ADA calls for ‘deliberative approach’ in EPA fluoride review

Association submits additional studies following federal appeals court decision on EPA fluoride case

The ADA is urging the Environmental Protection Agency to take what it called a more “deliberative approach” in its ongoing Human Health Toxicity Assessment for fluoride and to include additional scientific literature in its review process.

In a May 28 letter to the EPA’s Office of Water, the ADA requested that several recently published studies examining fluoride exposure, cognition and community water fluoridation be incorporated into the agency’s systematic literature review for the assessment.

The letter, signed by ADA President Richard Rosato, D.M.D., and Executive Director Nader Nadershahi, D.D.S., follows a May 21 decision by the U.S. Court of Appeals for the Ninth Circuit overturning a lower court ruling that had directed the EPA to “engage with a regulatory response” after the agency denied a citizen petition seeking to prohibit fluoridation chemicals in U.S. water supplies.

The Association said the lower court ruling had been one reason EPA chose to expedite a Human Health Toxicity Assessment for water fluoridation, “with an emphasis on neurodevelopment and dental fluorosis.”

“With the lower court’s order now vacated, EPA is no longer operating under that court-imposed rationale for expediting the [Human Health Toxicity Assessment],” the letter said. “We urge EPA to take a more deliberate approach to conducting the systematic review associated with its development.”

The ADA submitted several studies for consideration, including research published in the Journal of the American Dental Association, Science Advances and the Proceedings of the National Academy of Sciences.

“Several of these studies do not support an association between drinking water fluoridated at recommended levels and neurodevelopment outcomes, even when other sources of fluoride are readily available,” according to the letter.

The Association also noted that one study reported findings that IQ scores increase with fluoride exposure. The letter emphasized the public health implications of the EPA review and reiterated the ADA’s longstanding support for community water fluoridation at recommended levels.

“For over 80 years, community water fluoridation has been a safe and inexpensive way to reduce tooth decay in children and adults by at least 25 percent,” the ADA wrote, adding that the Centers for Disease Control and Prevention “hailed it as one of ten great public health achievements of the 20th century.”

The ADA urged the EPA to ensure the review reflects the full body of evidence and recommended several steps, including incorporating studies that question associations between fluoride and neurodevelopmental effects, reassessing the strength of literature identified in consensus documents, and involving experts qualified to evaluate IQ testing methodologies.

The Association also recommended distinguishing between mild and moderate dental fluorosis, which it described as “essentially cosmetic,” and severe dental fluorosis, “which rarely occurs in areas where community water systems are fluoridated.”
Additionally, the ADA called on the EPA to enlist the National Academies of Sciences, Engineering, and Medicine to conduct an independent peer review of the final report.

The ADA’s latest communication to the EPA follows the Association’s support for the Ninth Circuit’s recent decision overturning the lower court judgment in the fluoride case. Following the ruling, ADA President Richard Rosato, D.M.D., said the appellate court recognized that the lower court “improperly overstepped its role” and relied on materials not presented by either party.

The ADA has consistently maintained that community water fluoridation at recommended levels is safe and effective in preventing tooth decay and has said it will continue working with the EPA to provide scientific evidence regarding fluoridation’s safety and efficacy.

“The ADA welcomes the opportunity to assist the EPA with its review of scientific information, which includes sharing the best available scientific literature examining the safety of fluoride in drinking water,” the letter concluded.