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Application A588 – Voluntary Addition of Fluoride to Packaged Water – Draft Assessment Report

18 December 2008

Dear Sir/Madam

Thank you for the opportunity to comment on this application. The New Zealand Food Safety Authority has consulted with the Ministry of Health and this submission reflects the views of both organisations.

New Zealand supports the preferred regulatory approach to amend Standard 2.6.2 – Non-Alcoholic Beverages and Brewed Soft Drinks to permit the voluntary addition of fluoride to non-carbonated packaged (bottled) water at a level of 0.6mg - 1.0mg/L (total of naturally occurring and added fluoride). Our support of the preferred approach is conditional on the package label clearly stating the addition of fluoride.

As commented in our previous submission on the initial assessment report, the Ministry of Health recommends reticulated ‘tap’ water for drinking wherever safe supplies are available. Water fluoridation can decrease an individual’s risk of dental caries in addition to brushing twice a day with fluoridated toothpaste, eating healthy foods and timely check-ups with an oral health professional.

Approximately 50% of New Zealanders do not have access to reticulated fluoridated water. The voluntary addition of fluoride to packaged water provides consumers with potential access to fluoridated water but this would be at their cost. Further, the permission is a voluntary addition, therefore not all packaged water will have added fluoride, and it is unclear whether a premium price will apply to fluoridated packaged water. As such, public health policy that continues to promote the fluoridation of reticulated water supplies is required.

New Zealand supports the mandatory labelling provisions, which include fluoride added by the manufacturer or fluoride added by the local council, in cases where fluoridated reticulated water is packaged. This ensures consumers are being informed when fluoride has been added to any packaged water.

We are aware that in the FSANZ risk assessment a proportion of children up to 8 years are identified as having a theoretical risk of exceeding established upper levels (UL) of intake for fluoride, when their sole water source is fluoridated. These issues have stimulated broader discussion around the UL values for fluoride adopted by the National Health and Medical Research Council in 2005 and how these figures were derived.

New Zealand agrees with suggestions that the existing fluoride UL may need to be revised upward. We would support a re-examination of the UL, particularly for children. This would incorporate the 2002 New Zealand Children’s Nutrition Survey and ideally, the 2008/09 New Zealand Adult Nutrition Survey when these results become available in 2010/11.

In New Zealand, current evidence does not indicate an increase in moderate fluorosis within our communities. As such, the theoretical risk to children presented by FSANZ does not appear to be associated with elevated levels of fluorosis. We are comfortable that the revision of the fluoride UL does not take place as a matter of priority but is included in a more strategic programme of work.

Given the matters discussed above, the monitoring of voluntary additions of fluoride, potential harms, and availability and consumption of fluoridated packaged water, may be required and should be discussed by the appropriate jurisdictional authorities.

Yours sincerely