10th. March, 2024

A BRIEF SUMMARY OF WATER FLUORIDATION IN CUMBRIA

BACKGROUND

1.         A water fluoridation scheme has been in operation in West Cumbria since the late 1960’s / early 1970’s.  Operation has been intermittent with prolonged periods when the supply of fluoridated water ceased.

2.         In the autumn of 2021, the local authority (Cumbria County Council) initiated proceedings to “vary” the current scheme because of changes to the water source and the need for the water provider (United Utilities) to build a new water treatment works (Williamsgate WTW) and a new water distribution system.

3.         Water fluoridation in Cumbria is currently at a crossroads.  It ceased with the closing down of the Cornhow and Ennerdale water treatment works (WTW’s) in January, 2023 and could only re-start from the new WTW at Williamsgate with the authorisation of the Secretary of State for Health and Social Care (SoS) and appropriate approval from the Environment Agency (EA). Permission has now been given and fluoridation restarted in February 2024. No EA permit has yet been issued.

4.         A local opposition group (Fluoride Free Cumbria) have been actively campaigning during this period for reconsideration of continuing with the fluoridation scheme under a number of “headings”: -

            (i)         Public consultation

            (ii)        “Operable” and “efficient” (Costs)

            (iii)       Health Monitoring

            (iv)       ‘CATFISH’ and LLOTUS studies

            (v)        Environmental Impact Assessment

PUBLIC CONSULTATION

5.         The approximately 130,000 population of West Cumbria were never consulted when the scheme was introduced 50 years ago and have been  denied an opportunity to have their say on this important issue of using the public water supply system to deliver a medical treatment (for dental caries).

6.         Despite numerous  representations from the local MP (Mark Jenkinson MP), the position of the Secretary of State (SoS) has been made clear – public consultation (PC) is not required as the only change to the population served (by the “variation”) does not trigger the >20% threshold in the legislation.  The actual figure is 19.97%. FFC dispute this calculation. Morally this decision is outrageous.

“OPERABLE” AND “EFFICIENT” (COSTS)

7.         The SoS has a statutory responsibility to ensure any fluoridation scheme is “operable and efficient”.  He may well have done the former but there is significant doubt about the latter.  “Efficient” is taken as including “efficient” use of scarce NHS funding.  

8.         £1.1 million has recently been spent on replacing the fluoridating infrastructure in Cumbria without any attempt being made to quantify any benefits or savings which may accrue.  There has certainly been no cost benefit analysis done as promised by Earl Howe - "Finally, any future public consultation on expansion would also include information on the impact of any proposals on health, the environment and cost-benefit analysis ….." 

(Hansard https://hansard.parliament.uk/lords/2022-03-07/debates/94E636CE-A4D1-4380-940F-277A62CCB199/HealthAndCareBill – Column 1249) 

HEALTH MONITORING

9.         The Secretary of State has a legal duty to monitor the effects of water fluoridation schemes on health and report on it every four years.

10.       By far the most significant health concern is the ever-growing evidence base of fluoride, at the levels found in water fluoridation schemes, is a developmental neurotoxin.

11.       Three letters to two Prime Ministers from eminent scientists warning of the dangers have been ignored and a request from the local MP (Mark Jenkinson MP) for an independent toxicological investigation has been refused.

“CATFISH”

12.       The CATFISH Study was intended as the "be all and end all" of fluoride effectiveness research under current conditions of dental health in the UK.  The 6-year, £1.6 million study found: -

·         What benefits there may be are considered small.

There was no impact on reducing dental health inequalities.
There are other more cost effective and less controversial oral health improvement programmes.
13.       This study was specific to the area of Cumbria in question and so it is difficult to appreciate why the Secretary of State wants to re-start the fluoridation scheme in Cumbria when there is little or no benefit to be gained. The  LOTUS study of 6.5 million dental records in England confirmed the findings of CATFISH.

 

ENVIRONMENTAL IMPACT ASSESSMENT

14.       In the 60+ years of water fluoridation in this country there has never been an Environmental Impact Assessment (EIA), nor is there ever likely to be one.  There is neither the statutory framework nor a scientific framework in place which would make an EIA meaningful.

15.       Parliamentary questioning of the DHSC resulted in confirmation that they have NOT carried out an EIA and have no intention of doing so.

16.       The only statutory requirement for an EIA is the Town and Country Planning Regulations.  Interrogation of the submission by United Utilities for the new water treatment works at Williamsgate contained no reference to the effect of fluoride on the environment.

17.       The Environment Agency (EA) has no role to play in this statutory process – their only involvement is in activities they “permit”.  As it so happens, they are required to issue a permit for the operation of Williamsgate WTW as part of the non-statutory Habitat Regulations Appraisal (HRA).

18.       Any monitoring that is done is against the Environmental Quality Standard (EQS) – produced by the EA - which allows up to 15 mg/l of fluoride to be deposited into waterways which is 20 times greater than that known to be harmful to humans, and 75 times more harmful to aquatic life.  

19.       The monitoring only checks for the presence of fluoride (is it below the allowable threshold?) NOT the effect it is having on the environment.

 

SUMMARY

20.       For over two years the wisdom of continuing with the water fluoridation scheme in West Cumbria has been challenged through both local and national “democratic processes”.  In every case the DHSC has dismissed the arguments for public consultation, costs, fluorides neurotoxicity, the findings of the CATFISH and LOTUS studies and have no intention of carrying out an Environmental Impact Assessment.  An air of “press on regardless” pervades.

21.       The legal agreements have been amended and the DHSC has instructed United Utilities to re-commence water fluoridation. No EA permit has yet been issued. 

22.       The EA’s permitting process could well be the subject of a legal challenge because if its failure to protect the plant and aquatic environment from the damage caused by fluoride.