A broad coalition of more than 140 dental and children's health organizations has formally objected to the Environmental Protection Agency's plan for reassessing fluoride in drinking water, warning that methodological flaws in the agency's approach could undermine community water fluoridation — a public health intervention that has been in place for more than 80 years.

The American Academy of Pediatric Dentistry (AAPD) led the effort, submitting formal comments to the EPA's docket (No. EPA-HQ-OW-2025-3823) on the agency's Fluoride Preliminary Assessment Plan and Literature Survey. The letter draws a direct line between a deficient assessment process and a predictable downstream outcome: more tooth decay, more childhood dental pain, and higher public health costs.

The EPA is conducting a toxicological reassessment of fluoride in public water systems, a process that could ultimately result in lowered acceptable fluoride concentrations or policy changes affecting community water fluoridation nationwide. The AAPD's objection is not to the concept of periodic review, but to the scientific framework the agency is currently using to conduct it.

The coalition's central complaints fall into four categories.

Misclassifying cosmetic effects as toxicity. The EPA's assessment plan reportedly treats mild dental fluorosis as an adverse health outcome — a classification the AAPD strongly contests. Mild fluorosis, which produces faint white markings on tooth enamel, is considered a cosmetic variation with no clinical pathology and no functional impairment. Critics argue that treating it as a toxicity indicator inflates the apparent risk profile of fluoridated water without scientific justification.

Relying on a report that failed peer review. The assessment leans heavily on a 2024 National Toxicology Program (NTP) report that the National Academies of Sciences, Engineering, and Medicine (NASEM) declined to validate through its peer review process. The AAPD notes that the majority of studies underlying the NTP report were conducted outside the United States and do not reflect fluoride exposure levels found in American municipal water systems. Critically, the NTP report's own authors cautioned against using it to set recommended fluoride dosages — a caveat the EPA appears to have disregarded.

Excluding health benefits from the analysis. The EPA has stated explicitly that it will not weigh the health benefits of fluoride in its assessment. The AAPD calls this "irresponsible," arguing that any meaningful toxicological review should include a risk-benefit analysis. The coalition points to international evidence showing that communities which have intentionally removed fluoride from water supplies subsequently experienced measurable increases in childhood dental disease, missed school days, and emergency care utilization.

Methodological gaps. The AAPD also flagged that the EPA's literature search is already outdated, excluding studies published in 2025, and that the agency has not published a pre-specified systematic review protocol — a basic requirement for transparent, reproducible scientific review.

The breadth of organizational sign-ons is notable. The letter carries support from the American Dental Association, the American Dental Hygienists' Association, the Academy of General Dentistry, the American Association of Endodontists, the American College of Prosthodontists, and dozens of state dental associations representing virtually every region of the country. The American Academy of Pediatrics chapters from more than 20 states also joined, as did public health organizations, rural health associations, and disability advocacy groups.

The coalition's geographic and disciplinary diversity makes this more than a professional turf defense. It represents a near-consensus view within organized dentistry that the EPA's current methodology does not meet the scientific standards required for a decision with this magnitude of public health consequence.

The AAPD is urging the EPA to pause its current assessment process and refer the matter to NASEM for independent external review — the same body the agency bypassed when it leaned on the NTP report. The request is procedurally straightforward: apply the same "Gold Standard Science" standards the current administration has publicly championed to the fluoride assessment itself.

"If this assessment is not conducted with scientific integrity, children will experience more dental pain, infection, and lower quality of life," the AAPD stated in its letter.

Community water fluoridation was first introduced in the United States in 1945 and is widely regarded as one of the most cost-effective public health interventions ever implemented. The CDC has listed it among the ten great public health achievements of the 20th century. Current EPA maximum contaminant level goals and the U.S. Public Health Service's recommended concentration of 0.7 mg/L are the product of decades of research and periodic review.

The current reassessment is proceeding against a political backdrop in which fluoride skepticism has gained unusual visibility. Former presidential candidate Robert F. Kennedy Jr., now serving as Secretary of Health and Human Services, has publicly advocated for removing fluoride from public water supplies — a position that sits well outside the scientific mainstream but has given the issue renewed regulatory momentum.

The dental profession's response has been swift and unified. Whether the EPA adjusts its methodology in response to the coalition's comments remains to be seen, but the formal record is now clearly populated with objections from some of the most credentialed voices in children's health.