Fluoride Action Network

The National Toxicology Program

This section is dedicated to the National Toxicology Program’s (NTP) long involvement with the issue of fluoride's toxicity. The NTP is the scientific research arm for U.S. regulatory agencies. It comes under the aegis of the National Institute of Environmental Health Sciences (NIEHS). The NIEHS, in turn, comes under the umbrella of the National Institutes of Health (NIH).

NTP and NASEM: February 9, 2021, a date that won’t be forgotten.

The NTP has a long and complex involvement with fluoride that began in the late 1970s. At that time the U.S. Congress requested that they perform a study to determine if fluoride was a carcinogen. The NTP contracted out two animal studies with the results published in 1990. The findings created an enormous stir as EPA’s chief toxicologist, William Marcus, expressed concerns about the “systematic downgrading” of cancers in the published study.

In 2016 the NTP began a systematic review of fluoride’s neurotoxicity (called a monograph) at the request of the Fluoride Action Network.

The NTP spent three years on this monograph and then asked the National Academies of Sciences, Engineering and Medicine (NASEM) to peer review their work. NTP produced two draft reviews, which NASEM peer-reviewed.

Also, in 2016, a coalition of groups, including the Fluoride Action Network, petitioned the U.S. Envcironmenal Protection Agency to prohibit fluoridation chemicals used in water fluoridation schemes due to fluoride’s neurotoxicity under Section 21 of the Toxic Substances Control Act (TSCA).

In 2017, the EPA denied the citizens’ petition, and the groups took EPA to federal court. The “TSCA trial” was held in June 2020.

After the trial, the Court requested two documents before a decision can be made.

• The first was a Benchmark Dose (BMD) analysis of fluoride’s neurotoxicity. This became available on June 8, 2021, with the publication of Grandjean et al.’s analysis.

• The second was the NTP’s report on its systematic review of fluoride’s neurotoxicity. On February 9, 2021, the NTP, with no public announcement or explanation, ended its review.

Instead, the NTP will write a “state of the science” report which will be released “later in the year.”

The Court knows of this development, but still wants to read the report that NTP will produce.

The speculation is that fluoridation proponents within the NIH were responsible for stopping NTP’s systematic review of fluoride’s neurotoxicity. The concern is that they may also interfere in NTP’s forthcoming report.

February 9, 2021, a day that will be remembered by U.S. historians of fluoridation and public health:

NASEM’s peer-review of NTP’s second draft review of fluoride’s neurotoxicity was released on Feb 9:

NTP’s private statement in response to NASEM dated Feb 9:

“… the monograph cannot be used to draw conclusions regarding low fluoride exposure concentrations (less than 1.5 mg/mL), including those typically associated with drinking water fluoridation.”

“… We will carefully consider all of the committee’s comments as we finalize and publish the NTP Fluoride Monograph as a “state of the science” document later in 2021.”

NOTE: According to Chris Neurath, FAN’s science director,

FAN has demonstrated that with NTP’s own data, the high-quality studies finding loss of IQ at exposures below 1.5 mg/L are just as consistent and numerous as those above 1.5 mg/L.  Over 90% of the low-dose studies found loss of IQ.

NOTE: The “state of the science” document will have no regulatory teeth and will draw no conclusions.

Up to February 9, 2021, the following four were the major players involved in fluoride’s neurotoxicity:

1. The National Toxicology Program

The NTP spent four years performing a systematic review of fluoride’s neurotoxicity, also referred to as a monograph.

The overall objective of this evaluation is to undertake a systematic review to develop NTP hazard identification conclusions on the association between exposure to fluoride and neurodevelopmental and cognitive effects ….” [NTP 2020, p 4]

Their first two draft reviews were released in 2019 and 2020. Both drafts contained the following,

“NTP concludes that fluoride is presumed to be
a cognitive neurodevelopmental hazard to humans.”

But on February 9, 2021, the NTP reversed course and stated in a private statement, not released to the press or to the public, that it would not complete its systematic review. Instead, NTP wrote that it would do a “state of the science” document on fluoride’s neurotoxicity. The Fluoride Action Network learned of NTP’s private statement after lawyers representing the U.S. Environmental Protection Agency in the TSCA trial submitted it into the record on February 22, 2021. This submission led to a February 24, 2021, article in InsideEPA which noted that this document would not include conclusions, thus it will have no “teeth” compared to a systematic review.

