Southampton fluoridation nemesis

The councils cannot say no to fluoridation neither can the water companies and we are left with a consultation that dictates the rules of who can object to fluoridation and whose objections will be counted! The following is a letter from the SCSHA outlining the rules governing the consultation. This is like David and Goliarth but David has both hands tied.


The independent process for analysing and evaluating the responses to the consultation will be carried out in line with the Water Fluoridation (Consultation) (England) Regulations 2005 which state:
“A Strategic Health Authority shall not proceed with any step regarding fluoridation arrangements that falls within section 89(2) of the Act unless, having regard to the extent of support for the proposal and the cogency of the arguments advanced, the Authority are satisfied that the health arguments in favour of proceeding with the proposal outweigh all arguments against proceeding.”
In terms of responses to the consultation, the Chief Dental Officer at the Department of Health set out guidance earlier this year. It is from this guidance which we base our interpretation of the word cogency. Specifically the guidance states:
“Given that the Consultation Regulations require SHAs to take account of the cogency of the representations and their relevance to the ‘health arguments’, a SHA cannot base its decision solely on a simple count of the representations for or against the proposal. In weighing the cogency of the responses SHAs will need to consider if they are evidence-based and, if so:

The quality of the evidence;
The relevance of the representations to the health arguments in relation to fluoridation; and
The nature of the individual/body making the representations”
Arguments, therefore, should not only be forceful, but also relevant to the issue backed by robust peer-reviewed scientific evidence that can be referenced and quoted.
Olga Senior
Director of Communications and Corporate Affairs