The association has raised concerns about the agency’s reliance on existing conclusions for its accelerated assessment of fluoride in drinking water.
The American Dental Association (ADA) is urging the Environmental Protection Agency (EPA) to improve the protocols for its accelerated review of the potential health effects of fluoride in drinking water, according to a February 25 letter sent to the agency.
In the letter, ADA president Richard Rosato, DMD, and interim executive director Elizabeth Shapiro, DDS, raised concerns about the EPA’s proposed methodology and its plan to rely on certain “consensus hazard conclusions.”
“Relying on such documents as ‘consensus hazard conclusions’ without questioning or challenging the findings is a clear violation of the administration’s Gold Standard Science tenets,” the ADA wrote.
Concerns Over Proposed Methodology
According to ADA News, the association specifically questioned the EPA’s decision to use conclusions from assessments by other entities, such as the National Toxicology Program, the European Food Safety Authority, and Health Canada, rather than conducting a new review of the primary literature.
The letter points out that the EPA’s own legal arguments have previously described a report from the National Toxicology Program as “incomplete and not reflective of the best available science.”
The ADA’s comments are in response to a January 22 EPA announcement that it would begin a “fast-track effort” to study potential health effects of fluoride exposure on childhood development.
Recommendations for the Assessment
Rosato and Shapiro outlined several recommendations for the EPA’s fluoride assessment. The ADA urged the agency to:
- Re-review the literature that forms the basis of the cited consensus documents.
- Include studies that question or refute associations between fluoride and neurodevelopmental effects.
- Differentiate between mild and severe dental fluorosis.
- Incorporate additional subject-matter expertise, including a clinical psychologist or psychometrician with experience in pediatric IQ testing.
The association also recommended that the EPA engage the National Academies of Sciences, Engineering, and Medicine to conduct an independent peer review of the final report.
The letter notes that community water fluoridation has been practiced in the US for more than 75 years and is recognized by the Centers for Disease Control and Prevention as a major public health achievement.
“As a matter of scientific integrity, we note that routine exposure to fluoride concentrations over 1.5 mg/L are not germane to conversations about community water fluoridation in the United States,” Rosato and Shapiro wrote. The ADA has previously noted that U.S. public water systems fluoride optimal level is 0.7 mg/L.
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