LGOIMA Request Details: LG2408

The information you have requested is below.

1. Identify the factory/facility where the fluoride chemicals supplied to New Zealand water systems are produced, including location, operator, and production process. Include all applicable laws, regulations, licenses, and international standards governing manufacture. 
Manawatū District Council (the Council) does not purchase fluoride chemicals directly from the manufacturing facility and does not hold records identifying the specific factory or factories where IXOM’s fluoride products are manufactured, nor the detailed production processes, licences or international standards applicable to those facilities.  
What Council does hold and can confirm is that:  

• IXOM is the supplier of fluoride chemicals to Manawatū District Council.  

• The fluoride product used is hydrofluorosilicic acid (H₂SiF₆), dosed in accordance with New Zealand public health guidance.  

The detailed manufacturing information requested (specific factory location, operator, production process, licences, international standards) is held by IXOM and/or central government agencies, not by Council. This part of the request is therefore refused under s17(g) LGOIMA (information not held).  We recommend the requester contact IXOM directly for detailed manufacturing information, or make a request to the Ministry of Health / Manatū Hauora or Taumata Arowai if they require central government oversight information.   

2. Identify all upstream raw material suppliers, including chemical sources such as phosphate rock suppliers, and any subcontracted labs or blending facilities. 

Council does not hold information on IXOM’s upstream raw-material suppliers, phosphate rock suppliers, subcontracted laboratories or blending facilities. Council purchases finished product from IXOM and is not privy to their full supply chain.  This part of the request is refused under s17(g) LGOIMA (information not held). IXOM, as the supplier, is the appropriate source for this information.   

3. Provide the full chemical composition, including chemical names, chemical formulae, and concentrations of all fluoride compounds added to the public water supply. 

Council uses hydrofluorosilicic acid as the fluoride compound in drinking water treatment.  
Chemical name: Hydrofluorosilicic acid  
Chemical formula: H₂SiF₆    

 No other fluoride compounds are intentionally added to the Council’s drinking water supplies.  

4. Provide all Safety Data Sheets (SDS), production records, and toxicology studies related to the fluoride chemicals supplied. 

Safety Data Sheets (SDS)  Council holds the Safety Data Sheets provided by IXOM for the fluoride product used (hydrofluorosilicic acid). These SDS are publicly available from IXOM via their website - HFA_Safety_Data_Sheet.pdf 

Production records:  Council does not hold manufacturing production records for IXOM’s facilities. That information is held by the manufacturer/supplier. This part of the request is refused under s17(g) of the Local Government Official Information and Meetings Act (LGOIMA), the information not held by Council. 

Toxicology studies: Council does not hold original toxicology research studies. Our practice is to rely on assessments from central government and international health authorities, including:  
Ministry of Health / Manatū Hauora  
World Health Organization (WHO)  
New Zealand drinking water standards and public health guidance  

Toxicology information is available from the Ministry of Health, Taumata Arowai, and the World Health Organization. This part of the request is refused under s17(g) as the information is not held by Council. 

5. Provide details of any chemical by-products, waste, or residues generated during production, storage, transport, or dosing, including their environmental and human health impacts. 

Fluoride is a byproduct of phosphate fertiliser.  Fluoride does not break down in the water and therefore the concentrations added at the treatment plant are the concentrations consumed.   
NZ Health and World Health organisation recommend the use of Fluoride to protect public oral health.  Accordingly the Ministry of Health considers it safe to consume Fluoride within the specified range.    

6. Disclose all corporate entities, owners, and shareholders that profit from the manufacture or sale of fluoride chemicals in New Zealand. 

Council does not hold information on all corporate entities, owners, and shareholders involved in the manufacture, import and sale of fluoride chemicals in New Zealand.  Council’s direct commercial relationship is with IXOM as a supplier. Council does not have visibility of all entities and individuals who may profit in the upstream supply chain (manufacturers, investors, shareholders, etc.).  This part of the request is refused under s17(g) (information not held). Publicly available company information for IXOM and other entities may be obtained via the New Zealand Companies Office and equivalent overseas company registries.  

7. Clarify whether New Zealand currently manufactures fluoride chemicals domestically, imports ready-made fluoride chemicals, or both, including details of manufacturers and import sources. 

Council does not hold comprehensive information on national manufacturing vs importing of fluoride chemicals. We purchase product from IXOM and do not have detailed knowledge of whether IXOM’s fluoride products are manufactured in New Zealand, imported, or sourced from multiple locations at different times.  
This information sits with:  

• IXOM (as the commercial supplier), and  

• potentially with central government agencies (e.g. Ministry of Health, Ministry of Business, Innovation and Employment, or Taumata Arowai) in relation to approvals and regulatory oversight.  

Accordingly, this part of the request is refused under s17(g) (information not held).  

B. Transport & Logistics  

8. List all companies involved in transporting fluoride chemicals from production sites to distributors, councils, and water treatment facilities. Include freight, shipping, and air transport entities. 

Council’s direct interaction is with IXOM, which supplies and delivers fluoride products to Manawatū District Council’s water treatment plants. We do not hold a complete list of IXOM’s upstream transport providers (international freight, shipping lines, or domestic sub-contracted carriers beyond those engaged for specific deliveries).  We can confirm that:  

• Fluoride chemicals are delivered to our facilities by IXOM or carriers acting on their behalf under commercial arrangements.  

• Council does not normally contract separately with freight, shipping or air transport entities for fluoride chemicals.  

