Pediatric Dentists, Children’s Health Advocates Sound Alarm Over EPA’s Inadequate Fluoride Assessment Plan

American Academy of Pediatric Dentistry warns that the current methodology could erode decades of advancement in children’s oral health and urges immediate reconsideration

The American Academy of Pediatric Dentistry (AAPD), representing over 11,000 pediatric dental specialists, has formally submitted comments on the Environmental Protection Agency’s (EPA) Fluoride Preliminary Assessment Plan and Literature Survey (Docket No. EPA-HQ-OW-2025-3823). The Academy warns that the EPA’s current trajectory relies on discredited reports and inapplicable information that threatens safe community water fluoridation, triggering a public health crisis for American children. The AAPD is joined by 140 state and national organizations in its concern over the EPA plan and its repercussions.

In a comprehensive comment letter addressed to the EPA, the AAPD expressed "significant concerns" regarding the scientific integrity of the EPA’s plan, arguing it fails to meet the Administration’s own "Gold Standard Science" requirements.

Key Concerns Raised by the AAPD:

• Misclassifying "Mild Fluorosis" as Toxicity Indicator: The AAPD strongly objects to the EPA considering mild dental fluorosis – a purely cosmetic condition – as a "toxic" or "adverse" effect of safe water fluoridation. "Mild fluorosis has no deleterious or pathologic qualities," the letter states, noting that it often correlates with lower rates of tooth decay.
• Reliance on a Flawed Report: The Assessment Plan relies heavily on the 2024 National Toxicology Program (NTP) report despite its failed attempts at passing peer review with the National Academies of Sciences, Engineering, and Medicine (NASEM). The majority of the NTP report’s underlying studies were not conducted in the U.S. and do not reflect U.S. community water fluoridation exposure levels. The NTP report authors cautioned against using the report to set a recommended fluoride dose, yet EPA relies on the report for its planned assessment.
• Ignoring Health Benefits: The EPA explicitly stated they would not consider health benefits of fluoride in its assessment. The AAPD strongly disagrees with this approach and states that deriving a toxicity review conducted in a vacuum without a cost-benefit analysis or risk-benefit analysis is "irresponsible." The Academy points to historical data in other countries showing that when communities intentionally remove fluoride from water, children experience increases in dental pain, infection, and missed school days.
• Methodological Red Flags: The AAPD highlighted several problematic shortcomings in the planned assessment, including an outdated literature search that excludes 2025 studies and the absence of a transparent, pre-specified systematic review protocol.

"If this assessment is not conducted with scientific integrity, children will experience more dental pain, infection, and lower quality of life” due to tooth decay, the nation’s leading chronic childhood disease, the Academy stated. "The result of this deeply flawed plan points toward a de-fluoridation of water supplies that would undoubtedly lead to a surge in dental caries and healthcare costs."

A Call for Independent Review

The AAPD urges the EPA to pause its current process and engage an independent external reviewer—specifically the National Academies of Sciences, Engineering, and Medicine (NASEM)—to ensure a fair and scientifically sound assessment is conducted.

The Academy and its partners recognize optimally fluoridated drinking water as one of the most successful public health interventions in U.S. history. Our communities have benefited from safe and effective community water fluoridation for over 80 years, and it remains a cornerstone in preventing dental caries: the most common chronic disease among children. Together our organizations caution EPA and HHS from proceeding with the proposed plan, and we commit to continuing our work to protect and promote children’s oral and overall health.

