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Second submission on drinking water guidelines

Friday, January 24, 2003
The ADA has made a second submission to the National Health and Medical Research Council (NHMRC) on "Drinking Water Guidelines". The submission followed an earlier one in July 2001 and supports the retention of the guidelines relating to fluoridation which are contained in the draft.

The text of the submission is as follows:

16 December 2002


Mr Phil Callan
Assistant Director
Health Advisory Section
Mail Drop Point 100
Office of NHMRC
GPO Box 9848
CANBERRA ACT 2001-07-03


Dear Mr Callan

The Australian Dental Association Inc. (ADA) wishes to make a submission to the Framework for Management of Drinking Water Quality. This submission is complementary to our previous submission dated 3 July 2001 and is consistent with it.

The ADA is a professional association of dentists and the aims of the Association are to promote the art and science of dentistry and the health of the community. The ADA has a duty to promote effective measures for the prevention and control of dental disease and it is for this reason that this submission is made.

It is essential that, in considering the subject of drinking water quality, diligence is paid to the need to preserve essential nutrients which are contained in drinking water. In this submission, we are referring particularly to the need to ensure that this drinking water contains the optimal concentration of the fluoride ion. It is pleasing to see that, in the Draft Report Australian Drinking Water Guidelines, due recognition is paid to the benefits of the addition of the fluoride ion to drinking water, as a community health benefit. We have no suggestions for change to those sections which refer to fluoride, namely, Tables 10.1, 10.5, 10.6, 10.13; Special handling requirements for sampling for chemical, physical and radiological characteristics, and; Fact Sheet 51.




In 1999, the NHMRC commissioned an independent review of water fluoridation and this report outlines the benefits of the fluoridation of water supplies. In its conclusions, it found that “ Water fluoridation at optimal levels, varying from 0.6 ppm in sub-tropical regions to 1.1 ppm in temperate climates, continues to provide significant benefits in the prevention of dental caries for both deciduous and permanent teeth. The evidence for a protective effect on dental health is strongest in childhood but can also be demonstrated in adults.” Furthermore, it recommended to the NHMRC to “ Maintain the current level of fluoridation of reticulated drinking water supplies between the optimal levels of 0.6 ppm and 1.1 ppm subject to climatic variation”.

The abovementioned report was conducted by an expert team with qualifications in applied and nutritional toxicology, epidemiology, applied chemistry and preventive medicine. The report reviewed the scientific literature and was extremely well referenced. The ADA believes that it would be superfluous to clutter this submission with the repetition of any of the well-conducted studies which formed part of this reference material. However, the key points to be made for fluoridation of water supplies can be summarised as:

• Fluoride occurs naturally in the earth’s crust. In the sea water, fluoride concentrations range between 0.9 and 1.4 parts per million.
• Water fluoridation is the adjustment of the natural levels of fluoride in supplies of drinking water to a level shown to be optimal for a particular area, usually between 0.6 to 1.1 parts per million
• Every capital city in Australia, other than Brisbane, has a fluoridated drinking water supply. Around 70 percent of the Australian population has fluoridated drinking water. A number of towns and cities in Australia and overseas have naturally occurring fluoride in their drinking water, at optimal levels
• The Child Fluoride Study, undertaken by the University of Adelaide, found that, if the 201,084 children aged 5 to 15 years in non-fluoridated Brisbane were to receive fluoridated drinking water, there would be approximately 300,000 fewer tooth surfaces with dental caries
• Fluoridated drinking water has been named by the US Centers for Disease Control and Prevention as one of the ten great public health achievements of the twentieth century
• A recent review of the available literature undertaken by researchers at the University of York concluded that: “the best available evidence suggests that fluoridation of drinking water does reduce caries prevalence, both as measured by the proportion of children who are caries-free and by the mean change in dmft/DMFT [caries experience] score.”
• Two recent articles, published in international refereed scientific journals, have independently demonstrated the cost-effectiveness of water fluoridation. One of the studies, performed in New Zealand, estimated that, in communities of more than 20,000 people, for every $1 invested in this preventive measure, there is a $38 saving in dental treatment costs. Similar findings have been identified in Victoria
• Using scientific evidence as a basis for their justification, numerous scientific and health organisations in Australia and overseas have supported, and continue to support, fluoridation of drinking water. These organisations include the NHMRC, WHO, US Public Health Service, the US Centers for Disease Control, Australian and overseas dental and medical associations and the Public Health Association of Australia

The essential purpose of this brief submission, then, is to support the Draft Guidelines in their acknowledgement of fluoride as an essential component of drinking water supplies.


Yours sincerely




Robert J F Butler
Executive Director



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