To the extent that information about all transport providers from production site to distributor is sought, Council does not hold this and refuses that part under s17(g). IXOM would be the appropriate party to approach for full supply-chain transport details.  

9. Provide shipping manifests, including transport schedules, storage conditions, and handling protocols (personal driver details may be redacted). 

Shipping manifests & transport schedules:  
Council does not generally receive or retain full international shipping manifests or complete transport schedules from production facilities to New Zealand. We hold delivery documentation relating to shipments received at our sites (e.g. delivery dockets, consignment notes, invoices). If the requester wishes, Council can search and provide copies of delivery documentation for a defined time period (e.g. last 12 months), subject to appropriate redactions for personal information and commercially sensitive details.  

If you want to limit work, specify a timeframe in your final letter before agreeing to copy dockets.  

Storage conditions & handling protocols (Council facilities):  
Council holds and follows standard operating procedures (SOPs) for:  

• On-site storage of fluoride chemicals  

• Handling and dosing procedures  

• Health and safety controls (PPE, emergency response)  

These SOPs are internal operational documents developed to comply with hazardous substances and health and safety legislation and the supplier’s SDS.   

10. Include all applicable laws, licenses, and regulatory frameworks under which these transporters operate, particularly regarding hazardous substances. 

Council does not licence or regulate transport operators directly. Council expects IXOM and any carriers engaged by IXOM to operate in compliance with these laws and regulatory frameworks, and to maintain the necessary licences and approvals. Council does not hold copies of all licences for all carriers and therefore refuses that extension of the request under s17(g).  

C. Contractors & Distribution 

11. Identify all contractors, consultants, and water treatment personnel who handle, dose, or monitor fluoride chemicals. 

Fluoride chemicals at Manawatū District Council water treatment plant are handled, dosed and monitored by:  

• Council’s own water treatment operations staff (treatment operators), and  

• Where applicable, specialist maintenance contractors engaged by Council to work on dosing systems or related plant (e.g. mechanical or electrical contractors).  

All Council staff who handle fluoride chemicals are trained in chemical handling and operate under Council’s standard operating procedures and health and safety policies. We do not routinely outsource the day-to-day dosing and monitoring function to external water operators.  

12. Provide full contract details, including terms of service, duration, performance bonds, insurance coverage, and any professional certifications required. 

Council does not hold the specific contract details requested (including terms of service, duration, performance bonds, insurance coverage, and professional certification requirements). This information is therefore refused under section 17(g) of LGOIMA (the information is not held). 

 13. Disclose all corporate structures, shareholders, and profit arrangements related to these contractors. 

Council does not hold detailed information on the internal corporate structures, shareholders, or profit arrangements of IXOM or other private contractors beyond what appears in publicly available company information and what is necessary for contract management.  

• Company structure and shareholder information for New Zealand-registered entities can generally be obtained from the New Zealand Companies Office.  

• Profit arrangements and internal financial structures are matters for those companies and not information held by Council.  

This part of the request is refused under s17(g) (information not held). To the extent any such information is held incidentally and is of a commercially sensitive nature, it would also likely be withheld under s7(2)(b)(ii).   

D. Policy & Decision-Makers 

14. List all individuals, boards, committees, and advisers who approve or recommend fluoride use in New Zealand, including councils, Ministry of Health, and public health associations. Unknown

15. Include all corporate affiliations, financial interests, and advisory bodies that influence decisions regarding fluoride. 

Council holds no information showing corporate affiliations or financial interests that influence national or regional decisions regarding fluoridation. Council has no financial interest in fluoridation and receives no payments or incentives linked to the use of fluoride; Council’s only relevant commercial relationship is its supply arrangement for fluoride chemical (hydrofluorosilicic acid) with its supplier.  

Decision-making/advisory bodies: Decisions about whether a local authority must fluoridate are made at central government level. Under the Health (Fluoridation of Drinking Water) Amendment Act 2021, the Director-General of Health may direct a local authority to add (or not add) fluoride, and must seek and consider advice from the Director of Public Health before deciding whether to make a direction. 

E. Compliance, Oversight & Safety 

16. Provide copies of all risk assessments, environmental impact statements, monitoring reports, and internal or external evaluations regarding fluoride safety, dosing, and public health. 

Council does not hold environmental impact statements, public health evaluations, or monitoring reports of the kind requested, as fluoridation safety/effectiveness evaluations and population-health evidence reviews sit with central agencies/health authorities rather than Council. This aspect is refused under s17(g) LGOIMA (information not held). 

Set up WNZ fluoride dosing Hazardous location test certificate – Enviro Haz – bulk tank 

17. Provide documentation of regulatory compliance, inspections, or audits by government or third-party authorities. 

Council does not hold inspection/audit reports specifically about fluoridation safety or public health outcomes (as distinct from general drinking-water and hazardous-substances compliance). Taumata Arowai is the drinking-water regulator and sets compliance/monitoring/enforcement expectations for drinking-water suppliers. Hazardous substances requirements sit under the Health and Safety at Work (Hazardous Substances) Regulations 2017 (with WorkSafe/EPA roles). 

This aspect is refused under s17(g) LGOIMA (information not held). 

18. Disclose any incidents, complaints, or breaches relating to fluoride chemical safety, handling, or dosing. 

Council has no records of any incidents, complaints, or breaches relating to fluoride chemical safety, handling, or dosing for the relevant period.