The Academy of General Dentistry (AGD), representing approximately 40,000 general dentists nationwide, has formally submitted comments to the Honorable Lee Zeldin, Administrator of the United States Environmental Protection Agency (EPA) regarding the agency’s proposed Fluoride Preliminary Assessment Plan and Literature Survey.

As the largest dental organization exclusively representing general dentists, AGD:

• Emphasized the importance of grounding the EPA’s literature review in high-quality, peer-reviewed scientific research.
• Urged the agency to prioritize studies published in reputable journals.
• And, to align its review standards with institutions such as the National Academies of Sciences, Engineering, and Medicine, widely recognized as the gold standard in scientific peer review.

AGD cautioned against overreliance on non-peer-reviewed research or studies conducted in foreign countries where fluoride exposure levels may significantly exceed the 0.7 mg/L standard followed by U.S. municipal water systems. The organization noted that several studies alleging neurocognitive harm involve fluoride concentrations well above those used in community water fluoridation programs in the United States.

AGD also referenced findings from the National Toxicology Program indicating that a substantial portion of reviewed studies were published in journals not indexed by the National Library of Medicine, raising concerns about scientific rigor and reliability.

Additionally, AGD encouraged EPA to carefully evaluate methodologies used to measure fluoride exposure, noting that certain approaches, such as urinary sampling, may present reliability limitations.

“The Academy of General Dentistry appreciates the opportunity to provide input on this important issue,” the organization stated in its letter. “A literature survey grounded in Gold Standard Science will continue to demonstrate that fluoride at levels used in U.S. community water systems does not produce negative neurocognitive effects.”