At the end of January the Environmental Protection Agency (EPA) announced that it is undertaking an “accelerated review of public health risks from fluoride in drinking water.” EPA Administrator, Lee Zeldin, promised this action last year after our victory in federal court, the publication of the National Toxicology Program’s review on fluoride neurotoxicity, and Utah passing the first statewide law banning fluoridation. Zeldin has since promised to “expedite EPA’s next fluoride health assessment under the Safe Drinking Water Act schedule, while adhering to gold-standard scientific methods and radical transparency.”

The EPA also released a preliminary assessment on fluoride’s toxicity, outlining its plans to evaluate potential harms, including brain development, children’s IQ, and dental fluorosis. FAN published a bulletin providing additional details about the EPA’s landmark announcement, which you can find here.

As part of this process, the EPA has been collecting public comments about their review. Yesterday, FAN’s attorneys submitted our comment to the EPA. You can read it here.

Our comments focus on ensuring that a major flaw in past EPA risk assessments of fluoridation weren’t repeated. As attorney Michael Connett wrote in our comment:

“It is particularly critical that EPA adhere to its published procedures on selection of uncertainty factors (‘UF’)…Per EPA procedure, the default UF of 10 should be used unless there is suitable toxicokinetic and/or toxicodynamic data to justify a deviation.” – Michael Connett, esq

FAN implores the EPA to follow its established procedures for selecting uncertainty factors (UF), and that it do so in a clear and transparent way so that the public can be assured that the RfD is based solely on risk-related principles, and not based on policy concerns related to fluoridation. Per EPA procedure, the default UF of 10 should be used unless there is suitable toxicokinetic and/or toxicodynamic data to justify a deviation.

For studies finding IQ loss at a certain level of exposure, the standard risk assessment approach that EPA normally uses is to divide the level of exposure where studies find harm by 10 to reach a level low enough to prevent harm to more sensitive members of a population. An uncertainty factor of ten, which is appropriate for all life stages, inclusive of all life stages and vulnerabilities should be the benchmark margin of exposure. This is based on the finding that for any toxic substance, a few percent of people will typically be at least 10-times more sensitive than the average person. A dose that is 10-times less than what causes harm in average sensitivity people will cause harm in more sensitive people. EPA considers this a “protective approach” because it must protect all people, not just people of average susceptibility to any particular toxic chemical. 

It is generally accepted, even by the dental lobby, that there is evidence of fluoride’s neurotoxic effects at 1.5ppm in water. If EPA were to enact fluoride regulations consistent with how it regulates other toxic chemicals, EPA should be using at least a 10x safety factor to account for sensitive subpopulations exposed to fluoride in water.

1.5ppm fluoride in water (observed effect) divided by 10 (MoE, safety factor) = 0.15ppm safe level of fluoride in water.

We will be providing more updates and analysis. Stay tuned!