For more see, National Toxicology Program: Cowed by dental interests? by Fluoride Action Network, April 19, 2021


2. The National Academies of Sciences, Engineering and Medicine

The NASEM were the peer-reviewers of NTP’s reviews – see 2020, 2021. They issued their second draft review on February 9th, 2021, the same day the NTP ended its systematic review of fluoride’s neurotoxicity. NASEM used two groups of peer reviewers,

•The NASEM committee to peer review NTP’s monograph; and
•A second set of peer reviewers to peer review the NASEM committee’s reports.


3. The U.S. Environmental Protection Agency

The EPA regulates the allowable levels of contaminants in drinking water, under the enforceable MCL (Maximum Contaminant Level). They are mandated under the Safe Drinking Water Act (SDWA) to ensure that drinking water is safe to drink. The SDWA applies to every public water system in the United States. The EPA has never performed an assessment 0f the risks that fluoride poses to pregnant women, the fetus, and bottle-fed infants living in fluoridated communities. EPA is currently in federal court in a trial due to a 2016 Citizens’ Petition made under Section 21 of the Toxic Substances Control Act. The Petition requests EPA to prohibit the purposeful addition of fluoridation chemicals to U.S. water supplies due to fluoride’s neurotoxicity at doses within the range now seen in fluoridated communities.


4. The Trial under the Toxics Substances Control Act

The purpose of the TSCA trial, which is still ongoing, is to ban the purposeful addition of fluoridation chemicals into America’s drinking water due to fluoride’s neurotoxicity. A 2016 Citizens’ Petition to the U.S. EPA initiated the trial.  After a 7-day trial in Federal Court took place in June 2020 the Judge requested both sides to fulfill certain requests, which included the outcome of NTP’s systematic review of fluoride’s neurotoxicity. On February 9, 2021, the NTP ended its systematic review without any explanation to the public. They said they will produce a “state of the science” document, that will have no conclusions. The court knows of this because this document was entered into the trial. The Court will wait until the NTP releases its report.


After February 9, 2021?

The only avenue today to have the U.S. EPA respond to the potential of the lowering of the IQs of millions of American children is underway in the TSCA trial.

Currently no U.S. federal agency is concerned about the science of  this issue, including the four recent studies —Till et al. (2020), Green et al. (2019), Bashash et al. (2017), Bashash et al. (2018) that reveal fluoride’s potential, at the level introduced into America’s drinking water via drinking water fluoridation schemes, to harm the brains of our children.  The only hope today is the action by citizen groups that brought forward the lawsuit against the EPA under the Toxic Substances Control Act.

June 30, 2021.


Documents

Date Report
Feb 9, 2021 NAS: Second peer-review of the revised Draft NTP Monograph on the Systematic Review of Fluoride Exposure and Neurodevelopmental and Cognitive Health Effects: A Letter Report.
LINK: http://fluoridealert.org/wp-content/uploads/2021.nas-review-of-ntp-second-draft.feb-9.pdf
Feb 9, 2021 NTP: Private statement on ending its systematic review on fluoride’s neurotoxicity to converting this four-year effort into a “state of the science” document. The difference: a systematic review comes to a conclusion on whether the substance is a hazard, whereas a “state of the science” report does not. If NTP finds a substance is a hazard, the EPA would be mandated to perform a risk assessment, whereas with a “state of the science” report, the EPA doesn’t have to do anything.
LINK: http://fluoridealert.org/wp-content/uploads/niehs-ntp.statement.feb-9.2021.ocr_.pdf
Sept 16, 2020 NTP: Revised Draft Monograph on the Systematic Review of Fluoride Exposure and Neurodevelopmental and Cognitive Health Effects.
LINK: http://fluoridealert.org/wp-content/uploads/ntp.revised-monograph.9-16-2020.pdf
March 5, 2020 NAS: First peer review of the Draft NTP Monograph on the Systematic Review of Fluoride Exposure and Neurodevelopmental and Cognitive Health Effects.
Sept 6, 2019 NTP: First Draft NTP Monograph on the Systematic Review of Fluoride Exposure and Neurodevelopmental and Cognitive Health Effects.

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