst these studies, there are SIX Mother-Offspring studies based on water fluoridation, showing the relationship between maternal fluoride ingestion and subsequent lowered IQ in their children.[14]

However, the Green study (2019) is the first to compare fluoridated vs non-fluoridated cities in Canada, where fluoride-water levels are lower than in Australia.

Several other major studies show the link between fluoride and Attention Deficit Hyperactivity Disorder (ADHD), thyroid disorders, lowered IQ in formula-fed babies, and sleep disorders.[15]

Please note that of all the major studies referred to, and referenced in this section, only ONE study (Li et al, 2004) was conducted before the cut-off date for NHMRC’s most recent Fluoridation Review.

You should also be aware that next year, assuming fluoridation commences in Bunbury, an infant drinking baby formula reconstituted with fluoridated Bunbury tap water will be consuming around 200 times more fluoride than mothers’ breast milk.

Q18: In light of this substantial and steadily growing body of scientific evidence showing the damage fluoridation chemicals cause to the young, will you be warning pregnant mothers and bottle-feeding parents of the risks associated with consuming fluoridated water? If not, why not?

Q19: Why should any of your customers, especially those who are pregnant, expecting to be pregnant, or feeding their babies with reconstituted baby formula using fluoridated water, pay for their fluoridated water?

Community Consultation

Community consultation should be an essential part of any health intervention, especially one that is highly-controversial and mandated across an entire community.

Unfortunately, efforts to inform Bunbury residents about fluoridation generally, and about the ensuing fluoridation of Bunbury’s water supplies, by WA Health or Aqwest have been conspicuously lacking. In fact the community consultation which has occurred can only be described as pathetic!

The Australian Drinking Water Guidelines outline the importance of community consultation, as follows:

Australian Drinking Water Guidelines (ADWG) (Version 2.0 Updated December 2013 Page 6)

1.4 Community consultation

The ADWG are intended to provide consumers with safe and aesthetically pleasing water, and ultimately it is consumers who will be the final judges of water quality. It is vitally important that consumers are viewed as active partners in making decisions about drinking water quality and the levels of service to be adopted. Community expectations and willingness to pay must be considered. It is the responsibility of drinking water suppliers to keep the community fully informed about water quality, existing problems and needs for improvement. Consumers also need to be informed about their responsibilities in relation to domestic plumbing and of any possible issues associated with the interaction of mains water with this plumbing.

Q20: Why should any of your customers pay for fluoridated water when they have never been individually consulted, as stated in the NHMRC’s Australian Drinking Water Guidelines, and when there has been minimal community consultation conducted by WA Health?

Thank you for your time in considering these questions and complaints. We look forward to your response.

Sincerely

Fluoride Free Australia Inc.
Children’s Health Defense Ltd.
Fluoride Free WA Inc.

References

[1] A summary of water fluoridation: https://fluoridefreeaustralia.org/wp-content/uploads/2021/06/Summary-of-water-fluoridation.pdf

[2] A steady stream of science: https://fluoridefreeaustralia.org/stream-of-fluoride-science/

[3] The fluoridation farce – Water fluoridation is not effective: https://fluoridefreeaustralia.org/ineffectiveness/

[4] Cross D, Carton R, “Fluoridation: A Violation of Medical Ethics and Human Rights” International Journal of Occupational and Environmental Health; Published online: 20 Nov 2013

[5] http://www.thewaterpage.com/randwater_fluoride.htm

[6] Environmental Health Risk Assessment; Federal Department of Health, published 2012: https://www1.health.gov.au/internet/main/publishing.nsf/Content/A12B57E41EC9F326CA257BF0001F9E7D/$File/Environmental-health-Risk-Assessment.pdf

[7] Zipporah Iheozor‐Ejiofor et al; Water fluoridation for the prevention of dental caries; Cochrane Collaboration/Cochrane Database of Systematic Reviews; 18 June 2015.

[8] AIHW, March 2018 Oral Health Tracker and AIHW November 2018 Report.

[9] Waldbott, George, et al, (1978).  Fluoridation – The Great Dilemma, Lawrence, Kansas:  Coronado Press, Inc.
Waldbott GL. (1968). Hydrofluorosis in the U.S.A. Fluoride 1: 94-102.
Waldbott GL. (1958). Allergic reactions from fluorides. International Archives of Allergy 12: 347-355. (See study.)
Waldbott GL. (1956). Incipient fluorine intoxication from drinking water. Acta Medica Scandinavica 156: 157-168. (See summary.)
Waldbott GL. (1956). Incipient fluorine intoxication from drinking water, Int. Archives of Allergy and Applied Immunology, vol 9 241-9.