Official Press Release      Comment Letter to EPA

Concerned Partners

• American Academy of Pediatric Dentistry
• Academy of General Dentistry
• Access Ready Inc.
• Alaska Academy of Pediatric Dentistry
• Alcan Dental Cooperative
• American Academy of Oral & Maxillofacial Pathology
• American Academy of Oral Medicine
• American Academy of Orofacial Pain
• American Academy of Pediatrics California Chapter 1
• American Academy of Pediatrics, California Chapter 3
• American Academy of Pediatrics, California Chapter 4
• American Academy of Pediatrics, DC Chapter
• American Academy of Periodontology
• American Association for Dental, Oral, and Craniofacial Research
• American Association of Endodontists
• American Association of Orthodontists
• American Association of Public Health Dentistry
• American College of Prosthodontists
• American Dental Association
• American Dental Hygienists' Association
• American Fluoridation Society, Inc.
• American Institute on Disparities in Public Health
• American Network of Oral Health Coalitions
• American Public Health Association Oral Health Section
• American Society of Dentist Anesthesiologists
• American Student Dental Association
• Arcora Foundation
• Arizona Academy of Pediatric Dentistry
• Arizona Dental Association
• Arizona Oral Health Coalition
• Arkansas Society of Pediatric Dentists
• Arkansas State Dental Association
• California Dental Association
• California Pan-Ethnic Health Network
• California School-Based Health Alliance
• California Society of Pediatric Dentistry
• Children Now
• Children's Oral Health Network of Maine
• Coalition of Texans with Disabilities
• Colorado Academy of Pediatric Dentistry
• Connecticut Oral Health Initiative
• Connecticut Society of Pediatric Dentists
• Connecticut State Dental Association
• Delaware Academy of Pediatric Dentistry
• Dental Trade Alliance
• Elevate Oral Care
• Florida Academy of Pediatric Dentistry
• Florida Chapter of the American Academy of Pediatrics
• Florida Dental Association
• Foundation for Health Leadership and Innovation's North Carolina Oral Health Collaborative
• Georgia Academy of Pediatric Dentistry
• Gerontological Society of America
• Hawaii Dental Association
• Idaho Chapter of the American Academy of Pediatrics
• Idaho State Dental Association
• Illinois Chapter, American Academy of Pediatrics
• Illinois Oral Health Coalition
• Illinois Society of Pediatric Dentists
• Indiana Dental Association
• Indiana Oral Health Coalition
• International Association of Paediatric Dentistry
• Iowa Academy of Pediatric Dentistry
• Iowa Dental Association
• Justice in Aging
• Kansas Chapter, American Academy of Pediatrics
• Kentucky Academy of Pediatric Dentistry
• Knox County Dental
• Louisiana Academy of Pediatric Dentistry
• Louisiana Dental Association
• Maine Chapter, American Academy of Pediatrics
• Maine Dental Association
• Maine Primary Care Association
• Maine Society of Pediatric Dentistry
• Maryland Academy of Pediatric Dentistry
• Maryland Dental Action Coalition
• Maryland State Dental Association
• Massachusetts Chapter, American Academy of Pediatrics, Inc.
• Michigan Dental Association
• Michigan Dental Hygienists' Association
• Michigan Oral Health Coalition
• Minnesota Academy of Pediatric Dentistry
• Minnesota Chapter, American Academy of Pediatrics
• Minnesota Dental Association
• Minnesota Dental Therapy Association
• Mississippi Academy of Pediatric Dentistry
• Mississippi Chapter of the American Academy of Pediatrics
• Mississippi Dental Association
• Missouri Academy of Pediatric Dentistry
• Missouri Coalition for Oral Health
• Montana Chapter of the American Academy of Pediatrics
• National Association of Pediatric Nurse Practitioners
• National Dental Association
• National Network for Oral Health Access
• Nebraska Dental Association
• Nebraska Society of Pediatric Dentistry
• Nevada Academy of Pediatric Dentistry
• Nevada Dental Association
• New Hampshire Academy of Pediatric Dentistry
• New Hampshire Chapter of American Academy of Pediatrics
• New Jersey Academy of Pediatric Dentistry
• New Jersey Oral Health Coalition
• New Mexico Academy of Pediatric Dentistry
• New York Academy of Pediatric Dentistry
• North Carolina Dental Society
• North Central Society of Pediatric Dentistry
• Northern Virginia Dental Society
• Ohio Academy of Pediatric Dentistry
• Ohio Chapter, American Academy of Pediatrics
• Ohio Dental Association
• Oklahoma Academy of Pediatric Dentistry
• Oklahoma Chapter of the American Academy of Pediatrics
• Oral Health Coalition of Alabama
• Oral Health Kansas, Inc.
• Oral Health Ohio
• Oregon Academy of Pediatric Dentistry
• Pacific Northwest University of Health Sciences - School of Dental Medicine
• Pennsylvania Academy of Pediatric Dentistry
• Pennsylvania Chapter, American Academy of Pediatrics
• Pennsylvania Coalition for Oral Health
• Pennsylvania Dental Hygienists' Association
• Pennsylvania Rural Health Association
• Rhode Island Dental Association
• Santa Fe Group
• Sjogren's Foundation, Inc.
• Smiles for Life
• South Carolina Chapter of the American Academy of Pediatrics
• South Dakota Dental Association
• South Dakota Society of Pediatric Dentistry
• Southeastern Society of Pediatric Dentistry
• Tennessee Academy of Pediatric Dentistry
• Tennessee Dental Association
• Texas Academy of Pediatric Dentistry
• Texas Pediatric Society
• University of Texas School of Dentistry at Houston
• Utah Academy of Pediatric Dentistry
• Utah Chapter of the American Academy of Pediatrics
• Vermont Environmental Justice Network
• Vermont State Dental Society
• Virginia Academy of Pediatric Dentistry
• Virginia Health Catalyst
• VOICES for Alabama's Children
• Washington State Academy of Pediatric Dentistry
• Washington State Dental Association
• Washington State Oral Health Coalition
• Western Society of Pediatric Dentistry
• West Virginia Chapter, American Academy of Pediatrics
• West Virginia Dental Hygienists' Association
• West Virginia Oral Health Coalition, Inc
• Wisconsin Academy of Pediatric Dentistry
• Wisconsin Chapter of the American Academy of Pediatrics
• Wisconsin Dental Association
• Wyoming Dental Association