Breach of Version 1.2 – September 2013

Extract from

“…Where risks are identified, appropriate control measures should be identified,
implemented and monitored. Control measures should be based
on the hierarchy of controls. That is, wherever possible
hazards should be eliminated. If elimination
is not possible, hazards should be
controlled using substitution,
isolation or engineered
control methods…”

In the view of the evidence provided by recent research and presented on this web site,

we insist that the Queensland government obey its own regulations as printed under

‘Risk Management’ and close down all fluoridation dosing plants in Queensland immediately.

Version 1.2 – September 2013

viii) Risk management

Risk management is a holistic management process aimed at managing those risks which could adversely impact upon an organisation’s objectives. For water suppliers that fluoridate, risks that may jeopardise the provision of safe and optimally fluoridated water as well as those that may jeopardise workers’ health and safety, are likely to rank highly. It is therefore highly recommended that these water suppliers develop appropriate risk management systems for both dosing and workplace health and safety risks and incorporate this documentation into an overall risk management system.

In accordance with the requirements of the Water Supply (Safety and Reliability) Act 2008,all drinking water service providers are expected to operate under an approved Drinking Water Quality Management Plan (DWQMP) by July 2013. These management plans are essentially risk management systems and all water suppliers operating a fluoride dosing facility will need to address the dosing risks associated with their fluoride dosing facility in their DWQMP. The Water Supply (Safety and Reliability) Act 2008 is administered by the Department of Energy and Water Supply (DEWS) through the Queensland Water Supply Regulator (QWSR). DEWS’s requirements for DWQMPs can currently be accessed at: www.dews.qld.gov.au.

Various risk management frameworks have been developed by a number of proponents, however, risk management usually consists of the following steps in some form:

  • –  Establishing the context

  • –  Identifying risks

  • –  Assessing risks

  • –  Evaluating risks in light of context

  • –  Identifying and implementing appropriate control measures

  • –  Monitoring

  • –  Record keeping

  • –  Communication with stakeholders, and

  • –  Regular review

Risk management frameworks that water suppliers may be familiar with, and would be appropriate for adoption in the context of managing fluoridation risks, include:

  • –  HAZard and OPerability analysis (HAZOP)

  • –  Hazard Analysis and Critical Control Point (HACCP) principles

  • –  The 12 risk management principles (also known as ‘the 12 elements’) discussed

in the Australian Drinking Water Guidelines 2011

  • –  The risk management methodology detailed in ISO 31000 – Risk Management

and Principles

Site-specific risk assessments for both workplace health and safety risks as well as fluoride dosing risks should actively involve the design team, the water supplier and (if applicable) the reticulation system manager. Involving a cross section of staff will help ensure the resulting risk management system is relevant and understood by those staff involved in water fluoridation activities.

Where risks are identified, appropriate control measures should be identified, implemented and monitored. Control measures should be based on the hierarchy of controls. That is, wherever possible hazards should be eliminated. If elimination is not possible, hazards should be controlled using substitution, isolation or engineered control methods.