Request
1. Detailed breakdown of up-grading work required to meet the DWI Code of Practice.
2. Size of population covered by the fluoridation schemes
3. Water Fluoridation (Consultation) Regulations 2005 No. 9216
Our Response
Environmental Information Regulations (EIRs)
Thank you for your further email.
I have reviewed our previous response and noted your further comments. I will address each of your points in turn.
1. Detailed breakdown of up-grading work required to meet the DWI Code of Practice
In the context of Anglian Water, of the sums allocated, £773,620 is for Code of Practice Upgrade and the remainder, updating of equipment for the dosing plants. I have attached for your information, copies of the proposals and estimates for the fluoridation capital in the Lincolnshire area. We have redacted the personal details of the engineer contained within these reports as this is information we consider to be personal data under Section 12 (3) of the EIRs.
Following further liaison with Severn Trent Water, I have been advised that the plants in question all currently comply with the Code of Practice. These further discussions have highlighted that the information held by us actually details the works that need to be carried out due to the age and condition of the equipment. As I have already stated, all existing dosing plants run by Severn Trent comply with the Code of Practice, as will the new plants.
However, I do appreciate your concerns and have attached for your information a copy of the upgrade plans that we previously withheld. You will note that certain sections of the plans are redacted. These sections deal with detailed drawings of the plants and their specifications. We are still of the opinion that EIR regulation 12 (5) (a) which relates to national security and public safety can be engaged in this instance.
A number of the redacted sections refer directly to the dosing lines, dosing points or bulk tanks. All of these are the critical points in the system where alterations by persons with criminal intent would harm members of the community.
We have removed the population details supplied by each works and the volume supplied by each works to prevent the size of each treatment works being made readily available, which would help identify sites of biggest value to those planning criminal activities.
Balanced against the factors in favour of release is the very strong public interest in the maintenance of public safety. Due to the damage, which an incident could cause to the general public and the immediate area, there is a strong public interest in avoiding release of information where it could assist in the planning of criminal activity or the undermining of an effective emergency response.
The public interest in maintaining public security is strong and we feel that the balance lies in favour of withholding material where it could have an adverse effect on the local population and endanger public safety.
2. Size of population covered by the fluoridation schemes
In total, the information provided by Severn Trent Water shows that population served by their plants total 310,000. Unfortunately, we do not hold similar information on the populations served by Anglian Water.
You are absolutely right that the NHS is expected to monitor the health and well-being of communities. However, the current system is designed in such a way as to delegate that particular role to Primary Care Trusts (PCTs). Moreover, PCTs are expected to conduct oral health surveys and ensure actions are taken to ensure those needs are met. In this context, it is the role of Nottinghamshire County PCT and Lincolnshire PCT to monitor the health of local communities. You will need to contact the PCTs separately to obtain details. Contact details are available on our website at the following link:
http://www.eastmidlands.nhs.uk/the-local-nhs/nhs-organisations/
3. Water Fluoridation (Consultation) Regulations 2005 No. 9216
As stated previously, we do not hold the original documentation. Our Deputy Regional Director for Public Health has seen confidential documents held by the two water companies which set out dates from the late 1960s, 1970 and the early 1990s as being the start point for various schemes.
Undoubtedly the water utilities will know whether or not the original boundaries of the dosing plants have changed. Over the past 24 months, they have not indicated to us that any change has taken place and indeed as a consequence, we do not think that the boundaries have changed.
In response to your specific question, those involved in working through the proposals submitted by the Water Utilities have not questioned whether they boundaries of the fluoridation programme agreed in the 1960s, 1970s and the early 1990s have been changed by the Water Utilities. Rather, those colleagues have concentrated on whether the plants meet Code of Practice Guidelines and whether given the age of the equipment it would be justifiable for the NHS to fund the replacement under existing regulations placed on the NHS.
We do take our responsibilities under the EIRs seriously and we aim to be as open and transparent as possible in our dealings with you in terms of your request. I understand that you may still have further queries following this response and our Deputy Regional Director of Public Health, Dr Giri Rajaratnam would be happy to discuss any of these issues with you. You can contact Dr Rajaratnam on 0115 968 4681 or by email at Giri.Rajaratnam@nhs.net.
Of course, If you still remain dissatisfied with our response, you may complain to the Information Commissioner who can be contacted at:-
The Office of the Information Commissioner
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
