Dear Joy Warren,

 

Thank you for your request for information to the Environment Agency.

 

Your request for information has been logged under reference 346142 and
under the Environmental Information Regulations we must respond to you
within 20 working days. You should have our response by 5 March.

 

We will be back in touch once our response is ready but please don’t
hesitate to contact us if you have any questions in the meantime.

 

Kind regards,

 

Customers and Engagement Team
North East England
 
Email: [1][email address]

Environment Agency

Tyneside House

Skinnerburn Road

Newcastle Business Park

Newcastle Upon Tyne

NE4 7AR

 

[2]A blue sign with white text Description automatically generated

 

 

From: Joy Warren <[3][FOI #1081369 email]>
Sent: Tuesday, February 6, 2024 2:32 PM
To: National Requests <[4][Environment Agency request email]>
Subject: Freedom of Information request - Environmental Risk Assessment:
Fluoride in River Water

 

 

[You don't often get email from
[5][FOI #1081369 email]. Learn why this is
important at [6]https://aka.ms/LearnAboutSenderIdentific... ]

 

Dear Environment Agency,

 

In March 2022, Earl Howe in the House of Lords promised that there would
be an Environment Impact Assessment for new Water Fluoridation proposals
as described in the The Town and Country Planning (Environmental Impact
Assessment) Regulations 2017, s4.

 

The following is Earl Howe's promise:

 

“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.”

[7]https://eur03.safelinks.protection.outlo...

 

The Water Fluoridation Public Consultation for the North-East of England
is imminent and in order to inform those residents who are about to be
consulted, an Environment Risk Assessment is essential if the public are
to be enabled to respond knowledgeably.

 

1. Has the EA been asked by the DHSC (OHID) to complete an impact
statement and assessment for the Water Fluoridation Public Consultation
for the North-East of England?

 

2. If so, has the assessment been completed and submitted to the DHSC for
comment?

 

3. When was it submitted?

 

4. Within the assessment has reference been made to the EQS for fluoride
of 15 mg fluoride/litre river water?

 

5. Which organisation has devised and published this EQS?

 

6. Where can this EQS be found on the Internet?

 

Yours faithfully,

 

Joy Warren

 

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show quoted sections

Dear Joy,
 
RE: Request for information under the Freedom of Information Act 2000
(FOIA)/ Environmental Information Regulations 2004 (EIR)
 
Thank you for your email dated 06 February 2024, enquiring about a Water
Fluoridation Public Consultation for the North-East of England. You asked
us to address the following questions
 

 1. Has the EA been asked by the DHSC (OHID) to complete an impact
statement and assessment for the Water Fluoridation Public
Consultation for the North-East of England?
 2. If so, has the assessment been completed and submitted to the DHSC for
comment?
 3. When was it submitted?
 4. Within the assessment has reference been made to the EQS for fluoride
of 15 mg fluoride/litre river water?
 5. Which organisation has devised and published this EQS?
 6. Where can this EQS be found on the Internet?

 
Information held
 

 1. The Environment Agency was asked by DHSC to provide a view of the
Environmental Impacts of the proposed fluoridation scheme to be
included in the public consultation.
 2. The Environment Agency submitted the following to DHSC.  Based on the
concentration that will be dosed in drinking water, releases of
fluoride to the environment will not exceed the Environment Agency’s
non-statutory environmental quality standard set to protect aquatic
life.
 3. This was submitted in October 2023.
 4. No the assessment did not refer to the EQS for fluoride of 15mg/l. 
The EQS referred to in 2 above is the 1mg/l EQS that applies to rivers
with less than 50 milligrams of calcium carbonate per litre of water.
 5. Environmental Quality Standards for the protection of aquatic life are
derived based on consideration of the available data on the impact of
the substance to aquatic life.  Data on the toxicity of the substance
of interest is collated from a review of the available published
information (usually in the form of scientific studies, which, where
possible have been peer reviewed) and then assessed for relevance and
reliability by our scientists. 

 
Where available, data on aquatic plants/algae, invertebrates and fish are
considered. Following this assessment, the available dataset is then used
to derive the EQS. The lowest reliable and relevant datapoint is generally
used as the basis for the EQS derived. An assessment factor is then
applied to consider a variety of factors, for example, the fact that data
is not available for all species or all endpoints. For most substances, an
Annual Average EQS is derived which considers effects arising from chronic
exposure to the chemical alongside a Maximum Allowable Concentration (MAC)
EQS which takes into consideration effects arising from short-term
exposure.   
  
The EQS for fluoride was derived based on consideration of the data
available at the time of the derivation.  Information on effects arising
from short-term and long-term exposure were available for a range of
organisms including molluscs, crustaceans and fish. A review of the
available data indicated that the hardness of the water had an influence
on the toxicity of fluoride to aquatic life. As a result, it was decided
the EQS should be derived for two different hardness bandings to reflect
this.   
  
Based on a review of the available toxicity data for fluoride the lowest
reliable effect concentration for long-term exposure was used as the basis
of the Annual Average EQS for lower hardness waters. An appropriate
assessment factor was then applied to take into account the fact data was
not available for all species. The value derived was then used as the
basis for determining a relevant AA EQS for higher hardness waters taking
into account the available toxicity data for the different water
hardness.    
 
In addition, the difference between concentrations at which acute and
chronic effects were reported was used to determine the EQS for the
short-term exposure (MAC), based on the respective AA values. The EQS
derivation process at the time involved discussion between colleagues
working in this area as well as with other regulatory organisations
including the equivalent to Defra and SEPA at that time. 
  
The process described above is not stipulated in law. The Environment
Agency uses the [1]guidance developed by the European Union. This was not
published at the time we developed the non-statutory EQS for Fluoride,
although the principles are very similar. 
 

 1. The original scientific report the Environment Agency complied in
support of the assessment for an EQS can be accessed via this [2]link.
Please note that the link will expire in 30 days.

The report was completed in 1999. We have not become aware of any
additional evidence which has required us to review this. Please refer to
the [3]Open Government Licence which explains the permitted use. 
 
 
 
Rights of appeal 
 
If you are not satisfied you can contact us within 2 calendar months to
ask for our decision to be reviewed. We shall review our response to your
request and give you our decision in writing within 40 working days. 
 
If you are still not satisfied following this, you can raise a concern
with the Information Commissioner, who is the statutory regulator for
Freedom of Information and the Environmental Information Regulations.  The
contact details are: 
 
Information Commissioner’s Office 
Wycliffe House 
Water Lane 
Wilmslow 
Cheshire 
SK9 5AF 
Tel: 0303 123 1113 
Website: [4]http://ico.org.uk 
 
Kind Regards,
 
National Requests Team   
National Customer Contact Centre   
Contact Centre Services - Part of Operations, Regulation, Monitoring &
Customer   
Environment Agency    
   
( External:  03708 506 506 )
 
 
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References

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