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 ReviewThe 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 PartnersAmerican Academy of Pediatric DentistryAcademy of General DentistryAccess Ready Inc.Alaska Academy of Pediatric DentistryAlcan Dental CooperativeAmerican Academy of Oral & Maxillofacial PathologyAmerican Academy of Oral MedicineAmerican Academy of Orofacial PainAmerican Academy of Pediatrics California Chapter 1American Academy of Pediatrics, California Chapter 3American Academy of Pediatrics, California Chapter 4American Academy of Pediatrics, DC ChapterAmerican Academy of PeriodontologyAmerican Association for Dental, Oral, and Craniofacial ResearchAmerican Association of EndodontistsAmerican Association of Public Health DentistryAmerican College of ProsthodontistsAmerican Dental AssociationAmerican Dental Hygienists’ AssociationAmerican Fluoridation Society, Inc.American Institute on Disparities in Public HealthAmerican Network of Oral Health CoalitionsAmerican Public Health Association Oral Health SectionAmerican Society of Dentist AnesthesiologistsAmerican Student Dental AssociationArcora FoundationArizona Academy of Pediatric DentistryArizona Dental AssociationArizona Oral Health CoalitionArkansas Society of Pediatric DentistsArkansas State Dental AssociationCalifornia Dental AssociationCalifornia Pan-Ethnic Health NetworkCalifornia School-Based Health AllianceCalifornia Society of Pediatric DentistryChildren NowChildren’s Oral Health Network of MaineCoalition of Texans with DisabilitiesColorado Academy of Pediatric DentistryConnecticut Oral Health InitiativeConnecticut Society of Pediatric DentistsConnecticut State Dental AssociationDelaware Academy of Pediatric DentistryDental Trade AllianceElevate Oral CareFlorida Academy of Pediatric DentistryFlorida Chapter of the American Academy of PediatricsFlorida Dental AssociationFoundation for Health Leadership and Innovation’s North Carolina Oral Health CollaborativeGeorgia Academy of Pediatric DentistryGerontological Society of AmericaHawaii Dental AssociationIdaho Chapter of the American Academy of PediatricsIdaho State Dental AssociationIllinois Chapter, American Academy of PediatricsIllinois Oral Health CoalitionIllinois Society of Pediatric DentistsIndiana Dental AssociationIndiana Oral Health CoalitionInternational Association of Paediatric DentistryIowa Academy of Pediatric DentistryIowa Dental AssociationJustice in AgingKansas Chapter, American Academy of PediatricsKentucky Academy of Pediatric DentistryKnox County DentalLouisiana Academy of Pediatric DentistryLouisiana Dental AssociationMaine Chapter, American Academy of PediatricsMaine Dental AssociationMaine Primary Care AssociationMaine Society of Pediatric DentistryMaryland Academy of Pediatric DentistryMaryland Dental Action CoalitionMaryland State Dental AssociationMassachusetts Chapter, American Academy of Pediatrics, Inc.Michigan Dental AssociationMichigan Dental Hygienists’ AssociationMichigan Oral Health CoalitionMinnesota Academy of Pediatric DentistryMinnesota Chapter, American Academy of PediatricsMinnesota Dental AssociationMinnesota Dental Therapy AssociationMississippi Academy of Pediatric DentistryMississippi Chapter of the American Academy of PediatricsMississippi Dental AssociationMissouri Academy of Pediatric DentistryMissouri Coalition for Oral HealthMontana Chapter of the American Academy of PediatricsNational Association of Pediatric Nurse PractitionersNational Dental AssociationNational Network for Oral Health AccessNebraska Dental AssociationNebraska Society of Pediatric DentistryNevada Academy of Pediatric DentistryNevada Dental AssociationNew Hampshire Academy of Pediatric DentistryNew Hampshire Chapter of American Academy of PediatricsNew Jersey Academy of Pediatric DentistryNew Jersey Oral Health CoalitionNew Mexico Academy of Pediatric DentistryNew York Academy of Pediatric DentistryNorth Carolina Dental SocietyNorth Central Society of Pediatric DentistryNorthern Virginia Dental SocietyOhio Academy of Pediatric DentistryOhio Chapter, American Academy of PediatricsOhio Dental AssociationOklahoma Academy of Pediatric DentistryOral Health Coalition of AlabamaOral Health Kansas, Inc.Oral Health OhioOregon Academy of Pediatric DentistryPacific Northwest University of Health Sciences – School of Dental MedicinePennsylvania Chapter, American Academy of PediatricsPennsylvania Coalition for Oral HealthPennsylvania Dental Hygienists’ AssociationPennsylvania Rural Health AssociationRhode Island Dental AssociationSanta Fe GroupSmiles for LifeSouth Carolina Chapter of the American Academy of PediatricsSouth Dakota Dental AssociationSouth Dakota Society of Pediatric DentistrySoutheastern Society of Pediatric DentistryTennessee Academy of Pediatric DentistryTennessee Dental AssociationTexas Academy of Pediatric DentistryTexas Pediatric SocietyUniversity of Texas School of Dentistry at HoustonUtah Academy of Pediatric DentistryUtah Chapter of the American Academy of PediatricsVermont Environmental Justice NetworkVermont State Dental SocietyVirginia Academy of Pediatric DentistryVirginia Health CatalystVOICES for Alabama’s ChildrenWashington State Academy of Pediatric DentistryWashington State Dental AssociationWashington State Oral Health CoalitionWestern Society of Pediatric DentistryWest Virginia Chapter, American Academy of PediatricsWest Virginia Dental Hygienists’ AssociationWest Virginia Oral Health Coalition, IncWisconsin Academy of Pediatric DentistryWisconsin Chapter of the American Academy of PediatricsWisconsin 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.SOURCE American Academy of Pediatric Dentistry
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