13 March 2026

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AAPD Challenges EPA Fluoride Assessment Plan

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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, potentially 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 that it fails to meet the Administration’s own “Gold Standard Science” requirements.

Key Concerns Raised by the AAPD:

• Misclassifying “Mild Fluorosis” as a 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 to pass 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 the EPA relies on the report for its planned assessment.
• Ignoring Health Benefits: The EPA explicitly stated that it would not consider the 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 or risk-benefit analysis, is “irresponsible.” The Academy points to historical data from 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 health care 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 that 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 the EPA and HHS against proceeding with the proposed plan, and we commit to continuing our work to protect and promote children’s oral and overall health.

About the AAPD

The American Academy of Pediatric Dentistry (AAPD) is the recognized authority on children’s oral health. Founded in 1947, the AAPD is a not-for-profit professional membership association representing the specialty of pediatric dentistry. Its over 11,000 members provide primary care and comprehensive dental specialty treatment for infants, children, adolescents, and individuals with special health care needs. As advocates for the optimal oral health of all children, the AAPD promotes evidence-based policies, best practices, and clinical guidelines; educates and informs policymakers, parents and guardians, and other health care professionals; supports research; and provides continuing professional education for pediatric dentists and general dentists who treat children. Visit the AAPD website at www.aapd.org or the AAPD’s consumer website at www.mychildrensteeth.org for more from the BIG Authority on little teeth.

Source: https://www.aapd.org/