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

CHICAGO, Feb. 27, 2026 /PRNewswire/ -- 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.

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 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

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 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

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

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 treatments 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.

View original content to download multimedia:https://www.prnewswire.com/news-releases/pediatric-dentists-childrens-health-advocates-sound-alarm-over-epas-inadequate-fluoride-assessment-plan-302699675.html

SOURCE American Academy of Pediatric Dentistry