[10] Feltman R, Kosel G. (1961). Prenatal and postnatal ingestion of fluorides – Fourteen years of investigation – Final report. Journal of Dental Medicine 16: 190-99. (See excerpts.)

[11] de Vos G, et al. (2004). Effects of fluoride and mercury on human cytokine response in vitro. Journal of Allergy and Clinical Immunology 113(Suppl 1): S66. (See abstract.)
Goldman D. (2001). Tacrolimus ointment for the treatment of steroid-induced rosacea: a preliminary report. Journal of the American Academy of Dermatology 44: 995-8. (See abstract.)
Grimbergen GW. (1974). A Double Blind Test for Determination of Intolerance to Fluoridated Water (Preliminary Report). Fluoride 7:146-152.
Feltman R. (1956). Prenatal and postnatal ingestion of fluoride salts: A progress report. Dental Digest 62: 353-357.
Lewis A, Wilson CW. (1985). Fluoride hypersensitivity in Mains tap water demonstrated by skin potential changes in guinea-pigs. Medical Hypotheses 16: 397-402. (See abstract.)
Prival MJ. (1972). Fluorides and human health. Center for Science in the Public Interest, Washington D.C. pp. 23-25.
Shea JJ, et al. (1967). Allergy to fluoride. Annals of Allergy 25:388-91. (See study.)
Spittle B. (1993). Allergy and hypersensitivity to fluoride. Fluoride 26(4):267-73.(See abstract.)
Zanfanga PE. (1976). Allergy to fluoride. Fluoride 9(1): 36-41. (See summary.)

[12] Major studies clearly show the neurological damage of fluoride: https://fluoridefreeaustralia.org/neurological-damage-fluoride/

[13] Dose-Response Analysis of all Fluoride IQ Studies Rated High Quality by National Toxicology Program; C. Neurath, P. Connett, M. Connett, J. Hirzy: https://fluoridefreeaustralia.org/wp-content/uploads/2022/07/Neurath-ISEE2021-poster.pdf

[14] The six major Mother-Offspring developmental neurotoxicity studies are:

• Li et al., 2004; Effects of high fluoride level on neonatal neurobehavioral development. Published in the Chinese Journal of Endemiology in 2004; 23(5):463-5. Translated and republished in 2008 in Fluoride 41(2): 165-170.
• Valdez Jiménez et al., 2017. In utero exposure to fluoride and cognitive development delay in infants. Published in Neurotoxicology Mar;59:65-70.
• Bashash et al., 2017; Prenatal fluoride exposure and cognitive outcomes in children at 4 and 6–12 years of age in Mexico. Published in Environmental Health Perspectives on 19 September 2017.
• Thomas et al., 2018; Prenatal fluoride exposure and neurobehavior among children 1–3 years of age in Mexico. Only the abstract of this study has been published in Occupational & Environmental Medicine, 18 March 2018;75:A10.
• Green et al., 2019; Association between maternal fluoride exposure during pregnancy and IQ scores in offspring in Canada. Published in JAMA Pediatrics, 19 August 2019.
• Till, C et al., 2019; Fluoride exposure from infant formula and child IQ in a Canadian birth cohort. Environment International, Volume 134, January 2020, 105315 (available online on 16 November 2019).

[15] Several additional studies showing the link between fluoride and ADHD, thyroid disorders, lowered IQ in formula-fed babies, and sleep disorders are:

• Malin and Till, 2015; Exposure to fluoridated water and attention deficit hyperactivity disorder prevalence among children and adolescents in the United States: an ecological association. Published in Environmental Health, 2015.
• Bashash et al., 2018; Prenatal fluoride exposure and attention deficit hyperactivity disorder (ADHD) symptoms in children at 6-12 years of age in Mexico City. Environ Int. 2018 Dec;121(Pt 1):658-666.
• Till C, et al, 2018; Community Water Fluoridation and Urinary Fluoride Concentrations in a National Sample of Pregnant Women in Canada. Environmental Health Perspectives. 2018 Oct;126(10):107001.
• Malin et al., 2018; Fluoride exposure and thyroid function among adults living in Canada: Effect modification by iodine status. Published in Environment International; October 2018.
• Riddell et al., 2019; Association of water fluoride and urinary fluoride concentrations with attention deficit hyperactivity disorder in Canadian youth. Environment International; Oct 22, 2019.
• Malin, A et al., Fluoride exposure and sleep patterns among older adolescents in the United States: a cross-sectional study of NHANES 2015–2016. Environmental Health volume 18, Article number: 106 (2019